Finding Text
Finding No. 2022-001; Federal Assistance Listing Number 14.157 Criteria Tenant lease files are required to be maintained and tenant eligibility determined in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Condition In connection with our lease file review, we noted: 1. One instance of one tenant tested where management did not maintain move-out inspection forms in the lease file. 2. One out of one tenant tested where income verification was not performed with the use of the HUD Enterprise Income Verification ("EIV") or other verification methods. 3. One out of two tenants tested where a recertification was not performed timely. Cause Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs were not consistently followed. Effect or Potential Effect The procedures for determining tenant recertification 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 N/A Context One of one instance where management did not maintain move-out inspection forms in the lease file, one of one tenant where income verification was not obtained, and one of two tenants' recertification was not performed timely. Identification as a Repeat Finding Yes Recommendation Management should establish procedures and monitor compliance with those procedures to insure that recertifications are performed timely and signed, 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, E-Eligibility for Uniform Guidance Finding Resolution Status: Unresolved Views of Responsible Officials and Planned Corrective Actions Due to either tenant non-compliance or challenges with scheduling meetings with tenants or obtaining verifications, some recertifications were completed late. REACH has policies in place to complete recertifications timely, and will be providing ongoing training and guidance to staff to make sure the policies are being followed. Management has a policy for conducting move-out inspections and completing the move-out form, and will review this policy and procedure with staff to make sure it?s followed on all move-outs.