Corrective Action Plans

Broomfield agrees with the auditors' recommendation to follow the documented internal control process or adjust process for over review of eligibility determinations. Additionally, staff members working in areas concerning this process will be trained to ensure process adherence.

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Federal Assistance Listing Numbers: 14.871 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 HCVP administrative plan 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 any certainty that new move-ins were selected from the wait list in an order that is in accordance with the Authority’s policy. Context: Of a sample size of fifteen (15) Section 8 Housing Choice Vouchers' new move-ins, one (1) could not be traced to the Authority's waiting list. Known Questioned Costs: $4,336 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 Section 8 Housing Choice Vouchers 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 that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority agrees with the finding and will increase oversight on the maintenance of the waiting list and process of housing applicants to better monitor adequacy with compliance requirements. Ann Malfavon, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

NEED FROM CLIENT….

2023-003: Housing Voucher Cluster – Eligibility – Document Retention Name of Contact Person(s): Allison Gallagher, Director of Housing Choice Vouchers Management’s Views and Corrective Action Plan: Signed HAP contracts and lease agreements are required for every new lease up and MaineHousing will not release payment to the owner until those signed documents are received. These agreements state the contract rent and subsidy amounts at the time of the initial lease. Annually, each tenant is recertified and a contract amendment is generated with the current contract rent and subsidy amounts listed. These amendments are filed with the original documents. Management is certain that proper rent and subsidy payments were made based on annual and interim recertification documents on file. A new electronic file retention process was implemented in 2022, which involved organizing and converting volumes of physical files to electronic files. Since implementation of the new process, we have determined that some unit information for certain tenants was inadvertently discarded during conversion. Program staff are identifying missing unit information as they process annual recertification or when an outside party requests it and reaching out to the owner to obtain a copy of the signed original documents. The two HAP and lease contracts identified in this finding have been obtained. Management believes that the electronic file retention process currently in place is working well and this was isolated to the period of time when files were being organized and scanned from physical files to electronic files. Proposed Completion Date: Completed

Corrective Action Plan for Current Year Findings Finding 2023-001: Timely Processing of Participant Applications: Department of Health and Human Services - AL #93.568 Low Income Home Energy Assistance Program #Ll-023-024 Corrective Action: WICAA has developed a streamlined approach for assessing incoming applications, differentiating between complete and incomplete applications at the beginning of the processing cycle. This will ensure that complete applications can be promptly processed. Additionally, if a substantial number of unprocessed applications are nearing 10 days of the deadline for processing, our staff will be notified that there is a need for overtime. Overtime requirements will be assessed weekly. These modifications are anticipated to result in applications being processed within the allowable number of days. Person Responsible: The Energy Assistance Director has primary responsibility with oversight by the Executive Director. Timing for Implementation: Immediately

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Eligibility Recommendation: We recommend that the Commission review its process for collecting third party income support to ensure the accurate data is used as part of the tenant rent and HAP calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrected data is essential in determining the correct rent responsibility and HAP. To ensure that the data and rent calculations are correct, HCHC has taken the following steps: • Staff members have taken additional Housing Specialist training offered by Nan McKay. • HCHC has created and hired a quality control specialist who selects housing specialist 50058 actions to ensure that HCHC has data integrity, and all information is true and accurate. • The supervisor also selects housing specialist 50058 actions for review, ensuring that all required documentation is intact and that the proper rent responsibility and HAP calculations are correct. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Completion date for corrective action plan: 6/30/2024

Hamlet Housing Authority Corrective Action Plan For the Year Ended December 31, 2023 Section II - Financial Statement Findings None Reported. Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Gary Jones Executive Director Corrective Action: Management will review the recertification process and plan to monitor recertifications. Proposed Completion Date: Immediately

Finding 2023-001: Material Weakness over Subrecipient Monitoring and Required Filings The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Management had existing controls related to subrecipient monitoring. However, these controls were not sufficiently detailed relative to the collection of audited financial statements and eligibility to receive funding. During 2023, for one subrecipient, HESI did not retain evidence of the review performed of the subrecipient’s eligibility to receive funding and did not retain evidence of the monitoring of the subrecipient’s audited financial statements. Planned Corrective Action: The subrecipient’s audited financial statements and Report on Federal Awards in accordance with Uniform Guidance were subsequently requested and reviewed in September 2024. Procedures have been put in place to ensure that subrecipients are eligible to receive Federal funding and a subrecipient’s audited financial statements and compliance reports will be requested and reviewed annually. Name and Person Responsible: Beth-Ellen Berry, Chief Financial Officer Anticipated Completion Date: September 3, 2024

Corrective Action Plan For the year ended December 31, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Becky Tatum Interim Director Corrective Action: Mangagement will implement proper internal control procedures for the Housing Choice Voucher Program eligibility requirements. Proposed Completion Date: Immediately

Finding No. 2023-001 Eligibility: Public Housing Tenant Files Public and Indian Housing Program – CFDA Number 14.850 Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Condition: Out of a total tenant population of 1,275, 25 files were selected for testing. Exceptions were noted as follows: • 3 out of 25 tenants where an outdated flat rent was used instead of the current amount. • 1 tenant where wage income was calculated as paid bi-weekly when it was actually paid semi-monthly. • 2 tenants where the prior year social security income was used when the current year amount was known. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff. The cited files have been corrected. Effective Date: September 19, 2024 Contact Information Brian Griswell, Executive Director SC Regional Housing Authority No.1 218 Spring Street Laurens, SC 29360 (864) 984-6568

Finding Number: 2023-005 Finding Title: Eligibility – METS Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Kathryn Herding – Eligibility Supervisor Corey Remiger – Eligibility Supervisor Ashley VanOverbeke- Eligibility Supervisor Corrective Action Planned: The planned corrective action is to continue reminding and reviewing with staff on a regular basis and at unit meetings the need to utilize checklists with all applications and renewals so all required documentation is on file, verify income and asset requirements, and complete case transfers correctly. Supervisors and/or Lead Workers will also complete case reviews for accuracy. Anticipated Completion Date: October 31, 2024

Finding Number: 2023-004 Finding Title: Eligibility – MAXIS Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Kathryn Herding – Eligibility Supervisor Corey Remiger – Eligibility Supervisor Ashley VanOverbeke- Eligibility Supervisor Corrective Action Planned: The planned corrective action is to continue reminding and reviewing with staff on a regular basis and at unit meetings the need to utilize checklists with all applications and renewals so all required documentation is on file, verify income and asset requirements, and complete case transfers correctly. Supervisors and/or Lead Workers will also complete case reviews for accuracy. Anticipated Completion Date: October 31, 2024

3. 2023-003; Eligibility for Individuals – The PHA will provide ongoing training to housing choice voucher staff to instill compliance in the policy and procedures for Occupancy requirements. The PHA housing choice voucher staff has attended a HOTMA implementation training, as well as an EIV training from recognized housing compliance organizations. The PHA staff will continue to supplement eligibility requirements education from recognized institutions as well as the HUD Exchange site. The PHA housing choice voucher staff will be implementing a checklist for certifications to ensure program compliance. The PHA is committed to the success of the Section 8 HCV Program and will continue to monitor and improve as we transition a new Director of Leased Housing. We are in constant contact with our HUD representatives who continue to provide great support. Planned Implementation Date: Effective Immediately Corrective Action Responsible - Team Effort: Benjamin Gold, Executive Director (978)537-5300 Adam Gautie, Assistant Executive Director Lila Fernandez, Director of Leased Housing Sue Bonney, Director of Finance

RECOMMENDATION: MANAGEMENT OF THE PROJECT SHOULD UPDATE THEIR UNDERSTANDING OF THE INCOME LEVELS ALLOWED AND IMPLEMENT A CONTROL TO HAVE OVERSIGHT ON NEW TENANT QUALIFICATIONS. ACTION TAKEN: HOUSING STAFF AND MANAGEMENT ARE NOW AWARE OF THE "VERY LOW INCOME" LEVEL REQUIREMENT FOR THIS PROPERTY. MOVING FORWARD, ALL TENANTS WILL BE REVIEWED WITH THIS INCOME LEVEL.

GHA Georgetown Housing Authority Correctie Action Plan for the year ended December 31, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of contact person: Alissa Collington Executie Director Corrective Action: We will iplement proper internal control procedures for the Public and Indian Housing Program eligiblity requirements. Proposed Completion Date: Immediately.

U.S. Department of Housing and Urban Development 2023-001 Eligibility - Housing Choice Voucher Program – Assistance Listing No. 14.871 Recommendation: The City should review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with Enterprise income Verification (EIV) eligibility requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHA staff understand that income verification is essential to ensuring that only eligible participants are provided housing assistance benefits. In late 2023 they implemented a new file review procedure where the Community Development Senior Planner reviews all files processed by operational housing staff as a matter of quality control. In addition, the protocol for PHA quality control includes following the Section Eight Management Assessment Program (SEMAP) indicator iv. Accurate verification of family income by ensuring EIV Reports validate family income 120 days of submission of a new admission or reexamination and maintain copies of the report in the tenant file resolving any discrepancies of the family within 60 days of the EIV Report. The one instance of non-compliance found during the 2023 audit occurred prior to the implementation of this new procedure so staff believe that appropriate steps have been taken to address this concern. Name(s) of the contact person(s) responsible for corrective action: Steve Schaer Planned completion date for corrective action plan: The City believes the necessary corrective actions have been taken as of August 2024.

Management’s response/corrective action plan: The Nutrition Director will involve the Support Services Administrative Assistant in the student eligibility process to review and check for accuracy.

Management response/corrective action: The Nutrition Director will update student eligibility when verification requests are not returned. The Director will participate in Department of Education professional development to stay abreast of all requirements of School Nutrition.

Section III - Federal Award Findings and Questioned Costs Finding 2023-002 Name of Contact Person: Anette Ange Executive Director Corrective Action: Management will review the recertification process and plan to monitor recertifications. Proposed Compeltion Date: Immediately.

Management’s Response/Corrective Action Plan: We agree with RKO's recommendation that there are no provisions in the regulations that provide for large scale reclassifications through administrative override. There was some confusion on the part of Maine School Administrative District No. 35 when a communication from the State of Maine was received in November of 2022, that the rate of Free and Reduced children identified at Maine School Administrative District No. 35 had dropped dramatically from the prior year (due to the meals being free to all) and that it may negatively impact our subsidy. At that point, Maine School Administrative District No. 35 asked its building administrators to identify needy families based on conversations they had previously had with parents, from speaking with their guidance counselors, from knowledge they had working with outside community agencies (68 Hours of Hunger) to help identify families potentially in need. From there the lists provided by the building administrators were compared with the families who had already submitted applications, and the directly certified students, and any students who were not identified in either of those cohorts were added to the free and reduced list per administrative override. When RKO arrived in May 2023 to perform interim testing, they let us know that this was not appropriate. At that time, we removed those students from the free and reduced list, and adjusted all of our previously submitted claim forms to account for the change. Maine School Administrative District No. 35 is now clear on the rules with regards to the use of administrative override, and will not use it again in the future.

True North of Columbia's Response and Corrective Action Plan and Planned Completion Date for the Corrective Action Plan: True North was in the process of releasing its contracted HR firm and implementing an in-house process to ensure all required personnel forms (including I-9 forms) were completed appropriately and in a timely manner, when this oversight occurred. Two new personnel had I-9 forms that were completed, but mistakenly filed prior to being appropriately signed. Both were hired on the same day and the i-9s were completed during the brief interim period when new HR protocol was just being established. True North correct this error immediately upon notification by our auditors. The in-hosue protocol was implemented during the same week of their hire and has built-in safe-guards to aviod something like this from happening in the future. First teh Executive Director and/or the new employee's supervisor complete (and ensure the new employee appropriately completed all required employement paperwork) during a formal employee intake meeting. Completed paperwork is reviewed by the Executive Director and/or the employee's supervisor and is then routed to the Director of Finance and Grants who reviews the completed paperwork (again) and completes the E-verification proess, notifies the State of Missouri of the new hire, and enters the new employee's informaiton into the agency's online HR and payroll system. Once all information has been entered appropriately, the paperwork is routed to the Operations Specialist who checks each document against a checklist to ensure completeness and correctness. We believe this process is sufficient to ensure the agency does not miss signing or dating a personal document again. Official Responsible for Ensuring the Corrective Action Plan: Michele Snodderly

2023-001 ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The agency has begun implementing the Yardi software system that will include a landlord portal that will streamline W-9 and direct deposit documentation, while also creating a digital, cloud-based file for each landlord. This will enable the agency to better serve the needs of our landlords while also improving our records retention and filing systems. This function will also improve redundancy for continuity of operations and disaster planning. The new management team also created two (2) Fraud Specialist positions within the Housing Choice Voucher – Assisted Housing department that will audit landlord documentation to mitigate fraud risk. Person Responsible for Correction of Finding: Mr. Justin Brooks, Executive Director Projected Completion Date: December 31, 2024

Maher Duessel Finding Condition: During our review of 60 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted 4 instances where a tenant recertification using the HUD-50058, Family Report (OMB No. 2577-0083) form (which provides eligibility and reporting information) was either not completed, or not completely on a timely basis. We also noted multiple instances where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 that we were able to review and was not provided. This includes items such as rent reasonableness forms, support for income calculation, signed and approved HAP contracts and lease agreements, and signed HUD Form 9886. HACP Management Response/Action Taken: Action Taken: The HACP will continue to monitor and train staff regarding processes and procedures, to include and not limited to the HUD's hierarchy of income verification. In fiscal year (FY) 2023 the HCV Department had a significant turnover in line and managerial staff. The HACP promoted an aggressive hiring plan to attract new talent to fill vacant positions due to the great resignation that the HACP along with other national Agencies continue to experience. In addition, the HACP retained the services of CVR and Associates to train newly hired staff on all aspects of the HCV Program, to include and not limited to recertifications, contracts, interims, and rent increases. The HACP will continue managerial and internal audits by the HACP Internal Compliance Department to reduce the necessity of corrections after the initial submission. The HACP continues to: • Send notices regarding re-certifications 120 days in advance of the due date, • Require Managers to review reports to assure timely submission of re-certifications, • Utilize the Internal Compliance (IC) Department to review and sample files from the Occupancy and the HCV portfolio, • Make corrections when discovered, • Make payment adjustments to participant accounts when errors are discovered and corrected, • The HACP will offer periodic staff training on re-certification, • The HACP offers participants the use of technology to complete paperwork. In 2024, the HCV Department successfully tested the implementation of pre-populated recertification forms. The pre-populated forms allow the participant to confirm or quickly modify family composition and income information. In addition to the time and cost saving factor of the pre-populated forms, the forms are less daunting to complete. The HACP contends It will receive more cooperation from participants in completing the forms because of the ease of use. During FY 2022, the HACP was closed to the public. In July of 2023, the HACP opened a "One Stop Shop" that is open to the public from 8 a.m. to - 4:30 p.m. daily. The One Stop Shop is staffed with three (3) full-time staff members to receive information from participants and landlords to provide timely customer service. In July of 2024 the OSS was equipped with computers for the public to access HACP staff virtually as well as in person. The use of the computers allows staff to interact with participants regarding minor issues without having the staff physically come to the OSS, thus saving time and money for both the external customer and the Agency. The opening of the One Stop Shop has been successful in receiving the public and responding to concerns.

We will implement stricter verification processes and comprehensive staff training to ensure proper documetnation of eligibility. We will also conduct regular audits to prevent such issues in the future and review the questioned costs of to rectify any discrepancies.

Views of Responsible Officials Responsible/Contact Official Paul Barenfus, CLO, and Sylvia Sanchez, CFO Management Response The ERP Grant is a very different grant from previous grants received by the Credit Union. Although management followed the instructions provided on the CDFI website, it was not clear that running the loan through the ERP track for eligibility was only one of several steps. After auditors noted that 4 loans were ineligible, management searched the website to find the second track that the loans had to be qualified through, the Majority-Minority Census. The team has not had to qualify loans like this in the past, and the additional third step for qualification was not understood. Management has since replaced the unqualified loans on the 2023 SEFA with eligible loans. Documented procedures for the ERP Grant have been completed and are being followed. Anticipated Completion Date This item is complete.