EIN: 411692875
UEI: NPF9PVMU4F61
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 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 (52 days from today).
What is a management decision? →Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 – Supportive Housing for Persons with Disabilities (Section 811) Material Weakness & Noncompliance Category of Finding – Special Tests and Provisions Criteria - HUD regulations and Metro Apartments, Inc.’s Project Rental Assistance Contract (PRAC) require that withdrawals from the project’s replacement reserve be specifically approved by HUD prior to disbursement and limited to the approved amount. Replacement reserve funds are restricted and may only be used for eligible purposes authorized by HUD. Condition - Metro Apartments, Inc. submitted a replacement reserve withdrawal request to HUD totaling $39,746 for maintenance-related expenses. HUD approved $13,839 of the request and denied the remaining $25,907. Contrary to HUD’s approval, the organization withdrew the entire $39,746 from the replacement reserve. Cause - Management did not ensure that replacement reserve withdrawals were restricted to the amounts approved by HUD, resulting in a withdrawal that exceeded the approved amount. Effect - The organization withdrew $25,907 from restricted replacement reserve funds without HUD authorization, resulting in noncompliance with Special Tests and Provisions applicable to the Supportive Housing for Persons with Disabilities Program. This noncompliance could result in HUD requiring repayment of unapproved amounts or taking other corrective actions. Questioned Costs - $25,907 - representing the portion of the replacement reserve withdrawal that exceeded the amount approved by HUD. Identification of repeat finding – No Recommendation - We recommend that management strengthen controls over replacement reserve withdrawals to ensure that disbursements are limited to amounts specifically approved by HUD. Management should implement procedures to review HUD approval documentation prior to withdrawal and reconcile approved amounts to actual disbursements. Views of responsible officials and planned corrective actions - Management agrees with the finding. Management acknowledges that the withdrawal exceeded the amount approved by HUD and is reviewing internal procedures to ensure replacement reserve withdrawals comply with HUD approval requirements. Management will coordinate with HUD to resolve the unapproved portion of the withdrawal and take corrective action as necessary.
Show full finding ▾Hide full finding ▴Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 – Supportive Housing for Persons with Disabilities (Section 811) Material Weakness & Noncompliance Category of Finding – Special Tests and Provisions Criteria - HUD regulations and Metro Apartments, Inc.’s Project Rental Assistance Contract (PRAC) require that withdrawals from the project’s replacement reserve be specifically approved by HUD prior to disbursement and limited to the approved amount. Replacement reserve funds are restricted and may only be used for eligible purposes authorized by HUD. Condition - Metro Apartments, Inc. submitted a replacement reserve withdrawal request to HUD totaling $39,746 for maintenance-related expenses. HUD approved $13,839 of the request and denied the remaining $25,907. Contrary to HUD’s approval, the organization withdrew the entire $39,746 from the replacement reserve. Cause - Management did not ensure that replacement reserve withdrawals were restricted to the amounts approved by HUD, resulting in a withdrawal that exceeded the approved amount. Effect - The organization withdrew $25,907 from restricted replacement reserve funds without HUD authorization, resulting in noncompliance with Special Tests and Provisions applicable to the Supportive Housing for Persons with Disabilities Program. This noncompliance could result in HUD requiring repayment of unapproved amounts or taking other corrective actions. Questioned Costs - $25,907 - representing the portion of the replacement reserve withdrawal that exceeded the amount approved by HUD. Identification of repeat finding – No Recommendation - We recommend that management strengthen controls over replacement reserve withdrawals to ensure that disbursements are limited to amounts specifically approved by HUD. Management should implement procedures to review HUD approval documentation prior to withdrawal and reconcile approved amounts to actual disbursements. Views of responsible officials and planned corrective actions - Management agrees with the finding. Management acknowledges that the withdrawal exceeded the amount approved by HUD and is reviewing internal procedures to ensure replacement reserve withdrawals comply with HUD approval requirements. Management will coordinate with HUD to resolve the unapproved portion of the withdrawal and take corrective action as necessary.
Corrective Action: Management agrees with the finding. Management acknowledges that the withdrawal exceeded the amount approved by HUD and is reviewing internal procedures to ensure replacement reserve withdrawals comply with HUD approval requirements. Mangement will coordinate with HUD to resolve the unapproved portion of the withdrawal and take corrective action as necessary. 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
Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 – Supportive Housing for Persons with Disabilities (Section 811) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires owners and management agents of properties with Section 811 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: 2 out of 3 tenant files reviewed lacked completed income recertifications within the required timeframe. 2 out of 3 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 23 units, 3 units 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 - 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, 2024-001 and 2023-001 Recommendation - This is a repeat finding from 2023 and 2024. To ensure compliance with federal 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, 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 14.181 – Supportive Housing for Persons with Disabilities (Section 811) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires owners and management agents of properties with Section 811 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: 2 out of 3 tenant files reviewed lacked completed income recertifications within the required timeframe. 2 out of 3 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 23 units, 3 units 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 - 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, 2024-001 and 2023-001 Recommendation - This is a repeat finding from 2023 and 2024. To ensure compliance with federal 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, 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 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. 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, 2023-001
FAC accepted this audit on April 12, 2025 — management decision was due October 12, 2025.
2024-001 – Income Certifications Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 – Supportive Housing for Persons with Disabilities (Section 811) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires owners and management agents of properties with Section 811 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: • 2 out of 3 tenant files reviewed lacked completed income recertifications within the required timeframe. • 2 out of 3 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 23 units, 3 units 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 - 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, 2023-001 Recommendation - This is a repeat finding from 2023. To ensure compliance with federal 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 – Income Certifications Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 – Supportive Housing for Persons with Disabilities (Section 811) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires owners and management agents of properties with Section 811 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: • 2 out of 3 tenant files reviewed lacked completed income recertifications within the required timeframe. • 2 out of 3 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 23 units, 3 units 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 - 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, 2023-001 Recommendation - This is a repeat finding from 2023. To ensure compliance with federal 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
2024-002 –Tenant File Documentation Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 – Supportive Housing for Persons with Disabilities (Section 811) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires that tenant files contain all necessary documentation to verify eligibility, rent calculations, and compliance with federal regulations. Required documents include, but are not limited to, original applications, verified bank accounts, resident screenings, Enterprise Income Verification (EIV) reports, unit inspections, and move-out documentation. Maintaining complete tenant files is essential for ensuring compliance with federal requirements and preventing improper subsidy payments. Condition - During the audit, a review of tenant files revealed that required documentation was either missing or incomplete. Specifically: • In 3 out of 3 tenant files reviewed, we were not provided evidence that all required documents were included in the tenant file. Missing documentation included Enterprise Income Verification (EIV) reports and inspection forms. Context - Of the total population of 23 units, 3 units were tested. Questioned costs are not applicable to this finding. Based on our sample and inquiry of employees, we understand this finding to be prevalent at the Organization throughout the year. Cause - The identified deficiencies appear to be due to inadequate file management and oversight. Contributing factors may include insufficient staff training on federal documentation requirements, staff turnover resulting in inconsistencies in maintaining tenant records, and not conducting routine internal file audits to ensure compliance. Effect (Potential Effect) - Failure to maintain complete tenant files can lead to significant compliance and financial risks, including inability to verify tenant eligibility, which may result in improper subsidy payments, increased risk of findings in HUD’s Management and Occupancy Reviews (MORs) or audits, potential financial penalties or loss of subsidy funding, and risk of tenant disputes due to missing documentation. Identification of repeat finding - No Recommendation - To ensure compliance with federal requirements for tenant documentation, property management should conduct periodic internal file audits to identify and correct missing or incomplete documentation; provide staff training on proper file management and federal compliance requirements; establish a document tracking system to prevent missing files and ensure timely updates; and assign responsibility to designated staff for reviewing and maintaining complete tenant records. Views of responsible officials and planned corrective actions - The Organization agrees with the finding. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Management is working with the new property managers to ensure they have procedures in place to document and maintain tenant files in accordance with the Compliance Supplement and will have routine internal audits of tenant files to ensure compliance with federal regulations. For properties not transitioning to new property management, management believes the reduced volume of properties at one property manager will reduce staff turnover and more efficiently provide the proper training to existing staff to improve compliance with tenant files.
Show full finding ▾Hide full finding ▴2024-002 –Tenant File Documentation Federal Program – U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 – Supportive Housing for Persons with Disabilities (Section 811) Material Weakness & Noncompliance Category of Finding – Eligibility Criteria - The Compliance Supplement requires that tenant files contain all necessary documentation to verify eligibility, rent calculations, and compliance with federal regulations. Required documents include, but are not limited to, original applications, verified bank accounts, resident screenings, Enterprise Income Verification (EIV) reports, unit inspections, and move-out documentation. Maintaining complete tenant files is essential for ensuring compliance with federal requirements and preventing improper subsidy payments. Condition - During the audit, a review of tenant files revealed that required documentation was either missing or incomplete. Specifically: • In 3 out of 3 tenant files reviewed, we were not provided evidence that all required documents were included in the tenant file. Missing documentation included Enterprise Income Verification (EIV) reports and inspection forms. Context - Of the total population of 23 units, 3 units were tested. Questioned costs are not applicable to this finding. Based on our sample and inquiry of employees, we understand this finding to be prevalent at the Organization throughout the year. Cause - The identified deficiencies appear to be due to inadequate file management and oversight. Contributing factors may include insufficient staff training on federal documentation requirements, staff turnover resulting in inconsistencies in maintaining tenant records, and not conducting routine internal file audits to ensure compliance. Effect (Potential Effect) - Failure to maintain complete tenant files can lead to significant compliance and financial risks, including inability to verify tenant eligibility, which may result in improper subsidy payments, increased risk of findings in HUD’s Management and Occupancy Reviews (MORs) or audits, potential financial penalties or loss of subsidy funding, and risk of tenant disputes due to missing documentation. Identification of repeat finding - No Recommendation - To ensure compliance with federal requirements for tenant documentation, property management should conduct periodic internal file audits to identify and correct missing or incomplete documentation; provide staff training on proper file management and federal compliance requirements; establish a document tracking system to prevent missing files and ensure timely updates; and assign responsibility to designated staff for reviewing and maintaining complete tenant records. Views of responsible officials and planned corrective actions - The Organization agrees with the finding. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Management is working with the new property managers to ensure they have procedures in place to document and maintain tenant files in accordance with the Compliance Supplement and will have routine internal audits of tenant files to ensure compliance with federal regulations. For properties not transitioning to new property management, management believes the reduced volume of properties at one property manager will reduce staff turnover and more efficiently provide the proper training to existing staff to improve compliance with tenant files.
Corrective Action: The Organization agrees with the finding. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Management is working with the new property managers to ensure they have procedures in place to document and maintain tenant files in accordance with HUD and will have routine internal audits of tenant files to ensure compliance with HUD regulations. For properties not transitioning to new property management, management believes the reduced volume of properties at one property manager will reduce staff turnover and more efficiently provide the proper training to existing staff to improve compliance with tenant files. 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
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 14.181 – Supportive Housing for Persons with Disabilities (Section 811) 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 23 units, 3 units 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, 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. Identification of repeat finding – Yes, 2022-001 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: assembled and deployed a team of 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 14.181 – Supportive Housing for Persons with Disabilities (Section 811) 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 23 units, 3 units 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, 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. Identification of repeat finding – Yes, 2022-001 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: assembled and deployed a team of 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.
2022-001
FAC accepted this audit on April 5, 2023 — management decision was due October 5, 2023.
2022-001 ? Income Certifications Federal Program ? U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 ? Supportive Housing for Persons with Disabilities (Section 811) 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 23 units, 3 units 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, 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. Identification of repeat finding ? Yes, 2021-001 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.
Show full finding ▾Hide full finding ▴2022-001 ? Income Certifications Federal Program ? U.S. Department of Housing and Urban Development Assistance Listing Number 14.181 ? Supportive Housing for Persons with Disabilities (Section 811) 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 23 units, 3 units 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, 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. Identification of repeat finding ? Yes, 2021-001 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.
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 CFDA Number 14.181 ? Supportive Housing for Persons with Disabilities (Section 811) 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 23 units, 3 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 11 incomplete late annual recertifications for Metro Apartments, Inc.. 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 ? This is a repeat finding from 2020. Site staff 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. During 2021, management engaged a consultant to identify where processes and procedures can be improved. As a result of the consultant recommendations and management?s 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 employees 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 managers, and developed a monitoring program to set expectations and hold employees accountable to those expectations.
Show full finding ▾Hide full finding ▴2021-001 ? Income Certifications Federal Program ? U.S. Department of Housing and Urban Development CFDA Number 14.181 ? Supportive Housing for Persons with Disabilities (Section 811) 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 23 units, 3 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 11 incomplete late annual recertifications for Metro Apartments, Inc.. 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 ? This is a repeat finding from 2020. Site staff 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. During 2021, management engaged a consultant to identify where processes and procedures can be improved. As a result of the consultant recommendations and management?s 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 employees 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 managers, and developed a monitoring program to set expectations and hold employees accountable to those expectations.
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.
2020-001 ? Income Certifications Federal Program ? U.S. Department of Housing and Urban Development CFDA Number 14.181 ? Supportive Housing for Persons with Disabilities (Section 811) 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 23 units, 4 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 16 incomplete late annual recertifications for Metro Apartments, Inc.. 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 14.181 ? Supportive Housing for Persons with Disabilities (Section 811) 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 23 units, 4 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 16 incomplete late annual recertifications for Metro Apartments, Inc.. 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.
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 17, 2019 — management decision was due September 17, 2019.
FAC accepted this audit on April 10, 2018 — management decision was due October 10, 2018.
FAC accepted this audit on March 17, 2017 — management decision was due September 17, 2017.
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