Finding 1221476 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-06-30

AI Summary

  • Core Issue: Tenant eligibility documentation is often missing or incomplete, leading to significant deficiencies in compliance.
  • Impacted Requirements: Noncompliance with HUD regulations on tenant eligibility, income verification, and rent determination increases risks of improper determinations.
  • Recommended Follow-up: Strengthen internal controls by conducting regular file reviews and providing staff training on documentation requirements.

Finding Text

HUD insured mortgage program Section 223(f), ALN 14.155 Criteria: Under HUD regulations, recipients are required to maintain and make available all records necessary to demonstrate compliance with program requirements. HUD requires documentation of tenant eligibility, income verification, and rent determination. The Uniform Guidance requires recipients to maintain records that adequately identify the source and application of funds. Statement of Condition: We reviewed 10% of the total population of tenant files. During our review, we noted that documentation to support tenant eligibility determination was missing or incomplete. We consider this condition to be a significant deficiency. Cause: The deficiencies occurred due to inconsistent file management practices and ineffective internal review procedures to ensure that all required eligibility documentation is obtained and retained. Effect: Missing or incomplete files increase the risk of improper eligibility determinations, inaccurate rent calculations, questioned costs, and HUD noncompliance. Recommendation: We recommend that management strengthen internal controls over tenant file documentation by conducting periodic supervisory reviews of files to ensure that all required documentation is present and complete and by providing staff training on HUD eligibility and documentation requirements. Views of Responsible Officials: We agree with the auditor’s finding. The audited files exist in the same timeframe as other issues noted in the previous audit, and therefore findings will be similar. Those files and documents were not properly managed or maintained and some cannot be located. Prior management did not implement established and required processes and failed to oversee the work to ensure accuracy. In the second quarter of 2025, we began exploring the issues that existed at that time and correcting procedures, changing software systems, establishing supervisors, training staff, and establishing tracking and monitoring systems and processes. Staff have made substantial progress and continue to do so.

Corrective Action Plan

To address the noted deficiencies in tenant file documentation, staff and supervisors will continue to follow established processes. Supervisors continue to track and monitor productivity and progress. The current supervisor has implemented clear and concise instructions and rules for completing and managing files. All forms are now saved in tenant files, and not on individual laptops as they were in the past. The supervisor has also implemented schedules and tracking systems for monthly voucher submissions, annual recertifications, quarterly income checks and other processes in the occupancy workflow. In addition, the supervisor and the lead staff for housing compliance perform regular checks on tenant application paperwork and random checks on tenant files to ensure accuracy and completeness and correct any mistakes. Ongoing staff training, support and mentoring continues.

Categories

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

Other Findings in this Audit

  • 1221477 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.155 MORTGAGE INSURANCE FOR THE PURCHASE OR REFINANCING OF EXISTING MULTIFAMILY HOUSING PROJECTS $1.93M
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $207,861