Finding 34527 (2022-001)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-04-26
Audit: 36267
Organization: Community Housing, Inc. (OR)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: Timely tenant recertifications and income verifications were not consistently performed, violating HUD guidelines.
  • Impacted Requirements: Compliance with HUD Handbook 4350.3 regarding tenant eligibility and lease file maintenance was not met.
  • Recommended Follow-Up: Management should implement and monitor procedures to ensure timely recertifications and proper lease file management.

Finding Text

U.S. Department of Housing and Urban Development - Supportive Housing for the Elderly (Section 202) Program and Home Investment Partnership Program Finding No. 2022-001; Federal Assistance Listing Number 14.157; Finding No. 2022-002; and Federal Assistance Listing Number 14.239 Criteria 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 that: 1. One out of three tenants? recertification was not performed timely; and 2. One out of three tenants? income verification was not performed timely with the use of the HUD Enterprise Income Verification ("EIV") timeliness. Cause Management's policies with respect to recertifications and 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 recertification 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 One out of three tenants' recertification was not performed timely, and one out of three tenants tested did not have the EIV run timely Identification as a Repeat Finding Yes Recommendation Management should establish procedures and monitor compliance with those procedures to insure that recertifications are performed timely and signed, 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: E-Eligibility for Uniform Guidance; Z-Other Finding Resolution Status: Resolved Views of Responsible Officials and Planned Corrective Actions: Due to either tenant non-compliance or challenges with scheduling meetings with tenants or obtaining verifications, some recertifications were completed late. REACH has policies in place to complete recertifications timely and will be providing ongoing training and guidance to staff to make sure the policies are being followed.

Corrective Action Plan

Statement of Condition: In connection with our lease file review, we noted that: 1. One out of three tenants? recertification was not performed timely; and 2. One out of three tenants? income verification was not performed timely with the use of the HUD Enterprise Income Verification ("EIV") timeliness. Corrective Action: Due to either tenant non-compliance or challenges with scheduling meetings with tenants or obtaining verifications, some recertifications were completed late. REACH has policies in place to complete recertifications timely and will be providing ongoing training and guidance to staff to make sure the policies are being followed.

Categories

Eligibility HUD Housing Programs

Other Findings in this Audit

  • 34528 2022-003
    Significant Deficiency
  • 34529 2022-002
    Significant Deficiency Repeat
  • 610969 2022-001
    Significant Deficiency Repeat
  • 610970 2022-003
    Significant Deficiency
  • 610971 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $1.42M
14.239 Home Investment Partnerships Program $750,000