Finding Text
Criteria: Based on principles and guidance contained within the 2013 Internal Control?Integrated Framework as published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), management is responsible for the design, implementation and maintenance of internal controls over financial reporting with the objective that the financial statements are accurate under U.S. GAAP. As it relates to Assistance Listing Number 14.157 Supportive Housing for the Elderly (Section 202) Uniform Guidance requires that the owner is responsible for annually reexamining incomes of households occupying assisted units and making appropriate adjustments to the tenant payment and the project rental assistance payment in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 891.410(g)- Reexamination of household family income and composition - (1) Regular reexaminations. The Owner must reexamine the income and composition of the household at least every 12 months. Upon verification of the information, the Owner must make appropriate adjustments in the total tenant payment and must determine whether the household's unit size is still appropriate. The Owner must adjust tenant payment and the project rental assistance payment, and must carry out any unit transfer in accordance with HUD standards. As it relates to Assistance Listing Number 14.195 Section 8 Housing Assistance Payments Program Uniform Guidance requires that the Project reexamine family income and composition at least once every 12 months and adjust the total rent payment and housing assistance payment, as necessary in accordance with applicable federal laws, regulations, and standards identified in 24 CFR 880.603(c)- Reexamination of family income and composition - (1) Regular reexaminations. The owner must reexamine the income and composition of all families at least every 12 months. After consultation with the family and upon verification of the information, the owner must make appropriate adjustments in the Total Tenant Payment in accordance with part 5 of this title and determine whether the family's unit size is still appropriate. The owner must adjust Tenant Rent and the Housing Assistance Payment to reflect any change in Total Tenant Payment and must carry out any unit transfer required by HUD. Condition: During our review of eligibility testing support, we noted that for the tenant?s annual reexaminations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contact. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner?s Certification and Application for Housing Assistance Payments (HAP) for eight months of fiscal year 2022. Upon the Project?s analysis, it was determined that the total amount of the error, net of vacancies, was $37,585. Context: It was noted that the Project collected more money each month from HUD as a result of incorrectly including the utility allowance as part of the contract rent for eight months of fiscal year 2022. Effect: Incorrect rates were utilized to calculate the project tenant rental assistance payments. These incorrect rates were paid by HUD to the Project resulting in an overpayment of funds in the amount of $37,585. Cause: The Project relies heavily on a few key individuals to perform review of the tenant certifications and re-examinations. While this process of review did occur, the incorrect rents approved went undetected during the Project?s internal review process. Recommendation: We recommend that the Project establish procedures to ensure that there is a better process to check the amounts of contract rent being approved on the reexaminations and certifications of tenants. Additionally, we recommend that the monthly HAP forms are more closely reviewed by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan