Finding 564420 (2024-001)

Significant Deficiency Repeat Finding
Requirement
EN
Questioned Costs
-
Year
2024
Accepted
2025-06-11

AI Summary

  • Core Issue: Missing tenant documentation and expired certifications violate HUD regulations, impacting eligibility verification.
  • Impacted Requirements: Initial and ongoing tenant eligibility documentation, timely income verification via EIV, and annual recertification submissions.
  • Recommended Follow-Up: Ensure all required documents are collected and maintained, conduct timely inspections, and submit annual recertifications before expiration.

Finding Text

FINDING No. 2024-001: Project Based Rental Assistance Program, ALN 14.195 Finding Resolution Status: Unresolved. Information on Universe Population Size: One hundred and seventy-two tenants. Total assistance revenue. Sample Size Information: Twenty tenants. All monthly HAP requests. Identification of Repeat Finding and Finding Reference Number: Yes, 2023-001. Criteria: HUD regulations require all initial and ongoing tenant eligibility documentation to be appropriately executed and maintained. Additionally, HUD requires timely verification of the tenant’s current income through the use of Enterprise Income Verification (EIV) reports. As required by HUD regulations, annual recertification should be submitted in a timely manner to the regional HUD field office. Statement of Condition: Missing documentation in tenant files: • Thirteen tenant files were missing the initial EIV reports. • Three tenants files had tenant signed HUD-50059 forms signed by the tenant after the move in date. • Seven tenant files did not have an application stamp on the application for housing. • One tenant file was missing the application for housing form. • Two tenant files were missing the house rules. • One tenant file was missing the pet policy. • One tenant file was missing the bed bug policy. • Two tenant files had no tenant signatures on the pet policy. • Seven tenant files did not have the annual unit inspection dated. • One tenant file was missing the move in unit inspection. • Nine tenant files did not have the move in unit inspection dated. In addition, the Project requested rental assistance for tenants with expired annual certifications in TRACS. Cause: The manager did not perform and/or maintain appropriate tenant eligibility documentation in accordance with HUD requirements. Effect or Potential Effect: Improper maintenance of tenant files and not verifying tenant eligibility in accordance with HUD requirements can result in the cost of assistance and residency being disallowed. In addition, unable to determine date and time for the receipt of applications for proper waiting list placement and subsequent selection to occupy a unit. Furthermore, the Project is not in compliance with certain tenant requirements for submitting timely recertifications to the regional HUD field office resulting in withheld rental assistance. Auditor Non-Compliance Code: R – Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations will be adopted. Recommendation: The manager should verify eligibility by obtaining and maintaining all required documents for all tenants, maintain support for tenant income verification through the EIV system in a timely manner, and perform appropriate unit inspections. Furthermore, annual recertifications should be performed prior to expirations and transmitted to HUD through TRACS. Response Indicator: Agree Completion Date: 9/30/2025 Response: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures.

Corrective Action Plan

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Montgomery County, operating as Council House, respectfully submits the following corrective action plan for the year ended September 30, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: October 1, 2023 through September 30, 2024 The finding from the September 30, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2024-001: Project Based Rental Assistance Program, ALN 14.195 Recommendation: The manager should verify eligibility by obtaining and maintaining all required documents for all tenants, maintain support for tenant income verification through the EIV system in a timely manner, and perform appropriate unit inspections. Furthermore, annual recertifications should be performed prior to expirations and transmitted to HUD through TRACS. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

Categories

HUD Housing Programs Eligibility Reporting

Other Findings in this Audit

  • 1140862 2024-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.155 Mortgage Insurance for the Purchase Or Refinancing of Existing Multifamily Housing Projects $8.35M
14.195 Project-Based Rental Assistance (pbra) $2.14M