Corrective Action Plans

Federal Award Findings and Questioned Costs Item 2024-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons with Disabilities (Section 811) Program Federal Assistance Listing: Number 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to insure that EIVs and recertifications are performed timely, inspections are completed, waitlists are being completed and followed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2024. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance. Completion Date: June 30, 2025.

Federal Award Findings and Questioned Costs Item 2024-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons with Disabilities (Section 811) Program Federal Assistance Listing: Number 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to insure that EIVs are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2024. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance. Completion Date: June 30, 2025.

Federal Award Findings and Questioned Costs Item 2024-003 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Home Investment Partnership Program Federal Assistance Listing: Number 14.239 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to ensure that HQS inspections are done in a timely manner. Staffing shortages at the property had an impact on the completion of HQS inspections in 2024. As new staff are brought onboard training is provided and management will continue to coordinate and provide assistance to on-site staff to ensure that the inspections are being completed and properties are in compliance.

Federal Award Findings and Questioned Costs Item 2024-005 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Program Federal Assistance Listing: Number 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Action Taken: REACH has policies in place to ensure that move out inspections are done in a timely manner. Staffing shortages at the property had an impact on the timeliness of the move out. As new staff are brought onboard training is provided and training is provided to on-site staff to ensure that the inspections are being completed and properties are in compliance. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.

Federal Award Findings and Questioned Costs Item 2024-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Program Federal Assistance Listing: Number 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2024. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Management will continue to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.

Reference # and title: 2024-003 Controls and Compliance over Title I Targeting (Eligibility) Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title I 84.010A 2024 Criteria or specific requirement: Title I, Part A of the Elementary and Secondary Education Act of 1965, as amended by Every Student Succeeds Act, requires eligibility to be determined based on the number of children ages 5 through 17 from low-income families. School Board management is required to review all total 118 Corrective Action Plan for Current Year Findings and Questioned Costs (Continued) For the Year Ended June 30, 2024 119 enrollment and low-income families’ data to ensure that the underlying data includes only students ages 5 through 17 and to certify that the eligibility calculations are complete and accurate. Condition found: Title I management completes and submits the Title I Targeting online to the Louisiana Department of Education (LDOE). The LDOE pre-populates the enrollment and number of low-income students in the Title I Targeting; however, these numbers are required to be reviewed and changed, if necessary, by the School Board. In reviewing the underlying data in determining eligibility for each school, it was noted that the School Board did not remove those students under age 5, which resulted in the ranking of schools to not be accurate. Corrective action planned: The School Board was unaware of the data file used needed to be reviewed; however, we will only include the accurate age band moving forward.

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Education, Student Financial Assistance Programs Cluster, Assistance Listing #84.063, Federal Pell Grant Program, Assistance Listing #84.268, Federal Direct Student Loans, Contracts #003556 and G03556, Contract years: 05/05/21 – 12/31/26. Recommendation: Emphasize the importance of accurately reporting enrollment status. Planned corrective action: Management agrees with audit finding #2024-001. The Financial Aid Coordinator is responsible for reporting enrollment status changes, certifying enrollment every 60 days, and responding to NSLDS Roster files within 15 days, all through the NSLDSFAP website. To enhance the accuracy of these enrollment reports, the Institute is implementing a new double-check process. Henceforth, the Financial Aid Coordinator will print all enrollment status changes or enrollment report rosters prior to making any online updates or certifications. These printed reports will then be given to the Director of Operations for verification. Only after this verification will the Financial Aid Coordinator proceed with the necessary changes or certifications on the NSLDSFAP website. All printed reports will be retained by the Financial Aid Coordinator for documentation. Responsible officer: Cody Lopasky, President. Estimated completion date: June 1, 2025.

The following represents Alternatives to Hunger dba Bellingham Food Bank’s corrective action plan for the items identified in the audit of the December 31, 2024 financial statements in accordance with 2 CFR 200.511(c): Section III – Federal Award Findings and Questioned Costs Finding 2024-001 – Eligibility – Material Weakness in Internal Controls Over Compliance and Material Non-Compliance Condition and Context: Alternatives to Hunger dba Bellingham Food Bank (the Organization) did not require intake forms be completed by recipients of food commodities at certain distribution centers to determine and document eligibility throughout the entire year. No other verification was performed to determine whether individuals were eligible before receiving food commodities. The Organization did not finish implementing its new eligibility verification process until mid-2024 and, as such, was not in compliance with these requirements for the full year. Planned Corrective Action: In mid-2024 the organization implemented procedures to collect client intake data at the largest program identified in testing and was following intake guidelines for all programs by the end of 2024. Responsible Division/Office and Individual: Mike Cohen, Executive Director Estimated Completion Date: 12/31/2024

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Tyler Martin, Executive Director, is responsible for implementing this corrective action by December 31, 2025.

2024-008 Untimely Submission of Single Audit Reporting Package to the Federal Audit Clearinghouse Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. A procedure to ensure timely submission of reports and audit documentation will be implemented.

Federal Agency: U.S. Department of Veterans Affairs Federal Program: 64.033 Supportive Services for Veteran Affairs Responsible Official Jason Gilbert, Chief Executive Officer Plan Detail Clear Path for Veterans New England, Inc. is in the process of enhancing its internal controls over eligibility to ensure that participants are recertified within the allowable time frame. Anticipated Completion Date September 2025

The finding resulted from a manual error. The University will evaluate the existing review process to ensure it operates with the level of precision necessary to detect such discrepancies. Additionally, targeted training will be provided to staff, where applicable, to reinforce proper review procedures and reduce the risk of future manual errors.

2024 – 002 Lack of Segregation of Duties - Lack of Supervisory Review - Allow-ability of Expenses Charged to Grants The corrective action proposed for the above finding should be sufficient to account for any area of non-compliance in the evidence of supporting documentation for all disbursements. Additionally, the Business Operations Manager and Executive Director will implement a systematic review of all grant awards, contracts, and develop an addendum document charting all allowable expenses within each funding stream that will be utilized by the team when to determine proper allocation of disbursements. This chart will provide a quick guide to monitor compliance and allow-ability of expenditures to each funder at the time a check request is submitted. Checks

Management will continue to accumulate proper supporting documentation to support the organization’s compliance with the eligibility compliance requirement and to provide such documentation, when legally possible. Responsible parties: Cynthia Amodeo, Chief Executive Officer Myra Ricard, Program Director Anticipated Completion Date: Not Applicable as this is not correctable at this time due to New York State Executive Order 19-ADM-05; 19-OCFS-ADM-03.

Oversight Agency for Audit, NCSC/USA Housing Development Corporation Two Operating as I.W. Abel Place, respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: January 1, 2024 through December 31, 2024 The finding from the December 31, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2024-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement stronger internal controls over the administration of tenant eligibility and file maintenance, inclusive of more rigorous staff training, to ensure HUD regulations are followed timely and accurately. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting, tenant file maintenance, and monthly reporting procedures. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

Formula Grants for Rural Areas – Assistance Listing No. 20.509 Recommendation: We recommend the Organization revise its suspension and debarment policy to include process for retaining timestamp of search performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will take the steps necessary to properly document timing of suspension and debarment search performed. Names of the contact persons responsible for corrective action: Rich Pavek, Executive Director, and Kris Burkey, Finance Manager Planned completion date for corrective action plan: Ongoing

The Corporation screens applicants for eligibility by following the state of Indiana guidelines as provided through the INWIC system used to enter, track, and store information about applicants. Based on guidance contained in 7 CFR Section 246, states were encouraged to move to a paperless system. Specifically, federal guidance contained in 7CFR 246.7 (i)(4) and (5)(i) outlines acceptable documentation to be included on certification forms as “a description of the document(s) used to determine residency and identity or a copy of the document(s) used or the applicant’s written statement when no documentation exists,” and “a description of the document(s) used to determine income eligibility or a copy of the document(s) in the file.” The State of Indiana has followed that guidance and does not require the Corporation to retain copies of the WIC applicant’s proof of eligibility. Therefore, the auditors were not able to test internal controls over compliance or compliance over the eligibility compliance requirement through re-performance and have issued a qualified opinion based on the scope limitations. Compliance with State of Indiana participant eligibility requirements is the responsibility of Leslie Miller, WIC Coordinator. As the Corporation follows the State of Indiana’s paperless system as described above, no further corrective action will be taken.

Action Taken: Management agrees with the finding noted above. It is the stated practice of the management of the Housing Authority of the City of Tampa to comply with all rules and regulations regarding its programs. Management feels this condition is more the result of errors than process. It is management's feeling that this resulted from staffing turnover, available administration funding and the sheer volume of files processed annually. There is a highly refined review and quality control process in place which will be re-evaluated and changed as needed. Staff, under the direction of the Director of Assisted Housing, remains dedicated to processing files as accurately is possible. We are hopeful to close this finding in the next fiscal audit. If the Department of Housing and Urban Development has questions regarding this plan, please contact Jerome Ryans, President/CEO at (813) 3419101 .

The Management of the Authority agrees with the finding; We are in the process of implementing strengthened internal controls to ensure that all annual recertitications · include the required eligibility documentation an.d t hat all records are maintained in an organized and auditable format. For the MTW SB Program, Jackie Rojas, Section 8 Director, is responsible for compliance. She is currently finalizing the implementation of the Rent Cafe module within our Yardi property management sottware systern. This module automates and tracks key steps in the recertification process and includes built-in internal controls to improve compliance with eligibility requirements. She will also conduct an internal audit of all current client files for completion. For the Public Housing Program, Tasha Nelson, Deputy Director of Property Management, is responsible for compliance. She has implemented updated training and standard operating procedures (SOPs) to ensure consistent execution of eligibility determinations and file documentation. New internal controls will be implemented by the end of the fiscal year ending December 31, 2025. If the Department of Housing and Urban Development has questions regarding this plan, please contact Kim Wilford, Deputy Executive Director at (801) 428-0541.

The City will start requireing all supporting documentation for all grants, including those administered by a third party.

Finding 2024-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files - Noncompliance & Significant Deficiency – Housing Choice Voucher Program – ALN #14.871 The Greensboro Housing Authority (GHA) continues the implementation of systems and processes to correct internal control of participant files in the Housing Choice Voucher Program (HCVP) with the following actions: GHA will continue to have external and internal third-party reviews of select file samples ongoing throughout the year for the purpose of identifying each of the items stated in the above finding along with other potential areas for risk. GHA has implemented accountability measures through a two-pronged approach of quality control and quality assurance checks at both the division and department levels to verify the accuracy of calculations and the completeness of program participant files. GHA has also revised and updated its file readiness checklist to ensure consistent file quality and adherence to stated protocols. GHA will continue to provide internal and external training for HCV team members. Based on the results of independent and internal reviews, we have identified specific areas for ongoing training and development. We have also targeted specific individuals who need additional development and focused training. GHA has initiated and will continue implementing the latest module(s) within its corporate software platform (YARDI). This will result in streamlining and automation of the HCV process. These upgrades and enhancements will include eligibility, intake, inspection and recertification workflows which will minimize and even mitigate specific errors that have been identified above. As a result, we will have an effective increase in both quality control and quality assurance within the entire HCV process. Anticipated Completion Date: The above plans will be implemented immediately and will be continuously monitored. We anticipate a completion date of no later than December 31, 2025. Responsible Parties: Meredith J. Daye, Chief Operating Officer Donna Mills, Vice President of Voucher Administration

2024-002 ALN 14.850 – Public Housing Operating Fund – Eligibility Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Jessica Holcomb, Executive Director Projected Completion Date: December 31, 2025

2024-001 ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Jessica Holcomb, Executive Director Projected Completion Date: December 31, 2025

FINDING No. 2024-002: Section 236 Interest Reduction Payments, ALN 14.103 Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system within the established time frame. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO

FEDERAL AWARDS—CORRECTIVE ACTION PLAN REFERENCE # 2024-001 Federal Transit Cluster - ALN Number: 20.507; 20.525; and 20.526 Contract Number: C40261TECHINSP; C33941EFA-MTAB; C40265TECH-MTAB; U3NY-2023-101-02 and U9NY-2018-059-01 Significant Deficiency-Non-Compliance Agency: U.S. Department of Transportation Criteria: Activities Allowed/Allowable Costs/Cost Principles including Indirect Costs––Direct - As stated in Uniform Grant Guidance - §200 Requirements for Allowable Costs: a. Costs did not consist of improper payments, including (1) payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; (2) payments that do not account for credit for applicable discounts; (3) duplicate payments; (4) payments that were made to an ineligible party or for an ineligible good or service; and (5) payments for goods or services not received (except for such payments where authorized by law). Condition/Context: The MTA has Activities Allowed/Allowable Costs/Cost Principles including Indirect Costs procedures in place. MTA has corporate policies and procedures regarding Activities Allowed/Allowable Costs. We tested the Federal Transit Cluster’s Allowable Costs compliance. Based on our review of sixty samples related to Personnel Services and Other than Personnel Services for this cluster, we noted that four samples related to an MTA Bus Company personnel’s hourly rate were charged at higher rate. We noted that the rate per personnel file and employee payroll register differs from the actual rate used by the agency to charge labor costs. The agency calculated labor cost using the annual earnings that is divided by 52 weeks because there are 52 weeks a year, but MTA payroll department used 52.1428 weeks based upon 365/7 days a week, which created variances in labor costs billed and actual recorded labor costs. For Contract # - U3NY-2023-101-02 and U9NY-2018-059-01 – We noted two instances of sixty samples reviewed where the agency used 2023 approved overhead rate of 98.18% instead of the 2024 approved overhead rate of 98.98%. Recommendation: We recommend that MTA ensure that all personnel are reviewed and should be charged at the correct hourly rates as required by §200 CFR Subpart E – Allowable Costs. We also recommend that approved indirect rate applied to direct costs. Corrective Action Plan: MTA Bus will work with the project team to implement the correct rate and calculate the variance. MTA Bus will return the credit to the FTA as needed. Going forward, MTA Bus will review the employee wage rates from the official data sources to ensure that the correct rates are applied. SIR Finance will ensure that the overhead rates on the labor sheets are reflecting the correct percentage by adding a "verification measure" to a checklist while performing internal audits and approvals of the invoices prior to submission. Additionally, SIR-Finance will adjust the formatting within the invoice spreadsheets for easier visibility to a potential error in the calculated overhead percentage. Action Date: MTABUS – 1ST QUARTER 2026 SIRTOA - Effective Immediately - on July 2025 Invoices Final Implementation Date: MTABUS – 2ND QUARTER 2026 SIRTOA – July 2025 Name And Phone Number of Person Responsible For Implementation: MTABUS Marixsa Rivera Assistant Budget Chief • Project Development 718-927-8056 SIRTOA Marissa Rand Assistant Director, Finance & Timekeeping - SIR 347-694-6448