Finding Text
Finding No. 2023-001; Federal Assistance Listing Number 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
In connection with our lease file review we noted:
- two out of three tenants did not have a recertification performed timely.
- one out of four tenants did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely.
Cause
Management 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
The procedures for determining tenant EIV 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.
Context
Two out of three tenants tested did not have an EIV performed timely and one out of four tenants did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely.
Repeat Finding
Yes, 2022-001
Questioned Costs
N/A
Recommendation
Management should monitor compliance with procedures to insure that recertifications and EIVs are performed timely, 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; R-Section 8 program administration.
Finding Resolution Status: Resolved
Views of Responsible Officials and Planned Corrective Actions
REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2023. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Additional procedures have been implemented in 2023 to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.