Finding Text
Finding No. 2024-001; Federal Assistance Listing Number 14.157
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with
HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs.
Condition
In connection with our lease file review, we noted that three out of three tenants' income verification
was not performed timely with the use of the HUD Enterprise Income Verification ("EIV").
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of tenant
lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized
Multifamily Housing Programs were not consistently followed.
Effect or Potential Effect
The procedures for determining tenant recertification eligibility and maintaining tenant lease files
were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements
of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible
tenants or errors in the rent subsidies paid by HUD.
Questioned Costs
N/A
Context
Three out of three tenants tested did not have an EIV performed timely.
Identification as a Repeat Finding
Yes, 2023-001
Recommendation
Management should establish procedures and monitor compliance with those procedures to insure
that EIVs are performed timely, tenant eligibility is correctly determined and that tenant lease files
are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy
Requirements of Subsidized Multifamily Housing Programs.
Auditor Noncompliance Code: E - Eligibility for Uniform Guidance
Finding Resolution Status: Unresolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to complete certifications in a timely manner but due to staffing
shortages and tenant noncompliance issues the property continued to have issues with timely
completion of income certifications in 2024. As new staff are brought onboard training is provided
and annual HUD training is completed by all staff. Management will continue to coordinate and
provide assistance to on-site staff to ensure that the properties are in compliance.