Finding Text
Assistance Listing Number, Federal Agency, and Program Name 14.267, U.S. Department of Housing and Urban Development, Continuum of Care Youth Transitional Program and Green Willow Project
Federal Award Identification Number and Year:
Youth Transitional Program: CO0059L8T032013 April 1, 2021 to March 31, 2022, CO0059L8T032215 April 1, 2023 to March 31, 2024.
Green Willow Project: CO0133L8T032005 September 1, 2021 to August 31, 2022 and COOl 33L8T032106 September 1, 2022 to August 31, 2023.
Pass through Entity:
Youth Transitional Program: N/A Direct
Green Willow Project: Family Tree, Inc.
Finding Type Significant deficiency
Repeat Finding No
Criteria Per 24 CFR 578.51(g), U.S. Department of Housing and Urban Development (HUD) will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.
Condition In a monitoring visit performed by HUD, the grantor found that rent reasonableness determination was not completed on five of the six files reviewed. In our testing we found that six of ten participants we tested did not have a rent reasonableness determination dated prior to the grant funds being expended.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context The Organization performs rent reasonableness determination for 35 individuals and families. The grantor found five instances where the Organization did not have completed documentation on file to support that the rent reasonableness determination was performed and we identified six such instances. The Organization was able to perform a determination for all current participants in the program to fulfill the required corrective action of this monitoring visit and proved that all rent charged was reasonable, creating no questioned costs.
Cause and Effect The Organization did not have completed documentation on file to support that a rent reasonableness test had been performed for the files reviewed, and the internal policy does not address how rent reasonableness will be performed and documented. The effect is that participants may be subject to unneeded current and future housing costs and the Organization may be ineffectively using HUD funds and inadvertently incur ineligible costs.
Recommendation The Organization should implement controls to ensure that a rent reasonableness determination is completed and retained for every participant. In addition, the Organization should ensure the appropriate policies are put in place to address rent reasonableness.
Views of Responsible Officials and Corrective Action Plan The Organization revised the program policy to compare the rent reasonableness of at least three similar units using the Rent Reasonableness Comparison worksheet before any lease up and document the test with evidence that is reviewed and verified with a supervisor signature prior to execution of the lease. The Organization will repeat this process annually as long as the participant remains in the same unit. The Organization also hired an extra full time program quality control staff to monitor the compliance with the procedures. Moreover, the Organization will have an internal audit by the finance department at the halfway point of the grant year.