Coolidge Court, Inc.Non-Profit

2024-001 Enhancing Control Over Tenant File Management and Safekeeping Program Name/Assistance Listing Title: Supportive Housing for Persons with Disabilities (Section 811) Federal Assistance Listing No: 14.181 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Federal Award Finding Compliance Requirements: Eligibility Finding Resolution Status: In Process Information on Universe Population Size: 18 Sample Size Information: 6 Criteria: The U.S. Department of Housing and Urban Development (HUD) requires that tenant files be properly maintained to ensure compliance with federal regulations. Specifically:  HUD Handbook 4350.3: Occupancy Requirements of Subsidized Multifamily Housing Programs state that owners and managers must maintain complete and accurate tenant files to verify eligibility, income, and compliance with program requirements.  HUD's Tenant File Organization and Retention Guidelines emphasize the importance of proper record-keeping and require that all necessary certifications, verifications, and supporting documents be available for review  24 CFR § 5.240 – Verification of Eligibility mandates that owners and managers obtain and retain adequate documentation to verify tenant eligibility, income, and other relevant program criteria.  24 CFR § 5.233 – Mandated Use of EIV System requires that Section 811 properties and other HUD-assisted programs use the Enterprise Income Verification (EIV) system in full to verify tenant employment and income, and to reduce subsidy and rent calculation errors. Statement of Condition: During eligibility testing, the following were identified missing in the tenant file documentation:  Unit 2-201 – Missing asset verification and second page of HUD 50059.  Unit 3-302 – Missing lease contract and asset verification  Unit 3-303 – Missing EIV report Cause: The identified missing documents may be due to the absence of standardized filing procedures for managing tenant records. Additionally, the lack of a structured system for periodic file reviews and a comprehensive checklist of required documents may have contributed to inconsistencies in record retention. Potential Effect of Condition: Without a standardized filing and safekeeping process, there is an increased risk of non-compliance with regulatory requirements, delays in tenant eligibility verification, and inefficiencies in record retrieval. This could lead to audit findings, regulatory reviews, or challenges in maintaining accurate tenant records. Questioned Costs: The auditors have identified questioned costs of $24,052 for annual rental subsidies. These questioned costs pertain only to the sample tested. Reporting Views of Responsible Officials: The Organization agrees with the findings and recommendations and will adhere to the corrective action plan. Context: A review of tenant files identified missing documents, which may be due to the absence of standardized filing procedures and routine file audits. Implementing structured reviews and a checklist-based approach will help ensure completeness, compliance, and accurate record-keeping. Recommendation: To address the identified issues and ensure compliance with HUD regulations, we recommend the following actions: 1. Complete the Missing Documents – Conduct a review of all tenant files to identify and obtain any missing required documents, such as EIV reports, HUD 9887, Social Security verifications, Declaration Forms, asset verifications, and recertifications. Ensure all records are properly filed and up to date. 2. Develop and Implement Standardized Filing Procedures – Establish clear, written guidelines for managing tenant records, including document organization, storage, and retrieval processes. Provide staff with a checklist of required documents to ensure consistency across all tenant files. 3. Establish Routine File Reviews Using a Checklist – Implement a structured system for reviewing tenant files at least every quarter (end of Q3 and other scheduled intervals). Use a standardized checklist to verify required documents and quickly identify missing or incomplete records. Document findings and ensure prompt corrective action is taken. 4. Enhance Document Security and Accessibility – Implement safeguards to protect physical and electronic tenant records, such as restricted access, secure storage solutions, and digital backup procedures. Ensure documents are easily retrievable for audits and internal reviews. By completing missing documents, using a standardized checklist, and implementing quarterly reviews, the organization can strengthen compliance, reduce risks, and improve efficiency in tenant file management. Management Response: Thank you for your recommendations. At Coolidge Court we strive to operate with organization and efficiency. To mitigate risk and to remain in compliance with HUD we will increase the chart review from semi-annually to quarterly to ensure that all documents are filed and in order. For unit 201, not including the asset verification was an oversite, but we do have it on file and the 2nd page of the 50059 failed to upload but is in the tenant's chart. For unit 302, all documents requested are filed, but there was an oversite with uploading. For unit 303, a Citizen Declaration has been signed by the tenant which has been approved by our HUD representative to take the place of the EIV while the tenant continues to make efforts to obtain citizenship. We appreciate your thoroughness and will continue to follow all the recommendations listed above. We look forward to working with you in the future.