Finding Text
Finding 2022-002: Tenant Eligibility - Material Weakness Repeat of prior year finding 2021-001 Assistance Listing Number: 14.181 Federal Agency: U.S. Department of Housing and Urban Development Federal Award Number: Not applicable Federal Award Year: July 1, 2021 - June 30, 2022 Pass-Through Entity: Not applicable Criteria: Section 811 of the National Affordable Housing Act provides funding for housing for persons with disabilities. To qualify as disabled, the household must consist of at least one person who is an adult (18 years or older) with a disability, two or more persons with disabilities living together, or a surviving household member under certain circumstances (42 USC 1437a(b)(3); 24 CFR section 891.505). Residents must also qualify as very low-income households to be eligible (42 USC 8013). Eligibility is only determined at move-in or at initial certification except in circumstances whereas family composition changes after initial occupancy a determination must be made as to whether the remaining member of the household will be eligible to receive assistance. Eligibility requirements are found in HUD?s regulations at 24 CFR Part 5. The Corporation is responsible for annually reexamining incomes of households occupying assisted units and make appropriate adjustments to the tenant payment and the project rental assistance payment (24 CFR section 891.410). Assistance applicants shall submit signed consent forms upon initial application and at reexamination (24 CFR section 5.230). Questioned Cost: None reported Condition/Context: We identified a lack review and maintenance of tenant file documentation for eligibility requirements including documentation of a signed lease, asset verification, income verification, medical expense support, and an accurate wait-list. Our population included all tenants. Two of two tenant files reviewed were missing required support. This was not a statistically valid sample. Cause: Lack of management oversight due to turnover. Effect: Insufficient documentation of tenant eligibility. Similar issues over tenant recertification has caused delays in obtaining renewal of the Corporation?s PRAC contract. As a result of not renewing the PRAC contract timely there were operating cash flow deficiencies resulting in significant growth in related party balances due to the parent entity and unpaid subsidies at June 30,2022. Recommendation: The Corporation should have procedures in place to ensure documentation is maintained accordance with its requirements.