Finding 1172867 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-02-09
Audit: 386273
Organization: Atwood Elder Housing, Inc. (MA)
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: The Corporation failed to timely obtain tenant signatures for recertification and did not send all required reminder notices.
  • Impacted Requirements: This non-compliance with federal guidelines could lead to ineligible tenants receiving assistance and incorrect payment calculations.
  • Recommended Follow-up: Management should enhance internal controls and monitoring of recertification processes to ensure compliance with eligibility requirements.

Finding Text

Name of Federal Agency: Department of Housing and Urban Development Federal Program Name and Assistance Listing Number: 14.157 Federal Award Identification Number and Year: Not available; Program year 2025 Name of Pass-through Entity (if applicable): N/A Criteria: In accordance with 4-14.157-4 of the Appendix XI to 2 CFR, Part 200 of the United States Office of Management and Budget, the Corporation must reexamine family income and composition at least once every 12 months and adjust the total rent payment and housing assistance payment as necessary (24 CFR section 891.410). The Corporation is responsible for annually examining incomes of households occupying assisted units and making appropriate adjustments. Condition: In a sample of 4 files tested, there was an exception noted in 1 file in which the Corporation did not obtain the tenant's signature for recertification timely. Additionally, the Corporation only sent 1 of the 3 required reminder notices to the tenant beginning at 120 days prior to their recertification anniversary date. Cause: The Corporation failed to follow the recertification process and procedures which have been established for determining tenant eligibility in accordance with federal guidelines. Effect or Potential Effect: The Corporation is not in compliance with federal regulations regarding eligibility. Failure to timely recertify tenants could result in approval of ineligible tenants and incorrect assistance payment calculations. Questioned Costs: N/A Context: A sample of 4 tenant files were selected. We identified exceptions in 1 out of 4 files tested. The sample was not statistically valid. Identification as a Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend that management reviews its internal controls over performing tenant recertification procedures to ensure compliance with eligibility requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility is done in accordance with guidelines specified by federal regulations. Views of Responsible Officials: Management agrees with the assessment and resulting finding. Corrective actions have been implemented to strengthen compliance controls, including calendar reminders for compliance team members, enhanced documentation in recertification checklists to clarify specific program requirements, and routine review of compliance expectations during monthly staff training and meetings. Management has also increased supervisory oversight and implemented periodic internal file audits to monitor adherence to recertification procedures and prevent future occurrences.

Corrective Action Plan

Atwood Elder Housing, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The finding from the October 31, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Federal Award Findings and Questioned Costs Finding 2025-001 - Eligibility - Significant Deficiency Recommendation: Management should review its internal controls over performing tenant recertification procedures to ensure compliance with eligibility requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility is done in accordance with guidelines specified by federal regulations. Action Taken: Management agrees with the assessment and resulting finding. Corrective actions have been implemented to strengthen compliance controls, including calendar reminders for compliance team members, enhanced documentation in recertification checklists to clarify specific program requirements, and routine review of compliance expectations during monthly staff training and meetings. Management has also increased supervisory oversight and implemented periodic internal file audits to monitor adherence to recertification procedures and prevent future occurrences.

Categories

Eligibility HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $217,825