Corrective Action Plans

Criteria The Entity is required to maintain residual receipts in an interest-bearing account. Condition The Entity’s residual receipts were not maintained in an interest-bearing account. Cause The interest rate on the account was changed by the bank, which was not noticed by management personnel before the year end. Context When performing out audit, we noted that the Entity's residual receipts did not earn interest in 2023. Questioned Costs none noted. Effect The Entity was not in compliance with the requirement to maintain its residual receipts in an account that bears interest. Recommendation We recommend the Entity contact the bank to correct the interest rate on the account or move the balance to an interest-bearing account. Views of the Responsible Official See Corrective Action Plan

Missing Depository Agreements ( Non Compliance) Condition: The Housing Commison of Talbot (the "Commision") did not set up depository agreements with its financial institutions. Status: This finding is uncleared. A similar finding was noted in fischal year 2023. The Commission has had prior communications with the Bank regarding the depository agreements requirements. The Bank would not sign due to internal policies. The Commision will coordinate discussions between our HUD local field office and the Bank to discuss the requirements for obtaining a depository agreement.

Recommendation: The Authority should review and enhance its internal controls to ensure: · the utility allowance schedules are reviewed and updated as necessary at least annually; and units are inspected annually under HQS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority specialist responsible for file maintenance and recertifications during fiscal year 2022 and early 2023 is no longer with the Agency. The Authority has experienced staff now in place to perform these services. The Authority will revisit our policy and procedures over recertification, HQS, and file maintenance to ensure documentation is maintained and is in compliance with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2024

Recommendation: The Authority should review and enhance its internal controls to ensure: . management obtains and reviews documentation supporting United States of America citizenship; . tenants provide release forms prior to obtaining necessary documentation; . management verifies income listed on the HUD Form 50058; and recertifications are consistently reviewed and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority specialist responsible for file maintenance and recertifications during fiscal year 2022 and early 2023 is no longer with the Agency. The Authority has experienced staff now in place to perform these services. The Authority will revisit our policy and procedures over recertification and file maintenance to ensure documentation is maintained and is in compliance with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2024

Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024

Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024

Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024

Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024

Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024

2023-003 Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED SEPTEMBER 30, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended September 30, 2023. Finding 2023-001 Responsible Party Name: Peggy Scott Position: Manager Telephone Number: (660) 339-7235 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities – Section 811 Compliance Requirements N- Special Tests and Provisions Findings Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditors’ finding. Corrective Action We will follows our policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date July 31, 2024

In 2023 there was a change in management within ACED’s financial staff. The current supervisor was unaware that there was program income that had not been recorded. ACED has contracted with an outside auditing firm. All accounts are being reviewed and reconciled and program income is being receipted. ACED will receipt all program income as it comes in and it will be immediately allocated to eligible projects.

We review each invoice monthly as they are submitted. Most of the review is insuring the items being invoiced are eligible under HUD and making sure the amounts are added correctly. We will review more closely the match submitted. Match for HUD is now reported based on the entire funding and not by individual grants. All match from all HUD programs is added together and submitted on one final report at the end of each funding year. The requirement is 25% on all budget lines except for Leasing. However, if one program’s match is short of the 25% requirement, the overall CoC is responsible for the full match so additional DHS admin costs are used to represent the additional match needed. For our FY22-23 annual report to HUD, we submitted 30.47% in match for the overall funding. This amount did not include any additional HMIS (data system) costs, Allegheny Link (our coordinated entry system) costs or additional DHS admin costs. With these additional eligible activities, our matching amount could have been over 50%. Therefore, even if some identified items were considered ineligible our match would not be in jeopardy since we have a lot of eligible costs that DHS covers that would be considered match.

Contact Person Dara A. Lee, Executive Director Corrective Action Plan The Authority plans to review and make the necessary changes to its year-end financial closing procedures to ensure its financial records are reconciled and available in order to submit its financial data within a timely manner. Planned Completion Date for CAP December 31, 2024

Finding 2023-001- Special Tests Contact Person: William Bane Management Response: Management acknowledges that there were not sufficient controls in place prior to September 28, 2023, to ensure written consent from HUD prior to incurring new debt or lease arrangements. The three lease arrangements in question were all entered prior to the controls put in place on September 28, 2023. Current Management had previously established effective controls to ensure written consent is obtained prior to incurring any new debt or lease arrangements.

Finding 2023-002 – HQS Enforcement Auditee’s Response and Planned Corrective Action Rensselaer Housing Authority will document all failed inspections and ensuring that property issues are addressed in a reasonable time frame. Planned Implementation Date of Corrective Action: September 30, 2024 Person Responsible for Corrective Action: Marianne Ogren, Executive Director

Finding 2023-001 – Documentation of Controls Auditee’s Response and Planned Corrective Action Rensselaer Housing Authority to implement check list to ensure tenant files are organized and reviewed by another employee. Planned Implementation Date of Corrective Action: September 30, 2024 Person Responsible for Corrective Action: Marianne Ogren, Executive Director

Root Cause Analysis: 1. Lack of awareness of federal requirements. Corrective Action(s): 1. Create and maintain detailed equipment logs for all federally funded equipment purchases and obtain training on the proper procedures for equipment record keeping, emphasizing the importance of these logs in federal fund management. 2. Action Item: o Description: Reach out to our Federal grants liaison for recommendation on best training to attend and when they will occur in FY25. Create and maintain a detailed equipment log for all federally funded equipment purchased. o Responsible Person/Department: Director Finance for the Randolph Public Schools. o Expected Completion Date: Training via DESE PD opportunities. Equipment log will be created by 9/2024. o Description:The equipment log will be created and maintained by the Director of Finance for the Randolph Public Schools. o Responsible Person/Department: Director Finance for the Randolph Public Schools. o Expected Completion Date: Log will be created by September 2024.

2023-001 - HQS Enforcements and Annual HQS Inspections Housing Voucher Cluster - Assistance Listing No. 14.871 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In response to the HOS enforcement and annual inspections finding for the Housing Authority of the City of Key West, FL 12-31-2023 audit, management has completed the following items in order to address the issue: • Hired a new HCV Program Manager, • Procured a new outside HCV inspection contractor, • Provided current staff training on HCV program HOS requirements, • Adopted the recommendation from our independent auditors to have the Assistant to the Director of Housing sample 10% of the HCV recertification files monthly to ensure compliance with federal regulations and housing quality standards - files that are found to be out of compliance will be reported to the Director of Housing & Executive Director. In addition, the following items will be done: • Consider changing the administrative plan to prohibit time extensions beyond 30 days, thereby requiring abatement of HAP effective the 31st day in all cases, • Update the job description of the Assistant to the Director of Housing & change the title of the position to Assistant to the Director of Housing/Compliance Specialist. Name(s) of the contact person(s) responsible for corrective action: Randy Sterling, Executive Director Planned completion date for corrective action plan: October 31, 2024.

Management agrees that they had lost revenue that wasn’t utilized that was sufficient to cover the amount of expenses that were reported in error. There is no disagreement with the audit finding and will implement proper training, education, and review processes to ensure reporting is completed accurately going forward.

Management agrees with this finding. Management will review all new funding contracts and agreements and keep track of all reporting requirements and deadlines in order to stay in compliance. Management will document all requirements and deadlines by December 31st, 2024. The Finance Director will notify reporting staff that a report is due and confirm that it has been submitted prior to the due date.

2023-002 Condition: Deficiencies Noted in Examination of New Construction Section 8 Tenant Files Steps to resolve: We will review the internal control procedures over tenant file re-certifications and documents and implement procedures which will eliminate such errors. Management has implemented procedures in order to clear this finding in FY 2024. Timeframe: By FYE December 31, 2024 Individual responsible for correction: Ms. Zena Zahran, Executive Director

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and income is supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • We will be conducting a random audit of all LRPH files. • Training on best practice for PH and PBV reviews. This training will emphasize the importance of proper income documentation. • Sending out monthly report for reviews that are coming due. Name(s) of the contact person(s) responsible for corrective action: Suzanne Couttouw, Compliance Manager (audit and training) and Elise Anderson (monthly reporting.) Planned completion date for corrective action plan: March 30, 2025

Finding Number 2023-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). Condition/Context The Authority received funding from the HUD. The Public and Indian Housing program is to provide and operate cost effective, decent, safe, and affordable dwellings for lower income families through an authorized local PHA. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: Eight eligibility forms were not provided (five missing application forms, one missing certifications information provided to the PHA forms and two missing Release form). These forms are required documentation to be maintained in the case files to support eligibility for Public and Indian Housing Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan In January 2011, NYCHA implemented the Siebel Customer Relationship Management (CRM) system, which included digital file storage and an online application process, which replaced our previous paper application process. Any applications in process from that date onward were subject to document scanning and documentation was stored digitally. Any applications processed prior to this date were kept in a paper format and stored at the development, where the applicant was certified or where the tenant resides. If a tenant family transferred to another development, the physical tenant folder and documents were sent to their new location. In June 2020, NYCHA sought to digitize all tenant folders; however, the cost of the project was determined to be prohibitive so the goal of digitizing the tenant folders was not realized. Any documents damaged or lost prior to 2011 cannot be recovered, including those impacted by Hurricane Sandy. Action Date September 6,2024 Final Implementation September 6,2024 Name And Phone Number Of Person Responsible for Implementation Sylvia Aude Senior Vice president Office of the Senior Vice President for Public Housing Operations Tenancy Administration +1-212-306-3921

Finding Number 2023-001 SPECIAL TESTS AND PROVISIONS- ENVIRONMENTAL CONTAMINANTS TESTING AND REMEDIATION – MATERIAL WEAKNESS Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Special Tests and Provisions - Environmental Contaminants Testing and Remediation As stated in the May 2023 Compliance Supplement, Public Housing must be decent, safe, sanitary, and in good repair. Public Housing Authority’s (PHA) must maintain such housing in a manner that meets the physical condition standards set forth in 24 CFR section 5.703 in order to be considered decent, safe, sanitary, and in good repair. Those standards address the major areas of the public housing: the site; the building exterior; the building systems; the dwelling units; the common areas; and health and safety considerations. Health and safety considerations require that all areas and components of the housing must be free of health and safety hazards. These areas include, but are not limited to, air quality, electrical hazards, elevators, emergency/fire exits, flammable materials, garbage and debris, handrail hazards, infestation, and lead-based paint. The housing must have no evidence of infestation by rats, mice, or other vermin, or of garbage and debris. The housing must have no evidence of electrical hazards, natural hazards, or fire hazards. The dwelling units and common areas must have proper ventilation and be free of mold, odor (e.g., propane, natural gas, methane gas), or other indoor air hazards such as radon. The housing must comply with all requirements related to the evaluation and reduction of lead-based paint hazards and have available proper certifications of such (see 24 CFR Part 35). For the period under audit, the PHA is required to test for and remediate environmental contaminates including but not limited to lead-based paint, radon gas, and mold to ensure that public housing met the physical condition standards for health and safety considerations set forth in 24 CFR section 5.703. Condition/Context The New York City Housing Authority (the “Authority”) performs environmental contaminates testing and remediation including but not limited to Lead-based paint, Mold, Pest Control, Elevators, Heating and Annual Apartment Inspections. To track compliance with the Agreement executed on January 31, 2019 by and among the Authority, the U.S. Department of Housing and Urban Development (“HUD”) and the U.S. Attorney’s Office for the Southern District of New York (SDNY) and The City Of New York (the “HUD Agreement”), the Authority maintains monthly inspection reports for the various inspections performed and provides that information to HUD, the SDNY and the Federal Monitor appointed under the HUD Agreement. Deloitte obtained the bi-annual lead-based paint compliance reports from the Authority and for the Period from June 16, 2023 through December 15, 2023 and December 16, 2022 through July 15, 2023, we read extermination, heat outage, mold inspections, annual apartment inspections, and elevator outage reports for the months of February 2023; April 2023; July 2023; September 2023 and November. 2023. During our audit, we noted that the Authority did not complete all corrective actions in the 2023 audit period and is in the process of addressing these issues. Recommendation We recommend that the Authority continue to ensure that all environmental contaminates are properly remediated during the audit period through the HUD Agreement. Corrective Action Plan In January 2019, the Authority entered into the HUD Agreement to address building conditions, including conditions related to lead-based paint, mold, pests, elevators, and heating. Among other things, the HUD Agreement appointed a federal Monitor and established three new Departments – Compliance, Environmental Health & Safety, and Quality Assurance. It also required the promulgation of action plans around these health and safety issues and other items. These action plans are publicly available https://www1.nyc.gov/site/nycha/about/reports.page, along with other reports on health and safety issues, which detail the Authority’s efforts to inspect for and correct deficiencies associated with environmental contaminants like lead-based paint and mold. The Authority plans to continue to work to address these health and safety issues, and to work towards meeting the multi-year obligations laid out in the HUD agreement in addition to the action plans. NYCHA has recorded $4,392,861,000 of pollution remediation obligations as of December 31, 2023, which relates to costs to inspect for, and correct deficiencies associated with environmental contaminants. Action Date Ongoing milestones through January 31, 2039 Final Implementation The latest in time obligation under the HUD Agreement is the Authority’s obligation to abate 100% of the apartment units that contain lead-based paint, and the interior common areas that contain lead-based paint in the same building as those units, by January 31, 2039 Name And Phone Number Of Person Responsible For Implementation Brad Greenburg Chief Compliance Officer 212-306-4240