Finding 520954 (2024-002)

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

AI Summary

  • Core Issue: The project did not meet the requirement that at least 40% of new tenants be extremely low-income families.
  • Impacted Requirements: Lack of documentation for marketing efforts aimed at extremely low-income families indicates insufficient internal controls.
  • Recommended Follow-Up: Management should update policies and procedures for tenant acceptance and marketing to align with HUD guidelines.

Finding Text

2024-002 – Eligibility Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Eligibility) Federal program U.S. Department of Housing and Urban Development · Section 8 Housing Assistance Payments (ALN# 14.195) Criteria. Under Section 8 of the National Housing Act of 1959, project management is required to ensure that during a fiscal year at least 40% of the units that become available, together with initial certifications of in-place tenants, serve extremely low-income families. If the Project has actively marketed available units to extremely low-income families and has been unable to achieve the 40% target for admissions and initial certifications, the Project is permitted to rent to other eligible families after a reasonable marketing period has expired. Condition. Less than 40% of tenants who moved into the property during the year met the extremely-low income threshold and management did not maintain records of marketing efforts targeted to extremely low-income families, demonstrating that reasonable efforts were made to fill available units accordingly and that such efforts are ongoing. 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, the Project failed to meet the prescribed income targeting requirements and documentation of marketing efforts to reach the target population. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that management revisit their current policies and procedures surrounding tenant acceptance and marketing efforts to ensure compliance with HUD policies. View of Responsible Officials. Management agrees with this comment and has prepared a corrective action plan.

Corrective Action Plan

Corrective Action Plan Orion Area Non-Profit Housing Corporation Project No. 044-11113 Year Ended June 30, 2024 January 31, 2025 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2024-002 – Eligibility - Tenant Income Threshold Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Section 8 Housing Assistance Payments (ALN# 14.195) Condition. Less than 40% of tenants who moved into the property during the year met the extremely low-income threshold and management did not maintain records of marketing efforts targeted to extremely low-income families, demonstrating that reasonable efforts were made to fill available units accordingly and that such efforts are ongoing. Effect. As a result of this condition, the Project failed to meet the prescribed income targeting requirements and documentation of marketing efforts to reach the target population. Plan. Management agrees with finding 2024-002. Management agrees to target extremely low-income individuals for residence, and to retain marketing records that support this effort. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: June 30, 2025

Categories

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

Other Findings in this Audit

  • 1097396 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $1.60M
14.195 Project-Based Rental Assistance (pbra) $351,932
14.191 Multifamily Housing Service Coordinators $26,274