Corrective Action Plans

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Section 811 – Capital Advances, Section 811 – Project Rental Assistance Recommendation: The Organization should review its budgeting process to ensure compliance with HUD funding requirements for the reserve for replacement account. Additionally, they should implement regular monitoring to prevent f...
Section 811 – Capital Advances, Section 811 – Project Rental Assistance Recommendation: The Organization should review its budgeting process to ensure compliance with HUD funding requirements for the reserve for replacement account. Additionally, they should implement regular monitoring to prevent future underfunding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will take steps to adjust the budget and ensure the Reserve for Replacement account is adequately funded moving forward. Name(s) of the contact person(s) responsible for corrective action: Phil Pasmanik, Treasurer Planned completion date for corrective action plan: 03/31/2026
Agree with the facts and circumstances described above. Subsequent to year end, the Organization will be opening a separate security deposit account to hold the cash.
Agree with the facts and circumstances described above. Subsequent to year end, the Organization will be opening a separate security deposit account to hold the cash.
Name of auditee: Benjamin Hershey Memorial Convalescent Home HUD auditee identification number: 074-11175 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Jessica Ward Position: Chief Financial Officer Telephone number: 402...
Name of auditee: Benjamin Hershey Memorial Convalescent Home HUD auditee identification number: 074-11175 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Jessica Ward Position: Chief Financial Officer Telephone number: 402-333-7373 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2025-001: Comments on the Finding and Each Recommendation: The Corporation did not provide HUD with a completed annual financial report by March 31, 2026, as required by HUD. Pursuant to the terms of the Regulatory Agreement, within ninety (90) days following the end of each fiscal year, the Corporation shall provide a complete annual financial report based upon an examination of the books and records of the Community prepared in accordance with the requirements of HUD and certified by a Certified Public Accountant or other person acceptable to the Commissioner. As a result, the Corporation was not in compliance with the Regulatory Agreement. The annual financial statements should be issued in a timely manner pursuant to the time frame set forth by HUD. Action(s) taken or planned on the finding: The audit report as of and for the year ended June 30, 2025 has been submitted to HUD. No further action is required.
Repeat finding 2024-005 The City will establish policies, procedures and internal controls to ensure that all subrecipient CAPER reports are reconciled to the IDIS system and submitted to HUD within 90 days of year end.
Repeat finding 2024-005 The City will establish policies, procedures and internal controls to ensure that all subrecipient CAPER reports are reconciled to the IDIS system and submitted to HUD within 90 days of year end.
Special Tests and Provisions – Assistance Listing No. 14.267 Recommendation: We recommend program managers verify that rent reasonableness checklists and certifications are fully completed by HUD staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...
Special Tests and Provisions – Assistance Listing No. 14.267 Recommendation: We recommend program managers verify that rent reasonableness checklists and certifications are fully completed by HUD staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement a supervisory review process requiring program managers to review and formally sign off on rent reasonableness checklists and certifications. Staff will receive refresher training on completion requirements, and management will periodically review files to ensure documentation is complete and properly approved. Name(s) of the contact person(s) responsible for corrective action: Jamie Rotter Planned completion date for corrective action plan: 6/30/2026
United States Department of Housing and Urban Development Good Shepherd Homes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 01, 2025 - December 31, 2025 The findings from the schedule of findings and questioned costs are d...
United States Department of Housing and Urban Development Good Shepherd Homes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 01, 2025 - December 31, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS United States Department of Housing and Urban Development SIGNIFICANT DEFICIENCY 2025-001 Section 223(f) Mortgage Insurance for the Refinance of Existing Multifamily Housing Projects Federal Assistance Listing #14.155 Recommendation: We recommend that management deposit the remaining $770 to the residual receipts account as soon as possible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management deposited the $770 into the residual receipts account on March 12, 2026. Management will ensure moving forward that if the Project has surplus cash, the correct amount will be deposited into the residual receipts account. Name(s) of the contact person(s) responsible for corrective action: Krista Martini, Chief Financial Officer Planned completion date for corrective action plan: March 12, 2026 If the United States Department of Housing and Urban Development has questions regarding this plan, please call Krista Martini at 320-259-3490.
Section 202 - Supportive Housing for the Elderly Mortgage Financing– Assistance Listing No. 14.157 Recommendation: We recommend the funds over the FDIC limit be collateralized or insured, or invested at a bank with an approved HUD accepted rating. Explanation of disagreement with audit finding: Ther...
Section 202 - Supportive Housing for the Elderly Mortgage Financing– Assistance Listing No. 14.157 Recommendation: We recommend the funds over the FDIC limit be collateralized or insured, or invested at a bank with an approved HUD accepted rating. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will monitor funds held at Busey closely and exercise one of the following two options mentioned above. Name(s) of the contact person(s) responsible for corrective action: Jeff Cottingham, Property Manager Planned completion date for corrective action plan: 2026
Audit Finding 2025-001: Per the HUD management fee schedule for owners and agents, the basic rate for management fees is $50 per unit per month (pupm). The Project qualifies for add-on fees of $8 pupm for having 16 to 30 units in property and $3 pupm for being a Sec 811 property with the total cap o...
Audit Finding 2025-001: Per the HUD management fee schedule for owners and agents, the basic rate for management fees is $50 per unit per month (pupm). The Project qualifies for add-on fees of $8 pupm for having 16 to 30 units in property and $3 pupm for being a Sec 811 property with the total cap of management fees at $61 pupm. - Management fees for the year ended December 31, 2025 were paid in excess of the monthly pupm cap. Response: Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $4,183. The excess fees were paid back to the Project on March 20, 2026. - Name and Title of contact person responsible for corrective action: Steve Colella, Making a Difference in Property Management, LLC, Management Agent - 6800 Park Ten Blvd, Ste 184-W, San Antonio, TX 78213
Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. The hazard insurance policy for the project property was in force; however, due to an administrative oversight during policy renewal, the required standard mortgagee clause identi...
Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. The hazard insurance policy for the project property was in force; however, due to an administrative oversight during policy renewal, the required standard mortgagee clause identifying the U.S. Department of Housing and Urban Development (HUD) as mortgagee/loss payee was not reflected in the insurance documentation maintained on file. Corrective Action Plan: Management will work with the insurance broker to obtain the required endorsement naming the U.S. Department of Housing and Urban Development (HUD) as mortgagee/loss payee and will implement a review process to ensure required endorsements are verified upon future policy renewals. Responsible Official: Stacey Ninness, President/CEO Anticipated Completion Date: Management anticipates the policy endorsement will be completed within 60 days of the audit report date.
Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. Management determined that the noncompliance resulted from insufficient internal controls and monitoring procedures related to HUD-specific banking and cash management requirement...
Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. Management determined that the noncompliance resulted from insufficient internal controls and monitoring procedures related to HUD-specific banking and cash management requirements. Specifically, formal controls were not in place to ensure required account characteristics were reviewed and confirmed at account setup. Corrective Action Plan: Management will transition the project funds account to a compliant, interest-bearing account in accordance with HUD requirements. Management will also implement procedures to ensure that Section 811 revenues are deposited only into compliant accounts going forward. Responsible Official: Kimberly Burt, Chief Financial Officer Anticipated Completion Date: Management anticipates the bank account transition will be completed within 60 days of the audit report date.
Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. In prior years, the Single Audit Reporting Package was not submitted to the Federal Audit Clearinghouse due to an internal misunderstanding of management’s responsibility for subm...
Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. In prior years, the Single Audit Reporting Package was not submitted to the Federal Audit Clearinghouse due to an internal misunderstanding of management’s responsibility for submission. With the engagement of a new audit firm, management has clarified these responsibilities. Corrective Action Plan: Management will formally designate responsibility for the timely submission of the Single Audit Reporting Package to a specific member of the finance department. In addition, management will implement a review process to confirm submission and receipt acknowledgment from the Federal Audit Clearinghouse. Responsible Official: Kimberly Burt, Chief Financial Officer Anticipated Completion Date: Management anticipates the filing will be completed within 30 days of the audit report date.
Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management will make the delinquent deposit to the replacement reserve of $1,800 and establish transfers for the monthly deposit amount.
Management will make the delinquent deposit to the replacement reserve of $1,800 and establish transfers for the monthly deposit amount.
Management will deposit the $5,139 shortfall and ensure future deposits are made in a timely manner.
Management will deposit the $5,139 shortfall and ensure future deposits are made in a timely manner.
The delay in the deposit was an oversight. The deposit has been made. Management will review the surplus cash calculation and ensure any required deposits are made within 90 days of year end.
The delay in the deposit was an oversight. The deposit has been made. Management will review the surplus cash calculation and ensure any required deposits are made within 90 days of year end.
Management will deposit the $15,800 shortfall and ensure future deposits are made in a timely manner.
Management will deposit the $15,800 shortfall and ensure future deposits are made in a timely manner.
Finding 2025-001 - Housing Choice Voucher Tenant Files, Eligibility - Noncompliance & Significant Deficiency - Housing Choice Voucher Program - ALN 14.871 Corrective Action Plan: The audit identified that in 3 out of 12 Housing Choice Voucher (HCV) tenant files (25% of the sample), income verificati...
Finding 2025-001 - Housing Choice Voucher Tenant Files, Eligibility - Noncompliance & Significant Deficiency - Housing Choice Voucher Program - ALN 14.871 Corrective Action Plan: The audit identified that in 3 out of 12 Housing Choice Voucher (HCV) tenant files (25% of the sample), income verification requirements were not met. The files contained tenant self-certification only, with no documented attempts to obtain third-party verification as required by HUD regulations and the Agency's Administrative Plan. Corrective Action Steps: 1. Immediate File Review & Correction: Conduct a full review of all active HCV tenant files to identify any additional instances of missing third-party verification. For any file where verification is missing, take corrective action (e.g., obtain required third-party documentation or document attempts if unavailable). Ensure the verification tracking log is being utilized for all verification attempts going forward. 2. Implementation of Stronger Monitoring Controls: Develop a standardized Income Verification Checklist. Executive Director will increase monthly quality-control checks. 3. Staff Training: Provide mandatory training on HUD verification requirements, documentation standards and correct procedures for obtaining and recording third-party verification. 4. Policy Updates: Ensure SOP outlines required verification steps and documentation standards. Anticipated Completion Date: June 30, 2026 Person Responsible: LaToya Brown, Executive Director
A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2025-001 a. Comments on Finding and Each Recommendation Management agrees with the finding and the transition of responsibilities to the new President has been further identified and understood since ste...
A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2025-001 a. Comments on Finding and Each Recommendation Management agrees with the finding and the transition of responsibilities to the new President has been further identified and understood since stepping into the role in November 2024. b. Action(s) Taken or Planned on the Finding Identification and understanding of the reporting deadlines, along with the necessary access to facilitate the transmission of data. Going forward the Data Collection Form will be prepared by the management company and reviewed and approved by the President of the Pelham Corporation prior to submission. This action has been completed during 2025. This will allow the timely submission going forward B. Status of Corrective Actions on Findings Reported in the Prior Audit Schedule of Findings, Questions Costs and Recommendations There were no open findings on the prior audit report.
Finding #2025-001: Comments on the Finding and Each Recommendation: During the year ended December 31, 2025, the Corporation did not make the HUD required total amount of deposits to the reserve for replacements. Management should transfer $19,826 from the operating account to the reserve for replac...
Finding #2025-001: Comments on the Finding and Each Recommendation: During the year ended December 31, 2025, the Corporation did not make the HUD required total amount of deposits to the reserve for replacements. Management should transfer $19,826 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. On February 3, 2026, management transferred $20,258 from the operating account to the reserve for replacements. 35
FINDING 2025-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will address the shortfall in the replacement reserve by making up the missed deposits in the subsequent period alongside the normal required contributions. Action Take...
FINDING 2025-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will address the shortfall in the replacement reserve by making up the missed deposits in the subsequent period alongside the normal required contributions. Action Taken: The Organization will make the necessary required deposits to bring the balance of the reserve for replacement in alignment with requirements of Section 811 Capital Advance Program Regulatory Agreement.
Recommendation: We recommend that management and those charge with governance to improve internal controls to ensure that all required lease agreements are included in tenant files. Response: As of March 2026, to prevent recurrence, management has implemented the following procedural changes: 1. The...
Recommendation: We recommend that management and those charge with governance to improve internal controls to ensure that all required lease agreements are included in tenant files. Response: As of March 2026, to prevent recurrence, management has implemented the following procedural changes: 1. The move in checklist will add a line requiring staff sign-off confirming that all executed lease documents are placed in the tenant file prior to move-in or lease renewal. 2. Property management staff will conduct monthly file reviews to verify that all move in’s required documentation, including signed lease agreements, is present and current in each tenant file. 3. The Regional Manager will conduct quarterly file audits to ensure ongoing compliance and will report findings to management.
Project Legal Name: Casa Otonal Housing Corporation HUD Project No.: 017-EH073 Audit Firm: CohnReznick LLP Period covered by the audit: 06/30/2025 Corrective Action Plan prepared by: Name: Sabine Cox Position: Comptroller/Director of Finance Telephone Number: (203) 230-4809 The following is a recomm...
Project Legal Name: Casa Otonal Housing Corporation HUD Project No.: 017-EH073 Audit Firm: CohnReznick LLP Period covered by the audit: 06/30/2025 Corrective Action Plan prepared by: Name: Sabine Cox Position: Comptroller/Director of Finance Telephone Number: (203) 230-4809 The following is a recommended format to be followed by the auditee for preparing a correction action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendation Finding 2025-002 a. Comments on the Finding and Each Recommendation In connection with our lease file review, we noted the following deficiencies: For one out of one new tenant tested, the Project did not maintain evidence in the lease file that the Enterprise Income Verification ("EIV") system was utilized within 90 days of the tenant's initial certification date of April 1, 2025. For two out of ten existing tenants tested, the Project did not maintain evidence in the lease files that the EIV system was utilized within 120 days of the tenant's annual certification dates of August 1, 2024. For one out of one new tenant tested, the Project did not maintain evidence in the lease file that a move-in inspection was performed. b. Action(s) Taken or Planned on the Finding During the transition of a new site from a prior management company, the Property Manager, Regional Manager, and Director of Compliance must collaborate closely to conduct a thorough review of all tenant files. This coordinated effort helps ensure accuracy, identify any discrepancies early, and supports more effective and efficient use of the EIV system for tenant file testing.
HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1....
HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1. StaffingA new rental housing inspector has been hired. The position has been converted from part-time to full-time, allowingadequate time for the inspector to monitor inspection timelines, complete required inspections and reinspections, andensure timely reporting and compliance with program requirements. 2. Training and CertificationStaff completed training on new inspection guidelines and protocols in March 2024. Certification in both HQS andNSPIRE inspection standards are currently underway for the new inspector. This training will ensure the inspector isfully knowledgeable of federal inspection requirements, documentation standards, and required compliancetimelines. 3. Improved Inspection Monitoring and DocumentationThe EDA has strengthen internal procedures for scheduling and tracking inspections and reinspections within theinspection software to ensure all failed inspections are documented and scheduled for reinspection within therequired timeframe. 4. Transition to Electronic Inspection ReportingThe EDA requires the use of iPad-based electronic inspections rather than paper inspection forms. This changeprovides real-time documentation, ensure inspections are entered directly into the tracking system, and reduce therisk of inspections being completed but not logged. 5.Compliance Notification and Payment ControlsA formal procedure has been established to notify appropriate staff in the event of inspection non-compliance. Underthis procedure, Housing Assistance Payments (HAP) will be held until compliance is achieved or the tenant has movedfrom the unit, consistent with program regulations. Management believes these corrective actions will strengthen internal controls over the inspection process, improve documentation and tracking, and ensure compliance with HUD Housing Quality Standards requirements moving forward. The EDA will continue to monitor inspection activities to maintain safe and habitable housing conditions for program participants. Official Responsible for Ensuring CAP: Nicole Cunningham, Housing Coordinator, is the official responsible for ensuring corrective action.
2025-001 HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective ac...
2025-001 HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1. Staffing A new rental housing inspector has been hired. The position has been converted from part-time to full-time, allowing adequate time for the inspector to monitor inspection timelines, complete required inspections and reinspections, and ensure timely reporting and compliance with program requirements. 2. Training and Certification Staff completed training on new inspection guidelines and protocols in March 2024. Certification in both HQS and NSPIRE inspection standards are currently underway for the new inspector. This training will ensure the inspector is fully knowledgeable of federal inspection requirements, documentation standards, and required compliance timelines. 3. Improved Inspection Monitoring and Documentation The EDA has strengthened internal procedures for scheduling and tracking inspections and reinspections within the inspection software to ensure all failed inspections are documented and scheduled for reinspection within the required timeframe. 4. Transition to Electronic Inspection Reporting The EDA requires the use of iPad-based electronic inspections rather than paper inspection forms. This change provides real-time documentation, ensures inspections are entered directly into the tracking system, and reduce the risk of inspections being completed but not logged. 5. Compliance Notification and Payment Controls A formal procedure has been established to notify appropriate staff in the event of inspection non-compliance. Under this procedure, Housing Assistance Payments (HAP) will be held until compliance is achieved or the tenant has moved from the unit, consistent with program regulations. Management believes these corrective actions will strengthen internal controls over the inspection process, improve documentation and tracking, and ensure compliance with HUD Housing Quality Standards requirements moving forward. The EDA will continue to monitor inspection activities to maintain safe and habitable housing conditions for program participants. Official Responsible for Ensuring CAP: Nicole Cunningham, Housing Coordinator, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding. Nicole Cunningham Housing Coordinator
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