Corrective Action Plans

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Failure to Return Residual Receipts to HUD Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus ca...
Failure to Return Residual Receipts to HUD Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus cash to the residual receipts account. Proposed Completion Date: June 30, 2025
Failure to deposit Surplus Cash in the Residual Receipts accounts Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus ca...
Failure to deposit Surplus Cash in the Residual Receipts accounts Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus cash to the residual receipts account. Proposed Completion Date: June 30, 2025
Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies a...
Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies and procedures, as necessary, to address all current regulatory requirements. The Department’s multifamily monitoring for all projects in the HOME period of affordability will be completed prior to June 30, 2025. As part of the monitoring process, the Department will document all records requiring annual or semi-annual oversight and review for compliance with HOME requirements. Should the monitoring result in any findings requiring corrective action, the Department will ensure all findings are addressed by September 30, 2025. Anticipated Completion Date May 2025 Contact Information of Responsible Official Name: Augustine Ramirez Title: Division Manager, DPWP Community Development Division Phone: 559-600-4266
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. The Supplemental Nutrition and Assistance Program office (“SNAPO”) has addressed these issues within the division to make efforts to improve our payment accuracy which include electronic cas...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. The Supplemental Nutrition and Assistance Program office (“SNAPO”) has addressed these issues within the division to make efforts to improve our payment accuracy which include electronic case documentation and data entry accuracy. Corrective Action Taken or Planned: SNAPO has worked with Statewide Branch Administration (“SBA”) to address these types of deficiencies as Hawaii is presently under corrective action for payment error rates. A mandatory refresher training to address budgeting and household composition had been implemented starting in January 2024 to improve core eligibility fundamentals such as budgeting. SNAPO will share the findings provided from this audit to include this as a part of our broader corrective strategy being implemented across the division through the partnership of SNAPO and SBA to address root causes for these errors. Regular case reviews are planned on being conducted to address areas of concern and will be addressed accordingly through supervisory channels to improve payment accuracy and case documentation. Completion Date: This is an on going activity and started for planning purposes from December 2024. SNAPO and Statewide Branch will be implementing the inaugural training/review with the Quality Maintenance and their review of the Quality Control (“QC”) Reports from Audit, Quality Control and Research Office (“AQCRO”). The Quality Control office conduct monthly reviews of all SNAP cases to provide to USDA Food and Nutrition Services on payment errors and will notate administrative deficiencies such as incorrect data entry for both income and deduction amounts used to calculate benefits when determining SNAP eligibility. The regular review cadence is monthly for the QC reports with a tentative quarterly discussion on findings to determine further assistance that can be provided through a collaboration between SNAPO and Staff Development office with policy guidance and staff training. Responding Official(s): Ginet Hayes, Benefit, Employment, and Support Services Division Supplemental Nutrition and Assistance Program Administrator
Finding 540343 (2024-001)
Significant Deficiency 2024
Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact t...
Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact that the FSRS.gov system has since been retired and integrated into the SAM.gov system acknowledges the need for reducing duplicate recording in favor of an integrated system. Staff’s understanding of the process was in line with available guidance currently still posted on HUD’s website (https://www.hud.gov/sites/dfiles/CPD/documents/CPD_FSRS_Learning_Session_Final_8.26.21.pdf). The City of San Diego did not receive notification of the FSRS deadline from HUD for Fiscal Year (FY) 2024. With regard to the dates entered in the FSRS.gov system, the agreements’ effective dates cover the entire fiscal year, and the awards were approved by our City Council to be in effect for the full fiscal year. Hence, staff entered the date July 1, 2023. Management accepts that going forward, dates should be entered based on the date the agreements are fully executed. Management agrees to include specific FFATA training and procedures in all CDBG manuals and checklists including procedures for compliance, if and when federal agency communication is late or lacking. Implementation Date: The conditions described above have already been corrected. FFATA training and procedures will be implemented within 30 days. Contact: Michele Marano Assistant Deputy Director, Community Development Economic Development Department City of San Diego Email: mmarano@sandiego.gov Phone: 619.236.6381
Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Res...
Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Response PINC management acknowledges that some funds were inadvertently excluded from the Schedule of Expenditures of Federal Awards due to a combination of a recent CFO leadership transition and an outdated accounting system. However, these issues were not a result of fraud or misuse of funds, and the discrepancies were quickly addressed without any negative impact on the financial statements or audit timeline. The company is actively working to implement a new accounting system with an improved grants module to prevent similar issues in the future. These proactive steps reflect our commitment to compliance, financial accuracy, and continuous improvement in reporting processes. Contact Person Responsible for Corrective Action: Joshua Pevarnik, VP & CFO Anticipated Completion Date: Ongoing and by 6/30/2025
A. Comments on Finding and Recommendations Comments: It is important to note that at no time did L. Hayes & Associates, Inc. (LHA), Managing Agent, use project funds for unrelated costs. This finding No. 2024-001 refers specifically to fraudulent check charges that were posted to the Hughes operatin...
A. Comments on Finding and Recommendations Comments: It is important to note that at no time did L. Hayes & Associates, Inc. (LHA), Managing Agent, use project funds for unrelated costs. This finding No. 2024-001 refers specifically to fraudulent check charges that were posted to the Hughes operating account in March 2024 by an unknown person. There was a total of three (3) checks written by the same person. This person is unknown to us and did not have access to our check stock nor our office. Therefore, it appears that the perpetrator used some type of machine to reproduce copies of our checks and the signature of Ms. Voundy-Thomas, Operations Manager. Recommendations: Based on the recommendation of our auditor, our office contacted the Maryland Banking Commission to report and pursue reimbursement of the fraudulent charges deducted from the Hughes Neighborhood Housing operating bank account and they referred us to contact the Office of the Comptroller of Currency. Our auditor also suggested that we discuss potential solutions with our HUD Account Executive. B. Actions Taken or Planned Actions Taken: Upon reconciliation of the Project’s March 2024 bank accounts and the discovery of the fraudulent charges, Ms. Voundy, Thomas immediately contacted Wells Fargo’s Fraud Claims Department to report our findings, request reimbursement of the charges, and to place an alert of the account. In addition, Ms. Voundy-Thomas and Mr. Merrick, Hughes, BOD President, visited a Wells Fargo branch to discuss this matter directly with an Account Representative. Unfortunately, the bank denied our request for reimbursement of the fraudulent charges stating that our claim was not processed within 30-days of the posted charges. Actions Planned: Per the guidance from the Maryland Banking Commission, our office has contacted the Office of the Comptroller of Currency to further pursue reimbursement of the fraudulent charges. Also, upon completion and submission of the above-mentioned audit, we plan to pursue any further actions recommended by our HUD Account Executive regarding this finding. Status of Corrective Action on Prior Findings No prior findings were noted.
View Audit 350209 Questioned Costs: $1
Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of ...
Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of the program. UMMC will make efforts to ensure that all practices and policies are clearly documented and evaluated periodically. Estimated Completion Date: June 30, 2025
S3800-010: Finding Reference Number 2024-003 S3800-030: Statement of Condition: Management did not make all of the required deposits to the replacement reserve at June 30, 2024. The mortgage company billed $2,398 per month with the monthly mortgage statement which was the required deposit that we...
S3800-010: Finding Reference Number 2024-003 S3800-030: Statement of Condition: Management did not make all of the required deposits to the replacement reserve at June 30, 2024. The mortgage company billed $2,398 per month with the monthly mortgage statement which was the required deposit that went into effect on December 1, 2019. That deposit was increased by HUD each year thereafter effective each December 1; however, management believes that they were not notified of the increases in deposit requirements, and maintain that they did not receive copies of the revised HUD 9250 forms establishing the effective dates and amounts of deposit requirements changes for the years ended December 31, 2020 through December 31, 2022. The total amount of the replacement reserve deposit shortage was calculated to be $13,302. S3800-080: Auditor Recommendation: Management should review policies and procedures to ensure all required deposits to the reserve account are properly billed and deposited into the escrow account with the lender. Management should also deposit the shortage of $13,302 in the replacement reserve escrow account held by the lender. S3800-045: Actions Taken or to be Taken: Management will follow up with the lender about the new deposit requirement and deposit the funding shortage of $13,302 in the replacement reserve escrow account held by the lender. They will also request all missing copies of the HUD 9250 forms for the effective dates of December 1, 2020 through December 1, 2022.
S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in...
S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in these months, resulting in a deficiency in the account. Although the funding deficit amounts were not always significant, it is important that the security deposit cash account be fully funded at all times. S3800-080: Auditor Recommendation: We recommend that property management implement a more robust process for monitoring and reconciling the security deposit cash account on a monthly basis. This process should ensure that the account balance is consistently maintained at the required level. Furthermore, management should conduct periodic reviews of the security deposit balances to identify and address any discrepancies promptly. Training for staff involved in managing security deposits should be considered to ensure compliance with HUD regulations and internal policies. FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT (Continued) S3800-010: Finding Reference Number 2024-002 (Continued) S3800-045: Actions Taken or to be Taken: It is management’s policy to fully fund the security deposit account so the balance in cash meets or exceeds the total liability of deposits collected from tenants. Management discussed the importance of reviewing funding monthly with the Project Accountant, and new procedures have been implemented to include a monthly process to compare the security deposit liability to the bank account and fund any shortages to ensure the security deposit bank account is consistently maintained at the required level.
S3800-010: Finding Reference Number 2024-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an indep...
S3800-010: Finding Reference Number 2024-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an independent contractor prior to finalization of new tenant move-in. However, during our testing, we noted five (5) move-in files out of five (5) move-in files tested where tenants were approved for move-in prior to review and approval by the independent contractor, circumventing the control. S3800-080: Auditor Recommendation: We recommend that the client immediately implement corrective actions to ensure compliance with internal control procedures. Specifically: 1. The compliance specialist should be required to wait for proper approval of tenant eligibility files before processing them. 2. Review and reinforce the approval process through additional training for staff to ensure they understand the critical importance of obtaining necessary approvals before proceeding. 3. Implement stronger oversight and monitoring mechanisms to ensure that files are not processed before approval. S3800-045: Actions Taken or to be Taken: Management has reviewed the policies and procedures with the property manager, who also serves as the compliance specialist. The property manager was instructed that no tenants are to be granted occupancy until the file has been approved by the independent contractor conducting the compliance review.
Finding 539628 (2024-001)
Significant Deficiency 2024
MANAGEMENT’S OR DEPARTMENT’S RESPONSE: WE CONCUR. VIEWS OF RESPONSIBLE OFFICIALS AND CORRECTION ACTION: AMOUNT HAS BEEN DEPOSITED. ADDITIONALLY, ALL RESTRICTED ACCOUNTS WILL BE REVIEWED ANNUALLY TO ENSURE TRANSFERS ARE MADE.
MANAGEMENT’S OR DEPARTMENT’S RESPONSE: WE CONCUR. VIEWS OF RESPONSIBLE OFFICIALS AND CORRECTION ACTION: AMOUNT HAS BEEN DEPOSITED. ADDITIONALLY, ALL RESTRICTED ACCOUNTS WILL BE REVIEWED ANNUALLY TO ENSURE TRANSFERS ARE MADE.
The City is in agreement with the audit finding and it will make sure to attach the Indirect Cost Rate(s) Schedule as described in the “Special Conditions” of the contracts that are returned to HUD. The City already took action on this submission and the Indirect Cost Rate Schedule was attached as a...
The City is in agreement with the audit finding and it will make sure to attach the Indirect Cost Rate(s) Schedule as described in the “Special Conditions” of the contracts that are returned to HUD. The City already took action on this submission and the Indirect Cost Rate Schedule was attached as an “Addendum” to the contract B-24-MC-06-0006 executed with HUD for FY 24-25.
The City is in agreement with the audit finding. As of the date of the Single Audit Report, the City is caught up on its Financial Reports submission in IDIS-CPD Grant Portal. The City still needs to update its CDBG policies and procedures to specify required CDBG reporting requirements and obligati...
The City is in agreement with the audit finding. As of the date of the Single Audit Report, the City is caught up on its Financial Reports submission in IDIS-CPD Grant Portal. The City still needs to update its CDBG policies and procedures to specify required CDBG reporting requirements and obligations, per reporting compliance required under 24 CFR Section 570.507(d) - Other reports and 2 CFR 200.302(b)(2) – Financial management.
Corrective Action Plan: The Authority concurs with the finding. The following corrective actions are being implemented:  Reinstating and enhancing the inspection tracking log to monitor timely completion of all required inspections;  Utilizing property management software to schedule and track ins...
Corrective Action Plan: The Authority concurs with the finding. The following corrective actions are being implemented:  Reinstating and enhancing the inspection tracking log to monitor timely completion of all required inspections;  Utilizing property management software to schedule and track inspections;  Assigning oversight responsibility for inspections to the Property Manager and Safety Inspection Supervisor;  Conducting quarterly management reviews of inspection compliance;  Hired additional inspection sta􀀳, including Maintenance Operations Supervisor to complete any backlog and ensure ongoing compliance.  Requested funding from City, State, and County to assist in inspections compliance to address federal funding and revenue shortages due to rental income delinquency. Anticipated Completion Date: June 30, 2025 Responsible Party: Senior Manager of Housing Operations/Maintenance Manager
Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include:  Updating internal policies and procedures related to tenant file documentation and income verification requirements;  Providing targeted sta􀀳 training on proper...
Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include:  Updating internal policies and procedures related to tenant file documentation and income verification requirements;  Providing targeted sta􀀳 training on proper file documentation and third-party income verification procedures;  Implementing a mandatory checklist to ensure all required documentation is obtained and verified before finalizing recertifications;  Establishing a quality control process where supervisory sta􀀳 conduct periodic file reviews to ensure compliance;  Maintaining an audit trail of verification documentation to ensure proper retention.  Hired third-party service provider, Quadel to assist with tenant file documentation compliance, annual and interim recertifications and rent calculations.  Hiring Senior Housing Manager to assist with monitoring verification documentation, income calculation, citizenship and/or legal residency documentation, and signed release documentation compliance. Anticipated Completion Date: June 30, 2025 Responsible Party: Senior Manager of Housing Operations and PH Property Managers
Finding 2024-004 - HUD Comprehensive Review, Section 8 Housing Choice Voucher Program – CFDA No. 14.871; Grant period – year ended June 30, 2024 Corrective Action: The Authority submitted corrective actions to HUD dated August 17, 2023, which included implementing HUD’s recommended corrective action...
Finding 2024-004 - HUD Comprehensive Review, Section 8 Housing Choice Voucher Program – CFDA No. 14.871; Grant period – year ended June 30, 2024 Corrective Action: The Authority submitted corrective actions to HUD dated August 17, 2023, which included implementing HUD’s recommended corrective actions. Responsible Party: Matthew McClammey, Executive Director, (334)745-4171. Anticipated Completion Date: June 30, 2025.
View Audit 350086 Questioned Costs: $1
Finding 2024 - 003 - Housing Choice Vouchers Tenant Files Housing Choice Vouchers - CFDA No. 14.871; Grant period - year ended June 30, 2024 Corrective Action: The Authority will work on strengthening its internal controls to correct this situation and ensure that they will be in compliance with the...
Finding 2024 - 003 - Housing Choice Vouchers Tenant Files Housing Choice Vouchers - CFDA No. 14.871; Grant period - year ended June 30, 2024 Corrective Action: The Authority will work on strengthening its internal controls to correct this situation and ensure that they will be in compliance with the federal guidelines and the Authority’s policies. Responsible Party: Matthew McClammey, Executive Director, (334)745-4171. Anticipated Completion Date: June 30, 2025.
Finding 2024 - 002 - Section 8 HQS Inspection Deficiencies Housing Choice Vouchers - CFDA No. 14.871; Grant period - year ended June 30, 2024 Corrective Action: The Authority is continuing to work on the procedures for failed inspections to ensure that the reinspections are performed within the 30-d...
Finding 2024 - 002 - Section 8 HQS Inspection Deficiencies Housing Choice Vouchers - CFDA No. 14.871; Grant period - year ended June 30, 2024 Corrective Action: The Authority is continuing to work on the procedures for failed inspections to ensure that the reinspections are performed within the 30-day requirement. The Authority is also planning on additional training for employees to make sure they are qualified to meet the HQS re-inspection requirements. Responsible Party: Matthew McClammey, Executive Director, (334)745-4171. Anticipated Completion Date: June 30, 2025.
Corrective Action Plan for Finding 2024-003 Community Care agrees with this finding. The homeless youth service sector of our organization has significant report requirements that could not be supported by existing resources. A recent effort to improve report timing was to hire an administrative...
Corrective Action Plan for Finding 2024-003 Community Care agrees with this finding. The homeless youth service sector of our organization has significant report requirements that could not be supported by existing resources. A recent effort to improve report timing was to hire an administrative person to specifically focus on these reports. This individual began employment in February 2025. The primary purpose of this position will be to organize data and complete reports on schedule. Responsible Official: David McCluskey, Executive Director Date of Corrective Action: New employee hired in February 2025
Finding 2024-002 – Low Income Public Housing Tenant Files – Eligibility – Noncompliance & Material Weakness – Public and Indian Housing – ALN #14.850 Corrective Action Plan: The Housing Authority has contracted with US Inspections to continue pre-inspecting units in preparation for NSPIRE inspecti...
Finding 2024-002 – Low Income Public Housing Tenant Files – Eligibility – Noncompliance & Material Weakness – Public and Indian Housing – ALN #14.850 Corrective Action Plan: The Housing Authority has contracted with US Inspections to continue pre-inspecting units in preparation for NSPIRE inspections. Additionally, staff is coordinating Income Calculation training with Zeffert University. Lastly, the Housing Authority has implemented a 100% file compliance review, which took effect on January 1, 2025. Person Responsible: Tammy Bradshaw, Admissions & Compliance Manager Anticipated Completion Date: June 2025
Finding 2024-001 – Accounting Controls – Internal Controls over Financial Statement Preparation ALN 14.850 – Noncompliance and Material Weakness Corrective Action Plan: The Housing Authority is working with new personnel to ensure processes are documented and proper training is taking place. The...
Finding 2024-001 – Accounting Controls – Internal Controls over Financial Statement Preparation ALN 14.850 – Noncompliance and Material Weakness Corrective Action Plan: The Housing Authority is working with new personnel to ensure processes are documented and proper training is taking place. The Housing Authority has contracted with BDO to assist with year-end processes and training. Person Responsible: Sheila Crisp, Executive Director Anticipated Completion Date: June 2025
Management agrees with the finding. The excess funds were accrued to offset future Section 8 HAP requests.
Management agrees with the finding. The excess funds were accrued to offset future Section 8 HAP requests.
Finding 539409 (2024-004)
Significant Deficiency 2024
Finding 2024‐004: Significant Deficiency and Non‐Material Noncompliance – Housing Voucher Cluster REAC Report Name of Contact Person: Joan Duckett, Director of Housing & Community Development Corrective Action: The Office of Housing and Community Development (OHCD) has taken corrective measures to e...
Finding 2024‐004: Significant Deficiency and Non‐Material Noncompliance – Housing Voucher Cluster REAC Report Name of Contact Person: Joan Duckett, Director of Housing & Community Development Corrective Action: The Office of Housing and Community Development (OHCD) has taken corrective measures to ensure that the REAC reports are supported with accurate data and submitted in a timely manner. There are monthly reconciliation procedures in place which include management oversight and review of all reports. OHCD has and will continue to enter into a contractual agreement with a knowledgeable and reputable accounting firm that the County is under contract for services applicable to the need. REAC reports will be extensively reviewed by management prior to submission to HUD. Proposed Completion Date: Immediately
Finding 539408 (2024-003)
Significant Deficiency 2024
Finding 2024‐003: Significant Deficiency and Non‐Material Noncompliance – Housing Voucher Cluster Special Test 8 – Bank Accounts Name of Contact Person: Joan Duckett, Director of Housing & Community Development Corrective Action: The Office of Housing and Community Development began working with the...
Finding 2024‐003: Significant Deficiency and Non‐Material Noncompliance – Housing Voucher Cluster Special Test 8 – Bank Accounts Name of Contact Person: Joan Duckett, Director of Housing & Community Development Corrective Action: The Office of Housing and Community Development began working with the County’s Finance Department and the current Banking Financial Institution (Wells Fargo) and opened two separate accounts, one for the Housing Choice Voucher (HCV) program and one for the FSS Escrow Accounts in April 2024. The task included revised mapping of deposits and expenditures, including the establishment of related workflows within the County’s financial management system and therefore these changes were adequately tested. The migration to the two new bank accounts went live on July 1, 2024, and per HUD regulations a General Depository Agreement (HUD‐51999 GDA) was entered. Proposed Completion Date: Immediately
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