Finding 1239113 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 413989
Organization: Brighter Tomorrows, Inc. (NY)

AI Summary

  • Core Issue: Proposed rents exceeded the Organization's $100 limit over average gross rents and HUD Fair Market Rent limits, leading to potential non-compliance.
  • Impacted Requirements: Rent reasonableness documentation and federal rental assistance payments must adhere to established criteria and HUD Fair Market Rent limitations.
  • Recommended Follow-Up: Enhance review procedures to ensure compliance with rent criteria and document resolutions for any exceptions before approving federal rental assistance.

Finding Text

United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Grants used to pay rent for individual housing units should document that rent paid is reasonable in relation to rents being charged for comparable units, taking into account relevant features. In addition, the portion of rental assistance paid with Continuum of Care Program funds is subject to the applicable HUD Fair Market Rent limitation. The Organization's rent reasonableness procedures provide that the proposed gross rent should not exceed the average gross rent of comparable units by more than $100. Condition: Although the Organization strengthened its procedures during the current year and maintained rent reasonableness documentation within the tenant files selected for testing, there were instances in which the proposed gross rent exceeded the average gross rent of comparable units by more than the $100 limit established by the Organization. In addition, there were instances in which rental assistance paid with federal funds exceeded the applicable HUD Fair Market Rent after consideration of the applicable utility allowance, with no documentation supporting the amounts paid in excess of the applicable limit. Cause: The Organization's review procedures did not consistently identify instances in which proposed rents exceeded the limits established by its rent reasonableness procedures or rental assistance exceeded the applicable HUD Fair Market Rent. Effect: The Organization may pay rental assistance with federal funds for amounts that do not comply with its established rent reasonableness criteria or applicable HUD Fair Market Rent limitations. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2024-003. The Organization improved its procedures during the current year by maintaining rent reasonableness documentation within the tenant files; however, exceptions identified during current-year testing indicate that additional improvements to the review process are necessary. Questioned Costs: The population consisted of 21 tenant files with total federal rental assistance expenditures of $310,607. We selected 10 tenant files for testing monthly payments, representing $184,884 of federal rental assistance expenditures. Exceptions were identified for 25 monthly payments related to the Organization's rent reasonableness procedures and applicable HUD rental assistance requirements. The questioned costs associated with the exceptions totaled $6,036. Recommendation: The Organization should strengthen its review procedures to ensure that, prior to approval of federal rental assistance, proposed rents comply with the Organization's established rent reasonableness criteria and applicable HUD Fair Market Rent limitations. The review should be documented and evidence resolution of any identified exceptions prior to the payment of rental assistance with federal funds. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will strengthen its review procedures to ensure that rental assistance paid with federal funds complies with established rent reasonableness criteria and applicable HUD Fair Market Rent limitations.

Corrective Action Plan

2025-002. Special Tests and Provisions – Rent reasonableness United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: Although the Organization strengthened its procedures during the current year and maintained rent reasonableness documentation within the tenant files selected for testing, there were instances in which the proposed gross rent exceeded the average gross rent of comparable units by more than the $100 limit established by the Organization. In addition, there were instances in which rental assistance paid with federal funds exceeded the applicable HUD Fair Market Rent after consideration of the applicable utility allowance, with no documentation supporting the amounts paid in excess of the applicable limit. Recommendation: The Organization should strengthen its review procedures to ensure that, prior to approval of federal rental assistance, proposed rents comply with the Organization's established rent reasonableness criteria and applicable HUD Fair Market Rent limitations. The review should be documented and evidence resolution of any identified exceptions prior to the payment of rental assistance with federal funds. Corrective Action: The Organization will strengthen its review procedures to ensure that rental assistance paid with federal funds complies with established rent reasonableness criteria and applicable HUD Fair Market Rent limitations. Responsible Contact Person(s): Louis Bamonte, Director of Finance Brighter Tomorrows, Inc. - P.O. Box 706 – Shirley, New York 11967 Anticipated Completion Date: December 31, 2026.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1239112 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
16.575 CRIME VICTIM ASSISTANCE $645,599
14.267 CONTINUUM OF CARE PROGRAM $608,965
93.667 SOCIAL SERVICES BLOCK GRANT $84,292
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $59,916
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $23,446
16.736 TRANSITIONAL HOUSING ASSISTANCE FOR VICTIMS OF DOMESTIC VIOLENCE, DATING VIOLENCE, STALKING, OR SEXUAL ASSAULT $17,229
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $5,017
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $3,591