Finding Text
Finding 2025-001: Reportable Finding Considered a Significant Deficiency - Eligibility Program name: Supportive Housing for Elderly Assistance Listing: 14.157 Federal award Identification number: 121-EE015 Federal award year: 2025 Federal awarding agency: U.S. Department of Housing and Urban Development (HUD) Criteria: The Project Rental Assistance Contract requires that rental subsidy claims be based on the HUD-approved contract rent for each unit. Under 2 CFR 200.403(a), costs must be “necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.” Condition: Two of seven units tested were billed at rates exceeding the HUD-approved contract rent, resulting in overcharges to the Federal program. Cause: Internal controls over compliance with program compliance requirements are not operating effectively. Effect or Potential Effect: Overbilling resulted in unallowable costs charged to the Federal award, which may require repayment and could affect future funding. Known Questioned Costs Known questioned costs total $52,780, calculated as the difference between the approved contract rent and the billed amount for all units overcharged. Repeat finding: This is not a repeat finding. Perspective: Our sample included 7 units out of a population of 50 units; 2 errors were noted, indicating a potential systemic issue. Recommendation: We recommend the Owner/Agent: 1) Implement a review process to verify billed subsidy amounts against the approved contract rent schedule; 2) Train staff on compliance with the Project Rental Assistance Contract and 2 CFR 200 cost principles; and 3) Reimburse the Federal program for identified overcharges. Management’s response and corrective action plan (unaudited): Management at SAHA PM notes its responsibility to establish and maintain effective internal control over financial reporting to provide reasonable assurance that transactions are properly recorded, processed, and summarized to permit the preparation of reliable financial statements in accordance with generally accepted accounting principles (“GAAP”). We plan to establish a checklist for the property accounting team that includes a comparison of gross rent potential to the HUD approved rent schedule.