Corrective Action Plans

MIRACLE SQUARE, INC. Sumter, South Carolina CORRECTIVE ACTION PLAN October 29, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Miracle Square, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2023. Bernard Robinson & Company, L.L.P. Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended December 31, 2023 The findings from the Schedule of Findings and Questioned Costs for the year ended December 31, 2023 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2023-001 - U.S. Department of Housing and Urban Development, Supportive Housing for Persons with Disabilities (Section 811), Assistance Listing #14.181 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due date. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the annual financial statements are submitted once the audits are back on track with the scheduled due dates. Finding 2023-002 - U.S. Department of Housing and Urban Development, Supportive Housing for Persons with Disabilities (Section 811), Assistance Listing #14.181 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. If HUD has questions regarding this plan, please call (803) 808-3966. Sincerely yours, Reese Quick, President Southern Development Management Company, Inc.

Brockwood Community Association 801 W. Washington Street Greenville, South Carolina 29601 CORRECTIVE ACTION PLAN March 20, 2024 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Brockwood Community Association respectively submits the following Corrective Action Plan for the year ended December 31, 2023. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The finding from the year ended December 31, 2023 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING - Federal Award Program Audit Finding 2023-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects (Section 223(f)/207) Recommendation: We recommend that the management ensure the required household members sign the HUD-50059 prior to submitting to HUD. Action Taken: We agree with Finding 2023-001 and the recommendation described in the accompanying schedule of findings and questioned costs. Management obtained the required signature on the HUD-50059. Management will ensure that all required signatures are obtained on all Form HUD-50059's prior to submitting to HUD going forward. If HUD has questions regarding this corrective action plan, please call (704) 771-1696. Sincerely yours, Claudia A Keene, CPA Controller Multifamily Select, Inc. Managing Agent

Finding number 2023-002: 14.157 Supportive Housing for the Elderly Condition: The Project was late in making its July city real estate tax payment of which the first half is due August 1 of each year incurring a penalty of $1,754.89. This penalty is not an allowed Project cost. Recommendation: Other sources should be sought out to pay these penalties or other expenses be deferred to enable the taxes to be paid on time. Action Taken: To avoid incurring interest on taxes due in January 2025 and beyond, management has implemented a policy to set aside funds the month prior to the due date to eliminate the risk that delayed subsidy or other funding shortfall makes timely payment impossible. The Project will seek donations or other funding sources to recover funds. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Matthew Fontaine at (860) 951-9411 extension 249. Sincerely, Matthew Fontaine, CPA Managing Agent

Corrective Action Plan September 27, 2024 U.S. Department of Housing & Urban Development 20 Church Street, 10th floor Hartford, CT 06103 St Luke's Senior Housing Inc. respectfully submits the following corrective action plan for St Luke's Senior Housing (Project #Ol 7-EE086) year ended December 31, 2023, which was audited by: Bailey, Moore, Glazer, Schaefer & Proto LLP 16 Lunar Drive Woodbridge, CT 06525 The findings from the 12/31/2023 schedule of findings and questions costs are discussed below and numbered consistently with the numbers assigned in the schedule. FINDINGS- FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AW ARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Finding number 2023-001: 14.157 Supportive Housing for the Elderly Condition: The Project failed to make the December deposit to the replacement reserve and did not catch up the deposits when the December voucher was deposited in early January. Recommendation: Care should be taken to catchup any missing deposits and return approved loans when the missing vouchers are eventually deposited. Action Taken: The Project made the required deposit to get current. Also, the project will make the required reserve deposit as part of its monthly review of financials to ensure this account is adequately funded.

2023-004 Tenant File Documentation The Housing Authority of Okanogan County recognizes we had several oversights in our tenant file documentation. We will continue to review our tenant file documentation procedures to ensure compliance with HUD program requirements in the future. Subsequent to year-end, during April 2024, the Housing Authority of Okanogan County underwent a Section 8 Management Assessment Program review by the U.S. Department of Housing and Urban Development and received a final score of Standard. We have made several process and procedure improvements and anticipate full compliance during our subsequent audit.

2023-003 – Late Federal Audit Clearinghouse and HUD REAC Submissions The Housing Authority of Okanogan County recognizes the agency did not have adequate internal control processes over our accounting and reporting procedures to ensure that all reports were submitted timely in accordance with Federal requirements. We are reviewing our year end accounting procedures and will implement several changes ensuring our 2024 audit will be completed and filed timely.

Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2023 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (2) Finding 2023-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will provide on-going training for finance and accounting personnel to expand their knowledge on HUD reporting requirements related to VMS. Additionally, the Authority will conduct a thorough review to identify the root cause of the discrepancies between the VMS data and the supporting documentation. (c) Planned implementation date of corrective action - Completed by March 31, 2025.

Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2023 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (3) Finding 2023-003 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.

Statement of condition #2023-002: The Corporation did not furnish HUD a complete annual financial report within ninety (90) days following the end of the fiscal year ending March 31, 2023. Additionally, Form SF-SAC Single Audit Data Collection Form for the years ended March 31, 2023 and 2022 was not submitted to the federal audit clearinghouse in the required timeframe. Recommendation: The Corporation should submit the annual financial statements to HUD and Form SF-SAC Single Audit Data Collection Form for the years ended March 31, 2023 and 2022 as soon as practical. Action(s) Taken or Planned on the Finding: Management concurs with the finding and recommendation. The audited financial statements have been submitted to HUD and the federal clearinghouse. No further action is required.

CAMcare has made significant revisions to the financial screening department's leadership and workflows. We have since revised our Sliding Fee Scale Policy, the scale itself, and the SOPs for both Financial Screening of Uninsured and Underinsured Patients and Financial Assistance. All patient registration areas have the latest board-approved sliding fee scale, and the changes were announced during a weekly staff huddle. All PSRs and Financial Screeners were made aware of the change. The new Manager of the financial screening department has provided the team with subject matter expertise, additional training, and increased accountability in work product. CAMcare also has a new EMR system, Epic, (December of 2023) where applications are housed and tracked, creating a single record for financial screening with patient changes being more streamlined. The latest sliding fee scales have been uploaded to the EMR. Patients with applications in progress can be edited as needed more efficiently.

The following procedure is put in place to prevent the conditins found during a recent audit review of the LIPH and HCV files: All staff will read HUD requirements for reexamining income and family composition for families in the Public Housing and Housing Voucher Programs. Property managers will be reuqiqred to complete training courses in 2024. Property clerks and leasing specialists will be required to complete Rent Calculation courses that coorelate to their program type. HACFM is actively working on creating operation procedures and process manuals. the Procedure manaul will include the following reuqirements: Annual recertificaton packets will be sent to the resident 120 days from the houshold's annual effective date. Submission of reuqired documentation from resident will be enforced according to the lease agreements. A certification review checklist to support staff in ensuring all documnetation is in the file and all requried signatures are present. The Checklist will ensure that the submitter is verifying the file, the property manager has certified the file prior to finalizing the review in the tenant software program and uploading the file to the records. The property manager is reuqired to conduct 5% audit of the files monthly and correct any deficiencies found. An audit checklist will be created to support this required task. The management analyst position is required to audit 5 random files from each site on a quarterly basis. Ans audit checklist will be createdto support this required task.

The following procedure is put in place to prevent the conditins found during a recent audit review of the LIPH and HCV files: All staff will read HUD requirements for reexamining income and family composition for families in the Public Housing and Housing Voucher Programs. Property managers will be reuqiqred to complete training courses in 2024. Property clerks and leasing specialists will be required to complete Rent Calculation courses that coorelate to their program type. HACFM is actively working on creating operation procedures and process manuals. the Procedure manaul will include the following reuqirements: Annual recertificaton packets will be sent to the resident 120 days from the houshold's annual effective date. Submission of reuqired documentation from resident will be enforced according to the lease agreements. A certification review checklist to support staff in ensuring all documnetation is in the file and all requried signatures are present. The Checklist will ensure that the submitter is verifying the file, the property manager has certified the file prior to finalizing the review in the tenant software program and uploading the file to the records. The property manager is reuqired to conduct 5% audit of the files monthly and correct any deficiencies found. An audit checklist will be created to support this required task. The management analyst position is required to audit 5 random files from each site on a quarterly basis. Ans audit checklist will be createdto support this required task.

Federal Agency: US Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2205MN5ADM, 2023 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance Recommendation: We recommend the County puts in place the proper procedures to ensure it has proper controls in place to properly document the review of the state time study listings each quarter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will ensure there are proper financial procedures and controls in place to properly document the review of the state time study listings each quarter. Name(s) of the contact person(s) responsible for corrective action: Angie Larson, Auditor-Treasurer / Chief Financial Officer Planned completion date for corrective action plan: December, 31 2024

Finding 2023-001: For the years ending December 31, 2023 and 2022, the Corporation did not submit the Data Collection Form to the Federal Audit Clearinghouse in the time period required by Uniform Guidance. Comments on the Finding and Each Recommendation: The Corporation should submit the Data Collection Form to the Federal Audit Clearinghouse within the required time period. Management agrees with the finding and recommendation. Action(s) taken or planned on the finding: The Data Collection Form for the year ended December 31, 2022, was submitted on November 19, 2024. For the year ended December 31, 2023, the Data Collection Form will be submitted as soon as possible.

Recommendation: Management needs to ensure accounting transactions affecting related parties are communicated in a timely manner to ensure accuracy and agreement between the entities. Management’s Response: Management concurs with the auditor’s finding that the Project’s related parties should communicate and reconcile accounting transactions in a timely manner. Communications and reconciliation will begin immediately.

Recommendation: Management needs to ensure accrual basis of accounting is maintained. Accounting records need to be reconciled between management agent and Project owner and to the audited financial statements to ensure all entries have been made and the financial records current and accurate. Track invoices to ensure they are correctly recorded in the financial statements and when paid, they are properly removed from the schedules. Management’s Response: Management concurs with the auditor’s finding that the Project’s accounting records should be maintained and reconciled between management agent and Project owner and the audited financial statement. Communications and reconciliations will begin immediately.

Assistance listing numbers and program names: 21.023 COVID-19 - Emergency Rental Assistance Program 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Molly Bright, DES CCSD Assistant Director Anticipated completion date: June 30, 2026 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: 1. Ensure benefit payments are for allowable costs paid to or on behalf of eligible program applicants. The Department will review and confirm that benefits payments paid to or on the behalf of eligible program applicants are allowable expenditures of the federal funding being disbursed. 2. Follow existing policies and procedures to obtain required documentation to support requirements related to where the applicant lives and their income to ensure program applicants are eligible to receive benefit payments. The Department will abide by the existing adjudication policies and procedures that require the submission of substantiating documentation supporting the claims made by applicants regarding where they live and their household income to confirm that applicants are eligible to receive benefit payments under the program and to verify the amount of benefits they shall receive. 3. Allocate sufficient staffing resources to perform a thorough evaluation of program benefits applications and provide training on eligibility requirements and allowable benefit payments. The Department will attempt to obtain or allocate additional resources to staffing to support the program benefits application evaluation process and will provide additional training to staff on eligibility requirements and allowable benefit payment regulations. 4. Update the checklist Division personnel use to perform a post-review of eligibility determinations to include detailed guidance for verifying the determinations aligned with the Division’s written policies and procedures and supported by adequate documentation. The Department will update the checklist being used by staff to perform post-review of eligibility determinations to include detailed guidance on verifying the applicant benefits determinations in alignment with the divisional policies and procedures and evidenced by adequate substantiating documentation.

I was a newly elected official in 2023 with no prior training in the County Clerk’s office. After this finding was brought to my attention, I created a process where all grants received are tracked as are the expenditures for each grant so they can accurately be reported.

Eastern Carolina Human Services Agency, Inc. Corrective Action Plan For FY Ending June 30, 2023 Section II. Financial Statement Findings. 1. Finding 2023-001 - U.S. Department of Health and Human Services, Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: Internal control processes over financial accounting did not ensure that all transactions were properly recorded. Internal control processes over financial accounting did not ensure that key accounts were reconciled or received on a periodic basis. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director. Action Plan: After review/monitoring of the previous Finance Officers duties and responsibilities, it was determined that the internal control processes of the finance department were not carried out properly to meet the requirements of 2 CFR Part 200 Section 200.302. Therefore, the agency terminated the Finance Officer. The agency immediately began the search for a new Finance Officer via Indeed and other employment hiring agencies. This process took much longer than expected which left an unexperienced Accounting Technician to operate the Finance Department along with limited finance knowledge of the Executive Director. After several advertisements for the vacant position the agency interviewed numerous applicants and was finally able to hire the current Finance Officer. The Finance Officer has worked continuously to insure that the internal control process of the department is implemented by making sure all accounts are reconciled and reviewed with supporting evidence of each review. With this process back in place, management and the Board of Directors will review and sign off on each account's financial statements. Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-002 - U. S. Department of Housing and Urban Development Voucher Cluster, Assistance Listing #14.871/14.879 Statement of Condition: For the year ended June 30, 2022, the Organization did not submit their audited financial statements to HUD by the required deadline. For the year ended June 30, 2023, the Origination did not submit their unaudited or audited financial statements to HUD by the required deadline. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: The submittal of the GAAP-based unaudited and audited report for FY ending June 30, 2022, was a management oversight due to the lack of a Finance Officer in place. The agency currently has a Finance Officer in place who will submit timely GAAP-based unaudited and audited financial information electronically to HUD via the Financial Assessment Sub-System (FASS-PH). Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-03 - U.S. Department of Health and Human Services Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: The origination did not submit the data collection form and required reporting package to the Federal Audit Clearinghouse (FAC) for the year ended June 30, 2023, by the required due date. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: Management will ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. To further ensure this finding is resolved, training for the Finance Officer/Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Section II - Findings relating to the financial statements which are required to be reported in accordance with generally accepted government auditing standards. 1. Finding 2022-001 Statement of Condition: Controls over the vendor payment process were not properly followed. Action Plan: Submitted previously with Financial Statements and Independent Auditor's Report FY Ended June 30, 2022. Current Status: Corrected The Management Department (Finance Officer and Executive Director), with the supervision of the Board of Directors Finance Officer, will continue to make every effort necessary to meet all HUD submission as required, in order to be in compliance with all HUD rules and regulations. Respectfully submitted, Trudy Murray Executive Director

Eastern Carolina Human Services Agency, Inc. Corrective Action Plan For FY Ending June 30, 2023 Section II. Financial Statement Findings. 1. Finding 2023-001 - U.S. Department of Health and Human Services, Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: Internal control processes over financial accounting did not ensure that all transactions were properly recorded. Internal control processes over financial accounting did not ensure that key accounts were reconciled or received on a periodic basis. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director. Action Plan: After review/monitoring of the previous Finance Officers duties and responsibilities, it was determined that the internal control processes of the finance department were not carried out properly to meet the requirements of 2 CFR Part 200 Section 200.302. Therefore, the agency terminated the Finance Officer. The agency immediately began the search for a new Finance Officer via Indeed and other employment hiring agencies. This process took much longer than expected which left an unexperienced Accounting Technician to operate the Finance Department along with limited finance knowledge of the Executive Director. After several advertisements for the vacant position the agency interviewed numerous applicants and was finally able to hire the current Finance Officer. The Finance Officer has worked continuously to insure that the internal control process of the department is implemented by making sure all accounts are reconciled and reviewed with supporting evidence of each review. With this process back in place, management and the Board of Directors will review and sign off on each account's financial statements. Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-002 - U. S. Department of Housing and Urban Development Voucher Cluster, Assistance Listing #14.871/14.879 Statement of Condition: For the year ended June 30, 2022, the Organization did not submit their audited financial statements to HUD by the required deadline. For the year ended June 30, 2023, the Origination did not submit their unaudited or audited financial statements to HUD by the required deadline. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: The submittal of the GAAP-based unaudited and audited report for FY ending June 30, 2022, was a management oversight due to the lack of a Finance Officer in place. The agency currently has a Finance Officer in place who will submit timely GAAP-based unaudited and audited financial information electronically to HUD via the Financial Assessment Sub-System (FASS-PH). Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-03 - U.S. Department of Health and Human Services Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: The origination did not submit the data collection form and required reporting package to the Federal Audit Clearinghouse (FAC) for the year ended June 30, 2023, by the required due date. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: Management will ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. To further ensure this finding is resolved, training for the Finance Officer/Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Section II - Findings relating to the financial statements which are required to be reported in accordance with generally accepted government auditing standards. 1. Finding 2022-001 Statement of Condition: Controls over the vendor payment process were not properly followed. Action Plan: Submitted previously with Financial Statements and Independent Auditor's Report FY Ended June 30, 2022. Current Status: Corrected The Management Department (Finance Officer and Executive Director), with the supervision of the Board of Directors Finance Officer, will continue to make every effort necessary to meet all HUD submission as required, in order to be in compliance with all HUD rules and regulations. Respectfully submitted, Trudy Murray Executive Director

Management will continue to attempt to contact the Project's HUD Project Coordinator in order to obtain the required approval for the withdrawal from the reserve for replacements account

The Organization’s management agent is not approved by HUD. Management fees paid to unauthorized management agents are considered unauthorized distributions of project funds. Views of Management and Corrective Action Plan: The Organization has chosen to change management agents to one that will be approved by HUD. Contact Person: Mauro Hernandez

Finding: The Organization did not file its annual 2023 Single Audit and Data Collection form timely. The Organization did not file its HUD REAC Annual Financial Statement timely. Views of Management and Corrective Action Plan: The updated onboarding procedures listed in Finding II Corrective Action are designed to prevent delays in submitting required audit reporting. Key improvements include: 1. Timely Reporting Compliance: o Enhanced onboarding processes eliminate the factors that previously led to late audit submissions. 2. Accurate Financials: o Financial statements submitted to auditors will be complete and accurate, minimizing the need for corrections. 3. Proactive Issue Resolution: o By addressing reporting requirements early in the onboarding process, the likelihood of errors and delays is significantly reduced. These updates ensure that future audit reporting deadlines are consistently met, avoiding the challenges faced in the current year.

2023-005 – ALN 14.871 – Housing Choice Voucher Program – Eligibility Current management acknowledges the finding and is following the auditor’s recommendations. Person Responsible for Correction of Exception: Mr. Justin Jones, Executive Director Projected Completion Date: December 31, 2024

2023-003 – ALN 14.850 – Public & Indian Housing – Activities Allowed or Unallowed Current management acknowledges the finding and is following the auditor’s recommendations. Person Responsible for Correction of Exception: Mr. Justin Jones, Executive Director Projected Completion Date: December 31, 2024