Finding 974409 (2023-001)

Finding No. 2023-001; Section 202 Supportive Housing for the Elderly, Assistance Listing 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 the following deficiency:  One out of eight existing tenants tested had EIVs that were performed outside of the 120- day EIV window.  One out of one new tenants tested had an initial EIV certification that was performed outside of the 90-day EIV window. Cause Management's policies with respect to 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 security deposits and 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 There are no questioned costs. Identification as a Repeat Finding This is a repeat finding. Recommendation Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, 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: Section 202 Supportive Housing for the Elderly program administration. Finding Resolution Status: Resolved. Views of Responsible Officials The inspection was conducted under previous management. The Franklin Johnston Group took over July 1st, 2023. The Franklin Johnston EIV policies and procedures require site staff to Run Existing tenant searches within 90 days prior to the move in date which is required to be uploaded to the assigned Compliance specialist for review prior to move in approvals. Although HUD requires quarterly reports, the new management require monthly. Site teams are only permitted to pull the “By Head of Household Report” at the time of recertification. 90- day EIV’s are to be ran within 90days of the anticipated voucher submission date. Site staff are required to go through our approval process, staff are not required to perform a move with without Compliance Approval. The Franklin Johnston performs quarterly audits to ensure that these processes are being followed along with ensuring that the files are being properly maintained. All site teams members have been trained as it relates to these policies. In addition to this training all site teams are required to attend monthly EIV training/Policies and procedures trainings according to HUD guidelines.