Finding 374736 (2023-001)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-11
Audit: 294429
Organization: Hanac, Inc. and Affiliates (NY)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: Tenant lease files were not maintained properly, leading to missed recertifications and incomplete documentation.
  • Impacted Requirements: Compliance with HUD Handbook 4350.3 was inconsistent, risking eligibility errors and incorrect rent subsidies.
  • Recommended Follow-Up: Management should implement new procedures and regular monitoring to ensure compliance with tenant eligibility and lease file maintenance.

Finding Text

U.S. Department of Housing and Urban Development 14.157 Supportive Housing for the Elderly Section 202 Loan 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 review of eight lease files we noted the following deficiencies: Four files did not have timely recertification of tenants and Enterprise Income Verification system documentation was performed later than the required recertification date. One file did not contain the signed application or the background check. Cause Management's policies with respect to the determination of tenant security deposits 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 security deposits and 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 A sample of 8 tenant files were selected from a population of 64. We identified exceptions in 5 out of the 8 files tested. Identification as a repeat finding Yes or no? No Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, 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. View of Responsible Officials Management agrees with recommendation and has begun to implement the following: - A checklist form will be completed for every certification and signed off once file is approved. - An AR form will be created for the move in, transfer and move out process which is to be attached with proof of payment. Once completed it is to be sent to senior staff for review. The file setup format and recertification updates will be monitored on a monthly basis. - EIV are being run according to the frequency provisions related to the type of reports we are annually required to complete as per HUD. - Annual inspections are being schedule as per Annual Recertifications are being processed. - Bi-weekly meetings will be in place to discuss the results collected with a tracking log on the progress of the project. - Trainings will be scheduled to keep on top of HUD updates/compliance procedures; Yardi software trainings; and in-house trainings covering compliance with the files and Yardi 50059 module.

Corrective Action Plan

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 HANAC, Inc. and Affiliates (HANAC) respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2023 The finding from the June 30, 2023 consolidated and combined schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None reported. FINDINGS – FEDERAL AWARD PROGRAMS AUDITS Material Weakness FINDING 2023-001 Eligibility U.S. Department of Housing and Urban Development 14.157 Supportive Housing for the Elderly Section 202 Loan Condition: In connection with the audit, it was noted that of the eight lease files tested four files did not have timely recertification of tenants and Enterprise Income Verification system documentation was performed later than the required recertification date. Additionally, one file did not contain the signed application or the background check. Recommendation: Management should establish procedures and monitor compliance with those procedures to insure that tenant security deposits are correctly recorded, 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. Action Taken: Management agrees with recommendation and has begun to implement the following: - A checklist form will be completed for every certification and signed off once file is approved. - An AR form will be created for the move in, transfer and move out process which is to be attached with proof of payment. Once completed it is to be sent to senior staff for review. Under this new management, we already have set in place policies and procedures under the governance of HUD and the tenant selection plan to ensure compliance and due diligence is taking place. Any new staff will be HUD trained. - The file setup format and recertification updates will be monitored on a monthly basis. - EIV are being run according to the frequency provisions related to the type of reports we are annually required to complete as per HUD. Annual inspections are being schedule as per Annual Recertifications are being processed. - Bi-weekly meetings will be in place to discuss the results collected with a tracking log on the progress of the project. - Trainings will be scheduled to keep on top of HUD updates/compliance procedures; Yardi software trainings; and in-house trainings covering compliance with the files and Yardi 50059 module. Expected completion date: January 2024 If any cognizant or oversight agency has questions regarding this plan, please call Lola Maroulis, Chief Financial Officer at 212-840-8005, extension 111. Sincerely yours, Lola Maroulis, Chief Financial Officer

Categories

Eligibility HUD Housing Programs Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 951178 2023-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $10.25M
81.042 Weatherization Assistance for Low-Income Persons $826,308
93.493 Congressional Directives $310,378
16.575 Crime Victim Assistance $307,783
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $147,377
93.568 Low-Income Home Energy Assistance $132,267
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $117,690
14.191 Multifamily Housing Service Coordinators $85,928
93.053 Nutrition Services Incentive Program $67,592
14.252 Section 4 Capacity Building for Community Development and Affordable Housing $16,520
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $11,928
93.959 Block Grants for Prevention and Treatment of Substance Abuse $4,699