Corrective Action Plans

Management agrees with finding, will reevaluate salary levels and staffing for HCV program

Corrective Action Plan and Views of Responsible Officials The Corporation will ensure that all monthly deposits to the replacement reserve are made in a timely manner.

Finding 2023-002 - Continuumof Care Tenant Files - Eligibility - Internal Control over Tenant Files - Noncomplianceand Material Weakness Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the follow ing by our fiscal year-end September 30, 2024: a. Program Coordinators will maintain all Contin uum of Care Tenant files in individual file folders designated by special purpose voucher programs. All loosedocuments will be anchored in tenant files. b. An action plan has been developed for the Continuum of Care programs to ensure that all program files are HUD, State, and GHA compliant starting with October l, 2023, files through the current. c. Continuum of Care fiscal year 2024 (October 2023-September 2024) re­ exams and interim s will be caught up and complete as they become effective. All tenant files will be reviewed and compliant by FYE2024. d. All la te/overdue re-exams will be compliant by FYE2024. e. During FYE2024, the Deputy Executive Director/COOwill perform qualit y controls on all Continuum of Care tenant files processed each month prior to ini tialization c2_5th 3olh of each month). f. File checklist sheets will be placed in each file upon quality control review to be signed off by the Deputy Executive Director/COO. g. Additional training will be required and ongoing for Program Coordinators. h. Other internal control measures will be implemented to elim inate future audit findings. Person Responsible: Shanetta Moye, Deputy Executive Director/COO Anticipated Completion Date: September 30, 2024

Finding 2023-001 - Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance andSignificant Deficiency Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the following by our fisca l year-end September 30, 2024: a. Hous ing Choice Voucher tenant files will be reviewed and quality controlled each mo nth prior to initiali za tio n (25t 11- 30 111 of each month) by the Deputy Executive Director/COO. b. An action pla n has been develo ped for the Housing Choice Voucher department to ensure that all Housing Choice Voucher files are HUD and GHA compliant starting with October 1, 2023 files through the cun-e nt. c. Hous ing Choice Voucher calendar-year 2024 (October 2023-September 2024) re-exams are substantially complete, as they become effective. All tenant files will be reviewedand HUD-co mpliant by FYE2024. d. During FYE2024, the Deputy Executive Director/COO will perform 40% quality controls of the monthly re-exams processed by the Housing Specialists. e. File checklist sheets will be placed in each file upon quality control review to be signed off by the Deputy Executive Director/COO. f. Additional training has been and will be made available as necessary. g. Other interna l control measures will be implemented as deemed necessary by the Deputy Executive Director/COO, to eliminate future audit findings. Person Responsible: Shanetta Moye, Deputy Executive Director/COO Anticipated Completion Date: September 30, 2024

Corrective Action: This is a repeat finding, so the Authority was already aware of the deficiency. However, the prior year finding wasn’t issued until midway through the current fiscal year, so efforts to correct the deficiency did not take place until the latter half of the year. Since September of 2023, the Authority has revamped its HQS processes significantly. Responsibility for scheduling and tracking of inspections has been taken out of the hands of the individual inspectors and a single administrative employee has been dedicated to the job of tracking and scheduling inspections and follow-up inspections in order to ensure everything is properly documented and follow up is being done within the required time period.

Finding 2023-016 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Provider Eligibility Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS will amend the managed care contracts to require that signatures are obtained on the Provider Screening Information Collection Tool (PSICT) forms and returned timely when contracts and waivers are renewed and extended. MDHHS expects that signatures will be obtained on the PSICT forms effective September 2024 for the fiscal year 2025 contract cycle. MDHHS continues to send an annual reminder to the managed care entities to report any change in ownership to MDHHS within 35 days. In addition, MDHHS incorporated a review of provider agreements as part of their monitoring process conducted for all MI Choice Waiver Program (MI Choice) entities. MDHHS’s review of fiscal year 2023 provider agreements for MI Choice entities will be completed by September 30, 2024, and will be ongoing. MDHHS also added language to MI Choice contracts that requires PSICT forms to be returned by September 1 each year and reminders will be sent during August 2024 to complete the tools and submit to MDHHS by this deadline. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Elizabeth Gallagher, MDHHS Latina McCausey, MDHHS

The Consortium is in the processes of performing these unit inspections and will ensure those inspections are properly documented in the participant’s files. Name of Contact Person Responsible for Corrective Action: Kyle Lyskawa, CFO, (315) 424-1821. Anticipated Completion Date: May 2024

The City will work with all HOPWA subrecipients to ensure that a complete and accurate CAPER is completed in the appropriate format as required by HUD. This will include a focus on inputting the correct (eg, actual expended vs. award amount) funding amount.

Corrective Action Plan: The Executive Director will advise the CPA of all purchases that exceed the capitalization threshold when they occur. Copies of the check(s) and invoice(s) will be scanned into the month they are paid (into the Laserfiche electronic storage system). The CPA will review the payments scanned monthly and also scan the disbursements for any that could have been missed. At the end of the fiscal year, the disbursements that meet the capitalization requirements of HAHC and RTS will be entered into the depreciation schedule. Person(s) responsible: Executive Director- Connie Stewart CPA- Barfield and Kinkead LLC Completion Date: Fiscal year ending September 30, 2024

Management Corrective Action Plan For the Year Ended December 31, 2023 Community Roots Housing US Department of Homeland Security auditee identification number: PMDC-PJ-10-WA-2018-010 Audit Firm: Clark Nuber PS Audit Period: Year ended December 31, 2023 Finding 2023-001 – Significant deficiency in internal controls over compliance related to special tests and provisions. Requirement: Per the requirements contained in 24 CFR Part 982, property owners must perform housing quality inspections at the time of initial occupancy and at least annually thereafter to ensure that the units are decent, safe, and sanitary. Finding: Out of 12 units selected for testing, 2 units did not have documentation supporting that a housing quality standards inspection was completed during 2023. Recommendation: CRH should implement the necessary internal controls to ensure annual inspections are performed and documented. Comments Community Roots Housing agrees with this finding and recommendation. Corrective Action Plan Community Roots Housing maintains detailed listings of annual inspection work orders, including unit numbers and when they were finished. This listing is prepared by the maintenance department. An additional control will be added to include secondary review and oversight by the Director of Property Management. This review will occur quarterly, starting in the with the second quarter of 2024, to ensure that all inspections are completed before the end of 2024, and annually thereafter. The Director of Maintenance and the Director of Property Management will be responsible for ensuring these tasks are carried out. Corrective Action Plan prepared by: Leslie Woodworth, Chief Financial Officer, 206-895-2030

Finding 2023 - 001: Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Material Weakness Corrective Action Plan: Training: Currently, we are having all HCV staff trained and refreshed on rent calculations through Nan McKay. Staff will also be trained in best practices for properly obtaining verification and following the verification hierarchy process. Also, we are hiring a Training and Development Specialist. Once filled, we will conduct monthly and quarterly training. We anticipate filling the position by July 2024. Quality Control: We conduct 100% quality control on all new hires', completed action files and 100% quality control on all contract files. Quality Control of 25% of all annuals and 25% of all interims completed monthly by all non­ provisional employees. Department Structure: The supervisors will quality-control any caseworkers with an error rate of 80% of their files. Once we fill all staff vacancies and complete the provisional period for all our new staff, we will audit up to 40% of all completed files. Anticipated Completion Date: The current staff is attending Nan McKay's rent calculations training on June 4-6, 2024. We anticipate completion of the plan by 12/31/2024. Person Responsible: Ms. Rhonda Jackson, Housing Program Manager II, and Ms. Malandria Watson, Housing Program Manager I, will review the Quality Control Report and error ratios monthly.

Policies and Procedures for Federal Awards Corrective action planned: Management will consult an advisory firm to assist with providing sample policies and procedures for tracking and usage of federal awards. Management will review and implement policies and procedures no later than 60 days to ensure compliance with tracking and usage of federal awards. Anticipated completion date: June 30, 2024 Contact person responsible for corrective action: Angela St. John, CFO

Finding No. 2023-002 Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Material non-compliance and Material Weakness in Internal Control over Compliance This is a repeat finding of 2022-002 from September 30, 2022 (Originally reported as finding 2019-001 from September 30, 2019) Statement of Condition: Out of a total tenant population of approximately 1,142 vouchers, 25 files were selected for testing, and the following errors were discovered. • 1 tenant file had the following error: o The utility allowance was miscalculated by $32 (overstatement). The two-bedroom column utility rates were used when the 1-bedroom column utility rates should have been used. Correcting this error would cause which the HAP rent to decrease from $762 to $731. • 1 tenant file had the following error: o An EIV form was either not run or has been misplaced for the tenant’s annual recertification period. • 1 tenant file had the following error: o The utility allowance was miscalculated by $23 (understatement). The 2022 utility allowance schedule was used when the 2023 utility allowance schedule should have been used. Correcting this error would cause the HAP rent to increase from $494 to $517. • 1 tenant file had the following error: o The tenant did not check the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen. However, based on the birth certificate the tenant is a U.S. citizen. • 1 tenant file had the following error: o An EIV form was either not run or has been misplaced for the tenant’s annual recertification period. • 1 tenant file had the following error: o The tenant’s asset income was miscalculated. Correcting this error would increase the HAP rent by $4. • 1 tenant file had the following error: o The 50058-form reported childcare income support of $6,000, however, the support for the childcare income showed $5,800. Correcting this error had no effect on the HAP rent. • 1 tenant file had the following error: o No support for the tenant’s wage income of $23,296 on the 50058 form. Appears to be reported correctly, since the EIV shows an amount that approximates the tenant’s wage income of $23,296. Nonetheless, there needs to be support in the tenant file for the wage income. o Missing HAP contract. • 1 tenant file had the following error: o The utility allowance was miscalculated by $19 (understatement). Correcting this error would cause the HAP rent to increase from $924 to $943. In addition to the above, we noted the following during our new admissions testing (out of a total of 161 new admissions, 17 files were selected for testing.): • 1 tenant file had the following error: o The tenant did not check the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen. However, based on the birth certificate the tenant is a U.S. citizen. • 1 tenant file had the following error: o HAP contract was not executed timely (within 60 days). • 1 tenant file had the following error: o The voucher extension date was not documented on the voucher. • 1 tenant file had the following error: o The request for tenancy addendum was executed (dated) two days after the voucher extended due date. o The unit size on the voucher did not agree to the family voucher size on the 50058 and the wrong payment standard was applied to the tenant. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants. The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being to the Housing Programs Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the new Intake Counselor, have attended Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam. Effective Date: June 21, 2024 Contact Information Gwendolyn B. Dawson, CEO Ocala Housing Authority 1629 NW 4th Street Ocala, Florida 34475 (352) 369-2636

Corrective Action Plan For the Year Ended September 30, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Sara Potts, Executive Director Corrective Action: We concur. Management will review the internal control procedures as they relate to eligiblity and will implement procedures to ensure all documents are obtained during intake. Proposed Completion Date: Immediately.

June 14th, 2024 Findings- Major Federal Award Programs Audit- Corrective Action Plan (CAP) Public Housing Capital Fund finding 2023-001 For the year ended September 30th, 2023, the audit conducted by Cherry Bekaert LLP found Significant Deficiency, Nonmaterial Noncompliance- Obligation and Expenditure Verification for public housing capital fund grant. The recommendation to implement controls to ensure capital grants are fully obligated by contractual agreements and expended within the required deadlines will be put into procedure by management of the Housing Authority. Management understands the importance of obligating and expending capital fund grants and to remedy the above deficiency, the Housing Authority will take an approach that will implement controls within regulations. -The Charlestown Housing Authority will review 24 CFR 905.306 {a) and 24 CFR 905.306 (F), and other regulations required for compliance with capital funds. - The Charlestown Housing Authority will implement internal checks and balances when obligatlng and expending funds for grants to ensure timely contracts and expenditures. - The Housing Authority will obligate capital funds prior to the 24-month deadline and expend the funds within the 48-month deadline. Responsible Person: Leigh Bowyer Completion Date of CAP: 6/13/24

The Housing Services Manager will run a report on the 2nd Monday of each month identifying the new admissions that were completed four months prior. An EIV system check will be completed for each new admission and compared with the income that was submitted during the family' s initial interview. Once the report has been reviewed for accuracy, the Chief Operating Officer will review and sign off. The report will be filed and maintained by the Housing Services Manager.

Condition: Tiered environmental reviews were not completed for the City’s emergency and minor home rehabilitation activities. The environmental review for major rehabilitation activities was incomplete and was not submitted in the HEROS system. Planned Corrective Action: This finding was partly due to the staff members' need for more training. HUD mandated that staff undergo training on the HERO system as part of the resolution. The extra training enabled staff to revisit and finalize previous environmental reviews, ensuring compliance with environmental review regulations. After a follow-up with HUD, the agency considers the issue resolved. Going forward, environmental reviews will be conducted once every five years, which is in compliance with HUD regulations. Tiered reviews will be added as projects are completed. Our rehab specialist will be responsible for entering HEROs, and the division director will be responsible for public notices and hearings. Contact person responsible for corrective action: Madison Bjertness Anticipated Completion Date: 5/22/2024

Name of Auditee: Refugee & Immigrant Self-Empowerment, Inc. Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended September 30, 2023 CAP Prepared by: Haji Adan, Executive Director Phone: 315-214-4480 (A) Current Finding on the Schedule of Findings and Responses (6) Audit Finding 2023-006 (a) Comments on the finding and recommendation: Refugee & Immigrant Self-Empowerment, Inc. acknowledges the need for documenting credit card usage. (b) Actions Taken: Refugee & Immigrant Self-Empowerment, Inc. will establish a clear process requiring verification of identity and purpose for each transaction. We will implement strict controls, such as mandatory receipts, detailed transaction logs, and periodic audits. Additionally, we will provide comprehensive training to all employees on the proper use and accountability of credit cards, emphasizing the importance of adherence to established protocols. We will regularly review and update these procedures to adapt to evolving risks and maintain effective internal controls. (c) Anticipated Completion Date: August 31, 2024

Special Tests – Formula Income – Public and Indian Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority reviews their controls over submitting forms to HUD to ensure they contain accurate information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New CFO is preparing a Subsidy Calculation procedure so new staff will be aware of what is eligible and non-eligible transactions for preparing forms. Name(s) of the contact person(s) responsible for corrective action: Shannon Sterling and/or Carlton Brown

Allowable Costs – Operating Fund – Public and Indian Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority establishes procedures to properly reconcile the revolving fund cash account to ensure that cash and interprogram accounts are properly reported at the program level. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: There are procedures in place to settle interfunds if possible. Name(s) of the contact person(s) responsible for corrective action: J Daniels and Shannon Sterling

Reporting – PIC – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that the person assigned to submit the 50058s to PIC assures a quality control review is performed on the submissions to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Following CLA’s recommendation, SVP of Housing Choice will audit a random sample of 50058 submissions to PIC each month to ensure that all submissions are accurate in PIC. Additionally, the Agency is transitioning to Yardi software which should eliminate many of the submission issues caused by current enterprise software. Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023

Eligibility – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: CLA recommends management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify 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: : Following CLA’s recommendation, SVP of Housing Choice will audit a random sample of 10 files on a monthly basis. Agency working with Human Resources contractor to fill open staff positions Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023

Special Tests – Top of the Waiting List – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that the Authority reviews their standard procedures to ensure requests for informal reviews are granted and notified to the applicant within 30 days of the receipt of the request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency hired a dedicated Hearing Officer following last year’s audit. Unfortunately, during the period in question, the Hearing Officer went on maternity leave and then subsequently left the position resulting in a delay in completing hearings and reviews. The Agency has since contracted with a 3rd party to conduct hearings and reviews in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023

Special Tests – Annual HQS and Quality Control Inspections – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that management review their controls for conducting HQS biennial and quality control re-inspections and ensure compliance standards are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previously, staff used a 90-day window to select Quality Control samples. Doing so caused some QC inspections to be completed past the regulatory time period. Going forward, staff are selecting the sample size from a 45-day window. This allows sufficient time to complete the QC inspection within the regulatory time period. Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023

May 22, 2024 Vita Nova, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2023. Name and address of independent public accounting firm: Holyfield & Thomas, LLC, 125 Butler Street, West Palm Beach, FL 33407 Audit period: For the fiscal year ended September 30, 2023. The findings from the September 30, 2023 schedule of findings and questions costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FEDERAL AWARD PROGRAM AUDITS U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD) 2023-001 Significant deficiency for the Continuum of Care Program, Youth Homeless Demonstration Program (YHDP) – Assistance Listing No. 14.267. Recommendation: We recommend that when the rent reasonableness worksheet reflects that the proposed rent is not reasonable, the lease contracts should not be approved, and negotiations should begin with the landlord to get the rent within the reasonable range. To ensure this step is taken, we recommend that the Program Director review, and initial each rent reasonableness worksheet before the lease is signed for the client tenant. Action Taken: In September 2023, Vita Nova reassigned the YHDP program to the oversight of a new Director of Housing. In late October 2023, the new Director identified the specified issue as part of a detailed file review and immediately took action to correct this error. New lease agreements were established with both tenants as of November 2, 2023, using rent reasonable rates. Vita Nova has since taken additional steps to ensure this and other similar errors do not reoccur as follows: • Housing Case Managers are not authorized to complete rent reasonableness worksheets. This procedure is completed directly by the Director of Housing. • If the requested rent is found to not be reasonable, the Director of Housing initiates negotiations with the landlord. • If rent reasonable rates are not able to be negotiated, the lease will not be signed. • The Director of Housing approves all lease contracts and related rental costs. • Peer file reviews are conducted by Housing Case Managers (HCM) on a monthly basis, and review sheets are submitted to the Director of Housing. The Director of Housing then completes a follow-up internal review and returns any comments to the respective HCM(s) with a correction date for any needed revisions within 7 days. If the U.S. Department of Housing and Urban Development (HUD) has any questions regarding this plan, please call Kelly Landrum, Chief Operating officer at (561) 517-0040. Respectfully, Kelly A. Landrum Chief Operating Officer