Finding 38411 (2022-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-06-29
Audit: 33862
Organization: St. Patrick Apartments Ii, Inc. (MD)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: Tenant eligibility verification is not consistently documented, leading to potential noncompliance with HUD regulations.
  • Impacted Requirements: Management must adhere to HUD Handbook 4350.3 for tenant eligibility and lease file maintenance.
  • Recommended Follow-Up: Implement and monitor procedures to ensure compliance with HUD guidelines for tenant eligibility and documentation.

Finding Text

Finding No. 2022-002; Supportive Housing for the Elderly Section 202 Capital Advance (with "Project Rental Assistance Contract"), Assistance Listing 14.157 Criteria Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition During the procedures applied to a sample of 7 tenant lease files, we noted the following instances of noncompliance with HUD regulations regarding tenant eligibility and the maintenance of lease files. 1 out of 7 tenants tested did not have documentation in their lease file that their income was verified. Cause The project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines. Effect or Potential Effect Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs - None Identification as a Repeat Finding - None Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Auditor Noncompliance Code: R - Section 8 program administration Finding Resolution Status: Not Started or In Process Views of Responsible Officials All tenant income is verified at initial move in and at each annual and interim certification. The instance of noncompliance pertained to a tenant that only had social security income for her March 1, 2022 Annual Recertification, meaning that her verification would have been through the HUD EIV system and would not have been transmitted electronically to the auditors. Management believes the report was properly run. Additionally, our policies include running EIV master file reports on a monthly basis which would have alerted management to the presence of a new job or unreported income in the household had there been any.

Corrective Action Plan

B. Finding 2022-002 a. Comments on Findings and Recommendations 2022-002: All tenant income is verified at initial move in and at each annual and interim certification. The instance of non-compliance pertained to a tenant that only had social security income for her March 1, 2022, Annual Recertification, meaning that her verification would have been through the HUD EIV system and would not have been transmitted electronically to the auditors. Management believes the report was properly run. Additionally, our policies include running EIV master file reports on a monthly basis which would have alerted management to the presence of a new job or unreported income in the household had there been any.

Categories

HUD Housing Programs Eligibility

Other Findings in this Audit

  • 38410 2022-001
    Material Weakness Repeat
  • 614852 2022-001
    Material Weakness Repeat
  • 614853 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $4.60M