EIN: 251755544
UEI: M4APCNNHWHL5
Data as of August 26, 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 (396 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.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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