Finding Text
Finding No. 2023-003
Condition – In September 2023, HUD suspended its HAP subsidy to the Organization due to
noncompliance regarding the tenant recertifications requirements under the HAP Contract.
Criteria – Occupancy personnel are expected to have a strong knowledge of the various compliance
requirements regarding tenant recertifications. Controls should be in place to ensure noncompliance is
detected and corrected on a timely basis.
Cause – The system of quality review that was in place was not sufficient to detect all instances of
noncompliance with file documentation.
Effect – There is a possibility that, under the HAP Contract, HUD may invoke any remedies available by
law to redress the breach or compel compliance by the Organization with the tenant recertification
requirements.
Recommendation – We recommend that control systems are put in place to ensure there are regular reviews
of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures
to eliminate errors and issues of noncompliance in the future.
Auditor noncompliance code – S – Internal Control Deficiencies
Reporting views of responsible officials - Management understands the importance of the matter and the
issues that arise if tenant recertifications are not completed. The circumstances surrounding the
noncompliance related to tenant recertifications were reviewed, and a procedural change has been
implemented.
Concur or do not concur with this finding - Concur
Agree or disagree with auditor recommendations – Agree
Completion date or proposed completion date – December 18, 2024
Actions taken or planned on the finding – The Organization will implement procedures to ensure the
management agent complies with the tenant recertification requirements.