Corrective Action Plans

Finding 554380 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Brinkley

AR

HUD Housing Programs Eligibility

Housing Authority of the City of Brinkley respectfully submits the following corrective action plan for the year ended June 30, 2024. Responsible Official: Robert Pearson, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 721...

Housing Authority of the City of Brinkley respectfully submits the following corrective action plan for the year ended June 30, 2024. Responsible Official: Robert Pearson, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Audit period: Year ended June 30, 2024 Oversight Agency: U.S. Department of Housing and Urban Development The findings from the June 30, 2024, audit are discussed below. The findings are numbered to correspond to the auditing findings disclosed in the Schedule of Findings and Questioned Costs. 2024-001 Eligibility Federal Program: Public and Indian Housing, Federal Assistance Listing Number 14.850 Condition and Criteria: The Authority’s purpose for existence is to provide decent, safe, and affordable housing for low-income families. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of rent to be paid by the family. HUD regulations prescribe the content of these family files. These requirements consist of the following: a. As a condition of admission or continued occupancy, the tenant and other family members are required to provide necessary information, documentation, and releases for the PHA to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. c. Determine income eligibility and calculate the tenant’s rent payment in accordance with HUD regulations. d. Select tenants from the public housing waiting list in accordance with the PHA’s tenant selection policies. e. Re-examine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary. Population and Items Tested: We selected seventeen public housing tenant files for testing. One file did not contain an annual re-examination. The file indicates a re-examination for September 1, 2022. The next re-examination was conducted on September 1, 2024. One file indicated the tenant should have been charged $399. The tenant was charged $387. Auditor’s Recommendation: All re-examinations should be completed on an annual basis and the required documents should be signed by the tenant. All rent amounts should be updated to make sure they agree with the computed rent. Planned corrective actions: We will comply with the auditor’s recommendation. Estimated Completion Date: June 30, 2025.

View Audit 353046

Finding 554369 (2024-001)

Significant Deficiency 2024

Monte Vista Community Center Housing Authority, Inc.

CO

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Finding 2024-001: Rural Rental Housing Loans Assistance Listing Number: 10.415 U.S. Department of Agriculture Compliance Requirement: Eligibility Type of Finding: Internal Control Over Compliance (significant deficiency) Recommendation: The organ...

Finding 2024-001: Rural Rental Housing Loans Assistance Listing Number: 10.415 U.S. Department of Agriculture Compliance Requirement: Eligibility Type of Finding: Internal Control Over Compliance (significant deficiency) Recommendation: The organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The organization should consider assessing and realigning the duties and responsibilities of the Executive Director and Alamosa Site Manager to provide for a review process of tenant eligibility determinations. Action Taken: I have hired office personnel in the Monte Vista office. The procedures will be established to adequately segregate the duties. In the Alamosa office, either I or Priscilla Schimpf will be assisting Laura with adequately segregating the duties in that office. The process will become effective March 1, 2025. If there are questions regarding this plan, please call the responsible party at (719) 852-5505. Sincerely yours, Corinna Garcia Executive Director Monte Vista Community Center Housing Authority, Inc.

View Audit 352994

Finding 554344 (2024-001)

Material Weakness 2024

Lebanon City School District

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

The School District will implement monitoring control procedures to review software system eligibility determinations to ensure compliance with federal income guidelines.

View Audit 352954

Finding 554321 (2024-001)

Material Weakness 2024

Tcb Pedestal Gardens LLC

MA

HUD Housing Programs Eligibility Material Weakness

Finding 2024-001 - Eligibility - Material Weakness Recommendation: We recommend that management reviews its internal controls over obtaining and maintaining tenant file documentation to ensure compliance with eligibility requirements. Management should establish procedures and monitor compliance wit...

Finding 2024-001 - Eligibility - Material Weakness Recommendation: We recommend that management reviews its internal controls over obtaining and maintaining tenant file documentation to ensure compliance with eligibility requirements. 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 federal regulations. Action Taken: Management is aware of the finding and condition that allowed for the noncompliance. Management noted that the property was sold subsequent to period end and that they have informed the new owner of the potential tenant file issues.

View Audit 352915

Finding 553977 (2024-004)

Material Weakness 2024

Desert Aids Project, Inc.

CA

Questioned Costs Special Tests & Provisions Eligibility

Department of Housing and Urban Development Federal Financial Assistance Listing #93.224 and #93.527 Community Health Center Cluster Special Tests and Provision – Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary Health centers must prepare and apply a sliding f...

Department of Housing and Urban Development Federal Financial Assistance Listing #93.224 and #93.527 Community Health Center Cluster Special Tests and Provision – Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary Health centers must prepare and apply a sliding fee discount schedule (Sliding Fee Discounts) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Internal controls in place did not ensure that the sliding fee discount was not given until all income verification was obtained. Or in cases where the sliding fee discount was given pending income verification, the income verification was not completed which resulted in sliding fee discounts being given without adequate support. Responsible Individuals Nedy Terrazas, Assoc COO, Simon Bahta, EPIC EHR Mgr and Briana Renner, CFO Status Management of DAP Health, Inc. has policies and procedures in place which require the completion of the income verification and obtaining the necessary information for the sliding fee discount prior to a sliding fee discount being given. However, with the acquisition of the new clinics, the policies and procedures already in place were not being followed appropriately at all clinics. Management has had staff complete additional training and provided education to explain why the sliding fee discounts cannot be given until a completed file, including income verification support, is obtained. Anticipated Completion Date June 30, 2025

View Audit 352630 Questioned Costs: $1

Finding 553963 (2024-001)

Significant Deficiency 2024

University of Western States

OR

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Identifying Number: 2024-0001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may bo...

Identifying Number: 2024-0001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of student may not exceed the following: in the case of a graduate or professional student, $12,000. Finding: UWS improperly awarded 6 out of 6 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year of $20,500. Summary: During testing of eligibility, six out six students selected for testing within the Doctor of Naturopathic Program were overawarded Unsubsidized Federal Direct Loans. Eligibility testing was performed over 40 other students with no exceptions. We determined that UWS improperly awarded 6 out of 6 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year of $20,500. The total overawards accumulated to $119,443 in total loan funds. The students were awarded the higher annual Direct Unsubsidized Loan limits for certain graduate and professional health professions students. Schools may award the increased unsubsidized amounts to students who are enrolled at least half time in certain health professions programs. The programs must be accredited by specific accrediting agencies for students to qualify for additional unsubsidized loan amounts. The UWS Naturopathic Medicine Doctoral program has not yet achieved the required accreditation from The Council on Naturopathic Medical Education Corrective Action Planned or Taken: During the course of an internal audit of student awards in the Naturopathic Medicine Doctoral program it was determined that the required programmatic accreditation had not been achieved from the Council on Naturopathic Medical Education to qualify for the additional Health Professions unsubsidized loan eligibility. As a result of this finding a thorough audit was completed for all students that were enrolled in the program since the first class began in October of 2023. In total six students were identified, and awards were adjusted to the proper annual loan limit of $20,500. The Institution made students whole by forgiving any student balances that would have been paid by theover award amount. In addition, the software configuration was changed to ensure moving forward that students receive up to the proper maximum of $20,500 until proper accreditation is achieved. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 13, 2024

View Audit 352615 Questioned Costs: $1

Finding 553918 (2024-001)

Material Weakness 2024

Columbiana Metropolitan Housing Authority

OH

Questioned Costs HUD Housing Programs Eligibility

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. CMHA is awar...

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. CMHA is aware that the HAB/MRI software does not store waitlist reports by date processed and since then, CMHA has been saving Excel files of the waitlist reports. The applicants that were selected for the audit were applicants that had preference points. All applicants with preference points were contacted at the same time to be informed that they were eligible for a voucher. The CMHA waitlists were ran by preference points and time/date of application. Once those applicants were pulled the waitlist was not saved to Excel. The preference point list was then sorted alphabetically for sign in purposes and tracking of applicant documentation. This is the list that was provided to the auditor. Melissa Beadle, Deputy Director, will be responsible to implement this corrective action by June 30, 2025.

View Audit 352576 Questioned Costs: $1

Finding 553917 (2024-001)

None 2024

Massachusetts School of Law at Andover, INC

MA

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

AUDIT FINDING Finding 2024-001 NSLDS Status Reporting Error MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor's finding and identification of a deficiency in our internal controls. ACTIONS TAKEN OR PLANNED We will increase internal controls to ensure all NSLDS status ...

AUDIT FINDING Finding 2024-001 NSLDS Status Reporting Error MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor's finding and identification of a deficiency in our internal controls. ACTIONS TAKEN OR PLANNED We will increase internal controls to ensure all NSLDS status reporting is done correctly. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately

View Audit 352568

Finding 553835 (2024-004)

Material Weakness 2024

Shawano School District

WI

Internal Control / Segregation of Duties Cash Management Eligibility

Child Nutrition Cluster – Eligibility The finding is a material weakness in internal control over federal awards due to incorrect eligibility determination entered into the Food Service System. The District will train individuals involved in the eligibility process on correct processes and reviews a...

Child Nutrition Cluster – Eligibility The finding is a material weakness in internal control over federal awards due to incorrect eligibility determination entered into the Food Service System. The District will train individuals involved in the eligibility process on correct processes and reviews and implement controls to prevent the improper determination of eligibility. Responsible official: Janice Boucher, Finance Manager, jboucher@shawanoschools.org Anticipated Completion Date: June 30, 2025

View Audit 352543

Finding 553794 (2024-004)

None 2024

Edward M. Marx Apartments, Inc.

FL

HUD Housing Programs Eligibility Reporting

FINDING No. 2024-004: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: Management should ensure that initial and ongoing tenant eligibility documentation is obtained timely and appropriately maintained, tenant eligibility is verified, and all tenants eligible to receive PR...

FINDING No. 2024-004: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: Management should ensure that initial and ongoing tenant eligibility documentation is obtained timely and appropriately maintained, tenant eligibility is verified, and all tenants eligible to receive PRAC are included on the monthly HAP requests. Action Taken: Monthly reminders are being sent to all managers to run their tenant reports to maintain eligibility. In addition, random files are being reviewed by compliance to ensure all required documentation is completed. If the Oversight Agency for Audit has questions regarding this plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

View Audit 352378

Finding 553700 (2024-001)

Significant Deficiency 2024

Germaine Harbor, Inc.

PA

HUD Housing Programs Procurement, Suspension & Debarment Eligibility

Finding 2024-001 Department of Housing and Urban Development Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects - Section 223(f)/207, ALN 14.155. ...

Finding 2024-001 Department of Housing and Urban Development Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects - Section 223(f)/207, ALN 14.155. Recommendation: The Property should have procedures in place to ensure the internal controls established to review Form HUD-50059 verifying all documentation used to calculate the tenant rent and assistance payment is supported and properly calculated. Action taken: The new property manager was informed of the finding. The error occurred prior to his management assignment. The new property manager, will ensure the internal controls established to review Form HUD-50059 verifying all documentation used to calculate the tenant rent and assistance payment is supported and properly calculated.

View Audit 352302

Finding 553641 (2024-003)

Significant Deficiency 2024

Scotland County of North Carolina

NC

Eligibility

Corrective Action Plan For the Year Ended June 30, 2024 Finding: 2024-003 Name of contact person: Corrective action: Proposed completion date: Section IV - State Award Findings and Question Costs Corrective Actions for Finding 2024-002 and 2024-003, also apply to the State findings. Training was com...

Corrective Action Plan For the Year Ended June 30, 2024 Finding: 2024-003 Name of contact person: Corrective action: Proposed completion date: Section IV - State Award Findings and Question Costs Corrective Actions for Finding 2024-002 and 2024-003, also apply to the State findings. Training was completed on 10/17/2024 by the Adult Medicaid Supervisors and Family & Children Supervisors. Adult Medicaid and Family & Children Medicaid Supervisors will begin monthly unit group training starting January 2025. Training focus will be on error findings for past and current audit findings, as well as policy refreshers. Additional training topic will be added as needed. Section III - Federal Award Findings and Question Costs (continued) Shaneall Kollock, Medicaid Program Manager Adult Medicaid Supervisors have trained staff on policies MA-2300 Applications and MA-2230 Financial Resources. Family & Children's Medicaid Supervisors have trained staff on policy MA-3200 Applications.Supervisors have also reviewed with staff verification of evidence, documentation, electronic sources(TWN, ROD, Tax Office). Supervisors will regularly monitor and check random applications/cases for inadequate request for information and evidence verifications. Any staff with error issues will complete additional training with Supervisors and/or Lead Workers. Any issues with staff making continuous errors and/or showing no improvement will lead to possible disciplinary conferences. 118

View Audit 352223

Finding 553640 (2024-002)

Significant Deficiency 2024

Scotland County of North Carolina

NC

Eligibility

Finding: 2024-002 Name of contact person: Corrective action: Proposed completion date: Shaneall Kollock, Medicaid Program Manager Adult Medicaid Supervisors have trained staff on policies MA-2300 Applications and MA-2230 Financial Resources. Supervisors completed individual training with each staff ...

Finding: 2024-002 Name of contact person: Corrective action: Proposed completion date: Shaneall Kollock, Medicaid Program Manager Adult Medicaid Supervisors have trained staff on policies MA-2300 Applications and MA-2230 Financial Resources. Supervisors completed individual training with each staff member to ensure verification of evidence, application/case documentation, and electronic sources are completed . Supervisors and Lead Workers will regularly monitor applications/cases for inaccurate resource entry. Caseworkers have been informed all evidence must have supported verifications scanned and documented in NCFAST. Any staff with error issues will complete additional training with the Supervisors and/or Lead Workers. Any issues with staff making continuous errors and/or showing no improvement will lead to possible disciplinary conferences. Corrective action: The Finance Director has made modifications to the internal year-end audit preparation procedures. With these modifications in place the director feels that the audit can be completed in a timely manner moving forward. Section III - Federal Award Findings and Question Costs Training was completed on 10/17/2024 by Adult Medicaid Supervisors. Adult Medicaid Supervisors will begin monthly unit group training starting January 2025. Training focus will be on error findings for past and current audit findings, as well as policy refreshers. Additional training topic will be added as needed.

View Audit 352223

Finding 553586 (2024-002)

Significant Deficiency 2024

County of Jones, Nc

NC

Questioned Costs Eligibility Internal Control / Segregation of Duties

Name of contact person: Melissa Labra, Income Maintenance Administrator II Case workers will receive additional training on countable/non-countable resources. Workers will be reminded of the procedures and policies that should be followed at time of application and recertification processes. Superv...

Name of contact person: Melissa Labra, Income Maintenance Administrator II Case workers will receive additional training on countable/non-countable resources. Workers will be reminded of the procedures and policies that should be followed at time of application and recertification processes. Supervisors will conduct second party reviews on applications and recertification’s to determine that proper policies and procedures are being followed. Workers will be retrained on NCFAST evidence for resources to ensure procedures are being followed for evidence on dashboard to match the supporting documentation used as verifications. Supervisors will review cases to verify that evidence in NC FAST and supporting documentation match. Proposed Completion Date: January 31, 2026

View Audit 352178 Questioned Costs: $1

Finding 553585 (2024-001)

Significant Deficiency 2024

County of Jones, Nc

NC

Eligibility

Name of contact person: Melissa Labra, Income Maintenance Administrator II Corrective Action: Caseworkers will receive additional training on complete documentation in case files, application of NCFAST evidence including accurate needs unit, precise resource calculations and countable/non-countable ...

Name of contact person: Melissa Labra, Income Maintenance Administrator II Corrective Action: Caseworkers will receive additional training on complete documentation in case files, application of NCFAST evidence including accurate needs unit, precise resource calculations and countable/non-countable resources. Caseworkers will receive additional training in regards to the proper procedures and policies that should be followed at time of application and recertification process. Supervisors will conduct second party reviews on applications and recertification’s to determine that the correct procedures are being followed. Caseworkers will receive training on the work number (TWN) in NCFAST learning gateway. Caseworkers will receive training on income and budgeting policy (MA 3300). Caseworkers will receive training on third party insurance and inputting such into NC FAST. Supervisors will review cases to verify evidence and supporting documentation match and cases show consistency. Supervisors will review cases to ensure evidence is inputted correctly and accurate needs units is used in determination of benefits. Proposed Completion Date: January 31, 2026

View Audit 352178

Finding 551530 (2024-002)

Significant Deficiency 2024

Monarch Immigrant Services

MO

Eligibility

Finding 2024-002: Significant Deficiency in Internal Control over Compliance of Major Programs Corrective Action Plan: Program audited annually by grantor (HHS-ACF-ORR) without identifying as an issue. Departmental reorganization already underway to realign supervision and reporting across programs....

Finding 2024-002: Significant Deficiency in Internal Control over Compliance of Major Programs Corrective Action Plan: Program audited annually by grantor (HHS-ACF-ORR) without identifying as an issue. Departmental reorganization already underway to realign supervision and reporting across programs. Monarch Immigrant Services will implement a monthly eligibility and documentation review for screened SOT participants with incoming Mental Health Department Director. Name of Responsible Person: Jason Baker, Executive-Director Anticipated Completion Date: May 1, 2025

View Audit 352142

Finding 551523 (2024-001)

Significant Deficiency 2024

Suffolk Redevelopment and Housing Authority

VA

HUD Housing Programs Eligibility Significant Deficiency

Finding No. 2024-001 Housing Choice Voucher: Tenant Eligibility – Significant Deficiency Contact Person: Patricia Tyus Executive Director/CEO The Authority's Housing Choice Voucher program was not pulling Earned Income Verifications (EIVs) within 90 days of move-in, as required by HUD regulations....

Finding No. 2024-001 Housing Choice Voucher: Tenant Eligibility – Significant Deficiency Contact Person: Patricia Tyus Executive Director/CEO The Authority's Housing Choice Voucher program was not pulling Earned Income Verifications (EIVs) within 90 days of move-in, as required by HUD regulations. Additionally, the Authority was missing one recertification for a tenant during the audit period and was missing criminal background checks for tenants. These issues were all for tenants at Whitemarsh Point Eagle Landing. CORRECTIVE ACTION: EIV compliance The Nelrod Company was solicited to provide a Compliance Monitor Plan for SRHA. They did not completely prepare what was required for; but focused on SEMAP, and they were delayed with the deliveries in the contract. We discontinue the contractual relationship and implemented the following items in 2024. We have completed the following items: 1. SRHA placed a priority on getting the staff EIV access so that all the staff can pull and print the EIVs 2. HCV added additional EIV procedures to the HCV SOPs 3. Worked with Vista Management (PBV) to ensure the EIV are printed and in the files 4. Management staff completed training for the staff on the following dates: Quality Control file training—02/08/2024; Compliance Training on all processes--09/06/2024; Adjustment Payment Training--10/4/2024; File Compliance Procedures—1/17/2025. TARGET DATE: On-going

View Audit 352125

Finding 551508 (2024-001)

None 2024

Valor Christian College

OH

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

FINDING 2024-001: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOANS- the auditor tested forty files, thirty-six of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. It is recommended the College reclassify $2,124 from uns...

FINDING 2024-001: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOANS- the auditor tested forty files, thirty-six of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. It is recommended the College reclassify $2,124 from unsubsidized to subsidized and increase controls over packaging direct loans. Comments on Finding and Recommendation(s): We concur with the finding and we believe that these account represent a unique situtation. Actions Taken or Planned: For A1, Valor was able to rectify the account because it was within the 180-day limit. We have implemented an internal audit process that takes place twice each semester to reconcile federal aid awarded with the appropriate aid based on enrollment status and grade level. For A-2, Value is unable to reallocate subsidized and unsubsidized awards for the second student as the 180-day limit has passed. The student was awarded the correct total amount of aid. Moving forward, Valor will generate an NSLDS report whenever a 258 ISIR code appears on the ISIR to ensure proper aid allocation.

View Audit 352114

Finding 551393 (2024-005)

Material Weakness 2024

Hampton University

VA

Eligibility Reporting Matching / Level of Effort / Earmarking

Management agrees with this finding. The SSS director and staff will review the key line-item data at the point of entry to ensure the completeness and accuracy of information input into the Blumen system. Training will also be provided for the new administrative assistant. Prior to submitting the A...

Management agrees with this finding. The SSS director and staff will review the key line-item data at the point of entry to ensure the completeness and accuracy of information input into the Blumen system. Training will also be provided for the new administrative assistant. Prior to submitting the APR, a download of all data categories will be reviewed for accuracy and completeness.

View Audit 352091

Finding 551189 (2024-003)

Material Weakness 2024

The City of New York

NY

Questioned Costs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2024-003 Department(s): New York City Administration for Children’s Services and Department of Education Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: The City is planning to transition to the New York State IT system o...

Finding No. 2024-003 Department(s): New York City Administration for Children’s Services and Department of Education Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: The City is planning to transition to the New York State IT system once it is fully developed and implemented by the New York State Office of Children and Family Services and New York State Information Technology for the Child Care Assistance Program. The State IT system will be programmed to reflect current State policy on authorized hours, mitigating the risk of this error in the future. In the interim, The City will implement a short-term, manual solution that will ensure enrollments match authorized hours with regard to full time or part time enrollment and days of enrollment. The first step of the manual solution requires a feasibility analysis to see if it is possible to add a field for recording authorized hours into The City's IT system of record. DOE: The DOE will continue working with ACS to ensure compliance with internal controls, applicable state and federal statutes, regulations, requirements and guidelines. The internal controls include a quality assurance check process on submitted eligibility applications. Anticipated Completion Date: ACS: August 2025 and ongoing DOE: Ongoing Person(s) Responsible for Implementation: ACS: Shari Gruber, Associate Commissioner, Policy and Compliance, Division of Child & Family Well-Being, shari.gruber@acs.nyc.gov, (212) 393-5109 DOE: Meg Barboza, Senior Director of Program Enrollment, mbarboza@schools.nyc.gov, (212) 287-1996 Jodina Clanton, Eligibility and Senior Director of Policy, jclanton@schools.nyc.gov, (212) 287-1927

View Audit 352075 Questioned Costs: $1

Finding 551180 (2024-004)

Material Weakness 2024

The City of New York

NY

HUD Housing Programs Eligibility Material Weakness § 200.303

Finding No. 2024-004 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimiz...

Finding No. 2024-004 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 352075

Finding 551178 (2024-005)

Material Weakness 2024

The City of New York

NY

HUD Housing Programs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Pro...

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 352075

Finding 551177 (2024-007)

Significant Deficiency 2024

The City of New York

NY

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Finding No. 2024-007 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): HRA implemented the corrective actions noted in our response to the Fiscal 2023 Single Audit findings. In Nove...

Finding No. 2024-007 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): HRA implemented the corrective actions noted in our response to the Fiscal 2023 Single Audit findings. In November of 2023, HRA hired an Executive Director for the Home TBRA program, updated the quality assurance evaluation tool and trained staff on the differences of budgeting the “gross” and “net” income. Note that HRA began closing out the TBRA tenants with renewal lease dates starting on 8/1/2023, as the program fully closed and transitioned to the City Fighting Homelessness and Eviction Prevention Supplement (“CityFHEPS”) by the 6/30/24 HRA- Housing Preservation and Development Memorandum of Understanding expiration date. Although the rental assistance portion of the HOME TBRA program began phasing out, the following corrective actions were implemented as part of the Fiscal 2023 Single Audit recommendation: • Supervisory staff were retrained on case review and instructed to do a thorough and comprehensive review of the budget and documentation received to inform case decisions. There have been on-going team and individual meetings, informational sessions and trainings with staff involved with TBRA to improve performance and outcome. Anticipated Completion Date: Not Applicable. As noted above, the Rental Assistance portion of the program has been taken over by CityFHEPS. Person(s) Responsible for Implementation: Jordan Worrell, HTBRA Executive Director worrellj@hra.nyc.gov (929)-252- 5403

View Audit 352075

Finding 551172 (2024-001)

Significant Deficiency 2024

Mercy College

NY

Student Financial Aid Reporting Eligibility

Corrective action: There is a process in Banner that creates a file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process in Spring 2024 rendering the process unable to generate a file. The error was not resolved...

Corrective action: There is a process in Banner that creates a file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process in Spring 2024 rendering the process unable to generate a file. The error was not resolved until May 2024, which is when the submission for these students was completed. This was a one-time specific system failure occurrence which has been resolved and the process has been working correctly since May 2024. The Offices of the Registrar and Student Financial Services are working in conjunction with the University compliance team and Office of Institutional Research to enhance review and checks/balances of reporting deadlines to ensure that files are submitted within the required deadlines. Further, the Office of the Registrar will work with internal IT staff to research and implement backup reporting procedures for creating enrollment and graduation files in the event of another system issue. Proposed Completion Date: May 31, 2024

View Audit 352071

Finding 551133 (2024-009)

Material Weakness 2024

County of Solano

CA

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Foster Care Federal Assistance Listing Number: 93.658 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Allowable Activities and Allowed Costs Type ...

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Foster Care Federal Assistance Listing Number: 93.658 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Allowable Activities and Allowed Costs Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: Solano County has policies and procedures as well as systematic processes and oversight set up to ensure accurate assessments and determinations are made regarding the Federal or Non-Federal Eligibility of youth in the Foster Care system. It is Solano County’s policy to conduct these assessments at the onset of the case and ensure quality documentation. In addition, the Foster Care unit has a Lead worker and Supervisor who conduct periodic reviews of open cases to ensure accuracy of documentation and adherence to timelines are met. The specific corrective actions identified in this audit found errors related to the migration of data to the CalSAWS program in 2023, where an identified payment was incorrectly identified (Non-Federal to Federal) due to errors or information which existed in CalWin and were transferred improperly to CalSAWS. These conversion errors occurred automatically. As a result, the Foster Care Eligibility Unit has implemented the following changes. • Correction to identified payment: o The identified case was corrected immediately, and all payments adjusted as appropriate. • Changes to workflow to ensure accuracy: o The entire caseload of open Foster Care Eligibility cases will be reviewed to ensure that the original determination or as found in the FC3 or FC3A and granting comments, is correctly input in CalSAWS, and any payment errors corrected as needed. o The case aid code (noting eligibility type) will be included next to the youth’s name to ensure that it shows in the workload report in CalSAWS to ensure the information is easily accessible and any future errors can be identified. o Cases will be reviewed to ensure the above changes are completed through the unit supervisor’s ongoing qualitative review of cases. • The Foster Care Eligibility Supervisor will discuss the findings and requirement with subordinate staff in the following ways: o Unit meeting communication regarding Corrective Action findings and Agency steps to remediate. o Issue a reminder to all staff regarding the above remediation plan. Responsible Individual(s): Kim McDowell, Social Services Manager Neely McElroy, Deputy Director, Child Welfare Services Anticipated Completion Date: May 31, 2025

View Audit 352056 Questioned Costs: $1

Corrective Action Plans

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