Finding Text
Finding No. 2023-005 - Uniform Guidance Compliance Requirement Code: N- Special Tests and Provisions - Significant Deficiency
CDBG Entitlement Grants Cluster
Federal Assistance Listing Number #14.218
Community Development Block Grants - Entitlement Grants Cluster Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau::
Allen Fremont 3110013 2015 2
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Clark County Community Services CDBG Procedures Manual and grant documents.
Condition
In connection with our lease file review, we noted two instances of seven tenants tested where management was unable to locate tenant files.
Cause
Management's policies with respect to eligibility and the maintenance of tenant lease files in accordance with Compliance in Clark County Community Services CDBG Procedures Manual and grant documents were not consistently followed.
Effect or Potential Effect
This could result in units being rented to ineligible tenants.
Questioned Costs: N/A.
Context
In connection with the procedures applied to our CDBG units testing, two of the seven tenants tested did have lease files available.
Repeat Finding: No
Recommendation
Management should establish procedures and monitor compliance with those procedures to ensure that 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 Clark County Community Services CDBG Procedures Manual and grant documents.
Views of Responsible Officials
The Compliance Specialist discovered missing files at a property while pulling files for the audit. The Compliance team worked to contact residents and rebuild the files with the missing documents. Compliance management investigated and determined the cause of the missing documents was due to a prior site manager not scanning and filing the appropriate documents, along with high staff turnover during this time. The Compliance team is finalizing a new procedure, in addition to the existing, to audit Yardi Voyager for uploaded completed files after move-in and recertification: the goal of this is to catch missing files and documents timely and hold site teams accountable for following the required procedures.