Finding Text
Statement of Condition: The auditors noted that the entity did not complete annual tenant recertifications by the required due date for certain tenants. Specifically, for 2 of the 11 eligibility samples selected for testing, the annual tenant recertification was completed 22 days after the recertification due date. Criteria: Applicable HUD program requirements and the entity’s policies and procedures generally require annual tenant recertifications to be completed by the tenant’s annual recertification anniversary date (or other required due date) to support timely and accurate eligibility determinations and assistance calculations. Context: This condition was identified during eligibility testing for the HUD program. The auditors tested 11 tenant eligibility/recertification items and noted exceptions in 2 items in which the annual recertification was completed 22 days after the due date. Cause: The condition appears to have resulted from delays in tracking or monitoring recertification due dates and ensuring recertification activities were scheduled, completed, and reviewed timely. Contributing factors may include staffing constraints and/or insufficient oversight of the recertification tracking process. Effect: Failure to complete annual tenant recertifications timely results in noncompliance with applicable program requirements and increases the risk that tenant eligibility determinations and rental assistance amounts are based on outdated information. Questioned costs may arise if benefits were calculated or paid based on incomplete or outdated tenant information. This condition represents a deficiency in controls over the eligibility and recertification compliance process. Recommendation: The entity should strengthen controls over annual recertifications by implementing and maintaining effective tracking and monitoring of recertification due dates, including timely scheduling, automated or manual reminders, documented supervisory review of recertification status, and periodic management monitoring to ensure recertifications are completed by required due dates. Management Response: Management will continue to monitor recertification activity to ensure ongoing compliance with HUD occupancy requirements and to prevent similar issues moving forward