Finding 571351 (2023-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2025-07-15
Audit: 362297
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: Eight housing units failed to undergo required HUD Housing Quality Standards (HQS) inspections in 2023, indicating a significant compliance gap.
  • Impacted Requirements: The lack of inspections violates HUD's regulations for maintaining property standards during the affordability period.
  • Recommended Follow-Up: Management must implement procedures to ensure timely inspections and address any compliance issues promptly, especially for properties managed by third parties.

Finding Text

Finding No. 2023-001 - Uniform Guidance Compliance Requirement Code: N-Special Tests and Provisions - Significant Deficiency HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 HOME Investment Partnership Program Entity Identifying Number Initial year Finding instances Passed-through City of Portland, Portland Housing Bureau: Allen Freemont 3110013 2015 1 Passed-through State of Washington: Cascadia Village - HUD 02-40420-008 2002 1 Addy Street - HUD 09-47104-001 2009 1 Passed-through Clark County: Covington Commons - HUD 2011-HOME-11H01 2011 2 Addy Street - HUD 2008-HOME-08H15 2008 1 McCallister Village (Fruit Valley) 2010-HOME-0H0 2010 1 Passed-through City of Vancouver: McCallister Village (Fruit Valley) 2010-HOME-601002 2010 1 Total instances 8 Criteria During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Condition The owner did not ensure passing HQS inspections were performed during 2023. Cause Management did not have in place proper procedures and controls to ensure that HQS inspections were performed during the year ended December 31, 2023. Effect or Potential Effect Housing units may be out of compliance with HUD Quality Standards. Questioned Costs: Not applicable. Context In connection with the procedures applied to tenant file testing there were 8 instances of the 8 files tested where the passing HQS inspections were not performed during the year ended December 31, 2023. Repeat Finding: Yes - Finding 2022-001 Recommendation Management should ensure that all units are inspected timely, that they meet the HUD Housing Quality Standards and that the responses to any findings are cleared timely. Views of Responsible Officials REACH did return to doing HQS Inspections in 2023. With staffing shortages, it is possible that not every unit was inspected in 2023. REACH continued to reestablish our annual unit inspection process post COVID in 2024. For the finding related to Addy St. This property is managed by a third party management company, REACH's Asset Management team will work with the management company to ensure all inspections are happening.

Corrective Action Plan

Finding No. 2023-001 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Uniform Guidance Compliance Requirement Code: N-Special Tests and Provisions Criteria During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant- based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Condition The owner did not ensure passing HQS inspections were performed during 2023. Cause Management did not have in place proper procedures and controls to ensure that HQS inspections were performed during the year ended December 31, 2023. Effect or Potential Effect Housing units may be out of compliance with HUD Quality Standards. Questioned Costs: Not applicable. Context In connection with the procedures applied to tenant file testing there were 8 instances of the 8 files tested where the passing HQS inspections were not performed during the year ended December 31, 2023. Repeat Finding: Yes - Finding 2022-001 Recommendation Management should resume making sure all units meet the HUD Housing Quality Standards and ensure that the responses to any findings are cleared timely. Views of Responsible Officials REACH did return to doing HQS Inspections in 2023. With staffing shortages, it is possible that not every unit was inspected in 2023. REACH continued to reestablish our annual unit inspection process post COVID in 2024. For the finding related to Addy St. This property is managed by a 3rd party management company, REACH’s Asset Management team will work with the management company to ensure all inspections are happening.

Categories

Special Tests & Provisions HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 571352 2023-002
    Significant Deficiency Repeat
  • 571353 2023-003
    Significant Deficiency Repeat
  • 571354 2023-004
    Significant Deficiency
  • 571355 2023-005
    Significant Deficiency
  • 571356 2023-006
    Significant Deficiency Repeat
  • 571357 2023-007
    Significant Deficiency
  • 1147793 2023-001
    Significant Deficiency Repeat
  • 1147794 2023-002
    Significant Deficiency Repeat
  • 1147795 2023-003
    Significant Deficiency Repeat
  • 1147796 2023-004
    Significant Deficiency
  • 1147797 2023-005
    Significant Deficiency
  • 1147798 2023-006
    Significant Deficiency Repeat
  • 1147799 2023-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $1.76M
14.275 Housing Trust Fund $1.63M
99.999 Low Income Housing Preservation and Resident Homeownership Act of 1990-Capital Grant $964,955
14.195 Section 8 Housing Assistance Payments Program $536,176
14.155 Mortgage Insurance for the Purchase Or Refinancing of Existing Multifamily Housing Projects $527,343
21.000 Section 607(e ) of the Neighborhood Reinvestment Corporation Act, As Amended $432,750
14.241 Housing Opportunities for Persons with Aids $380,000
14.239 Home Investment Partnerships Program $214,929