EIN: 251672175
UEI: DCL3ZY6HCUZ4
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 27, 2025. 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 27, 2025 (391 days ago).
What is a management decision? →During the audit, we found the Project may not have adequate internal controls over tenant eligibility determination process process that at a minimum, would satisfactorily achieve federal statutory, regulatory, and Handbook requirements, including a lack of supervisory review of tenant certifications and a lack of documented staff training. Criteria: In accordance with HUD Handbook 4350.3, management agents of HUD-assisted properties are required to ensure all applicants meet eligibility criteria for income and other program requirements. Effective internal controls, including supervisory review, segregation of duties, and staff training are necessary to verify tenant eligibility accurately and ensure compliance with HUD regulations. Effect of Condition: Without adequate internal controls, there is a risk that ineligible tenants may receive assistance, which could lead to noncompliance with HUD regulations. Cause of Condition: The lack of internal controls was due to the absence of standard procedures for review of tenant certification and documentation of HUD-specific staff training. Recommendation: We recommend that management develop and implement formal policies and procedures for tenant eligibility determination to be consistent with HUD Handbook 4350.3, including steps for initial eligibility verification which would include a supervisory review process. We also recommend that staff attend HUD-specific training upon hire and then annually to ensure that adequate knowledge of HUD regulations is maintained. Documentation of this training, including certificates of completion, should be kept on file. Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-001 – Supportive Housing for Elderly Persons ALN 14.157 Statement of Condition: During the audit, we found the Project may not have adequate internal controls over tenant eligibility determination process process that at a minimum, would satisfactorily achieve federal statutory, regulatory, and Handbook requirements, including a lack of supervisory review of tenant certifications and a lack of documented staff training. Criteria: In accordance with HUD Handbook 4350.3, management agents of HUD-assisted properties are required to ensure all applicants meet eligibility criteria for income and other program requirements. Effective internal controls, including supervisory review, segregation of duties, and staff training are necessary to verify tenant eligibility accurately and ensure compliance with HUD regulations. Effect of Condition: Without adequate internal controls, there is a risk that ineligible tenants may receive assistance, which could lead to noncompliance with HUD regulations. Cause of Condition: The lack of internal controls was due to the absence of standard procedures for review of tenant certification and documentation of HUD-specific staff training. Recommendation: We recommend that management develop and implement formal policies and procedures for tenant eligibility determination to be consistent with HUD Handbook 4350.3, including steps for initial eligibility verification which would include a supervisory review process. We also recommend that staff attend HUD-specific training upon hire and then annually to ensure that adequate knowledge of HUD regulations is maintained. Documentation of this training, including certificates of completion, should be kept on file. Response: See Corrective Action Plan.
We concer with the auditors' finding that the project did not have adequate internal controls in place over tenant eligbility determination process per HUD's guidelines. While HANDS has internal policies and procedures for review of tenant certifications, the compliance position has been vacant and never properly functioned as it should. The CEO, Matthew Good, and the Director of Community Management, Cathy Consilgio, had decided prior to the audit engagement that a third party would be contracted to review applicant files prior to move-in for all HUD subsidized properties. (We have used AJ Johnson to review/approve LIHTC/HOME files for several years.) Employee training had been put on hold due to the upcoming HOTMA changes, and as the dates for HOTMA were pushed, training lagged. Our policy is as follows: once a new hire Property Manager or Assistant Property Manager completes the initial 90-day probationary period, they will be scheduled for formal HUD occupany training, and formal LIHTC training if it applies to their portfolio. Current employes will receive training bi-annually, which may include training that occures during the PAHMA conferences. All employes receive Fair Housing Training at least bi-annually, with new employees being scheduled for the first available training after their initial 90-day probationary period. The tracking sheet will be updated as training occurs, and any certificates earned will be kept on file.
FAC accepted this audit on January 29, 2023 — management decision was due July 29, 2023.
The Project did not remit residual receipts balances in excess of $250 per unit to HUD by the Project Rental Assistance Contract renewal date. Criteria: Pursuant to statutory language from the Consolidated and Further Continuing Appropriations Act, HUD is required to recapture residual receipt balances that are in excess of $250 per unit. The fund must be remitted to HUD upon ?termination? of the Project Rental Assistance Contract. Termination is defined as expiration of the contract term, which for most PRACs falls on contract renewal date. Effect of Condition: This is a violation of the HUD Regulations. Cause of Condition: The procedures in place to ensure the excess residual receipts remittance was made timely were not consistently followed. Recommendation: No action is needed, as the required return of excess residual receipts has already been remitted to HUD. Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-01 ? Supportive Housing for Disabled Persons, ALN #14.181 Statement of Condition: The Project did not remit residual receipts balances in excess of $250 per unit to HUD by the Project Rental Assistance Contract renewal date. Criteria: Pursuant to statutory language from the Consolidated and Further Continuing Appropriations Act, HUD is required to recapture residual receipt balances that are in excess of $250 per unit. The fund must be remitted to HUD upon ?termination? of the Project Rental Assistance Contract. Termination is defined as expiration of the contract term, which for most PRACs falls on contract renewal date. Effect of Condition: This is a violation of the HUD Regulations. Cause of Condition: The procedures in place to ensure the excess residual receipts remittance was made timely were not consistently followed. Recommendation: No action is needed, as the required return of excess residual receipts has already been remitted to HUD. Response: See Corrective Action Plan.
Comment on Findings and Recommendations: We concur with the auditor's finding that the balance in the excess residual receipts was above the limit allowed by HUD and was not remitted per HUD's guidelines. Action Taken or Planning: The Director of Accounting will review the Residual Receipts balance, determine amount eligible for retainage and return the remainder to HUD in accordance with current regulations.
FAC accepted this audit on January 25, 2022 — management decision was due July 25, 2022.
The Project did not make the full residual receipts (surplus cash) deposit from the fiscal year-end September 30, 2020. Criteria: Per the Project?s Regulatory Agreement, the Project is required to deposit residual receipts (surplus cash) with 90 days after the end of the fiscal year-end. Effect of Condition: This is a violation of the Regulatory Agreement entered into with HUD. Cause of Condition: The procedures in place to ensure the residual receipts deposit was made were not followed. Recommendation: No action is needed, as the required return of excess residual receipts was made in April 2021, therefore no deposit is necessary at this time. Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2021-01 ? Supportive Housing for Disabled Persons, CFDA #14.181 Statement of Condition: The Project did not make the full residual receipts (surplus cash) deposit from the fiscal year-end September 30, 2020. Criteria: Per the Project?s Regulatory Agreement, the Project is required to deposit residual receipts (surplus cash) with 90 days after the end of the fiscal year-end. Effect of Condition: This is a violation of the Regulatory Agreement entered into with HUD. Cause of Condition: The procedures in place to ensure the residual receipts deposit was made were not followed. Recommendation: No action is needed, as the required return of excess residual receipts was made in April 2021, therefore no deposit is necessary at this time. Response: See Corrective Action Plan.
WE CONCUR WITH THE AUDITORS' FINDING THAT THE PROJECT DID NOT MAKE THE FULL RESIDUAL RECEIPTS (SURPLUS CASH) DEPOSIT WITHIN 90 DAYS OF THE SEPTEMBER 30, 2020 FISCAL YEAR END. THE DIRECTOR OF ACCOUNTING AND THE PROPERTY ACCOUNTANT WILL REVIEW AND VERIFY THE BALANCE OF THE PROJECT'S SURPLUS CASH AND ENSURE THE RESIDUAL RECEIPTS DEPOSIT IS MADE WITHIN 90 DAYS OF THE FISCAL YEAR END IN ACCORDANCE WITH CURRENT REGULATIONS.
FAC accepted this audit on January 27, 2021 — management decision was due July 27, 2021.
The balance of the tenant deposits held in trust asset account does not equal or exceed the balance in the tenant deposits held in trust liability account. Criteria: The balance of the tenant deposits held in trust asset account should always be equal to or exceed the balance in the tenant deposits held in trust liability account. Effect of Condition: This is a violation of the Regulatory Agreement entered into with HUD. Cause of Condition: The procedures in place to ensure that all tenant deposits held in trust are deposited into the correct account were not followed. A portion of a tenant deposit held in trust was included in the operating cash account at year end. Recommendation: Tenant deposits held in trust should be reconciled monthly to ensure that the tenant deposit held in trust asset account is equal to or exceeds the tenant asset deposits held in trust liability account.
Show full finding ▾Hide full finding ▴2020-001 ? Supportive Housing for Disabled Persons, CFDA #14.181 Statement of Condition: The balance of the tenant deposits held in trust asset account does not equal or exceed the balance in the tenant deposits held in trust liability account. Criteria: The balance of the tenant deposits held in trust asset account should always be equal to or exceed the balance in the tenant deposits held in trust liability account. Effect of Condition: This is a violation of the Regulatory Agreement entered into with HUD. Cause of Condition: The procedures in place to ensure that all tenant deposits held in trust are deposited into the correct account were not followed. A portion of a tenant deposit held in trust was included in the operating cash account at year end. Recommendation: Tenant deposits held in trust should be reconciled monthly to ensure that the tenant deposit held in trust asset account is equal to or exceeds the tenant asset deposits held in trust liability account.
Comment on Findings and Recommendations: We concur with the auditor's finding that the balance in the security deposit asset account was less than the security deposit liability on September 30, 2020. Actions Taken or Planned: The Property Manager and Property Accountant will review and verify tenant account activity on a monthly basis to ensure that ledgers are correct and all security deposits received are deposited in a timely manner. The Director of Community Management and Director of Accounting will perform and internal audit on a regular basis to ensure compliance with stated policy and procedure.
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