Corrective Action Plans

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

Finding 2024-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Numbers: 14.850 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its Admissions and Continued Occupancy Policy for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203(Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with certainty that new move-ins were selected from the wait list in an order that is in accordance with the Authority’s policy. Context: Two (2) names were selected from the new move-in list and those names were to be traced to the waiting list to verify new move-ins were chosen in an order that was in accordance with the Authority’s policy. It was determined that two (2) out of two (2) new move-ins selected could not be traced with certainty back to the Authority's waiting list Known Questioned Costs: $8,691 Findings – Federal Award Program Audit (continued) Finding 2024-003 (continued) Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selections from the waiting list. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Public and Indian Housing Program is in material non-compliance with the special tests and provisions type of compliance related to selections from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures related to selections from the waiting list that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Public and Indian Housing Program and will implement internal control procedures related to selections from the waiting list that will ensure compliance with federal regulations. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2025.

El Proyecto del Barrio, Inc. acknowledges the finding related to the incorrect administration of sliding fee discounts. We are committed to strengthening the administration of the sliding fee program to ensure full compliance with grant requirements. To address these issues and prevent recurrence, the following corrective actions are being implemented: 1. Revised Application and Documentation Requirements: o The Sliding Fee Program application forms are being updated to include structured sections for staff to record income from supporting documentation (e.g., pay stubs, tax returns), rather than relying on the patient to write their income on the application, which will greatly reduce incorrect income stated on support. Staff will be responsible for calculating annual gross income based on supporting documentation and have a checklist to ensure documentation is complete and retained/uploaded in the system. 2. Two-Step Review Process: o A staff member (the “Preparer) will calculate the annual gross income, determine the household size, and determine the eligible sliding fee discount, and a second staff member (the “Reviewer”) will independently review and verify the Preparer’s calculations and determinations based on the supporting documentation. Both parties will document their review of the application to establish accountability. 3. Staff Training and Ongoing Competency Checks: o Comprehensive refresher training will be provided to all staff involved in the sliding fee program process, including the use of the poverty guidelines, income calculation methods, the new forms, entering income and household size into the system, and uploading support to the system. 4. Formal Review: o The Billing Department will conduct regular audits of completed sliding fee applications and eligibility determination forms to ensure compliance with policies. Errors will be tracked and addressed through corrective action and coaching. El Proyecto del Barrio, Inc. remains committed to accurate, compliant, and equitable implementation of the Sliding Fee Program. Person Responsible: Ricardo Ornelas Position of Responsible Party: Chief Financial Officer Completion Date: August 31, 2025

Action: Checklists for eligibility functions were implemented 07.31.24 with the FY23 Audit Findings. The deficiencies for the FY24 Audit occurred prior to the implementation of the checklists. 01.26.24 for use of the incorrect UA and 01.18.23 for incorrect calculation of income. Due Date: July 31, 2024 Responsible Person: Program Manager, Christi Champ Action: Overdue Inspections Completed. The full portfolio of required HQS inspections were vetted following the FY23 audit, and any overdue inspections were completed. Due Date: March 31, 2025 Responsible Person: Program Manager, Nat Dybens

Finding Number: 2024-005 Title: Missing Receipt Support for MTW Public Housing Tenant Transactions Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: A review of tenant files under the Moving to Work (MTW) Public Housing program found that while the tenant files themselves were complete, the Authority did not provide supporting documentation for certain rent receipts. In several instances, the rent amounts recorded in the receipt or rent register did not agree with the amounts reported on HUD Form 50058, and no receipt documentation was available to reconcile the difference. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to improve tenant file management, ensure complete supporting documentation, and address disbursement variances.

Finding Number: 2024-004 Title: Incomplete Tenant File Documentation and Disbursement Variances for MTW Housing Assistance Payments Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: A review of tenant files and disbursement activity under the Moving to Work (MTW) Housing Assistance Payments (HAP) program identified multiple deficiencies in documentation and compliance. For six out of the sixteen tenants tested, the Authority was unable to provide the tenant file for review. Among the files that were available, several lacked required documentations for the required period to support continued occupancy, rent adjustments, reexaminations, income verification, and inspections. Additionally, variances were noted between the amounts reported on HUD Form 50058 and the actual HAP/UAP disbursements made. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to improve tenant file management, ensure complete documentation, and address disbursement variances.

Mov ing to Work Demonstra tion Program - Capital Fund ProgramALN: 14.881 Description: During testing of the Mov ing to Work Demonstration Program - Capital Fund Progra m, we selected a sample of eight elOCCS drawdown vouchers for rev iew. Of these, the Authority was unable to provide sufficient supporting documentation to substantia te the eligibility, timing, or purpose of the draw d owns for four v ouchers. For another v oucher, the Authority could only partially support the a mount dra wn. These issues reflect a lack of a dequate documentation necessary to substantiate the allowability and propriety of the expenditure charged to the CFP grants. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility and "just-in-time" requirements prior to the Executive Director signing the request.

Title: Incomplete Support for Capital Fund Program (CFP) Drawdown Sample Program Name: Capital Fund Program ALN: 14.872 Description: As part of the testing of the Capital Fund Program (CFP) major program, a sample of six drawdown vouchers were selected for review. The Authority was unable to provide adequate supporting documentation for one voucher in the sample. The missing documentation prevented verification of the eligibility, timing, and allowability of the associated expenditures. Planned Corrective Action: Fiscal Vear 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility, timing, and allowability of the associated expenditures.

The Department of Health (DC Health) concurs with the finding. The HIV/AIDS, Hepatitis, STD and TB Administration (HAHSTA) has done a preliminary assessment of the root cause and conditions that created the exceptions noted in the testing of eligibility samples. DC Health agrees that the infrequency of reviews and lack of documented secondary supervisory reviews are contributing factors. DC Health will develop and implement a plan to build a supervisory-tier of eligibility review into the operations of the ADAP program and to standardize an internal audit process. The ADAP program will target a random sampling of 20% of applications submitted weekly to test compliance with eligibility criteria and documentation of eligibility reviews and decisions, including supervisory sign-off. Peer and supervisory audits will follow a protocol to validate application decisions, standardize the audit process and ensure the audits are documented appropriately. Any findings will be documented in the Ramsell Eligibility System. Job aides and training will be provided to eligibility specialists. Avemaria Smith, Interim Chief - HIV Care and Treatment Services (HAHSTA) Contact: Clara Ann McLaughlin, Chief - Office of Grants Management Estimated Completion Date: October 30, 2025 See Corrective Action Plan for chart/table

The Economic Security Administration (ESA) concurs with this finding. DC Access System (DCAS) currently has a timeliness monitoring report called the “Pending Summary Report” (PSR). This is a report that is automatically produced within Microstrategy, to notify applicable management of applications (initial and renewals) that have been pending determination for 30 days. During FY 24, this report was produced to applicable managers on a weekly basis. As of June 16, 2025, this report is now issued on a daily basis. DHCF believes that increasing the frequency of reporting cases that are over 30 days in “pending” status, will increase the timeliness of application determinations. Contact: Melisa Byrd, Senior Deputy Director and Medicaid Director Estimated Completion Date: June 30, 2025 See Corrective Action Plan for chart/table

The Child and Family Services Agency (CFSA) concurs with the findings. The licensure issue involved a provider who was in process of permanently closing her home as a foster care provider (and the existing license expired in the meantime), and the other item involved a brief lapse in the child protection register check. Corrective action will involve improved automation within the claiming process. CFSA also acknowledges that the third bullet regarding the legibility of the background criminal check document for the “other adult in the home” is an internal control issue for which there are no questioned costs. Corrective action will occur within STAAND implementation as key system edits in the foster care maintenance claim report will account for lapsing/expiring (according to District standards) licensure documentation. Payments to providers that do not meet title IV-E requirements across all axes will be left out of the IV-E foster care maintenance claim. Contact: James Murphy, Business Services Administrator Estimated Completion Date: December 31, 2025 See Corrective Action Plan for chart/table

The Department of Human Services (DHS) agrees with the findings that appropriate actions were taken to approve the case, however, the reviewing supervisor failed to update the Supervisory Case Review form with 1) date the discussion was held with the eligibility worker, the date the eligibility worker made corrections, and the date the eligibility worker review was completed and 2) failed to enter comments on “No” responses on various questions. DHS will enforce current policies and procedures and will ensure that Supervisory Case Reviews are updated and double-checked by the supervisor once the eligibility worker make the corrections prior to OSSE’s report being submitted to reflect the accurate information. The corrective action plan developed for the Child Care Services Division (CCSD) is to conduct refresher training with the CCSD Supervisory Leadership Team on the requirements for the supervisors reviewing the case files. The supervisors will double-check the Supervisory Case Review forms to ensure it is completed in its entirety including all recommended corrections. The 2nd level reviewer will make sure the Supervisory Case Review forms are correct and reflect the findings and corrections. The Supervisory Case Review form will be revised. Contact: Ann Pierre, Deputy Administrator, Division of Customer Workforce Employment & Training (DCWET) Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

The Department of Human Services (DHS)/Economic Security Administration (ESA) concur with the findings. The TANF corrective action plan outlines several key actions to enhance compliance and reduce improper payments. First, policies and procedures will be updated to mandate responses to all eligibility questions and require verification of documentation before case approval. System enhancements in DCAS will introduce validation rules to prevent incomplete submissions and block duplicate payments without supervisory clearance. Staff will receive mandatory refresher training focused on documentation requirements and proper DCAS data entry and verification processes. Felony Conviction questions are asked in the Integrated paper benefits application. DCAS system updates are needed to the DCAS online and case worker portal IEG scripts. Contact: Francine Miller, Deputy Administrator Estimated Completion Date: September 30, 2026 See Corrective Action Plan for chart/table

The Office of the Deputy Mayor for Planning and Economic Development (DMPED) does not concur with the auditor’s finding regarding the allowability of rent per the CPF guidance. DMPED’s current grant procedures include a legal review and analysis by its Office of General Counsel (OGC) to determine activities that are allowed or unallowed and allowable costs/cost principles to ensure only allowable expenses are charged to federal programs as required under 2 CFR Section 200.403. Before DMPED approved the payment of rent for the Whitman-Walker Saint Elizabeth’s Expansion project, DMPED OGC had conducted legal analysis and determined that payment of rent qualifies as an allowable cost. DMPED had also received Treasury approval the summer prior (July 2024) for ancillary costs needed to operationalize the capital asset. As part of its Corrective Action Plan, DMPED will commit to seeking expressed approval from the awarding Federal agency in cases where the project guidance may be unclear and where DMPED OGC has interpreted the guidance, in order to validate DMPED’s interpretation. As a result, DMPED will take the following steps outlined below: 1. Evaluate its procedures in identifying Activities Allowed or Unallowed and Allowable Costs/Cost Principles to ensure only expressly allowable expenses are charged to the program as required under 2CFR Section 200.403. Estimated Completion Date: July 6, 2025 2. Add internal controls and policies that include clearer protocols around seeking awarding Federal Agency approval in cases where DMPED OGC has interpreted the guidance, in order to validate DMPED’s interpretation of generalized categorical guidance. Estimated Completion Date: August 6, 2025 Contact: Darya Razavi, Program Manager, Office of the Deputy Mayor for Planning and Economic Development See Corrective Action Plan for chart/table

The Office of the Chief Financial Officer/Office of Finance and Treasury (OCFO/OFT) for Department of Human Services (DHS) concurs with this finding. The process to manage card distribution is manual, utilizing paper forms. UPO is evaluating the current policy and procedures to identify areas for improvement, including additional validation steps. Any updates to the policy and procedures will be documented in the EBT Program Manual and shared with the District. Employees will be held accountable for their performance in following the policy and procedures as documented in the EBT Program Manual. The Quarterly UPO internal audits, and the Quarterly Regis audits will continue to assist in identifying areas for improvement. The EBT Manager and Supervisors will define and implement a process for additional review and validation of the daily paperwork with the Card Production Specialists to ensure compliance of policy and procedures. Contact: Joseph Cobb, Contracting Officers Technical Representative (COTR) and Payment Operation Center Manager Estimated Completion Date: September 30, 2026 See Corrective Action Plan for chart/table

The Department of Human Services (DHS) and Department of Health Care Finance (DHCF) DC Access System (DCAS) team agree with the findings. For the twelve (12) findings, DHS/ESA has identified the description of the deficiencies, examined the magnitude and geographic extent of the deficiencies, identified the actions completed to eliminate the deficiencies. The District will focus on efforts that will create the maximum impact, which includes creating new options for collaboration, streamlining current communication, and introducing cross-functional prioritization. These strategies will help the District move projects toward completion and are rooted in continuous quality improvement. To guide its strategic efforts and track its impact, DHS has outlined the following four phases of corrective action plans to be taken to ensure the deficiencies will be eliminated: • Review and Prioritization, • Design and Development, • Implementation, and • Monitor and Evaluation. Each phase has several process steps including a completion document that signals the permission to move to the next phase. The detailed process steps are documented under DHS’ Consolidated Semi-Annual SNAP Advance Warning Letter Corrective Action Plan and FFY2025 Quality Control Corrective Action Plan reports. The corrective action plan is facilitated by the Quality Improvement Program and since implementing this process in January 2021, the District has identified root causes for errors and gaps in internal auditing and evaluation processes. Therefore, the flow of the semi-annual corrective action plans reflects the District’s commitment to a collaborative corrective action plan - expanding the data analysis section to include data and analysis of internal methods, a complete summary of each phase completed, and a timeline for upcoming phase/project completion. Contact: Stephanie Bloch-Newman, Deputy Administrator for Innovation & Change Management Estimated Completion Date: September 30, 2026 See Corrective Action Plan for chart/table

Name of Auditee: Town of Huntington Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: September 30, 2024 CAP Prepared by: Steve Nakano, Executive Director Phone: (631) 427-6220 (A) Current Finding on the Schedule of Findings and Questioned Costs (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will conduct a thorough review of all tenant files to identify and resolve missing documentation, including signed applications, lease agreements, proof of citizenship or eligible immigration status, independent income verification, HUD forms (50058 and 9886), rent reasonableness documentation, and HQS inspection records. Staff will work to obtain missing documents from tenants, landlords, or other necessary parties. A standardized checklist should be used to ensure all required items are present in each file moving forward. (c) Planned implementation date of corrective action - Completed by September 30, 2025.

Dear Cognizant or Oversight Agency for Audit: The Women’s Home respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Doeren Mayhew Assurance, 2600 North Loop West, Suite 2600 , Houston TX, 77092. The finding discussed below from the Schedule of Findings and Questioned Costs (the schedule) for the year ended December 31, 2024 is numbered consistently with the number assigned in the schedule. Federal Award Finding 2024-001 Corrective Action Plan: We will incorporate quarterly audits of income verification by our grants compliance manager. Regular chart audits by the program team will be conducted to review all documents and re-certify as necessary. Contact Person Responsible for Corrective Action: Ms. Anna Coffey, Chief Executive Officer Anticipated Completion Date: Respectfully submitted, Ms. Anna Coffey Chief Executive Officer

Responsible Official’s Response: The City acknowledges the deficiency and has taken measures to prevent this from occurring again. The City has engaged the services of an Interim Finance Director who is experienced and skilled in governmental accounting. The Interim Finance Director will remain with the City through the FY2025 audit and will be responsible for the audit and any single audits for this fiscal year. In addition, the City will retain the Interim Finance Director to train current and future staff to ensure the City is in compliance with any and all current and future federal, state and local grants.

Responsible Official’s Response: The City acknowledges the deficiency and has taken measures to prevent this from occurring again. The City has engaged the services of an Interim Finance Director who is experienced and skilled in governmental accounting. The Interim Finance Director will remain with the City through the FY2025 audit and will be responsible for the audit and any single audits for this fiscal year. In addition, the City will retain the Interim Finance Director to train current and future staff to ensure the City is in compliance with any and all current and future federal, state and local grants.

Reference Number: 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Authority’s Response & Actions Taken The Authority has made considerable progress in addressing the backlog of annual re-examinations that resulted from the transition of a third-party contractor to new third-party contractors to administer its Project-Based and Tenant-Based Voucher Programs. The material weakness was further exasperated by tenants not responding to re-examination notices or failing to provide the required income and household documentation by established deadlines. In an effort to avoid unnecessary subsidy terminations and protect vulnerable tenants, the Authority’s administrative plan allows for extended grace periods and repeated follow-ups. While this tenant-centered approach helped mitigate adverse outcomes for families, it also contributed to delays and ultimately resulted in noncompliance with HUD’s timeliness requirements. The Authority recognizes the critical importance of conducting timely and accurate annual reexaminations to maintain program integrity, ensure proper subsidy determination, and remain in compliance with HUD regulations. With that said, the Authority continues to work diligently with its third-party HCV contractors, city department partners, onsite service providers and property management companies to ensure the Authority is timely recertifying all assisted households. Although the Authority has established procedures to initiate reexaminations 150 days in advance of their due dates, a significant portion of the delays cited in the recent audit were the result of tenant non-responsiveness—specifically, the failure to provide required documentation despite multiple notices and outreach efforts. Importantly, all overdue reexaminations identified during the audit were ultimately completed. Each of the affected households was determined to be eligible under HUD guidelines, and housing assistance payments (HAPs) were accurately processed based on verified household information. The Authority remains committed to its tenant-centered mission, which prioritizes preventing unnecessary subsidy terminations and supporting household stability. At the same time, the Authority fully recognizes the importance of complying with HUD’s reexamination timelines. The corrective actions outlined below are designed to ensure that tenant-related delays are minimized, documented, and managed in a way that prevents the recurrence of this material weakness. To address this finding and in accordance with the Authority’s Administrative Plan and HUD rules and regulations, the Authority has already implemented the following actions starting fiscal year 2023-24: • Initiating the Annual Re-examination process 150 days before the required anniversary date to give households more time to comply. • Reviewing the report of outstanding Annual Re-examinations on a weekly basis. • Scheduling additional partner calls with property management and resident services to assist non-compliant families. • Enforcing Annual Reexamination compliance through the Intent to Terminate process • Scheduling and completing on-site visits for senior-disabled sites and non-restricted sites with large numbers of families out of compliance. • Reviewing discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. Per CFR 24 985.3, Section 8 Management Assessment Program (SEMAP) Indicator 9 for Annual Reexamination, 95% of all households must be recertified within 14 months of their last annual recertification to maintain full compliance, and 90% of all households must be recertified within 14 months to maintain partial compliance with the SEMAP Assessment standards required by HUD. The Authority expects to hit 90% by the end of the SEMAP year September 30, 2025. Anticipated Implementation Date September 30, 2025 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

The Management of the Authority agrees with the findings; we will implement improved internal controls to ensure that all annual recertifications are performed in a timely manner and that all required documents are kept in an organized manner. The Authority hired a Compliance Specialist in May 2025 to perform quality control checks on the files to eliminate errors. The HCV Program Director is the responsible party, and controls will be in place by the end of the September 30, 2025 fiscal year.

The Management of the Authority agrees with the findings; we will implement improved internal controls to ensure that all annual recertifications are performed in a timely manner and that all required documents are kept in an organized manner. The Authority hired a Compliance Specialist in May 2025 to perform quality control checks on the files to eliminate errors. The Public Housing Director is the responsible party, and controls will be in place by the end of the September 30, 2025 fiscal year.

Planned Implementation Date of Corrective Action: July 2025 Person Responsible for Correctove Action: Krishonna Murray, Executive Director I. 2024-001 Eligibility Rent Calculation Other Matter/Significant Deficiency The Authority had instances of missing income verifcation. Gardner Housing Authority has establised a system of internal control over the participant recertification process that meets HUD's requirements. Seven (7) to ten (10) files will be reviewed fiscally for quality assurance.

FINDING No. 2024-003: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure all documentation related to applicants and tenants are properly executed and maintained, and that the manager verifies eligibility by obtaining all required documents for potential tenants while verifying and maintaining support for tenant income eligibility through the EIV system in a timely manner. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. 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