EIN: 273561771
UEI: LPMGMKVJ6C48
Audited by: Mahoney Ulbrich Christiansen & Russ, PA
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 24, 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 24, 2026 (56 days from today).
What is a management decision? →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 and management agents of properties with Section 202 project rental assistance contracts to complete annual income recertifications for all tenants. These recertifications must be conducted timely, with notices sent at least 120 days prior to the effective date and all required documentation collected and maintained in a tenant file to ensure accurate rent calculations and continued eligibility. Condition - During the audit, a review of tenant files revealed that income recertifications were either not completed or not completed in a timely manner. Specifically, 1 out of 5 tenant files reviewed lacked completed income recertifications within the required timeframe. In addition, we were informed that certain tenant files not selected in our sample also did not contain all required documentation in the tenant files. Context - Of the total population of 42 units, 5 were tested. Questioned costs are not applicable to this finding. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand this finding to be prevalent at the Corporation throughout the year. Cause - The identified deficiencies appear to be due to inadequate oversight and ineffective tracking of the recertification process by property management. Factors contributing to the issue include not utilizing a tracking system to track recertification deadlines and timely distribution of recertification notices; insufficient staff training on federal compliance requirements; and staff turnover resulting in inconsistent adherence to required procedures. Effect (Potential Effect) - Failure to perform annual recertifications on a timely basis increases the risk that ineligible tenants may continue to receive assistance or that assistance amounts may not be properly calculated based on current income and family composition. This could result in questioned costs and potential repayment of HUD assistance related to periods in which recertifications were late. Identification of repeat finding – Yes Recommendation - To ensure compliance with HUD recertification requirements, management should utilize available tracking systems to monitor and enforce recertification deadlines; provide staff training on HUD Handbook 4350.3 recertification procedures and requirements; establish a quality control process to verify recertifications are completed on time and properly documented in tenant files; and conduct periodic internal audits to identify and correct any deficiencies in the recertification process. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agents’ procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations.
Show full finding ▾Hide full finding ▴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 and management agents of properties with Section 202 project rental assistance contracts to complete annual income recertifications for all tenants. These recertifications must be conducted timely, with notices sent at least 120 days prior to the effective date and all required documentation collected and maintained in a tenant file to ensure accurate rent calculations and continued eligibility. Condition - During the audit, a review of tenant files revealed that income recertifications were either not completed or not completed in a timely manner. Specifically, 1 out of 5 tenant files reviewed lacked completed income recertifications within the required timeframe. In addition, we were informed that certain tenant files not selected in our sample also did not contain all required documentation in the tenant files. Context - Of the total population of 42 units, 5 were tested. Questioned costs are not applicable to this finding. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand this finding to be prevalent at the Corporation throughout the year. Cause - The identified deficiencies appear to be due to inadequate oversight and ineffective tracking of the recertification process by property management. Factors contributing to the issue include not utilizing a tracking system to track recertification deadlines and timely distribution of recertification notices; insufficient staff training on federal compliance requirements; and staff turnover resulting in inconsistent adherence to required procedures. Effect (Potential Effect) - Failure to perform annual recertifications on a timely basis increases the risk that ineligible tenants may continue to receive assistance or that assistance amounts may not be properly calculated based on current income and family composition. This could result in questioned costs and potential repayment of HUD assistance related to periods in which recertifications were late. Identification of repeat finding – Yes Recommendation - To ensure compliance with HUD recertification requirements, management should utilize available tracking systems to monitor and enforce recertification deadlines; provide staff training on HUD Handbook 4350.3 recertification procedures and requirements; establish a quality control process to verify recertifications are completed on time and properly documented in tenant files; and conduct periodic internal audits to identify and correct any deficiencies in the recertification process. Views of responsible officials and planned corrective actions - The Corporation agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agents’ procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations.
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agent's procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
2024-001
FAC accepted this audit on April 12, 2025 — management decision was due October 12, 2025.
2024-001 – Annual Income 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 Criteria - The Compliance Supplement requires owners and management agents of properties with Section 202 project rental assistance contracts to complete annual income recertifications for all tenants. These recertifications must be conducted timely, with notices sent at least 120 days prior to the effective date and all required documentation collected to ensure accurate rent calculations and continued eligibility. Condition - During the audit, a review of tenant files revealed that income recertifications were either not completed or not completed in a timely manner. Specifically: • 3 out of 5 tenant files reviewed lacked completed income recertifications within the required timeframe. • 3 out of 5 tenant files we reviewed did not contain evidence that tenants were notified of their obligation to provide updated income and family composition information. Context - Of the total population of 42 units, 5 were tested. Questioned costs are not applicable to this finding. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand this finding to be prevalent at the Organization throughout the year. Cause - The identified deficiencies appear to be due to inadequate oversight and ineffective tracking of the recertification process by property management. Factors contributing to the issue include not utilizing a tracking system to track recertification deadlines and timely distribution of recertification notices; insufficient staff training on federal compliance requirements; and staff turnover resulting in inconsistent adherence to required procedures. Effect (Potential Effect) - Failure to complete or timely conduct income recertifications can lead to several compliance and financial risks, including: incorrect rent calculations, resulting in overpayment or underpayment of housing assistance subsidies; loss of subsidy for tenants who fail to complete recertification, potentially leading to eviction risks; increased administrative burden to resolve delayed recertifications and financial discrepancies; and risk of noncompliance findings in HUD’s Management and Occupancy Reviews (MORs), potentially leading to corrective actions or penalties. Identification of repeat finding - Yes Recommendation - To ensure compliance with HUD recertification requirements, management should utilize available tracking systems to monitor and enforce recertification deadlines; provide staff training on HUD Handbook 4350.3 recertification procedures and requirements; establish a quality control process to verify recertifications are completed on time and properly documented in tenant files; and conduct periodic internal audits to identify and correct any deficiencies in the recertification process. Views of responsible officials and planned corrective actions - The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications and hired a team of additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025.
Show full finding ▾Hide full finding ▴2024-001 – Annual Income 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 Criteria - The Compliance Supplement requires owners and management agents of properties with Section 202 project rental assistance contracts to complete annual income recertifications for all tenants. These recertifications must be conducted timely, with notices sent at least 120 days prior to the effective date and all required documentation collected to ensure accurate rent calculations and continued eligibility. Condition - During the audit, a review of tenant files revealed that income recertifications were either not completed or not completed in a timely manner. Specifically: • 3 out of 5 tenant files reviewed lacked completed income recertifications within the required timeframe. • 3 out of 5 tenant files we reviewed did not contain evidence that tenants were notified of their obligation to provide updated income and family composition information. Context - Of the total population of 42 units, 5 were tested. Questioned costs are not applicable to this finding. Based on our sample, inquiry of employees and a master list of late annual recertifications provided by management, we understand this finding to be prevalent at the Organization throughout the year. Cause - The identified deficiencies appear to be due to inadequate oversight and ineffective tracking of the recertification process by property management. Factors contributing to the issue include not utilizing a tracking system to track recertification deadlines and timely distribution of recertification notices; insufficient staff training on federal compliance requirements; and staff turnover resulting in inconsistent adherence to required procedures. Effect (Potential Effect) - Failure to complete or timely conduct income recertifications can lead to several compliance and financial risks, including: incorrect rent calculations, resulting in overpayment or underpayment of housing assistance subsidies; loss of subsidy for tenants who fail to complete recertification, potentially leading to eviction risks; increased administrative burden to resolve delayed recertifications and financial discrepancies; and risk of noncompliance findings in HUD’s Management and Occupancy Reviews (MORs), potentially leading to corrective actions or penalties. Identification of repeat finding - Yes Recommendation - To ensure compliance with HUD recertification requirements, management should utilize available tracking systems to monitor and enforce recertification deadlines; provide staff training on HUD Handbook 4350.3 recertification procedures and requirements; establish a quality control process to verify recertifications are completed on time and properly documented in tenant files; and conduct periodic internal audits to identify and correct any deficiencies in the recertification process. Views of responsible officials and planned corrective actions - The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications and hired a team of additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025.
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications and hired a team of additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2025. Name of contact person: Jennifer Anderson, Interim CFO
2023-001
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 42 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 15 incomplete or late annual recertifications for Riverview Apartments Senior 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 - Yes Recommendation - This is a repeat finding from 2022. 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 continued to implement strategies to address these issues throughout 2023, including: assembling and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 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 42 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 15 incomplete or late annual recertifications for Riverview Apartments Senior 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 - Yes Recommendation - This is a repeat finding from 2022. 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 continued to implement strategies to address these issues throughout 2023, including: assembling and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 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.
2022-001
FAC accepted this audit on August 3, 2023 — management decision was due February 3, 2024.
2022-001 ? 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 42 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. Management has reported that as of December 31, 2022, there was one incomplete or late annual recertifications for Riverview Apartments Senior 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 - Yes Recommendation - This is a repeat finding from 2021. 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 continued to implement strategies to address these issues throughout 2021 and 2022, 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. SECTION IV ? PRIOR AUDIT FINDINGS 2021-001 ? 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 Condition ? Annual recertifications of family income and composition were not completed and/or were not completed timely. Recommendation ? It was recommended 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. Current Status ? Ongoing. See Views of responsible officials and planned corrective actions in Finding 2022- 001. The finding was first reported in the 2020 schedule of findings and questioned costs in March 2021.
Show full finding ▾Hide full finding ▴2022-001 ? 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 42 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. Management has reported that as of December 31, 2022, there was one incomplete or late annual recertifications for Riverview Apartments Senior 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 - Yes Recommendation - This is a repeat finding from 2021. 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 continued to implement strategies to address these issues throughout 2021 and 2022, 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. SECTION IV ? PRIOR AUDIT FINDINGS 2021-001 ? 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 Condition ? Annual recertifications of family income and composition were not completed and/or were not completed timely. Recommendation ? It was recommended 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. Current Status ? Ongoing. See Views of responsible officials and planned corrective actions in Finding 2022- 001. The finding was first reported in the 2020 schedule of findings and questioned costs in March 2021.
2022-001 Income Certifications 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 2021 and 2022, 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 controls and training done by December 31, 2023.
2021-001
FAC accepted this audit on April 20, 2022 — management decision was due October 20, 2022.
2021-001 ? 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 ? The Corporation was out of compliance during the year, which was noted by reviewing monthly HUD vouchers and management?s tracking schedule. Management has reported that as of December 31, 2021, there were 10 incomplete or late annual recertifications for Riverview Apartments Senior 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 - 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.
Show full finding ▾Hide full finding ▴2021-001 ? 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 ? The Corporation was out of compliance during the year, which was noted by reviewing monthly HUD vouchers and management?s tracking schedule. Management has reported that as of December 31, 2021, there were 10 incomplete or late annual recertifications for Riverview Apartments Senior 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 - 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.
2021-001 Income Certifications Name of contact person ? Angela Riley, CFO Corrective action ? Management agrees with the finding. During 2021, management engaged a consultant to identify where processes and procedures can be improved. As a result of the consultant recommendations and managements review of processes and procedures in place, the following strategies have been or are currently being implemented: 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 regional property managers 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 controls and training done by December 31, 2022.
2020-001
FAC accepted this audit on July 18, 2021 — management decision was due January 18, 2022.
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 42 units, 5 units were tested. Three units selected for testing at this property resulted in noncompliance. 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 implementing 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 ▴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 42 units, 5 units were tested. Three units selected for testing at this property resulted in noncompliance. 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 implementing 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.
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 May 31, 2020 — management decision was due December 1, 2020.
FAC accepted this audit on April 15, 2019 — management decision was due October 15, 2019.
FAC accepted this audit on April 10, 2018 — management decision was due October 10, 2018.
FAC accepted this audit on May 8, 2017 — management decision was due November 8, 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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