EIN: 042543731
UEI: DM9RFJEECP18
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 14, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 14, 2026 (43 days ago).
What is a management decision? →The Organization had cash balances that exceeded federally insured limits and management did not monitor or maintain documentation of the financial institutions’ ratings. Questioned costs: None. Context: The Organization had cash balances that exceeded federally insured limits. Controls to monitor and maintain documentation of the financial institutions’ ratings were not in place. The Organization’s cash is held at a financial institution that does not meet the minimum GNMA ratings. Cause: The cause of this issue was the absence of established procedures requiring periodic review of cash balances exceeding federally insured limits and the lack of a documented process for monitoring and retaining financial institution rating information. Effect: There were no negative effects on the Organization. Repeat finding: No. Recommendation: Funds should be transferred to a financial institution that meets minimum GNMA ratings and management should implement internal controls to monitor ratings on a quarterly basis for depositories where cash balances exceed FDIC limits and maintain that documentation for at least three years. Views of responsible officials: The Organization has maintained a strong partnership with our banking institution for several years, and this relationship continues to provide meaningful support to our residents and community. Management acknowledges that certain cash balances exceeded federally insured limits and that documentation of financial institution ratings was not consistently monitored or maintained. To address this, management will (1) evaluate opportunities to rebalance cash holdings to remain within insured limits where feasible, and (2) implement a formal process to review, document, and retain financial institution credit ratings on at least a quarterly basis. This process will be incorporated into the Organization’s ongoing treasury and risk-management procedures to ensure compliance going forward.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 223(f) Mortgage Insurance for the Purchase or Refinance of Existing Multifamily Housing Projects Assistance Listing Number: 14.155 Award Period: October 1, 2024 through September 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: HUD guidelines require cash to be maintained in financial institutions which meet minimum GNMA ratings when balances exceed federally insured limits. Financial institution ratings are to be monitored by management on a quarterly basis and documentation maintained for at least three years as required by the HUD Handbook 4350.1. Condition: The Organization had cash balances that exceeded federally insured limits and management did not monitor or maintain documentation of the financial institutions’ ratings. Questioned costs: None. Context: The Organization had cash balances that exceeded federally insured limits. Controls to monitor and maintain documentation of the financial institutions’ ratings were not in place. The Organization’s cash is held at a financial institution that does not meet the minimum GNMA ratings. Cause: The cause of this issue was the absence of established procedures requiring periodic review of cash balances exceeding federally insured limits and the lack of a documented process for monitoring and retaining financial institution rating information. Effect: There were no negative effects on the Organization. Repeat finding: No. Recommendation: Funds should be transferred to a financial institution that meets minimum GNMA ratings and management should implement internal controls to monitor ratings on a quarterly basis for depositories where cash balances exceed FDIC limits and maintain that documentation for at least three years. Views of responsible officials: The Organization has maintained a strong partnership with our banking institution for several years, and this relationship continues to provide meaningful support to our residents and community. Management acknowledges that certain cash balances exceeded federally insured limits and that documentation of financial institution ratings was not consistently monitored or maintained. To address this, management will (1) evaluate opportunities to rebalance cash holdings to remain within insured limits where feasible, and (2) implement a formal process to review, document, and retain financial institution credit ratings on at least a quarterly basis. This process will be incorporated into the Organization’s ongoing treasury and risk-management procedures to ensure compliance going forward.
Condition: The Organization had cash balances that exceeded federally insured limits, and management did not monitor or maintain documentation of the financial institutions’ ratings Criteria: HUD guidelines require cash to be maintained in financial institutions that meet minimum GNMA ratings when balances exceed federally insured limits. Financial institution ratings are to be monitored by management on a quarterly basis, and documentation is to be maintained for at least three years as required by the HUD handbook 4350.1 Cause: The cause of this issue was the absence of established procedures requiring periodic review of cash balances exceeding federally insured limits and the lack of a documented process for monitoring and retaining financial institution rating information. Effect: There were no negative effects on the Organization. Action Plan: The Organization has maintained a strong partnership with our banking institution for several years, and this relationship continues to provide meaningful support to our residents and community. Management acknowledges that certain cash balances exceeded federally insured limits and that documentation of financial institution ratings was not consistently monitored or maintained. To address this, management will (1) evaluate opportunities to rebalance cash holdings to remain within insured limits where feasible, and (2) implement a formal process to review, document, and retain financial institution credit ratings on at least a quarterly basis. This process will be incorporated into the Organization’s ongoing treasury and risk-management procedures to ensure compliance going forward.
The Organization’s fidelity bond was below the requirement for the period under audit. Questioned costs: None. Context: The Organization’s resident service revenue increased in the current year to an amount that is higher than historical fidelity bond coverage. Cause: Following completion of the 2025 Mark-to-Market process for HRCA Housing for Elderly Inc., we failed to update our fidelity bond coverage to reflect the revised requirements. Effect: There were no negative effects on the Organization. Repeat finding: No. Recommendation: We recommend that the Organization obtain the requisite fidelity bond coverage and to monitor the coverage to ensure it is in compliance with HUD requirements. Views of responsible officials: Once the finding was identified, we immediately contacted our insurance broker and requested an increase to the fidelity bond coverage. The bond has since been raised to a $2M limit, and the updated policy became effective on 11/14/25. Going forward, the fiscal team will incorporate an annual verification of bond coverage into its routine monitoring procedures to ensure timely updates after significant organizational or regulatory changes. In addition, we are implementing an internal audit component to enhance our review of all HUD requirements. This added oversight will help mitigate future risk and ensure continued compliance with all applicable regulations
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 223(f) Mortgage Insurance for the Purchase or Refinance of Existing Multifamily Housing Projects Assistance Listing Number: 14.155 Award Period: October 1, 2024 through September 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: HUD requires the Organization to maintain fidelity bond coverage of at least two months cash collections. Condition: The Organization’s fidelity bond was below the requirement for the period under audit. Questioned costs: None. Context: The Organization’s resident service revenue increased in the current year to an amount that is higher than historical fidelity bond coverage. Cause: Following completion of the 2025 Mark-to-Market process for HRCA Housing for Elderly Inc., we failed to update our fidelity bond coverage to reflect the revised requirements. Effect: There were no negative effects on the Organization. Repeat finding: No. Recommendation: We recommend that the Organization obtain the requisite fidelity bond coverage and to monitor the coverage to ensure it is in compliance with HUD requirements. Views of responsible officials: Once the finding was identified, we immediately contacted our insurance broker and requested an increase to the fidelity bond coverage. The bond has since been raised to a $2M limit, and the updated policy became effective on 11/14/25. Going forward, the fiscal team will incorporate an annual verification of bond coverage into its routine monitoring procedures to ensure timely updates after significant organizational or regulatory changes. In addition, we are implementing an internal audit component to enhance our review of all HUD requirements. This added oversight will help mitigate future risk and ensure continued compliance with all applicable regulations
Criteria: HUD requires the Organization to maintain fidelity bond coverage of at least two months' cash collections Cause: Following completion of the 2025 Mark-to-Market process for HRCA Housing for Elderly Inc., we failed to update our fidelity bond coverage to reflect the revised requirements. Action Plan: Once the finding was identified, we immediately contacted our insurance broker and requested an increase to the fidelity bond coverage. The bond has since been raised to a $2M limit, and the updated policy became effective on 11/14/25. Going forward, the fiscal team will incorporate an annual verification of bond coverage into its routine monitoring procedures to ensure timely updates after significant organizational or regulatory changes. In addition, we are implementing an internal audit component to enhance our review of all HUD requirements. This added oversight will help mitigate future risk and ensure continued compliance with all applicable regulations.
FAC accepted this audit on January 9, 2023 — management decision was due July 9, 2023.
A separated employee's earned time was paid out at the incorrect pay rate in error, resulting in an overpayment to the employee. Questioned costs: $18,048 Context: The error impacted one employee and appears to be an isolated incident. Cause: As part of the separated employee?s transition, the separated employee agreed to stay on and work on a per diem basis at a higher hourly rate. The employee?s hourly rate had been updated in the human resources information system prior to the earned time pay out. The earned time pay outs hours was then processed with the new hourly rate. As the total hours to be paid out was validated, the new rate was over looked, thus resulting in the separated employee being overpaid. This was caught by management subsequently after the pay-out as part of their monthly review and import into Yardi. Effect: An overpayment of $18,048 was made and is owed to the Organization by the employee as of the fiscal year end. Repeat Finding: No Recommendation: Management should review its internal control procedures to ensure proper oversight over the payroll disbursement process surrounding earned time payouts. View of responsible officials and planned corrective actions: In agreement with the finding. Upon realization of the overpayment, Human Resource (HR) and Payroll have developed a new process where the hourly rates are to be verified and validated for all employees that stay employed but are no longer eligible to accrue earned time, thus requiring their earned time to be paid out. On the bi-weekly HR changes worksheet, HR will denote what the hourly rate should be upon pay out of the earned time. Payroll will then cross-check the hourly rate and the earned time hours prior to processing payroll.
Show full finding ▾Hide full finding ▴2022 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Housing Assistance Payments Program Assistance Listing Number: 14.195 Contract Number: MA060470201 Award Period: October 1, 2021 through September 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Disbursements should be only for allowable expenses of the Project. Condition: A separated employee's earned time was paid out at the incorrect pay rate in error, resulting in an overpayment to the employee. Questioned costs: $18,048 Context: The error impacted one employee and appears to be an isolated incident. Cause: As part of the separated employee?s transition, the separated employee agreed to stay on and work on a per diem basis at a higher hourly rate. The employee?s hourly rate had been updated in the human resources information system prior to the earned time pay out. The earned time pay outs hours was then processed with the new hourly rate. As the total hours to be paid out was validated, the new rate was over looked, thus resulting in the separated employee being overpaid. This was caught by management subsequently after the pay-out as part of their monthly review and import into Yardi. Effect: An overpayment of $18,048 was made and is owed to the Organization by the employee as of the fiscal year end. Repeat Finding: No Recommendation: Management should review its internal control procedures to ensure proper oversight over the payroll disbursement process surrounding earned time payouts. View of responsible officials and planned corrective actions: In agreement with the finding. Upon realization of the overpayment, Human Resource (HR) and Payroll have developed a new process where the hourly rates are to be verified and validated for all employees that stay employed but are no longer eligible to accrue earned time, thus requiring their earned time to be paid out. On the bi-weekly HR changes worksheet, HR will denote what the hourly rate should be upon pay out of the earned time. Payroll will then cross-check the hourly rate and the earned time hours prior to processing payroll.
U.S. Department of Housing and Urban Development 2022-001: Section 8 Housing Assistance Payments Program ? Assistance Listing No. 14.195 Recommendation: Management should review its internal control procedures to ensure proper oversight over the payroll disbursement process surrounding earned time payouts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon realization of the overpayment, Human Resource (HR) and Payroll have developed a new process where the hourly rates are to be verified and validated prior to the processing of an earned time payout. This process is for all employees that remain employed but are no longer eligible to accrue earned time, thus requiring their earned time to be paid out. On the bi-weekly HR changes worksheet, HR will denote what the hourly rate should be upon pay out of the earned time. Payroll will then cross-check the hourly rate and the earned time hours prior to processing payroll. Name(s) of the contact person(s) responsible for corrective action: Jonathan Allia, Vice President of Finance Planned completion date for corrective action plan: August 1, 2022 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Jonathan Allia, Vice President of Finance at 617-971-5762.
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