Corrective Action Plans

Finding 479014 (2023-002)

Significant Deficiency 2023

CO

Special Tests & Provisions HUD Housing Programs Significant Deficiency

HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County con...

HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County continue to train personnel so that the inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2023, performance issues with the administration of the HOME program were discovered, to include the absence of required inspections. With significant turnover of tenured leadership and employees within the Community Resources Department, Arapahoe County Community Resources took proactive measures in 2023 for review of the Community Development Housing and Homeless Services (CDHHS) programs by recognized consultants within the field. Community Resources has contracted with two consultants, to assist in a full review and re-development of policies and procedures (Civitas) for the CDBG and HOME programs as well as a full review of all case files (Affordable Housing Consultants). Included with this response are the contracts with both Civitas and Affordable Housing Consultants for verification purposes. The County anticipates their work to be completed and an implementation of updated policies and procedures for these programs by fall of 2024. The role of Program Administrator over the HOME program was not filled until April of 2024. This role will be responsible for all future HOME program inspections. Community Resources CDHHS employees will be taking part in a two-day training in June 2024 (June 11th and 12th, 2024) for the following:  Davis Bacon & Related Acts (Applicability, wage determinations, payroll review, interviews, common errors and how to correct)  Section 3 (Applicability, Safe Harbor benchmarks, documenting compliance, qualitative efforts)  TBRA Inspections (National Standards for the Physical Inspection of Real Estate (NSPIRE) administrative procedures)  HOME Program - Implementation and Best Practices - Arapahoe County, CO - June 12, 2024  This HOME training is an introductory course focusing on underwriting and subsidy layering requirements.  Eligible Activities (Homeowner rehab programs, Homebuyer programs, Rental housing)  Underwriting (Subsidy layering and underwriting requirements and best practices)  Community Housing Development Organization (CHDO) (Requirements, best practices, management, etc)  Long-term Compliance (HOME Match, eligible beneficiaries, income limits, subsidy layering & limits, affordability, written agreements, etc)  IDIS and Reporting Arapahoe County staff will be conducting monitoring of the two Tenant Based Rental Assistance (TBRA) programs and projects within in the affordability period (20-year span) between mid-June to mid-August of 2024. The remaining HOME program projects, within the affordability period (20-year span) will have audits completed by the end of our 2023 grant cycle, September 30th, 2024. Name of the contact person responsible for corrective action: Katherine Smith Planned completion date for corrective action plan: September 30, 2024

View Audit 315527

Finding 478886 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Seattle

WA

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties § 200.302

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payme...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Housing Choice Voucher department is addressing inspection controls in multiple ways. The Department has added additional staffing and also has created new tracking that makes it easier to review and identify units that have not passed inspection and not been abated. The Department has also instituted an ongoing process that has the inspections manager conducting a monthly review of units moving through the abatement process to ensure timely processing and cessation of HAP payments as needed. As part of this review the Department is also conducting a comprehensive review of units that have prior failed inspections to ensure abatement occurred. Name of the contact person responsible for corrective action: Mark La Brayere Planned completion date for corrective action plan: Three elements are continuous with no final completion date. The singular comprehensive review is scheduled to be completed within three months.

View Audit 315516 Questioned Costs: $1

Finding 478876 (2023-001)

None 2023

Palermo Lakes, Inc.

FL

HUD Housing Programs Reporting

Oversight Agency for Audit, Palermo Lakes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit per...

Oversight Agency for Audit, Palermo Lakes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2023 through December 31, 2023 The finding from the December 31, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2023-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should make sufficient deposits to the escrow accounts in a timely manner. Action Taken: New procedures have been implemented to ensure appropriate amounts are reserved in escrow. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

View Audit 315508

Finding 478772 (2023-003)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

HUD Housing Programs Reporting Significant Deficiency § 200.303

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that performance reports are prepared and reviewed by separate individuals. Documentation will be ...

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that performance reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of annual report.

View Audit 315421

Finding 478682 (2023-001)

None 2023

Nueces County Housing Assistance, Inc.

TX

Cash Management HUD Housing Programs

Management will prepare the surplus cash calculation in a matter timely enough to ensure any required deposit to the residual receipts account is made within 90 days of year-end.

View Audit 315316

Finding 478658 (2023-001)

Significant Deficiency 2023

Northwest Regional Housing Authority

AR

HUD Housing Programs

Northwest Regional Housing Authority Abatement process will be enforced. There were several issues last year with inability to get materials and labor. Northwest Regional Housing Authority over road abatement when this was the issue. We will keep better records of abatements. Moving forward, we will...

Northwest Regional Housing Authority Abatement process will be enforced. There were several issues last year with inability to get materials and labor. Northwest Regional Housing Authority over road abatement when this was the issue. We will keep better records of abatements. Moving forward, we will follow the abatement requirements as required.

View Audit 315249

Finding 478560 (2023-001)

None 2023

Carlisle Senior Housing Associates

PA

Cash Management HUD Housing Programs

The delinquent deposit will be made Tuesday May 21, 2024. In the future, the calculation will be done in February and if there is surplus cash, the funds will be deposited within the required time period.

View Audit 315189

Finding 478409 (2023-003)

Significant Deficiency 2023

Johnnie B. Moore Towers, Inc.

GA

HUD Housing Programs

Management is in agreement with the finding and will adhere to the requirements set forth in the HUD Handbook going forward and reinstate the fidelity bond insurance policy in accordance with HUD regulations.

View Audit 315100

Finding 478408 (2023-002)

Significant Deficiency 2023

Johnnie B. Moore Towers, Inc.

GA

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

In accordance with HUD regulations, entities should not make unauthorized distributions of project funds. The project paid expenses for an adjacent property. The Corporation paid non-project expenses from Project funds. The Project is noncompliant with the HUD regulatory agreement. Expense allocatio...

In accordance with HUD regulations, entities should not make unauthorized distributions of project funds. The project paid expenses for an adjacent property. The Corporation paid non-project expenses from Project funds. The Project is noncompliant with the HUD regulatory agreement. Expense allocations should be closely monitored to ensure Project funds are not used for non-project expenses.

View Audit 315100 Questioned Costs: $1

Finding 478371 (2023-001)

Significant Deficiency 2023

Boston Tremont Housing Development Fund Corporation

NY

Eligibility HUD Housing Programs Reporting

Corrective Action Plan Project Legal Name: Boston Tremont Housing Development Fund Corporation HUD Project Nos.: NY 36L000080 and NY 36L000081 Audit Firm: CohnReznick LLP Period covered by the audit: December 31, 2023 Corrective Action Plan prepared by: Name: Lukeman Ogunyinka Position: Chief Financ...

Corrective Action Plan Project Legal Name: Boston Tremont Housing Development Fund Corporation HUD Project Nos.: NY 36L000080 and NY 36L000081 Audit Firm: CohnReznick LLP Period covered by the audit: December 31, 2023 Corrective Action Plan prepared by: Name: Lukeman Ogunyinka Position: Chief Financial Officer Telephone Number: (212) 243-9090 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2023-1 a. Comments on the Finding and Each Recommendation 4 out of 26 tenants tested did not have an annual tenant recertification Form HUD 50059 completed timely. Moving forward, management will follow established procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with the guidelines specified by HUD. b. Action(s) Taken or Planned on the Finding Management has addressed the issue by recertifying the tenant and does not expect a late recertification to occur again based on procedures in place.

View Audit 315050

Finding 478356 (2023-004)

Material Weakness 2023

Alpena Housing Commission

MI

Questioned Costs Special Tests & Provisions HUD Housing Programs

Capital Fund Program – CFDA 14.872 Recommendation: The Commission should review the obligation and expenditure of capital grants on an ongoing basis and implement policies and procedures to ensure all federal compliances are followed pertaining to obligation and expenditures verification. Action Tak...

Capital Fund Program – CFDA 14.872 Recommendation: The Commission should review the obligation and expenditure of capital grants on an ongoing basis and implement policies and procedures to ensure all federal compliances are followed pertaining to obligation and expenditures verification. Action Taken: New Management has taken over as of March 2023 and will review and implement stronger policies and procedures pertaining to capital fund grants. Anticipated Completion Date of Action: December 31, 2024.

View Audit 315015 Questioned Costs: $1

Finding 478278 (2023-004)

Significant Deficiency 2023

Crookston Housing and Economic Development Authority

MN

HUD Housing Programs Reporting Significant Deficiency

1. Correcting Plan CHEDA staff are aware of Voucher for Payment of Annual Contributions and Operating Statement report monthly to HUD via the Voucher Management System (VMS) requirements and will implement appropriate review of statements prior to submission. 2. Explanation of Disagreement with the ...

1. Correcting Plan CHEDA staff are aware of Voucher for Payment of Annual Contributions and Operating Statement report monthly to HUD via the Voucher Management System (VMS) requirements and will implement appropriate review of statements prior to submission. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 314956

Finding 478277 (2023-003)

Significant Deficiency 2023

Crookston Housing and Economic Development Authority

MN

HUD Housing Programs Eligibility Significant Deficiency

1. Correcting Plan CHEDA staff are aware of income eligibility documentation and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – Execut...

1. Correcting Plan CHEDA staff are aware of income eligibility documentation and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 314956

Finding 478276 (2023-002)

Material Weakness 2023

Crookston Housing and Economic Development Authority

MN

Allowable Costs / Cost Principles HUD Housing Programs

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – E...

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 314956

Finding 478275 (2023-001)

Significant Deficiency 2023

Watertown Housing Authority

MA

Eligibility HUD Housing Programs Allowable Costs / Cost Principles

Name of Auditee: Watertown Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2023 CAP Prepared by: Michael Lara, Executive Director Phone: (617) 923-3950 (A) Current Findings on the Schedule of Findings and Questioned Costs (1) Finding 2023-001 (a...

Name of Auditee: Watertown Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2023 CAP Prepared by: Michael Lara, Executive Director Phone: (617) 923-3950 (A) Current Findings on the Schedule of Findings and Questioned Costs (1) Finding 2023-001 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action taken. (b) Action taken - The Authority’s HCV program coordinator will review records in each tenant’s file to ensure all required documents are present. (c) Planned implementation date of corrective action - Completed by December 31, 2024.

View Audit 314952

Finding 478208 (2023-001)

Significant Deficiency 2023

Archdiocesan Housing Authority

WA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Management has implemented a quarterly inspection schedule of all units with documentation centrally located for visibility.

View Audit 314901

Finding 478206 (2023-001)

Significant Deficiency 2023

Providence Manor Development Corporation

GA

Questioned Costs HUD Housing Programs

Amounts paid to management company exceed amounts dictated in agreement and approved by HUD. Management fees were overpaid during the year ended December 31, 2023. Controls were not in place to ensure managemennt fees were calculated and paid in accordance with the agreement. The effect is that the ...

Amounts paid to management company exceed amounts dictated in agreement and approved by HUD. Management fees were overpaid during the year ended December 31, 2023. Controls were not in place to ensure managemennt fees were calculated and paid in accordance with the agreement. The effect is that the project is not in compliance with HUD requirements. Policies and procedures will be reviewed to ensure management fees are paid in accordance with executed agreements as required by HUD.

View Audit 314896 Questioned Costs: $1

Finding 478202 (2023-003)

Significant Deficiency 2023

Anderson Place Apartments, Inc.

IN

HUD Housing Programs Cash Management

The management of Anderson Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will contact HUD to ensure that all excess residual receipts are remitted to HUD as soon as possible.

View Audit 314892

Finding 478199 (2023-003)

Significant Deficiency 2023

Edsil's Place Apartments, Inc.

KY

HUD Housing Programs Cash Management

The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will contact HUD to ensure that all excess residual receipts are remitted to HUD as soon as possible.

View Audit 314891

Finding 478191 (2023-002)

Significant Deficiency 2023

Alliance Apartments Housing Development Fund Co., Inc.

NY

Cash Management HUD Housing Programs Matching / Level of Effort / Earmarking

We have requested HUD approval to delay reimbursement of the reserves pending receipt of Budget Based Rent increase. We anticipate that this will be approved.

View Audit 314887

Finding 478187 (2023-003)

Material Weakness 2023

Jackson Housing Commission

MI

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

Finding 2023-003 - Lack of Data Available to Audit Federal Compliance Requirements Applicable to the Section 8 Housing Choice Program (Material Weakness, Potential Material Noncompliance) Public Housing Program -Assistance Listing No. 14.871; Grant period - fiscal year ended March 31,2023 Condition:...

Finding 2023-003 - Lack of Data Available to Audit Federal Compliance Requirements Applicable to the Section 8 Housing Choice Program (Material Weakness, Potential Material Noncompliance) Public Housing Program -Assistance Listing No. 14.871; Grant period - fiscal year ended March 31,2023 Condition: We did not attain sufficient supporting data in order to audit the Commission's compliance with the Allowable Activities, Allowable Costs , Eligibility, Reporting and Special Tests and Provisions compliance requirements applicable to the Section 8 Housing Choice Voucher Program. Contact person responsible for corrective action: Arturo Puckerin Corrective action planned: The authority hired a new financial fee accountant to review the internal controls and the state of the Authority's financials as of fiscal year 2023 forward. The authority was able to correct the HUD REAC Financial Data Schedule for the audited financials for fiscal year 2023, record the pension and other post-retirement employment benefits balances and begin work on reconstructing the capital asset register. The authority has integrated proper financial and accounting internal controls through the accounts payable, cash receipts, payroll and accounting entries during fiscal year 2024. The authority has the financial fee accountant work with accounting and program staff to ensure the financials are materially stated monthly, hud reporting is completed on a timely basis with materially stated financial and operational information and the executive staff is reviewing the appropriate financial information. The board approved the fiscal year 2025 budget which was in balance and set the course for continued improvement of financial reporting and proper internal controls over financial reporting. The Authority has reconciled the (HCVP) activities to the account ledgers for program, housing assistance payments, subsidies received by type and other income through fiscal year-end 2024 and forward. Anticipated completion date: March 31, 2024

View Audit 314861

Finding 478186 (2023-004)

Material Weakness 2023

Jackson Housing Commission

MI

HUD Housing Programs Special Tests & Provisions Procurement, Suspension & Debarment

Finding 2023-004 - Lack of Data Available to Audit Federal Compliance Requirements Applicable to the Public Housing Capital Fund Program (Material Weakness, Potential Material Noncompliance) Public Housing Program-Assistance Listing No.14.872; Grant period-fiscal year ended March 31,2023 Condition: ...

Finding 2023-004 - Lack of Data Available to Audit Federal Compliance Requirements Applicable to the Public Housing Capital Fund Program (Material Weakness, Potential Material Noncompliance) Public Housing Program-Assistance Listing No.14.872; Grant period-fiscal year ended March 31,2023 Condition: We did not attain sufficient supporting data in order to audit the Commission's compliance with the Allowable Activities, Allowable Costs, Cash Management, Procurement and Special Tests and Provisions compliance requirements applicable to the Capital Fund Program . Contact person responsible for corrective action: Arturo Puckerin Corrective action planned: The authority hired a new financial fee accountant to review the internal controls and the state of the Authority's financials as of fiscal year 2023 forward. The authority was able to correct the HUD REAC Financial Data Schedule for the audited financials for fiscal year 2023, record the pension and other post-retirement employment benefits balances and begin work on reconstructing the capital asset register. The authority has integrated proper financial and accounting internal controls through the accounts payable, cash receipts, payroll and accounting entries during fiscal year 2024. The authority has the financial fee accountant work with accounting and program staff to ensure the financials are materially stated monthly, hud reporting is completed on a timely basis with materially stated financial and operational information and the executive staff is reviewing the appropriate financial information. The board approved the fiscal year 2025 budget which was in balance and set the course for continued improvement of financial reporting and proper internal controls over financial reporting. The Authority has reconciled the Capital fund accounting activity to the respective Capital Fund approved budgets by active program years, reconciled drawdowns and properly recorded the expenditures and drawdown by respective grant years and applicability to Asset Management Properties. Anticipated completion date: March 31, 2024

View Audit 314861

Finding 478185 (2023-002)

Material Weakness 2023

Jackson Housing Commission

MI

HUD Housing Programs Special Tests & Provisions Procurement, Suspension & Debarment

Finding 2023-002 - Lack of Data Available to Audit Federal Compliance Requirements Applicable to the Public Housing Program (Material Weakness, Potential Material Noncompliance) - Continued Corrective action planned: The authority hired a new financial fee accountant to review the internal controls ...

Finding 2023-002 - Lack of Data Available to Audit Federal Compliance Requirements Applicable to the Public Housing Program (Material Weakness, Potential Material Noncompliance) - Continued Corrective action planned: The authority hired a new financial fee accountant to review the internal controls and the state of the Authority's financials as of fiscal year 2023 forward. The authority was able to correct the HUD REAC Financial Data Schedule for the audited financials for fiscal year 2023, record the pension and other post-retirement employment benefits balances and begin work on reconstructing the capital asset register. The authority has integrated proper financial and accounting internal controls through the accounts payable, cash receipts, payroll and accounting entries during fiscal year 2024. The authority has the financial fee accountant work with accounting and program staff to ensure the financials are materially stated monthly, hud reporting is completed on a timely basis with materially stated financial and operational information and the executive staff is reviewing the appropriate financial information. The board approved the fiscal year 2025 budget which was in balance and set the course for continued improvement of financial reporting and proper internal controls over financial reporting. Anticipated completion date: March 31, 2024

View Audit 314861

Finding 478184 (2023-002)

None 2023

Desoto Parish Police Jury

LA

HUD Housing Programs

The Police Jury will adhere to the standards required by the Section 8 administative plan by placing the performed annual inspections in the unit files.

View Audit 314858

Finding 478181 (2023-002)

None 2023

Plainfield Housing Authority

CT

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

In the past, the Housing Authority has completed Rent Reasonableness forms for every new and existing tenant by referring to a rent comparison log that is periodically updated and l<ept in the office. Every tenant has the form in their files and the FMR guidelines were always adhered to assure that ...

In the past, the Housing Authority has completed Rent Reasonableness forms for every new and existing tenant by referring to a rent comparison log that is periodically updated and l<ept in the office. Every tenant has the form in their files and the FMR guidelines were always adhered to assure that the rents proposed by Landlords were reasonable. The Plainfield Housing Authority has now contracted with RentWatch as of January 4, 2024, which allows the Housing Authority to see comparable rents and automatically produces Rent Reasonable reports to print and put in tenant files.

View Audit 314846

Corrective Action Plans

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