Corrective Action Plans

Finding 1224921 (2023-001)

Material Weakness 2023

NE

HUD Housing Programs

Management agrees with the recommendation and submitted the audited financial statements to HUD. No further action is required.

View Audit 408175

Finding 1224018 (2023-003)

Material Weakness 2023

LAND MANOR, INC.

TX

Subrecipient Monitoring Allowable Costs / Cost Principles HUD Housing Programs

Block Grant for Prevention and Treatment of Substance Abuse (CFDA 93.959) - Compliance - Special Testing Corrective Action Plan: Quality Management Coordinator has conducted in-service training with staff members at the TRA and TRF facilities. Management will continue to emphasize, with the appropri...

Block Grant for Prevention and Treatment of Substance Abuse (CFDA 93.959) - Compliance - Special Testing Corrective Action Plan: Quality Management Coordinator has conducted in-service training with staff members at the TRA and TRF facilities. Management will continue to emphasize, with the appropriate individuals, the need to complete and document, contemporaneously, each program requirement. Anticipated Completion Date: July 15, 2026 Responsible Party: Land Manor Executive Director, Quality Management Coordinator and Program Directors.

View Audit 407429

Finding 1223940 (2023-005)

Material Weakness 2023

Hope Toledo Services

OH

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Other Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the management and finance staff work on retaining documentation and training staff to ensure processes and controls are in place over provider payment calculations and payroll. ...

Other Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the management and finance staff work on retaining documentation and training staff to ensure processes and controls are in place over provider payment calculations and payroll. We also recommend a formal check signing process is implemented to ensure authorization of disbursement is documented appropriately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We will update our policies and procedures to incorporate the recommendations above. Name of the contact person responsible for corrective action: John C. Jones, President and CEO Planned completion date for corrective action plan: 9/30/2026

View Audit 407341

Finding 1223936 (2023-003)

Material Weakness 2023

Hope Toledo Services

OH

Questioned Costs HUD Housing Programs Reporting

Reporting Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that reports are prepared and reviewed by separate individuals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/tak...

Reporting Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that reports are prepared and reviewed by separate individuals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will put a formal layer of review after preparation of the report and before submission to the grantor. Name of the contact person responsible for corrective action: John C. Jones, President and CEO Planned completion date for corrective action plan: 9/30/2026

View Audit 407341

Finding 1223917 (2023-002)

Material Weakness 2023

Municipality of Camuy

PR

HUD Housing Programs § 200.327 § 200.328

We do not agree with the finding. The FASS-PHA cannot be submitted until the Single Audit is completed and issued. We acknowledge that the unaudited FASS-PHA was submitted late, and evidence was provided and the report was approved by HUD. We have the audited submission in draft pending the issuance...

We do not agree with the finding. The FASS-PHA cannot be submitted until the Single Audit is completed and issued. We acknowledge that the unaudited FASS-PHA was submitted late, and evidence was provided and the report was approved by HUD. We have the audited submission in draft pending the issuance of the Single Audit. The Municipality has developed an internal plan with the auditors and consultants to perform all pending Single Audit to the Federal Audit Clearinghouse as soon as possible. The Single Audit for the fiscal years ended June 30, 2024 and June 30, 2025 are already contracted and are expected to begin in August 2026. Personnel in charge: Daiana González Hernández, Finance Office Director Projected Completion Date: August 30, 2027

View Audit 407331

Finding 1223791 (2023-001)

Material Weakness 2023

Comite Gericola Regional De Mayaguez, Incorporado-Ciudad Del Retiro

PR

HUD Housing Programs

Management currently evaluating the alternative.

View Audit 407272

Finding 1223126 (2023-011)

Material Weakness 2023

St. Croix Chippewa Housing Authority

CA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management § 200.305

2023-011 Timely Grant Draws Material Weakness Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed. Action Taken: The Housing Authority agrees with this fi...

2023-011 Timely Grant Draws Material Weakness Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

View Audit 406660

Finding 1223122 (2023-007)

Material Weakness 2023

St. Croix Chippewa Housing Authority

CA

Eligibility HUD Housing Programs Material Weakness

2023-007 Tenant Eligibility Material Weakness Recommendation: In general, we continue to recommend a review of the re-certification process to determine areas of weakness. Specifically, we recommend the use of a standard checklist in the re-certification process. We further recommend that each re-ce...

2023-007 Tenant Eligibility Material Weakness Recommendation: In general, we continue to recommend a review of the re-certification process to determine areas of weakness. Specifically, we recommend the use of a standard checklist in the re-certification process. We further recommend that each re-certification clerk’s work be routinely audited. We also recommend more standardization in resident files organization of information, and procedures established to make sure all files are maintained adequately in order to be compliant. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

View Audit 406660

Finding 1219651 (2023-010)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring HUD Housing Programs Internal Control / Segregation of Duties

Director of Finance (CDBG-DR Unit), Compliance team, and Chief Financial Officer October 2023 VIHFA has established enhanced internal controls and comprehensive record-keeping protocols. This includes expanded training initiatives for staff and subrecipients, as well as strengthened procedures for r...

Director of Finance (CDBG-DR Unit), Compliance team, and Chief Financial Officer October 2023 VIHFA has established enhanced internal controls and comprehensive record-keeping protocols. This includes expanded training initiatives for staff and subrecipients, as well as strengthened procedures for record retention. The Authority has also updated its policies and standard operating procedures to ensure greater coverage and effectiveness, and is committed to ongoing improvement and consistently meets all compliance requirements through detailed documentation. These measures have been implemented, training has taken place, and policies have been revised.

View Audit 405194

Finding 1219651 (2023-010)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring HUD Housing Programs Internal Control / Segregation of Duties

Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compli...

Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compliance with applicable federal regulations

View Audit 405194

Finding 1218727 (2023-002)

Material Weakness 2023

Benton County

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs

The County has since implemented corrective actions to strengthen internal controls and ensure compliance moving forward, including: Providing targeted staff training on eligibility requirements, including self-attestation limitations. Implementing a secondary review process for eligibility determin...

The County has since implemented corrective actions to strengthen internal controls and ensure compliance moving forward, including: Providing targeted staff training on eligibility requirements, including self-attestation limitations. Implementing a secondary review process for eligibility determinations and payment calculations when clients self-certify income. Establishing ongoing monitoring procedures, including periodic file reviews. Benton County is committed to maintaining strong internal controls and ensuring compliance with all applicable federal and state requirements. These enhancements are designed to prevent recurrence and support consistent application of program guidelines.

View Audit 404788

Finding 1217652 (2023-006)

Material Weakness 2023

LAUREL ADVOCACY & REFERRAL SERVICES, INC.

MD

Reporting Subrecipient Monitoring HUD Housing Programs

LARS has implemented the following controls to address each element of this finding: HUD CoC Match Tracking: A grant-level match tracking schedule has been established for the CoC program. The schedule documents required match amounts, eligible match contributions, and cumulative match-to-date, and ...

LARS has implemented the following controls to address each element of this finding: HUD CoC Match Tracking: A grant-level match tracking schedule has been established for the CoC program. The schedule documents required match amounts, eligible match contributions, and cumulative match-to-date, and is updated at each reporting period. The Finance Director reviews the schedule prior to each drawdown and at fiscal year-end. Administrative Cost Limitation Monitoring: Written policies and procedures have been updated to include a procedure for monitoring the HUD CoC administrative cost limitation. The Finance Director calculates the limitation at the beginning of each grant year and monitors actual administrative costs on a quarterly basis. Grant Cutoff Procedures: A written grant financial management policy has been adopted that establishes cutoff procedures for recording expenditures within applicable grant performance periods. The accounting system has been configured to flag transactions with dates outside an active grant period for Finance Director review prior to posting. SEFA Preparation and Review: A formal SEFA preparation procedure has been implemented that requires: • A reconciliation of SEFA amounts to the general ledger and underlying grant records • A documented review of all grants and funding sources including state and local grants to determine proper SEFA inclusion and reporting treatment

View Audit 403810

Finding 1216463 (2023-004)

Material Weakness 2023

Mt Pleasant Housing Develpment Fund Company

NY

Eligibility HUD Housing Programs

Concord’s Compliance Dept has implemented procedures to ensure the tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that the tenant lease files are properly maintained in accordance with HUD’s requirements.

View Audit 402963

Finding 1216462 (2023-003)

Material Weakness 2023

Mt Pleasant Housing Develpment Fund Company

NY

HUD Housing Programs

Concord is making “unauthorized” loans only as it pertains to insurance payments. Until the rental increases are large enough to cover the ongoing increasing costs of insurance premiums, management has no choice but to allow the entity with the most stable cashflow to make the monthly insurance paym...

Concord is making “unauthorized” loans only as it pertains to insurance payments. Until the rental increases are large enough to cover the ongoing increasing costs of insurance premiums, management has no choice but to allow the entity with the most stable cashflow to make the monthly insurance payments on behalf of the entities that are unable to cover their portion. The only available insurance coverage is via a policy that covers all three entities as the cost to cover the entities individually is astronomical. The only way to ensure the entities are insured and there is no lapse in coverage is to allow the entity with the stable cashflow to make the payments and for the other entities to reimburse for their portion. That is until the rental increases are substantial enough to actually cover the rising costs of insurance premiums.

View Audit 402963

Finding 1214959 (2023-004)

Material Weakness 2023

HOUSING AUTHORITY OF THE CITY OF LITTLE ROCK, ARKANSAS

CA

Allowable Costs / Cost Principles HUD Housing Programs Questioned Costs

Finding 2023-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, Public Housing Capital Fund Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, 14.872, and 21.01...

Finding 2023-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, Public Housing Capital Fund Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, 14.872, and 21.019 Material Noncompliance Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance Criteria: The Authority must maintain complete and accurate accounts and other records for the program in accordance with HUD compliance requirements. Condition: The Authority did not maintain complete and accurate accounts and other records in accordance with HUD compliance requirements regarding Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility, Reporting, and Special Tests and Provisions. Context: The Authority was unable to provide requested documentation at the time of audit to properly test the HUD compliance requirements. Known Questioned Costs: Unknown Cause: There is a material weakness in internal controls over compliance related to the maintenance of tenant files, wait lists, inspection reports and other records. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non- compliance with the compliance requirements of the program. Recommendation: We recommend that the Authority implement a process whereby Authority documents are stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority experienced significant turnover in employees during the year and as a result certain source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows its internal control over compliance processes and procedures related to the Housing Voucher Cluster, Public and Indian Housing Program and Public Housing Capital fund Program to remedy the aforementioned deficiencies. Byran McClellan, CFO, will be responsible to implement this corrective action by December 31, 2023.

View Audit 401728

Finding 1214611 (2023-011)

Material Weakness 2023

Town of Saugerties

NY

HUD Housing Programs Special Tests & Provisions

Finding 2023-011 - Special Tests and Provisions: Depository Agreements Auditee's Response and Planned Corrective Action The Town will work with the Public Housing administrator to insure a depository agreement is in place and documentation of same is on file and readily available. Planned Implementa...

Finding 2023-011 - Special Tests and Provisions: Depository Agreements Auditee's Response and Planned Corrective Action The Town will work with the Public Housing administrator to insure a depository agreement is in place and documentation of same is on file and readily available. Planned Implementation Date of Corrective Action: January 2025 Person Responsible for Corrective Action: Fred Costello, Town Supervisor

View Audit 401283

Finding 1214610 (2023-010)

Material Weakness 2023

Town of Saugerties

NY

HUD Housing Programs

Finding 2023-010 - Reporting Auditee's Response and Planned Corrective Action The town will work with the Public Housing administrator to implement a system to complete and file the unaudited financial information within two and a half months, and with the independent audit finn to file within nine ...

Finding 2023-010 - Reporting Auditee's Response and Planned Corrective Action The town will work with the Public Housing administrator to implement a system to complete and file the unaudited financial information within two and a half months, and with the independent audit finn to file within nine months. Planned Implementation Date of Corrective Action: January 2025 Person Responsible for Corrective Action: Fred Costello, Town Supervisor

View Audit 401283

Finding 1213510 (2023-001)

Material Weakness 2023

Housing Authority of the County of Santa Barbara

CA

HUD Housing Programs Special Tests & Provisions

Corrective Action Plan For the year ended December 31, 2023 U.S. Department of Housing and Urban Development: Housing Authority of the County of Santa Barbara respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Novogradac and Company, LLP Certifie...

Corrective Action Plan For the year ended December 31, 2023 U.S. Department of Housing and Urban Development: Housing Authority of the County of Santa Barbara respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Financial Statement Findings There were no findings relating to the financial statements which are required to be reported in accordance with Government Auditing Standards. Federal Award Findings and Questioned Costs 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). Sanford Riggs, Director of Operations, is responsible for implementing this corrective action by December 31, 2024 Schedule of Prior Year Audit Findings Context: Based upon inspection of the Authority’s procurement files, there was one vendor who was contracted utilizing non competitive (sole source) proposals in violation of the Authority's approved Statement of Fiscal Policies, dated August 16, 2018. Status: The finding has been cleared. Sincerely yours, Irene Melton, Director of Finance Housing Authority of the County of Santa Barbara

View Audit 400458

Finding 1208852 (2023-001)

Material Weakness 2023

Cornerstone Homes River Gardens, Inc.

LA

HUD Housing Programs

Management deposited $3,005 into the Reserve for Replacement account on April 15, 2026 to cover the shortage.

View Audit 399813

Finding 1208283 (2023-004)

Material Weakness 2023

Aurora Homes, Inc.

MD

Questioned Costs Eligibility HUD Housing Programs

Tenant File Review - Review all tenant files; obtain and file missing documentation - May 2026 Policies and procedures - Update and document procedures; implement standardized checklist; supervisory review required. - May 2026 Staff Training - Train staff on HUD eligibility, documentation standards,...

Tenant File Review - Review all tenant files; obtain and file missing documentation - May 2026 Policies and procedures - Update and document procedures; implement standardized checklist; supervisory review required. - May 2026 Staff Training - Train staff on HUD eligibility, documentation standards, and updated procedures Ongoing Monitoring - Quarterly internal audits; COO and Board Finance Committee review of compliance - ongoing Oversight and Reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to finance committee - ongoing

View Audit 399312

Finding 1208282 (2023-003)

Material Weakness 2023

Aurora Homes, Inc.

MD

Questioned Costs HUD Housing Programs Reporting

Compliance Calendar - Implement a calendar for all federal reporting deadlines with advance reminders - May 2026 Month-End and Year-End Close - Standardize closing procedures; set internal deadlines ahead of REAC requirement - May 2026 Oversight and Monitoring - CFO review of compliance; periodic up...

Compliance Calendar - Implement a calendar for all federal reporting deadlines with advance reminders - May 2026 Month-End and Year-End Close - Standardize closing procedures; set internal deadlines ahead of REAC requirement - May 2026 Oversight and Monitoring - CFO review of compliance; periodic updates to CEO and Board Finance Committee Contingency Procedure - Submit owner-certified report if audited statements not finalized within 90 days - as needed

View Audit 399312

Finding 1208281 (2023-006)

Material Weakness 2023

Ashmore Homes, Inc.

MD

Questioned Costs Special Tests & Provisions Eligibility

Fund Account - Deposited back to the replacement reserve account - October 16, 2025 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - M...

Fund Account - Deposited back to the replacement reserve account - October 16, 2025 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - May/June 2026 Oversight and Reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to Finance Committee - Ongoing

View Audit 399311

Finding 1208279 (2023-004)

Material Weakness 2023

Ashmore Homes, Inc.

MD

Questioned Costs Eligibility HUD Housing Programs

Tenant File Review - Review all tenant files; obtain and file missing documentation - May 2026 Policies and procedures - Update and document procedures; implement standardized checklist; supervisory review required. - May 2026 Staff Training - Train staff on HUD eligibility, documentation standards,...

Tenant File Review - Review all tenant files; obtain and file missing documentation - May 2026 Policies and procedures - Update and document procedures; implement standardized checklist; supervisory review required. - May 2026 Staff Training - Train staff on HUD eligibility, documentation standards, and updated procedures Ongoing Monitoring - Quarterly internal audits; COO and Board Finance Committee review of compliance - ongoing Oversight and Reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to finance committee - ongoing

View Audit 399311

Finding 1208278 (2023-003)

Material Weakness 2023

Ashmore Homes, Inc.

MD

Questioned Costs HUD Housing Programs Reporting

Compliance Calendar - Implement a calendar for all federal reporting deadlines with advance reminders - May 2026 Month-End and Year-End Close - Standardize closing procedures; set internal deadlines ahead of REAC requirement - May 2026 Oversight and Monitoring - CFO review of compliance; periodic up...

Compliance Calendar - Implement a calendar for all federal reporting deadlines with advance reminders - May 2026 Month-End and Year-End Close - Standardize closing procedures; set internal deadlines ahead of REAC requirement - May 2026 Oversight and Monitoring - CFO review of compliance; periodic updates to CEO and Board Finance Committee Contingency Procedure - Submit owner-certified report if audited statements not finalized within 90 days - as needed

View Audit 399311

Finding 1206357 (2023-007)

Material Weakness 2023

HOUSING AUTHORITY OF THE CITY OF MILWAUKEE

WI

HUD Housing Programs

2023-007 Allowability - Interprograms Housing Voucher Cluster Material Weakness in Internal Controls Material Noncompliance Condition: Currently the Authority maintains a material interprogram receivable in Housing Choice Voucher program ("HCV"), which is due from the Central Office Cost Center ("CO...

2023-007 Allowability - Interprograms Housing Voucher Cluster Material Weakness in Internal Controls Material Noncompliance Condition: Currently the Authority maintains a material interprogram receivable in Housing Choice Voucher program ("HCV"), which is due from the Central Office Cost Center ("COCC"). As of December 31, 2023, the interprogram receivable for HCV is $2,500,000. Auditor Recommendations: The Authority should follow the Recovery Plan, once established, that will be implemented with HUD to pay back the interprogram receivable. The Authority should continue to budget and monitor COCC and other Authority expenses to eliminate the need for borrowing funds from restricted federal programs, and to have the a bility to reimburse HCV for the borrowed funds. Action Taken: HACM performed a 100% financial transaction review related to the Housing Choice Voucher program in compliance with requirements from the HUD Quality Assurance Division Corrective Action Plan. This fi nancial transaction review identified a total of $2,900,000 in amounts in the Housing Choice Voucher program funding that needed to be repaid to HUD and an additional $11,712 in ineligible expenses spent from HCV Administrative funding. H ACM's Acting Secretary-Executive Director has been working with the Quality Assurance Division to provide them documentation requested so that QAD can perform an analysis of HACM's ability to pay. The goal is to work with HUD to identify a longerterm repayment plan that is in line with the PHA's ability to pay. The goal is to finalize a repayment agreement in the next couple months. Name of Responsible Person: Ken Barbeau, Acting Secretary-Executive Director; C hief Financial Officer (when hired); Projected Completion Date: June 30, 2026

View Audit 398376

Corrective Action Plans

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