Finding Text
Information on the Federal Program: U.S. Department of Housing and Urban Development (“HUD”) – 14.157 Supportive Housing for the Elderly (Section 202); FAIN #012-EH692; July 1, 2024 – June 30, 2025 Finding Type: Significant deficiency Criteria: In accordance with 24 CFR 891.400(e) and 891.600(e), and the Organization’s HUD Regulatory Agreement and Project Rental Assistance Contract (PRAC), surplus cash generated from project operations is required to be deposited into the Residual Receipts Reserve account in a timely manner and maintained in accordance with HUD requirements. Condition and Context: During our compliance testing of Special Tests and Provisions for the Organization’s HUD Section 202 program for the year ended June 30, 2025, we noted that the Organization did not deposit surplus cash into the Residual Receipts Reserve account in a timely manner, as required based on the annual surplus cash computation for the audit year. This condition related to the project’s Residual Receipts Reserve account maintained for the project during the period under audit. Cause: During the period of transition in finance/management personnel, responsibility for preparing/reviewing the annual surplus cash computation and initiating the required Residual Receipts deposit was not clearly reassigned or sufficiently reviewed, resulting in an oversight of the deposit requirement in a timely manner. Effect or Potential Effect: Project funds that should have been restricted in the Residual Receipts Reserve account remained in operating accounts, increasing the risk that restricted amounts could be used for unapproved purposes and resulting in potential HUD compliance consequences. Questioned Costs: None Recommendation: We recommend that management establish written procedures and assign responsibility for monitoring surplus cash calculations and ensuring timely deposits to the Residual Receipts Reserve, including documented management review, particularly during periods of personnel transition. Management’s Response: Management is in the process of implementing formal procedures to strengthen oversight of HUD regulatory requirements, including the preparation, review, and timely execution of surplus cash calculations and related residual receipts deposits. These procedures will include clearly assigning responsibility, incorporating the requirement into a year-end compliance checklist, and documenting management review. Management expects these procedures to be implemented promptly and believes they will ensure compliance with HUD requirements going forward.