Finding Text
During the procedures applied to a sample of eight tenant lease files, we noted the following instances of noncompliance with HUD regulations regarding tenant eligibility and the maintenance of lease files. The instances of noncompliance were isolated to six of the eight tenant files. 1. Five instances where the annual recertification process for a tenant was not performed in a timely manner.
2. Four instances where the EIV system report used for the annual recertification was not performed in a timely manner due to management not having access to the EIV system.
3. Five instances where a tenant's income/asset verification was not substantiated with the EIV system report. Criteria Management is responsible for determining tenant eligibility and maintaining lease files in accordance with HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs.
Cause
The Project failed to follow the policies and procedures which have been established for proper tenant file maintenance and determining tenant eligibility in accordance with HUD guidelines.
Effect or Potential Effect
Noncompliance with HUD guidelines could result in units being rented to ineligible tenants or errors in the rent subsidies paid by HUD.
Recommendation
Management should establish procedures and monitor compliance with those procedures to ensure that 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
Finding Resolution Status
In process Reporting Views of Responsible Officials Management was made aware of instances where timely recertifications were not being performed. To ensure these situations do not continue to occur, Management made the following improvements to their internal processes: 1. Recertification reminder letters are being consistently sent to residents at 120, 90, 60, and 30 days prior to recertification date.
2. Incentives were put in place to encourage site associates to complete recertification tasks timely including staff lunches. After working hour sessions are also being held.
3. Third party consultants are being utilized when necessary.
4. Site associates are going door to door and enlisting help from resident services teams to engage residents. Management is aware of the required use of the EIV system reports. Management believes the instance in which noncompliance occurred was due to lack of training and experience of certain individuals and has further addressed this condition by implementing additional training for all associates.