Corrective Action Plans

Finding 499288 (2023-001)

Significant Deficiency 2023

The Housing Authority of the City of Key West, Florida

FL

Questioned Costs HUD Housing Programs Subrecipient Monitoring

2023-001 - HQS Enforcements and Annual HQS Inspections Housing Voucher Cluster - Assistance Listing No. 14.871 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in ...

2023-001 - HQS Enforcements and Annual HQS Inspections Housing Voucher Cluster - Assistance Listing No. 14.871 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In response to the HOS enforcement and annual inspections finding for the Housing Authority of the City of Key West, FL 12-31-2023 audit, management has completed the following items in order to address the issue: • Hired a new HCV Program Manager, • Procured a new outside HCV inspection contractor, • Provided current staff training on HCV program HOS requirements, • Adopted the recommendation from our independent auditors to have the Assistant to the Director of Housing sample 10% of the HCV recertification files monthly to ensure compliance with federal regulations and housing quality standards - files that are found to be out of compliance will be reported to the Director of Housing & Executive Director. In addition, the following items will be done: • Consider changing the administrative plan to prohibit time extensions beyond 30 days, thereby requiring abatement of HAP effective the 31st day in all cases, • Update the job description of the Assistant to the Director of Housing & change the title of the position to Assistant to the Director of Housing/Compliance Specialist. Name(s) of the contact person(s) responsible for corrective action: Randy Sterling, Executive Director Planned completion date for corrective action plan: October 31, 2024.

View Audit 322102 Questioned Costs: $1

Finding 499275 (2023-001)

Significant Deficiency 2023

Lutheran Senior Services

MO

Internal Control / Segregation of Duties HUD Housing Programs Reporting

Management agrees that they had lost revenue that wasn’t utilized that was sufficient to cover the amount of expenses that were reported in error. There is no disagreement with the audit finding and will implement proper training, education, and review processes to ensure reporting is completed accu...

Management agrees that they had lost revenue that wasn’t utilized that was sufficient to cover the amount of expenses that were reported in error. There is no disagreement with the audit finding and will implement proper training, education, and review processes to ensure reporting is completed accurately going forward.

View Audit 322085

Finding 499246 (2023-002)

Significant Deficiency 2023

Parkview Services

WA

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

Management agrees with this finding. Management will review all new funding contracts and agreements and keep track of all reporting requirements and deadlines in order to stay in compliance. Management will document all requirements and deadlines by December 31st, 2024. The Finance Director will no...

Management agrees with this finding. Management will review all new funding contracts and agreements and keep track of all reporting requirements and deadlines in order to stay in compliance. Management will document all requirements and deadlines by December 31st, 2024. The Finance Director will notify reporting staff that a report is due and confirm that it has been submitted prior to the due date.

View Audit 322053

Finding 499240 (2023-002)

Material Weakness 2023

Housing Authority of the City of Washington

GA

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

2023-002 Condition: Deficiencies Noted in Examination of New Construction Section 8 Tenant Files Steps to resolve: We will review the internal control procedures over tenant file re-certifications and documents and implement procedures which will eliminate such errors. Management has implement...

2023-002 Condition: Deficiencies Noted in Examination of New Construction Section 8 Tenant Files Steps to resolve: We will review the internal control procedures over tenant file re-certifications and documents and implement procedures which will eliminate such errors. Management has implemented procedures in order to clear this finding in FY 2024. Timeframe: By FYE December 31, 2024 Individual responsible for correction: Ms. Zena Zahran, Executive Director

View Audit 322035

Finding 499237 (2023-002)

Significant Deficiency 2023

Home Forward

OR

Eligibility HUD Housing Programs

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and income is supported. Explanation of disagreement with audit finding: There is no disagreement w...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and income is supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • We will be conducting a random audit of all LRPH files. • Training on best practice for PH and PBV reviews. This training will emphasize the importance of proper income documentation. • Sending out monthly report for reviews that are coming due. Name(s) of the contact person(s) responsible for corrective action: Suzanne Couttouw, Compliance Manager (audit and training) and Elise Anderson (monthly reporting.) Planned completion date for corrective action plan: March 30, 2025

View Audit 322033

Finding 499187 (2023-002)

None 2023

New York City Housing Authority

NY

Questioned Costs HUD Housing Programs Eligibility

Finding Number 2023-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms th...

Finding Number 2023-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). Condition/Context The Authority received funding from the HUD. The Public and Indian Housing program is to provide and operate cost effective, decent, safe, and affordable dwellings for lower income families through an authorized local PHA. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: Eight eligibility forms were not provided (five missing application forms, one missing certifications information provided to the PHA forms and two missing Release form). These forms are required documentation to be maintained in the case files to support eligibility for Public and Indian Housing Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan In January 2011, NYCHA implemented the Siebel Customer Relationship Management (CRM) system, which included digital file storage and an online application process, which replaced our previous paper application process. Any applications in process from that date onward were subject to document scanning and documentation was stored digitally. Any applications processed prior to this date were kept in a paper format and stored at the development, where the applicant was certified or where the tenant resides. If a tenant family transferred to another development, the physical tenant folder and documents were sent to their new location. In June 2020, NYCHA sought to digitize all tenant folders; however, the cost of the project was determined to be prohibitive so the goal of digitizing the tenant folders was not realized. Any documents damaged or lost prior to 2011 cannot be recovered, including those impacted by Hurricane Sandy. Action Date September 6,2024 Final Implementation September 6,2024 Name And Phone Number Of Person Responsible for Implementation Sylvia Aude Senior Vice president Office of the Senior Vice President for Public Housing Operations Tenancy Administration +1-212-306-3921

View Audit 321980 Questioned Costs: $1

Finding 499186 (2023-001)

Material Weakness 2023

New York City Housing Authority

NY

HUD Housing Programs Material Weakness Special Tests & Provisions

Finding Number 2023-001 SPECIAL TESTS AND PROVISIONS- ENVIRONMENTAL CONTAMINANTS TESTING AND REMEDIATION – MATERIAL WEAKNESS Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Special Tests and Provisio...

Finding Number 2023-001 SPECIAL TESTS AND PROVISIONS- ENVIRONMENTAL CONTAMINANTS TESTING AND REMEDIATION – MATERIAL WEAKNESS Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Special Tests and Provisions - Environmental Contaminants Testing and Remediation As stated in the May 2023 Compliance Supplement, Public Housing must be decent, safe, sanitary, and in good repair. Public Housing Authority’s (PHA) must maintain such housing in a manner that meets the physical condition standards set forth in 24 CFR section 5.703 in order to be considered decent, safe, sanitary, and in good repair. Those standards address the major areas of the public housing: the site; the building exterior; the building systems; the dwelling units; the common areas; and health and safety considerations. Health and safety considerations require that all areas and components of the housing must be free of health and safety hazards. These areas include, but are not limited to, air quality, electrical hazards, elevators, emergency/fire exits, flammable materials, garbage and debris, handrail hazards, infestation, and lead-based paint. The housing must have no evidence of infestation by rats, mice, or other vermin, or of garbage and debris. The housing must have no evidence of electrical hazards, natural hazards, or fire hazards. The dwelling units and common areas must have proper ventilation and be free of mold, odor (e.g., propane, natural gas, methane gas), or other indoor air hazards such as radon. The housing must comply with all requirements related to the evaluation and reduction of lead-based paint hazards and have available proper certifications of such (see 24 CFR Part 35). For the period under audit, the PHA is required to test for and remediate environmental contaminates including but not limited to lead-based paint, radon gas, and mold to ensure that public housing met the physical condition standards for health and safety considerations set forth in 24 CFR section 5.703. Condition/Context The New York City Housing Authority (the “Authority”) performs environmental contaminates testing and remediation including but not limited to Lead-based paint, Mold, Pest Control, Elevators, Heating and Annual Apartment Inspections. To track compliance with the Agreement executed on January 31, 2019 by and among the Authority, the U.S. Department of Housing and Urban Development (“HUD”) and the U.S. Attorney’s Office for the Southern District of New York (SDNY) and The City Of New York (the “HUD Agreement”), the Authority maintains monthly inspection reports for the various inspections performed and provides that information to HUD, the SDNY and the Federal Monitor appointed under the HUD Agreement. Deloitte obtained the bi-annual lead-based paint compliance reports from the Authority and for the Period from June 16, 2023 through December 15, 2023 and December 16, 2022 through July 15, 2023, we read extermination, heat outage, mold inspections, annual apartment inspections, and elevator outage reports for the months of February 2023; April 2023; July 2023; September 2023 and November. 2023. During our audit, we noted that the Authority did not complete all corrective actions in the 2023 audit period and is in the process of addressing these issues. Recommendation We recommend that the Authority continue to ensure that all environmental contaminates are properly remediated during the audit period through the HUD Agreement. Corrective Action Plan In January 2019, the Authority entered into the HUD Agreement to address building conditions, including conditions related to lead-based paint, mold, pests, elevators, and heating. Among other things, the HUD Agreement appointed a federal Monitor and established three new Departments – Compliance, Environmental Health & Safety, and Quality Assurance. It also required the promulgation of action plans around these health and safety issues and other items. These action plans are publicly available https://www1.nyc.gov/site/nycha/about/reports.page, along with other reports on health and safety issues, which detail the Authority’s efforts to inspect for and correct deficiencies associated with environmental contaminants like lead-based paint and mold. The Authority plans to continue to work to address these health and safety issues, and to work towards meeting the multi-year obligations laid out in the HUD agreement in addition to the action plans. NYCHA has recorded $4,392,861,000 of pollution remediation obligations as of December 31, 2023, which relates to costs to inspect for, and correct deficiencies associated with environmental contaminants. Action Date Ongoing milestones through January 31, 2039 Final Implementation The latest in time obligation under the HUD Agreement is the Authority’s obligation to abate 100% of the apartment units that contain lead-based paint, and the interior common areas that contain lead-based paint in the same building as those units, by January 31, 2039 Name And Phone Number Of Person Responsible For Implementation Brad Greenburg Chief Compliance Officer 212-306-4240

View Audit 321980

Finding 499138 (2023-001)

Significant Deficiency 2023

Wireless Infrastructure Association and Affiliates

VA

Cash Management Subrecipient Monitoring HUD Housing Programs § 200.305

WIA management will implement the following corrective action plan: In order to ensure compliance with the timeliness of disbursements of federal funds contemplated under 2 CFR 200.305(b), WIA will implement the following additional procedures for federally-funded expenses. A detailed evaluation ...

WIA management will implement the following corrective action plan: In order to ensure compliance with the timeliness of disbursements of federal funds contemplated under 2 CFR 200.305(b), WIA will implement the following additional procedures for federally-funded expenses. A detailed evaluation of project deliverables and timelines will be conducted by the Project Manager and Project Director for any program subject to compliance with Federal guidelines. The timelines, deliverables and affected funding mechanism(s) will be aligned to determine if there may be a delay beyond a reasonable period which would impact the submission and processing of payments to subcontractors. If it is determined that a delay is possible or likely, consideration will be given to contract amendments which better support the processing of payments aligned with 2 CFR 200.305(b). Further, the Finance team member assigned to the associated program will provide regular guidance to the project team which may include a detailed briefing on the CFR and any relevant concerns with cash management. Disbursements of federal funds will be issued in a timely manner in all instances. The additional set of procedures described above will be implemented in September 2024. In addition, we are currently working through finalizing the contract for Phase 2 of the specific contract related to this finding. We anticipate these negotiations will be completed by October 31st, 2024. Once the Phase 2 agreement has been reached, we will immediately release the Phase 1 funds to the vendor and obtain guidance from The Ohio State University as to the proper disposition of any interest that has been earned by WIA from the withheld Phase 1 payment. Marta Sokol, Chief Financial Officer is the individual responsible for oversight of this corrective action plan. Mrs. Sokol can be reached at 703.535.7447 or Marta.Sokol@wia.org.

View Audit 321912

Finding 499114 (2023-002)

Significant Deficiency 2023

Bronx Community Health Network, Inc.

NY

Subrecipient Monitoring Reporting HUD Housing Programs § 200.303

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2023 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2023-002 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) – Significant Deficienc...

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2023 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2023-002 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) – Significant Deficiency Description of Finding: There was no evidence of review and approval by someone other than the preparer of the FFATA subawards that were submitted to the FSRS. The FFATA subawards were not submitted timely to the Federal Funding Accountability and Transparency Act Subaward Reporting System (“FSRS”). Statement of Concurrence: We concur with the finding above. Corrective Action: As of September 1, 2023, BCHN implemented a workflow where FFATA information will be reported to the FSRS upon receipt of the Notices of Award. In addition, as of September 9, 2024, the FFATA report will be reviewed by someone other than the preparer prior to submission and evidence of the approval maintained. Completion Date: September 9, 2024. Name of Contact Person: James Paine, Ph.D. Chief Executive Officer Tel. No.: (718) 405-4993 E-mail: jpaine@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call James Paine at (718) 405-4993. Sincerely yours, _________________________ James Paine, Ph.D. Chief Executive Officer

View Audit 321903

Finding 499111 (2023-002)

Significant Deficiency 2023

Regent at Apple Valley, LLC Dba: the Seasons at Apple Valley

MN

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to maintain tenant security deposits in a separate bank account in an amount adequate to cover the security deposit liability. The security deposit bank account balance was not adequate to cover the security depos...

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to maintain tenant security deposits in a separate bank account in an amount adequate to cover the security deposit liability. The security deposit bank account balance was not adequate to cover the security deposit liability. Recommendation: Recommend management fund the security deposit account in an amount that is adequate to cover the security deposit liability. There is no disagreement with the audit finding. Action taken in response to finding: We have funded the security deposit account in an amount adequate to cover the security deposit liability. Name of the contact person responsible for corrective action: Cassandra Johnson Planned completion date for corrective action plan: July 2024

View Audit 321895

Finding 499110 (2023-001)

Significant Deficiency 2023

Regent at Apple Valley, LLC Dba: the Seasons at Apple Valley

MN

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to retain the HUD approved management agreement to ensure payments made are in accordance with HUD requirements. The Project does not have a HUD approved management agreement. Recommendation: Recommend that manage...

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to retain the HUD approved management agreement to ensure payments made are in accordance with HUD requirements. The Project does not have a HUD approved management agreement. Recommendation: Recommend that management work with HUD to have the current management agreement approved. There is no disagreement with the audit finding. Action taken in response to finding: We have contacted HUD to obtain an approved management agreement. Name of the contact person responsible for corrective action: Cassandra Johnson Planned completion date for corrective action plan: September 2024

View Audit 321895

Finding 499106 (2023-002)

Material Weakness 2023

St. Charles Parish Housing Authority

LA

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

Corrective Action Plan Finding: Finding 2023-002-Lack of Adequate Quality Control Regarding Tenant Procedures-Eligibility Condition: The quality of supervision over tenant file functions, such as calculating tenant rent and Housing Assistance Payments should be timely and sufficient to find error...

Corrective Action Plan Finding: Finding 2023-002-Lack of Adequate Quality Control Regarding Tenant Procedures-Eligibility Condition: The quality of supervision over tenant file functions, such as calculating tenant rent and Housing Assistance Payments should be timely and sufficient to find errors in calculations or mis-application or mis-understanding of procedures. Corrective Action Planned I am Jedidiah Jackson. I was hired as E.D., effective July 1, 2024. We are in the process of addressing the problems noted in the audit, as well as correcting other issues noted by HUD. Person responsible for corrective action: Jedidiah Jackson, E.D. Telephone: (985) 785-2601 St. Charles Parish Housing Authority Fax: (985) 785-6238 200 Boutte Estates Dr. Boutte, LA 70039 Anticipated Completion Date- October 31, 2024

View Audit 321894

Finding 499105 (2023-001)

Material Weakness 2023

St. Charles Parish Housing Authority

LA

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

ST. CHARLES PARISH HOUSING AUTHORITY________________________________________PHONE: 985-785-2601 ·FAX:985-785-6238· 200 BOUTTE ESTATES DRIVE ·BOUTTE, LA 70039-0448 ________________________________________ HOUSING AUTHORITY OF ST. CHARLES PARISH, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER...

ST. CHARLES PARISH HOUSING AUTHORITY________________________________________PHONE: 985-785-2601 ·FAX:985-785-6238· 200 BOUTTE ESTATES DRIVE ·BOUTTE, LA 70039-0448 ________________________________________ HOUSING AUTHORITY OF ST. CHARLES PARISH, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2023 Corrective Action Plan Finding: Finding 2023-001-Internal Controls Inadequate for Disbursements-Allowable Costs Condition: Good internal controls should be in place to make sure that disbursements are for eligible payments, are correctly classified, and are timely paid. Good controls ensure that there is proper, documented review of all these functions. Records should be maintained in an order that is conducive to efficient and timely summarizing by the outside fee accounting firm. Unaudited financial statements should be produced on a timely basis, and reviewed by the Board of Commissioners. Corrective Action Planned I am Jedidiah Jackson. I was hired as E.D., effective July 1, 2024. We are in the process of addressing the problems noted in the audit, as well as correcting other issues noted by HUD. Person responsible for corrective action: Jedidiah Jackson, E.D. Telephone: (985) 785-2601 St. Charles Parish Housing Authority Fax: (985) 785-6238 200 Boutte Estates Dr. Boutte, LA 70039 Anticipated Completion Date- October 31, 2024

View Audit 321894

Finding 499083 (2023-002)

Significant Deficiency 2023

Mobile Housing Authority

AL

Eligibility HUD Housing Programs Significant Deficiency

Action Taken: MHA will review and enhance as necessary the program’s existing quality control (QC) file review procedures as well as daily data validation reports to include a measure that cross-checks existing reports in the Yardi system of record and aids in validating data routinely submitted to ...

Action Taken: MHA will review and enhance as necessary the program’s existing quality control (QC) file review procedures as well as daily data validation reports to include a measure that cross-checks existing reports in the Yardi system of record and aids in validating data routinely submitted to HUD’s PIC system. To further mitigate the risk posed by frequent turnover among Housing Specialist-I (HS-I) staff, MHA will increase the frequency of training on rent and income determination for all staff including tenured team members and new hires, alike, to occur quarterly. In 2023, MHA implemented a Housing Specialist-II Team Lead to oversee HS-I staff processing annual reexaminations in accordance with 24 CFR 982.516. This team member is responsible for ensuring families are notified in a timely manner and if they do not comply with the annual reexamination requirement, they receive termination notices in compliance with HUD and MHA Administrative Plan requirements. MHA also implemented two compliance analysts in 2023; we will add another compliance analyst staff person in 2024 to increase the percentage of files undergoing quality control review. These three (3) Compliance Analyst will report to the Operations and Compliance Manager who monitors HUD’s PIC system and analyzes discrepancies between PIC data and MHA data housed in the Yardi system of record. This information is maintained in the program file. Name of Responsible Person: Paul and Magdalene Watkins, Program Administration Team Projected Completion Date: 12/31/2024

View Audit 321867

Finding 499072 (2023-001)

Significant Deficiency 2023

Council Towers II Housing Development Fund Corporation

NY

HUD Housing Programs Special Tests & Provisions

1. Finding 2023-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding and will implement the auditor’s recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action(s) Taken or Planned on the Finding Action ...

1. Finding 2023-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding and will implement the auditor’s recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action(s) Taken or Planned on the Finding Action 1-The residence director, building office staff, and accounting staff will be informed of the HUD requirements regarding the timely refund of security deposits. Action 2-The residence director and building office staff will immediately notify the accounting staff of all move outs by email so that a security deposit refund check can be promptly issued. Action 3-The asset management staff will review the accounts payable aging on a weekly basis to ensure that all security deposit refund checks have been issued. b. Support staff has been brought in to lighten the workload of the fiscal staff allowing them the time to ensure that the return of the security deposits are processed in a timely manner.

View Audit 321849

Finding 499071 (2023-001)

Significant Deficiency 2023

Council Towers IV Housing Development Fund Corporation

NY

HUD Housing Programs Special Tests & Provisions Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Although the Housing Director processed the Final Accoun...

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Although the Housing Director processed the Final Accounting Statement in a timely manner and requested that the security deposit be returned to the tenant, the Accounts Payable Department missed the request. As staff have been covering two, sometimes three positions, adequate attention was not given to this item. This year, we have brought additional help to support the Fiscal Department. This support staff has allowed the key members of the fiscal team to work with a manageable workload and at a pace that will ensure that security deposits will be returned within 30 days of a tenant’s departure.

View Audit 321847

Finding 499070 (2023-001)

Significant Deficiency 2023

Council Towers III Housing Development Fund Corporation

NY

HUD Housing Programs Special Tests & Provisions

Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action 1-The residence director, building office staff, and accounting staff will be informed of the HUD requirements ...

Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action 1-The residence director, building office staff, and accounting staff will be informed of the HUD requirements regarding the timely refund of security deposits. Action 2-The residence director and building office staff will immediately notify the accounting staff of all move outs by email so that a security deposit refund check can be promptly issued. Action 3-The asset management staff will review the accounts payable aging on a weekly basis to ensure that all security deposit refund checks have been issued.

View Audit 321845

Finding 498920 (2023-001)

Significant Deficiency 2023

Regent at Maplewood, LLC Dba: the Seasons at Maplewood

MN

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to maintain tenant security deposits in a separate bank account in an amount adequate to cover the security deposit liability. The security deposit bank account balance was not adequate to cover the security depos...

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to maintain tenant security deposits in a separate bank account in an amount adequate to cover the security deposit liability. The security deposit bank account balance was not adequate to cover the security deposit liability. Recommendation: Recommend management fund the security deposit account in an amount that is adequate to cover the security deposit liability. There is no disagreement with the audit finding. Action taken in response to finding: We have funded the security deposit account in an amount adequate to cover the security deposit liability. Name of the contact person responsible for corrective action: Cassandra Johnson Planned completion date for corrective action plan: July 2024

View Audit 321756

Finding 498901 (2023-002)

Significant Deficiency 2023

City of Charleston, South Carolina

SC

HUD Housing Programs Period of Performance Reporting

The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

View Audit 321709

Finding 498867 (2023-002)

None 2023

City of Bayonne

NJ

HUD Housing Programs Reporting

The City will ensure that the Annual MBE Report is filed.

View Audit 321620

Finding 498836 (2023-001)

Material Weakness 2023

Housing Authority of Columbus

GA

HUD Housing Programs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding 2023-001- Accounting Controls - Internal Controls over Financial Statement Preparation ALN 14.881- Noncompliance and Material Weakness Corrective Action Plan: 1. Cash and Investments • HACG cash reconciliations will be completed, verified, and reported to the CEO monthly 2. Capital Assets an...

Finding 2023-001- Accounting Controls - Internal Controls over Financial Statement Preparation ALN 14.881- Noncompliance and Material Weakness Corrective Action Plan: 1. Cash and Investments • HACG cash reconciliations will be completed, verified, and reported to the CEO monthly 2. Capital Assets and Depreciation • Comptroller will update and verify capital assets throughout the year, in accordance with the HACG's procurement policy. • Comptroller will verify the reporting period is accurate for the depreciation schedule. 3. Notes Receivable and Notes Payable • Verify monthly that all note receivables and payables are reported correctly 4. General Financial Statement Reconciliation • CFO will review all financials throughout the year to assure unaudited financial statements are presented accurately. Person Responsible: Carla Godwin Anticipated Completion Date: On-going

View Audit 321589

Finding 498831 (2023-001)

Significant Deficiency 2023

City of Platteville

WI

Internal Control / Segregation of Duties HUD Housing Programs

Finding #2023-001- Segregation of Duties Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control ...

Finding #2023-001- Segregation of Duties Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or can both make and conceal an error, whether such error is intentional or unintentional. Condition: A properly designed system of internal control includes adequate staffing, policies, and procedures to properly segregate duties. All internal control duties can be classified into four broad categories: authorization, custody, recordkeeping, and reconciliation. No one person should have control of two or more of these four categories for any one cycle. There are key controls related to significant transaction cycles that are important in reducing the risk of errors or irregularities. Currently, there are the following overlapping duties: - Both Accounting Specialists have the authority to enter invoices into the system, print checks, and have access to the electronic signatures. Preferably, the check cutting process would separate the entering of payment information into the system and the ability to print signed checks. - One Accounting Specialist creates deposits and makes deposits with the bank. Although not the standard procedure, the Accounting Specialist has the authority to collect cash receipts. Ideally, separate individuals would collect cash and make deposits. - The Housing Authority Executive Director opens the mail, creates deposits and takes deposits to the bank. The Executive Director also enters invoices into the system and prints checks. The Board of Commissioners approves disbursements and all checks require dual signatures. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities because of the lack of segregation of duties. Cause: Limited number of personnel. Recommendation: We recommend that the City consider the benefits of implementing additional policies and procedures to address key controls related to its significant transaction cycles as noted. Response: We agree with this finding but do not believe it is cost effective to increase personnel to bring about a more effective segregation of duties.

View Audit 321586

Finding 498767 (2023-001)

Material Weakness 2023

Housing Authority of Asotin County

WA

HUD Housing Programs Subrecipient Monitoring Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Housing Authority of Asotin County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the Housing Authority is planning to take for findings included in this report in accordance with Title 2 U.S...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Housing Authority of Asotin County January 1, 2023 through December 31, 2023 This schedule presents the corrective action the Housing Authority is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The Housing Authority had inadequate internal controls for ensuring compliance with Housing Quality Standards enforcement requirements of its Housing Voucher Cluster program. Name, address, and telephone of Housing Authority contact person: KayLee Rosgen, Manager, Business and Finance 1212 Fair St., Clarkston, WA 99403 (509) 758-5751 ext. 4 Corrective action the auditee plans to take in response to the finding: The Housing Authority does concur with the State Auditor’s Office finding that the Housing Quality Standards (HQS) requirements are to follow up with the landlord if any life-threatening deficiencies are identified during an inspection. The requirement states that “If a deficiency is life-threatening, the owner (landlord) must correct the deficiency within 24 hours of notification” (24 CFR 982.404(a)(3)). The Housing Authority’s corrective action plan moving forward includes the following: • Reviewing HQS/NSPIRE standards with current staff assigned to performing and processing Section 8 inspections during a monthly meeting • Implement internal controls that ensure all life-threatening deficiencies are identified and all required notifications are made • Review all parts of the Code of Federal Regulations (CFR) and PIH notices distributed by HUD monthly that pertain to HQS/NSPIRE inspection standards • All pertinent staff will take the next NSPIRE Inspection Standards training (all inspectors and Section 8 Occupancy Specialist) • Updating our process to include the use of a new inspection checklist that separately identifies life-threatening deficiencies, as well as using a new form to document attempts to contact the landlord and the date the deficiency is resolved The Housing Authority acknowledges that we lacked the appropriate internal controls to identify and notify the landlords of any life-threatening deficiencies that must be corrected within 24 hours. With this corrective action plan in place as of September 9, 2024, the Housing Authority feels that we are on track to comply with the requirements set forth by HUD and any relevant CFRs. Anticipated date to complete the corrective action: September 9, 2024 (immediately and on-going)

View Audit 321448

Finding 498739 (2023-001)

Significant Deficiency 2023

White River Housing Association

WA

HUD Housing Programs Reporting

Management will restore funds to replacement reserve account when project funds become available. Management will review reserve withdrawals prior of release of funds from the reserve account to verify the release is approved by the HUD account executive and the release is not a duplicate. The app...

Management will restore funds to replacement reserve account when project funds become available. Management will review reserve withdrawals prior of release of funds from the reserve account to verify the release is approved by the HUD account executive and the release is not a duplicate. The approval will be reviewed by the person initiating the request and verified by the project bookkeeper.

View Audit 321420

Finding 498693 (2023-005)

Material Weakness 2023

Victoria Jennings Residences, LTD

IL

HUD Housing Programs

The Project will follow HUD directives regarding tenant recertification by issuing a new lease, and the effective utility allowance will be stated on the lease and Form HUD 50059.

View Audit 321399

Corrective Action Plans

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