Corrective Action Plans

Finding 556015 (2024-001)

Significant Deficiency 2024

Legal Aid Chicago

IL

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that management implement a control to review PAI time entries to ensure they are accurate. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: In 2024, but after employees logged the two erro...

Recommendation: We recommend that management implement a control to review PAI time entries to ensure they are accurate. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: In 2024, but after employees logged the two erroneous PAI entries, we implemented a new PAI time entry system in LegalServer. Employees must now choose the nature of the PAI involvement when they log the time, which would have avoided both of the two erroneous entries, had that been in place. Additionally, our Deputy Director/General Counsel provided an LSC regulations training in Q1 2025 to remind employees of LSC regulations, including the regulation governing PAI time. Name of the contact person responsible for corrective action: Teresa Sullivan, Deputy Director / General Counsel Planned completion date for corrective action plan: Already implemented

View Audit 354747

Finding 555985 (2024-002)

Significant Deficiency 2024

Dal Housing for the Elderly

OH

Questioned Costs HUD Housing Programs Reporting

Management is currently conducting a comprehensive review of the process to ensure alignment with compliance requirements and identify areas for improvement.

View Audit 354707 Questioned Costs: $1

Finding 555984 (2024-001)

Significant Deficiency 2024

Dal Housing for the Elderly

OH

Questioned Costs HUD Housing Programs Eligibility

Management is currently conducting a comprehensive review of the process to ensure alignment with compliance requirements and identify areas for improvement. Status of finding: Corrective Action

View Audit 354707 Questioned Costs: $1

Finding 555940 (2024-001)

Significant Deficiency 2024

Manchester Supportive Housing, Inc. D/b/a Page Place

PA

HUD Housing Programs Eligibility

The following represents the Corrective Action Plan related to the audit finding listed in the Schedule of Findings and Questioned Costs included in the December 31, 2024 audited financial statements of Manchester Supportive Housing, Inc. d/b/a Page Place (the “Corporation”). Finding 2024-001: Incom...

The following represents the Corrective Action Plan related to the audit finding listed in the Schedule of Findings and Questioned Costs included in the December 31, 2024 audited financial statements of Manchester Supportive Housing, Inc. d/b/a Page Place (the “Corporation”). Finding 2024-001: Incomplete Documentation of New Residents Condition and Criteria: The Corporation is required to obtain, confirm, and document income information for each resident in Form HUD-50059 upon move-in and recertification. The Corporation was found to have an error in the documented income information for one out of the three residents selected for testwork. Management Response and Corrective Action Plan: Management agrees with the finding. The Corporation is implementing an updated standard review process over the resident files to prevent and detect errors on a timely basis.

View Audit 354634

Finding 555939 (2024-001)

Significant Deficiency 2024

Plum Presbyterian Housing, Inc. D/b/a Plum Creek Acres

PA

HUD Housing Programs Procurement, Suspension & Debarment Eligibility

The following represents the Corrective Action Plan related to the audit finding listed in the Schedule of Findings and Questioned Costs included in the December 31, 2024 audited financial statements of Plum Presbyterian Senior Housing, Inc. d/b/a Plum Creek Acres (the “Corporation”). Finding 2024-0...

The following represents the Corrective Action Plan related to the audit finding listed in the Schedule of Findings and Questioned Costs included in the December 31, 2024 audited financial statements of Plum Presbyterian Senior Housing, Inc. d/b/a Plum Creek Acres (the “Corporation”). Finding 2024-001: Incomplete Documentation of New Residents Condition and Criteria: The Corporation is required to have all new residents sign a Form HUD-9887 and a Resident Rights and Responsibilities document upon move-in. The Corporation did not have these documents signed and maintained in the resident file for one out of four residents selected for testwork. Management Response and Corrective Action Plan: Management agrees with the finding. The Corporation is implementing an updated standard review process over the resident files to prevent and detect errors on a timely basis.

View Audit 354632

Finding 555938 (2024-001)

Significant Deficiency 2024

East Liberty Supportive Housing, Inc. D/b/a Negley Commons

PA

HUD Housing Programs Eligibility

The following represents the Corrective Action Plan related to the audit finding listed in the Schedule of Findings and Questioned Costs included in the December 31, 2024 audited financial statements of East Liberty Supportive Housing, Inc. d/b/a Negley Commons (the “Corporation”). Finding 2024-001:...

The following represents the Corrective Action Plan related to the audit finding listed in the Schedule of Findings and Questioned Costs included in the December 31, 2024 audited financial statements of East Liberty Supportive Housing, Inc. d/b/a Negley Commons (the “Corporation”). Finding 2024-001: Incomplete Documentation of New Residents Condition and Criteria: The Corporation is required to have all new residents provide their social security number upon move-in. The Corporation did not have a social security card maintained in the resident file for two out of three residents selected for testwork. Management Response and Corrective Action Plan: Management agrees with the finding. The Corporation is implementing an updated standard review process over the resident files to prevent and detect errors on a timely basis.

View Audit 354630

Finding 555899 (2024-001)

Significant Deficiency 2024

Marillac Community Health Centers

LA

Eligibility Internal Control / Segregation of Duties

Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to retaining the completed sliding fee applications in the patients record to support the sliding fee discount pr...

Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to retaining the completed sliding fee applications in the patients record to support the sliding fee discount provided to the patient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees that this was a clerical error and an isolated incident. To improve the process and minimize errors, eligibility applications will now be processed at the Grand Junction, Colorado office by a different eligibility staff. This team will enter applications into the electronic medical record system and maintain either paper or digital copies for one year to ensure no applications are lost. This new procedure will provide an additional safeguard in the application process.

View Audit 354557

Finding 555839 (2024-001)

Significant Deficiency 2024

Coolidge Court, INC

CA

Questioned Costs HUD Housing Programs Eligibility

Develop and implement a standardized file checklist for all tenant files Conduct staff training on housing documentation requirements and retention Perform a comprehensive audit of all current tenant files Correct all deficiencies found in tenant files and document corrections Establish a monthl...

Develop and implement a standardized file checklist for all tenant files Conduct staff training on housing documentation requirements and retention Perform a comprehensive audit of all current tenant files Correct all deficiencies found in tenant files and document corrections Establish a monthly internal file review schedule Implement a digital tracking system for file compliance status Housing Program Mgr DONE In Progress Housing Program Mgr 5/9/2025 In Progress Assigned Housing Team Ongoing In Progress Assigned Program Staff Quarterly In Progress Assigned Program Staff 5/1/2025 In Progress Housing Program Mgr 5/1/2025 Not Started Proposed Completion Date: 06/30/2025 Contact Person: Antonechia Smith – Housing Program Manager Kasi Jones – Property Manager

View Audit 354536 Questioned Costs: $1

Finding 555812 (2024-001)

Material Weakness 2024

Oak Hill Apartments, Inc.

NC

HUD Housing Programs Procurement, Suspension & Debarment Eligibility

OAK HILL APARTMENTS, INC. Raleigh, North Carolina CORRECTIVE ACTION PLAN March 25, 2025 U. S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303-2806 Oak Hill Apartments, Inc. respectfully...

OAK HILL APARTMENTS, INC. Raleigh, North Carolina CORRECTIVE ACTION PLAN March 25, 2025 U. S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303-2806 Oak Hill Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended June 30, 2024 The finding from the June 30, 2024 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Federal Award Programs Audits Finding No. 2024-001: Supportive Housing for Persons with Disabilities (Section 811), CFDA #14.181 Recommendation: We recommend that management ensure the required recertifications are performed annually. Views of Responsible Officials and Corrective Action Plan: Management has hired additional employees to fully staff the leasing department. Management will ensure that all required recertifications are performed going forward. If HUD has questions regarding this plan, please call Mr. Everett McElveen at 919-754-9960. Sincerely yours, Everett McElveen CEO CASA

View Audit 354519

Finding 555811 (2024-001)

Material Weakness 2024

Robertson Hill Apartments, Inc.

NC

HUD Housing Programs Procurement, Suspension & Debarment Eligibility

ROBERTSON HILL APARTMENTS, INC. Raleigh, North Carolina CORRECTIVE ACTION PLAN March 25, 2025 U. S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303-2806 Robertson Hill Apartments, Inc. ...

ROBERTSON HILL APARTMENTS, INC. Raleigh, North Carolina CORRECTIVE ACTION PLAN March 25, 2025 U. S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303-2806 Robertson Hill Apartments, Inc. respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended June 30, 2024 The finding from the June 30, 2024 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Federal Award Programs Audits Finding No. 2024-001: Supportive Housing for Persons with Disabilities (Section 811), CFDA #14.181 Recommendation: We recommend that management ensure the required recertifications are performed annually. Views of Responsible Officials and Corrective Action Plan: Management has hired additional employees to fully staff the leasing department. Management will ensure that all required recertifications are performed going forward. If HUD has questions regarding this plan, please call Mr. Everett McElveen at 919-754-9960. Sincerely yours, Everett McElveen CEO CASA

View Audit 354517

Finding 555794 (2024-001)

Significant Deficiency 2024

Trinity Terrace, Inc.

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as w...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

View Audit 354477

Finding 555792 (2024-004)

Significant Deficiency 2024

Rome Housing Authority

NY

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions

RHA has put in place comprehensive new procedures and controls for all the staff members, including Clerks, Housing Assistants, Housing Coordinators and Project Managers, concerning the management of the waiting list process. As of September 2024m a new waiting list will be generating following each...

RHA has put in place comprehensive new procedures and controls for all the staff members, including Clerks, Housing Assistants, Housing Coordinators and Project Managers, concerning the management of the waiting list process. As of September 2024m a new waiting list will be generating following each new move-in, and the previous waiting list will be appropriately filed and preserved. Name of Responsible Person: Entire Admin Staff lmplementatio_n Date: September 2024

View Audit 354468

Finding 555740 (2024-001)

Material Weakness 2024

Victory Oaks, Inc.

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as w...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring

View Audit 354366

Finding 555736 (2024-002)

Material Weakness 2024

Victory Heights, Inc.

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines and that a move-in inspection report was missing. We attribute this findin...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines and that a move-in inspection report was missing. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

View Audit 354365

Finding 555733 (2024-001)

Material Weakness 2024

Victory Crest, Inc.

MD

HUD Housing Programs Eligibility

a. Comments on the Finding and Each Recommendation 1 out of 10 tenant tested did not compute the monthly tenant rent and subsidy portion accurately. b. Action(s) Taken or Planned on the Finding All files are reviewed by the Compliance Department. The Compliance Department uses the standard rules of...

a. Comments on the Finding and Each Recommendation 1 out of 10 tenant tested did not compute the monthly tenant rent and subsidy portion accurately. b. Action(s) Taken or Planned on the Finding All files are reviewed by the Compliance Department. The Compliance Department uses the standard rules of calculation and each file is accompanied with a calculation work sheet provided thru the software. To ensure the accuracy of the calculations moving forward, review of the hourly rate, # of hours worked and pay frequency will be calculated to verify what is on the calculation worksheet to ensure the accuracy of the information submitted. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Audit Findings, Questioned Costs and Recommendations This process is established as a policy for the Compliance Department and published in the Fundamentals of Compliance handbook/

View Audit 354364

Finding 555732 (2024-001)

Significant Deficiency 2024

Manor Apartments, Inc.

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as w...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

View Audit 354363

Finding 555731 (2024-001)

Material Weakness 2024

Cheval Court, Inc.

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as w...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

View Audit 354361

Finding 555716 (2024-001)

Significant Deficiency 2024

Avondale Park Apartments, INC

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as w...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

View Audit 354355

Finding 555692 (2024-001)

Significant Deficiency 2024

Wyoming Housing Network, Inc. and Subsidiaries

WY

HUD Housing Programs Subrecipient Monitoring Eligibility

Finding #2024-001 Comments on the Finding and Each Recommendation: During the year ended September 30, 2024, two of the nine resident files selected for testing under the HUD Consolidated Audit Guide lacked properly executed and documented resident eligibility forms. The Agent should ensure that all...

Finding #2024-001 Comments on the Finding and Each Recommendation: During the year ended September 30, 2024, two of the nine resident files selected for testing under the HUD Consolidated Audit Guide lacked properly executed and documented resident eligibility forms. The Agent should ensure that all resident files are maintained at the site for each resident of the Property, and the Agent should ensure that the resident files include all properly executed and documented resident eligibility forms. Action(s) taken or planned on the finding: The Agent concurs with the finding and recommendation. The resident files noted in the statement of condition were for residents who moved out of the Property during the year ended September 30, 2024. No further action is required related to these residents' files. The Agent intends to review and update, as necessary, the other resident files during the year ended September 30, 2024 to ensure the Property is in compliance with HUD requirements.

View Audit 354311

Finding 555669 (2024-001)

Significant Deficiency 2024

Alpha Warren Housing Corporation

OH

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

Management is currently conducting a comprehensive review of the process to ensure alignment with compliance requirements and identify areas for improvement. Completion Date: Immediately

View Audit 354277

Finding 555573 (2024-010)

Material Weakness 2024

Lincoln Street Housing, Inc.

CA

HUD Housing Programs Eligibility Reporting

Finding 2024-10 EIV reports for LSH were inconsistently run in FY 2024. Moving forward, EIV reports will be run monthly and during annual and interim recertifications. The Portfolio Assistant will complete Rules of Behavior for Use of EIV certification and will be responsible for completing this tas...

Finding 2024-10 EIV reports for LSH were inconsistently run in FY 2024. Moving forward, EIV reports will be run monthly and during annual and interim recertifications. The Portfolio Assistant will complete Rules of Behavior for Use of EIV certification and will be responsible for completing this task, effective March 1, 2025.

View Audit 354066

Finding 555572 (2024-009)

Material Weakness 2024

Lincoln Street Housing, Inc.

CA

HUD Housing Programs Eligibility Reporting

Finding 2024-00G Annual inspections for FY2024 were not completed. FY2025 inspections were completed in August 2024, and annual inspections were completed annually prior to FY 2024. Inspections will continue to be completed annually going forward.

View Audit 354066

Finding 555571 (2024-008)

Material Weakness 2024

Lincoln Street Housing, Inc.

CA

HUD Housing Programs Eligibility Reporting

Finding 2024-008 The file in question contained completed recertification forms that were missing tenant signatures. HCEB will obtain signatures and place the recertification forms into the tenant file. All future completed recertifications will include tenant signatures.

View Audit 354066

Finding 555570 (2024-007)

Material Weakness 2024

Lincoln Street Housing, Inc.

CA

HUD Housing Programs Eligibility Material Weakness

Finding 2024-007 The June 2023 voucher was not correct when initially submitted. HCEB has attempted over the past 18 months to correct the June 2023 voucher, working closely with our Yardi support and HUD-SF team. Once the June 2023 voucher is paid, July 2023 and subsequent vouchers will be matched ...

Finding 2024-007 The June 2023 voucher was not correct when initially submitted. HCEB has attempted over the past 18 months to correct the June 2023 voucher, working closely with our Yardi support and HUD-SF team. Once the June 2023 voucher is paid, July 2023 and subsequent vouchers will be matched to Yardi records and submitted to TRACS processing.

View Audit 354066

Finding 555569 (2024-006)

Material Weakness 2024

Lincoln Street Housing, Inc.

CA

HUD Housing Programs Eligibility Reporting

Finding 2024-006 By April 30, 2025, HCEB will engage ACE Housing Group to complete a file audit for the 10 units of supportive housing for persons with disabilities in Fremont in accordance with HUD Handbook 4350.3, Chapter 6, Section 1 6-5B. All tenants will be listed on the leases and required HUD...

Finding 2024-006 By April 30, 2025, HCEB will engage ACE Housing Group to complete a file audit for the 10 units of supportive housing for persons with disabilities in Fremont in accordance with HUD Handbook 4350.3, Chapter 6, Section 1 6-5B. All tenants will be listed on the leases and required HUD addendums.

View Audit 354066

Corrective Action Plans

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