Finding 555732 (2024-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-04-23
Audit: 354363
Organization: Manor Apartments, Inc. (MD)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: Tenant lease files were not maintained properly, leading to issues with timely use of the EIV system and accurate reporting on HUD Form 50059.
  • Impacted Requirements: Compliance with HUD Handbook 4350.3 was not consistently followed, risking eligibility determinations and potential errors in rent subsidies.
  • Recommended Follow-Up: Management should implement and monitor procedures to ensure accurate tenant eligibility and lease file maintenance in line with HUD guidelines.

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 7 tenants tested did not utilize the Enterprise Income Verification (EIV) system timely. 2 out of 7 tenants tested did not prepare the HUD Form 50059 timely. 1 out of 7 tenants tested did not have the accurate amount of adjusted annual income reported on HUD Form 50059. Cause The Project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines. Effect or Potential Effect The procedures for determining tenant security deposits and eligibility and maintaining tenant lease files were not consistently applied in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD. Questioned Costs None Context A sample of 7 tenant files from a population of 54 were selected. We identified exceptions in 3 out of the 7 files tested. The sample in not a statistically valid sample. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, 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: R - Section 8 program administration Finding Resolution Status: Resolved Views of Responsible Officials As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as implementing corporate compliance monitoring.

Corrective Action Plan

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

Categories

HUD Housing Programs Eligibility Subrecipient Monitoring

Other Findings in this Audit

  • 1132174 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $3.89M