Corrective Action Plans

2023-001 - Determination of Contract Rents, Maintenance of Tenant Files Condition: Eligibility recertification procedures required as a part of the annual recertification have not been performed or not performed sufficiently for tenants housed as of December 31, 2023. Corrective Action Planned: Staff has worked diligently to get all tenants housed at the Housing Authority recertified with sufficient documentation. Management believes all issues with tenant files to be corrected as of the report date. Staff are to receive continued education training on the operations of the RAD program and the compliance requirements. Person responsible for corrective action: Akinola Popoola, Executive Director Telephone: (256) 232-5300 x 8 Trudi Harris, Property Manager Anticipated Completion Date: Management believes files have been corrected as of the 2023 year-end audit report date.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2023-001: Major Programs: Major Program: Section 202 Supportive Housing for the Elderly, Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all tenants’ 90-day EIV reports are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. ACTION TAKEN The Project will be monitoring use of the EIV system for move ins and recertifications.

Section 8 Housing Choice Vouchers Program -Finding 2023-002 Finding – Of a sample size of 25 units that previously failed inspection, one unit did not pass reinspection within 30 days. Housing assistance payments were not abated nor was the tenant evicted resulting in questioned cost of $3,412. This is considered a significant deficiency in internal controls over compliance for special tests and provisions type of compliance related to Housing Quality Standards (HQS) inspections. The Agency has not properly performed HQS inspections in compliance with program requirements. Recommendation – The Agency design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Corrective Action – The Agency will increase oversight in the Section 8 Housing Choice voucher Program with respect to following up on units that previously failed inspections in accordance with HQS to ensure that established internal control policies are being followed on a timely basis. Implementation Date – August 1, 2024

Finding – Of a sample size of 21 tenant files, income was miscalculated on one file resulting in questioned costs of $304. This is considered a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Agency has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Recommendation – The Agency design and implement internal control procedures that will reasonably assure compliance with Uniform Guidance and the compliance supplement. Corrective Action - The Agency will increase oversight in the Section 8 Housing Choice voucher Program with respect to calculated income to ensure that established internal control policies are being followed on a timely basis. Implementation Date -August 1, 2024

Finding Reference Number: 2023-001 Description of Finding: Virginia Supportive Housing (the Agency), was undergoing staff and programmatic reorganization during the time required to submit the audit. This resulted in the Agency being unable to timely meet the compliance audit testing in a timely manner and submit the completed audit package to the Federal Audit Clearinghouse (FAC) by the statutory deadline. Statement of Concurrence or Nonconcurrence: The Agency agrees with the audit finding. Corrective Action: The corrective action was for the Agency to submit the completed audit package to the Federal Audit Clearinghouse (FAC). Status of Corrective Action: Completed. Name of Contact Person: W. Carter Dages, Jr., Director of Finance; (804) 314-7870; cdages@SupportWorksHousing.org Projected Completion Date: Report was filed on October 3, 2024.

SIGNIFICANT DEFICIENCY 2023-002 Deposit of surplus cash to residual receipts more than 90 days Recommendation: Management should continue to evaluate their internal policies and procedures to ensure surplus cash is deposited within 90 days of year-end. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management adopt policies of earlier deposit or switch to electronic methods. Name of the contact person responsible for corrective action: Nicole Chwala, CEO Planned completion date for corrective action plan: December 2024

FINDING 2023-003: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will immediately transfer the delinquent surplus cash to the residual receipts reserve account and implement robust internal controls to ensure all future deposits are made promptly and in compliance with the Regulatory Agreement. Action Taken: Management has transferred the overdue amount to the residual receipts reserve account and implemented enhanced internal controls to prevent future non-compliance.

FINDING 2023-002: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement a comprehensive internal control system to ensure all tenant files include required documentation, and will conduct a thorough review of all current tenant files to verify compliance and completeness. Action Taken: Ownership agrees with the auditor’s finding and recommendation and has hired a new management agent to oversee the implementation of a comprehensive internal control system, ensuring all tenant files include required documentation

FINDING 2023-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement internal controls to ensure timely monthly contributions to the replacement reserve and will address the shortfall by making up the missed deposits in the subsequent period alongside the normal required contributions. Action Taken: Management will make the necessary required deposits to bring the balance of the reserve for replacement in alignment with requirements of Section 811 Capital Advance Program Regulatory Agreement.

FINDING 2023-002: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement internal controls to ensure timely monthly contributions to the replacement reserve and will address the shortfall by making up the missed deposits in the subsequent period alongside the normal required contributions. Action Taken: The Organization will make the necessary required deposits to bring the balance of the reserve for replacement in alignment with requirements of Section 811 Capital Advance Program Regulatory Agreement.

FINDING 2023-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement a comprehensive internal control system to ensure all tenant files include required documentation, and will conduct a thorough review of all current tenant files to verify compliance and completeness. Action Taken: Ownership agrees with the auditor’s finding and recommendation and has hired a new management agent to oversee the implementation of a comprehensive internal control system, ensuring all tenant files include required documentation.

Subsequently, on August 2024, the shortfall in the reserve for replacement was funded.

CORRECTIVE ACTION PLAN Name and Number of the Project: Alamo Area Mutual Housing Association Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2023 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING 2023-003: Section 223(a)(7) HUD Insured Loan, Assistance Listing 14.135 - AAMHA Western Hills, LLC HUD Project No. 115-115888, AAMHA KPTP, LLC HUD Project No 115-35652 and Section 223(f) HUD Insured Loan, Assistance Listing 14.155 - AAMHA Calcasieu, LLC HUD Project No 115-11280Section 223(a)(7) HUD Insured Loan, Assistance Listing 14.135. Entity expenses and receipts were recorded on the incorrect project’s books. CORRECTIVE ACTION COMPLETED: a. AAMHA Western Hills, LLC - On April 24, 2024, $3,199 was received from an affiliate. b. AAMHA KPTP, LLC - During 2023, $16,321 was received from affiliates. On May 10, 2023, the Project received $8,027. c. AAMHA Calcasieu, LLC – On April 16, 2024, the Project received $5,869 from an affiliate. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Any questions regarding the above corrective action plan should be directed to Christine Drennon, Executive Director.

Finding 2023-003 – Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: We appreciate the audit team's diligence in reviewing our financial processes and acknowledge the finding related to the untimely reserve deposit. 1. Explanation: Example: "The delay in making the reserve deposit was primarily due to management not fully understanding HUD fund authorization per the HUD Handbook 4350. 2. Corrective Actions Taken: We have taken the following corrective actions: All reserve funds have been deposited in the appropriate reserve accounts at our bank. We have implemented a revised deposit schedule that will deposit reserve funds as required after receipt of direct deposit voucher payment from CMS. 3. Preventive Measures: To prevent a recurrence of this issue, we have instituted additional preventive measures, including producing monthly financial reports showing the deposits in a bank reconciliation line of the item and on the balance sheet. 4. Commitment to Compliance: We uphold the highest financial responsibility and compliance standards. Moving forward, we will remain vigilant to ensure timely reserve deposits and will continue to prioritize adherence to all relevant regulations and internal policies."

Finding 2023-002 – Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: Explanation: We acknowledge the oversight and would like to provide context to understand better the circumstances that led to the delay. We had internal challenges when our previous management company departed, leaving us with incomplete files and late recertifications or recertifications that never started, making it next to impossible to catch up promptly. Next, staff staffing issues contributed to the delays because staff members were not properly trained. Despite these challenges, we recognize the importance of adhering to HUD regulations and are committed to taking corrective measures. Corrective Actions Taken: We initiated immediate corrective actions to rectify the situation upon discovering the late recertifications. We have instituted the following measures to prevent the recurrence of late annual recertifications. 1. Created a recertification schedule and calendar with the annual recertification date, specific dates to notify residents that their annual recertification is due, and dates for submitting the information to CMS and to trac. The schedule and calendar are submitted to the executive director every two weeks to monitor progress, and a meeting is scheduled with staff every two weeks to review recertification issues. 2. We hired a consultant specializing in recertification to train the staff and work with staff daily to answer questions concerning our certification. This is not a one-anddone; our recertification consultant is permanently on call to answer certification issues and continuous staff training. These measures are designed to ensure timely compliance with HUD regulations and to strengthen our internal processes.

Finding 2023-001: The Organization did not retain a printed and dated copy of the Failed Verification and Failed EIV Prescreen reports for two out of twelve months of the year. Recommendations (2023-001-a): Auditor recommends that management reevaluate its system and procedures to ensure that the required reports are printed and retained on the required schedule with clear dates of printing, going forward. View of Responsible Officials: Management concurs with this finding and agrees with the auditor’s recommendation. Management considers corrective action to be completed and will reevaluate its system to ensure future compliance.

September 25, 2024 Management's Planned Corrective Action Plan For the Year Ended December 31, 2023 Names of contact person(s) responsible for corrective action: Georgina Acevedo, Chair and Kevin McAllister, Treasurer Federal Award Finding and Questioned Costs Finding Number: 2023-001 - Supportive Housing for the Elderly (Section 202) - CFDA # 14.157 Planned Corrective Action: The Board of Directors acknowledges the required deposits to the replacement reserve account were not made. The Project is applying for a rent increase and deposits will be made as soon as the cash position is available to make the required deposits. Anticipated Completion Date: Upon approval of the rent increase.

September 25, 2024 Management's Planned Corrective Action Plan For the Year Ended December 31, 2023 Names of contact person(s) responsible for corrective action: Malcolm A. Punter, President Federal Award Finding and Questioned Costs Finding Number: 2023-001 - Supportive Housing for the Elderly (Section 202) - CFDA # 14.157 Planned Corrective Action: The Board of Directors acknowledges the required deposits to the replacement reserve account were not made. Management will transfer the funds as soon as the cash position is available to make the required deposits. Anticipated Completion Date: Upon availability of cash flows.

Management concurs with the findings and is working to ensure all employees adhere to control procedures and compliance requirements set by HUD. For finding 2023-003, the Organization is working to deposit surplus cash into a residual receipts account.

Management concurs with the findings and is working to ensure all employees adhere to control procedures and compliance requirements set by HUD. For finding 2023-002, the Organization is working to transfer the funds into an interest-bearing account.

Managing agent subsequently obtained approval from HUD for the questioned replacement reserve withdrawal. All replacement reserve withdrawals will obtain prior approval from HUD.

2023-005 Special Tests and Provisions – Waiting List Moving to Work Demonstration Program AL No. 14.881 Other Matter to be Reported Under the Uniform Guidance Condition: While testing of applicants that reached the top of the waiting list during the year ended December 31, 2023, the Authority was unable to provide sufficient documentation for one of the applicants to support their position on the list. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to waiting list selection process and document retention requirements. Action Taken: The Houston Housing Authority agrees with this finding. A review of existing procedures revealed that there were issues with the management of the waiting lists. The Houston Housing Authority is transitioning to a new software program during 2024. One of the reasons for the implantation of the new software is to make use of a better wait list management feature that is available within the new software. Waitlists have been reviewed and purged of stale an do dated information which will facilitate better management of the waitlist for future periods.

2023-004 Eligibility Section 8 Project-Based Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 670 of tenants, 20 tenant files were tested and the following deficiencies were noted: • Nine files did not have annual recertifications performed during the year, • Eight files did not have 9886 release of information forms within 15 months of annual recertification, • Six files did not have an annual recertification performed within 12 months, • Six files did not have documentation necessary to verify the reported income, and • Three files did not have a 214 declaration form for all members of the household. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that a HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. Because the file clean up work was being performed in calendar year 2024 we expected this finding would be present for the 2023 audit. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024

2022-003 Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 484 of Housing Voucher Cluster tenants the following deficiencies were noted: Mainstream Voucher AL #14.879 (a total of 4 tenants selected for testing): • One file did not have an annual recertification performed during the year, • One file did not have an annual recertification performed within 12 months, • Two files did not have 9886 release of information forms within 15 month of the annual recertification, • One file did not have a 214 declaration form for all members of the household, and • One file did not have documentation necessary to verify the reported income. Emergency Housing Voucher AL #14.871 (a total of 5 tenants selected for testing): • Four files did not have an annual recertification performed within 12 months, • Three files did not have a 214 declaration form for all members of the household, • Four files did not have 9886 release of information forms within 15 month of the annual recertification, and • Five files did not have rent reasonableness form performed for the annual certification. The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that a HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. Because the file clean up work was being performed in calendar year 2024 we expected this finding would be present for the 2023 audit. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024. FINDINGS - FEDERAL AWARD PROGRAMS AUDIT 2023-003 Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 1,500 of Housing Voucher Cluster tenants the following deficiencies were noted: Mainstream Voucher AL #14.879 (a total of 5 tenants selected for testing): • Five files did not have supporting documents needed to determine eligibility. Emergency Housing Voucher AL #14.871 (a total of 5 tenants selected for testing): • Four files did not have supporting documents needed to determine eligibility, and • One files did not have an annual recertification performed. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that a HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. Because the file clean up work was being performed in calendar year 2024 we expected this finding would be present for the 2023 audit. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024.

2023-002 Eligibility Moving to Work Demonstration Program AL No. 14.881 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 18,300 of Section 8 Housing Choice Voucher and 2,300 Low Rent Public Housing tenants the following deficiencies were noted: Section 8 Housing Choice Voucher (a total of 40 tenants selected for testing): • Thirty-five files did not have annual recertifications performed during the year, • Nine files did not have 9886 release of information forms within 15 months of annual recertification, • Four files did not have a annual recertification performed with 12 months of the previous certification, • Three file did not have an inspection performed during the year • Three files did not have documentation necessary to verify the reported income, • Two files did not have a 214 declaration for a member of the household, and • Two files did not have documentation necessary to verify custody of dependents. Low Rent Public Housing (a total of 40 tenants selected for testing): • Fourteen files did not contain flat rent options forms, • Ten files did not have documentation necessary to verify the reported income, • Seven files did not have the annual recertification performed or documented, • Five files did not have a 214 declaration for a member of the household, • Three files did not have support necessary to verify income allowances, • Two files did not have 9886 release of information form within 15 months of the annual recertification, and • One file did not have annual recertifications performed within 12 months of the previous annual certification. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected during the final quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that all HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. Because the file clean up work was being performed in calendar year 2024 we expected this finding would be present for the 2023 audit. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the final quarter of 2024.