Finding 555736 (2024-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-04-23
Audit: 354365
Organization: Victory Heights, Inc. (MD)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: Tenant eligibility and lease file maintenance are not being managed properly, leading to potential compliance risks with HUD guidelines.
  • Impacted Requirements: Key procedures from HUD Handbook 4350.3 are not consistently followed, including move-in inspections and timely completion of Form 50059.
  • Recommended Follow-Up: Management should implement and monitor new procedures to ensure compliance with HUD requirements and address previous deficiencies.

Finding Text

Criteria Management is responsible for determining tenant eligibility and maintaining lease files 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 new tenants tested did not a have a move in inspection in their lease file. 7 out of 13 new and existing tenants tested did not utilize the Enterprise Income Verification (EIV) system. 5 out of 12 existing tenants tested did not complete the Form 50059 timely. 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 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. Questioned Costs None Context A sample of 13 tenant files from a population of 72 were selected. We identified exceptions in 7 out of the 13 files tested. The sample in not a statistically valid sample. Identification as a Repeat Finding Repeat finding of prior year finding 2023-002. 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: In-ProcessViews 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 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 and that a move-in inspection report was missing. 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

  • 555735 2024-001
    Significant Deficiency
  • 555737 2024-002
    Material Weakness Repeat
  • 555738 2024-003
    Significant Deficiency
  • 555739 2024-003
    Significant Deficiency
  • 1132177 2024-001
    Significant Deficiency
  • 1132178 2024-002
    Material Weakness Repeat
  • 1132179 2024-002
    Material Weakness Repeat
  • 1132180 2024-003
    Significant Deficiency
  • 1132181 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $7.77M
14.239 Home Investment Partnerships Program $4.25M