Finding Text
Finding No. 2023-002 - Uniform Guidance Compliance Requirement Code: E-Eligibility - Significant Deficiency
HUD HOME Investment Partnerships Program
Federal Assistance Listing Number #14.239
HOME Investment Partnership Program Entity Identifying Number Initial year Finding instances
Passed-through State of Washington:
Cascadia Village - HUD 02-40420-008 2002 1
Passed-through Clark County:
Covington Commons - HUD 2011-HOME-11H01 2011 1
McCallister Village (Fruit Valley) 2010-HOME-0H0 2010 1
Passed-through City of Vancouver:
McCallister Village (Fruit Valley) 2010-HOME-601002 2010 1
Total instances 4
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual.
Condition
In connection with our lease file review, we noted four instances of eight tenants tested where management did not provide support that they performed a 3rd party income verification in accordance with policy.
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual were not consistently followed.
Effect or Potential Effect
This could result in units being rented to ineligible tenants.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to our HOME units testing, four of the eight tenants tested did not have a 3rd party income verification performed in accordance with policy.
Repeat Finding: Yes - Finding 2022-002
Recommendation
Management should establish procedures and monitor compliance with those procedures to ensure that recertifications and correct income verification procedures are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual.
Views of Responsible Officials
For the properties in Washington, they have several sources of HOME funds based on the issuing jurisdiction State, County or City that adds a layer of complexity to the recertification process and due to staffing turnover, both at the properties and REACH main office some of the HOME third party income verifications were missed at recertification. Management has established policies and procedures for complying with the HOME program which includes a centralized tracker for HOME certifications.