Finding 48124 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-08-15
Audit: 38718
Organization: Honor Ehg INC (NY)
Auditor: Rbt CPAS LLP

AI Summary

  • Core Issue: Rents paid by HONOR ehg Inc. for tenants in the COC program exceed HUD's Fair Market Rental Rates.
  • Impacted Requirements: Compliance with 2 CFR part 200 requires rents to be reasonable compared to similar units and not exceed the landlord's own unassisted rents.
  • Recommended Follow-Up: HONOR ehg Inc. should conduct annual rent reasonableness certifications for all COC-funded tenants, ensuring documentation of comparable rents and compliance with HUD standards.

Finding Text

2022-001 Rent Reasonableness Controls. Condition: HONOR ehg Inc. rents paid for tenants within COC program exceeded Fair Market Rental Rates published by HUD. Criteria: Per 2 CFR part 200, Appendix IX, Compliance Supplement, rents paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, rents may not exceed rents currently being charges by the same owner for comparable unassisted units, and the portion of rents paid with grant funds may not exceed HUD-determined fair market rents. Grant funds in the amount of 1 months rent may be used to pay the non-recipient landlord for any damages to leased units by home less participants. Context: 2 of 9 tenants selected rental payments exceeded HUD published Fair Market Rents based on location and unit type. 1 tenant selected has no documentation related to unit type to determine fair market rent applicability. 1 tenant selected had a security deposit that exceeded 1 months rent. Cause: HONOR ehg, Inc. does not perform rent reasonableness testing annual and does not track tenant portion of rents due. Effect: Honor is not in compliance with the Continuum of Care Reasonable Rental Rates component. Recommendation: We recommend that HONOR ehg Inc. perform annual rent reasonableness certifications on all tenants whose rent is paid by COC funding. Rent reasonableness certification should document comparable rental units in the area, cost of other rental units from the same landlord and that the rent portion funded by COC funds is at or below the Fair Market Rent published annually.

Corrective Action Plan

2022-001 Rent Reasonableness Controls: A program policy and procedure has been put into place to conduct a Rent Reasonableness Certification prior to signing a lease that utilizes COC funds. This documentation is submitted to the CFO for review when presented with a new lease to sign. The initial Rent Reasonableness Citification will be maintained in the client's housing records. All current tenants will have a Rent Reasonableness Cortication Conducted annually and maintained in the client's housing program record.

Categories

HUD Housing Programs

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance for Needy Families $1.96M
14.267 Continuum of Care Program $759,092
14.231 Emergency Solutions Grant Program $700,437
93.667 Social Services Block Grant $151,993
93.623 Basic Center Grant $150,000
10.558 Child and Adult Care Food Program $105,912
93.658 Foster Care_title IV-E $71,365
97.024 Emergency Food and Shelter National Board Program $57,000
14.239 Home Investment Partnerships Program $8,990