Corrective Action Plans

Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Federal Financial Assistance Listing #93.498 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Reporting Finding Summary: Winneshiek Medical Center claimed expenses that had been reimbursed by another source. The Medical Center is a critical access hospital which means that a portion of their expenditures are covered by Medicare. The Medical Center did not decrease their expenses for the portion that was reimbursed by Medicare. The Medical Center’s special report submitted to the Department of Health and Human Services for Period 4 TIN #420680487 reported these expenses that were reimbursed by other sources which made the report inaccurate as well. Responsible Individuals: Ben Stevens, CFO Corrective Action Plan: Management agrees with the finding. The Medical Center created a “Federal Reporting Review Policy” dated March 9, 2023 as a result of working with HRSA and the 2021FY audit. This policy was approved and is now in process. Anticipated Completion Date: No future reports are anticipated to be filed under this program.

CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the finding. 2. Actions Planned in Response to Finding The District's internal controls related to Maintenance of Effort will continue to improve. 3. Official Responsible for Ensuring CAP Linh Phan, Manager, Accounting and Finance, Grants Accounting 4. Planned Completion Date for CAP The planned completion date for the CAP is June 30, 2024. 5. Plan to Monitor Completion of CAP The Finance Department management will be monitoring the corrective action plan.

Checklists used during file review will be maintained in each client file. Checklists are available on Lane County's website under provider tools. When program ends, staff will store files in bankers boxes labeled by program, fiscal year and destruction date based on program requirements.

Finding 2023-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Laura Hubinger, CFO-Greater Clark County Schools lhubinger@gccschools.com Beverly Woodring, GM Student Nutrition-Aramark bwoodring@gccschools.com Jennifer Cato, Deputy Treasurer-Greater Clark County Schools jcato@gccschools.com Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Currently hand completed lunch applications are verified by the food service department, and reviewed by Deputy Treasurer/Food Service Liaison. The task of random verification for this process will be assigned to a staff position in the business office to check for eligibility compliance requirements. Anticipated Completion Date: April 2024

San Francisco AAP FY 2022/2023 Corrective Action Plan The Adoption Assistance Program (AAP) was selected as a major program in the City's FY 2022/23 single audit. The Auditor tested AAP's compliance with eligibility requirements. The audit sample consisted of 55 on-going active cases, and 5 intake samples for the Fiscal year 2022-2023 from a random sampling. Findings The Auditor tested a statistically valid sample of 60 participants selected from a population of 1,087 cases receiving benefits under the AAP program for the period of July 1, 2022 through June 30, 2023, the Period under review (PUR). The Auditor noted 7 case findings needing improvement. All case findings were from the on-going active case samples. All of the intake cases sampled were correct with no error. There were no findings found to have any dollar amount errors. The auditor identified the following issues: renewal checklists were not submitted with physical files on a consistent basis. It could not be verified that Supervisor reviews were done consistently on all reassessments as the checklists used by the caseworkers, were not consistently found in the case files. Response to findings The Family & Children’s Services Foster Care Eligibility (FCE) unit recognizes the need for improvements through the Auditor’s findings. Inconsistencies were in large part due to the circumstances of the COVID-19 Pandemic. We have changed our previous business practices to improve deficiencies and maintain program integrity. Root Causes - COVID-19 pandemic The pandemic’s restrictions significantly altered FCE’s traditional in-office schedules and business processes, prompting a significant shift towards remote work arrangements and digital transformation. FCE adapted quickly to these operations changes while trying to maintain employee safety. This transition necessitated the need for flexible working hours, increased reliance on virtual communication, implementation of new technologies, and business processes to streamline workflows. - Physical files o FCE, during the PUR of this audit, used physical case files. Digital case files offer many advantages that FCE wasn’t able to access, such as easier accessibility, improved organization capabilities through search functions, greater security measures to protect sensitive data from unauthorized access or loss, and better oversight capabilities. Overall, transitioning from physical case files to digital files will result in having files easily accessible and will increase effectiveness and efficiency. - Staffing issues During the PUR, there were a variety of staffing issues that included leaves, promotions, and shortages. These staffing changes significantly impacted the administration of FCE program benefits. Corrective Actions - Future Staff training o We have recognized the need to develop refresher training for staff that will provide a thorough understanding of our AAP business processes. These trainings will ensure that AAP case reassessments are processed uniformly across the program. By investing in the development of these refresher staff trainings, we aim to equip our staff with the knowledge and skills necessary to perform their roles effectively and contribute positively towards achieving our organizational goals. o Time frame to implement trainings will be no later than 6/1/2024 with completion by 10/2024. - Digital Files o FCE recognizes the need to move from physical case files to digital case files. The COVID-19 pandemic provided the catalyst to speed up the transition to digital files. With the change to digital imaged files, future case reviews and tasks completed by workers and supervisors can, and will, be done more efficiently and will provide the necessary oversight.  Imaging case files conversion project was created in 4/2023.  FCE is currently at 70% percent converted to digital case files since the implementation of CalSAWS (11/1/2023).  FCE plans to convert to 100% digital files by the end of June 30, 2024. - Systematic Reporting o Reports generated from CalSAWS and case tasking will help improve our program’s overall efficiency.  Effective 11/2023, implementation of new task reports generated from CalSAWS will aid staff with reminders of tasks and will improve overall case review.  CalSAWS provides unit Supervisors with reports of overdue, pending and future case actions needed, including AAP reassessments.  By June 30, 2024, FCE will provide unit Supervisors and staff with additional tools to support them with their case tracking and reporting. This includes developing detailed reports accessible through our eligibility system CalSAWS. The AAP Corrective Action plan will be administered by FCE Program Specialist Justin Hyun and overseen by Program Manager, Juliet Halverson.

Under Awarding of Pell Based on Enrollment Status Planned Corrective Action: Crossover PELL only occurs with the College's online population of students and while there are systems currently in place to check for this, it does not always get caught. There is a plan in place to begin a better tracking system within the Financial Aid Office to track who should have crossover PELL so that it can be certain it is not missed. The Financial Aid Office will also request a list of all summer school students from the Academic Office to confirm summer attendance and funding eligibility. Person Responsible for Corrective Action Plan: Lyndsi Romero, Director of Financial Aid Anticipated Date of Completion: 12/31/2024

Finding #2023-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Agriculture, Food Distribution Cluster, Emergency Food Assistance Program (Food Commodities), Assistance Listing #10.569, Passed through The Houston Food Bank, Montgomery County Food Bank, and Galveston County Food Bank, Contract Year: 10/01/22 – 09/30/23. Recommendation: Communicate and emphasize adherence to contractual requirements for determining eligibility and provide training to volunteers as needed to ensure compliance. Planned corrective action: In May 2023, we elected to close the Food Fair operation responsible for the significant deficiency. We will continue to communicate and emphasize adherence to contractual requirements for determining eligibility and provide training to volunteers as needed to ensure compliance to the other food pantries. Responsible officer: Kirk Vogeley. Estimated completion date: June 30, 2024

Significant Deficiency 2023-001. Allowable Costs/Cost Principles United States Federal Communications Commission: COVID-19: Emergency Connectivity Fund Program ALN: 32.009 Condition: Subpart E, 2 CFR §200.404 of the Uniform guidance requires that any monies charged to the Emergency Connectivity Fund Program be reasonable costs allowable under the approved grant application, including the grant requirement that reimbursed costs for devices or equipment are only eligible for a one-per user limitation. During the current year, we noted that the District purchased and was reimbursed for additional devices or equipment beyond the unmet need and the one per-user limitation. Planned Corrective Action: The District agrees with the recommendation, and the Assistant Superintendent for Finance and Management Services will contact the federal agency to determine the appropriate action for the reimbursement of the excess funds received. Responsible Contact Person: Jennifer Segui Assistant Superintendent for Finance & Operations South Country Central School District 189 N. Dunton Avenue East Patchogue, NY 11772 Anticipated Completion Date: June 30, 2024

FINDING 2023-002: OVERAWARDED FEDERAL DIRECT SUBSIDIZED LOAN A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT B2 WAS NOT PROPERLY PRORATED WHEN FEDERAL DIRECT LOANS WERE CALCULATED. B. ACTIONS TAKEN OR PLANNED: MOSTLY ALL STUDENTS THAT ATTEND PIMS NEED TO BE PRORATED FOR THEIR LAST ACADEMIC YEAR. THIS STUDENT SHOULD HAVE BEEN PRORATED, PIMS WILL RETURN THE $2,709 THE STUDENT IS INELIGIBLE FOR. FA MANAGEMENT HAS BEGUN CONDUCTING QUARTERLY FILE REVIEWS WHERE END PROCESSING AND STUDENT PRORATION CALCULATIONS CAN CONTINUE TO BE MONITORED FOR COMPLIANCE.

FINDING 2023-001: INCORRECT PELL GRANTS A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT A1 RECEIVED THE INCORRECT AMOUNT OF PELL AND STUDENT B1 WAS INCORRECTLY ADJUSTED DURING THE R2T4 PROCESS. B. ACTIONS TAKEN OR PLANNED: PIMS HAS FOUND THAT AN EXTRA LAYER OF REVIEW ON EACH PELL DISBURSEMENT ROSTER FROM FAME WILL ELIMINATE INCORRECT PAYMENTS. PIMS REPORTS THE NUMBER OF CREDITS AND ENROLLMENT STATUS TO FAME THEN FAME REQUESTS THE FUNDS BASED ON THIS INFORMATION THAT PIMS ELECTRONICALLY TRANSMITS. IN MOST CASES THE PAYMENT AND THE ENROLLMENT STATUS MATCH BUT FOR STUDENT A1 THAT IS NOT THE CASE. GOING FORWARD, AT THE TIME THE ROSTER IS PRODUCED THE FA OFFICE WILL VERIFY EACH PAYMENT BEFORE THE ROSTER GOES TO THE BUSINESS OFFICE. PIMS WILL ALSO RETURN THE $811 OF 21/22 PELL THAT STUDENT A1 WAS INELLIGIBLE FOR. PELL ADJUSTMENTS DURING THE R2T4 PROCESS WILL BE LOOKED AT BY BOTH THE FA PROCESSOR AND SUPERVISOR. AS WITH THE PELL MATCHING THE STUDENTS' ENROLLMENT WHILE ATTENDING THE INSTITUTE'S FA OFFICE UNDERSTANDS THAT THE SAME CONCEPT IS APPLIED WHEN A STUDENT WITHDRAWAL AND A PELL RE-CALCULATION IS REQUIRED. PIMS WILL RE-REQUEST ON BEHALF OF STUDENT B1 $431 IN PELL GRANT FUNDS.

Management’s Response and Planned Corrective Actions: 1. The corrective action planned: a. Pinehurst Management was overseeing property through 4/30/23. ShelterCare was assigned as new managing agent 5/1/2023. b. ShelterCare is working to ensure that the onsite manager will be trained in HUD compliance. c. We are currently prioritizing recertifications by oldest first so we are able to catch them up and get the property certifications back on track. d. Monthly review of TRACS reports to ensure recertifications are being completed in a timely manner. 2. The name of the contact person(s) responsible for the corrective action a. Dana Petersen-Crabb, Sr. Director of Housing, ShelterCare b. Amanda Smith, Property Development Manager, ShelterCare 3. The anticipated completion date: a. Monthly review of TRACS reports will be implemented by 10/1/2023. Training was provided to new staff in February of 2024. Recertifications are expected to be completed by June 30, 2024.

II. FEDERAL FINDINGS AND QUESTIONED COSTS 2023-001 50000 - ELIGIBILITY Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. Meal applications are verified a total of three times. The Nutrition Specialist is the Determining Official, the Director is the Confirming Official, and either the Secretary or Clerk is the Verifying official. Each official reviews the application for accuracy. Name of responsible individual: Brenda Zarate Implementation Date: 7/1/2023

Finding 2023-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Sandy Denny – Food Service Director Contact Phone Number: 812-952-2555 ext. 250 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will implement a formal review of the meal system income threshold parameters used to ensure the eligibility determinations are correct. Anticipated Completion Date: July 2024 (new school year)

Finding Number: 2023-003 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents didn’t begin until the Summer 2023, with an automated procedure being implemented in the Fall 2023 semester. Contact person responsible for corrective action: Kent McGowan, Assistant Director, Office of Financial Aid Anticipated Completion Date: 01/01/2024

Finding 2023-001 – Housing Opportunities for Persons with AIDS Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Housing Opportunities for Persons with AIDS Program – ALN 14.241, Grant Year 2022 & 2023 Corrective Action Plan: The two tenant files with income calculation errors resulting in the tenant overpaying. This has been corrected on both files and tenants have had a HAP payment in excess of their rental amount to provide a credit. The tenant file with no recertification in 2022. We have no idea how this could have happened unless a wrong date prior to this. The recertification was done in July 2023 and scheduled to be done for July 2024, so we are going forward. Additional file reviews will be done in the future. Person Responsible: Joseph Beasley and Connie Howard Anticipated Completion Date: Everything except the additional file reviews has already occurred (2/5/24).

FINDING 2023-001 Finding Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications 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 Special Tests and Provisions - Verification of Free and Reduced Price Applications compliance requirement. Based upon the number of approved applications on file on October 1, the School Corporation was required to select a sample of three applications for fiscal year 2022- 2023 that were approved for free and reduced price meals, to verify the applicants' eligibility for the benefits received. The School Corporation requested income documentation from each applicant to perform the verifications as required. The School Corporation did not receive a response from any of the applicants. As a result, the student included in each application should have had a change in status from free or reduced to paid. However, for two of the applicants, the student was flagged in the system as no response, but the students' statuses were not updated to reflect that each was no longer eligible for free or reduced price meals. Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number- 812-689-6282 Email- lmiller@sripley.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 28 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This finding was a result of a new staff person in the position working with software that was new to her. It was noted by the auditor that the application status was changed to paid in the verification status. The staff person involved did not know that she needed to make another change in the software other than changing the application status. We have discussed with the person responsible for this regarding the needed two-step process to change a student’s status. Additionally, the staff person has set up a process for segregation of duties. A second person will be reviewing the screens after verification changes are made. This person will also sign off on the paper/report to show the second review and segregation of duties. Anticipated Completion Date: Immediately, February 2024

Federal Agency Name: Department of Health and Human Services Program Name: COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN #420868216 Federal Financial Assistance Listing #93.498 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: The Hospital claimed expenses in the HHS special report for Period 4 that were related to services to be performed after the period of availability. Responsible Individuals: Craig Carstens, CFO Corrective Action Plan: Management agrees with the findings. Management will ensure that all expenses claimed are properly documented and supported by appropriate documentation, including invoices, receipts, and service agreements. Management will provide training and education to relevant staff members responsible for preparing and submitting expense claims to ensure they understand the period of availability and the importance of accurate reporting. Management will implement controls and procedures to prevent similar errors in the future. This may include implementing a review process for expense claims to ensure compliance with reporting requirements. Management will communicate the importance of accurate reporting and adherence to reporting equirements to all relevant staff members. Emphasize the impact of inaccurate reporting on the hospital's reputation and compliance status. Management will Establish a system for ongoing monitoring and oversight of expense reporting processes to identify and address any issues or discrepancies in a timely manner. Anticipated Completion Date: 2/26/2024.

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS has requested the vendor's records. Once received, DSS will audit those records to provide reasonable assurance that the contractor administered the LIHWAP federal grant program in accordance with federal statutes, regulations, and the terms and conditions of the federal award before it closes the grant award. Estimated Completion Date: 6/30/2024

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director Senior Benefit Programs Denise Surber, EAP Manager - Division of Benefit Programs Corrective Action Planned: DSS will work to provide additional training to local agency eligibility workers on how to properly determine and document eligibility determinations in the case management system. Additionally, DSS will consider monitoring local agency eligibility worker’s use of manual overrides to confirm that they properly document eligibility determinations in the case management system. Estimated Completion Date: 12/31/2024

Responsible Contact Person(s): Barry Davis, Chief Information Security Officer and Director of Information Security & Risk Management Steve McCauley, Assistant Division Director Corrective Action Planned: DSS will perform an annual access review of user accounts for the case management system. Estimated Completion Date: 12/31/2024

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Kavansa Gardner, Information Technology Manager Corrective Action Planned: DSS will perform and document a conflicting access review for the case management system to identify the combinations of roles that could pose separation of duties conflicts and ensure compensating controls are in place to mitigate risks arising from those conflicts. Additionally, DSS will work with a vendor to update the role-based security access documentation to reflect all system changes from prior case management system related releases when there are proposed changes to the roles matrix. Estimated Completion Date: 12/31/2024

Finding No. 2023-001 Eligibility – Tenant Files Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-001 from June 30, 2022 (initially reported June 30, 2021) Statement of Condition Out of a total tenant population of approximately 194 vouchers, 20 files were selected for testing. Exceptions were noted as follows: • 1 file where a math error on zero-income calculation resulted in an increase in HAP rent from $709 to $712. • 1 file where a math error on zero-income calculation resulted in a decrease in HAP rent from $961 to $912. • 1 file where social security income was calculated using 2022 amounts despite move-in date in February 2023. As a result, HAP rent decreased from $561 to $546. • 1 file where social security income was calculated using 2022 amounts despite annual re-exam in February 2023. As a result, HAP rent decreased from $709 to $687. In addition to the above, during our new admissions testing (5 tested out of 44 new admissions) we noted the following: • 1 file that did not contain a signed lease agreement. Recommendation The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken We concur with this finding and have implemented various controls. A tenant file and unit quality control procedure has been developed and implemented.

Finding 2023-003: Allowable Cost/Cost Principles and Reporting Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 4 TIN#237224698 Federal Financial Assistance Listing Number: 93.498 Finding Summary: Imagine the Possibilities, Inc. final eligible expenditure listing identified as eligible and claimed under the Provider Relief Fund program was not reviewed and approved by a separate individual outside of the preparer. In addition, the Organization’s special report submitted to the Department of Health and Human Services for Period 4 TIN #237224698 was not reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Megan Simmons, CFO Corrective Action Plan: Management agrees with the finding. The Organization will review the internal controls and implement improvements related to allowability of all federal cost claimed, including those regarding the identification of duplicate items and approved costs. Anticipated Completion Date: March 31, 2024

The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Award Program Audit Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs Federal Catalog Numbers: 14.871 and 14.879 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Section 8 Housing Choice Vouchers Program - No Mainstream Vouchers Program - Yes Material Weaknesses in Internal Control over Compliance for Eligibility for the Mainstream Vouchers Program Significant Deficiency in Internal Control over Compliance for Eligibility Section 8 Housing Choice Vouchers Program Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 5,295 units. Of a sample size of seventy-one (71) tenant files, the following was noted: • HUD 9886 Form was missing in 1 file • Annual HUD 50058 recertification form and related verification of income and assets was missing in 1 file Our sample size is statistically valid. Known Questioned Costs: • Mainstream Vouchers $19,830 • Section 8 Housing Choice Vouchers Program $1,875 Cause: There is a significant deficiency in compliance for the eligibility type of compliance related to the maintenance of tenant files in the Section 8 Housing Choice Vouchers Program. There is a material weakness in compliance for the eligibility type of compliance related to the maintenance of tenant files in the Mainstream Vouchers Program. The Authority has not properly maintained tenant files in compliance with program requirements following the expiration of HUD waivers. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. The Mainstream Vouchers Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. Following the expiration of the COVID-19 HUD regulatory waivers, the Authority experienced a large backlog of reexaminations along with higher than usual rates of staff turnover and other staff capacity challenges related to the pandemic. Authority management developed and implemented a plan to rapidly work through the backlog, and has made significant progress to bring the program into compliance. The audit resulted in one missing consent form (HUD 9886), and one re-examination (HUD 50058), which is noted as missing. While the consent form had expired and a new consent form was required during the audit period, the income information collected for the household was collected while the consent form was still valid. With regards to the re-examination noted as missing, this re-examination was performed late, having been completed just six days after the end of the audit period. The re-examination was initiated on time, and the delay in completing the re-examination was caused by the program participant’s delay in providing the required documents. Additionally, the Authority has been selected for participation in the Moving to Work program ('MTW'). Alternative re-examination schedules, including biennial re-examinations, are an approved MTW activity allowable through the MTW Operations Notice. The Authority has received HUD approval of a waiver that allows the use of an alternate re-examination schedule effective July 1, 2023. This re-examination schedule is in effect currently and will be in effect for the entire duration of the subsequent audit period. Based on the transition to biennial and triennial re-examinations, the Authority has already come into compliance with timely recertifications. Further, the Authority management is in the process of implementing enhanced Quality Control procedures, with staff to conduct ongoing internal audits over the course of the year. If the U.S. Department of Housing and Urban Development has any questions regarding this plan, please call Aaron Pomeroy, Finance Director at 831-454-5908.

Finding 2023-001: Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended Sessions Village 202 obtain the missing signed documents if the tenant still resides at the project. In addition, it was recommended Sessions Village 202 review all tenant files to ensure all other records are complete. Also, it was recommended staff involved in the tenant move-in process review the requirements and revise their current process and procedures as needed to ensure the appropriate forms are completed correctly and kept in the tenant files going forward. Additional controls could include completing a checklist of required signed forms obtained during the move-in process. Action Taken: The first tenant listed above no longer resides at the project and a signed HUD model lease cannot be obtained. On November 7, 2023, the Property Manager at Sessions Village 202 obtained the missing signed documents for the second tenant listed above. The Property Manager at Sessions Village 202 will review the process and procedures in place, and implement controls to ensure the appropriate forms are completed correctly and kept in the tenant files going forward.