Corrective Action Plans

Management’s Response: The Authority has implemented the following in response to this finding: • All staff recently attended voucher training to understand the importance of and the process for file review and the documentation required, including rent reasonableness at move-in and as required. Staff will attend various HCV training throughout the year to ensure practical application. • Internal and third-party file reviews are and will continue to be conducted quarterly, to ensure file completeness, including rent reasonableness is completed properly and present in every move-in file and as required. If no rent reasonableness is in the file, SMHO will ensure one is completed, along with a clarification explaining any discrepancy. • SMHO will require managerial file review/approval for all new staff for the first six months of hire and will sign the check sheet for each file to indicate the review/approval has been completed.

Finding Reference Number 2023-002 1. Name of contact person responsible for corrective action Annmarie Covone, Executive Vice President/Chief Financial Officer 2. Corrective action planned Management changes caused delays in locating support for the single audit testing. Accordingly, the new management anticipates that these matters will not repeat themselves in the future periods and the audited financial statements will be submitted timely. 3. Anticipated Completion Date This will be completed in October 2024. 4. If the client does not agree with the findings or believes corrective action is not required, include an explanation and specific reasons We agree with Finding Reference No. 2023-002 Contact Information Annmarie Covone Executive Vice President/Chief Financial Officer 205 Lexington Avenue, 2nd Floor, New York, NY 10016 P (646) 633-4702 acovone@archcare.org

Tenant security deposit bank account. Contact person - Executive Director. Corrective action planned - The Project will maintain a tenant security deposit bank account in accordance with the regulatory agreement. Anticipated completion date - Within the next fiscal year.

Recommendation: The organization should obtain the requisite fidelity bond coverage and monitor the coverage to ensure it is in compliance with HUD requirements. Action Taken: Fidelity bond coverage was increased accordingly.

Corrective Action Plan Audit FYE 2023 Housing Assistance Program Discrepancies Finding: Discrepancies in tenant files, including missing forms (HUD-9886, Section 214 Status), Housing Assistance Payment (HAP) contracts, utility allowances, rent reasonableness, and asset verifications. Actions Taken: - Reviewed and corrected tenant files, ensuring all required documentation (HUD-9886, Section 214 forms) is present. - Rent reasonableness assessments have been updated for all relevant tenant files. - The utility allowance schedule was reviewed for 2023 in accordance with 24 CFR § 982.517. The review showed a change of less than 10% in utility costs. The utility allowance schedule was reviewed for 2024 and adjustments were made to maintain compliance. Future Actions: - File Review and Documentation: Conduct a full audit of tenant files to address missing forms and ensure compliance with all HUD regulations. Missing forms (e.g., HUD-9886) will be collected from tenants, and any discrepancies corrected. - Staff Training: Implement a comprehensive staff training program on file documentation and HUD compliance requirements. This will include sessions on rent calculations, utility allowances, and income verification. - Monthly Audits: Establish monthly internal audits to ensure ongoing compliance and rectify any future discrepancies promptly. Utility Allowances and Rent Reasonableness Finding: Utility allowances had not been reviewed in over three years, and discrepancies in rent reasonableness and utility allowances led to miscalculations in tenant payment obligations. Actions Taken: - The utility allowance schedule was reviewed for 2023 in accordance with 24 CFR § 982.517. The review showed a change of less than 10% in utility costs. The utility allowance schedule was reviewed for 2024 and adjustments were made to maintain compliance. - Rent reasonableness procedures were reviewed and updated to ensure that all tenants' rents are fair and consistent with current market rates. Future Actions: - Annual Utility Allowance Reviews: Continue to review utility allowances annually, ensuring compliance with HUD regulations and adjusting allowances when necessary. - Documentation: Maintain thorough records of rent reasonableness and utility allowance calculations to ensure compliance with HUD guidelines. SEMAP (Section Eight Management Assessment Program) Performance Finding: Previous audits revealed a low SEMAP score, indicating areas of non-compliance in key performance indicators. Actions Taken: - A corrective strategy for SEMAP indicators has been implemented, focusing on timely re- examinations, accurate rent calculations, and Housing Quality Standards (HQS) inspections. - Ongoing training has been provided to staff on SEMAP indicators to ensure improvement in future assessments. - 2022 SEMAP scores are "Standard." Future Actions: - SEMAP Re-assessments: Conduct quarterly internal SEMAP reviews to monitor compliance with key indicators. - Staff Training: Continue training staff on SEMAP performance metrics, particularly regarding timely re-certifications and inspections. - Quality Control: Implement a quality control process that includes random checks of tenant files and HQS inspection records. Finding: Inconsistent file documentation and procedural errors indicate a need for further staff training and improvements in administrative procedures. Actions Taken: - Staff training has been initiated to ensure all team members understand HUD regulations and file documentation requirements. - The Jacksonville Housing Authority website has been launched, including portals for tenants, landlords, and applicants, improving communication and service delivery. Future Actions: - Staff Education: Provide ongoing refresher courses to ensure staff remain compliant with HUD regulations and procedural updates. - Improved Administrative Procedures: Develop and implement a Standard Operating Procedures (SOP) manual that outlines key administrative tasks, including tenant file maintenance and compliance checks. - Resident Advisory Board: Actively recruit volunteers for the Resident Advisory Board to increase community engagement. Finding: Low utilization of vouchers due to limited available housing and participant eligibility issues. Actions Taken: - The Jacksonville Housing Authority has exceeded the goal of issuing 5 vouchers per month, issuing: - October: 5 vouchers - November: 6 vouchers - December: 9 vouchers - We added 5 new landlords in 2023 and opened our waiting list. Future Actions: - Landlord Recruitment: Continue to engage with landlords to increase housing availability and create a Landlord/Property Manager Advisory Board. - Voucher Utilization: Issue more vouchers as per HUD's recommendation and increase payment standards to 120% to make vouchers more competitive in the market when allowed. We have made significant strides in addressing the findings from the audit and will continue our efforts to ensure full compliance with HUD regulations. Our focus will remain on improving file documentation, tenant services, and program utilization while ensuring that Jacksonville Housing Authority operates efficiently and transparently. This Corrective Action Plan serves as our roadmap to address current audit findings, continue progress, and implement necessary changes to ensure sustainable program success.

FINDING #2023-002 RESERVE FOR REPLACEMENT Condition: The Reserve for Replacement account balance for Park Ridge Apartments, Phase 4 underfunded in the amount of $750. Recommendation: The management agent should ensure that all required deposits are made to the Reserve for Replacement account and that the balance in that account meets the minimum required balance in accordance with the regulatory agreement between the Entity and HUD. View of Responsible Officials and Planned Corrective Action: The management agent agrees with the finding and the auditor’s recommendations have been adopted.

FINDING #2023-001 SURPLUS CASH Condition: At December 31, 2022 the Entity had surplus cash totaling $9,162, due to Home Funds. Park Ridge Apartments, Phase 3 had surplus cash in the amount of $4,000. Park Ridge Apartments, Phase 4 had surplus cash in the amount of $2,077. Park Ridge Apartments, Phase 5 had surplus cash in the amount of $1,379. Parsk Ridge Apartments, Phase 6 had surplus cash in the amount of $1,706. The Entity did not make any payments on the loan as required by the loan agreement. Recommendation: The management agent should compute an estimate of surplus cash for the fiscal year upon completion of that period. In the event that surplus cash exists at the completion of the fiscal period, the management agent should make an installment payment on the HOME note. Views of Responsible Officials and Planned Corrective Action: The management agent agrees with the finding and the auditor’s recommendations have been adopted. Surplus cash will be calculated upon the completion of an annual fiscal period. If it is concluded that surplus cash exists at the end of the annual fiscal period, an installment payment will be made on the loan.

An age waiver has been submitted to HUD and is currently being reviewed. We are awaiting their decision. While we await a decision, Meadow Lane will review all existing application for eligibility and advise any existing applicants who are not of age that they are no longer eligible via mail. Anticipated Completion Date: Pending HUD approval of age waiver

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund program to ensure that established internal control policies related to wage rate requirements are being followed. Donald Paredez, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

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

Authority Response and Planned Corrective Action: The Authority agrees with the finding and will increase oversight related to the maintenance of tenant files to better monitor adequacy with compliance requirements. Donald Paredez, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

Authority Response and Planned Corrective Action: Management agrees with the Auditors' finding and will implement the required updates and safeguards to ensure that the Authority complies with Section 19 of the ACC to remedy the aforementioned deficiencies. Donald Paredez, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

Finding ref number: 2023-002 Finding caption: The Housing Authority had inadequate internal controls for ensuring compliance with the Housing Quality Standards enforcement requirements of its Housing Voucher Cluster program. Name, address, and telephone of Housing Authority contact person: Joanna Tepley, Finance Director 1555 S. Methow Street Wenatchee, WA 98801 (509) 663-7421 Corrective action the auditee plans to take in response to the finding: The HCV department will be creating an Excel spreadsheet for the inspector to complete and utilize to better manage compliance dates. It will include the failed inspection date, compliance due date, tenant and landlord names, passed date, abatement start date, and memos. In addition, the supervisor will be monitoring this spreadsheet and auditing inspection compliance more frequently. Anticipated date to complete the corrective action: Immediately

Finding ref number: 2023-001 Finding caption: The Housing Authority had inadequate internal controls for ensuring compliance with the Housing Quality Standards inspection requirements of its Project-Based Rental Assistance Program. Name, address, and telephone of Housing Authority contact person: Joanna Tepley, Finance Director 1555 S. Methow Street Wenatchee, WA 98801 (509) 663-7421 Corrective action the auditee plans to take in response to the finding: In 2023, CCWHA resumed its annual inspections of leased units, assigning a specific inspection month to each property. We acknowledge that, during this transition, certain units were not inspected within the expected annual timeline, as noted by the State Auditor's Office. This was primarily due to tenant refusals and necessary rescheduling. To address this, CCWHA has implemented the following corrective measures: 1.Revised Inspection Schedule: We have adopted a new system to ensure that inspections are completed in the month preceding the assigned inspection month from the prior year. 2.Ongoing Staff Training: Housing Authority staff responsible for inspections will continue to receive regular training to emphasize the importance of timely, comprehensive assessments. This training reinforces the need for compliance with federal Housing Quality Standards (HQS) and the importance of maintaining accurate records. We fully understand the importance of adhering to HQS requirements to ensure a safe and healthy living environment for our tenants. We are committed to continuously improving our inspection processes and appreciate the opportunity to address these concerns. Anticipated date to complete the corrective action: Immediately

The Clifton Public Housing Agency has contracted with PHA-Web as the software system managing the Housing Choice Voucher Program. This system allows the PHA to put "on hold" any landlord/tenant payments that are not to be processed due to outstanding requirements such as lease documents, tenant income verification, inspection failures or any other missing information that the PHA may need to process the monthly payment. Therefore, "on Hold" checks are not processed until the tenant/landloard complies with all the requirements. Also, any checks that are released are forwarded to the City's positive pay file for processing.

Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Assistance Listing Number: 14.871 Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussion with management, there was a failed inspection that did not pass reinspection within 30 days without penalty. Context: There were approximately six hundred ninety four (694) failed inspections during the audit period. Of a sample size of twenty-five (25) failed inspections, one (1) unit did not pass reinspection within 30 days. HAP was not abated nor was the tenant transferred. Known Questioned Costs: $4,107 Our sample size is statistically valid. Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor and will make the necessary changes to its inspection process to ensure enforcement of Housing Quality Standards (or any subsequent replacement). Irene Melton, Director of Finance, is responsible for implementing this corrective action by December 31, 2024

2023-002 – Reserve Funds for Replacement Condition: Current year HUD required reserve deposits were not made in accordance with the RCC. Corrective Action Planned: Management is to make the required deposits to get the account funded at a level in compliance with the RCC. Person responsible for corrective action: Akinola Popoola, Executive Director Telephone: (256) 232-5300 x 8 Trudi Harris, Property Manager Anticipated Completion Date: Management expects the accounts to be back in compliance by the end of the 2024 fiscal year.

2023-001 - Determination of Contract Rents, Maintenance of Tenant Files Condition: Eligibility recertification procedures required as a part of the annual recertification have not been performed or not performed sufficiently for tenants housed as of December 31, 2023. Corrective Action Planned: Staff has worked diligently to get all tenants housed at the Housing Authority recertified with sufficient documentation. Management believes all issues with tenant files to be corrected as of the report date. Staff are to receive continued education training on the operations of the RAD program and the compliance requirements. Person responsible for corrective action: Akinola Popoola, Executive Director Telephone: (256) 232-5300 x 8 Trudi Harris, Property Manager Anticipated Completion Date: Management believes files have been corrected as of the 2023 year-end audit report date.

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2023-001: Major Programs: Major Program: Section 202 Supportive Housing for the Elderly, Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all tenants’ 90-day EIV reports are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. ACTION TAKEN The Project will be monitoring use of the EIV system for move ins and recertifications.

Section 8 Housing Choice Vouchers Program -Finding 2023-002 Finding – Of a sample size of 25 units that previously failed inspection, one unit did not pass reinspection within 30 days. Housing assistance payments were not abated nor was the tenant evicted resulting in questioned cost of $3,412. This is considered a significant deficiency in internal controls over compliance for special tests and provisions type of compliance related to Housing Quality Standards (HQS) inspections. The Agency has not properly performed HQS inspections in compliance with program requirements. Recommendation – The Agency design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Corrective Action – The Agency will increase oversight in the Section 8 Housing Choice voucher Program with respect to following up on units that previously failed inspections in accordance with HQS to ensure that established internal control policies are being followed on a timely basis. Implementation Date – August 1, 2024

Finding – Of a sample size of 21 tenant files, income was miscalculated on one file resulting in questioned costs of $304. This is considered a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Agency has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Recommendation – The Agency design and implement internal control procedures that will reasonably assure compliance with Uniform Guidance and the compliance supplement. Corrective Action - The Agency will increase oversight in the Section 8 Housing Choice voucher Program with respect to calculated income to ensure that established internal control policies are being followed on a timely basis. Implementation Date -August 1, 2024

Finding Reference Number: 2023-001 Description of Finding: Virginia Supportive Housing (the Agency), was undergoing staff and programmatic reorganization during the time required to submit the audit. This resulted in the Agency being unable to timely meet the compliance audit testing in a timely manner and submit the completed audit package to the Federal Audit Clearinghouse (FAC) by the statutory deadline. Statement of Concurrence or Nonconcurrence: The Agency agrees with the audit finding. Corrective Action: The corrective action was for the Agency to submit the completed audit package to the Federal Audit Clearinghouse (FAC). Status of Corrective Action: Completed. Name of Contact Person: W. Carter Dages, Jr., Director of Finance; (804) 314-7870; cdages@SupportWorksHousing.org Projected Completion Date: Report was filed on October 3, 2024.

SIGNIFICANT DEFICIENCY 2023-002 Deposit of surplus cash to residual receipts more than 90 days Recommendation: Management should continue to evaluate their internal policies and procedures to ensure surplus cash is deposited within 90 days of year-end. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management adopt policies of earlier deposit or switch to electronic methods. Name of the contact person responsible for corrective action: Nicole Chwala, CEO Planned completion date for corrective action plan: December 2024

FINDING 2023-003: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will immediately transfer the delinquent surplus cash to the residual receipts reserve account and implement robust internal controls to ensure all future deposits are made promptly and in compliance with the Regulatory Agreement. Action Taken: Management has transferred the overdue amount to the residual receipts reserve account and implemented enhanced internal controls to prevent future non-compliance.

FINDING 2023-002: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement a comprehensive internal control system to ensure all tenant files include required documentation, and will conduct a thorough review of all current tenant files to verify compliance and completeness. Action Taken: Ownership agrees with the auditor’s finding and recommendation and has hired a new management agent to oversee the implementation of a comprehensive internal control system, ensuring all tenant files include required documentation