Corrective Action Plans

Finding 528256 (2023-001)

Material Weakness 2023

Casita Park Housing Development Fund Corporation

NY

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Finding 2023-001 a. Condition During the year ended September 30, 2023, the project paid insurance expenses in the amount of $4,247 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of September 30, 2023 is $53,397. b. Action(s) Taken or Planned on th...

Finding 2023-001 a. Condition During the year ended September 30, 2023, the project paid insurance expenses in the amount of $4,247 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of September 30, 2023 is $53,397. b. Action(s) Taken or Planned on the Finding Because the PRAC contracts expire in April there is a delay in receiving subsidy monies until the renewals are approved. Insurance costs for this entity continue to increase exponentially, creating a financial burden on the project. To ensure the policies don’t cancel we will have the entity with the most money pay the bill and have the other PRAC projects reimburse. In 2023/2024 the PRACs are now on a five-year renewal so there should not be a delay in receiving subsidy monies. Thus, going forward, we do not anticipate this being an issue as long as the subsidy monies aren’t delayed and the rent increases are substantial enough to cover the large increases in insurance renewal premiums. The Corporation agrees with the finding and the auditor's recommendations have been adopted. As of the report date and subsequent to the statement of financial position date, the $53,397 was repaid back to the Corporation.

View Audit 346289 Questioned Costs: $1

Finding 524581 (2023-001)

Significant Deficiency 2023

City of Clarksville

TN

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Management’s Corrective Action Plan: Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements. This matter was resolved subsequent to June 3...

Management’s Corrective Action Plan: Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements. This matter was resolved subsequent to June 30, 2023.

View Audit 344028

Finding 524463 (2023-002)

Significant Deficiency 2023

Collier Housing Alternatives, Inc.

FL

HUD Housing Programs Reporting

The management's company's new CFO has brought the filings up-to-date as of November 2024 and reporting sumbissions will now be filed in a timely manner.

View Audit 343799

Finding 524240 (2023-002)

Material Weakness 2023

Next Move Homeless Services

CA

Questioned Costs Special Tests & Provisions HUD Housing Programs

Program: Continuum of Care Federal Financial Assistance Listing No.:14.267 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward Award Year: 2023 Compliance Requirement: Special Tests and Provisions – Reasonable Rental Rates Grant Award Number: ...

Program: Continuum of Care Federal Financial Assistance Listing No.:14.267 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward Award Year: 2023 Compliance Requirement: Special Tests and Provisions – Reasonable Rental Rates Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208 Finding Summary: • As a result of our procedures performed, we noted for 8 out of 17 rental participants tested, the organization could not provide documentation to demonstrate the reasonableness of contract rents being paid for individual housing units in relation to rents being charged for comparable units. This should have included an analysis of rents in the immediate area of the participants housing. • For 3 out of 41 rental payments tested, we noted the rent paid exceed the HUD-determined fair market rents for the fiscal year. Repeat Finding from Prior Years: Yes, Finding 2022-002 Management’s Response: We concur. Views of Responsible Officials and Corrective Action: • Develop policies and procedures for staff working on grants to ensure that all contract rents being paid for individual housing units are reasonable in relation to rents being charged for comparable units. Additionally, the policies and procedures will ensure that grant funds being used to pay rent will not exceed HUD-determined fair market rents. • Train grant staff on new policies and procedures. Name of Responsible Person: Bryan Wagner, CFO Projected Implementation Date: December 31, 2024

View Audit 343437 Questioned Costs: $1

Finding 523665 (2023-001)

Material Weakness 2023

Young Womens Christian Association of Greater Lafayette

IN

HUD Housing Programs Internal Control / Segregation of Duties

2023-001: EMPLOYMENT VERIFICATION--VOCA Issue: Employment Verification form for one employee from a sample of ten was missing from the employee’s files. Recommendation: Internal controls and procedures should be established, and documentation maintained to support all employee verification for emp...

2023-001: EMPLOYMENT VERIFICATION--VOCA Issue: Employment Verification form for one employee from a sample of ten was missing from the employee’s files. Recommendation: Internal controls and procedures should be established, and documentation maintained to support all employee verification for employment. Corrective Actions: YWCA acknowledges discrepancies in data metrics reported. • Implement a standardized checklist for employment documentation. • Educate HR staff on audit best practices, emphasizing complete and accurate employee files. • Schedule quarterly reviews to ensure compliance with documentation requirements.

View Audit 343088

Finding 523601 (2023-001)

None 2023

Iha, INC

CT

HUD Housing Programs Procurement, Suspension & Debarment Special Tests & Provisions

U.S. Department of Housing and Urban Development AUDIT FINDINGS: Finding Reference Number: 2023-001 Description of Finding: Homes with Hope, Inc. and Affiliate provides supportive housing via HUD Project Number 017-HD015, which requires the establishment and maintenance of a replacement reserve f...

U.S. Department of Housing and Urban Development AUDIT FINDINGS: Finding Reference Number: 2023-001 Description of Finding: Homes with Hope, Inc. and Affiliate provides supportive housing via HUD Project Number 017-HD015, which requires the establishment and maintenance of a replacement reserve fund in accordance with its HUD Regulatory Agreement. The Project did not make the monthly deposits in a timely manner during the year ended December 31, 2023 as specified in the agreement, and seven months’ worth of deposits were delinquent as of December 31, 2023. This was due, at least in part, to cash flow issues that resulted from delays in the process that the Project’s property manager utilized during the period for invoicing HUD via a third-party vendor for the related rental subsidy funds. Statement of Concurrence or Nonconcurrence: Homes with Hope, Inc. and Affiliate concurs with this audit finding. Corrective Action: A new in-house billing process that does not rely on a third-party vendor has been implemented since year-end, which should eliminate the cash-flow issue, Additionally, all delinquent deposits that were due as of December 31, 2023, were deposited in March 2024. Name of Contact Person: Helen McAlinden President & Chief Executive Director 203-226-3426x14 hmcalinden@hwhct.org Projected Completion Date: Immediately

View Audit 342991

Finding 523546 (2023-002)

Significant Deficiency 2023

Pennsylvania Housing Finance Agency

PA

Questioned Costs Cash Management HUD Housing Programs

U.S. Department of Housing and Urban Development Housing Trust Fund Program – Assistance Listing No. 14.275 Recommendation: CLA recommended that PHFA review their procedures around administrative expenses charged to the HTF program. Explanation of disagreement with audit finding: There is no disa...

U.S. Department of Housing and Urban Development Housing Trust Fund Program – Assistance Listing No. 14.275 Recommendation: CLA recommended that PHFA review their procedures around administrative expenses charged to the HTF program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHFA will implement electronic time tracking, this will replace the current manual process of preparing timesheets that are entered into a database used to accumulate administrative expenses charged to federal programs. PHFA is currently in the process of implementing a Human Capital Management system that will allow employees to track the time they work on federal programs. Name of the contact person responsible for corrective action: Adrianne Trumpy, Director of Accounting Planned completion date for corrective action plan: July 1, 2024

View Audit 342838 Questioned Costs: $1

Finding 523361 (2023-019)

Material Weakness 2023

Government of Guam

GU

Subrecipient Monitoring Reporting HUD Housing Programs

Finding No.: 2023-019 Reporting Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director (DOA) An awardee could not report the required information in FSRS unless the federal awarding agency has registered the award. The US Treasury has no...

Finding No.: 2023-019 Reporting Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director (DOA) An awardee could not report the required information in FSRS unless the federal awarding agency has registered the award. The US Treasury has not advised the Government that they have registered the Capital Projects Fund award.

View Audit 342645

Finding 523109 (2023-006)

Significant Deficiency 2023

Municipality of Las Piedras

PR

HUD Housing Programs Reporting

We partially concur with this finding. The unaudited report for the fiscal year ended June 30, 2023 was submitted through the portal of REAC on September 12, 2024. Regarding the late filing of the 2022 report, we concur with the finding. On September 12, 2024, the unaudited report for fiscal year...

We partially concur with this finding. The unaudited report for the fiscal year ended June 30, 2023 was submitted through the portal of REAC on September 12, 2024. Regarding the late filing of the 2022 report, we concur with the finding. On September 12, 2024, the unaudited report for fiscal year 2024 was submitted to REAC. The Department of Federal Programs will implement new controls and procedures to ensure these reports are prepared and submitted in a timely manner each subsequent fiscal year. Anticipated completion date: September 12, 2024 Contact person: Mr. Edjoel Cosme, Director of Federal Programs Telephone: (787) 733-2160 Email: federaleslp@gmail.com

View Audit 342411

Finding 522624 (2023-002)

Significant Deficiency 2023

Caldwell County, Missouri

MO

Subrecipient Monitoring Reporting HUD Housing Programs § 200.510

I was a newly elected official in 2023 with no prior training in the County Clerk’s office. I had no knowledge of how SEFA monies were to be reported. After this finding was brought to my attention, internal controls were implemented. A process/procedure was put into place where all grants received ...

I was a newly elected official in 2023 with no prior training in the County Clerk’s office. I had no knowledge of how SEFA monies were to be reported. After this finding was brought to my attention, internal controls were implemented. A process/procedure was put into place where all grants received are tracked, as are the expenditures for each grant. The clerk and deputy clerk are now involved in the grant tracking procedure as well as reviewing the SEFA report for accuracy after it is prepared. In January 2025 a Grant Policy was adopted by the Caldwell County Commission to make all county employees aware of the process for reporting and tracking grants received. The Grant Expenditures and Reimbursements Tracking Procedures were also revised. The procedure now involves not only the county clerk and deputy clerk, but also the grant applicant, accounts payable clerk, and the county Collector/Treasurer. The SEFA report will be reviewed by all involved to help ensure accuracy. Anticipated Completion Date: It is anticipated that the 2025 SEFA grant reporting will be much more accurate than in previous years. However, considering the new Grant Policy and the revised Grant Expenditures and Reimbursement Tracking Procedures were not in place until January 2025, it is anticipated that the date of completion will be January 2026.

View Audit 341878

Finding 522411 (2023-005)

Significant Deficiency 2023

400-408 Housing Development Fund Company INC

NY

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Management has acknowledged a breach in protocol and deposited the current year’s surplus cash on February 6, 2025.

View Audit 341688

Finding 522395 (2023-005)

Significant Deficiency 2023

Rome Housing Authority

NY

HUD Housing Programs Cash Management Significant Deficiency § 200.05

2023-005 Drawing of Capital Funds RHA is committed to ensuring that all capital fund expenditures are processed and distributed within a maximum of three days. By doing this we will stay in compliance with HUD regulations. Name of Responsible Person: Tami Lucia Executive Director Implementation d...

2023-005 Drawing of Capital Funds RHA is committed to ensuring that all capital fund expenditures are processed and distributed within a maximum of three days. By doing this we will stay in compliance with HUD regulations. Name of Responsible Person: Tami Lucia Executive Director Implementation date: October 2024

View Audit 341664

Finding 522394 (2023-004)

Significant Deficiency 2023

Rome Housing Authority

NY

HUD Housing Programs Reporting Significant Deficiency

he Executive Director has implemented procedures for the procurement of an auditor to ensure the Financia Data Schedule is filed within nine months after the conclusion of the fiscal year. Name of Responsible Person: Tami Lucia, Executive Director Implementation date: April 2024

View Audit 341664

Finding 522393 (2023-003)

Significant Deficiency 2023

Rome Housing Authority

NY

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions

2023-003 Selection of the Waiting List RHA has put in place comprehensive new procedures and controls for all the staff members, including Clerks, Housing Assistants, Housing Coordinators and Project Managers, concerning the management of the waiting list process. As of September 2024m a new waitin...

2023-003 Selection of the Waiting List RHA has put in place comprehensive new procedures and controls for all the staff members, including Clerks, Housing Assistants, Housing Coordinators and Project Managers, concerning the management of the waiting list process. As of September 2024m a new waiting list will be generating following each new move-in, and the previous waiting list will be appropriately filed and preserved. Name of Responsible Person: Entire Admin Staff Implementation Date: September 2024

View Audit 341664

Finding 522198 (2023-004)

Material Weakness 2023

Municipality of Barceloneta

PR

HUD Housing Programs Reporting

We recommend of the municipality has issued clear and specific instructions to the director of this area, demanding that she and her team take immediate measures to ensure that these types of findings are not repeated in future fiscal periods or in the years to come.

View Audit 341405

Finding 522156 (2023-003)

Material Weakness 2023

Housing Authority of the County of Monroe

WI

HUD Housing Programs Reporting

Corrective Action Planned: The Authority will make sure their future audits are completed timely and Audited REAC submissions are completed on time.

View Audit 341370

Finding 520848 (2023-006)

Material Weakness 2023

Municipality of Ceiba

PR

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

We concur with the finding. During the fiscal year 2024-2025, all participant files will be revised to include all missing documents referred to in the finding.

View Audit 340664

Finding 520847 (2023-005)

Material Weakness 2023

Municipality of Ceiba

PR

HUD Housing Programs Reporting

We concur with the finding. During the fiscal year 2024-2025, both reports for fiscal years 2021 and 2022 will be filed. Therefore, the conditions of the findings have been corrected.

View Audit 340664

Finding 520813 (2023-005)

Material Weakness 2023

County of Trinity

CA

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

Federal program title – Home Partnership Investment Program – HOME loan – CFDA 14.239 Recommendation: CLA recommends the County develop procedures, such as including a compliance checklist in the receivables listing sent to the auditor’s office, to ensure that outstanding loan continuing compliance...

Federal program title – Home Partnership Investment Program – HOME loan – CFDA 14.239 Recommendation: CLA recommends the County develop procedures, such as including a compliance checklist in the receivables listing sent to the auditor’s office, to ensure that outstanding loan continuing compliance is performed timely and documented in accordance with the HOME grant loan provision. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grants department had two employees in FY 22/23. The Grant coordinator and assistant both terminated county employment in fiscal year 22/23 and left virtually no records. Information and materials, they did leave behind were stuffed in boxes and tracking in the electronic workbook was not fully completed. Admin staff trained the Grant employees but was unaware they were not following the process and procedures, and only saving information to their personal computer. Current admin staff requested the documents from prior staff members and they were received, though we are unsure if all were sent. Staff is doing their due diligence and working diligently to get back on track in monitoring activities, and train the newly hired staff. There is insufficient budget to hire the staff needed to fully monitor the Home Program loan efforts. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins. Planned completion date for correcting action plan: Undetermined at this time as the staff continues their current minimal Home Program loan efforts while still maintaining all other duties, and being short staffed. Existing Home Program workload is being closed out as fast as possible.

View Audit 340608 Questioned Costs: $1

Finding 520808 (2023-004)

Material Weakness 2023

County of Trinity

CA

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

Federal program title – Community Development Block Grant – CDBG – CFDA 14.228 Recommendation: CLA recommends the County develop procedures, such as including a compliance check list in the receivables listing sent to auditor’s office, to ensure that outstanding loan continuing compliance is perfor...

Federal program title – Community Development Block Grant – CDBG – CFDA 14.228 Recommendation: CLA recommends the County develop procedures, such as including a compliance check list in the receivables listing sent to auditor’s office, to ensure that outstanding loan continuing compliance is performed timely and documented in accordance with the CDBG grant loan provision. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grants department had two employees in FY 22/23. The Grant coordinator and assistant both terminated county employment in fiscal year 22/23 and left virtually no records. Information and materials, they did leave behind were stuffed in boxes and tracking in the electronic workbook was not fully completed. Admin staff trained the Grant employees but was unaware they were not following the process and procedures, and only saving information to their personal computer. Current admin staff requested the documents from prior staff members and they were received, though we are unsure if all were sent. Staff is doing their due diligence and working diligently to get back on track in monitoring activities, and train the newly hired staff. There is insufficient budget to hire the staff needed to fully monitor the CDBG efforts. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins Planned completion date for correcting action plan: Undetermined at this time as the staff continues their current minimal CDBG efforts while still maintaining all other duties, and being short staffed. Existing CDBG workload is being closed out as fast as possible.

View Audit 340608 Questioned Costs: $1

Finding 520223 (2023-002)

Significant Deficiency 2023

Central Montana Regional Water Authority

MT

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.302

The Project Administrator will reimburse the funds to the Montana Department of Natural Resources (DNRC), based on directions provided by DNRC. The Project Administrator will work with the outside accountant on record keeping of the Authority. Responsible Officials: Monty Sealey, Project Manager an...

The Project Administrator will reimburse the funds to the Montana Department of Natural Resources (DNRC), based on directions provided by DNRC. The Project Administrator will work with the outside accountant on record keeping of the Authority. Responsible Officials: Monty Sealey, Project Manager and Melissa Carlson, Accountant Expected Completion Date: by June 30, 2025

View Audit 339789 Questioned Costs: $1

Finding 520210 (2023-007)

Material Weakness 2023

I&f Incorporated Nfp

IL

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

FINDING 2023-007: LACK OF INTERNAL CONTROLS OVER COMPLIANCE Corrective Action Plan A compliance management framework will be developed by March 31, 2025, and training for relevant staff will begin shortly thereafter. Monitoring mechanisms and documentation practices will also be implemented to ensu...

FINDING 2023-007: LACK OF INTERNAL CONTROLS OVER COMPLIANCE Corrective Action Plan A compliance management framework will be developed by March 31, 2025, and training for relevant staff will begin shortly thereafter. Monitoring mechanisms and documentation practices will also be implemented to ensure ongoing compliance. Estimated Completion Date: 3/31/2025 Contact Person for Implementation of All Corrective Action Plans: Andre Thomas (Executive Director) (773) 756-6806

View Audit 339764

Finding 520151 (2023-004)

Significant Deficiency 2023

City of Alamogordo

NM

Internal Control / Segregation of Duties HUD Housing Programs Significant Deficiency

Auditor's Recommendation – CRI recommends that the contract immediately be amended to include the required prevailing wage rate clauses. Furthermore, a review process should be implemented to ensure all future contracts comply with prevailing wage requirements. Views of Responsible Officials and Pla...

Auditor's Recommendation – CRI recommends that the contract immediately be amended to include the required prevailing wage rate clauses. Furthermore, a review process should be implemented to ensure all future contracts comply with prevailing wage requirements. Views of Responsible Officials and Planned Corrective Action – Prior to the transfer of the Housing Authority to the Eastern Regional Housing Authority (ERHA), the City of Alamogordo did not understand the limitations of the ERHA accounting and financial system. Since this time, the City has had multiple conversations with ERHA leadership about their financials systems. The City has no authority over ERHA and does not expect any changes in their accounting practices. Responsible Person – ERHA Accounting Staff Targeted Date of Completion – Fiscal Year 2025

View Audit 339709

Finding 520110 (2023-004)

Material Weakness 2023

City of Allentown

PA

Reporting HUD Housing Programs

Finding 2023-004-Reporting Repeat Finding-See Finding 2022-005 Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. Action Take...

Finding 2023-004-Reporting Repeat Finding-See Finding 2022-005 Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. Action Taken: The Grants Accountant reconciles all required reports to the general ledger prior to submission. The Grants Manager reviews and approves the Grants Accountant's reconciliations. These procedures were implemented effective June 30, 2024.

View Audit 339690

Finding 520108 (2023-002)

Material Weakness 2023

City of Allentown

PA

Special Tests & Provisions HUD Housing Programs Internal Control / Segregation of Duties

Finding 2023-002-SpecialTests and Provisions-Citizen Participation Repeat Finding-See Finding 2022-003 Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submissi...

Finding 2023-002-SpecialTests and Provisions-Citizen Participation Repeat Finding-See Finding 2022-003 Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. Action Taken: The City has adopted HUD regulations to comply with all citizen participation requirements (24 CFR 91.105). These were implemented January 1, 2024.

View Audit 339690

Corrective Action Plans

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