EIN: 273561703
UEI: WBJ5AQGTJHH6
Audited by: Mahoney Ulbrich Christiansen & Russ, PA
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 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 October 14, 2026 (38 days from today).
What is a management decision? →FAC accepted this audit on April 14, 2026 — management decision was due October 14, 2026.
2024-001 - Income Certifications Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Eligibility Criteria - The Compliance Supplement requires Owners inform tenants, through written notices, about the tenants’ responsibility to provide information necessary to complete annual recertifications. Owners must conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants’ rents and assistance payments, if applicable, based on the information gathered. Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Context - Of the total population of 47 units, 5 were tested. Two units selected for testing at this property resulted in noncompliance. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand the finding to be prevalent at the Corporation throughout the year. Cause - Inexperienced site employees and changes in procedures for processing tenant files which resulted in numerous failures to timely complete the required annual recertifications. The Corporation has changed management companies to assist in this matter. Effect - The Corporation was not in compliance with the Compliance Supplement. In addition, rental assistance may be delayed and changes in rental assistance will be effective from the tenants’ annual recertification dates. Any changes in the tenant portion of rent may not take effect until the annual recertifications are complete and may result in a loss of rent. Identification of repeat finding - Yes Recommendation - Site managers should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. In addition, procedures should be put in place to ensure recertifications continue to be completed when site staff turns over at properties. Management should continue to monitor site staffing and ensure procedures are in-place as back up for site staffing shortages. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding. The Corporation has changed management agent to Tapestry which has a compliance department to assist site staff in completing tenant recertifications.
Show full finding ▾Hide full finding ▴2024-001 - Income Certifications Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Eligibility Criteria - The Compliance Supplement requires Owners inform tenants, through written notices, about the tenants’ responsibility to provide information necessary to complete annual recertifications. Owners must conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants’ rents and assistance payments, if applicable, based on the information gathered. Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Context - Of the total population of 47 units, 5 were tested. Two units selected for testing at this property resulted in noncompliance. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand the finding to be prevalent at the Corporation throughout the year. Cause - Inexperienced site employees and changes in procedures for processing tenant files which resulted in numerous failures to timely complete the required annual recertifications. The Corporation has changed management companies to assist in this matter. Effect - The Corporation was not in compliance with the Compliance Supplement. In addition, rental assistance may be delayed and changes in rental assistance will be effective from the tenants’ annual recertification dates. Any changes in the tenant portion of rent may not take effect until the annual recertifications are complete and may result in a loss of rent. Identification of repeat finding - Yes Recommendation - Site managers should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. In addition, procedures should be put in place to ensure recertifications continue to be completed when site staff turns over at properties. Management should continue to monitor site staffing and ensure procedures are in-place as back up for site staffing shortages. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding. The Corporation has changed management agent to Tapestry which has a compliance department to assist site staff in completing tenant recertifications.
Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Eligibility Name of contact person – Nation Wright, AICDC Chief Operating Officer Corrective action – The Corporation has changed management agent to Tapestry which has a compliance department to assist site staff in completing tenant recertifications. Completion date – Management and the Board of Directors implemented the above as of December 2024.
2023-001
2024-002 - Replacement Reserve Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Special Tests and Provisions Criteria - The Regulatory Agreement requires that 12 monthly deposits be made to the replacement reserve. Condition - The Corporation did not make the monthly required deposits from September through December 2024. Context - The Corporation made 8 out of 12 monthly deposits. Cause - The change in management agent in September 2024 caused the delinquent deposits. Effect - The replacement reserve account was not adequately funded at year end, and the Corporation was not in compliance with the Regulatory Agreement. Identification of repeat finding - No Recommendation - The Corporation should make a deposit in the amount of $11,680 to adequately fund the replacement reserve. View of responsible officials and planned corrective actions - The Corporation agrees with the finding. The Corporation changed the management agent to Tapestry and a deposit of $11,680 was made on January 9, 2025 to properly fund the replacement reserve.
Show full finding ▾Hide full finding ▴2024-002 - Replacement Reserve Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Special Tests and Provisions Criteria - The Regulatory Agreement requires that 12 monthly deposits be made to the replacement reserve. Condition - The Corporation did not make the monthly required deposits from September through December 2024. Context - The Corporation made 8 out of 12 monthly deposits. Cause - The change in management agent in September 2024 caused the delinquent deposits. Effect - The replacement reserve account was not adequately funded at year end, and the Corporation was not in compliance with the Regulatory Agreement. Identification of repeat finding - No Recommendation - The Corporation should make a deposit in the amount of $11,680 to adequately fund the replacement reserve. View of responsible officials and planned corrective actions - The Corporation agrees with the finding. The Corporation changed the management agent to Tapestry and a deposit of $11,680 was made on January 9, 2025 to properly fund the replacement reserve.
Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Special Tests and Provisions Name of contact person – Nation Wright, AICDC Chief Operating Officer Corrective action – The Corporation changed the management agent to Tapestry and a deposit of $11,680 was made on January 9, 2025 to properly fund the replacement reserve. Completion date – Management and the Board of Directors implemented the above as of January 2025.
2024-003 - Cash Disbursements Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Cash Management Criteria - The HUD audit guide requires that all disbursements from the regular operating account must be supported by approved invoices, bills, or other supporting documentation and be in the name of the Project. Condition - The Corporation made several payments without having proper documentation and also made one payment not in the name of the Project. Context - Of the total population of 12 months of disbursements, 40 were tested. One invoice was not in the name of the Project and 3 disbursements did not have proper documentation for the payment. Based on our sample, inquiry of employees, we understand the finding to be prevalent at the Corporation throughout the year. Cause - The previous management agent chose to pay the invoices without proper documentation. Effect - We are unable to determine if the expenditures are in compliance with the Regulatory Agreement and also the Corporation had $128 less of operating cash due to paying an invoice not the Project’s name. Identification of repeat finding - No Recommendation - The Corporation should only make disbursements when there is proper documentation supporting the disbursement. View of responsible officials and planned corrective actions - The Corporation agrees with the finding and believes the new management agent has the procedures and controls in place to detect and prevent a similar finding to occur in the future. 2023-001 - Income Certifications Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Eligibility Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Recommendation - Site managers should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. In addition, procedures should be put in place to ensure recertifications continue to be completed when site staff turns over at properties. Management should continue to monitor site staffing and ensure procedures are in-place as back up for site staffing shortages. Status - Not corrected. Repeat finding in 2024
Show full finding ▾Hide full finding ▴2024-003 - Cash Disbursements Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Cash Management Criteria - The HUD audit guide requires that all disbursements from the regular operating account must be supported by approved invoices, bills, or other supporting documentation and be in the name of the Project. Condition - The Corporation made several payments without having proper documentation and also made one payment not in the name of the Project. Context - Of the total population of 12 months of disbursements, 40 were tested. One invoice was not in the name of the Project and 3 disbursements did not have proper documentation for the payment. Based on our sample, inquiry of employees, we understand the finding to be prevalent at the Corporation throughout the year. Cause - The previous management agent chose to pay the invoices without proper documentation. Effect - We are unable to determine if the expenditures are in compliance with the Regulatory Agreement and also the Corporation had $128 less of operating cash due to paying an invoice not the Project’s name. Identification of repeat finding - No Recommendation - The Corporation should only make disbursements when there is proper documentation supporting the disbursement. View of responsible officials and planned corrective actions - The Corporation agrees with the finding and believes the new management agent has the procedures and controls in place to detect and prevent a similar finding to occur in the future. 2023-001 - Income Certifications Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Eligibility Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Recommendation - Site managers should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. In addition, procedures should be put in place to ensure recertifications continue to be completed when site staff turns over at properties. Management should continue to monitor site staffing and ensure procedures are in-place as back up for site staffing shortages. Status - Not corrected. Repeat finding in 2024
Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Cash Management Name of contact person – Nation Wright, AICDC Chief Operating Officer Corrective action – The Corporation has changed management agent to Tapestry which has the procedures and controls in place to detect and prevent a similar finding to occur in the future. Completion date – Management and the Board of Directors implemented the above as of December 2024.
FAC accepted this audit on May 8, 2024 — management decision was due November 8, 2024.
2023-001 – Income Certifications Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 – Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires Owners inform tenants, through written notices, about the tenants’ responsibility to provide information necessary to complete annual recertifications. Owners must conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants’ rents and assistance payments, if applicable, based on the information gathered. Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Context - Of the total population of 47 units, 5 were tested. One unit selected for testing at this property resulted in noncompliance. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand the finding to be prevalent at the Corporation throughout the year. Management has reported that as of December 31, 2023, there were two incomplete or late annual recertifications for Bii Di Gain Dash Anwebi Elder Housing. Cause - Inexperienced site employees, changes in procedures for processing tenant files, and a global pandemic restricting personal interactions between site employees and tenants all contributed to multiple breakdowns in procedures, which resulted in numerous failures to timely complete the required annual recertifications. Effect - The Corporation was not in compliance with the Compliance Supplement. In addition, rental assistance may be delayed and changes in rental assistance will be effective from the tenants’ annual recertification dates. Any changes in the tenant portion of rent may not take effect until the annual recertifications are complete and may result in a loss of rent. Identification of repeat finding - No Recommendation - Site managers should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. In addition, procedures should be put in place to ensure recertifications continue to be completed when site staff turns over at properties. Management should continue to monitor site staffing and ensure procedures are in-place as back up for site staffing shortages. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding, and has implemented strategies to address these issues throughout 2023, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations.
Show full finding ▾Hide full finding ▴2023-001 – Income Certifications Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 – Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires Owners inform tenants, through written notices, about the tenants’ responsibility to provide information necessary to complete annual recertifications. Owners must conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants’ rents and assistance payments, if applicable, based on the information gathered. Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Context - Of the total population of 47 units, 5 were tested. One unit selected for testing at this property resulted in noncompliance. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand the finding to be prevalent at the Corporation throughout the year. Management has reported that as of December 31, 2023, there were two incomplete or late annual recertifications for Bii Di Gain Dash Anwebi Elder Housing. Cause - Inexperienced site employees, changes in procedures for processing tenant files, and a global pandemic restricting personal interactions between site employees and tenants all contributed to multiple breakdowns in procedures, which resulted in numerous failures to timely complete the required annual recertifications. Effect - The Corporation was not in compliance with the Compliance Supplement. In addition, rental assistance may be delayed and changes in rental assistance will be effective from the tenants’ annual recertification dates. Any changes in the tenant portion of rent may not take effect until the annual recertifications are complete and may result in a loss of rent. Identification of repeat finding - No Recommendation - Site managers should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. In addition, procedures should be put in place to ensure recertifications continue to be completed when site staff turns over at properties. Management should continue to monitor site staffing and ensure procedures are in-place as back up for site staffing shortages. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding, and has implemented strategies to address these issues throughout 2023, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations.
Name of contact person – Angela Riley, CFO Corrective action – The Corporation agrees with the finding and has continued to implement strategies to address these issues throughout 2023, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations. Proposed completion date – Management has begun the corrective action and is expected to have additional internal control and training done by December 31, 2024.
FAC accepted this audit on April 5, 2023 — management decision was due October 5, 2023.
FAC accepted this audit on April 20, 2022 — management decision was due October 20, 2022.
FAC accepted this audit on July 18, 2021 — management decision was due January 18, 2022.
2020-001 ? Income Certifications Federal Program ? U.S. Department of Housing and Urban Development CFDA Number 14.157 ? Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding ? Eligibility Criteria ? The Compliance Supplement requires Owners inform tenants, through written notices, about the tenants? responsibility to provide information necessary to complete annual recertifications. Owners must conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants? rents and assistance payments, if applicable, based on the information gathered. Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Context - Of the total population of 47 units, 5 units were tested. One unit selected for testing at this property resulted in noncompliance. Management has reported that at one time during the year there were 33 incomplete late annual recertifications for Bii Di Gain Dash Anwebi Elder Housing. Cause - Inexperienced site employees, changes in procedures for processing tenant files, and a global pandemic restricting personal interactions between site employees and tenants all contributed to multiple breakdowns in procedures, which resulted in numerous failures to timely complete the required annual recertifications. Effect - The Corporation was not in compliance with the Compliance Supplement. Rental assistance may be delayed and changes in rental assistance will be effective from the tenants? annual recertification dates. Any changes in the tenant portion of rent may not take effect until the annual recertifications are complete and may result in a loss of rent. Recommendation - The responsible employees should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. Management should monitor outstanding or late recertifications on a regular basis. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding, is diligently working to resolve the finding, and is working on putting in additional controls to prevent a reoccurrence of this finding or similar findings. Employees responsible for these procedures will receive additional training and have been reminded of the procedures. In addition, the Corporation has instituted a new monitoring procedure, in order to assist in getting all late recertifications completed.
Show full finding ▾Hide full finding ▴2020-001 ? Income Certifications Federal Program ? U.S. Department of Housing and Urban Development CFDA Number 14.157 ? Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding ? Eligibility Criteria ? The Compliance Supplement requires Owners inform tenants, through written notices, about the tenants? responsibility to provide information necessary to complete annual recertifications. Owners must conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants? rents and assistance payments, if applicable, based on the information gathered. Condition - Annual recertifications of family income and composition were not completed and/or were not completed timely. Context - Of the total population of 47 units, 5 units were tested. One unit selected for testing at this property resulted in noncompliance. Management has reported that at one time during the year there were 33 incomplete late annual recertifications for Bii Di Gain Dash Anwebi Elder Housing. Cause - Inexperienced site employees, changes in procedures for processing tenant files, and a global pandemic restricting personal interactions between site employees and tenants all contributed to multiple breakdowns in procedures, which resulted in numerous failures to timely complete the required annual recertifications. Effect - The Corporation was not in compliance with the Compliance Supplement. Rental assistance may be delayed and changes in rental assistance will be effective from the tenants? annual recertification dates. Any changes in the tenant portion of rent may not take effect until the annual recertifications are complete and may result in a loss of rent. Recommendation - The responsible employees should receive additional training and be reminded of the procedures in place to ensure that annual recertifications are completed timely. Management should monitor outstanding or late recertifications on a regular basis. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding, is diligently working to resolve the finding, and is working on putting in additional controls to prevent a reoccurrence of this finding or similar findings. Employees responsible for these procedures will receive additional training and have been reminded of the procedures. In addition, the Corporation has instituted a new monitoring procedure, in order to assist in getting all late recertifications completed.
BII DI GAIN DASH ANWEBI ELDER HOUSING CORRECTIVE ACTION PLAN For the Year Ended December 31, 2020 2020-001 Income Certifications Name of contact person ? Angela Riley, CFO Corrective action ? Management agrees with the finding, is diligently working to resolve the finding, and is working on putting in additional controls to prevent a reoccurrence of this finding or similar findings. Management has hired a consultant to help design and implement these additional internal controls. Employees responsible for these procedures will receive additional training and have been reminded of the procedures. In addition, Management has instituted a new monitoring procedure, in order to assist in getting all late recertifications completed. Proposed completion date ? Management has begun the corrective action and is expected to have additional internal controls and training done by December 31, 2021.
FAC accepted this audit on March 10, 2020 — management decision was due September 10, 2020.
FAC accepted this audit on March 14, 2019 — management decision was due September 14, 2019.
FAC accepted this audit on April 10, 2018 — management decision was due October 10, 2018.
FAC accepted this audit on March 15, 2017 — management decision was due September 15, 2017.
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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