Finding 1208460 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-04-22
Audit: 399437
Organization: Victory Oaks, Inc. (MD)
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: Tenant lease files are not being maintained properly, leading to delays in using the EIV system and completing HUD Form 50059.
  • Impacted Requirements: Noncompliance with HUD Handbook 4350.3 could result in renting to ineligible tenants and incorrect rent subsidies.
  • Recommended Follow-Up: Management should implement and monitor procedures to ensure timely processing of tenant files and adherence to HUD guidelines.

Finding Text

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 the following deficiencies: 1 out of 9 tenants tested did not utilize the Enterprise Income Verification (EIV) system timely. 7 out of 9 tenants tested did not complete the HUD Form 50059 timely. Cause The Project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines. Effect or Potential Effect The procedures for determining tenant security deposits and eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs None Context A sample of 9 tenant files from a population of 47 were selected. We identified exceptions in 7 out of the 9 files tested. The sample in not a statistically valid sample. Identification as a Repeat Finding This finding is a repeat finding of prior year finding 2024-001. Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, 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: R - Section 8 program administration Finding Resolution Status: Resolved Views of Responsible Officials Management compliance is addressing the generating of EIV reports to align with verification dates (<120 days) rather than when annual recertification notices are generated/sent (at least 120 days). Delays in recertification completion have improved; a majority of the certifications reviewed were effective within first 6 months of transition while the site was still adjusting to new software and management. Additional training has been provided to emphasize the importance of timely reporting and completion.

Corrective Action Plan

a.Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 day time frame. b. Action(s) Taken or Planned on the Finding Management compliance is addressing the generating of EIV reports to align with verification dates (<120 days) rather than when annual recertification notices are generated/sent (at least 120 days). Delays in recertification completion have improved; a majority of the certifications reviewed were effective within first 6 months of transition while the site was still adjusting to new software and management. Additional training has been provided to emphasize the importance of timely reporting and completion.

Categories

HUD Housing Programs Eligibility

Other Findings in this Audit

  • 1208459 2025-001
    Material Weakness Repeat
  • 1208461 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $6.86M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $830,666