Corrective Action Plans

Name of auditee: Town of Plattsburgh Housing Development Fund Company, Inc. TIN: 014-EE068 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2025 CAP prepared by: David Kimmel President Two Plus Four Property Management Co,. Inc. (315) 437-2178 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations Finding 2025-001 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation, please see below for action taken. (b) Action taken: Management has deposited the underfunded amount of $21,250 into the residual account on February 19, 2026.

Management concurs with the finding and notes that the Town is actively working to complete the integration of the payroll module within the new accounting platform. Management has arranged system training to ensure staff understand the payroll and reconciliation functions and can effectively utilize the module once configuration is complete. In the interim, the Town will continue to prepare timely reconciliations and record necessary adjusting entries to ensure accurate financial reporting.

Audit Finding 2025-001 - Funds were withdrawn from the reserve for replacement account to cover an operational shortfall and were withdrawn without HUD approval. Response: Management will refund the replacement reserve for the withdrawn funds as soon as excess operating cash becomes available. - Name and Title of contact person responsible for corrective action: Linda Holder - Executive Director – Houston Housing Management Corporation - Fulton Gardens II - PO Box 1819 - Houston, TX 77002 - 713-526-9470

Approved expenditures of federal awards were not for the Project. Recommendation: CLA recommends enforcing control procedures over expenditures of federal awards. CLA also recommends performing an additional year-end review of accounts payable to confirm that expenditures are appropriately classified and allocated to the correct sites. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will recommunicate their policies and ensure proper controls over expenditures of federal awards are enforced. Name of the contact person responsible for corrective action: Sabine Cox, EHM Comptroller Planned completion date for corrective action plan: September 30, 2026

Eligibility for a resident was not supported. Recommendation: CLA recommends enforcing control procedures over resident eligibility. Explanation of disagreement with audit finding: Management identifies that the resident move-in was conducted by the prior management company. Action planned in response to finding: During fiscal 2026, the management company will recommunicate their policies and ensure proper controls over eligibility are enforced. Name of the contact person responsible for corrective action: Sabine Cox, EHM Comptroller Planned completion date for corrective action plan: September 30, 2026

An ineligible resident was residing at the property. Recommendation: CLA recommends enforcing control procedures over resident eligibility. Explanation of disagreement with audit finding: Management identifies that the resident move-in was conducted by the prior management company. Action planned in response to finding: During fiscal 2026, the management company will recommunicate their policies and ensure proper controls over eligibility are enforced. Name of the contact person responsible for corrective action: Sabine Cox, EHM Comptroller Planned completion date for corrective action plan: September 30, 2026

Reserve for replacement funds and project funds were not maintained in interest bearing bank accounts. Recommendation: CLA Recommends withdrawing the reserve for replacement funds and project funds and depositing the funds into interest bearing accounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: During fiscal 2026, the funds were deposited into interest bearing accounts. Name of the contact person responsible for corrective action: Sabine Cox, EHM Comptroller Planned completion date for corrective action plan: December 31, 2025

Deposits required by HUD were not made in full during fiscal year 2025 to the reserve fund. Recommendation: CLA Recommends the Project make all fiscal year 2025 deposits as soon as funds allow. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: During fiscal 2026, the missing deposits were made. Name of the contact person responsible for corrective action: Sabine Cox, EHM Comptroller Planned completion date for corrective action plan: December 31, 2025

Finding Reference Number: 2025-001 Federal Program: Supportive Housing for the Elderly-Section 202 (Assistance Listing No. 14.157) Federal Award Agency: U.S. Department of Housing and Urban Development Name of contact person: Shannon McCandlish, Controller Manor Management Services of Alaska Corrective Action: A tenant file containing three income sources were not supported by third party verification, as required by HUD. The on site manager understands and will be diligent in using internal checklists that would have identified the missing income verification documentation. Date of Planned Corrective Action : January 06, 2026

The Owner has ended the additional principal payments being paid to the mortgage company, effective August 2025. The Owner is also in the process of requesting authorization from the US Department of HUD to disburse $260,000 from residual receipts (the sum of the additional principal payments made on the mortgage from August 2024 - August 2025, without previous HUD approval) to reimburse the operating account for these disbursements.

Comments on the Finding and Each Recommendation The Property received a NSPIRE inspection dated August 1, 2024. The inspection resulted in a score of 59 (out of a possible 100). Scores below 60 are referred to the Departmental Enforcement Center. Management must maintain the Property in decent, safe, and sanitary condition and good repair. Management must respond to HUD in three days of receiving the inspection report and confirm all lifethreatening deficiencies have been corrected. Action(s) taken or planned on the finding Management and the Board of Directors concur with the finding and the auditor's recommendations. Management has responded to HUD in regard to this inspection report and on July 8, 2025 another inspection was conducted that resulted in a final score of 95 (out of a possible 100).

Finding 2025-001 - Housing Choice Voucher Tenant Files - Eligibility - Rent Calculations Noncompliance & Material Weakness Section 8 Housing Choice Voucher Program -ALNs #14.871 and #14.EHV Corrective Action Plan: Action Steps: • Separate responsibilities into two functions: eligibility/verification and rent calculation, assigning verification tasks to new staff and rent calculations to experienced staff. • Strengthen monitoring and evaluation of HCVP files to ensure accurate income projections and rent calculations. The Compliance Officer will conduct individual reviews of audit findings and resolve discrepancies. • Engage an external contractor to perform biannual audits on 10% of files. Findings will inform targeted staff training. • Implement monthly peer audits among Program Assistants to identify and correct errors collaboratively, fostering continuous learning. • Conduct monthly training sessions led by the Program Director to address recent discrepancies and promote team development. • Enforce disciplinary measures for underperformance: employees failing to achieve an 80% audit success rate for three consecutive months will enter a 90-day improvement plan. Person(s) Responsible: Shanae Golliday-Anderson, Program Director Pam Jackson, Deputy Director Anticipated Completion Date: June 30, 2026

Finding 2025-002 - Low Rent Public Housing Tenant Files - Eligibility - Rent Calculations Noncompliance & Significant Deficiency Low Rent Public Housing - ALN #14.850 Corrective Action Plan: Action Steps: • SCCHA will hire an industry consultant to evaluate its internal processes related to eligibility and tenant rent calculations, with a focus on improving the accuracy of adjusted annual income computations. • An external contractor will conduct biannual audits on 10% of files, with results guiding targeted staff training initiatives. • The Compliance & Integrity Coordinator will review audited files and hold individual meetings with team members to address errors and clarify relevant procedures and policies. • Monthly peer-to-peer audits will be implemented, along with staff meetings to collectively analyze identify errors, fostering ongoing training and staff engagement. • Enforce disciplinary measures for underperformance: employees failing to achieve an 80% audit success rate for three consecutive months will enter a 90-day improvement plan. Person(s) Responsible: Meisha Kerby, Program Director Pam Jackson, Deputy Director Anticipated Completion Date: June 30, 2026

Management has addressed the issue by recertifying the tenant and does not expect late recertifications or income verification to occur again.

On November 4, 2025, UK HealthCare (UKHC) Information Technology implemented a system configuration change within Epic related to the NFV Sliding Scale settings. This change restricts the application of Federal Poverty Level (FPL) discounts to accounts with a status of “Approved for Financial Assistance,” thereby preventing discounts from being applied to accounts that have not been formally approved. In addition, on December 8, 2025, a new status option— “Did Not Apply for FA”—was added to the status field within the FPL table in Epic. This option is to be selected when patients do not apply for financial assistance, ensuring that status fields are never left incomplete or blank. NFVCHC staff were notified of this update and instructed to consistently complete this step. Planned Process Improvements:NFVCH leadership will conduct a comprehensive review of the NFV and JB clinic policies and procedures related to Financial Assistance Program (FAP) eligibility determination and reevaluation. This review will ensure that: FAP documentation does not include overlapping coverage periods Effective and termination dates are properly validated Internal processes align with system requirements and safeguard against data inconsistencies Ongoing Monitoring / Sustainability Plan: To strengthen oversight and ensure longterm control effectiveness, UKHC Enterprise Revenue Cycle will incorporate into its monthly audit procedures the following reviews: A report identifying accounts with blank or incomplete status entries on the Federal Poverty Level table A review of overlapping FPL coverage dates Monitoring for patients who have both UK and NFV Charity Care, ensuring the correct NFV FPL table is applied for NFVCH accounts This continuous monitoring will ensure system controls operate as designed and that corrective actions remain effective over time. Responsible Party: Larry Quillen – Executive Director, NFVCH Anne Wray - ERC Revenue Assurance Director/UKHC Target Completion Date: Completed on November 4, 2025, with additional enhancements on December 9, 2025

The Village has discussed the finding but must consider the cost of adequate segregation of duties when determining the use of tax money.

February 25, 2026 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2025 AUDITOR FINDING: 2025-002 – AL# 14.181 Supportive Housing for Persons with Disabilities (Section 811) Area: Eligibility In accordance with 24 CFR section 891.410, section 5.230, and OMB No. 2502-0204, owner shall re-examine tenant eligibility at least every 12 months with respect to family income, composition and is required to obtain signed consent forms from assistance applicants. In accordance with HUD Multifamily Occupancy Handbook, Chapter 7, annual certification should be completed and submitted through TRACS within 15 months from previous year’s anniversary date. Based on testing performed recertifications did not occur within the required time period. It is recommended to add monitoring controls to help ensure recertifications are completed in accordance with 24 CFR section 891-410, section 5.230, and OMB No. 2502-0204. CLIENT PLANNED ACTION: (1) Annual recertification report will be reviewed monthly with ComCap Management to ensure timely completion of all recertifications. Demands will be given to tenants if recertifications are not completed within 60 days of initial notification. (2) Monthly dashboards will continue to be produced and reviewed with ComCap Management. The monthly dashboards include annual recertifications, occupancy/vacancy, and move-in/move-outs. CLIENT RESPONSIBLE PARTY: Darla Goddard, Director of Real Estate COMPLETION DATE: 01/01/2026

February 25, 2026 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2025 AUDITOR FINDING: 2025-002 – AL# 14.157 Supportive Housing for the Elderly (Section 202) Area: Eligibility In accordance with 24 CFR section 891.410, section 5.230, and OMB No. 2502-0204, owner shall re-examine tenant eligibility at least every 12 months with respect to family income, composition and is required to obtain signed consent forms from assistance applicants. In accordance with HUD Multifamily Occupancy Handbook, Chapter 7, annual certification should be completed and submitted through TRACS within 15 months from previous year’s anniversary date. Based on testing performed recertifications did not occur within the required time period. It is recommended to add monitoring controls to help ensure recertifications are completed in accordance with 24 CFR section 891-410, section 5.230, and OMB No. 2502-0204. CLIENT PLANNED ACTION: (1) Annual recertification report will be reviewed monthly with ComCap Management to ensure timely completion of all recertifications. Demands will be given to tenants if recertifications are not completed within 60 days of initial notification. (2) Monthly dashboards will continue to be produced and reviewed with ComCap Management. The monthly dashboards include annual recertifications, occupancy/vacancy, and move-in/move-outs. CLIENT RESPONSIBLE PARTY: Darla Goddard, Director of Real Estate COMPLETION DATE: 01/01/2026

Criteria: Neither the PHA nor any of its contractors or subcontractors may enter into any contract or arrangement in connection with the HCV program in which any of the following classes of persons has any interest, direct or indirect, during tenure or for one year thereafter (2) Any employee of the PA, or any contractor, subcontractor or agent of the PHA, who formulates policy or who influences decisions with respect to the programs (24 CFR sections 982.161). Condition: During the audit, it was noted that multiple (3) participants of the HCV program were either employees or relatives of employees. Context: According to 24 CFR 982.161, any employee who exercise authority over the PHA cannot receive benefits. However, past OIG action has issued findings to Public Housing Authority entitles when any employee and immediate family member receives benefits as unallowable cost. The OIG's concern seems to be that the tenant may have received special treatment at admission or is currently receiving special treatment related to rent calculation, unit inspections, etc. The OIG regarded the HAP costs as ineligible and recommended that the PHA re-pay the funds. Cause: The non-compliance appears to stem from ambiguity in the Housing Authority's policy relating to Conflict of Interest. Effect: The Conflict of Interest undermines the community's trust with the Housing Choice Vouchers Program. It also represents a risk of improper use of federal funds and can impact the credibility and effectiveness of the program. Recommendations: Update the Authority's Conflict of Interest policy and implement more stringent procedures for monitoring Conflict of Interest. Questioned Costs: The exact monetary impact needs further investigation to determine the amount of HAP that should have been unallowable for the period of non-compliance. Management Views: Management Agrees - see Corrective Action Plan ecommended in the Independent Auditor's Report as it pertains to internal controls over our HCV program. Please note, our agency is in the midst of transitioning between executive directors - therefore, we request additional time so that our personnel policy can be gone through by our new executive director, after which such individual is hired, reviewed by our agency attorney, and then approved by our board of commissioners. This process will take additional time to complete. Our agency will review its internal control over annual policy reviews to ensure that all policies, not just our "Coriflict of Interest Policy", are adhered to. Below is our current HACPFC Coriflict of Interest Policy, followed by our proposed amended Coriflict of Interest Policy. You are to avoid placing yourself in a position that may create or lead to a conflict of interest or the appearance of one. A conflict of interest exists when there is evidence of or the appearance that a commissioner's/employee's personal interests have influenced or may influence HACPFC transactions or operations, or that these interests take precedence over the interests, goals, and/or mission of HACPFC. Or a situation where a benefit or advantage of an economic or tangible nature that might inure to an HACPFC employee, creates a potential bias or loss of independence of judgment in the performance of that employee's or Commissioner's duties. For the purpose of this policy, a relative is defined as a spouse/significant other, parent, sibling, child, grandchild, grandparent, parent-in-law, brother-in-law, sister-in-law, daughter-in-law, son in-law, aunt, uncle, niece, nephew, cousin, stepparent, or stepchild. An actual, potential, or perceived conflict of interest occurs when an employee, contractor, agent, officer, or member of the Board of Commissioners is in a position to influence a decision that may result in a personal gain for that employee or for a relative as a result of the HACPFC's business dealings. Employees need to refrain from conducting business that presents a conflict of interest as described above. No "presumption of guilt" is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to the Executive Director of HACPFC as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties. Employees should avoid any situations which involves or may involve a conflict between their personal interest and the interest in HACPFC or any other arrangement or circumstances including family or other personal relationships, which might dissuade the employees from acting in the best interest of HACPFC. All employees will be required to sign the Employee Conflict of Interest Disclosure Form as part of employment. You are also prohibited from having any personal interest, directly or indirectly, in any transaction with HACPFC or from otherwise using your position to secure special privileges for yourself or others. You may not directly or indirectly give or receive any compensation, gift, reward or gratuity from any source other than HACPFC for any matter or service which relates directly or indirectly in any way to your work for HACPFC. You also may not accept or engage in any business, personal or professional activity that might be reasonably expected to require or induce you to disclose confidential or proprietary information regarding HACPFC or its applicants, tenants or program participants. If you have any questions regarding whether a conflict may exist, you should ask the Executive Director before engaging in the conduct at issue. Proposed Personnel Policv Change/ added language in red: Gifts: Conflict of Interest: You are to avoid placing yourself in a position that may create or lead to a conflict of interest or the appearance of one. A conflict of interest generally exists when there is evidence of or the appearance that a commissioner's/employee's personal interests have influenced or may influence HACPFC transactions or operations, or that these interests take precedence over the interests, goals, and/or mission of HACPFC.

Criteria: HUD requires that all units under the Housing Choice Vouchers Program meet specific Housing Quality Standards (HQS). In cases of failed inspections, timely re-inspections are mandatory, and if compliance is not achieved, abatement of Housing Assistance Payments (HAP) or voucher cancellation is required Condition: During the audit, it was noted that in one (1) instance a unit that failed its HQS inspection (life­threatening failure) did not undergo a subsequent reinspection within the proper 24-hour time period: Consequently, the required abatement of HAP or cancellation of the housing voucher was not executed. Context: This finding represents an issue within the Housing Voucher Cluster program, as it was identified in one (1) files tested out of a sample of two (2) failed inspections. It highlights a need for more rigorous enforcement and monitoring ofHQS compliance Cause: The non-compliance appears to stem from oversight or procedural lapses in the enforcement of HQS within the Housing Voucher Cluster program. This may be due to inadequate training, monitoring, or failure to adhere to established protocols Effect: This non-compliance undermines the integrity of the Housing Choice Vouchers Program and may lead to tenants living in substandard conditions. It also represents a risk of improper use of federal funds and can impact the credibility and effectiveness of the program. Recommendation: Implement more stringent procedures for monitoring HQS compliance, including timely reinspection and enforcement of HAP abatement or voucher cancellation. Enhance training for staff involved in the HQS process to ensure a thorough understanding of compliance requirements. Establish a system of regular audits to identify and rectify lapses in HQS enforcement promptly. Questioned CostsL The exact monetary impact needs further investigation to determine the amount of HAP that should have been abated for the period of non-compliance. A. HACPFC Corrective Actio11 P/all: Our staff who conduct the HCV inspections are certified in both HQS and NSP IRE Standards. This failure to re-inspect this life-threatening finding within 24 hours after the discovery was an obvious oversight by our inspection staff as they are all aware of this requirement. However, the Agency will review internal controls related to training and will ensure that all inspectors are provided with additional training to reinforce compliance with the 24-hour re-inspection requirement and follow up with the landlord to verify compliance and penalty if required. The HA CP FC will also continue to review process over the auditing of tenant files to ensure that there are no lapses in the compliance requirements. B. A1tticipated Completion Date: This is already in progress.

PBRA/MOD Vacant Units Recommendation: The Commission should implement processes to ensure that vacancies are appropriately accounted for in the HUD-52670's, within HAP registers, and within other relevant records. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies site staff will retrain staff on the move-out / deposit accounting process and the required month end closeout process no later than February 28, 2026. Regional Managers will review and confirm completion of end-of-month checklists to verify that all required monthly tasks have been performed, thereby reducing the risk of this exception occurring in the future. Name(s} of the contact person(s} responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately corrected this discrepancy and will implement the remaining corrections by February 28, 2026.

PBRA/MOD Housing Quality Standards Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences and that related inspections are performed on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, policy has been updated to reflect the requirement to complete within 365 days of the previous inspection. Name(s} of the contact person(s} responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action as outlined above.

PBRA/MOD Eligibility Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, will retrain all site staff on acceptable and complete forms of income, asset, and expense documentation for initial certifications and the annual recertification process no later than February 15, 2026. Pratum's Compliance team will continue to review each new move-in file from eligibility determination through lease execution to ensure ongoing programmatic compliance. In addition, the Compliance team will complete supplemental training by February 15, 2026, to reinforce proper use of the internal control's checklist, which is required to be attached to all submitted move-in files. Name(s) of the contact person(s) responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action outlined above.

HCVP Housing Quality Standards and Enforcement Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences, that related inspections are performed on a timely basis, and ensure standards related to abatement of housing assistance payments are being followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC will collaborate with the software vendor, IT department, and a third-party consultant to remediate system deficiencies affecting inspection tracking and compliance. This will include developing and implementing quality control reports to identify units with failed or overdue inspections, restoring accurate inspection date tracking, and strengthening monitoring processes to ensure timely inspections, abatements, and enforcement in accordance with program regulations. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division. Planned completion date for corrective action plan: HRD has initiated implementation of the corrective action plan by engaging the IT department and the software vendor to assess system deficiencies impacting inspection tracking, abatement enforcement, and regulatory compliance. Initial meetings have focused on identifying root causes, reviewing data integrity issues, and evaluating potential system enhancements and reporting solutions to improve monitoring and oversight. HOC will continue coordinated efforts with IT, the software vendor, and a third-party consultant to design, test, and implement corrective measures. Full implementation and stabilization of the identified solutions is anticipated to be completed by December 2026.

Jeff Cottingham, Management agent, and Father Elia, sponsor of the project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.