Corrective Action Plans

Finding 387660 (2023-002)

Significant Deficiency 2023

Village of Spring Valley Housing Authority

NY

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

Finding 2023-002 Eligibility Auditee's Response and Planned Corrective Action The Authority has had staff and consultant turnover during the 2022 audit period. Additionally, the eviction moratorium and lasting effects from the COVID-19 pandemic have resulted in delayed or nonexistent response from ...

Finding 2023-002 Eligibility Auditee's Response and Planned Corrective Action The Authority has had staff and consultant turnover during the 2022 audit period. Additionally, the eviction moratorium and lasting effects from the COVID-19 pandemic have resulted in delayed or nonexistent response from tenants regarding obtaining the necessary documentation for eligibility requirements. The Authority has evidentiary documentation supporting their attempts to obtain the required documents from the tenants, including certified letters. The courts suspended evictions during the eviction moratorium that resulted from the COVID-19 pandemic, which includes evictions for nonpayment and noncompliance. The Authority has been working with legal counsel on these matters and continues to pursue this vigorously. The Authority's staff and consultants have been diligently working to implement improvements to the administrative systems related to recertifications. Additionally, the Authority has put in place a checklist for occupancy documents that are reviewed during recertification and when processing new tenants that must have annotations, check mark, that confirm that all required papers are in compliance and signed where appropriate. This check list will have at least one redundant review by the Authority's directors or designee. Planned Implementation Date of Corrective Action: March 2024 Person Responsible for Corrective Action: Keith Burrell, Executive Director

View Audit 299738

Finding 387195 (2023-001)

Significant Deficiency 2023

Idaho Housing and Finance Association

ID

HUD Housing Programs Reporting Significant Deficiency

2023-001 U.S. Department of Housing and Urban Development CFDA # 14.182, 14.195, 2023 Award Year, Award Number: Not Provided Section 8 Project – Based Cluster Compliance Requirement: Reporting Type of Finding: Compliance Finding Summary: As part of the testing for wait list applicants, the auditors ...

2023-001 U.S. Department of Housing and Urban Development CFDA # 14.182, 14.195, 2023 Award Year, Award Number: Not Provided Section 8 Project – Based Cluster Compliance Requirement: Reporting Type of Finding: Compliance Finding Summary: As part of the testing for wait list applicants, the auditors selected a sample of 60 applications. Of the 60, one instance of the required documentation for the applicant was not available by the property manager. Responsible Individuals: Cory Phelps, VP Project Finance Corrective Action Plan: IHFA Compliance staff will send a memo to all owner/agents in the Project Based Section 8 program that wait list applications must be retained. IHFA will further explain that failure to have proper documentation in the maintained will result in a deficiency on the Management and Occupancy Review. Anticipated Completion Date: December 30, 2023

View Audit 299469

Finding 387094 (2023-005)

Material Weakness 2023

Isd # 682 Roseau

MN

School Nutrition Programs Eligibility HUD Housing Programs

CContact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – December 29, 2023

View Audit 299411

Finding 387086 (2023-003)

Material Weakness 2023

Isd # 682 Roseau

MN

Reporting Cash Management HUD Housing Programs

Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District has implemented new meal count procedures effective May 2023. Completion Date – May 1, 2023

View Audit 299411

Finding 387083 (2023-001)

Material Weakness 2023

Housing Authority of the City of Everett

WA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We starte...

The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We started the process on 6/29/2022 to replace our Housing Inspector that left EHA 5/04/2022. The person that filled this Housing Inspector position started at EHA on 1/05/2023, completed training and began taking on an inspection workload in February 2023. • In March 2023, twenty-five (25) staff in EHA’s Housing Management Department attended an HQS inspections training. EHA Housing Management staff began completing initial and annual HQS inspections at EHA PBV properties on 7/01/2023. • EHA budgeted for a second Housing Inspector position in EHA’s FYE2023 budget. We started the process to hire the second Housing Inspector on 7/13/2023. The person that filled this second Housing Inspector position started at EHA on 9/19/2023, completed training and began taking on an inspection workload at the end of October 2023. • EHA budgeted for an Inspections Coordinator position in EHA’s FYE2023 budget. We started the process to hire the Inspections Coordinator on 8/14/2023. The person that filled the Inspections Coordinator position started on 11/06/2023. • On 10/30/2023, EHA’s Executive Director decided to add a third Housing Inspector to the EHA inspections team to assist with the backlog of biennial inspections. We started the process to hire the third Housing Inspector on 10/31/2023. The person that filled this third Housing Inspector position started in the position on 1/16/2024, completed training and began taking on an inspection workload in February 2024. • On 2/23/2024, an HCV Manager was appointed to supervise the inspections team (three Housing Inspectors and one Inspections Coordinator), to provide increased oversight over EHA’s inspections workload. The HCV Manager is responsible for monitoring progress towards addressing the biennial inspections backlog, delegating inspections workload to the inspections team, and providing guidance and support to the inspections team. The HCV Manager meets with the inspections team on a weekly basis as well as conducts individual check-ins with all inspections team members. Our increased inspections capacity has allowed us to make significant progress on addressing the pandemic-caused backlog of biennial inspections. Based on our expanded internal staffing resources, we expect to complete all late biennial inspections by 12/31/2024.

View Audit 299403

Finding 386971 (2023-001)

Significant Deficiency 2023

City of Westland, Michigan

MI

Subrecipient Monitoring HUD Housing Programs Reporting

Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for...

Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for the program year ended June 30, 2023, we have taken immediate and strategic steps to address and prevent future occurrences. These include streamlining our data collection and reporting processes for greater efficiency, enhancing staff training on reporting responsibilities, and implementing robust internal monitoring to ensure adherence to reporting deadlines. These measures, designed to address both the immediate issue and bolster our overall reporting framework, demonstrate our commitment to transparency, accountability, and continuous improvement in our program operations. Contact person responsible for corrective action: Joanne Campbell Anticipated Completion Date: October 10, 2023

View Audit 299310

Finding 386943 (2023-001)

Material Weakness 2023

Eaton Place 202, Inc.

MA

Questioned Costs HUD Housing Programs Cash Management

Recommendation: Management should establish internal controls and procedures to ensure that required residual receipt remittances are made when required. Action Taken: The Corporation agrees with the finding and the auditor’s recommendations have been adopted.

View Audit 299288 Questioned Costs: $1

Finding 386909 (2023-009)

Significant Deficiency 2023

City of Wilmington

DE

HUD Housing Programs Reporting Subrecipient Monitoring

The City of Wilmington, Real Estate and Housing Department as the HOPWA grantee remains responsible for collecting, reviewing (for accuracy and completeness), and transmitting to HUD the Consolidated APR/CAPER workbooks. Submission of the complete set of Grantee and Provider Workbooks together cons...

The City of Wilmington, Real Estate and Housing Department as the HOPWA grantee remains responsible for collecting, reviewing (for accuracy and completeness), and transmitting to HUD the Consolidated APR/CAPER workbooks. Submission of the complete set of Grantee and Provider Workbooks together constitutes the Grantee’s annual performance report to HUD. Included in this submission is the Grantee Performance Report and all of the Provider Performance Reports together. Staff in the Real Estate and Housing Department review them to the best of our ability for accuracy and completeness. The finding notes that the documentary evidence of this review was not retained other than the subsequent data validation which occurs with HUD’s Technical Assistance (TA) HOPWA Data Validation team and through Cloudburst email. In the future the Real Estate and Housing Department will note to file the email confirmation of the received report is as complete and error free as possible.

View Audit 299217

Finding 386896 (2023-003)

Material Weakness 2023

Pittsfield Housing Authority

RI

Eligibility HUD Housing Programs Material Weakness

At the beginning of FY2024, under the terms of PHA's Recovery Agreement with HUD, PHA's consultants conducted PIH internal QCs and staffing assessments. As a result of those findings, PHA has reorganized and increased the PHA staff, with a new Public Housing Manager. Staff are being fully trained re...

At the beginning of FY2024, under the terms of PHA's Recovery Agreement with HUD, PHA's consultants conducted PIH internal QCs and staffing assessments. As a result of those findings, PHA has reorganized and increased the PHA staff, with a new Public Housing Manager. Staff are being fully trained regarding eligibility determinations and rent calculations, checklists are being developed and regular internal QCs performed, with an objective of full compliance by the end of calendar year 2024.

View Audit 299209

Finding 386895 (2023-002)

Material Weakness 2023

Pittsfield Housing Authority

RI

Questioned Costs HUD Housing Programs Special Tests & Provisions

Effective 3/3/23, PHA switched from manual calculations of rent reasonableness to a web-based Rental Reasonableness software designed to meet HUD standards. PHA began conducting reasonableness determinations utilizing the Rent Reasonableness software, beginning March 2023. Rent reasonableness determ...

Effective 3/3/23, PHA switched from manual calculations of rent reasonableness to a web-based Rental Reasonableness software designed to meet HUD standards. PHA began conducting reasonableness determinations utilizing the Rent Reasonableness software, beginning March 2023. Rent reasonableness determinations are now being made for all participants prior to initial HAP contract execution and in conjunction with any requested rent increases. Continuing compliance will be internally reviewed during a July 2024 SEMAP QC review.

View Audit 299209 Questioned Costs: $1

Finding 386894 (2023-001)

Material Weakness 2023

Pittsfield Housing Authority

RI

HUD Housing Programs Eligibility Material Weakness

The finding of missing income verifications for eligibility and recertification rent calculations is being addressed as part of a holistic review under the Recovery Agreement of Section 8 program compliance. Following an internal SEMAP QC review in July 2023, staff have been retrained and certificat...

The finding of missing income verifications for eligibility and recertification rent calculations is being addressed as part of a holistic review under the Recovery Agreement of Section 8 program compliance. Following an internal SEMAP QC review in July 2023, staff have been retrained and certification/recertification checklists have been created. Initial and annual recertifications are currently being conducted in accordance with the applicable HUD regulations and guidance and will be internally reviewed during a July 2024 SEMAP QC review .

View Audit 299209

Finding 386881 (2023-002)

Material Weakness 2023

Mental Health Center of Champaign County Housing Corporation

IL

Questioned Costs HUD Housing Programs Special Tests & Provisions

Finding: Management did not remit payment to HUD for the amount in excess of $250 per unit for their fifteen units. Uniform Guidance states that controls should be implemented to ensure the Project is in compliance with special tests and provisions. As stated in the Coronavirus Disease 2019 memorand...

Finding: Management did not remit payment to HUD for the amount in excess of $250 per unit for their fifteen units. Uniform Guidance states that controls should be implemented to ensure the Project is in compliance with special tests and provisions. As stated in the Coronavirus Disease 2019 memorandum released by HUD, remittance of residual receipts were suspended through December 31, 2021. Residual receipts were due to HUD by the next Project Rental Assistance Contracts renewal which was October 1, 2022. Management was unaware the funds needed to be remitted back to HUD in the time frame noted. We recommend management review their processes and controls surrounding residual receipts to ensure amounts due to HUD are properly remitted. Corrective Action: Management has updated their internal controls to ensure a proper review of residual receipts is conducted quarterly. This review will be completed by an assigned staff member, with a secondary review completed by management. Residual receipts in excess of allowed amounts will be properly accounted for as a liability on the books and records of the Project. Residual receipts in excess of the allowed amounts will be remitted when due.

View Audit 299197 Questioned Costs: $1

Finding 386844 (2023-001)

Significant Deficiency 2023

Woodside Village, Inc. 042-Hd112

OH

HUD Housing Programs Cash Management Reporting

Response Management has completed the required deposit to the prohibited amenities escrow of $3,971 in September 2023.

View Audit 299175

Finding 386842 (2023-001)

Significant Deficiency 2023

Accessible Country Trail, Inc. 042-Hd033

OH

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Response: Management has completed the required deposit to the reserve for replacement of $3,450 in September 2023.

View Audit 299164

Finding 386830 (2023-001)

None 2023

Mhccc Housing CORP Iic

IL

HUD Housing Programs

Finding: Management did not complete the search for a tenant prior to move-in. According to Chapter 9 ofthe HUD Multifamily Occupancy Handbook, HUD requires an Existing Tenant Search through the Enterprise Income Verification System (EIV) be completed for all new tenants prior to move in. Due to a c...

Finding: Management did not complete the search for a tenant prior to move-in. According to Chapter 9 ofthe HUD Multifamily Occupancy Handbook, HUD requires an Existing Tenant Search through the Enterprise Income Verification System (EIV) be completed for all new tenants prior to move in. Due to a clerical error, an incorrect social security number was entered while running the EIV. We recommend management verify the information entered into the EIV. Corrective Action: Management acknowledges the error and will continue to verify the social security numbers being entered.

View Audit 299143

Finding 386678 (2023-003)

Significant Deficiency 2023

Community Health and Counseling Services

ME

HUD Housing Programs

Program Affected: 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services, agreement period February 15, 2021 through August 14, 2023. Condition and Context: Of the one report haphazardly selected for testing, it was unable to be tested as it was not provided. Correct...

Program Affected: 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services, agreement period February 15, 2021 through August 14, 2023. Condition and Context: Of the one report haphazardly selected for testing, it was unable to be tested as it was not provided. Corrective Action Plan: Reporting for the Federal Award is maintained within the SAMHSA website. Reporting information should have been made available as requested. The new Finance Director will serve as the point of contact for future audits and will make reports available as requested. The new Finance Director will establish procedures to capture report submissions that are managed via a portal. The procedures will include parameters that can be used to verify timely submission. Responsible Official: Dale Hamilton, Executive Director & Kathie Norwood, Finance Director Implementation Date: April 1, 2024

View Audit 298999

Finding 386677 (2023-004)

Significant Deficiency 2023

Community Health and Counseling Services

ME

HUD Housing Programs Reporting

Program Affected: 93.498 Provider Relief Fund and American Rescue Plan Rural Distribution, agreement period January 1, 2020 through June 30, 2023. Condition and Context:Of the one report haphazardly selected for testing, it was unable to be tested as it was not provided. Corrective Action Pla...

Program Affected: 93.498 Provider Relief Fund and American Rescue Plan Rural Distribution, agreement period January 1, 2020 through June 30, 2023. Condition and Context:Of the one report haphazardly selected for testing, it was unable to be tested as it was not provided. Corrective Action Plan:The new Finance Director will establish procedures to capture report submissions that are managed via a portal. The procedures will include parameters that can be used to verify timely submission. Responsible Official: Dale Hamilton, Executive Director & Kathie Norwood, Finance Director Implementation Date: April 1, 2024

View Audit 298999

Finding 386543 (2023-001)

None 2023

Clinch River Apartments, Inc.

TN

HUD Housing Programs

Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.

View Audit 298845

Finding 386521 (2023-003)

Significant Deficiency 2023

St. Giles Manor, Inc.

AL

HUD Housing Programs Matching / Level of Effort / Earmarking

SPM terminated the employment of the person responsible for this oversight and has implemented an internal control for its Financial Planning & Analysis department to monitor the management team’s compliance with these deadlines.

View Audit 298828

Finding 386520 (2023-002)

Significant Deficiency 2023

St. Giles Manor, Inc.

AL

HUD Housing Programs

SPM has hired a new Director of Treasury with responsibility for this activity. Additionally, SPM is investigating moving these funds to the lender held reserve account to avoid this issue in the future and eliminate the impact to the financial statement.

View Audit 298828

Finding 386389 (2023-002)

Significant Deficiency 2023

The Housing Authority of the City of Hot Springs

AR

HUD Housing Programs Special Tests & Provisions

Condition and Criteria: The Authority’s purpose for existence is providing decent safe and affordable housing to low-income persons. As such, HUD requires the Authority to comply with special tests and provisions relating to its Housing Choice Voucher program. The Authority must inspect the unit le...

Condition and Criteria: The Authority’s purpose for existence is providing decent safe and affordable housing to low-income persons. As such, HUD requires the Authority to comply with special tests and provisions relating to its Housing Choice Voucher program. The Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The Authority must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Population and Items Tested: Per Table 10-1 of the Housing Choice Voucher Guidebook, the Authority was required to perform 19 quality control housing reinspections. Ten quality control re-inspections could be documented. Auditor’s Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Grantee Response: We will comply with the auditor’s recommendation. Anticipated Completion Date: June 30, 2024

View Audit 298714

Finding 386388 (2023-001)

Significant Deficiency 2023

The Housing Authority of the City of Hot Springs

AR

HUD Housing Programs Eligibility

Condition and Criteria: The Authority’s purpose for existence is providing decent, safe and affordable housing to low- income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of...

Condition and Criteria: The Authority’s purpose for existence is providing decent, safe and affordable housing to low- income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of rent assistance to be paid on the family’s behalf. HUD regulations prescribe the content of these family files. These requirements consist of the following: a. As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. c. Determine income eligibility and calculate the tenant’s rent payment in accordance with HUD regulations. d. Select tenants from the public housing waiting list in accordance with the PHA’s tenant selection policies. e. Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary. Population and Items Tested: Testing of sixty family files revealed the following deficiencies: 1. Two lacked documentation of rent reasonableness. 2. One file contained a HAP contract not signed by the owners. 3. Two files calculated an incorrect housing assistance payment. 4. One file lacked signed Form 9886 authorization for the period under review. Auditor’s Recommendation: A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Grantee Response: We will comply with the auditor’s recommendation.

View Audit 298714

Finding 386244 (2023-004)

Material Weakness 2023

Lansing Housing Commission

MI

Subrecipient Monitoring HUD Housing Programs Material Weakness § 200.334

Condition: The Commission did have required written policies in place during the year under audit or retained copies of grant agreements once they became the direct recipient of the grants. Planned Corrective Action: Management agrees with the finding as reported. To correct this finding, the Commis...

Condition: The Commission did have required written policies in place during the year under audit or retained copies of grant agreements once they became the direct recipient of the grants. Planned Corrective Action: Management agrees with the finding as reported. To correct this finding, the Commission reviewed its policies and procedures and revised as needed to comply with federal regulations. The policies were presented and approved at the August 2023 board meeting. The Commission has sent revised policies to HUD for their review and approval. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024

View Audit 298666

Finding 386243 (2023-003)

Material Weakness 2023

Lansing Housing Commission

MI

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.306

Condition: The Commission was unable to provide adequate source documentation to support that the match requirement was met. Planned Corrective Action: Management agrees that match requirements for Continuum of Care awards have not been maintained as required by the Uniform Guidance. In July 2023, m...

Condition: The Commission was unable to provide adequate source documentation to support that the match requirement was met. Planned Corrective Action: Management agrees that match requirements for Continuum of Care awards have not been maintained as required by the Uniform Guidance. In July 2023, management was notified by HUD after completion of an on-site monitoring visit that the Commission's claimed matching expenses that were not adequately supported by source documentation. In response, management has placed in service additional controls to ensure the compliance requirements are being monitored and in place for the new program. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024

View Audit 298666 Questioned Costs: $1

Finding 386242 (2023-001)

Significant Deficiency 2023

Lansing Housing Commission

MI

HUD Housing Programs Eligibility Significant Deficiency

Condition: For a sample of tenants selected in conjunction with eligibility testing, the Commission did not correctly calculate family income composition, and did not retain required documentation supporting eligibility determinations. Planned Corrective Action: The Commission is implementing a plan...

Condition: For a sample of tenants selected in conjunction with eligibility testing, the Commission did not correctly calculate family income composition, and did not retain required documentation supporting eligibility determinations. Planned Corrective Action: The Commission is implementing a plan to audit internally 100 percent of all tenant files in our Low Income Public Housing (LIPH) program. This plan involves both the use of experienced employees and an outside consultant. The plan includes updating and automating files, identifying recurring compliance issues, and expanding formal training and specific training from the consultant. In addition, an additional level of review will be put in place to assist in catching any inconsistencies. The Commission has added additional employees to the LIPH program, which include an operations manager and a staff person. These additional resources will be incorporated into our overall plan to increase our compliance controls. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024

View Audit 298666

Corrective Action Plans

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