Finding 2243 (2022-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-11-20
Audit: 3827
Organization: Victory Heights, Inc. (MD)
Auditor: Cohnreznick

AI Summary

  • Core Issue: Tenant eligibility procedures were not consistently followed, leading to inaccuracies in income reporting and delays in recertifications.
  • Impacted Requirements: Compliance with HUD Handbook 4350.3 was lacking, risking the rental of units to ineligible tenants and potential errors in rent subsidies.
  • Recommended Follow-Up: Management should implement and monitor new procedures to ensure accurate tenant eligibility determinations and proper maintenance of lease files.

Finding Text

Criteria - Eligibility Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review we noted the following deficiencies: 1 out of 8 tenants tested did not have the accurate amount of adjusted annual income reported on HUD Form 50059 and did not have documentation in their lease file that certain income was verified. 6 out of 8 tenants tested did not utilize the Enterprise Income Verification system timely. 1 out of 8 tenants tested did not perform recertifications on HUD Form 50059 timely. Cause Management's policies with respect to the determination of tenant eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. This could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs: N/A Context The sample is not considered a statistically valid sample. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to insure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Auditor Noncompliance Code: R - Section 8 program administration Finding Resolution Status: In-process Views of Responsible Officials The incorrect adjusted annual income was corrected on the HUD Form 50059. The full-time manager that was authorized to run the EIV reports was out for a portion of the year. When a staff member is out or a position is vacant, someone at another site who is authorized to run EIVs will help cover until a replacement is found. The EIV paperwork has since been placed in the correct files. A full EIV Policy and Procedure manual is located on site and the new employee was trained on these policies by their supervisor and compliance manager. The tenant signed her recertification paperwork 20 days late due a transition in the office. New employee was trained on HUD policies by their supervisor and compliance manager.

Corrective Action Plan

Our back up plan for when a staff member is out or a position vacant is to have someone who is authorized to run EIV at another location/site to help cover until a replacement is found. In this case the EIV paperwork was held at a separate location and has since been placed in all the correct files. A full EIV Policy and Procedure manual is located on site and the new employee is trained on these policies by their supervisor and compliance manager. Both items were addressed in the follow up to the audit. The adjusted income was dealing with a lump sum of income which is not included in income. Correction was made to the 50059. The tenant signed her recertification paperwork 20 days late due a transition in the office. This was documented and file has been corrected. Additional training is provided to all managers on Section 8 Policies and Procedures on a regular basis. Policies and Procedures are also located on our direct intra network for individuals to refer to specific calculations, income issues, asset issues, forms and policies. This training is ongoing.

Categories

HUD Housing Programs Eligibility

Other Findings in this Audit

  • 2244 2022-001
    Significant Deficiency
  • 578685 2022-001
    Significant Deficiency
  • 578686 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $7.45M
14.239 Home Investment Partnerships Program $4.25M