Corrective Action Plans

Name of Contact Person: Lynn Alligood, Executive Director Corrective Action: We will implement proper internal control procedures for the Public and Indian Housing program eligibility requirements. Immediately.

Name of Contact Person: Lynn Alligood, Executive Director Corrective Action: We will implement proper internal control procedures for the Section 8 New Construction program eligibility requirements. Immediately.

Recommendation: The Commission should consider reviewing its current policy regarding rent certifications. The Commission should ensure all persons involved in the certification process are properly trained and understand regulations in order to accurately identify errors. Additionally, the Commission should implement a thorough second party review of annual certifications to verify accuracy. Action Taken: Management will implement stronger controls over tenant files including a more thorough second party review. Anticipated Completion Date of Action: August 31, 2025.

Finding Number: 2024-004 Finding Title: Eligibility Program: 93.558 Temporary Assistance for Needy Families Name of Contact Person Responsible for Corrective Action: QC Team (Lead ES): Whitney VonDeLinde, Megan Howard, Melissa Hoeft Kellie Tienter, Public Assistance Manager Jessica Leth, Economic Assistance Director Corrective Action Planned: • Training TANF employees: o Distribution of Lead ES Newsletter – monthly training communication (includes updates to forms, bulletins from the state, policy & procedural changes, and technical tips) o Supervisor’s will review mandatory verifications at unit meetings by the end of Q3 2025. o Child Support Income Budgeting Guide  Includes how to budget, case noting, etc. o Move In Checklist  We have made clarifying updates to this document regarding requesting a case file from a previous county if not already received. o April 2025 PSU News  QC team shared information and tips from what they noticed while going through the audit • MFIP case reviews conducted by supervisors in Q2 and Q3. 15 per ES per year. • Per Hennepin County we were only transferring the last year of case file documents when clients moved from Anoka County to Hennepin County. Beginning in Q2 of 2025 Anoka County began transferring the entire case file to ensure the complete retention of case files. Anticipated Completion Date: • Completion by end of Q3 2025

NONCOMPLIANCE WITH GRANT TERMS AND CONDITIONS, AIRPORT IMPROVEMENT PROGRAM, CFDA NO. 20.106, CONTRACT NO. AIP-3-30-0068-014-2022 Name of contact person: Board of County Commissioners Corrective Action: The Board will take a more active role in insuring that all grant terms and conditions are being adhered to. Proposed Completion Date: Immediately.

Contact Person Larissa Deedrich, Executive Director Corrective Action Plan Management has begun the process of creating a quality control plan to ensure that all files are accurate and follow all local, state and federal compliance guidelines. Planned Completion Date for CAP September 30, 2025

ALLOWABLE COSTS AND ALLOWABLE ACTIVITIES – TEMPORARY ASSISTANCE FOR NEEDY FAMILIES Recommendation: It is recommended that the County has a supervisor review the random moment studies wages in detail to ensure costs are accurate by report line. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies to ensure all expenditures reported are accurate. Name of the contact person responsible for corrective action plan: Kara Terry, Community Services Director Planned completion date for corrective action plan: December 31, 2025

REPORTING – COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: It is recommended that the County review their policies and federal requirements to ensure all costs incurred are reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies to ensure that all costs incurred are reported accurately. Name of the contact person responsible for corrective action plan: Nancy Malecha, Finance Director Planned completion date for corrective action plan: December 31, 2025

2024-003 Housing Choice Voucher Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters This is a repeat finding of 2023-002 from September 30, 2023 (Originally reported as Material non-compliance and Material Weakness in Internal Control over Compliance under finding 2019-001 from September 30, 2019) Statement of Condition: Out of a total tenant population of approximately 1,118 vouchers, 25 files were selected for testing, and the following errors were discovered. • 2 tenant files had the following error: o The HAP contract in the tenants’ file was not signed by a representative of Ocala Housing Authority. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will decrease the Housing Assistance Payment by $4. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $23. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $7. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates for a 1-bedroom unit. The 2024 utility allowance rates for a 2-bedroom unit should have been used. Correcting this error will increase the Housing Assistance Payment by $20. 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: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants. The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being sent to the Compliance Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the Counselor handling specialty vouchers, will attend Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam during the next 24 months, as budget permits.

2024-002 Public Housing Tenant Files: Eligibility Program: U.S. Department of HUD: Public and Indian Housing Program (ALN #14.850) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Statement of Condition: We tested 19 out of approximately 181 tenant files and discovered the following errors: • 1 tenant file had the following error: o A dependent of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the dependent’s birth certificate, the dependent is a U.S. citizen. • 1 tenant file had the following error: o The tenant’s childcare income was calculated and reported incorrectly on the 50058 form in the amount of $2,472. Correcting the tenant’s childcare income to $2,237 would decrease the tenant’s rent by $6. • 1 tenant file had the following error: o Support for the tenant’s wage income could not be located. It’s unknown as to whether the tenant’s wage income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly. • 1 tenant file had the following error: o The tenant’s social security income was carried forward from the prior year in the amount of $11,172. Correcting the tenant’s social security income to $12,144 for the annual recertification period tested, would increase the tenant’s rent by $25. • 1 tenant file had the following error: o The tenant’s social security income was carried forward from the prior year in the amount of $12,456. Correcting the tenant’s social security income to $13,548 for the annual recertification period tested, would increase the tenant’s rent by $27. • 1 tenant file had the following error: o The tenant’s other source income of $720 was carried forward from the prior year. The tenant’s income was not updated for the annual recertification and it’s unknown as to whether the tenant’s other source income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly. 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: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and a PH Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. Management will monitor and review counselor’s strength and weaknesses and determine if additional training and/or monitoring is needed.

Corrective Action – GYAC has purchased an electronic system that assists with the tracking of meal count sheets and attendance rosters. This system compares the names on the roll with the number of meals being claimed, ensuring that participant rosters are accurately maintained and matched with meal delivery records, thereby preventing discrepancies and reducing the error rate in submissions. Responsible for Corrective Action: Rosman T. Randle, Executive Director Date of Implementation: June 2025

Views of Responsible Officials and Planned Corrective Action: Global Communities experienced staff turnover in the positions responsible for FFATA reporting. Management will ensure those staff now responsible for maintaining compliance with FFATA reporting requirements have received adequate training and that supporting documentation of the review and approval of FFATA reports prior to submission are retained in our files.

Finding 2024- 001: Housing Choice Voucher Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance and Material Weakness Corrective Action Plan: Training: To reinforce compliance and ensure consistent adherence to policies a specialized team­ including a Compliance & Training Administrator, a Trainer, and two Senior Occupancy Specialists-has been established to oversee all Housing Choice Voucher (HCV) program training and compliance. This team is responsible for: ■ New hire training to ensure foundational competency. • Refresher trainings to address knowledge gaps and reinforce standards. • Policy & procedure update trainings to keep staff informed of changes. Quality Control: We conduct 100% quality control on all new hires', completed action files and 100% quality control on all contract files. Twenty-five percent (25%) of all Non-provisional employees work product is quality controlled by the compliance team. Department Structure: The entire leadership team completed Nan McKay's HOTMA training to ensure full alignment with the latest Housing Opportunity Through Modernization Act {HOTMA) requirements. This top-down approach guarantees that policy Interpretations and training materials are consistent and up to date. To ensure all required documents are properly retained and accessible, the agency has expedited the transition to a fully digital file system. This will Include standardized naming conventions, centralized storage with access controls, and a documented retention protocol to prevent future discrepancies. Additionally, any staff that falls below the 80 % success rate will be required to actively engage in all mandated trainings and utilize the compliance team as a resource for clarification. Furthermore, staff requiring further reinforcement will be promptly addressed through one-on­ one coaching or additional training sessions with their immediate supervisor. Anticipated Completion Date: The current staff is attending monthly trainings on the Administrative Plan, best practices and HOTMA policy changes. We anticipate completion of the plan by 12/31/2025. Person Responsible: Ms. Rhonda Jackson, Housing Program Manager II, Ms. Malandria Watson, Housing Program Manager I, -and Ebony Bell, Compliance and Training Administrator will be responsible for reviewing the Quality Control Report and error ratios monthly.

N/A

2024-007 – Eligibility Housing Opportunities for Persons with Aids – Assistance Listing 14.241 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Explanation of disagreement with audit finding: There is no disagreement with the audit finding Action taken in response to finding: All current PBCHA staff responsible for eligibility determinations have received HCV rent calculation training through Nan McKay as of March 21, 2025. The PBCHA will continue to conduct training for program staff on eligibility documentation requirements and program rules to reinforce compliance standards. Through the implementation of intakes, interims and annual recertifications utilizing Yardi’s online workflows, the PBCHA expects to see increased improvement through automated application and documentation processes. The PBCHA will utilize available dashboards, internal audits and formal monitoring protocols to ensure continued compliance and to minimize the risk of recurring deficiencies. The PBCHA will continue to assess current staffing levels and evaluate the feasibility of hiring outside consultants or increasing staffing to support consistent and compliant eligibility determinations while being cognizant of current funding uncertainties. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

2024-06 – Eligibility Public Housing – Assistance Listing 14.850 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All current PBCHA staff responsible for eligibility determinations have received HCV rent calculation training through Nan McKay as of March 21, 2025. The PBCHA will continue to conduct training for program staff on eligibility documentation requirements and program rules to reinforce compliance standards. Through the implementation of intakes, interims and annual recertifications utilizing Yardi’s online workflows, the PBCHA expects to see increased improvement through automated application and documentation processes. The PBCHA will utilize available dashboards, internal audits and formal monitoring protocols to ensure continued compliance and to minimize the risk of recurring deficiencies. The PBCHA will continue to assess current staffing levels and evaluate the feasibility of hiring outside consultants or increasing staffing to support consistent and compliant eligibility determinations while being cognizant of current funding uncertainties. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

2024-004 – Selection from the Waiting List Housing Voucher Cluster – Assistance Listing 14.871 and 14.879 Recommendation: We recommend management that designates an induvial to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the wait list timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Beginning in March 2023, the PBCHA implemented the completion of all waiting lists generation/selection and intakes for eligibility within its Yardi resident portal. Intakes within Yardi automates applications, increases efficiency and ensures compliance with program requirements. Utilizing this technology, the PBCHA has seen improvement in this longstanding finding. The PBCHA will utilize available dashboards and reports to improve monitoring and oversight to ensure compliance and that correspondence with potential tenants is properly documented and tracked. Additionally, PBCHA will implement procedures to regularly monitor its waitlist tracking software to confirm that applicants are removed from the wait list in a timely and compliant manner. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

2024-001 – Eligibility Housing Voucher Cluster – Assistance Listing 14.871 and 14.879 Recommendation: We recommend that management conduct training for program staff on eligibility documentation requirements and program rules. Additionally, we recommend that the Housing Authority implement internal audits of tenant files to proactively identify and correct documentation issues. A monitoring protocol should also be established to ensure ongoing compliance and to prevent the recurrence of documentation deficiencies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All current PBCHA staff responsible for eligibility determinations have received HCV rent calculation training through Nan McKay as of March 21, 2025. The PBCHA will continue to conduct training for program staff on eligibility documentation requirements and program rules to reinforce compliance standards. Through the implementation of intakes, interims and annual recertifications utilizing Yardi’s online workflows, the PBCHA expects to see increased improvement through automated application and documentation processes. The PBCHA will utilize available dashboards, internal audits and formal monitoring protocols to ensure continued compliance and to minimize the risk of recurring deficiencies. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

To address the finding, ARC will strengthen internal controls related to federal reporting by taking the following actions: 1. Enhance Reporting Oversight: The Finance Manager and Grants and Compliance Officer will assume primary responsibility for monitoring and verifying all federal reporting deadlines and submission requirements. 2. Document Retention Procedure: Additional double checks of record retention will take place in monthly reporting meetings, ensuring that centralized record keeping is complete. 3. Compliance Calendar Audit: A quarterly internal audit of the compliance calendar and reporting checklist will be conducted to verify deadlines are met.

2024-001 - Missing evidence of review and approval Auditor Description of Condition and Effect: During our testing of Allowable Costs, we noted 4 disbursements tested did not have signed and approved purchase orders. During our testing of Reporting, we noted two quarterly reports that had no evidence of review and approval. During our Eligibility testing, we noted one applicant whose certification form was not signed by the supervisor. As a result of this condition, there is an increased risk of unallowable expenses being charged to the grant, inaccurate financial reporting, allowing ineligible participants to receive grant benefits and other potential noncompliance with federal regulations. Auditor Recommendation: We recommend the Agency adheres to their internal control process of an independent review and approval of transactions and reporting related to federal grant programs. Corrective Action: The Agency will review the accounts payable/purchase order approval process with the finance department, all of whom were new (or the position vacant) during much of the period being examined, to ensure they understand the various requirements. The Agency will verify the review of the semi-annual and annual federal financial reporting by signing off on the reports after various staff have reviewed them. Responsible Person: Anthony J Samon, CFO Anticipated Completion Date: June 15, 2025

Auditor recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for implementation: Ryan Bansbach, Deputy CFO, Housing, 503.846.8811 Response: The Housing Authority of Washington County (HAWC) is addressing these findings by implementing systems and policies that require secondary review of reports and determinations prior to upward reporting, voucher issuance, or tenant move‐in. HAWC implemented systems in 2025 where the staff preparing and submittng the HUD 52681‐B form will send to the form to the Program Manager or Designee for review and approval stamp before the form is submitted to HUD in the VMS or eVMS system. A checklist has been created and a system updated on routing files after review for eligibility to have a secondary review and final approval prior to issuance of voucher by the program supervisor, program manager or designee. Additional training and internal quality control checks will be implemented to ensure that metric is met. HAWC has also established checklists and procedures to ensure Rent Reasonableness is reviewed and approved prior to tenant move‐in, using a third‐party system to conduct the rent reasonableness determinations. This metric will also be added to the internal quality control procedures to monitor compliance.

Corrective Action Plan Actions Planned – The HRA will create monitoring controls to ensure its policies relating to tenant eligibility are being followed. Official Responsible – Sarah Abe, HRA Administrator Planned Completion Date – December 31, 2025 Disagreement With or Explanation of Finding – The HRA agrees with this finding. Plan to Monitor – Sarah Abe, HRA Administrator, will oversee the process to ensure a tenant checklists for eligibility are completed and a separate program specialist is assigned to review and sign off on the checklists.

Finding 2024-002 – Continuum of Care Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the following by our fiscal year-end September 30, 2025: a. Program Coordinators will maintain all Continuum of Care Tenant files in individual file folders designated by special purpose voucher programs. All loose documents will be anchored in tenant files. b. An action plan has been developed for the Continuum of Care programs to ensure that all program files are HUD, State, and HACG compliant starting with October 1, 2024, files through the current. c. Continuum of Care fiscal year 2024 (October 2023-September 2024) re- exams and interims will be caught up and completed as they become effective. All tenant files will be reviewed and compliant by FYE2024. d. All late/overdue re-exams will be compliant by FYE2024. e. During FYE2024, the Housing Choice Voucher Director will perform quality controls on all Continuum of Care tenant files processed each month prior to initialization (25th-30th of each month). f. File checklist sheets will be placed in each file upon quality control review to be signed off by the Housing Choice Voucher Director. g. Additional training will be required and ongoing for Program Coordinators. h. Other internal control measures will be implemented as deemed necessary by the Deputy Executive Director/COO, to eliminate future audit findings. Person Responsible: Shanetta Moye, Deputy Executive Director/COO Anticipated Completion Date: September 30, 2025

Finding 2024-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Significant Deficiency Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the following by our fiscal year-end September 30, 2025: a. Housing Choice Voucher tenant files will be reviewed and quality controlled each month prior to initialization (25th-30th of each month) by the Housing Choice Voucher Director. b. An action plan has been developed for the Housing Choice Voucher department to ensure that all Housing Choice Voucher files are HUD and GHA compliant starting with October 1, 2024 files through the current. c. Housing Choice Voucher calendar-year 2024 (October 2023-September 2024) re-exams are substantially complete, as they become effective. All tenant files will be reviewed and HUD-compliant by FYE2024. d. During FYE2024, the Housing Choice Voucher Director will perform 40% quality controls of the monthly re-exams processed by the Housing Specialists. e. File checklist sheets will be placed in each file upon quality control review to be signed off by the Housing Choice Voucher Director. f. Additional training has been and will be made available as necessary. g. Other internal control measures will be implemented as deemed necessary by the Deputy Executive Director/COO, to eliminate future audit findings. Person Responsible: Shanetta Moye, Deputy Executive Director/COO Anticipated Completion Date: September 30, 2025

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2024-035 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: The Department should enhance its procedures and internal controls to ensure it promptly follows up with participants whose eligibility review identifies errors and that ineligible participants are terminated from the program. Action taken in response to finding: The State will implement the following corrective actions to enhance the oversight within the Eligibility Quality Assurance (EQA) program: • Annual refresher training for supervisory staff The State will perform an annual refresher training for all Team Leaders and Supervisors who are responsible for reviewing and correcting tasks identified by the Eligibility Quality Assurance unit. • Comprehensive training for new supervisory workers The State will ensure that all newly appointed Team Leaders and Supervisors receive a comprehensive training that will include a detailed overview of the eligibility review and correction process established by the Eligibility Quality Assurance unit. • Review of corrections The State will establish a process to assist and remind managers and supervisors that they are expected to review and approve all corrections made by the eligibility workers in response to the Eligibility Quality Assurance Unit findings. Documentations of such corrections will be maintained for audit and monitoring purposes. • Standardized member outreach process for incomplete Employee Sponsored Insurance forms (ESI). The State will develop and implement a standardized process for timely outreach to members whose ESI form is identified as incomplete. Name(s) of the contact person(s) responsible for corrective action: Tosin Adebiyi, Assistant Director of Special Eligibility Programs and Audits Marco Gonzalez, Eligibility Quality Assurance Team Leader Planned completion date for corrective action plan: All corrective actions are targeted for full implementation by December 31st, 2026.