Finding Text
2023-002 Program Income
Program: 14.267 Continuum of Care Program
Criteria: In accordance with 2 CFR 200.307, program income (in this case, tenant rent) must be
correctly determined and properly recorded in the accounting records. Eligibility and rent
determination evaluations are performed for new tenants before move-in and annually for
existing tenants to determine their portion of rent to pay via the Tenant Income Certification
or Re-certification of Permanent Supportive Housing – Eligibility and Rent Determination
forms which are approved by the San Diego Housing Commission. Housing program
tenants are required to pay up to 30% of their income for rent.
Condition: For one out of 12 transactions tested, The Center collected $344.40 which could not be
directly traced to an individual tenant. Because it could not be directly traced, the Tenant
Income Certification or Re-certification of Permanent Supportive Housing – Eligibility and
Rent Determination forms could not be identified and tested for accuracy or completeness
and compliance with the tenant’s share of the rental payment could not be determined.
Cause: There is no process to regularly review tenant rent payments to ensure that amounts
received are matched with a specified tenant and that amounts collected are accurate and
agree with the Eligibility and Rent Determination form.
Effect: Rent payment was not attributed to an individual tenant. Rent was underpaid by one tenant
for multiple months.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: After further investigation, it was determined that one tenant did not pay rent for certain
months during fiscal year 2023. Based on a review of client payments and files, it was
plausible that the payment received was back rent for this tenant.
Repeat Finding: No.
Recommendation: The Center should develop a policy for handling payment of tenant rent, including
underpayments and overpayments. Rent collected should be compared to the amount
determined on the Eligibility and Rent Determination form on a monthly basis to review for
inconsistencies and, when differences arise, they should be timely investigated and
followed-up on with the appropriate corrective action, per the established policy.
Views of Responsible
Officials: Management agrees with the finding and a response is included in the corrective action
plan.