Corrective Action Plans

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2023-003 ALN 14.850 - Public & Indian Housing Program - Eligibility Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Jessica Holcomb, Executive Director Projecte...
2023-003 ALN 14.850 - Public & Indian Housing Program - Eligibility Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Jessica Holcomb, Executive Director Projected Completion Date: December 31, 2024
2023-002 ALN 14.850 - Public & Indian Housing Program - Allowable Activities - Use of Operating Funds for Capital Improvements Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correcti...
2023-002 ALN 14.850 - Public & Indian Housing Program - Allowable Activities - Use of Operating Funds for Capital Improvements Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Jessica Holcomb, Executive Director Projected Completion Date: December 31, 2024
View Audit 316234 Questioned Costs: $1
To Health Resources and Services Administration Care Alliance Health Center, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: October 31, 2023 The findings from the October 31, 202...
To Health Resources and Services Administration Care Alliance Health Center, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: October 31, 2023 The findings from the October 31, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Federal Award Findings: Finding 2023.001 - Special Tests and Provisions - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken We will invest the time and resources into improving all areas related to the Sliding Fee Scale. We will implement the following steps to our process to ensure all federal guidelines and requirements are met. 1. Documented Process: Design and implement an internal control process to ensure sliding fee discounts are accurately calculated based on family size and income. 2. Documented Procedures: Establish clear procedures and guidelines for front desk staff to follow when determining discounts, including appropriate documentation requirements, eligibility criteria, and fee structure. These procedures will be aligned with our written policy to ensure consistency and accuracy in discount calculations. 3. Training and Education: Provide training to front desk staff members responsible for determining eligibility and applying sliding fee discounts to ensure they understand the process. 4. Regular Reviews: Implement regular reviews and monthly audits to verify that all discounts are properly supported and documented. Quarterly reviews will be conducted to verify compliance, identify areas for improvement, and evaluate the effectiveness of the sliding scale fee program to ensure it meets our patients' needs and complies with all federal guidelines. Responsible Parties: 1. The Controller and revenue cycle staff will develop the written procedure. 2. The Clinical Support Supervisor and revenue cycle staff will overseE3 the training. 3. The Revenue Cycle Manager_will monitor adherence to the procedure, conduct regular monthly audits, and report results to the Controller. 4. The Controller will conduct quarterly documentation reviews of the internal audit results. Timeline: 1. Procedure draft completion: Completed 2. Review and approval by senior management: July 24, 2024 3. Initial staff training session: July 25, 2024 4. Follow-up training sessions: As needed 5. Monthly compliance audits: Starting September 1, 2024
Finding Number: 2023-001 Finding Title: Eligibility – Source Documentation Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Name of Contact Person Responsible for Corrective Action: Terri Smith, Director Metro HRA Corrective Action Planned: HRA staff has developed a check...
Finding Number: 2023-001 Finding Title: Eligibility – Source Documentation Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Name of Contact Person Responsible for Corrective Action: Terri Smith, Director Metro HRA Corrective Action Planned: HRA staff has developed a checklist form and update procedures for all staff to ensure signatures and forms are not missing in case files, this includes but is not limited to criminal background checks performed, citizenship forms, members of the household forms, and debts owed forms. The checklist will be completed for each case and stored in each participant file as part of the quality control process. The quality control process that was implemented in June 2023 had not been in place for a full year when the 2023 audit was completed. All files are being checked at Annual Recertification. Once this has been in place for a full year, all files will have been checked for the appropriate forms and signatures. Anticipated Completion Date: This process will be in place effective July 2024.
Finding 479420 (2023-001)
Significant Deficiency 2023
Special Tests and Provisions: HPP staff will follow written policy and procedures for ensuring all clients have a rent reasonableness form with new move ins and annual recertifications. The Director of Housing Programs will initial each document submitted for a new move in or an annual recertificati...
Special Tests and Provisions: HPP staff will follow written policy and procedures for ensuring all clients have a rent reasonableness form with new move ins and annual recertifications. The Director of Housing Programs will initial each document submitted for a new move in or an annual recertification to ensure all necessary documents are in each client file. Person Responsible for Corrective Action: Director of Housing Heather Ryan Figueroa Anticipated Date of Completion: June 7, 2024
No action needed. Required deposit of $1,971 was deposited into the residual reserve account on March 4, 2024.
No action needed. Required deposit of $1,971 was deposited into the residual reserve account on March 4, 2024.
View Audit 315935 Questioned Costs: $1
Finding, Reference Number: 2023-001 Federal Agency: Department of Agriculture (USDA) Description of Finding: Criteria: 7 CFR Section 250.1 9(a) identifies requirements related to record keeping for this major program. It is important to note the Food Bank appeared to maintain the appropriate suppo...
Finding, Reference Number: 2023-001 Federal Agency: Department of Agriculture (USDA) Description of Finding: Criteria: 7 CFR Section 250.1 9(a) identifies requirements related to record keeping for this major program. It is important to note the Food Bank appeared to maintain the appropriate supporting documents and required components, this finding relates to one component regarding the lack of a signoff not lack of documentation. Condition: During audit testing, we noted the following; the invoices created as a result of USDA orders being made were not consistently signed off on by the recipient agency representative upon pick up or delivery of the commodities. Statement of Concurrence or Nonconcurrence: The Food Bank agrees with this finding. Corrective Action: The Food Bank places a strong emphasis on ensuring accountability in the pickup process for agencies by requiring them to sign invoices upon receiving their orders. This practice is crucial for maintaining accurate records and verifying the receipt of products and other items. To strengthen this procedure, we will be reinforcing with our staff the absolute requirement for agencies to sign for their orders at the time of pickup. As of July 8, 2024 we will implement a new procedure mandating dual sign-offs on all orders by both the agency representative and a Food Bank staff member. Our Programs team will also conduct educational marketing raising awareness among the agencies about the importance of signing their invoices. These steps will not only enhance our operational efficiency but also uphold our commitment to transparency and accountability in distributing food resources to those in need. Name of Contact Person: Nicholas Pisani, Chief Operating Officer; phone number 518-786-3691 ext. 241; email NickP@Regionalfoodbank.net Projected completion date: July 8, 2024
Finding 2023-002: Special Tests and Provisions The Corporation has three properties secured by CDBG loans. The properties are known as Mid-City, AppleTree Housing, Inc. (“ATH”), and Center West. The Corporation was unable to support that at least fifty-one percent (51%) of the tenants at the ATH pro...
Finding 2023-002: Special Tests and Provisions The Corporation has three properties secured by CDBG loans. The properties are known as Mid-City, AppleTree Housing, Inc. (“ATH”), and Center West. The Corporation was unable to support that at least fifty-one percent (51%) of the tenants at the ATH property were leased to and occupied by low or very low-income persons as determined by the Federal “Section 8” Income Standards with completed tenant certifications and recertifications. At ATH, 6 of 6 occupied unit’s certifications were not completed during the year ended June 30, 2023. This was an initial finding during the year ended June 30, 2020. Planned Corrective Action: It is the goal of the Corporation to maintain compliance with regulatory requirements. Where hardships are encountered the Corporation remains in ongoing communication with respective regulatory agencies to promote transparency and mitigate risk of loss in fundings or default. Mark Deitcher, CFO, is responsible for the corrective action plan. If the U.S Department of Housing and Urban Development has questions regarding this plan, please call Mark Deitcher at 1-215-557-8414.
Planned Corrective Action: While we agree that the submission dates lagged the scheduled dates, we do not agree that this condition rises to the level of a material weakness in internal controls over reporting. BVCOG submitted their audited financial statements for fiscal year 2022 through the Feder...
Planned Corrective Action: While we agree that the submission dates lagged the scheduled dates, we do not agree that this condition rises to the level of a material weakness in internal controls over reporting. BVCOG submitted their audited financial statements for fiscal year 2022 through the Federal Audit Clearinghouse (FAC) on June 30, 2023, which is prior to June 30, 2023. BVCOG awaits receipt of their audited financial fiscal year 2023 in order to submit them to the FAC. The audited fiscal year 2022 financial statements were submitted separately to HUD on November 22, 2023. HUD approved our submission without notice of delay. Unaudited financial statements for the fiscal year ending 2023 were submitted and accepted by HUD, with no point score deduction penalties or requests for corrective action. The timing of HUD’s Real Estate Assessment Center (REAC) report submission depends on acceptance of the previous unaudited or audited financial statements. The REAC submissions require that each year’s unaudited submission be approved by HUD before the audited submission can be submitted; further, both submissions for a year must be accepted by HUD before the next year’s submissions can be completed. Due to various factors including the COVID-19 pandemic and Winter Storm Uri in 2021, the Fiscal Year 2020 unaudited submission process completed April 2022. Subsequent staff turnover delayed the submission of the audited 2020 submission until August 2023. Once that submission was approved by HUD, the 2021 and 2022 submissions were completed by the end of November 2023. BVCOG realizes its REAC submission procedures rely on institutional knowledge and addressed this risk by engaging an outside CPA firm with personnel knowledgeable of the REAC system. This arrangement ensures additional cross-training opportunities in the future for current finance staff such that, if a key staff person leaves, there will be others in the department who know and understand the procedures necessary for compliance with HUD deadlines. Contact Person Responsible for Corrective Action: Janet Dudding, MBA, CPA, CGFO, Director of Finance Anticipated Completion Date: July 2024
2023-001 The management company over the operations during 2023 was replaced effective November 1, 2023.
2023-001 The management company over the operations during 2023 was replaced effective November 1, 2023.
Moving forward, a supervisory review of the move in files will be performed by a different staff member for the Authority than the staff member who initially determined eligibility. This will ensure that the Authority continues compliance with eligibility requirements.
Moving forward, a supervisory review of the move in files will be performed by a different staff member for the Authority than the staff member who initially determined eligibility. This will ensure that the Authority continues compliance with eligibility requirements.
It was discovered that our financial institution was pledging securities based on book value and not on market value which led to the deposits not being fully collateralized according to HUD requirements and State Statutes. The Authority will review the collateral reports at least quarterly to dete...
It was discovered that our financial institution was pledging securities based on book value and not on market value which led to the deposits not being fully collateralized according to HUD requirements and State Statutes. The Authority will review the collateral reports at least quarterly to determine that pledging requirements are adequate to ensure compliance in the future.
BCHS will implement adequate internal control procedures related to account reconciliations and ensure that control process for approval of expenditures is followed.
BCHS will implement adequate internal control procedures related to account reconciliations and ensure that control process for approval of expenditures is followed.
The Corporation contacted the local Continuum of Care and regional HUD office in an effort to verify the required number of units occupied by individuals meeting the definition of "homeless". The local Continuum of Care had no record of the original grant agreement or required number of "homeless" t...
The Corporation contacted the local Continuum of Care and regional HUD office in an effort to verify the required number of units occupied by individuals meeting the definition of "homeless". The local Continuum of Care had no record of the original grant agreement or required number of "homeless" to be served. The Corporation contacted three staff in the regional HUD office, including the staff that had been our representative for annually renewed operation and support service grants for the two projects. Regional HUD staff were not able to provide a copy of the original grant agreements which would indicate the number of persons to be served by each project. HUD staff stated that they do not keep copies of grant agreements longer than seven years. Corporation management will continue to work with HUD personnel to determine the continuing compliance requirements of the Continuum of Care funding received for initial construction or rehabilitation. Corporation management will continue to serve individuals meeting the definition of homelessness at its two projects and document evidence in the file.
Finding 2023-003: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the inte...
Finding 2023-003: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board had reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.
HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County con...
HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County continue to train personnel so that the inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2023, performance issues with the administration of the HOME program were discovered, to include the absence of required inspections. With significant turnover of tenured leadership and employees within the Community Resources Department, Arapahoe County Community Resources took proactive measures in 2023 for review of the Community Development Housing and Homeless Services (CDHHS) programs by recognized consultants within the field. Community Resources has contracted with two consultants, to assist in a full review and re-development of policies and procedures (Civitas) for the CDBG and HOME programs as well as a full review of all case files (Affordable Housing Consultants). Included with this response are the contracts with both Civitas and Affordable Housing Consultants for verification purposes. The County anticipates their work to be completed and an implementation of updated policies and procedures for these programs by fall of 2024. The role of Program Administrator over the HOME program was not filled until April of 2024. This role will be responsible for all future HOME program inspections. Community Resources CDHHS employees will be taking part in a two-day training in June 2024 (June 11th and 12th, 2024) for the following:  Davis Bacon & Related Acts (Applicability, wage determinations, payroll review, interviews, common errors and how to correct)  Section 3 (Applicability, Safe Harbor benchmarks, documenting compliance, qualitative efforts)  TBRA Inspections (National Standards for the Physical Inspection of Real Estate (NSPIRE) administrative procedures)  HOME Program - Implementation and Best Practices - Arapahoe County, CO - June 12, 2024  This HOME training is an introductory course focusing on underwriting and subsidy layering requirements.  Eligible Activities (Homeowner rehab programs, Homebuyer programs, Rental housing)  Underwriting (Subsidy layering and underwriting requirements and best practices)  Community Housing Development Organization (CHDO) (Requirements, best practices, management, etc)  Long-term Compliance (HOME Match, eligible beneficiaries, income limits, subsidy layering & limits, affordability, written agreements, etc)  IDIS and Reporting Arapahoe County staff will be conducting monitoring of the two Tenant Based Rental Assistance (TBRA) programs and projects within in the affordability period (20-year span) between mid-June to mid-August of 2024. The remaining HOME program projects, within the affordability period (20-year span) will have audits completed by the end of our 2023 grant cycle, September 30th, 2024. Name of the contact person responsible for corrective action: Katherine Smith Planned completion date for corrective action plan: September 30, 2024
Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payme...
Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Housing Choice Voucher department is addressing inspection controls in multiple ways. The Department has added additional staffing and also has created new tracking that makes it easier to review and identify units that have not passed inspection and not been abated. The Department has also instituted an ongoing process that has the inspections manager conducting a monthly review of units moving through the abatement process to ensure timely processing and cessation of HAP payments as needed. As part of this review the Department is also conducting a comprehensive review of units that have prior failed inspections to ensure abatement occurred. Name of the contact person responsible for corrective action: Mark La Brayere Planned completion date for corrective action plan: Three elements are continuous with no final completion date. The singular comprehensive review is scheduled to be completed within three months.
View Audit 315516 Questioned Costs: $1
Oversight Agency for Audit, Palermo Lakes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit per...
Oversight Agency for Audit, Palermo Lakes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2023 through December 31, 2023 The finding from the December 31, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2023-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should make sufficient deposits to the escrow accounts in a timely manner. Action Taken: New procedures have been implemented to ensure appropriate amounts are reserved in escrow. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that performance reports are prepared and reviewed by separate individuals. Documentation will be ...
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that performance reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of annual report.
Management will prepare the surplus cash calculation in a matter timely enough to ensure any required deposit to the residual receipts account is made within 90 days of year-end.
Management will prepare the surplus cash calculation in a matter timely enough to ensure any required deposit to the residual receipts account is made within 90 days of year-end.
Northwest Regional Housing Authority Abatement process will be enforced. There were several issues last year with inability to get materials and labor. Northwest Regional Housing Authority over road abatement when this was the issue. We will keep better records of abatements. Moving forward, we will...
Northwest Regional Housing Authority Abatement process will be enforced. There were several issues last year with inability to get materials and labor. Northwest Regional Housing Authority over road abatement when this was the issue. We will keep better records of abatements. Moving forward, we will follow the abatement requirements as required.
The delinquent deposit will be made Tuesday May 21, 2024. In the future, the calculation will be done in February and if there is surplus cash, the funds will be deposited within the required time period.
The delinquent deposit will be made Tuesday May 21, 2024. In the future, the calculation will be done in February and if there is surplus cash, the funds will be deposited within the required time period.
Management is in agreement with the finding and will adhere to the requirements set forth in the HUD Handbook going forward and reinstate the fidelity bond insurance policy in accordance with HUD regulations.
Management is in agreement with the finding and will adhere to the requirements set forth in the HUD Handbook going forward and reinstate the fidelity bond insurance policy in accordance with HUD regulations.
In accordance with HUD regulations, entities should not make unauthorized distributions of project funds. The project paid expenses for an adjacent property. The Corporation paid non-project expenses from Project funds. The Project is noncompliant with the HUD regulatory agreement. Expense allocatio...
In accordance with HUD regulations, entities should not make unauthorized distributions of project funds. The project paid expenses for an adjacent property. The Corporation paid non-project expenses from Project funds. The Project is noncompliant with the HUD regulatory agreement. Expense allocations should be closely monitored to ensure Project funds are not used for non-project expenses.
View Audit 315100 Questioned Costs: $1
Corrective Action Plan Project Legal Name: Boston Tremont Housing Development Fund Corporation HUD Project Nos.: NY 36L000080 and NY 36L000081 Audit Firm: CohnReznick LLP Period covered by the audit: December 31, 2023 Corrective Action Plan prepared by: Name: Lukeman Ogunyinka Position: Chief Financ...
Corrective Action Plan Project Legal Name: Boston Tremont Housing Development Fund Corporation HUD Project Nos.: NY 36L000080 and NY 36L000081 Audit Firm: CohnReznick LLP Period covered by the audit: December 31, 2023 Corrective Action Plan prepared by: Name: Lukeman Ogunyinka Position: Chief Financial Officer Telephone Number: (212) 243-9090 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2023-1 a. Comments on the Finding and Each Recommendation 4 out of 26 tenants tested did not have an annual tenant recertification Form HUD 50059 completed timely. Moving forward, management will follow established procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with the guidelines specified by HUD. b. Action(s) Taken or Planned on the Finding Management has addressed the issue by recertifying the tenant and does not expect a late recertification to occur again based on procedures in place.
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