Corrective Action Plans

Finding 384799 (2023-002)

Significant Deficiency 2023

Newport News Redevelopment and Housing Authority

VA

HUD Housing Programs Eligibility Significant Deficiency

2023-002 Section 8 Project-Based Cluster – Assistance Listing No. 14.249/14.182 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be follo...

2023-002 Section 8 Project-Based Cluster – Assistance Listing No. 14.249/14.182 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure property management staff is properly trained and supervised to ensure eligibility determinations are completed correctly. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024

View Audit 297906

Finding 384787 (2023-003)

Material Weakness 2023

Newport News Redevelopment and Housing Authority

VA

Questioned Costs HUD Housing Programs Eligibility

2023-003 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their pr...

2023-003 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure staff is properly trained to ensure the recertification process is completed correctly. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024

View Audit 297906 Questioned Costs: $1

Finding 384786 (2023-001)

Significant Deficiency 2023

Newport News Redevelopment and Housing Authority

VA

HUD Housing Programs Eligibility Significant Deficiency

2023-001 Low-Rent Public Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when comple...

2023-001 Low-Rent Public Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure property management staff is properly trained and supervised to ensure eligibility determinations are completed correctly. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024

View Audit 297906

Finding 384766 (2023-003)

Material Weakness 2023

Housing Authority of the City of Martinsburg

WV

Questioned Costs Eligibility Procurement, Suspension & Debarment

Finding 2023-003 - Documentation of Costs and Vendor Invoices - Financial Reporting and Internal Controls ALN 14.850 & 14.871- Noncompliance & Material Weakness Corrective Action Plan: Vendor invoice backup supplied to HUD for questionable expense s. Executive Director must approve all expenses goi...

Finding 2023-003 - Documentation of Costs and Vendor Invoices - Financial Reporting and Internal Controls ALN 14.850 & 14.871- Noncompliance & Material Weakness Corrective Action Plan: Vendor invoice backup supplied to HUD for questionable expense s. Executive Director must approve all expenses going forward and keep sufficient backup for audit. Person Responsible: John Sales, Interim Executive Director Anticipated Completion Date: January 31, 2024

View Audit 297881 Questioned Costs: $1

Finding 384736 (2023-003)

Significant Deficiency 2023

State of Kansas

KS

Questioned Costs Eligibility Matching / Level of Effort / Earmarking § 200.303

Condition: During testing of eligibility, the following items were noted: • Two beneficiaries had income entered incorrectly, causing the benefits to be overstated. • One beneficiary had income entered incorrectly but there was no impact on the benefit. • One beneficiary’s income was not entered for...

Condition: During testing of eligibility, the following items were noted: • Two beneficiaries had income entered incorrectly, causing the benefits to be overstated. • One beneficiary had income entered incorrectly but there was no impact on the benefit. • One beneficiary’s income was not entered for consideration, which caused the beneficiary to be incorrectly labeled as eligible. Recommendation: We recommend that KDCF strengthen internal controls in place to mitigate this from happening in the future. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Below are the determined causes for the identified errors. • Failure to review application and supporting documents prior to processing – Case #1 • Failure to double check information that was entered – Case #2 • Failure to review EDBC summary – Case #3 • Failure to adequately document income on the Application Worksheet – where they got income, listing income dates and amounts – Case #4 All causes identified are obviously human error related to lack of attention to detail. In each of the four cases identified, staff reviewed the eligibility determination and corrected as appropriate, including Recovery Accounts established and notices mailed to the household. Corrective action will involve review of training material to determine if there are opportunities to strengthen training material to enhance emphasis on attention to detail for staff receiving the training. Emphasize will also be placed on reviewing material before finalization of case processing to assure accuracy of determination. In addition, the agency is reviewing plans to move from a model that uses several temporary staff that complete only LIEAP eligibility to using full time EES eligibility staff that will do LIEAP in addition to all other EES caseloads. These workers do eligibility for several programs year-round and would not have to be retrained each year. We believe this will improve eligibility determinations and the review and approval process. Name(s) of the contact person(s) responsible for corrective action: Lewis Kimsey, Public Service Executive Shannon Connell, Policy Coordination Assistant Director. Planned completion date for corrective action plan: Training Material finalized by 10/1/24 and that training will be completed by Dec 31, 2024.

View Audit 297874 Questioned Costs: $1

Finding 384730 (2023-004)

Material Weakness 2023

Lake County School District #7

OR

School Nutrition Programs Eligibility Material Weakness

a. Material Weakness-Verification of Free and Reduced Price Applications The District did not select or verify a sample of applications that it approved for free and reduced price meals during 2022-2023. b. LCSD7 Plan of Action - New staff hired in July of 2023 has received training from Oregon Depa...

a. Material Weakness-Verification of Free and Reduced Price Applications The District did not select or verify a sample of applications that it approved for free and reduced price meals during 2022-2023. b. LCSD7 Plan of Action - New staff hired in July of 2023 has received training from Oregon Department of Education on the verification of application process. In January the District received a waiver and now can offer every student free meals. c. The Business Manager along with the Elementary Principal will ensure this process is complete in June 2024.

View Audit 297873

Finding 384726 (2023-001)

Significant Deficiency 2023

Puerto Rico Public Housing Administration

PR

Eligibility

Reinforcement of the required documentation is being done frequently with the occupancy officers to request all the required documents in the kit provided to them as part of the procedures. The agency is providing continous training to the employees in order to streamline the processes, avoid mi...

Reinforcement of the required documentation is being done frequently with the occupancy officers to request all the required documents in the kit provided to them as part of the procedures. The agency is providing continous training to the employees in order to streamline the processes, avoid missing documents and ensure rent calculations are accurate. New procedures were revised as of 2020 when PRPHA started as new Section 8 receiving agency and is in the process of updating the current documentation.

View Audit 297868

Finding 384687 (2023-001)

Material Weakness 2023

Housing Authority of the City of Brownsville

TX

Questioned Costs HUD Housing Programs Eligibility

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers and Emergency Housing Vouchers programs. Leticia Gonzalez, Director o...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers and Emergency Housing Vouchers programs. Leticia Gonzalez, Director of Client Services, will be responsible to implement this corrective action by June 30, 2024.

View Audit 297792 Questioned Costs: $1

Finding 384655 (2023-001)

Significant Deficiency 2023

City of St. Louis Municipal Library District

MO

Equipment & Real Property Management Special Tests & Provisions Subrecipient Monitoring

Finding No. 2023-001 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2024 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipm...

Finding No. 2023-001 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2024 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipment and make necessary revisions to processes and procedures to ensure all staff are properly trained to successfully execute all transactions

View Audit 297725

Finding 384569 (2023-007)

Material Weakness 2023

Wawasee Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303 § 200.334 § 200.77 § 200.78

FINDING 2023-007 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: There was a material weakness, in that the School Corporation had not properly designed or implemented a system of internal controls, including appropriate segregation of duties, that wou...

FINDING 2023-007 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: There was a material weakness, in that the School Corporation had not properly designed or implemented a system of internal controls, including appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. During the audit period, the School Corporation submitted two Title I Applications using the prior year’s Real Time Report data. The October 2021 Real Time Report used for the 2022-2023 Title I Application was not available for review to ensure compliance with the grant’s eligibility requirement. Contact Person Responsible for Corrective Action: Amanda Knipper Contact Phone Number and Email Address: 574-457-3188 x 1376, aknipper@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The Real Time Report data is pulled by Data Exchange directly from the School Corporation’s student management software system. The School Corporation will put a system in place to ensure that all student data within the student software system is accurate to ensure correct reporting of the Real Time data. The Grant Coordinator will review the Real Time report before submission with the information housed in the student management software and a second person will review the data for accuracy. An internal sign-off form will be created and implemented to document the secondary review of the report data. The Superintendent and the Treasurer will both sign off on the data digitally during the certification period as determined by IDOE. Anticipated Completion Date: The projected date of completion is August 2024.

View Audit 297652

Finding 384554 (2023-004)

Material Weakness 2023

Wawasee Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: This is a repeat finding for Eligibility from the immediately prior audit report. The prior audit finding number was 2021-005. The School Corporation did not properly design or implement an effective sy...

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: This is a repeat finding for Eligibility from the immediately prior audit report. The prior audit finding number was 2021-005. The School Corporation did not properly design or implement an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance. The free and reduced-price applications were processed by one employee and updated within the software without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. One employee at the School Corporation submitted meal reimbursement claim reports on a monthly basis with no review or oversight process in place to ensure the reports were properly and timely submitted. Contact Person Responsible for Corrective Action: Jessica Murray Contact Phone Number and Email Address: 574-457-3188 x 3234, jmurray@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The meal reimbursement claim reports will be prepared by the Food Service Director and reviewed and verified by the Treasurer prior to submission. The Food Service Director will submit the reports and the Treasurer will review the submitted reports to verify accuracy in submission. An internal sign-off form will be created and implemented to document the secondary review of the report data. The direct certification lists will be downloaded monthly by the Food Service Director and uploaded into the software system. A secondary person will review the data following upload into the software system to ensure data was uploaded correctly and that direct certified students were correctly processed. An internal sign-off form will be created and implemented to document the secondary review of the upload data. The free and reduced-price applications will be processed by the Food Service Director. The Treasurer will review each application to ensure it has been accurately processed and will sign off on each application to indicate completion of the secondary review. Anticipated Completion Date: The projected date of completion is August 2024.

View Audit 297652

Finding 384507 (2023-001)

Material Weakness 2023

Northwest Allen County Schools

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: We did not properly design internal controls to prevent, detect or correct noncompliance over Eligibility, Direct Certifications, or Reporting Claims Submissions. Contact Person Responsible for Correcti...

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: We did not properly design internal controls to prevent, detect or correct noncompliance over Eligibility, Direct Certifications, or Reporting Claims Submissions. Contact Person Responsible for Corrective Action: Leeanne Koeneman Contact Phone Number and Email Address: Leeanne.Koeneman@nacs.k12.in.us; 260-637-8768 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Board has already taken action and approved an additional staff member to the Food Service Department to ensure segregation of duties. By adding the Food Service Administration Assistant to the department, their role will add a level of review to ensure compliance with Direct Certification eligibility status for students that are uploaded by the Assistant Food Service Director. The review will ensure that the upload of data is correct and complete. The duties of the added position with also include a review of monthly reporting of Sponsorship Claims, prepared by the Food Service Director prior to submission to the Indiana Department of Education (IDOE). Anticipated Completion Date: June 30, 2024

View Audit 297615

Finding 384450 (2023-001)

Significant Deficiency 2023

Roanoke Rapids Housing Authority

NC

Eligibility HUD Housing Programs Reporting

Corrective Action Plan For the year Ended June 30, 2023 Section II - Financial Statement Findings None reported. Section III – Federal Award Findings and Questioned Costs Significant Deficiency Finding 2023-001 Internal Control Over Compliance-Public and Indian Housing Name of Contact Person: Wil...

Corrective Action Plan For the year Ended June 30, 2023 Section II - Financial Statement Findings None reported. Section III – Federal Award Findings and Questioned Costs Significant Deficiency Finding 2023-001 Internal Control Over Compliance-Public and Indian Housing Name of Contact Person: William Bobbitt, Executive Director Corrective Action: We will review our intake and recertification procedures. We will also review our tenant file monitoring procedures. Proposed Completion Date: Management will implement the above procedure immediately.

View Audit 297586

Finding 384436 (2023-003)

Material Weakness 2023

Linton-Stockton School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation failed, due to the lack of internal controls, to provide adequate oversight to ens...

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation failed, due to the lack of internal controls, to provide adequate oversight to ensure that the parameters that were entered into the student information software system were accurate. The School Corporation failed to maintain adequate documentation of the on-line and paper applications that were reviewed so that documentation was available for audit. The School Corporation failed, due to the lack of internal controls, to provide adequate oversight of the direct certification process to ensure that the Direct Certification Reports were generated and input accurately into the student information software system. Verifications of Free and Reduced Price Applications The School Corporation failed, due to the lack of internal controls, to provide adequate oversight to ensure that the verification process was properly performed. Contact Person Responsible for Corrective Action: Carla Gambill Contact Phone Number and Email Address: 812-847-6020 ext. 1004 cgambill@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 32 Description of Corrective Action Plan: Eligibility - Income guidelines will be entered by the Director of Food Services and reviewed by the Director of School Finance to ensure accuracy. Review by the Director of School Finance will be noted on the July monthly checklist completed by the Director of School Finance. Direct certification - The direct certification process will be completed monthly by the Director of Food Services and will be reviewed by the Director of School Finance. Review by the Director of School Finance will be noted on the monthly checklist completed by the Director of School Finance. Review of Applications - The Director of Food Services will compile and maintain a spreadsheet of all free and reduced applications received. The spreadsheet will include pertinent information from the application as well as information regarding what benefits were assigned to the student based on the application. The spreadsheet will be reviewed periodically by the Director of School Finance and that review will be documented on the spreadsheet. Verification - Verification will be completed by the Student Data Coordinator and a review of the verification documentation will be completed by the Director of Food Services evidenced by signature on the documentation. Anticipated Completion Date: This Corrective Action Plan will be put in effect March 2024.

View Audit 297573

Finding 384429 (2023-009)

Material Weakness 2023

Rush County Schools

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: Eligibility determinations were made by the Cafeteria Secretary, and are now reviewed by the Food Service Director. However, this control was not in place for the majority of the audit period. Contact P...

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: Eligibility determinations were made by the Cafeteria Secretary, and are now reviewed by the Food Service Director. However, this control was not in place for the majority of the audit period. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Since the 2019 audit, the responsibility of the Free/Reduced lunch applications was shifted to the middle school cafeteria secretary, Connie Amos. Mrs. Amos reviews information in the application and designates if it meets the criteria for Free, Reduced, or Paid lunches. The Food Service Director, Nancy Schroeder will also review the applications and confirm the results calculated by Mrs. Amos. This control was brought to our attention late in the application process so only part of the applications were reviewed. Now 100% of all applications will be reviewed by two people. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384428 (2023-008)

Material Weakness 2023

Rush County Schools

IN

School Nutrition Programs Eligibility Material Weakness § 200.303

FINDING 2023-008 Finding Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications INDIANA STATE BOARD OF ACCOUNTS 48 Summary of Finding: One employee was responsible for performing the required verification of the free and reduced price ap...

FINDING 2023-008 Finding Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications INDIANA STATE BOARD OF ACCOUNTS 48 Summary of Finding: One employee was responsible for performing the required verification of the free and reduced price applications. While the verification was reviewed by a second person, that control was not effective. All six of the required verified applications in the fiscal year 2022-23 were tested. Two of the six verified applications were calculated incorrectly resulting in improper eligibility status changes. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: The middle school cafeteria secretary, Connie Amos, will contact parents regarding verification of their free/reduced lunch application. This information will then be reviewed by the Food Service Director, Nancy Schroeder, to determine the information is accurate. Parents are always notified on any changes to the lunch status. Anticipated Completion Date: April 2024

View Audit 297571

Finding 384412 (2023-003)

Material Weakness 2023

Rush County Schools

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.334

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the ...

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The October 1st Real Time Report of Pupil Enrollment (PE) was used by the Indiana Department of Education to pull data into the Title I application. These numbers were then used to calculate Percent Poverty which was used to rank schools for Title I eligibility. One person was primarily responsible for compiling and uploading student data, including poverty status for Real Time reports. There was no additional review or verification being done to ensure that the numbers being pre-populated on the grant applications were correct. There was no internal control in place, such as an oversight, review or approval process to ensure eligibility was properly determined. The Indiana Department of Education (IDOE) used the October 1 Real Time reports for fiscal years 2020- 2021 and 2021-2022, as provided by the School Corporation, to determine Title I Eligibility for the 2021- 2022 and 2022-2023 grant programs, respectively. There was no October 1 Real Time report presented for audit for fiscal year 2021-2022, which would have been used to pull in enrollment and poverty information for the 2022-2023 grant. Therefore, we were unable to verify if the amounts reported in the grant application were correct. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Eligibility – The Technology Director, Brevin Runnebohm will supply the Title I director with the official October 1 count each school year. This will be retained for audit and will be used by the Grant Coordinator, Nancy Schroeder, to determine the enrollment numbers in the Title I application have INDIANA STATE BOARD OF ACCOUNTS 45 been prepopulated correctly. The Grant Coordinator will sign off that she has reviewed this information and find it accurate. Anticipated Completion Date: 10/2024

View Audit 297571

Finding 384369 (2023-001)

Significant Deficiency 2023

The New Reidsville Housing Authority

NC

HUD Housing Programs Eligibility Significant Deficiency

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Noncompliance & Significant Deficiency – Housing Choice Voucher Program – ALN 14.871 The New Reidsville Housing Authority suffered a tremendous loss with the passing of the Housing Choice Voucher (HCV) and Public Housing Special...

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Noncompliance & Significant Deficiency – Housing Choice Voucher Program – ALN 14.871 The New Reidsville Housing Authority suffered a tremendous loss with the passing of the Housing Choice Voucher (HCV) and Public Housing Specialists within weeks of one another and immediately before the start of the fiscal year. As a small housing authority, the deaths of two of the five office employees who had a combined 33 years of Authority experience left a significant void in knowledge and experience. Although the two employees were cross trained on each other’s jobs, no remaining employees were fully trained or capable of assuming those positions or responsibilities. In the immediate months after the passing of the employees, temporary and consultant labor was utilized until the Authority filled the vacant positions. Unfortunately, employee turnover among the new hires created further voids in HCV personnel during and after the fiscal year. Although a comprehensive review of all tenant and participant files to ensure completeness and compliance had begun prior to the audit, the sudden declining health and subsequent passing of the Executive Director hindered efforts even further. All new and existing housing personnel have received and continue to receive housing-related training and cross training on both the Public and Housing Choice Voucher programs. Comprehensive file review, written documentation of all tasks, and an office-wide evaluation of processes will continue as the employees become accustomed to their new positions. Corrective Action Plan: We concur with this finding. We are emphasizing the importance of accurate and complete tenant file information with our staff and within their new positions. We are confident these errors and oversights will not occur in the future. An extensive tenant file review was underway but was not completed at the time of the audit. All staff are being trained in their positions, and future cross-training and peer review processes are currently being put into practice to execute an added layer of review for all tenant files. Person Responsible: Samantha Shumaker, Interim Director Anticipated Completion Date: June 30, 2024

View Audit 297483

Finding 384368 (2023-002)

Significant Deficiency 2023

The New Reidsville Housing Authority

NC

Questioned Costs HUD Housing Programs Eligibility

Finding 2023-002 – Low Income Public Housing Tenant Files – Eligibility – Noncompliance & Significant Deficiency – Public and Indian Housing – ALN 14.850 The New Reidsville Housing Authority suffered a tremendous loss with the passing of the Housing Choice Voucher and Public Housing Specialists wi...

Finding 2023-002 – Low Income Public Housing Tenant Files – Eligibility – Noncompliance & Significant Deficiency – Public and Indian Housing – ALN 14.850 The New Reidsville Housing Authority suffered a tremendous loss with the passing of the Housing Choice Voucher and Public Housing Specialists within weeks of one another and immediately before the start of the fiscal year. As a small housing authority, the deaths of two of the five office employees who had a combined 33 years of Authority experience left a significant void in knowledge and experience. Although the two employees were cross trained on each other’s jobs, no remaining employees were fully trained or capable of assuming those positions or responsibilities. In the months after the passing of the PH Specialist, temporary labor was utilized until such time as the position was filled on a permanent basis. Although a comprehensive review of all tenant and participant files to ensure completeness and compliance had begun prior to the audit, the sudden declining health and subsequent passing of the Executive Director hindered efforts even further. All new and existing housing personnel have received and continue to receive housing-related software-specific training and cross training on both the Public and Housing Choice Voucher programs. Comprehensive file review, written documentation of all tasks, and an office-wide evaluation of processes will continue as the employees become accustomed to their new positions. Corrective Action Plan: We concur with this finding. We are emphasizing the importance of accurate tenant file information, data entry, and calculations with our staff in their new positions. We are confident these errors and oversights will not occur in the future. An extensive tenant file review was underway but was not completed at the time of the audit. A thorough tenant file audit to detect and correct any misstatements will begin as well. All staff are being trained in their positions, and future cross-training and peer review processes are currently being put into practice to execute an added layer of review for all tenant files. Person Responsible: Samantha Shumaker, Interim Director Anticipated Completion Date: June 30, 2024

View Audit 297483 Questioned Costs: $1

Finding 384365 (2023-003)

None 2023

Eastern University

PA

Questioned Costs Eligibility Internal Control / Segregation of Duties

Incorrect Pell Calculations Planned Corrective Action: All of our undergraduate programs now follow a similar calendar pattern and enrollment requirements which will prevent issues when a student switches from one type of program to another. Person Responsible for Corrective Action Plan: Andrea Rut...

Incorrect Pell Calculations Planned Corrective Action: All of our undergraduate programs now follow a similar calendar pattern and enrollment requirements which will prevent issues when a student switches from one type of program to another. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: Completed

View Audit 297474 Questioned Costs: $1

Finding 384290 (2023-001)

Significant Deficiency 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Eligibility

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend that the Authority review their internal controls over the eligibility requirements to ensure all documentation is maintained at the time of recertification. We recommend the Authority review t...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend that the Authority review their internal controls over the eligibility requirements to ensure all documentation is maintained at the time of recertification. We recommend the Authority review their internal controls over the HAP process to ensure the correct amounts are paid each month. We recommend the Authority review their process for uploading data to PIC to ensure each recertification gets submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has begun the assessment, development and implementation of several internal controls to address recertification documentation, HAP processes, and PIC data submission to ensure compliance with Federal regulations. The Authority will develop and implement a quality control process on or before June 30, 2024, to ensure all documentation is maintained, signed and dated by all required parties at the time of certification. Currently, the Authority has developed a checklist system for each step of the recertification process. The checklist includes each step of the recertification process, along with due dates, and responsible entities. While not a Federal Requirement, the Authority did establish the discretionary policy to require housing specialists sign and date the Housing Information Forms. This policy was implemented after this audit finding and would not have been a requirement of the one file reviewed by the audit team. However, this step is included in the checklist process. The Authority is actively working to modify the electronic documentation and record retention system and process. Planned implementation of new electronic documentation and record retention processes is contingent on system updates managed by third party venders, however new written internal procedures are under development. The Authority will develop and implement a quality control process for the HAP process on or before June 30, 2024. This will include procedures for Program Compliance Officers (PCOs) and HCVP’s Accounting Team to work closely and coordinate to ensure each responsible person fully understands their roles and responsibilities. The Authority will implement monthly reviews of HAP payments, by the Housing Choice Voucher Program Compliance Manager. The Authority PCOs and/or accounting staff will follow the procedures for correcting any issues identified during the reviews. Over the past year, the Authority has created a System and Reporting Team that is now responsible for timely PIC submissions and addressing discrepancies and/or errors in the PIC and/or EIV system. By having a dedicated team, the Authority now exceeds the HUD requirement of submitting PIC data within 60 days of the effective date of any action. The Authority submits PIC monthly, performs monthly reviews of PIC data, and ensures staff addresses all fatal errors. In addition to these processes, the System and Reporting Team receives one on one training to address specific and challenging errors and discrepancies. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Finding 384226 (2023-003)

None 2023

Hannibal-Lagrange University

MO

Reporting Student Financial Aid Eligibility

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. St...

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. Student information is uploaded to the NSLDS monthly, so this should provide another layer of assurance each time information is submitted. An internal deadline and standing meeting will be established to ensure consistent compliance. Person Responsible for Corrective Action Plan: Joseph D. Garner III, Registrar Anticipated Date of Completion: The new process will begin April, 2024.

View Audit 297334

Finding 384215 (2023-003)

Significant Deficiency 2023

Housing Authority of the City of Monroe

LA

HUD Housing Programs Eligibility Significant Deficiency

Finding 2023-003 Public Housing Tenant Files - Eligibility - Rent Calculations Federal Program: Public Housing Program -ALN 14.850, Grant Year 2022 & 2023 Condition & cause: We reviewed seventy-five (75) Public Housing Tenant Files and noted seven (7) files not in compliance, or 9.3 %. We noted the ...

Finding 2023-003 Public Housing Tenant Files - Eligibility - Rent Calculations Federal Program: Public Housing Program -ALN 14.850, Grant Year 2022 & 2023 Condition & cause: We reviewed seventy-five (75) Public Housing Tenant Files and noted seven (7) files not in compliance, or 9.3 %. We noted the following discrepancies: • Two (2) files with no verification of income; • Two (2) files that relied on tenant declaration without documenting the reason for not obtaining third-party verification; and • Three (3) miscalculations of annual income. The income calculation and verification deficiencies were the result of employee errors and failure by the Agency to properly review and correct the errors. We were able to extrapolate the total potential misstatement and found it to be immaterial to the financial statements. However, due to the percentage of files not in compliance, we feel the Agency has a significant deficiency in this area. Corrective action planned: Monroe Housing Authority will continue to develop more effective processes for measuring, monitoring, and reducing errors in subsidy payments due to rent calculation and tenant underreporting of income. Implementations and strategies to include: • Resolution of income and rent issues identified in the report and communication to Tenants where applicable. • Development and implementation of an ongoing quality control review process of income at initial certification and re-examination to mitigate wage/income calculation errors to PHA and tenants by: o Hiring (1) FTE to perform quality control review of verification of income (upfront and/or a third party), and Tenant files upon new lease and re-examinations. o Developing a Tenant File Review checklist to document the result of file reviews. • Partner with the National Association of Housing and Redevelopment Officials (NAHRO) and other agencies, where applicable, to train staff on Public Housing Occupancy, Eligibility, Income and Rent training to accurately calculate Tenant Rent and avoid common errors in occupancy and eligibility functions in addition to understanding updates to the HUD-50058. Person responsible for corrective action: Mr. William Smart, Executive Director, Housing Authority of the City of Monroe Anticipated Completion Date: June 30, 2024

View Audit 297297

Finding 384198 (2023-002)

None 2023

Legal Aid of Southeastern Pennsylvania, Inc.

PA

Questioned Costs Allowable Costs / Cost Principles Eligibility

For the finding regarding LASP's compliance with 45 CFR § 1626, a detailed plan has been created that will include weekly compliance team meetings, review of LegalServer reports, and ongoing communication with, and training of, LASP staff on the requirements of the regulation. These activities wil...

For the finding regarding LASP's compliance with 45 CFR § 1626, a detailed plan has been created that will include weekly compliance team meetings, review of LegalServer reports, and ongoing communication with, and training of, LASP staff on the requirements of the regulation. These activities will be supervised by LASP's Chief Counsel, Director of Operations, and Grants and Compliance Specialists. As a direct response to the finding, LASP has implemented a monthly review of open and closed cases involving non-citizens to ensure that files contain the required documentation. Advocate time entries will also be reviewed to ensure that time entries are allocated to an allowable funding source.

View Audit 297293 Questioned Costs: $1

Finding 384124 (2023-003)

Significant Deficiency 2023

Concordia University, St. Paul

MN

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their controls around eligibility. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The ...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their controls around eligibility. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid receives a weekly report indicating the amount and type of notifications sent in the prior week to compare to the list of actual transactions in the system. This allows for a more frequent review and notification of any errors. On the IT side of the process, the notification process has been added to their checklist to check for any new server updates. Name of the contact person responsible for corrective action: Financial Aid Director, Amanda McCaughan Planned completion date for corrective action plan: Already in place and ongoing process.

View Audit 297264

Corrective Action Plans

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