BALTIMORE REGIONAL HOUSING PARTNERSHIP, INC.Non-Profit

Finding No. 2021 - 001: Federal Agency: Department of Housing and Urban Development ("HUD") Federal Program Title: Moving to Work Demonstration Program (HCVP Only) Federal Assistance Listing Number: 14.881 Award Period: January 1, 2021 through December 31, 2021 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition/Context: A sample of 60 tenant files tested found that 15 files did not have HUD-50058 data uploaded to the PIH Information Center ("PIC") in a timely manner. Questioned Costs: N/A Criteria: Tenant information must be uploaded to the PIC system for each HUD-50058 report completed no later than 60 calendar days from the effective date of any action recorded of the form HUD-50058. Cause: BRHP's Administrative Plan allows for retroactive effective dates for interim changes that will benefit the family when income decreases, as opposed to selecting a future effective date and forcing the family to pay their portion when they do not have the income to support it. Typically, staff would submit 50058 actions to HUD using the PIC system at least once per month. Action effective dates must be for the first of any month. Considering BRHP's policy of allowing retroactive effective dates and submitting records to PIC once a month, there is more opportunity for late submissions. The untimely PIC submissions were caused by a combination of staff turnover and a monthly PIC submission schedule as opposed to a weekly submission schedule. Effect: The delay in uploading information to the PIC system may result in inaccurate reporting to HUD which is used for funding purposes. Recommendations: We recommend BRHP perform their reporting to HUD on a weekly basis rather than on a monthly basis. Views of the Responsible Officials and Corrective Action Plan: At this time, all files selected for the audit have corresponding records successfully submitted to HUD through the PIC submission portal. BRHP will ensure a full-time employee is responsible for weekly PIC submissions and clearing of fatal errors and have at minimum a second, trained employee available as a redundancy measure. It is not unusual for BRHP to process retroactive actions and at times, the effective date of the action can be for a date several weeks in the past. If PIC submissions are completed weekly rather than monthly, there will be more opportunities to upload the 50058 in accordance with the 60-day required period. Additionally, in the 2023 Moving To Work Plan, BRHP will propose an activity allowing for the processing of interim recertifications retroactive up to 60 days from approval, thereby resolving a conflict between the BRHP Administrative Plan and the governing regulations.

Finding No. 2021 - 002: Federal Agency: Department of Housing and Urban Development Federal Program Title: Moving to Work Demonstration Program (HCVP Only) Federal Assistance Listing Number: 14.881 Award Period: January 1, 2021 through December 31, 2021 Compliance Requirement: Special Tests Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition/Context: A sample of 25 tenant files tested for special tests found the following exceptions: Two (2) of 25 files tested did not have a housing quality standards inspection performed within 25 months of the previous inspection. Questioned Costs: N/A Criteria: The Program Administrative Plan states that BRHP will attempt to inspect all units under contract in accordance with its housing quality standards at least once every 25 months. Cause: Two BRHP families had inspections that exceeded the 25-month limit, a deficiency noted in a prior year audit. As a result of the prior audit, BRHP developed an internal report that required a monthly review of possible missed inspections. While it was a supervisor's responsibility to review the report monthly, some documented inspections were still missed. BRHP attributes this to a breakdown in the supervisor review and a lack of understanding of the internal reports. Effect: BRHP is not in compliance with its administrative plan and the Uniform Guidance compliance requirements. Recommendations: We recommend that BRHP review their process for tracking and scheduling inspections to ensure compliance. Views of the Responsible Officials and Corrective Action Plan: The two files reviewed with missed inspections have been scheduled for the biennial inspection. BRHP has since developed a comprehensive report that provides a monthly view of unscheduled inspections and a comprehensive view of all possibly missed inspections. Unlike in the case of recertifications that prevent payment where deadlines are missed, there is no automated failsafe that can be enabled in Yardi to prevent further processing in the absence of an inspection status. Therefore, BRHP has assigned review of the monthly, QC report to the inspections Customer Care Representative ("CCR") support staff and the comprehensive full report to the Rental Assistance supervisor and added an extra review to be conducted by the Housing Choice Voucher Director bimonthly. BRHP has a full grasp of the total universe of potentially missed inspections and will conduct a total review of these files for completion over the next 30 days.

Finding 2019-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Moving to Work Demonstration (HCVP Only) CFDA Number: 14.881 Award Period: January 1, 2019 through December 31, 2019 Compliance Requirement: Special Tests Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition/Context: A sample of 40 tenant files tested for special tests found the following exceptions: ? One (1) of 40 files tested did not have a HQS inspection performed within 25 months of the previous inspection. Questioned Costs: N/A Criteria: The Program Administrative Plan states that BRHP will attempt to inspect all units under contract in accordance with its housing quality standards at least once every 25 months. Cause: Several factors contributed to the finding. In 2016 BRHP changed software from Visual Homes to Yardi. As they converted systems, the past inspection date for some tenants was not recorded correctly, which caused the tenants to not appear on the list of needed inspections. In addition, there is a known issue with Yardi that would mark occupied units as ?Excluded,? and would therefore exclude those units during the inspection scheduling process, causing those inspections to be missed. Effect: BRHP is not in compliance with its administrative plan and Uniform Guidance compliance requirements. Repeat Finding: Yes Recommendation: We recommend that BRHP review their process for tracking and scheduling inspections to ensure compliance. Views of Responsible Officials: There is no disagreement with the finding.

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