Finding 2022-004: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Continuum of Care Program Federal Catalog Numbers: 14.267 Noncompliance ? E. Eligibility ? Tenant Files Non Compliance Material to the Financial Statements: No Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 71 units. Of a sample size of twenty-one (21) tenant files, the following was noted: - HUD 50058 annual recertification was missing in 1 file - Income Verification was missing in 2 files Our sample size is statistically valid. Known Questioned Costs: $30,581 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Continuum of Care Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: MHA agrees with the findings that some tenant file documents were essentially unavailable for examination at the time of the audit and that a system of consistent document filing, and regular file reviews are necessary. The ?missing? documents were subsequently found but in various electronic locations, thereby making them not easily accessible to the auditors. There were also timing issues, in that a recertification was begun in 2022 but not completed or made effective until 2023 once all documents had been received. ? The tenant documents will now be filed in one place, in Yardi as attachments to the Family Detail Info (FDI) screen in the proper subfolder depending upon subject (e.g. Assets, Income, Member). MHA is working to create and label the subfolders needed for this purpose. ? The contractor and internal staff will receive detailed instructions on how to file all documents, from the receipt of documents from the tenant to the commemoration of the transaction in a HUD Form 50058. All will be required to sign a confirmation they received such instructions. ? All new staff responsible for collecting documents, processing transactions and creating 50058s will obtain training in the correct system of filing such documents as part of their on-boarding packet of trainings. ? MHA will institute a quality control procedure for the regular review of random sample files at least quarterly to ensure that the filing system is being followed and the documents are complete and readily found. Views of responsible officials and planned corrective action: Nick Zhou, Chief Financial Officer, is responsible for implementing this corrective action by December 31, 2023.