Finding Text
Finding No. 2022-002; Section 811, CFDA 14.181 Statement of Condition In connection with the procedures applied to a sample of 4 lease files we noted the following deficiencies: ? 3 instances where the file did not contain the appropriate Enterprise Income Verification system documentation. ? 2 instances where the tenant recertification was signed off but not dated by the tenant. ? 4 instances where the tenant recertification was not signed off by management. ? 1 instance where the file did not contain the tenant application, proof of citizenship or background check. ? 1 instance where the HUD-50059 contained a security deposit of $240 however there was no security deposit in the security deposit payable listing. 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. Questioned Costs None 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 or tenant being charged incorrect amount of rent. Cause Management's policies with respect to 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, and tenants income may be over/under reported. 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. Auditor Noncompliance Code: R - Section 8 Program Administration Finding Resolution Status: In process. Views of Responsible Officials and Planned Corrective Actions The Harlem United management team has established a new policy to ensure compliance of tenant lease files. Specifically, when intake staff receive a referral from the NYC HIV/AIDS Services Administration (HASA), an interview will take place to determine if the individual fits the program criteria (including documentation of their income, medical status, psychosocial assessment and/or psychiatric evaluation and proof of citizenship). If the individual fits the criteria and accepts an efficiency unit at North General / Foundation House East, the person?s documentation will be forwarded to our consultant, P & L Management, to verify the income and complete all leasing documentation for HUD approval (background checks and security deposits are not required of this program). Upon completion of the HUD documentation process, the intake staff will check to verify that all documentation have been signed and dated by the appropriate persons which includes P & L Management and North staff, and the tenant. Annually, the income information of all tenants at North General will be sent to P & L Management for verification; if the tenant?s income status continues to meet the HUD guidelines, the updated documentation will be forwarded back to the staff at North General. If the tenant?s income status does not meet the HUD criteria, the individual?s income information will be forwarded to NYC HASA for alternate housing placement. In addition, the Managing Director of North General will perform quarterly mock audits to ensure that tenant lease files are in compliance.