Finding 485753 (2023-002)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-09-05
Audit: 318591
Organization: Pilgrim Towers, Inc. (CT)
Auditor: Whittlesey PC

AI Summary

  • Core Issue: The Agency lacks sufficient documentation to verify annual income for families receiving housing assistance under the HOME program.
  • Impacted Requirements: Compliance with income targeting requirements and record-keeping for low-income eligibility is not being met.
  • Recommended Follow-Up: Ensure all annual income assessments are documented and signed by both tenants and property managers by December 31, 2024.

Finding Text

S3800-010 Finding reference number: 2023-002 S3800-011 Title and CFDA: Home Investment Partnerships Program CFDA# 14.239 S3800-015 Type of Finding: FA S3800-016 Finding resolution status: In process S3800-019 Identification of repeat finding: N/A S3800-020 Criteria: The HOME program has income targeting requirements. Only low-income or very lowincome persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR section 92.1). Therefore, the Agency must determine if each family is income eligible by determining the family’s annual income, including all persons in the household. The Agency must maintain records for each family assisted. S3800-030 Statement of Condition: During our audit for the year ended December 31, 2023, we noted that sufficient supporting documentation was not available for the annual income amounts. S3800-032 Cause: Annual income determinations were not properly documented by the property management company. S3800-033 Effect of Potential Effect: There is not sufficient supporting documentation for the annual income used to assess housing eligibility and the auditor can not determine if appropriate rental limits were followed in line with the HOME program compliance requirements. S3800-035 Auditor non-compliance code: S S3800-040 Amount of questioned costs: $0 S3800-045 Reporting Views of Responsible Officials: As of April 1, 2024, a new management company has taken over responsibility of management of the Pilgrim Towers project. This new management company will be diligently working to update and obtain the documentation that is unavailable, and will ensure to properly maintain any future documentation regarding annual income certifications for housing elilgiblity. S3800-037 FHA/Contract number: CT26M000251 S3800-038 Questioned Costs: $0 S3800-050 Context: The Agency is not in compliance with the HOME Program requirements of maintain records for each family assisted. HOME-assisted units in a rental housing project must be occupied only by households that are eligible as low-income families and must meet certain limits on the rents that can be charged. Due to the lack of supporting documentation of annual income the auditor is unable to determine if the tenants are eligible under the HOME program. S3800-080 Recommendation: We recommend that the Agency documents all annual income assessments, and that it retain copies of the income assessment and supporting documentation to comply with the requirements of the HOME Program. In addition, we recommend that the annual income certifications be signed by the tenant and a property manager. S3800-090 Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: Annual income determinations must be documented and maintained by the Agency. S3800-130 Response Indicator: A S3800-140 Completion date of proposed recommendation: December 31, 2024 S3800-150 Response: We agree with the finding, and expect this to be resolved in the coming year with the new management company, Kingsway Senior Housing, in place as of April 1, 2024.

Corrective Action Plan

Finding Reference Number: 2023-002 Description of Finding: During our audit for the year ended December 31 , 2023, we noted that sufficient supporting documentation was not available for the annual income amounts. Statement of Concurrence or Nonconcurrence: We are in agreement with this finding. Corrective Action: A new management company has been engaged as of April 1, 2024. The new management company, Kings Daughters and Sons Management Company, Inc., is very diligent in maintaining its records and ensuring they are in compliance. It is expected that they will ensure that the supporting document for annual income amounts will be properly documented and filed going forward. Name of Contact Person: Pat Thatcher, Board Treasurer patthatcher1@gmail.com 203-451-1090 Projected Completion Date: Expectation is that the new management company will ensure proper income verification for all tenants for the year ended December 31, 2024.

Categories

Eligibility Reporting

Other Findings in this Audit

  • 485752 2023-001
    Significant Deficiency Repeat
  • 1062194 2023-001
    Significant Deficiency Repeat
  • 1062195 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $1.63M
14.239 Home Investment Partnerships Program $800,000
14.164 Flexible Subsidy Loan (section 201) $373,400
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $339,711
14.191 Multifamily Housing Service Coordinators $56,847