Corrective Action Plans

Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Voucher Programs to ensure that established internal control policies are being followed on a timely basis. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

PA-HUD-201 CORRECTIVE ACTION PLAN Project Legal Name: Lucille C. Clark Housing Development Fund Corporation HUD Project No.: 012-EE167 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2022- 9/30/2023 Corrective Action Plan prepared by: Name: Maryann Marty Position: Director Telephone Number: Current Findings on the Schedule of Findings, Questioned Costs and Recommendations: Finding 2023-001 a. Condition As of September 30, 2023, management has not fully funded the tenant security deposits cash account. The tenant security deposits cash account was underfunded by $1,712. b. Action(s) Taken or Planned on the Finding Management will transfer $1,712 from the operating account in order to fully fund the tenant security deposits account.

2023-005 Eligibility – Tenant Files Public and Indian Housing Program – CFDA Number 14.850 Material Weakness in Internal Control, Material Noncompliance This is a repeat finding of 2022-004, reported as a Material Weakness and Material Noncompliance from June 30, 2022 (initially occurred as Finding 2021-002, Material Weakness and Material Noncompliance) Condition: Out of a total tenant population of approximately 269 tenant files, 25 files were selected for testing. Exceptions were noted as follows: • 4 tenant files where the 214 Affidavit was not in the file or was incorrectly completed (2 files for missing 214 affidavits and 2 files where boxes were not checked to indicate adults were signing for dependents). • 5 tenant files where the tenant’s personal declaration form was missing for the time period tested. • 2 tenant files where the Form 9886 were missing for the time period tested. • 10 tenant files where there were income issues (including income calculation errors or missing support or missing Forms 50058). • 7 tenant files had deduction issues (several for deductions that were taken twice for food stamp income that was “excluded” and then deducted again, incorrect utility allowances, incorrect child care costs). • 1 tenant file where the Form 50058 was missing so unable to determine if recertification date was correct. • 4 tenant files with missing birth certificates • 1 tenant file where the tenant’s date of birth on the 50058 form did not match the tenant’s birth certificate. • 5 tenant files with missing social security cards. • 1 tenant file where the adult tenants did not sign the lease agreement. • 5 tenant files with missing EIVs. Auditor’s 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: As was also instituted for HCV participant files, the Authority has instituted a checklist sheet that will occupy the front interior of all tenant files. This checklist will contain every document that is required to be placed in the tenant file. The Authority has and will affirm the use of its procedures, and continue to implement procedures to ensure all tenant files are maintained in accordance with policies and procedures. Additionally: • All noted deficiencies will be corrected and cured. • The Authority has also taken steps to stabilize staff by hiring a Property Manager and an Occupancy Specialist that will support the Public Housing Department. • The Authority has implemented a 100% quality control review of all participant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured. Thereby reducing any additional findings with tenant files. • Repeated noted errors will be reported to the Senior Property Manager and additional hand's-on training regarding deficient items will be completed as necessary.

2023-003 Special Tests and Provisions – Inter-Program Fund Management Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: There were inter-program borrowings using federal funds which are unauthorized distributions, resulting in $3,943,604 of the total $4,164,790 in inter-program "due from" and "due to" balances lacking supporting documentation or reconciliation schedules. The unsupported balances primarily consist of significant amounts due to the Public Housing program, including $1,590,789 due to AMP 2 and $2,200,000 due to AMP 199 HOPE VI. These are offset by significant amounts owed by the Housing Choice Voucher program ($1,458,947) and the Central Office Cost Center ($2,190,705). Auditor’s Recommendation: To strengthen internal controls and ensure compliance, it is recommended that the Authority perform a detailed analysis to identify and document the specific transactions comprising the outstanding inter-program balances. Based on this analysis, a formal plan should be developed to resolve and settle these balances. To prevent a recurrence, the Authority should also establish and implement written policies that outline clear requirements for proper authorization, documentation, and timely settlement of any future inter-program transactions. Specifically, the inter-program amounts should be settled every month and balances should not be carried forward. Finally, ongoing compliance can be ensured by incorporating a monthly reconciliation of all "due from" and "due to" accounts into the regular financial closing process. Action Taken: Management has begun a detailed analysis to fully reconcile all unsupported inter-program balances by April 30, 2026. Following this, a formal plan to settle the balances will be presented to the Board by May 31, 2026. To prevent a recurrence, a new Inter-Program Transfer Policy—requiring written authorization and clear documentation—is being drafted for Board approval by June 30, 2026. These new controls will be supported by mandatory monthly reconciliation procedures to ensure ongoing compliance, with all corrective actions to be fully implemented by July 31, 2026.

2023-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control Material Noncompliance Condition: The unaudited FDS filing was not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on October 13, 2023 (the due date was August 31, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by March 31, 2024 at completion of the single audit, but was not filed timely as the audit was completed on October 8, 2025. Auditor’s Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Action Taken: We concur with the recommendation. Due to staff absences and turnover, we were unable to submit the unaudited FDS before the filing deadline, and we were unable to file the OMB Data Collection Form before the filing deadline. We are taking corrective action to ensure there is adequate staffing and sufficient processes in place to submit the unaudited FDS submission and the OMB Data Collection Form before the filing deadline.

2023-004 Eligibility – Tenant Files Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-001, reported as a Material Weakness and Material Noncompliance from June 30, 2022 (initially occurred as Finding 2017-001, Material Weakness and Material Noncompliance) Condition: Out of a total tenant population of approximately 1452 vouchers, 25 files were selected for testing. Exceptions were noted as follows: • 3 tenant files where the wrong utility allowance was used, which caused a miscalculation in the tenants’ utility allowance rate but had no effect on the HAP rent. • 3 tenant files where the wrong utility allowance was used, which caused a miscalculation in the tenants’ utility allowance rate. Correcting these errors would cause the HAP rent to increase by $3 and decrease by $41 and $37 for each of the three tenant files. • 1 tenant file had the following issues: o The wrong utility allowance was used, which caused a miscalculation in the tenant’s utility allowance rate. Correcting this error would decrease the HAP rent by $52. o The tenant’s asset income was miscalculated, but the error itself would not have changed the HAP rent. • 1 tenant file had the following issues: o The wrong utility allowance was used, which caused a miscalculation in the tenant’s utility allowance rate. Correcting this error would cause the HAP rent to decrease by $14. o The tenant’s asset income was miscalculated and correcting this error would decrease the HAP rent by $13. • 1 tenant file where the tenant’s other source income was excluded from the tenant’s income on the 50058 form. Auditor’s 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 has implemented a 100% quality control review of all participant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured before the final completion of certification. Thereby reducing any additional findings with tenant files.

: Management must strengthen internal controls to ensure that it meets the deadline period for making the deposit to the Residual Receipt Bank Account in the event of a surplus cash.

Corrective Action Plan For the year ended December 31, 2023 The Housing Authority of the City of Hoboken respectfully submits the following corrective action plan for the year ended September 30, 2024. Auditor: Polcari & Company CPA 2035 Hamburg Tpke Unit H Wayne, New Jersey 07470 The findings from December 31, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding- 2023-005 Redevelopment Authority – CDBG Type of Deficiency – Significant Deficiency Compliance Requirement – Reporting The Authority did not file accurate and timely PR-26 “Financial Summary Report” and PR-29 “Cash on Hand Report” as required. The PR-29 report is HUD’s quarterly cash on hand report of CDBG and CDBG-CV Programs Cause: The Authority did not implement proper controls, including a review process to ensure that quarterly and year-end reporting information extracted from IDIS were accurate and timely reported as required. Condition: The Authority did not have proper controls in place to ensure that quarterly and year-end reports were done in a timely manner. Criteria: The Authority is required under 24CFR570.502(b) to remit the annual performance report PR-26 specifying the amount of funds drawn from the IDIS system 90 days after year end. Under CFR 200 – Uniform Administrative Requirements, Cost Principles and Audit Requirements Subpart D section 200.328 the PR-29 quarterly report is required to be submit quarterly no later than 30 days after year end Effect of Condition: The effect of not accurate and timely reporting affects HUD’s ability to analyze program activities and properly fund programs to meet the needs of the populations served. View of Responsible Officials and Corrective Actions: This report was late every month in 2023, due to the new Finance Director trying to research and submit the correct numbers to HUD. In 2024 this report was submitted timely. If there are any questions regarding this plan, please contact: Justin Eby Executive Director (717) 394-0793 jeby@lchra.com

1. Revisiting AMA Consulting Group Proposal:_x000B_RCRHA is in the process of revisiting a formal proposal previously received from AMA Consulting Group, LLC, which outlines a detailed "Agency Health Check" for our Public Housing program. This proposal includes: • An operational audit of tenant files and eligibility documentation • Process mapping to improve workflow and accountability • Quality control implementation • Recommendations for electronic file storage and ongoing compliance monitoring. 2. Recent Staff Training: Nan McKay Rent Calculation Course:_x000B_To immediately address gaps in eligibility documentation practices, RCRHA staff participated in the Nan McKay HCV and Public Housing Rent Calculations Course, held March 18-20, 2025, in Washington, NC._x000B_The three-day seminar provided comprehensive instruction in: • Income and asset verification under 24 CFR Part 5 • Adjusted income and allowable deductions • Total Tenant Payment (TTP) calculations for both HCV and Public Housing • Case study applications using HUD Form 50058. 3. Internal File Review and Compliance Checklist Implementation:_x000B_RCRHA has initiated a review of all active Public Housing tenant files to ensure that required eligibility documents are present, accurate, and properly stored. A standardized checklist is being introduced to guide staff and ensure uniform compliance across all tenant records. 4. Electronic File System Evaluation:_x000B_In alignment with HUD best practices and our consultant's recommendation, RCRHA is evaluating the feasibility of transitioning to an electronic document management system to ensure long-term retention, audit readiness, and streamlined access to eligibility documentation.

Contact Person Terry Hanson, Executive Director Corrective Action Plan The Authority will review responsibilities pertaining to VMS reporting and ensure timely, accurate, and appropriate VMS reporting. Planned Completion Date for CAP Immediately

Contact Person Terry Hanson, Executive Director Corrective Action Plan The Authority will review its polies and procedures for ensuring inspections happen timely. Planned Completion Date for CAP Immediately

Contact Person Terry Hanson, Executive Director Corrective Action Plan The Authority will review its policies and procedures for ensuring proper documentation on waiting list pulls. Planned Completion Date for CAP Immediately

ontact Person Terry Hanson, Executive Director Corrective Action Plan The Authority has encountered turnover with their finance staff and will review, implement, and document controls to ensure that REAC filing is done on time. Planned Completion Date for CAP Immediately

Finding 2023-006 Due to cash flow constraints, the Project was not able to repay the replacement reserve. The Project will repay the replacement reserve when cash is available. If cash becomes available, the anticipated completion date is June 30, 2024.

Finding 2023-005 Due to the financial situation the Project is in at June 30, 2023, making this deposit is impossible. HUD has agreed to suspend the monthly required debt service savings deposit effective September 1, 2019. Management is negotiating with HUD to get the past debt service saving deposit requirement suspended permanently. If management is successful in negotiations with HUD, the anticipated completion date is June 30, 2024.

Finding 2023-004 Due to cash flow constraints, the Project was not able to repay the nonprofit sponsor’s foundation. The Project will repay the nonprofit sponsor’s foundation when cash is available. If cash becomes available, the anticipated completion date is June 30, 2024.

Finding 2023-003 Due to cash flow constraints, the Project was not able to repay the nonprofit sponsor’s foundation. The Project will repay the nonprofit sponsor’s foundation when cash is available. If cash becomes available, the anticipated completion date is June 30, 2024.

Finding Number 2023-084 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 - LIHEAP Planned Corrective Action DHS agrees that improvements are needed in documentation and coordination to support the accurate identification and tracking of ARPA payments. While all recipients of the supplemental ARPA payments had documented arrearages and met general LIHEAP eligibility at the time of payment, we recognize the need for improved system documentation and reporting processes to support eligibility determinations and data integrity. It is also important to note that the ARPA funding was a onetime, temporary supplement to LIHEAP and is no longer active in the current program year. OKDHS is taking the following steps to strengthen system documentation, reporting accuracy, and cross-divisional reconciliation: • System and Reporting Enhancements: The Data Transformation Office (DTO) and Finance Division are collaborating to develop system functionality and reporting tools that clearly identify funding sources and improve the readability and completeness of payment data used for audit and program oversight. • Cross-Divisional Reconciliation Effort: AFS, Finance, and DTO are jointly working to establish a coordinated reconciliation process that ensures eligibility data aligns with payment records and federal reporting, including future SEFA submissions. • Process Documentation: OKDHS is documenting the updated processes and reporting requirements to ensure consistency in implementation and to support audit readiness going forward. • Internal Audit Oversight and Support: OKDHS has recently reorganized its Internal Audit division to enhance independence, improve reporting structure, and expand its capacity to support internal control consultation and program integrity reviews. Internal Audit will assist in evaluating reconciliation efforts, documentation standards, and data reporting controls as they are implemented. Anticipated Completion Date Ongoing Responsible Contact Person Kayla Urtz

Finding Number 2023-010 Subject Heading (Financial) or AL no. and program name (Federal) TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.010 Planned Corrective Action The Office of Title Services is implementing policies and procedures to demonstrate compliance. We are strengthening our policies and procedures to ensure LEAs are submitting accurate documentation for our SNS Specialist to determine that LEAs are meeting the supplement not supplant requirements. We will ensure that all policies and procedures, as well as the Title I Supplement Not Supplant Tracking Spreadsheet, are uploaded to our internal I-Drive. Anticipated Completion Date May -25 Responsible Contact Person Tammy Smith

Finding Number 2023-027 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action AUDIT BULLET POINT “Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Eligibility exceptions: • For 22 of 89, or 24.72%, of items tested, the applicant was an Afghanistan refugee and not a renter who lived in Oklahoma at the time of applying for assistance; therefore, they were not eligible, and the payment was unallowable. The subrecipient, Communities Foundation of Oklahoma, paid for the applicant to be in a hotel and then subsequently paid for their rent and utilities. Since the applicants were not eligible all payments were unallowable; therefore, we did not determine if the payment was calculated correctly or if the assistance exceeded 15 months for ERA 1 or 18 months for ERA 2. However, of these unallowable costs, we noted the following: • Some applicants were reimbursed for monthly lawn services as part of their monthly rental payment. • Several payments were made to the applicants after the initial payment without receiving an additional application or additional funds request (AFR) form (See FAQ #10).” OMES RESPONSE: The State disagrees that payments made to Afghan refugees were unallowable. The finding asserts that 22 applicants were ineligible for Emergency Rental Assistance (ERA) because they were Afghan refugees and were not “renters who lived in Oklahoma at the time of applying.” This interpretation is inconsistent with U.S. Department of the Treasury guidance, which does not require U.S. citizenship, legal residency, or prior tenancy in Oklahoma as a condition of eligibility. • Citizenship or Legal Residency Is Not a Requirement for ERA Eligibility. It is never mentioned in the ERA statute or Treasury guidance that U.S. citizenship, lawful residency, or duration of tenancy required. The U.S. Treasury’s ERA FAQ #1 explicitly outlines the four criteria for eligibility: • The household must be obligated to pay rent on a residential dwelling; • One or more individuals within the household must have experienced financial hardship due to the pandemic; • The household must demonstrate a risk of homelessness or housing instability; • Household income must be at or below 80% of area median income (AMI). These Afghan households were invited by our government leaders to resettle in Oklahoma as part of the federal government’s Operation Allies Welcome initiative. When the Afghans arrived in Oklahoma, they immediately sought housing, being assisted by agencies such as Catholic Charities. Obviously, they were not homeowners. As tenants or households seeking to rent housing during the midst of a pandemic without any immediate means of securing employment, they were experiencing housing instability and fully met the ERA Program 1 and 2 criteria. Upon arrival: • They were not homeowners; • They had no permanent housing; • They were working with nonprofit agencies like Catholic Charities to find housing; • Because of the pandemic, they were not able to secure work and had no or extremely low income; • They were at imminent risk of homelessness. Treasury has further emphasized in FAQ #1, “… these requirements provide for various means of documentation so that grantees may extend this emergency assistance to vulnerable populations without imposing undue documentation burdens…” Again, never is the word “residence or citizen” used, even in the footnotes. This language was clearly intended to include undocumented individuals, newly arrived refugees, and others in nontraditional or transitional housing situations. Furthermore, as noted in the CFO/CCP ERA application for rental assistance previously provided to SAI, the eligibility requirements do not require residency but that only the applicant live in the State of Oklahoma. Further Support: • September 9, 2021, Email between CCP/CFO and the Director of Tax and Housing Advocacy for the National Council of State Housing Agencies. Discusses that CCP was working with housing stability service partners, specifically Catholic Charities, to help with housing Afghans when they came to Oklahoma. Emails also clarify that the Afghan refugees would only be able to apply once they moved to Oklahoma. (See attached) • Sept 29, 2021 – Email from U.S. Dept. of State, Bureau of Populations, Refugees, and Migration (PRM), U.S. Department of State, which invited a variety of Federal Agency representatives to a call to hear from the OK Catholic Charities director to speak about the Oklahoma Catholic Charities “model of utilizing CARES Act funding to support both temporary and long term housing for Afghan arrivals and an additional hour was set aside for discussion of this model. Executive Director of the Oklahoma City Catholic Charities forwarded this email to CCP asking if she would join to assist with the discussion of this model. Listed below are the agencies that had representatives on the email. the National Security Council and Subcommittees  The White House – Organization of the National Security Council and Subcommittees  Executive Office of the President.  U.S. Department  Federal FEMA Office  U.S. Citizenship and Immigration Services  Homeland Security  Catholic Charities  U.S. Conference of Catholic Bishops  Administration of Children & Families  Governors, Biden Administration point person for Afghan Parolee Assistance. (See attached) • October 3, 2021, Follow-up Email thanking people regarding the presentation and for joining the call. “The insight, creativity, and partnership is inspiring and has the potential to assist so many Afghans.” Furthermore, an email was to the attendees of the presentation clarifying ERA as the funding source for Oklahoma’s model for developing housing resource for Afghan arrival. Additionally, it was stated that “We hope that these clarifications and enclosed links will help us understand how these funds may be leveraged to house Afghans when they are resettled from the bases to other locations around the country.” (see attached) • October 24, 2021, Email from ERA Outreach Team Leader, Emergency Housing Team, U.S. Department of the Treasury, to CCP wanting to connect them with Chicago who was looking to do some work with asylum seekers/refugees and was wanting to talk to other grantees who have worked with these populations using ERA funds. Note, this is an ERA Team Leader from the Treasury wanting CCP to share CCP/CFO’s ERA model. Obviously, the Treasury would not reach out to connect CCP/CFO to speak about their Afghan refugee model if they did not approve of the use of ERA funds to assist with housing the refugees. (See attached) • Treasury FAQ #37 – Addresses how grantees can promote access to assistance for all eligible households and is clear that the Guidance contemplates serving individuals from all background and nationalities, stating that grantees “should address barriers … including by providing program documents in multiple languages.” Furthermore, the Guidance states “Grantees should also provide, whether directly or through partner organizations, culturally and linguistically relevant outreach and housing stability services to ensure access to assistance for all eligible households.” In accordance with Title VI of the Civil Rights Act of 1964 (Title VI) ERA grantees must ensure they provide meaningful access to their limited-Englishproficiency (LEP) applicants and beneficiaries of their federally assisted programs, services, and activities. Finally, “Denial of an LEP person’s access to federally assisted programs, services, and activities is a form of nationalorigin discrimination prohibited under Title VI and Treasury’s Title VI implementing regulations at 31 CFR Part 22.” • Treasury guidance on creating applications for the ERA program with no mention of citizenship or residency requirements. Allow applicants to progress and self-attest if they cannot provide documentation - At the stage when applicants are asked to provide documents to establish COVID hardship, housing instability, income, or rental obligation, applicants should also be informed that they may self-attest and move forward in the application if they do not have those documents. • Disaster Housing Recovery Coalition, C/O National Low Income Housing Coalition (NLIHC) – Published an information sheet for recipients of Federal awards in response to the COVID-19 pandemic which detailed which awards did not consider immigration status when providing assistance. Under the ERA Program, the NLIHC stated that “The law establishing the Emergency Rental Assistance Program does not impose restrictions based on immigration status.” (Attached – labeled FAQs- Eligibility for Assistance Based on Immigration Status) 2. Hotel Stays Are Allowable Options for Temporarily Displaced Households Treasury provided a Broader Reading of “Obligated to Pay Rent on a Residential Dwelling,” and determined the costs of staying in a hotel are eligible expenses, and rental assistance could be provided to temporarily displaced households living in hotels. The audit finding narrowly interprets the term “obligated to pay rent” in FAQ #1. However, multiple Treasury FAQs — including FAQ #7, #26, and #35 — demonstrate that the Department intended a flexible, inclusive interpretation, recognizing the emergency nature of the program and the housing challenges faced by displaced individuals and families and reinforces that the term “residential dwelling” is not limited to traditional apartments with leases but includes hotels and other temporary housing used in transition. • FAQ #7: Permits hotel or motel costs to be covered using ERA funds when the household lacks alternative housing options, even without a formal lease. • FAQ #26: States that rental assistance may be provided to households residing temporarily in hotels or motels when they are • displaced or between housing. FAQ #27: Allows rental assistance for rent-to- own households, further demonstrating that the key is ERA CANNOT be used for homeowners (FAQ #20). • FAQ #35: Specifically authorizes relocation assistance for households who have been evicted or otherwise displaced and are attempting to secure new permanent housing. These provisions explicitly contemplate support for individuals and families—such as Afghan refugees— who were temporarily displaced and used hotels as the only available rental housing (in truth, many Oklahomans are forced to do this) until suitable housing could be secured (rendered more difficult for larger families – up to 10+ children). As allowed under Treasury ERA FAQs #7 and #26, hotel stays were covered when used as transitional housing due to lack of available rental stock—especially for large families. Afghan refugees fell squarely within this provision. 3. Lawn Services as Part of Rent This is allowable as part of the cost of the rental of the premises. For all rentals that have a yard there is lawn maintenance, and the landlord has the option to determine how to charge (or absorb) that cost. These costs were not reimbursed as separate utility costs, but as part of the monthly rental obligation agreed to in writing. 4. Subsequent Payments Without AFR Forms • ERA guidance allows grantees to implement streamlined processes to reduce burden and deliver aid efficiently. CCP’s internal policies permitted continued rental and utility assistance without requiring new applications or additional AFR forms, so long as eligibility remained unchanged and appropriate documentation was on file. This approach is aligned with Treasury’s consistent encouragement to minimize administrative barriers in the interest of program responsiveness and urgency. Treasury guidance also stated, Only ask applicants for information that is required by the ERA statutes and Treasury’s guidance to provide them assistance. AUDIT BULLET POINT “Further, while summarizing the data on ‘applicant’, we noted one line item was made up of 498 individual payments made to hotels on behalf of the Afghanistan refugees, which consisted of 186 applicants. We identified 185 of these applicants had payments for Afghanistan refugees to live in hotels prior to applying to the ERA program. Since, at the time of the application, they were not obligated to pay rent on a residential dwelling per Department of Treasury FAQ 1 and established CCP ERA policy, the cost is unallowable. This resulted in $1,727,687.64 in questioned costs (these costs do not include payments previously questioned in the first bullet).” OMES RESPONSE: OMES disagrees with this finding. Multiple Treasury FAQs, including #7, #26, and #35, reinforces the term “residential dwelling” is not limited to traditional apartments but may include hotels and other temporary housing used in transition. Also, FAQ #8 states that a beneficiary is not required to have rental arrears to receive assistance and permits enrollment “of households for only prospective benefits.” The only restriction is that for the ERA1 program, if an applicant is requesting prospective assistance and the applicant also has rental arrears, the grantee must also provide assistance to reduce those arrears (this restriction does not apply to ERA2). Finally, per FAQ # 13, eligible households do not have to be in their current rental home when the COVID-19 public health emergency was declared, stating, “Payments under ERA are provided to help households meet housing costs that they are unable to meet as a result of the COVID-19 pandemic. There is no requirement regarding the length of tenure in the current unit.” Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. Beginning with FY2025, OMES has taken the following measures: • Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience. • To ensure that the subrecipient agreement includes all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) have recently executed a Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies. See Attached – Grant Agreement Amendment. • OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed. • OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMESGMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMESGMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multi-layer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements. • Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMES-GMO conducts biweekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

The Corporation should file the December 31, 2023 financial statements as soon as possible and should ensure the annual financial report is filed within 90 days in future periods or within nine months of fiscal year end if an owner certified submission was furnished to HUD.

Audit Finding 2023-025 U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Summary of Finding: The Nevada Department of Transportation (NDOT) is required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. A VE analysis was not performed when required by NDOT policy because NDOT did not have adequate internal controls to ensure their VE policy was followed. Recommendation: NDOT should enhance internal controls to ensure the VE policy is followed or, if necessary, the VE policy is updated as needed and provided that it complies with federal requirements. Agency Response Does the Agency Agree with Finding: Yes Additional Comments: Current NDOT policy has a lower cost threshold (i.e. stricter) for VE analysis than the federal requirement, and the finding references and evaluated project at that lower threshold. NDOT has also had significant organizational and staffing changes since the creation of this, and many other, policies and is currently in the process of updating all agency policies. Corrective Action Action to be Taken: NDOT will update the internal policy and processes relating to VE, including roles and responsibilities and internal controls to match or exceed federal requirements and to meet agency needs and resources. Date of Completion or Estimated Completion: October 1, 2026 Contact Person: Mark Wooster, Performance Analysis Division Head, mwooster@dot.nv.gov

Corrective Action Plan (CAP) Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2023 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (3) Finding 2023-003 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation. Please see below for action taken. (b) Action taken: Management has deposited the underfunded amount as of the date of this report.

Corrective Action Plan (CAP) Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2023 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2023-002 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation. Please see below for action taken. (b) Action taken: Management has deposited the underfunded amount as of the date of this report.

Corrective Action Plan - Missing tenant file documentation. Contact person - Executive Director. Corrective action planned - The PHA will use a tenant file checklist and review tenant file documentation to make sure all required documentation is present. Anticipated completion date - Within the next fiscal year.