Corrective Action Plans

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To Whom it May Concern, Orlando Rehabilitation Group, Inc. has a $2.7 million dollar advance on their balance sheet. These advances were made to unaffiliated not-for-profit healthcare organizations. These advances are to be repaid by these organizations. Orlando Rehabilitation Group, Inc., was unawa...
To Whom it May Concern, Orlando Rehabilitation Group, Inc. has a $2.7 million dollar advance on their balance sheet. These advances were made to unaffiliated not-for-profit healthcare organizations. These advances are to be repaid by these organizations. Orlando Rehabilitation Group, Inc., was unaware that such an advance was not permitted to be made. Kane Financial Services was also unaware. The plan to correct it includes the following action steps:  Seeking approval from HUD for the $2.7M advance.  If the advance is not approved, then the repayment will occur by the organizations over an 18 month period beginning in October 2025. It is understood that such advances will not be made going forward without prior HUD approval. The contact information for oversight of the plan is: Susan Shain Executive Vice President of Finance, Kane Financial Services Email: SShain@kanefs.com Phone: 561-223-4161
To Whom it May Concern, Orlando Rehabilitation Group, Inc. issued $8.0 million in grants during the fiscal year ending March 31, 2026. These grants were made to unaffiliated not-for-profit healthcare organizations. Orlando Rehabilitation Group, Inc., was unaware that these grants were not permitted ...
To Whom it May Concern, Orlando Rehabilitation Group, Inc. issued $8.0 million in grants during the fiscal year ending March 31, 2026. These grants were made to unaffiliated not-for-profit healthcare organizations. Orlando Rehabilitation Group, Inc., was unaware that these grants were not permitted to be made according to the structure of their HUD Mortgage. Kane Financial Services was also unaware. The plan to correct it includes the following action steps:  Seeking approval from HUD for the $8.0M in grants.  If the grant is not approved, then the Orlando Rehabilitation Group, Inc., will attempt to facilitate a re-payment plan over an extended period of time with the recipients of the grants. It is understood that such grants will not be made going forward without prior HUD approval. The contact information for oversight of the plan is: Susan Shain Executive Vice President of Finance, Kane Financial Services Email: SShain@kanefs.com Phone: 561-223-4161
Management has reviewed the audit finding and acknowledges the allegation related to improper administration of the applicant wait list. The former project manager is no longer with the Project, and management responsibilities have been reassigned. Management plans to review wait list procedures, st...
Management has reviewed the audit finding and acknowledges the allegation related to improper administration of the applicant wait list. The former project manager is no longer with the Project, and management responsibilities have been reassigned. Management plans to review wait list procedures, strengthen oversight and documentation requirements, and implement additional controls to ensure applicants are processed in accordance with established policies and applicable program requirements.
Management agrees with the finding and will put processes and controls in place to verify timely deposits in the future. The required deposit of $4,477 was made in July 2025 to the residual receipts account. The corrective response has already been put into place for this fiscal year.
Management agrees with the finding and will put processes and controls in place to verify timely deposits in the future. The required deposit of $4,477 was made in July 2025 to the residual receipts account. The corrective response has already been put into place for this fiscal year.
Management has agreed to review program requirements for fidelity bond coverage and obtain appropriate coverage
Management has agreed to review program requirements for fidelity bond coverage and obtain appropriate coverage
Supportive Housing for Persons with Disabilities CFDA No. 14.181 U.S. Department of Housing and Urban Development (“HUD”) Criteria or Specific Requirement – Special Tests and Provisions: (24 CFR section 891.400(e)) Condition – The Organization is required to establish a separate project fund interes...
Supportive Housing for Persons with Disabilities CFDA No. 14.181 U.S. Department of Housing and Urban Development (“HUD”) Criteria or Specific Requirement – Special Tests and Provisions: (24 CFR section 891.400(e)) Condition – The Organization is required to establish a separate project fund interest bearing account in a federally insured depository. During the fiscal year the project fund was not in an interest-bearing account. Questioned Costs - None Context – During the fiscal year the project fund was not included in a interest bearing account. Effect – The Organization did not properly comply with the special test and provisions requirements. Cause – The Organization’s internal controls did not properly identify the project fund was not maintained in an interest-bearing account. Identification as a repeat finding – Not a repeat finding. Recommendation – The Organization should move the project fund into an interest-bearing account. Views of Responsible Officials and Planned Corrective Actions – During the 2027 fiscal year management will move the project fund to an interest-bearing account and implement procedures to periodically review the project fund and other HUD accounts for compliance with HUD requirements. This corrective action plan will be monitored by Nathan Mordica, Controller and Michael Jones, Director of Accounting, and is anticipated to be completed by the end of fiscal year 2027, or March 31, 2027.
Supportive Housing for Persons with Disabilities CFDA No. 14.181 U.S. Department of Housing and Urban Development (“HUD”) Criteria or Specific Requirement – Special Tests and Provisions: (24 CFR section 891.400(e)) Condition – The Organization is required to establish a separate project fund interes...
Supportive Housing for Persons with Disabilities CFDA No. 14.181 U.S. Department of Housing and Urban Development (“HUD”) Criteria or Specific Requirement – Special Tests and Provisions: (24 CFR section 891.400(e)) Condition – The Organization is required to establish a separate project fund interest bearing account in a federally insured depository. During the fiscal year the project fund was not in an interest-bearing account. Questioned Costs - None Context – During the fiscal year the project fund was not included in a interest bearing account. Effect – The Organization did not properly comply with the special test and provisions requirements. Cause – The Organization’s internal controls did not properly identify the project fund was not maintained in an interest-bearing account. Identification as a repeat finding – Not a repeat finding. Recommendation – The Organization should move the project fund into an interest-bearing account. Views of Responsible Officials and Planned Corrective Actions – During the 2027 fiscal year management will move the project fund to an interest-bearing account and implement procedures to periodically review the project fund and other HUD accounts for compliance with HUD requirements. This corrective action plan will be monitored by Nathan Mordica, Controller and Michael Jones, Director of Accounting, and is anticipated to be completed by the end of fiscal year 2027, or March 31, 2027.
Supportive Housing for Persons with Disabilities CFDA No. 14.181 U.S. Department of Housing and Urban Development (“HUD”) Criteria or Specific Requirement – Special Tests and Provisions: (24 CFR section 891.400(e)) Condition – The Organization is required to establish a separate project fund interes...
Supportive Housing for Persons with Disabilities CFDA No. 14.181 U.S. Department of Housing and Urban Development (“HUD”) Criteria or Specific Requirement – Special Tests and Provisions: (24 CFR section 891.400(e)) Condition – The Organization is required to establish a separate project fund interest bearing account in a federally insured depository. During the fiscal year the project fund was not in an interest-bearing account. Questioned Costs - None Context – During the fiscal year the project fund was not included in a interest bearing account. Effect – The Organization did not properly comply with the special test and provisions requirements. Cause – The Organization’s internal controls did not properly identify the project fund was not maintained in an interest-bearing account. Identification as a repeat finding – Not a repeat finding. Recommendation – The Organization should move the project fund into an interest-bearing account. Views of Responsible Officials and Planned Corrective Actions – During the 2027 fiscal year management will move the project fund to an interest-bearing account and implement procedures to periodically review the project fund and other HUD accounts for compliance with HUD requirements. This corrective action plan will be monitored by Nathan Mordica, Controller and Michael Jones, Director of Accounting, and is anticipated to be completed by the end of fiscal year 2027, or March 31, 2027.
S3800-045 ACTIONS TAKEN OR TO BE TAKEN: Management will endeavor to check files at the site level to ensure that the approval of each certification is retained on file. Management will work with the site managers and the compliance reviewing company to ensure accuracy of certifications, verification...
S3800-045 ACTIONS TAKEN OR TO BE TAKEN: Management will endeavor to check files at the site level to ensure that the approval of each certification is retained on file. Management will work with the site managers and the compliance reviewing company to ensure accuracy of certifications, verifications and rent calculations. The deficiencies found in the files audited will be corrected by Compliance and the site manager and reviewed by the Affordable Housing Director for completion and accuracy.
MANAGEMENT AGREES WITH THE FINDING. THE FUNDS WERE DEPOSITED BACK INTO THE RESTRICTED ACCOUNT.
MANAGEMENT AGREES WITH THE FINDING. THE FUNDS WERE DEPOSITED BACK INTO THE RESTRICTED ACCOUNT.
Corrective Action Plan for Current Year Findings 2026-001 Deposit of Surplus Cash into a Residual Receipts Account Corrective Action Plan No later than 90 days past the end of the fiscal year, we will identify surplus cash in the project funds account and deposit into the residual receipts account. ...
Corrective Action Plan for Current Year Findings 2026-001 Deposit of Surplus Cash into a Residual Receipts Account Corrective Action Plan No later than 90 days past the end of the fiscal year, we will identify surplus cash in the project funds account and deposit into the residual receipts account. Person(s) Responsible: Aaron Franklin Timing for Implementation: Immediate
Finding 2026-002 CAPBM acknowledges the finding regarding inaccuracies identified in several tenant annual recertifications that required corrected HUD-50059-A forms to accurately reflect the Total Tenant Payment (TTP) and HUD subsidy amounts. The errors were the result of calculation and data entry...
Finding 2026-002 CAPBM acknowledges the finding regarding inaccuracies identified in several tenant annual recertifications that required corrected HUD-50059-A forms to accurately reflect the Total Tenant Payment (TTP) and HUD subsidy amounts. The errors were the result of calculation and data entry mistakes during the annual recertification process with past management. Current management is currently reviewing the affected tenant files and will complete any necessary corrections to ensure tenant rent and subsidy calculations are accurate and compliant with HUD requirements. To prevent similar errors in the future, CAPBM has implemented an additional review procedure for all annual recertifications. Once the Compliance Manager completes the annual recertification and prepares the HUD-50059, the Director of Affordable Housing will conduct a secondary review of the certification, including income calculations, asset determinations, applicable deductions, Total Tenant Payment (TTP), and subsidy calculations, prior to final approval and submission. Additionally, staff will continue to receive training on HUD occupancy requirements and annual recertification procedures to ensure compliance with HUD regulations. Management believes these corrective actions will strengthen internal controls and reduce the likelihood of future calculation errors. CAPBM is committed to maintaining accurate tenant certifications and ensuring ongoing compliance with HUD requirements. Completion Date: 12/1/2026 Contact: Jackie Oliveira-Director of Affordable Housing
Finding 2026-004 Plan: Please see below the new process regarding hiring additional staff and turnover at Community Action Partnership Belknap-Merrimack Counties Inc. Due to lack of management, it is understood the importance of having staff training on a regular basis to ensure management and compl...
Finding 2026-004 Plan: Please see below the new process regarding hiring additional staff and turnover at Community Action Partnership Belknap-Merrimack Counties Inc. Due to lack of management, it is understood the importance of having staff training on a regular basis to ensure management and compliance duties can be performed adequately. Community Action Program Belknap-Merrimack Counties Inc. plans to improve the standards of employee training and will be hosting quarterly trainings on employee responsibilities, performance, and areas for improvement. This includes HUD trainings and keeping up to date on any new HUD policies and procedures. We understand the importance of a well-trained staff. We are committed to our performance and adhering to HUD standards while implementing policies to follow for continuous improvement. Please see below the new process regarding filling vacancies and completing management duties in a timely manner: 1. Immediate Focus on Vacancies: We are prioritizing the filling of vacant units by having two staff members complete move ins at the same time. 2. Streamlined Recertification Process: We have updated our process to ensure all tenants are recertified in a timely manner. There has been a new system in place to monitor deadlines and improve efficiency. 3. Staffing and Training: We are actively recruiting and training additional staff to ensure these tasks are handled promptly, preventing future delays. These steps will address the backlog of management duties and ensure that all tasks, such as filling vacancies, submitting budgets, and completing tenant recertifications, are handled in a timely and efficient manner. Completion Date: 11/1/2026 Contact: Jackie Oliveira-Director of Affordable Housing
Finding 2026-003 Action Plan: Management has submitted all corrections to HUD, but the MOR report has not been closed out or finalized as of yearend. See 2026-003. Completion Date: 9/1/2026 Contact: Jackie Oliveira-Director of Affordable Housing
Finding 2026-003 Action Plan: Management has submitted all corrections to HUD, but the MOR report has not been closed out or finalized as of yearend. See 2026-003. Completion Date: 9/1/2026 Contact: Jackie Oliveira-Director of Affordable Housing
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2026-001: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 Condition: One of the tenant files tested did not contain a copy of the tenant's disability verification. Recommendation: The Project should obtain a copy of the tenant's disability verificati...
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2026-001: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 Condition: One of the tenant files tested did not contain a copy of the tenant's disability verification. Recommendation: The Project should obtain a copy of the tenant's disability verification and place it in the tenant file. Action Taken: The Project agrees with the finding. They obtained a copy of the tenant's disability verification during June, 2026. If the Department of Housing and Urban Development has questions regarding this plan, please call Les Russo at 847-424-5601.
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2026-001: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 Condition: The Project's replacement reserve cash balance was underfunded at March 31, 2026. Recommendation: The Project should deposit $30 into the replacement reserve account. Action Taken: ...
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2026-001: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 Condition: The Project's replacement reserve cash balance was underfunded at March 31, 2026. Recommendation: The Project should deposit $30 into the replacement reserve account. Action Taken: The Project agrees with the finding. Management deposited $30 into the replacement reserve account in April 2026. If the Department of Housing and Urban Development has questions regarding this plan, please call Jeanne Overocker at 651-645-7271.
Remaining balance was deposited on April 16, 2026. In the future management will ensure deposits are made timely or obtain HUD appproval permitting delay if there were cash flows issues.
Remaining balance was deposited on April 16, 2026. In the future management will ensure deposits are made timely or obtain HUD appproval permitting delay if there were cash flows issues.
Statement of Condition 2026-001 (Assistance Listing 14.155): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended January 31, 2026. Recommendation: Management should notify the lender of the new reserve for replacement deposit amount and make an ad...
Statement of Condition 2026-001 (Assistance Listing 14.155): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended January 31, 2026. Recommendation: Management should notify the lender of the new reserve for replacement deposit amount and make an additional $565 deposit to the reserve for replacements fund on the next billing. Management Response: Agree. Management has notified the lender of the new required deposit and will make an additional $565 deposit to the reserve for replacements fund on the next billing.
Federal Award Finding 2025-005 - Material Weakness, Material Non-Compliance - Special Tests and Provisions, Surplus Cash and Distributions to Owners or Affiliates Finding: During the fiscal year ended December 31, 2025, project management did not prepare or document a surplus cash calculation in acc...
Federal Award Finding 2025-005 - Material Weakness, Material Non-Compliance - Special Tests and Provisions, Surplus Cash and Distributions to Owners or Affiliates Finding: During the fiscal year ended December 31, 2025, project management did not prepare or document a surplus cash calculation in accordance with HUD requirements, nor did management implement controls to review, approve, or retain documentation supporting the required calculation. Recommendation: Management should establish and implement formal policies and procedures to ensure that surplus cash is independently calculated in accordance with HUD requirements and the applicable HUD Regulatory Agreement. Such procedures should include preparation of a documented surplus cash calculation at each required reporting period using HUD-prescribed criteria; Independent review and approval of the surplus cash calculation by appropriate management personnel or, where applicable, the court-appointed receiver; and retention of supporting documentation sufficient to demonstrate compliance with HUD restrictions on the use and distribution of project funds. Management should coordinate with the court-appointed receiver and HUD to ensure that surplus cash determinations are performed consistently and in compliance with program requirements going forward. Action Taken: Management acknowledges the finding related to the absence of an independently prepared and documented surplus cash calculation. During the fiscal year ended December 31, 2025, the Organization operated in an environment of financial distress, limited staffing resources, and evolving oversight responsibilities, which contributed to informal and undocumented procedures related to surplus cash determinations. As disclosed in the financial statements, the Organization became subject to a court-appointed receivership. Following the appointment of the receiver, responsibility for financial oversight, including compliance with HUD cash flow and surplus cash requirements, has transitioned to the receiver in coordination with HUD. The receiver and management are evaluating HUD requirements related to surplus cash calculation. Responsible Person: Paul Valentine, Receiver Target Completion Date: September 30, 2026 Status: Not started
Federal Award Finding 2025-004 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Cash Receipts Finding: The Organization maintained cash balances in excess of federally insured limits in financial institutions that did not meet HUD's minimum GNMA rating requirements. Recomm...
Federal Award Finding 2025-004 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Cash Receipts Finding: The Organization maintained cash balances in excess of federally insured limits in financial institutions that did not meet HUD's minimum GNMA rating requirements. Recommendation: The Organization should transfer excess cash balances to financial institutions that meet HUD's GNMA rating requirements or otherwise structure its cash holdings to ensure compliance with federal insurance limits and HUD custodial requirements. Action Taken: Nevins moved to this financial institution with the first HUD loan in 2015. This is a local bank that actively supports Nevin's mission in the community. Given Nevins’ current financial struggles, the balance in the bank seldom exceeds the $250,000 threshold. In addition, the receiver established its own account with East West Bank and was in the process of fully transitioning the operating account to East West Bank at the end of the fiscal year. Responsible Person: Paul Valentine, Receiver Target Completion Date: September 30, 2026 Status: Not started
Federal Award Finding 2025-003 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Mortgage Reserve Fund, Equipment Replacement Reserve Fund, and Special Escrows Finding: During the audit period, Henry C. Nevins Home, Inc. did not make all required deposits into the reserve f...
Federal Award Finding 2025-003 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Mortgage Reserve Fund, Equipment Replacement Reserve Fund, and Special Escrows Finding: During the audit period, Henry C. Nevins Home, Inc. did not make all required deposits into the reserve for replacement fund in accordance with the terms of the applicable HUD Regulatory Agreement. The required monthly reserve deposits were either not made or were made in amounts less than those required. Recommendation: We recommend that Henry C. Nevins Home, Inc., in coordination with the court-appointed receiver and HUD, establish procedures to ensure that reserve for replacement deposits are made timely and in accordance with the HUD Regulatory Agreement, or that appropriate waivers or modifications are obtained from HUD where compliance is not currently feasible. Action Taken: Management acknowledges the audit finding related to the failure to make required deposits into the reserve for replacement fund in accordance with the HUD Regulatory Agreement. As disclosed in the notes to the financial statements, during the audit period the Organization was subject to a court-appointed receivership effective September 12, 2025 and is in default under its HUD-insured mortgages. As part of the receivership, control over substantially all cash management and financial decision-making activities was assumed by the court-appointed receiver. Management believes that the conditions giving rise to this finding are directly related to liquidity constraints. Given the complexities of the receivership and regulatory environment, a specific timeline for remediation is not able to be determined. As a result of the loan default, the mortgage was assigned to the U.S. Department of Housing and Urban Development. Since the appointment of the Receiver, responsibility for cash management, financial oversight, and debt service planning has transitioned to the Receiver. The Receiver and the Organization are actively evaluating available options to address the loan default which includes marketing the Organization for a sale. Interim corrective actions include enhanced cashflow monitoring, prioritization of expenses required to continue operations, and ongoing communication with HUD regarding the sale process. Management believes that these actions will address the conditions identified and result in the satisfaction of the HUD loan. Responsible Person: Paul Valentine, Receiver Target Completion Date: September 30, 2026 Status: In process
Federal Award Finding 2025-002 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Mortgage Status and Reserve for Replacements Finding: During the fiscal year, the Organization experienced ongoing financial distress and declining liquidity, which adversely affected its abili...
Federal Award Finding 2025-002 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Mortgage Status and Reserve for Replacements Finding: During the fiscal year, the Organization experienced ongoing financial distress and declining liquidity, which adversely affected its ability to meet financial obligations as they became due. As a result, mortgage payments, including required principal, interest, mortgage insurance premiums, and escrow deposits, were not made in accordance with the loan and regulatory agreements. As of December 31, 2025, delinquent amounts totaled approximately $978 thousand. Recommendation: The Receiver and the Organization should work with HUD to develop and implement a formal workout or resolution plan, including enhanced cash-flow monitoring and debt service planning, to address the loan default and restore compliance with HUD debt service requirements. Action Taken: Management acknowledges the finding related to the failure to make required debt service payments under the HUD Section 232 and Section 241(a) insured mortgage loan agreements. The Organization experienced significant financial distress and constrained liquidity during the fiscal year, which limited its ability to remit required principal, interest, mortgage insurance premium, and escrow payments as they became due. As a result of the loan default, the mortgage was assigned to the U.S. Department of Housing and Urban Development. With the appointment of a Receiver over the Organization, responsibility for cash management, financial oversight, and debt service planning has transitioned to the Receiver. The Receiver is marketing the facility towards a sale in order to satisfy the outstanding loan balance with HUD. Interim corrective actions include enhanced cash-flow monitoring, prioritization of operational suppliers, and ongoing communication with HUD regarding the project's financial condition and sale status. Management believes that these actions will support progress towards stabilization and marketability of the Organization. Responsible Person: Paul Valentine, Receiver Target Completion Date: September 30, 2026 Status: In process
Action Taken: The Management of the Authority agrees with the findings; we will implement improved internal controls to ensure consistent compliance with regulatory requirements. We plan to continue to conduct file audits, standardize electronic document management procedures, expand use of Yardi co...
Action Taken: The Management of the Authority agrees with the findings; we will implement improved internal controls to ensure consistent compliance with regulatory requirements. We plan to continue to conduct file audits, standardize electronic document management procedures, expand use of Yardi compliance tools, and enhance quality control reviews. Strengthened compliance through revised checklists, increased file auditing, targeted staff training, expanded access to procedures and resources, enhanced supervisory oversight, and quarterly monitoring of utility allowance anomalies to improve consistency, accuracy, and adherence to HUD requirements. The HCV Director is the responsible party, and controls will be in place by the end of the December 31, 2026 fiscal year.
Management does not concur. Documentation was provided and no further information was requested by auditors. Expected Implementation Date: None required. Contact Person: Housing Program Director
Management does not concur. Documentation was provided and no further information was requested by auditors. Expected Implementation Date: None required. Contact Person: Housing Program Director
Management does not concur. Documentation was provided during fieldwork. Expected Implementation Date: None required. Contact Person: Housing Program Director
Management does not concur. Documentation was provided during fieldwork. Expected Implementation Date: None required. Contact Person: Housing Program Director
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