Corrective Action Plans

The Organization will deposit $2,243 to their residual receipts account.

Recommendation: We recommend that management of Drexel Square Apartments develop and implement policies and monitoring procedures to ensure timely submission of the data collection form and reporting package to the FAC and the annual financial statements to the REAC.

The auditee will ensure financial records are finalized and submitted in accordance with the HUD Regulatory Agreement.

Response: We have focused on getting the audit for FYE June 30, 2023 completed.  The audit firm that we had contracted with had performed over one-half of the audit work when they withdrew from the engagement.  It was difficult by that time to engage a new auditor that would be able to meet the filing deadlines.  We were unable to hire a new auditor prior to March 31, 2024.  We anticipate hiring the auditor for the fiscal year ended June 30, 2024 within the next week.  The most important requirement in our contract with the auditor will be to meet the filing deadlines.  From now on, we will hire the auditor prior to the end of our fiscal year.  Prior to June 30, 2023, our audits and HUD filings have never been late.  We will make sure that we are current in the future.

Response: We have focused on getting the audit for FYE June 30, 2023 completed.  The audit firm that we had contracted with had performed over one-half of the audit work when they withdrew from the engagement.  It was difficult by that time to engage a new auditor that would be able to meet the filing deadlines.  We were unable to hire a new auditor prior to March 31, 2024.  We anticipate hiring the auditor for the fiscal year ended June 30, 2024 within the next week.  The most important requirement in our contract with the auditor will be to meet the filing deadlines.  From now on, we will hire the auditor prior to the end of our fiscal year.  Prior to June 30, 2023, our audits and HUD filings have never been late.  We will make sure that we are current in the future.

Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe. Responsible Person: Sarby Singh Expected Implementation Date: 07/01/2024

Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Choice Vouchers Federal Catalog Numbers: 14.871 Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Inspections. Per the Authority's HCV Admin Plan, the PHA must inspect the unit leased to a family at least annually to determine if the unit meets HQS standards and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management there were inspection reports that were unavailable for examination at the time of audit. Context: Of a sample size of thirty-two (32) units, four (4) units did not have annual HQS inspections performed timely. Our sample size is statistically valid. Known Questioned Costs: $2,249 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the significant deficiency in the Section 8 Housing Choice Vouchers Program and will implement internal control procedures that will ensure compliance with federal regulations. Joanna Lara, Director of Housing Administration is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring by December 31, 2024.

Management will deposit required amounts.

We are aware of the findings from the report and we will take the necessary steps to mitigate the issues.

Finding 2023-002 Late Submission of Financial Statements to FAC and REAC (Significant Deficiency) Recommendation: The Authority should review and enhance its policies, procedures, and internal controls to ensure the financial reporting package and audited financial statements are submitted by the required due date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will evaluate its’ financial reporting and close processes and controls to determine whether additional controls over the preparation of the final trial balances and related schedules should be implemented. As part of this process, we will create a yearend checklist with deadlines established, and set up status meetings to monitor the progress. Name(s) of the contact person(s) responsible for corrective action: Cia Cook, Deputy Executive Director & CFO Planned completion date for corrective action plan: August 31, 2024

Finding 2023-001 Federal Program Funds Utilized for Non-Federal Programs Recommendation: The Authority should locate additional sources of non-federal funds or reduce costs sufficiently so that the program can have enough cash to cover ongoing operations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has reevaluated its cost allocation plan, and restructured various department to better align staffing. This process helps ensure the COCC and funds are being properly charged for actual costs incurred. The Authority is also redeveloping its entire portfolio. This process had been and will continue to bring in developer and management fees to the COCC to help reduce the due to/due from activity. Name(s) of the contact person(s) responsible for corrective action: Cia Cook, Deputy Executive Director & CFO Planned completion date for corrective action plan: June 30, 2025

CORRECTIVE ACTION PLAN ISSUED BY THE BOARD OF DIRECTORS Louis Sandman Senior Housing, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of public accounting firm: John Flusche, CPA 5735 East 102nd Street Tulsa, Oklahoma 74137 Audit Period: Year ended December 31, 2023 The findings from the December 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDING No. 2023-001: Recommendation: The Project’s management should redeposit the funds into the Replacement Reserve bank account as soon as possible, to bring the account to the correct balance. Action Taken: The Project’s management will redeposit the funds into the replacement reserve account in 2024. If the Department of HUD has questions regarding this plan, please contact Rick Gowin, Westchester Realty & Development. March 12, 2024 Allen Leaird, Board Member Date March 12, 2024 Rick Gowin, Management Agent Date

Heartland House, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of public accounting firm: John Flusche, CPA 5735 East 102nd Street Tulsa, Oklahoma 74137 Audit Period: Year ended December 31, 2023 The findings from the December 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDING No. 2023-001: Recommendation: The Project’s management should redeposit the funds into the Security Deposit bank account as soon as possible, to bring the account to the correct balance. Action Taken: The Project’s management will redeposit the funds into the security account in 2024. If the Department of HUD has questions regarding this plan, please contact Rick Gowin, Westchester Realty & Development. March 12, 2024 Dwight McGee, Chairman Date March 12, 2024 Rick Gowin, Management Agent Date

For the year ended December 31, 2023 CORRECTIVE ACTION PLAN ISSUED BY THE BOARD OF DIRECTORS 205 Corporation, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of public accounting firm: John Flusche, CPA 5735 East 102nd Street Tulsa, Oklahoma 74137 Audit Period: Year ended December 31, 2023 The findings from the December 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDING No. 2023-001: Recommendation: The Project’s management should redeposit the funds into the Residual Receipts bank account as soon as possible, to bring the account to the correct balance. Action Taken: The Project’s management will redeposit the funds into the Residual Receipts account in 2024. If the Department of HUD has questions regarding this plan, please contact Rick Gowin, Westchester Realty & Development. March 12, 2024 Randy Lauderdale, President Date March 12, 2024 Rick Gowin, Management Agent Date

CORRECTIVE ACTION PLAN ISSUED BY THE BOARD OF DIRECTORS Big 5 Ada Housing, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of public accounting firm: John Flusche, CPA 5735 East 102nd Street Tulsa, Oklahoma 74137 Audit Period: Year ended December 31, 2023 The findings from the December 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDING No. 2023-002: Recommendation: The Project’s management should redeposit the funds into the Security Deposit bank account as soon as possible, to bring the account to the correct balance. Action Taken: The Project’s management will redeposit the funds into the security account in 2024.

CORRECTIVE ACTION PLAN ISSUED BY THE BOARD OF DIRECTORS Big 5 Ada Housing, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of public accounting firm: John Flusche, CPA 5735 East 102nd Street Tulsa, Oklahoma 74137 Audit Period: Year ended December 31, 2023 The findings from the December 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDING No. 2023-001: Recommendation: The Project’s management should redeposit the funds into the Replacement Reserve bank account as soon as possible, to bring the account to the correct balance. Action Taken: The Project’s management will redeposit the funds into the replacement reserve account in 2024.

B. Finding 2023-002 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 207/223(f)) (CFDA# 14.155) Allowable costs/cost principles The Project disbursed $47,837 of legal costs that were not operating expenses for the project. (1) Comments on the Finding and Each Recommendation Management concurs with this finding and the current management agent has ensured that $47,837 was reimbursed from entity non-project funds. (2) Actions Taken on the Finding The funds were reimbursed from entity non-project funds.

A. Finding 2023-001 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 207/223(f)) (CFDA# 14.155) Residual Receipts The Project did not deposit their residual receipts deposit of $31,573 from prior year surplus cash within the required deadline of 90 days after year end. (1) Comments on the Finding and Each Recommendation Management concurs with this finding, agrees with the auditor recommendation, and has made the required residual receipts deposit. (2) Actions Taken on the Finding The funds have been deposited to residual receipts.

Management’s Response: The Authority has implemented the following in response to this finding: • All staff recently attended voucher training to understand the importance of and the process for file review and the documentation required, including rent reasonableness at move-in and as required. Staff will attend various HCV training throughout the year to ensure practical application. • Internal and third-party file reviews are and will continue to be conducted quarterly, to ensure file completeness, including rent reasonableness is completed properly and present in every move-in file and as required. If no rent reasonableness is in the file, SMHO will ensure one is completed, along with a clarification explaining any discrepancy. • SMHO will require managerial file review/approval for all new staff for the first six months of hire and will sign the check sheet for each file to indicate the review/approval has been completed.

Finding Reference Number 2023-002 1. Name of contact person responsible for corrective action Annmarie Covone, Executive Vice President/Chief Financial Officer 2. Corrective action planned Management changes caused delays in locating support for the single audit testing. Accordingly, the new management anticipates that these matters will not repeat themselves in the future periods and the audited financial statements will be submitted timely. 3. Anticipated Completion Date This will be completed in October 2024. 4. If the client does not agree with the findings or believes corrective action is not required, include an explanation and specific reasons We agree with Finding Reference No. 2023-002 Contact Information Annmarie Covone Executive Vice President/Chief Financial Officer 205 Lexington Avenue, 2nd Floor, New York, NY 10016 P (646) 633-4702 acovone@archcare.org

Tenant security deposit bank account. Contact person - Executive Director. Corrective action planned - The Project will maintain a tenant security deposit bank account in accordance with the regulatory agreement. Anticipated completion date - Within the next fiscal year.

Recommendation: The organization should obtain the requisite fidelity bond coverage and monitor the coverage to ensure it is in compliance with HUD requirements. Action Taken: Fidelity bond coverage was increased accordingly.

Corrective Action Plan Audit FYE 2023 Housing Assistance Program Discrepancies Finding: Discrepancies in tenant files, including missing forms (HUD-9886, Section 214 Status), Housing Assistance Payment (HAP) contracts, utility allowances, rent reasonableness, and asset verifications. Actions Taken: - Reviewed and corrected tenant files, ensuring all required documentation (HUD-9886, Section 214 forms) is present. - Rent reasonableness assessments have been updated for all relevant tenant files. - The utility allowance schedule was reviewed for 2023 in accordance with 24 CFR § 982.517. The review showed a change of less than 10% in utility costs. The utility allowance schedule was reviewed for 2024 and adjustments were made to maintain compliance. Future Actions: - File Review and Documentation: Conduct a full audit of tenant files to address missing forms and ensure compliance with all HUD regulations. Missing forms (e.g., HUD-9886) will be collected from tenants, and any discrepancies corrected. - Staff Training: Implement a comprehensive staff training program on file documentation and HUD compliance requirements. This will include sessions on rent calculations, utility allowances, and income verification. - Monthly Audits: Establish monthly internal audits to ensure ongoing compliance and rectify any future discrepancies promptly. Utility Allowances and Rent Reasonableness Finding: Utility allowances had not been reviewed in over three years, and discrepancies in rent reasonableness and utility allowances led to miscalculations in tenant payment obligations. Actions Taken: - The utility allowance schedule was reviewed for 2023 in accordance with 24 CFR § 982.517. The review showed a change of less than 10% in utility costs. The utility allowance schedule was reviewed for 2024 and adjustments were made to maintain compliance. - Rent reasonableness procedures were reviewed and updated to ensure that all tenants' rents are fair and consistent with current market rates. Future Actions: - Annual Utility Allowance Reviews: Continue to review utility allowances annually, ensuring compliance with HUD regulations and adjusting allowances when necessary. - Documentation: Maintain thorough records of rent reasonableness and utility allowance calculations to ensure compliance with HUD guidelines. SEMAP (Section Eight Management Assessment Program) Performance Finding: Previous audits revealed a low SEMAP score, indicating areas of non-compliance in key performance indicators. Actions Taken: - A corrective strategy for SEMAP indicators has been implemented, focusing on timely re- examinations, accurate rent calculations, and Housing Quality Standards (HQS) inspections. - Ongoing training has been provided to staff on SEMAP indicators to ensure improvement in future assessments. - 2022 SEMAP scores are "Standard." Future Actions: - SEMAP Re-assessments: Conduct quarterly internal SEMAP reviews to monitor compliance with key indicators. - Staff Training: Continue training staff on SEMAP performance metrics, particularly regarding timely re-certifications and inspections. - Quality Control: Implement a quality control process that includes random checks of tenant files and HQS inspection records. Finding: Inconsistent file documentation and procedural errors indicate a need for further staff training and improvements in administrative procedures. Actions Taken: - Staff training has been initiated to ensure all team members understand HUD regulations and file documentation requirements. - The Jacksonville Housing Authority website has been launched, including portals for tenants, landlords, and applicants, improving communication and service delivery. Future Actions: - Staff Education: Provide ongoing refresher courses to ensure staff remain compliant with HUD regulations and procedural updates. - Improved Administrative Procedures: Develop and implement a Standard Operating Procedures (SOP) manual that outlines key administrative tasks, including tenant file maintenance and compliance checks. - Resident Advisory Board: Actively recruit volunteers for the Resident Advisory Board to increase community engagement. Finding: Low utilization of vouchers due to limited available housing and participant eligibility issues. Actions Taken: - The Jacksonville Housing Authority has exceeded the goal of issuing 5 vouchers per month, issuing: - October: 5 vouchers - November: 6 vouchers - December: 9 vouchers - We added 5 new landlords in 2023 and opened our waiting list. Future Actions: - Landlord Recruitment: Continue to engage with landlords to increase housing availability and create a Landlord/Property Manager Advisory Board. - Voucher Utilization: Issue more vouchers as per HUD's recommendation and increase payment standards to 120% to make vouchers more competitive in the market when allowed. We have made significant strides in addressing the findings from the audit and will continue our efforts to ensure full compliance with HUD regulations. Our focus will remain on improving file documentation, tenant services, and program utilization while ensuring that Jacksonville Housing Authority operates efficiently and transparently. This Corrective Action Plan serves as our roadmap to address current audit findings, continue progress, and implement necessary changes to ensure sustainable program success.

FINDING #2023-002 RESERVE FOR REPLACEMENT Condition: The Reserve for Replacement account balance for Park Ridge Apartments, Phase 4 underfunded in the amount of $750. Recommendation: The management agent should ensure that all required deposits are made to the Reserve for Replacement account and that the balance in that account meets the minimum required balance in accordance with the regulatory agreement between the Entity and HUD. View of Responsible Officials and Planned Corrective Action: The management agent agrees with the finding and the auditor’s recommendations have been adopted.

FINDING #2023-001 SURPLUS CASH Condition: At December 31, 2022 the Entity had surplus cash totaling $9,162, due to Home Funds. Park Ridge Apartments, Phase 3 had surplus cash in the amount of $4,000. Park Ridge Apartments, Phase 4 had surplus cash in the amount of $2,077. Park Ridge Apartments, Phase 5 had surplus cash in the amount of $1,379. Parsk Ridge Apartments, Phase 6 had surplus cash in the amount of $1,706. The Entity did not make any payments on the loan as required by the loan agreement. Recommendation: The management agent should compute an estimate of surplus cash for the fiscal year upon completion of that period. In the event that surplus cash exists at the completion of the fiscal period, the management agent should make an installment payment on the HOME note. Views of Responsible Officials and Planned Corrective Action: The management agent agrees with the finding and the auditor’s recommendations have been adopted. Surplus cash will be calculated upon the completion of an annual fiscal period. If it is concluded that surplus cash exists at the end of the annual fiscal period, an installment payment will be made on the loan.