Finding 520950 (2024-001)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-01-31

AI Summary

  • Core Issue: There are gaps in internal controls related to tenant file documentation, leading to noncompliance with HUD eligibility requirements.
  • Impacted Requirements: Key processes like running EIV checks, timely disbursing refunds, and verifying tenant asset balances were not consistently followed.
  • Recommended Follow-Up: Management should enhance policies, implement a documented review process for tenant files, and ensure compliance with HUD guidelines to prevent future issues.

Finding Text

2024-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Eligibility) Federal program U.S. Department of Housing and Urban Development · Supportive Housing for the Elderly (ALN# 14.157) Criteria. Under Section 202 of the National Housing Act of 1959, Project management is responsible for performing an examination of and obtaining support for items of income, assets, and expenses, for proper calculation of tenant assistance payments of applying residents, and annual recertification and calculation of such information thereafter, and for obtaining signed and properly completed forms. Condition. Out of a sample of six tenant files, we noted: 1) One out of six instances where an EIV was not run for a tenant file within 90 days of move in; 2) One out of six instances where a refund was not disbursed to a tenant within 60 days of move-out; 3) Two out of six instances where the incorrect checking account balance was used in the verification of tenant assets. Cause. Management does not appear to have sufficient internal control procedures in place to properly implement all of HUD's program requirements. Effect. As a result of this condition, employees did not follow HUD guideline procedures, and/or did not properly calculate the tenant subsidy in HUD Form 50059. While there were no significant differences in the amount of subsidies allowed compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, in as much as no unallowable expenditures were noted. Recommendation. We recommend that management should strengthen their current policies and follow a documented review process for all new and existing resident files and ensure that this review occurs on a timely basis. Further, we recommend that management ensure all proper HUD guideline procedures are followed, and tenant subsidies are appropriately calculated. View of Responsible Officials. Management agrees with this comment and has prepared a corrective action plan.

Corrective Action Plan

Corrective Action Plan East Detroit Area Non-Profit Housing Corporation Project No. 044-EH221 Year Ended June 30, 2024 January 31, 2025 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2024-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (ALN# 14.157) Condition. Out of a sample of 6 tenant files, it was noted: 1. One out of six instances where an EIV was not run for a tenant file within 90 days of move in; 2. One out of six instances where a refund was not disbursed to a tenant within 60 days of move-out; 3. Two out of six instances where the incorrect checking account balance was used in the verification of tenant assets; Effect. As a result of this condition, employees did not follow HUD guideline procedures, and/or did not properly calculate the tenant subsidy in HUD Form 50059. While there were no significant differences in the amount of subsidies allowed compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Plan. Management agrees with finding 2024-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: 1/31/2025

Categories

Allowable Costs / Cost Principles Eligibility HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 520951 2024-001
    Significant Deficiency Repeat
  • 520952 2024-002
    Significant Deficiency
  • 520953 2024-002
    Significant Deficiency
  • 1097392 2024-001
    Significant Deficiency Repeat
  • 1097393 2024-001
    Significant Deficiency Repeat
  • 1097394 2024-002
    Significant Deficiency
  • 1097395 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $361,969