Corrective Action Plans

Finding 497303 (2023-001)

Significant Deficiency 2023

SC

Eligibility HUD Housing Programs Reporting

GHA Georgetown Housing Authority Correctie Action Plan for the year ended December 31, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of contact person: Alissa Collington Executie Director Corrective A...

GHA Georgetown Housing Authority Correctie Action Plan for the year ended December 31, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of contact person: Alissa Collington Executie Director Corrective Action: We will iplement proper internal control procedures for the Public and Indian Housing Program eligiblity requirements. Proposed Completion Date: Immediately.

View Audit 319952

Finding 497281 (2023-001)

Significant Deficiency 2023

City of West Allis

WI

HUD Housing Programs Eligibility Significant Deficiency

U.S. Department of Housing and Urban Development 2023-001 Eligibility - Housing Choice Voucher Program – Assistance Listing No. 14.871 Recommendation: The City should review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with Ente...

U.S. Department of Housing and Urban Development 2023-001 Eligibility - Housing Choice Voucher Program – Assistance Listing No. 14.871 Recommendation: The City should review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with Enterprise income Verification (EIV) eligibility requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHA staff understand that income verification is essential to ensuring that only eligible participants are provided housing assistance benefits. In late 2023 they implemented a new file review procedure where the Community Development Senior Planner reviews all files processed by operational housing staff as a matter of quality control. In addition, the protocol for PHA quality control includes following the Section Eight Management Assessment Program (SEMAP) indicator iv. Accurate verification of family income by ensuring EIV Reports validate family income 120 days of submission of a new admission or reexamination and maintain copies of the report in the tenant file resolving any discrepancies of the family within 60 days of the EIV Report. The one instance of non-compliance found during the 2023 audit occurred prior to the implementation of this new procedure so staff believe that appropriate steps have been taken to address this concern. Name(s) of the contact person(s) responsible for corrective action: Steve Schaer Planned completion date for corrective action plan: The City believes the necessary corrective actions have been taken as of August 2024.

View Audit 319901

Finding 496949 (2023-005)

Significant Deficiency 2023

Regional School Unit #54 - Msad #54

ME

Eligibility

Management’s response/corrective action plan: The Nutrition Director will involve the Support Services Administrative Assistant in the student eligibility process to review and check for accuracy.

View Audit 319690

Finding 496948 (2023-004)

Significant Deficiency 2023

Regional School Unit #54 - Msad #54

ME

Eligibility School Nutrition Programs Internal Control / Segregation of Duties

Management response/corrective action: The Nutrition Director will update student eligibility when verification requests are not returned. The Director will participate in Department of Education professional development to stay abreast of all requirements of School Nutrition.

View Audit 319690

Finding 496937 (2023-002)

Significant Deficiency 2023

Plymouth Housing Authority

NC

Eligibility HUD Housing Programs Reporting

Section III - Federal Award Findings and Questioned Costs Finding 2023-002 Name of Contact Person: Anette Ange Executive Director Corrective Action: Management will review the recertification process and plan to monitor recertifications. Proposed Compeltion Date: Immediately.

View Audit 319683

Finding 496927 (2023-001)

Significant Deficiency 2023

Maine School Administrative District No. 35

ME

Eligibility School Nutrition Programs Internal Control / Segregation of Duties

Management’s Response/Corrective Action Plan: We agree with RKO's recommendation that there are no provisions in the regulations that provide for large scale reclassifications through administrative override. There was some confusion on the part of Maine School Administrative District No. 35 when a...

Management’s Response/Corrective Action Plan: We agree with RKO's recommendation that there are no provisions in the regulations that provide for large scale reclassifications through administrative override. There was some confusion on the part of Maine School Administrative District No. 35 when a communication from the State of Maine was received in November of 2022, that the rate of Free and Reduced children identified at Maine School Administrative District No. 35 had dropped dramatically from the prior year (due to the meals being free to all) and that it may negatively impact our subsidy. At that point, Maine School Administrative District No. 35 asked its building administrators to identify needy families based on conversations they had previously had with parents, from speaking with their guidance counselors, from knowledge they had working with outside community agencies (68 Hours of Hunger) to help identify families potentially in need. From there the lists provided by the building administrators were compared with the families who had already submitted applications, and the directly certified students, and any students who were not identified in either of those cohorts were added to the free and reduced list per administrative override. When RKO arrived in May 2023 to perform interim testing, they let us know that this was not appropriate. At that time, we removed those students from the free and reduced list, and adjusted all of our previously submitted claim forms to account for the change. Maine School Administrative District No. 35 is now clear on the rules with regards to the use of administrative override, and will not use it again in the future.

View Audit 319663

Finding 496926 (2023-001)

Significant Deficiency 2023

True North of Columbia, Inc.

MO

Eligibility

True North of Columbia's Response and Corrective Action Plan and Planned Completion Date for the Corrective Action Plan: True North was in the process of releasing its contracted HR firm and implementing an in-house process to ensure all required personnel forms (including I-9 forms) were completed ...

True North of Columbia's Response and Corrective Action Plan and Planned Completion Date for the Corrective Action Plan: True North was in the process of releasing its contracted HR firm and implementing an in-house process to ensure all required personnel forms (including I-9 forms) were completed appropriately and in a timely manner, when this oversight occurred. Two new personnel had I-9 forms that were completed, but mistakenly filed prior to being appropriately signed. Both were hired on the same day and the i-9s were completed during the brief interim period when new HR protocol was just being established. True North correct this error immediately upon notification by our auditors. The in-hosue protocol was implemented during the same week of their hire and has built-in safe-guards to aviod something like this from happening in the future. First teh Executive Director and/or the new employee's supervisor complete (and ensure the new employee appropriately completed all required employement paperwork) during a formal employee intake meeting. Completed paperwork is reviewed by the Executive Director and/or the employee's supervisor and is then routed to the Director of Finance and Grants who reviews the completed paperwork (again) and completes the E-verification proess, notifies the State of Missouri of the new hire, and enters the new employee's informaiton into the agency's online HR and payroll system. Once all information has been entered appropriately, the paperwork is routed to the Operations Specialist who checks each document against a checklist to ensure completeness and correctness. We believe this process is sufficient to ensure the agency does not miss signing or dating a personal document again. Official Responsible for Ensuring the Corrective Action Plan: Michele Snodderly

View Audit 319661

Finding 496854 (2023-001)

Significant Deficiency 2023

South Mississippi Housing Authority

MS

Internal Control / Segregation of Duties Eligibility HUD Housing Programs

2023-001 ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The agency has begun implementing the Yardi software system that will include a landlord portal th...

2023-001 ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The agency has begun implementing the Yardi software system that will include a landlord portal that will streamline W-9 and direct deposit documentation, while also creating a digital, cloud-based file for each landlord. This will enable the agency to better serve the needs of our landlords while also improving our records retention and filing systems. This function will also improve redundancy for continuity of operations and disaster planning. The new management team also created two (2) Fraud Specialist positions within the Housing Choice Voucher – Assisted Housing department that will audit landlord documentation to mitigate fraud risk. Person Responsible for Correction of Finding: Mr. Justin Brooks, Executive Director Projected Completion Date: December 31, 2024

View Audit 319579

Finding 496766 (2023-001)

Material Weakness 2023

Housing Authority of the City of Pittsburgh

PA

Questioned Costs Eligibility HUD Housing Programs

Maher Duessel Finding Condition: During our review of 60 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted 4 ...

Maher Duessel Finding Condition: During our review of 60 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted 4 instances where a tenant recertification using the HUD-50058, Family Report (OMB No. 2577-0083) form (which provides eligibility and reporting information) was either not completed, or not completely on a timely basis. We also noted multiple instances where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 that we were able to review and was not provided. This includes items such as rent reasonableness forms, support for income calculation, signed and approved HAP contracts and lease agreements, and signed HUD Form 9886. HACP Management Response/Action Taken: Action Taken: The HACP will continue to monitor and train staff regarding processes and procedures, to include and not limited to the HUD's hierarchy of income verification. In fiscal year (FY) 2023 the HCV Department had a significant turnover in line and managerial staff. The HACP promoted an aggressive hiring plan to attract new talent to fill vacant positions due to the great resignation that the HACP along with other national Agencies continue to experience. In addition, the HACP retained the services of CVR and Associates to train newly hired staff on all aspects of the HCV Program, to include and not limited to recertifications, contracts, interims, and rent increases. The HACP will continue managerial and internal audits by the HACP Internal Compliance Department to reduce the necessity of corrections after the initial submission. The HACP continues to: • Send notices regarding re-certifications 120 days in advance of the due date, • Require Managers to review reports to assure timely submission of re-certifications, • Utilize the Internal Compliance (IC) Department to review and sample files from the Occupancy and the HCV portfolio, • Make corrections when discovered, • Make payment adjustments to participant accounts when errors are discovered and corrected, • The HACP will offer periodic staff training on re-certification, • The HACP offers participants the use of technology to complete paperwork. In 2024, the HCV Department successfully tested the implementation of pre-populated recertification forms. The pre-populated forms allow the participant to confirm or quickly modify family composition and income information. In addition to the time and cost saving factor of the pre-populated forms, the forms are less daunting to complete. The HACP contends It will receive more cooperation from participants in completing the forms because of the ease of use. During FY 2022, the HACP was closed to the public. In July of 2023, the HACP opened a "One Stop Shop" that is open to the public from 8 a.m. to - 4:30 p.m. daily. The One Stop Shop is staffed with three (3) full-time staff members to receive information from participants and landlords to provide timely customer service. In July of 2024 the OSS was equipped with computers for the public to access HACP staff virtually as well as in person. The use of the computers allows staff to interact with participants regarding minor issues without having the staff physically come to the OSS, thus saving time and money for both the external customer and the Agency. The opening of the One Stop Shop has been successful in receiving the public and responding to concerns.

View Audit 319534 Questioned Costs: $1

Finding 496758 (2023-003)

None 2023

Near West Side Multi-Service Corporation

OH

Questioned Costs Eligibility Internal Control / Segregation of Duties

We will implement stricter verification processes and comprehensive staff training to ensure proper documetnation of eligibility. We will also conduct regular audits to prevent such issues in the future and review the questioned costs of to rectify any discrepancies.

View Audit 319526 Questioned Costs: $1

Finding 496677 (2023-003)

None 2023

Santa Cruz Community Cu

CA

Eligibility Reporting Material Weakness

Views of Responsible Officials Responsible/Contact Official Paul Barenfus, CLO, and Sylvia Sanchez, CFO Management Response The ERP Grant is a very different grant from previous grants received by the Credit Union. Although management followed the instructions provided on the CDFI website, it was no...

Views of Responsible Officials Responsible/Contact Official Paul Barenfus, CLO, and Sylvia Sanchez, CFO Management Response The ERP Grant is a very different grant from previous grants received by the Credit Union. Although management followed the instructions provided on the CDFI website, it was not clear that running the loan through the ERP track for eligibility was only one of several steps. After auditors noted that 4 loans were ineligible, management searched the website to find the second track that the loans had to be qualified through, the Majority-Minority Census. The team has not had to qualify loans like this in the past, and the additional third step for qualification was not understood. Management has since replaced the unqualified loans on the 2023 SEFA with eligible loans. Documented procedures for the ERP Grant have been completed and are being followed. Anticipated Completion Date This item is complete.

View Audit 319492

Finding 496636 (2023-012)

Significant Deficiency 2023

City of Boston

MA

Procurement, Suspension & Debarment Eligibility Significant Deficiency § 200.303

Boston Public Schools (BPS) has revised their tracking and documentation for special education expenses. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496463 (2023-005)

Material Weakness 2023

Washington Parks Academy

MI

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Even though the Academy transferred $3,345,325 of ESSER funds to LKAYA based on the intergovernmental agreement that was in place during that time, the Academy itself did incur ESSER eligible costs that could have been applied against these ESSER dollars if they had remained within the Academy. The ...

Even though the Academy transferred $3,345,325 of ESSER funds to LKAYA based on the intergovernmental agreement that was in place during that time, the Academy itself did incur ESSER eligible costs that could have been applied against these ESSER dollars if they had remained within the Academy. The costs incurred involved improvements to technology, maintaining and increasing additional staff, curriculum materials, instructional supplies, and staff training to name a few.

View Audit 319381 Questioned Costs: $1

Finding 496457 (2023-003)

Material Weakness 2023

Saint John's Program for Real Change

CA

Subrecipient Monitoring Eligibility

2023-003— FederalAward Findings and Questioned Costs Jose Dominguez, Interim CEO, jdominguez@saintjohnsprogram.org Corrective Action Planned: The Saint John's Program for Real Change will introduce a dual review process for meal counts, with the aim of ensuring that both the kitchen staff and their ...

2023-003— FederalAward Findings and Questioned Costs Jose Dominguez, Interim CEO, jdominguez@saintjohnsprogram.org Corrective Action Planned: The Saint John's Program for Real Change will introduce a dual review process for meal counts, with the aim of ensuring that both the kitchen staff and their supervisors meticulously scrutinize the document for accuracy of all data before its submission to the Finance Department for final review. Additionally, the meal count spreadsheet will undergo thorough review, to assure assessments for participants' age and eligibility will be conducted monthly. Moreover, Assistant Director of Social Enterprises, Food Service Manager, kitchen staff and all designated personnel responsible for meal counts will be mandated to complete the CACFP Annual Mandatory Training. This training will serve to keep the staff abreast of CACFP updates, regulations, and procedures, thereby aiding CACFP Operators in upholding program integrity. Subsequent to the training, the kitchen staff, personnel responsible for meal counts, and the finance department will collectively review the existing spreadsheet and practices behind the meal counts to make any necessary updates. We have made sure that the finance department has finished the training for CACFP meal counting, claiming, and documentation, as well as the Mandatory annual training. Chef Scott Davison and Assistant Director of Social Enterprises Nicholle Cox are currently in the process of obtaining their CACFP Annual Mandatory Training certification. Anticipated Completion Date: 8/30/2024

View Audit 319380

Finding 496410 (2023-001)

Material Weakness 2023

Full Harvest Housing, Inc.

IA

Allowable Costs / Cost Principles Special Tests & Provisions Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended March 31, 2023. Finding 2023-001 Responsible Party Name: Tamara Wallace Position: Executive Director – Management Agent Telephone Number: 816-233-4250 Federal Agency Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements A/B - Activities Allowed or Unallowed and Allowable Costs/Cost Principles, C – Cash Management, E – Eligibility, L – Reporting, and N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action Management reported that the failure(s) involved records related to the period managed by the predecessor management company. We will request and keep all required documentation from HUD and establish processes and procedures to ensure compliance with the Regulatory Agreement. Anticipated Completion Date September 30, 2024

View Audit 319318

Finding 496204 (2023-005)

Material Weakness 2023

Atlantic Housing Foundation, Inc.

TX

Questioned Costs HUD Housing Programs Subrecipient Monitoring

CORRECTIVE ACTION PLAN Name and Number of the Project: See below Audit Firm: M Group, LLP Audit Period: December 31, 2023 Project Name of Waters at James Crossing, LP, FHA/Contract No. VA36-L000-130, Questioned Cost of $52,007; Project Name of Brittany Woods...

CORRECTIVE ACTION PLAN Name and Number of the Project: See below Audit Firm: M Group, LLP Audit Period: December 31, 2023 Project Name of Waters at James Crossing, LP, FHA/Contract No. VA36-L000-130, Questioned Cost of $52,007; Project Name of Brittany Woods/Park Chase, LLC, FHA/Contract No. GA06L00060, Questioned Cost of $73,002; Total of $125,009. Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN OR TO BE TAKEN FINDING #2023-005: Section 8 Housing Assistance Payments Program, Assistance Listing #14.195 CORRECTIVE ACTION TO BE COMPLETED: The Projects will review and monitor tenant eligibility and documentation procedures to ensure compliance. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Michael Nguyen, President of Atlantic Housing Management, Inc.

View Audit 319145 Questioned Costs: $1

Finding 486148 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of Greensboro

NC

HUD Housing Programs Subrecipient Monitoring Eligibility

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Corrective Action Plan: Greensboro Housing Authority (GHA) continues implementation of systems and processes to correct internal control over particip...

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Corrective Action Plan: Greensboro Housing Authority (GHA) continues implementation of systems and processes to correct internal control over participant files in the Housing Choice Voucher Program (HCVP) with the following actions: In 2023, GHA made leadership changes through the recruitment of talented and transformational leaders that are knowledgeable of program rules and requirements. In addition to the two-pronged approach that was implemented in the prior year, GHA team members will expand Quality Control and Quality Assurance checks on program participants’ files to verify the accuracy of calculations and compliance requirements. This will be augmented by increased sampling and review from a third-party consultant. GHA will continue to provide internal and external training to team members. We have completed an independent review of over 25% of our files and we are using the results of that review to identify specific areas for ongoing training and development. We have also invested in leveraging technology to help us mitigate the errors identified during the audit. Anticipated Completion Date: The above plans will be implemented immediately and will be continuously monitored. We anticipate a completion date of no later than December 31, 2024. Responsible Person: Meredith Daye, Chief Operating Officer

View Audit 318801

Finding 486048 (2023-003)

Material Weakness 2023

The Salvation Army Northwest Division

WA

Subrecipient Monitoring Eligibility Material Weakness

The Division will contact each unit distributing TEFAP assistance and communicate the requirement to retain documentation regarding the determination of client eligibility. Anticipated Completion Date: October 2024. Responsible Contact Person: Yohannes Gedlu, Northwest Division Divisional Finance D...

The Division will contact each unit distributing TEFAP assistance and communicate the requirement to retain documentation regarding the determination of client eligibility. Anticipated Completion Date: October 2024. Responsible Contact Person: Yohannes Gedlu, Northwest Division Divisional Finance Director & Julie Luft, Northwest Division Social Services Director

View Audit 318713

Finding 486017 (2023-004)

Significant Deficiency 2023

Charleston County Housing and Redevelopment Authority

SC

HUD Housing Programs Subrecipient Monitoring Eligibility

2023-004 ALN: 14.871 - ALN 14.850 – Public & Indian Housing – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Angela Childers, Chief Executive O...

2023-004 ALN: 14.871 - ALN 14.850 – Public & Indian Housing – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Angela Childers, Chief Executive Officer Projected Completion Date: March 31, 2025

View Audit 318709

Finding 485966 (2023-001)

Significant Deficiency 2023

Benjamin Franklin Cummings Institute of Technology

MA

Questioned Costs Procurement, Suspension & Debarment Student Financial Aid

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Corrective Action Plan: An in-depth review will be completed for each student who is designated with a SAP Status from th...

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Corrective Action Plan: An in-depth review will be completed for each student who is designated with a SAP Status from the Registrar before Federal Aid is disbursed. SAP designations will be kept as part of the student’s financial aid file from one semester to the next and this status will be reviewed before any Title IV Aid is disbursed. Timeline for Implementation of Corrective Action Plan: May 1, 2024 Contact Person: Shani Wilkerson, Director of Financial Aid

View Audit 318688 Questioned Costs: $1

Finding 485753 (2023-002)

Significant Deficiency 2023

Pilgrim Towers, Inc.

CT

Eligibility Reporting

Finding Reference Number: 2023-002 Description of Finding: During our audit for the year ended December 31 , 2023, we noted that sufficient supporting documentation was not available for the annual income amounts. Statement of Concurrence or Nonconcurrence: We are in agreement with this finding. Cor...

Finding Reference Number: 2023-002 Description of Finding: During our audit for the year ended December 31 , 2023, we noted that sufficient supporting documentation was not available for the annual income amounts. Statement of Concurrence or Nonconcurrence: We are in agreement with this finding. Corrective Action: A new management company has been engaged as of April 1, 2024. The new management company, Kings Daughters and Sons Management Company, Inc., is very diligent in maintaining its records and ensuring they are in compliance. It is expected that they will ensure that the supporting document for annual income amounts will be properly documented and filed going forward. Name of Contact Person: Pat Thatcher, Board Treasurer patthatcher1@gmail.com 203-451-1090 Projected Completion Date: Expectation is that the new management company will ensure proper income verification for all tenants for the year ended December 31, 2024.

View Audit 318591

Finding 485732 (2023-001)

Significant Deficiency 2023

New Jersey Housing and Mortgage Finance Agency

NJ

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Homeowners Assistance Fund– Assistance Listing No. 21.026 – Eligibility Recommendation: The Agency should evaluate the steps they take to ensure that any required documentation not gathered from the program participant is followed-up on and obtained, prior to finalizing an application and providin...

Homeowners Assistance Fund– Assistance Listing No. 21.026 – Eligibility Recommendation: The Agency should evaluate the steps they take to ensure that any required documentation not gathered from the program participant is followed-up on and obtained, prior to finalizing an application and providing housing assistance. Any changes in this methodology ought to be documented in the program policies and procedures, and communicated to all employees who engage in the application process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: All staff has been reminded and retrained to fully review each file to ensure that a properly executed 4506C has been uploaded to our operating system. Additionally, a lookback procedure has been instituted to capture any files from the current year that may be missing this document. Also, ERMA/HAF closers have been instructed to ensure that the form is available in our operating system, or they are to instruct the title agent and the applicant(s) that a form must be signed as part of the closing documents NJHMFA provides to the title agency. It is important to note that the document is not a US Treasury requirement and its inclusion in ERMA/HAF files was determined to be necessary to ease income reviews for self-employed applicants as well as those who receive rental income and include it on their IRS 1040 returns. While NJHMFA decided it would request this form for all applicants, the form itself is not utilized in every instance. Name(s) of the contact person(s) responsible for corrective action: William Schmidt (Assistant Director of HAF); James Abrams (HAF Program Manager); Tina White (HAF Program Manager) Planned completion date for corrective action plan: Training for staff and closers has already occurred. Closers have also received instructions to ensure the form is uploaded at time of closing. The lookback procedure shall be completed by no later than September 1st, 2024.

View Audit 318568

Finding 485728 (2023-001)

Significant Deficiency 2023

Victory Oaks, Inc.

MD

HUD Housing Programs Eligibility

The policy for the return of security deposits received on site is consistent throughout the company. This is taught to incoming sta􀆯 members to make sure that the proper timeline is adhered to during the move out process each month. The policy is specific in saying that the paperwork and letter not...

The policy for the return of security deposits received on site is consistent throughout the company. This is taught to incoming sta􀆯 members to make sure that the proper timeline is adhered to during the move out process each month. The policy is specific in saying that the paperwork and letter notifying the tenant(s) status of their security deposit whether it is a refund, or they owe additional funds upon vacating from their apartment is sent by the manager within 7 – 10 business days. The policy is attached for reference. The security deposit refund is also checked by our Regional by the 15th of each month and our inhouse Accounting Department to make sure that all security deposits are completed and sent out prior to 30 days from the day that the resident moves out. Going into 2024, this training is scheduled throughout the year and always available on our HAU Training Programs accessible to all employees. The training is for new hires and existing employees to reiterate the process to make sure all employees are aware of the sensitive timeline associated with the return of the security deposit for our tenants.

View Audit 318547

Finding 485726 (2023-002)

Material Weakness 2023

Victory Heights, Inc.

MD

HUD Housing Programs Eligibility

Each resident’s information is processed before moving in to ensure they don’t have tenancy elsewhere. Going forward, we will ensure that things are processed timely within the 90-day period. Going forward, management will ensure that the EIV system is utilized correctly and timely. Tenant files hav...

Each resident’s information is processed before moving in to ensure they don’t have tenancy elsewhere. Going forward, we will ensure that things are processed timely within the 90-day period. Going forward, management will ensure that the EIV system is utilized correctly and timely. Tenant files have been noted on the late EIV reports. Management is now running EIV reports from corporate to eliminate the pate processing or missing EIV reports.

View Audit 318546

Finding 485723 (2023-001)

Material Weakness 2023

Victory Crest, Inc.

MD

HUD Housing Programs Eligibility

Onsite team members have received refresher training and have the EIV binder available onsite. They have also set calendar reminders to make sure that EIV reports are pulled in a timely manner. The regional manager will be following up with the onsite staff to make sure they are in compliance.

View Audit 318545

Corrective Action Plans

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