Finding 503889 (2024-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2024-10-28

AI Summary

  • Core Issue: Tenant lease files are not consistently maintained according to HUD guidelines, leading to potential eligibility errors.
  • Impacted Requirements: EIV reports for new and existing tenants were improperly generated or missing, violating HUD Handbook 4350.3.
  • Recommended Follow-Up: Management should enforce new procedures and regular training to ensure compliance with HUD requirements for tenant eligibility and lease file maintenance.

Finding Text

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. Condition In connection with our lease file review, we noted the following deficiencies: - 1 out of 1 lease files for new tenants did not follow EIV guidelines, no EIV report was generated for move-in certification. - 3 out of 11 lease files for existing tenants did not follow EIV guidelines, EIV reports were generated outside of the allowed 120-day period. - 3 out of 11 lease files for existing tenants did not contain necessary documentation, files were missing gross rent change forms and latest executed versions of HUD-50059 form. Cause Management's policies with respect to the determination of 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. Effect or Potential Effect The procedures for 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. Recommendations Management should establish procedures and monitor compliance with those procedures to ensure that 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: Z. Other View of Responsible Officials Management agrees with the finding and has implemented the below policies and will continue to train, and connect our team members with the in house HUD Compliance Specialist for support. 1. Move in EIV's - All move in files will be sent to our in house compliance department and Franklin Group has an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90 day reminders for all move in. 2. Existing Tenant EIV - It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The RM is required during monthly visits to spot check at least 5 existing tenants. 3. Gross Rent Change & Medical Reporting - The policy states that all Gross Rent Changes are to be completed as approved by the new rent schedule - The Community Manager is required to scheduled appointments with all residents to sign the effective gross rent change and file in tenants files, it is also required that residents 50059s are signed and in the file, the Community Manager has taken the latest HUD training with our in house HUD Compliance Manager- The Regional Manager will also spot check files to be certain that all Gross Rent Changes are in it's 6 part file folders. Medical reporting records were discussed in our HUD Compliance Training and all expenses must be in the 6-part file folder. Again, the RM will continue to spot check files during the monthly required inspections. All HUD Communities were required to participate in the HUD Training as a reminder tool. 4. Security Deposit - Franklin Companies has a policy that all security deposit refunds must be submitted within the 3 days move out period. This situation was due to the changeover in Management. Finding Resolutions Status: Resolved

Categories

Eligibility HUD Housing Programs Reporting

Other Findings in this Audit

  • 503888 2024-001
    Material Weakness Repeat
  • 503890 2024-002
    Material Weakness
  • 503891 2024-002
    Material Weakness
  • 503892 2024-003
    Material Weakness
  • 503893 2024-003
    Material Weakness
  • 503894 2024-004
    Material Weakness
  • 503895 2024-004
    Material Weakness
  • 503896 2024-005
    Material Weakness
  • 503897 2024-005
    Material Weakness
  • 1080330 2024-001
    Material Weakness Repeat
  • 1080331 2024-001
    Material Weakness Repeat
  • 1080332 2024-002
    Material Weakness
  • 1080333 2024-002
    Material Weakness
  • 1080334 2024-003
    Material Weakness
  • 1080335 2024-003
    Material Weakness
  • 1080336 2024-004
    Material Weakness
  • 1080337 2024-004
    Material Weakness
  • 1080338 2024-005
    Material Weakness
  • 1080339 2024-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $7.42M
14.157 Supportive Housing for the Elderly ("prac") $500,322