Finding 1215377 (2025-002)

Material Weakness Repeat Finding
Requirement
Eligibility
Questioned Costs
-
Year
2025
Accepted
2026-05-21

AI Summary

  • Core Issue: Four tenant recertifications were completed late, ranging from three to twelve months after the required date, leading to potential eligibility risks.
  • Impacted Requirements: Federal guidelines mandate annual tenant eligibility checks and accurate rent calculations based on documented income.
  • Recommended Follow-Up: Strengthen internal controls and monitoring to ensure timely recertifications and proper documentation of income before determining eligibility and rent.

Finding Text

Condition During audit testing, the auditor identified four instances in which tenants’ annual HUD‑50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures (tenant recertification), were not completed in a timely manner. Specifically, recertifications were completed three to twelve months after the required annual effective date, resulting in significant delays between the effective date and execution of the certification. In addition, one tenant recertification file lacked adequate income support documentation to substantiate tenant eligibility and the calculation of the tenant portion of rent. Criteria The terms and conditions of the federal award require the auditee to determine tenant eligibility and calculate the tenant portion of rent based on supported and documented income information on at least an annual basis. Cause The condition occurred because management had insufficient internal controls and monitoring procedures to ensure that tenant recertifications were completed within required timeframes and that income documentation was consistently obtained, reviewed, and retained prior to determining eligibility and calculating tenant rent. Effect or Potential Effect Untimely tenant recertifications increase the risk that tenants may occupy assisted units without documented eligibility for the applicable period. As a result, subsidy rents charged during uncertified periods may not be allowable under the terms and conditions of the federal award. Additionally, because income support documentation was not maintained for one tenant, the auditee was unable to demonstrate that eligibility requirements were met or that the tenant’s portion of rent was calculated correctly, which could result in unallowable subsidy payments. Context Testing was performed on 16 tenant files selected from a population of 40 tenant files for the program. Questioned Costs $13,560 Repeat Finding No Recommendation The auditor recommends that management strengthen internal controls and monitoring procedures to ensure tenant recertifications are completed timely, including periodic supervisory review. In addition, management should implement procedures to ensure that income documentation is obtained, reviewed, and retained prior to determining tenant eligibility and calculating rent amounts. Management Response Management agrees with the finding and has prepared an attached corrective action plan to address the issue.

Corrective Action Plan

Responsible Official Nichelle Brown, Senior Vice President of Property and Asset Management Plan Detail Management concurs with the audit finding related to untimely tenant recertifications and missing income documentation. Management reviewed the circumstances that contributed to the delayed completion of tenant recertifications and incomplete documentation and determined that existing internal monitoring procedures did not consistently ensure tenant recertifications were completed within required timeframes. To address these issues, management has implemented corrective actions designed to strengthen oversight and improve the timeliness and completeness of tenant recertifications. These actions include reinforcing internal tracking procedures for recertification due dates, enhancing supervisory review of tenant eligibility files, and providing additional training to staff responsible for tenant eligibility determinations and income verification. Management expects these corrective actions to be fully implemented and operating effectively for all tenant recertifications going forward, thereby improving compliance with federal award requirements and reducing the risk of future untimely tenant recertifications or missing documentation. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in fiscal year 2026.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility HUD Housing Programs Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1215376 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.155 MORTGAGE INSURANCE FOR THE PURCHASE OR REFINANCING OF EXISTING MULTIFAMILY HOUSING PROJECTS $2.51M
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $499,182