Finding 515780 (2024-006)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-19

AI Summary

  • Core Issue: The Commission lacks adequate internal controls to ensure proper application of contract rent changes, leading to noncompliance with federal program requirements.
  • Impacted Requirements: Annual adjustments to contract rents must align with approved schedules and not create significant discrepancies between assisted and unassisted units.
  • Recommended Follow-Up: The Commission should establish processes to ensure compliance with rent change requirements and prevent future issues.

Finding Text

2024 – 006 – PBRA/MOD – Contract Rent Change Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner applies or ensures annual adjustments to contract rents are applied. The HAP original term contract or renewal contract specifies the method to be used to determine rent adjustments. Adjustments must not result in material differences between rents charged for assisted units and comparable unassisted units except as those differences existed at contract execution. Special adjustments to contract rents, within the original contract term, may also be made to the extent deemed necessary by the PHA or HUD (24 CFR sections 880.609, 881.601, 882.410, 882.808(e), 883.701, 884.109, 886.112, 886.312(c) and Section 524 of Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) Title V of the HUD Fiscal Year 1998 Appropriations Act, Pub. L. 105-65, as amended). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure rent changes were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 12 exceptions: - 12 files where the rent on the 50059 did not match the approved rent schedules Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over rent changes. Effect: The Commission is not in compliance with program requirements over rent changes. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will review certifications to ensure that any necessary corrections are made so that the correct contract rent is reflected on the hUD50059. Moving forward management will ensure that site staff review the HUD-50059 contract rent amounts for accuracy against the approved Rent Schedule. Additionally, Pratum will ensure that certifications are completed early, ahead of any Gross Rent Increase, and that affected certifications are corrected as needed to reflect the correct contract rents on the HUD-500-59. Pratum will also ensure that rent change letters are provided as required, with a copy retained in the resident file along with the certification. Furthermore, management will ensure that a copy of the rent change letter is uploaded to Yardi, along with the completed certification, the completed unit inspection form, and the notification letters for HQS annual inspection scheduling. Lastly, Pratum will review the reference tenant file and provide a copy of the HUD-50059 and rent change form for review. Management will ensure that these documents are retained in the resident file and uploaded to Yardi upon completion of all further certifications. The HOC compliance team will focus on conducting site visits for the Project Based Rental Assisted properties following the same guidelines used for the annual financial audit. The goal is to perform a 100% file review for properties with 25 or less units and a 50% file review for properties with more than 25 units. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. The HOC compliance team will start site visits by January 2025 and will review files from the start of the fiscal year.

Categories

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 515771 2024-001
    Material Weakness Repeat
  • 515772 2024-002
    Significant Deficiency
  • 515773 2024-001
    Material Weakness Repeat
  • 515774 2024-002
    Significant Deficiency
  • 515775 2024-001
    Material Weakness Repeat
  • 515776 2024-002
    Significant Deficiency
  • 515777 2024-003
    Material Weakness Repeat
  • 515778 2024-004
    Material Weakness Repeat
  • 515779 2024-005
    Significant Deficiency Repeat
  • 515781 2024-007
    Material Weakness
  • 515782 2024-008
    Significant Deficiency
  • 515783 2024-003
    Material Weakness Repeat
  • 515784 2024-004
    Material Weakness Repeat
  • 515785 2024-005
    Significant Deficiency Repeat
  • 515786 2024-006
    Material Weakness
  • 515787 2024-007
    Material Weakness
  • 515788 2024-008
    Significant Deficiency
  • 1092213 2024-001
    Material Weakness Repeat
  • 1092214 2024-002
    Significant Deficiency
  • 1092215 2024-001
    Material Weakness Repeat
  • 1092216 2024-002
    Significant Deficiency
  • 1092217 2024-001
    Material Weakness Repeat
  • 1092218 2024-002
    Significant Deficiency
  • 1092219 2024-003
    Material Weakness Repeat
  • 1092220 2024-004
    Material Weakness Repeat
  • 1092221 2024-005
    Significant Deficiency Repeat
  • 1092222 2024-006
    Material Weakness
  • 1092223 2024-007
    Material Weakness
  • 1092224 2024-008
    Significant Deficiency
  • 1092225 2024-003
    Material Weakness Repeat
  • 1092226 2024-004
    Material Weakness Repeat
  • 1092227 2024-005
    Significant Deficiency Repeat
  • 1092228 2024-006
    Material Weakness
  • 1092229 2024-007
    Material Weakness
  • 1092230 2024-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.188 Housing Finance Agencies (hfa) Risk Sharing $315.42M
14.267 Continuum of Care Program $4.11M
14.195 Project-Based Rental Assistance (pbra) $3.69M
14.879 Mainstream Vouchers $2.03M
14.871 Section 8 Housing Choice Vouchers $1.85M
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $768,888
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $429,791
14.896 Family Self-Sufficiency Program $367,956
14.269 Hurricane Sandy Community Development Block Grant Disaster Recovery Grants (cdbg-Dr) $134,147
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $67,225
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $30,770