Corrective Action Plans

Name of Contact Person: Sue Ledford, Executive Director. Corrective Action and Proposed Completion Dates: 1. ED monthly 1:1 with Directors meetings to continue. Implemented 5/1/2022. 2. Monthly Group meeting with Directors/Leadership Team to continue. Implemented 5/1/2022. 3. Internal Audit (monitoring) to be conducted quarterly by each Departmental Director. Partner with Leadership Team to complete. Implement by 3/30/23. a. Review mandated contractual compliance, financial compliance, and adequate documentation processes. b. Documentation to filed on FSCA Common Drive. 4. Continue internal audits/monitoring of HUD tenant files with focus on compliance to Administrative Plan, HUD notices, and proper documentation. Implemented 7/1/22.

2022-001: Eligibility Recommendation: We recommend that management implement a control to ensure documentation is maintained to support that all cases have been reviewed when closed. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: We will draft a supervisor case closing checklist. We will distribute the checklist to supervisors once it is finalized. We will then pull a random sample of recently closed cases in October to see if supervisors are completing the review as instructed. Name of the contact person responsible for corrective action: Daniel Lindsey, Chief Litigation Officer Planned completion date for corrective action plan: September 30, 2023

Finding: 2022-002 Agency: U.S. Department of Health and Human Services ? ALN 93.558 ? TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF) Name of contact person and title: Shelia Triplett, Executive Director Anticipated completion date: September 2023 MYCAP?s response: Concur MYCAP agrees with this finding and provided the following response for corrective action: U.S. Department of Health and Human Services ? Significant Deficiency ? Internal Controls over Compliance ? Eligibility Plan of Action: The Support Specialist will gather all required documents for the TANF program, ensuring the application documents and required income are on file. The Chief Operating Officer (COO) will conduct a second review of all TANF files for proper eligibility requirements including recalculations of income, ensuring all files are eligible, marking the file with initial and approval for processing.

2022-004 Material Weakness in Controls over Compliance: Activities Allowed or Unallowed We agree with the recommendations and have made improvements to our procedures. The schools were not prepared for the rapid expansion of the food program, not only at our two high schools, but our partner schools' which requested contracted breakfast/lunch food services for their students as well. This unprecedented growth coupled with supply chain issues from food wholesalers, and shortage of employees in the hiring pool, only exacerbated our issues. The audit sample showed a large error rate for one of the schools. We have gone through the entire year for the school(s) individual count sheets. In the event the Michigan Department of Education determines that the identified discrepancies warrant a repayment we have recorded an allowance in the financial statements for the year ended June 30, 2021. Staff were not properly trained in how to complete the count sheets; however, supervisors did not take the time once they saw there was a problem due to everyone trying to simply get the meals served to the children. In addition, there was a lack of oversight of the Food Service Manager by her direct supervisor. At the time of the 2021 audit, when the issue was brought to our attention, we developed new procedures. School staff performing counts have been trained in how to properly complete the count sheets. The Business Manager now reviews all count sheets and ties counts to the summary report used to submit claims prior to submittal for reimbursement. Given that training and implementation of procedures did not fully occur until January 2022, there are errors in counts prior to implementation of the procedures and repeat findings in fiscal year 2021-22. In addition, with the end of the pandemic, beginning with the 2022-23 school year, the schools were able to resume using electronic software to accurately capture the meal counts.

Legal Name: Housing and Community, Inc. Audit Firm: CohnReznick Period covered by the audit: January 1, 2022 ? December 31, 2022 Corrective Action Plan prepared by: Name: James Butcher Position: SVP of Finance & Accounting Telephone Number: 210-821-4392 1. Current Findings on the Schedule of Findings and Questioned Costs 2. Finding 2022-001 a. Comments on the Finding and Each Recommendation Management did not certify income through the EIV system as part of the initial certification procedures for new tenants. b. Action(s) Taken or Planned on the Finding The management company is highly aware of the importance surrounding the EIV information and timeline of when these reports need to be pulled for documentation and review. We will make sure to provide additional training to ensure we remain in compliance going forward. We have also mandated manager reminders be put in place every time new tenants move in, ensuring the EIV be pulled within 90 days and 120 days prior to annual recertifications being performed for existing tenants. Management has also reviewed this proposed resolution with the Southwest Housing Corporation, the area HUD representative, and they have approved the aforementioned proposed resolution.

2022-001 U.S. Department of Agriculture, Food, and Nutrition Service Emergency Food Assistance Program CFDA Number: 10.568/10.569 Passed Through: The Arizona Department of Economic Security Pass Through Number: CtR052634 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding ? Significant Deficiency in Internal Control over Compliance Condition/Context ? Internal control procedures over eligibility requirements for 1 of 40 eligibility sheets tested indicated there was no certifying signature by the eligible recipient agency volunteer, and there was no evidence of secondary review by the distribution agency program officials. Contact Person ? Chariti Stern, Chief Program Officer Corrective Action Plan ? United Food Bank has entirely onboarded all TEFAP agencies to be active on Link2Feed; however, a handful of agencies still use sign-in sheets due to technology limitations. At the 2022 Agency Conference, a presentation was done that conveyed the importance of checking all signatures on United Food Bank documents. The 2022 Partner Agency Handbook explains that a signature is required for the reports and sign-in sheets to be authorized and accepted by United Food Bank. Re-training United Food Bank staff has also occurred to ensure that all reports have the correct signatures and that the United Food Bank staff?s initials are on all documents to ensure that the reports were reviewed.

U.S. Department of Housing and Urban Development, passed through the Massachusetts Housing Finance Agency Section 8 Housing Assistance Payments Program ? Assistance Listing No. 14.195 Significant Deficiencies 2022-001 Condition: 1) 1 of the 40 tenants selected for testing had an incorrect amount reported for social security income on Form HUD-50059. 2) 1 of the 40 tenants selected for testing had an amount reporting for medical expenses on Form HUD-50059 that was not supported by documentation in the tenant?s file. Auditor's Recommendation: We recommend that an internal control procedure be implemented to ensure that all HUD-50059 forms are completed accurately and all required information is obtained and maintained within the tenant files. Action Taken: 1) Management will meet with the tenant to properly investigate causation for the finding noted above. Pending the outcome of the investigation, Management will correct the July 2022 Annual Certification with the expectation of correcting the income used to tabulate the tenant?s level of rental assistance, the tenant will not be charged for the error, and HUD will be reimbursed for subsidy accordingly. 2) Management removed the active medical expense from the expense tab on the management software. The medical expenses do not impact the level of rental assistance since the amount did not exceed 3 percent of the tenant?s household income. Nevertheless, Management reclassified the medical expense as inactive to ensure the medical expense is not part of the future certifications.

Finding 2022-001 - Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Significant Deficiency Corrective Action Plan: GHA will implement the following immediate and on-going actions to correct internal control over participant files in the Housing Choice Voucher program: Immediate Response: GHA is guided by seven core values. The first of which is Integrity. Upon discovery of forged documents, in March 2023 it was clearly communicated and reiterated that any actions, such as alternation, falsification, or fabrication is unacceptable and the appropriate disciplinary would be taken. A prompt and thorough investigation resulted in a team member being terminated for forging documents and a change is senior leadership. A third-party consultant was brought in immediately to complete an assessment and review of the voucher programs internal process to provide immediate process improvement along with reviewing an additional sample set of participant files. Ongoing Response: GHA will improve internal controls in the area of file review and quality control and assurance by completing multiple examinations of applicants/program participants calculations at initial move- in, interim, and re-examination anniversary. In addition to the two-prong reviews being completed by team members, a third-party compliance company may be used to review all initials, and up to twenty-five percent (25%) of all interim and re-examination of program participants' files. Internal/external training will be provided to each team member involved with the determination of rent and maintaining tenant files, as well as programmatic eligibility and administration of the housing choice voucher program in 2023. Voucher Administration leadership will continue to work closely with the Compliance Department to ensure that GHA's program files are compliant with all federal regulations, rules, HUD guidelines as well as GHA's policy and procedures. Anticipated Completion Date: The above plans will be implemented immediately and will be continuously monitored. We anticipate a completion date of December 2023. Responsible Person: Meredith Daye, Chief Operating Officer

Views of the Responsible Officials and Planned Corrective Actions: During the pandemic, SVDP distributed Emergency Rental Assistance Program funding that was a new, specific response to the COVID pandemic. Due to significant staff turnover with the team administering these services, there was misplacement of participant income verification documentation for six cases. SVDP subsequently confirmed the income eligibility for these six participants and is therefore confident that the participants were in fact eligible for the assistance received. However, we recognize that the income eligibility documentation for these six participants could not be found at the time of the audit and as a result are undertaking quality assurance and compliance measures to ensure participant files are always fully compliant in order to prevent this type of error from occurring again. These measures include: (a) instituting a new compliance scorecard for internal chart reviews, (b) monthly peer chart reviews, (c) frequent case management supervisor chart reviews, (d) spot chart auditing by SVDP?s internal Quality Assurance Specialist, and (e) updated training for case management staff on procedures for participant case files and for the retention of forms and other documents.

We agree with this finding that certifications of direct assistance provided to individuals were not obtained. We have taken steps to correct the issues identified and during June 2023 we modified our procedures for certification of direct assistance received by clients. We will review our process and procedures for obtaining signatures from clients receiving gift cards and other forms of direct assistance, including non-financial assistance as well as rent and utility assistance, to ensure that amounts received, and dates received are attested by clients via signature or via an acceptable alternative electronic attestation.

Management Response and Corrective Action: HACLA administers the third largest Housing Choice Voucher program in the United States with an allocation of 52,646 vouchers and 44 percent of all HACLA certificate and voucher resources are housing formerly homeless individuals and families. The average income of all program participants is $19,815 per annum while the rents in Los Angeles are high. These participants have extremely low incomes, are at-risk households, living in a high-rent market, and without the subsidy would not be able to afford decent, safe, and sanitary housing. Further, the program is a valuable resource because in any given night there are more than 75,000 unsheltered residents in the Los Angeles area. HACLA?s highest priority is to house individuals which without the assistance of the program would be unable to pay rent and fall into homelessness or forced back to homelessness. With that said, program compliance is also a high priority for HACLA. As stated in Title 24 Code of Federal Regulations (24 CFR) ?982.516(a) the public housing authority must conduct a reexamination of family income and composition at least annually. Given HACLA?s very large program and the population it serves it is impossible to complete the annual reexamination within 12 months for 100% of the participants. Due to extenuating circumstances such as health issues, the death of the head of household and other challenges the family may be facing, it is impossible to have 100% compliance with this CFR. The housing authority must provide flexibility and extensions. The alternative would be for the housing authority to move forward with terminating the assistance in order to be fully compliant with the CFR--a position that HACLA does not take lightly given the humanitarian crisis in Los Angeles. The CFR is simply no longer in line with the realities of administering the program, and the expectation of the community. HACLA believes that HUD recognizes this in its monitoring practices for SEMAP. Nonetheless, HACLA?s goal is to complete all annual reviews within 12 months and will strike an appropriate balance to do so. These audit findings will assist HACLA in further advocating with HUD to adjust the regulatory requirement on annual reexamination completion time periods to be more in line with the reality of the homeless families that HACLA serves. HACLA?s Section 8 Department has the controls in place to ensure annual reexaminations are completed timely. Management will continue to proactively work with staff on an ongoing basis to ensure that participant families submit documentation timely or begin the intent to terminate process. This is a fine line, however, as HACLA is in the business of housing not terminating families. In line with HACLA?s Vision Plan, Executive Management is committed to improve processes across business lines. In mid-2022, HACLA contracted with Guidehouse, Inc., a consulting firm that works with housing authorities across the country such as the largest--the New York City Housing Authority, to identify and implement process improvements to simplify operations, meet regulatory requirements more efficiently and provide better customer services to applicants, participants and landlords. Guidehouse is in the process of that analysis and it is HACLA?s expectation that there will be an improvement and associated training in the annual reexamination completion process through better monitoring reports and dashboards to be provided in a shift to a better housing program platform as they have recommended. Person Responsible: Director of Section 8

CORRECTIVE ACTION PLAN Audit Finding Reference Number: 2022-002 Contact Information: Pam Barnes Chief Financial Officer Health Services of North Texas, Inc. Plan of Corrective Action: HSNT is committed to addressing this condition promptly, thoroughly and will continue to monitor for policy and procedure adherence. The case manager will ensure overall compliance with eligibility determination every six (6) months by collecting proof of income, including assessing income within 500% federal poverty level (FPL), proof of residence, and obtaining documentation of HIV diagnosis from testing agency. The eligibility process will be conducted annually and at 6-month eligibility recertification. The manager of programs will monitor case managers? new clients enrolled into Ryan White daily to verify eligibility documents are complete. Additionally for existing patients, appointment calendars are monitored and cross-referenced for documents in the patient?s Electronic Medical Record. Ryan White standards of care eligibility is verified every six months. In the interim a process to standardize the naming convention of eligibility documents has been completed to allow further auditing and oversight of the collection of eligibility documents. In consultation with our Ryan White program Monitor (Dallas County) we have received technical assistance and guidance related to eligibility. All items above have been completed on March 31st, 2023 Anticipated Completion Date: March 31, 2023

CORRECTIVE ACTION PLAN Audit Finding Reference Number: 2022-001 Contact Information: Pam Barnes Chief Financial Officer Health Services of North Texas, Inc. Plan of Corrective Action: HSNT is committed to addressing this condition promptly, thoroughly and will continue to monitor for policy and procedure adherence. The case manager will ensure overall compliance with eligibility determination every six (6) months by collecting proof of income, including assessing income within 500% federal poverty level (FPL), proof of residence, and obtaining documentation of HIV diagnosis from testing agency. The eligibility process will be conducted annually and at 6-month eligibility recertification. The manager of programs will monitor case managers? new clients enrolled into Ryan White daily to verify eligibility documents are complete. Additionally for existing patients, appointment calendars are monitored and cross-referenced for documents in the patient?s Electronic Medical Record. Ryan White standards of care eligibility is verified every six months. In the interim a process to standardize the naming convention of eligibility documents has been completed to allow further auditing and oversight of the collection of eligibility documents. In consultation with our Ryan White program Monitor (Dallas County) we have received technical assistance and guidance related to eligibility. All items above have been completed on March 31st, 2023 Anticipated Completion Date: March 31, 2023

2022-003 Waiver of Asset Ceilings Legal Services Corporation ALN#09.233100 Finding: Per LSC Reg.# 1611.3.d Financial eligibility policies, (1) As part of its financial eligibility policies, every recipient shall establish reasonable asset ceilings for individuals and households. In establishing asset ceilings, the recipient may exclude consideration of a household?s principal residence, vehicles used for transportation, assets used in producing income, and other assets which are exempt from attachment under State or Federal law. (2) The recipient?s policies may provide authority for waiver of its asset ceilings for specific applicants under unusual circumstances and when approved by the recipient?s Executive Director, Project Director, or his/her designee. When the asset ceiling is waived, the recipient shall record the reasons for such waiver and shall keep such records as are necessary to inform the Corporation of the reasons for such waiver. Per Legal Services NYC policy, asset ceiling is $25,000. Out of sixty (60) LSC cases selected for testing, a waiver approval of asset ceilings for two (2) cases was not obtained. Corrective Action Taken or Planned: The paralegal who closed the case has been instructed to review for this kind of error before closing. The Compliance Officer is working with IT to see if there is a way to make the ?continue? button be required so it cannot be bypassed by clicking to page back. Upcoming trainings on closing cases will stress the importance of verifying accuracy and consistency in eligibility information before closing. The intake paralegal has been instructed not to use the Asset Override Note field to enter basic case notes, and both she and the paralegal who closed the case has been instructed to verify eligibility information against other data in the case before closing. Financial eligibility training will emphasize that the Asset Override Note field should only be used for relevant information, and continue to emphasize that Asset Waivers require written supervisor approval that must be uploaded into the case file.

2022-002 Financial Eligibility ? Assets Definition Legal Services Corporation ALN#09.233100 Finding: Per LSC Reg.# 1611.2(d) Definition of Assets, ?Assets? means cash or other resources of the applicant or members of the applicant?s household that are readily convertible to cash, which are currently and actually available to the applicant. Out of sixty (60) LSC cases selected for testing, three (3) cases were reported as having an asset above ceiling ($25,000). However, the reported assets did not meet the asset the definition of assets as per LSC Reg.# 1611.2(d). These program clients were indeed financially eligible but the asset classification in Legal Server was not accurate and did not support the eligibility conclusion. Corrective Action Taken or Planned: All financial eligibility trainings and compliance trainings describe what does and doesn?t constitute an includable asset and instruct employees to click on the ?Exclude? button where appropriate. We will continue to emphasize that this is necessary in trainings throughout the year.

2022-001 Retainer Agreements Legal Services Corporation ALN#09.233100 Finding: Legal Services Corporation (LSC) Reg. #1611.9.a Financial Eligibility section 9 Retainer agreements requires that when an LSC grant recipient provides extended service to a client, the recipient shall execute a written retainer agreement with the client when representation commences or as soon thereafter as is practicable. Out of sixty (60) LSC cases selected for eligibility testing, a retainer was not executed for one (1) extensive service case and a retainer agreement for one (1) case could not be located. However, there is a case note written by the former employee who handled the case documented that the retainer agreement was obtained. Corrective Action Taken or Planned: The paralegal was admonished and provided with additional training stressing the need to have an executed retainer uploaded to each case file where needed. All compliance trainings for staff emphasize that retainers must be executed and uploaded to Legal Server prior to commencement of legal representation. We will continue to emphasize the need for this at trainings throughout the year.

Mater Academy, Inc. March 21, 2023 HLB Gravier, LLP 396 Alhambra Circle, Suite 900 Coral Gables, Florida 33134 RE: MANAGEMENT?S RESPONSE TO AUDITOR?S RECOMMENDATION The following is management?s response to your recommendations: ML-2022-03 Income Verification Recommendation We recommend that the Organization adhere to the control procedure of changing the lunch status and provide additional training and oversight as necessary. Management Response The Organization has appointed staff to provide additional training to ensure full compliance with the changing eligibility statutes once verification is completed. Proof of status change from the POs system will be required to ensure full compliance. Sincerely, Ana M. Martinez Authorized Signer Mater Academy, Inc. "

Management has reviewed the draft Schedule of Findings and Questioned Costs for FY 2022. We agree with the finding and are actively working to improve processes to ensure student files are uploaded timely. The Vice President of Student Services has already begun training with the Assistant Registrar to ensure these errors are not duplicated in future years. Additionally, we have reached out to POISE to find the source of the data collection issue. We feel certain as we move forward with a new student information system these errors will be resolved.

Finding Number: 2022-005 Finding: Emergency Rental Assistance Program Allowable Costs and Activities and Eligibility. Disbursement of benefits under the program may have been made to individuals that were not eligible for benefits. Planned Corrective Actions: In the future, we will consult with our local jurisdiction to discuss any guidance as it relates to eligible activities and will formally document our discussion to include a set of policies and procedures that mitigate risks to the best of our ability. Anticipated Completion Date: Completed. Responsible Contact Person: David France, Director of Finance

2022-001 Income Certifications Name of contact person ? Angela Riley, CFO Corrective action ? The Corporation agrees with the finding, and has continued to implement strategies to address these issues throughout 2021 and 2022, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations. Proposed completion date ? Management has begun the corrective action and is expected to have additional internal controls and training done by December 31, 2023.

Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs / Cost Principles, E. Eligibility, and N. Special Tests and Provisions ? Material Weakness in Internal Controls Over Compliance Federal Program: COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing Treatment, and Vaccine Administration for the Uninsured, Assistance Listing No. 93.461 (COVID-19 Uninsured Program) Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Pass-Through Award Period: January 1, 2022 through December 31, 2022 Views of responsible officials and planned corrective actions: Management agrees with the finding as reported. It is noteworthy that the COVID-19 Uninsured Program (the Program) ceases to accept claims for testing and treatment effective March 22, 2022. Claims for vaccinations were no longer accepted after April 5, 2022. Should HRSA funding be re-instated, the Network is committed to ensure proper internal controls over compliance are established to fully comply with the Program?s set terms and conditions.

As a corrective measure, along with additional staff training, Vanderbilt will be implementing a quality control step to ensure that the notifications are properly made. This step will essentially do a sweep of students whose financial aid awards have been finalized (but prior to the actual disbursement of funds) but have not yet received the required financial aid notification letter. This process will be executed on a weekly basis. Vanderbilt University expects to have this process in place by November 2022. For follow-up questions and information, please contact Brent Tener, Executive Director of Student Financial Aid and Scholarships at Vanderbilt University.

March 17, 2023 Cognizant or Oversight Agency for Audit Coffeyville Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2022. The findings from the March 17, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2022-001 ? Special Tests and Provisions ? Enrollment Reporting Condition: During our testing of the enrollment reporting, it was noted that Coffeyville Community College did not have internal controls of reporting changes in student status? to NSLDS. Recommendation: Policies and procedures should be written to provide additional training and oversight of staff responsible for enrollment reporting. We recommend the College establish an oversight process that includes additional controls necessary until staff are fully trained in the area of enrollment reporting. Views of responsible officials and planned corrective action: The VP for Academic Services will review and establish written policies/procedures to provide transparency regarding graduation deadline dates for awarding academic degrees, as well as student current enrollment status at the institution. The VP for Academic Services will hold meetings with the Registrar, Advising, Financial Aid, and Institutional Research departments to identify and address data inconsistencies prior to enrollment reporting dates. If the Oversight Agency for Audit has questions regarding this plan, please call Jeff Morris, Vice President for Operations and Finance. (620)251-7700. Sincerely, Coffeyville Community College

City of Anaheim, California Corrective Action Plan For Single Audit Reports For the Year Ended June 30, 2022 Finding #2022-001 Eligibility Program: Home Investment Partnership Program (CFDA # 14.239) Condition: During the test work over continuing eligibility requirements for loan recipients of the program, it was noted that the City did not have sufficient controls in place nor were adequate records maintained to verify that the property was the principal residence of the homebuyer during the period of affordability described in the finding. Corrective Action Plan: During fiscal year 2022, the Department underwent a reorganization as the City Council approved the establishment of two separate departments, Housing & Community Development and Economic Development. In April 2022, the Department contracted with Keyser Marston and Associates to train newly hired staff to assist the Department with Loan portfolio monitoring and to ensure on-going compliance. In addition, the Department will be implementing new procedures through a program called Neighborly to facilitate and streamline the process for all outstanding loans. The Neighborly program will assist with loan tracking, communicating with loan participants and obtaining annual compliance certifications. The Department will be focusing its resources to ensure on-going compliance and plans to close this finding in fiscal year 2023. Contact Person: Andy Nogal, Deputy Director Anticipated Completion Date: June 2023

Finding 2022-001 ? Housing Choice Voucher Tenant Files ? Eligibility ? Noncompliance & Significant Deficiency ? Housing Choice Voucher Program ? CFDA #14.871 This last year was an extraordinary year for the New Reidsville Housing Authority. Not only did the Authority and its employees continue to experience the effects of the COVID pandemic, but two key employees, the HCV and Public Housing Specialists with almost 33 years of combined Authority experience, passed away. As a small housing authority, the sudden declining health and subsequent passing of two of the five office employees within weeks of one another left a significant void in knowledge and experience. Although the two employees that passed were cross trained on each other?s jobs, no remaining employees were fully trained or capable of assuming those positions. Recruiting began immediately, and all employees worked together to keep the departments functioning. In the months after the employees? passing, temporary and consultant labor was utilized until the Authority was able to find permanent replacements. The new personnel have proven to be extremely capable in a very short amount of time, and the process began immediately to organize and review each tenant and participant file to ensure completeness and compliance. Unfortunately, not all the files had been reviewed by the time of the annual audit. Prior to the annual audit, all new and existing housing personnel received training and cross training on both the Public Housing and Housing Choice Voucher programs. In addition, the Authority began discussions with staff regarding the implementation of a peer review system where the HCV and PH specialists will audit each other?s files to ensure that accurate calculations are performed and that all required components and signatures are present in each file. An added layer of Executive Director review of a sampling of the Specialists? files will occur as well. The processes of cross training continued with software and housing-related training, written documentation of all tasks, file review, and office-wide organization of all pending items within each office and department will continue. Corrective Action Plan: We concur with this finding. We have emphasized to our new staff the importance of accurate tenant file information and are confident these errors and oversights will not occur in the future. A comprehensive tenant file review was underway but not complete at audit time. All new staff have been trained and cross-trained, and a peer review system with an added layer of Executive review of all tenant files and calculations is in the process of implementation. Person Responsible: Mitchell Fahrer, Executive Director Anticipated Completion Date: June 30, 2023