Corrective Action Plans

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

WIA management will implement the following corrective action plan: In order to ensure compliance with the timeliness of disbursements of federal funds contemplated under 2 CFR 200.305(b), WIA will implement the following additional procedures for federally-funded expenses. A detailed evaluation of project deliverables and timelines will be conducted by the Project Manager and Project Director for any program subject to compliance with Federal guidelines. The timelines, deliverables and affected funding mechanism(s) will be aligned to determine if there may be a delay beyond a reasonable period which would impact the submission and processing of payments to subcontractors. If it is determined that a delay is possible or likely, consideration will be given to contract amendments which better support the processing of payments aligned with 2 CFR 200.305(b). Further, the Finance team member assigned to the associated program will provide regular guidance to the project team which may include a detailed briefing on the CFR and any relevant concerns with cash management. Disbursements of federal funds will be issued in a timely manner in all instances. The additional set of procedures described above will be implemented in September 2024. In addition, we are currently working through finalizing the contract for Phase 2 of the specific contract related to this finding. We anticipate these negotiations will be completed by October 31st, 2024. Once the Phase 2 agreement has been reached, we will immediately release the Phase 1 funds to the vendor and obtain guidance from The Ohio State University as to the proper disposition of any interest that has been earned by WIA from the withheld Phase 1 payment. Marta Sokol, Chief Financial Officer is the individual responsible for oversight of this corrective action plan. Mrs. Sokol can be reached at 703.535.7447 or Marta.Sokol@wia.org.

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2023 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2023-002 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) – Significant Deficiency Description of Finding: There was no evidence of review and approval by someone other than the preparer of the FFATA subawards that were submitted to the FSRS. The FFATA subawards were not submitted timely to the Federal Funding Accountability and Transparency Act Subaward Reporting System (“FSRS”). Statement of Concurrence: We concur with the finding above. Corrective Action: As of September 1, 2023, BCHN implemented a workflow where FFATA information will be reported to the FSRS upon receipt of the Notices of Award. In addition, as of September 9, 2024, the FFATA report will be reviewed by someone other than the preparer prior to submission and evidence of the approval maintained. Completion Date: September 9, 2024. Name of Contact Person: James Paine, Ph.D. Chief Executive Officer Tel. No.: (718) 405-4993 E-mail: jpaine@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call James Paine at (718) 405-4993. Sincerely yours, _________________________ James Paine, Ph.D. Chief Executive Officer

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to maintain tenant security deposits in a separate bank account in an amount adequate to cover the security deposit liability. The security deposit bank account balance was not adequate to cover the security deposit liability. Recommendation: Recommend management fund the security deposit account in an amount that is adequate to cover the security deposit liability. There is no disagreement with the audit finding. Action taken in response to finding: We have funded the security deposit account in an amount adequate to cover the security deposit liability. Name of the contact person responsible for corrective action: Cassandra Johnson Planned completion date for corrective action plan: July 2024

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to retain the HUD approved management agreement to ensure payments made are in accordance with HUD requirements. The Project does not have a HUD approved management agreement. Recommendation: Recommend that management work with HUD to have the current management agreement approved. There is no disagreement with the audit finding. Action taken in response to finding: We have contacted HUD to obtain an approved management agreement. Name of the contact person responsible for corrective action: Cassandra Johnson Planned completion date for corrective action plan: September 2024

Corrective Action Plan Finding: Finding 2023-002-Lack of Adequate Quality Control Regarding Tenant Procedures-Eligibility Condition: The quality of supervision over tenant file functions, such as calculating tenant rent and Housing Assistance Payments should be timely and sufficient to find errors in calculations or mis-application or mis-understanding of procedures. Corrective Action Planned I am Jedidiah Jackson. I was hired as E.D., effective July 1, 2024. We are in the process of addressing the problems noted in the audit, as well as correcting other issues noted by HUD. Person responsible for corrective action: Jedidiah Jackson, E.D. Telephone: (985) 785-2601 St. Charles Parish Housing Authority Fax: (985) 785-6238 200 Boutte Estates Dr. Boutte, LA 70039 Anticipated Completion Date- October 31, 2024

ST. CHARLES PARISH HOUSING AUTHORITY________________________________________PHONE: 985-785-2601 ·FAX:985-785-6238· 200 BOUTTE ESTATES DRIVE ·BOUTTE, LA 70039-0448 ________________________________________ HOUSING AUTHORITY OF ST. CHARLES PARISH, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2023 Corrective Action Plan Finding: Finding 2023-001-Internal Controls Inadequate for Disbursements-Allowable Costs Condition: Good internal controls should be in place to make sure that disbursements are for eligible payments, are correctly classified, and are timely paid. Good controls ensure that there is proper, documented review of all these functions. Records should be maintained in an order that is conducive to efficient and timely summarizing by the outside fee accounting firm. Unaudited financial statements should be produced on a timely basis, and reviewed by the Board of Commissioners. Corrective Action Planned I am Jedidiah Jackson. I was hired as E.D., effective July 1, 2024. We are in the process of addressing the problems noted in the audit, as well as correcting other issues noted by HUD. Person responsible for corrective action: Jedidiah Jackson, E.D. Telephone: (985) 785-2601 St. Charles Parish Housing Authority Fax: (985) 785-6238 200 Boutte Estates Dr. Boutte, LA 70039 Anticipated Completion Date- October 31, 2024

Action Taken: MHA will review and enhance as necessary the program’s existing quality control (QC) file review procedures as well as daily data validation reports to include a measure that cross-checks existing reports in the Yardi system of record and aids in validating data routinely submitted to HUD’s PIC system. To further mitigate the risk posed by frequent turnover among Housing Specialist-I (HS-I) staff, MHA will increase the frequency of training on rent and income determination for all staff including tenured team members and new hires, alike, to occur quarterly. In 2023, MHA implemented a Housing Specialist-II Team Lead to oversee HS-I staff processing annual reexaminations in accordance with 24 CFR 982.516. This team member is responsible for ensuring families are notified in a timely manner and if they do not comply with the annual reexamination requirement, they receive termination notices in compliance with HUD and MHA Administrative Plan requirements. MHA also implemented two compliance analysts in 2023; we will add another compliance analyst staff person in 2024 to increase the percentage of files undergoing quality control review. These three (3) Compliance Analyst will report to the Operations and Compliance Manager who monitors HUD’s PIC system and analyzes discrepancies between PIC data and MHA data housed in the Yardi system of record. This information is maintained in the program file. Name of Responsible Person: Paul and Magdalene Watkins, Program Administration Team Projected Completion Date: 12/31/2024

1. Finding 2023-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding and will implement the auditor’s recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action(s) Taken or Planned on the Finding Action 1-The residence director, building office staff, and accounting staff will be informed of the HUD requirements regarding the timely refund of security deposits. Action 2-The residence director and building office staff will immediately notify the accounting staff of all move outs by email so that a security deposit refund check can be promptly issued. Action 3-The asset management staff will review the accounts payable aging on a weekly basis to ensure that all security deposit refund checks have been issued. b. Support staff has been brought in to lighten the workload of the fiscal staff allowing them the time to ensure that the return of the security deposits are processed in a timely manner.

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Although the Housing Director processed the Final Accounting Statement in a timely manner and requested that the security deposit be returned to the tenant, the Accounts Payable Department missed the request. As staff have been covering two, sometimes three positions, adequate attention was not given to this item. This year, we have brought additional help to support the Fiscal Department. This support staff has allowed the key members of the fiscal team to work with a manageable workload and at a pace that will ensure that security deposits will be returned within 30 days of a tenant’s departure.

Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action 1-The residence director, building office staff, and accounting staff will be informed of the HUD requirements regarding the timely refund of security deposits. Action 2-The residence director and building office staff will immediately notify the accounting staff of all move outs by email so that a security deposit refund check can be promptly issued. Action 3-The asset management staff will review the accounts payable aging on a weekly basis to ensure that all security deposit refund checks have been issued.