Corrective Action Plans

Finding 497987 (2023-001)

None 2023

Town of Plattsburgh Housing Development Fund Company, Inc.

NY

Special Tests & Provisions HUD Housing Programs

Name of auditee: Town of Plattsburgh Housing Development Fund Company, Inc. TIN: 014-EE068 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2023 CAP prepared by: David Kimmel President Two Plus Four Property Management Co,. Inc. (315) 437-2178 Current Finding on the S...

Name of auditee: Town of Plattsburgh Housing Development Fund Company, Inc. TIN: 014-EE068 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2023 CAP prepared by: David Kimmel President Two Plus Four Property Management Co,. Inc. (315) 437-2178 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations Finding 2023-001 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation, please see below for action taken. (b) Action taken: Management will deposit the underfunded amount of $6,000 into the reserve for replacements account during August 2024.

View Audit 320668

Finding 497980 (2023-003)

Significant Deficiency 2023

Maine Sate Housing Authority

ME

HUD Housing Programs Eligibility

2023-003: Housing Voucher Cluster – Eligibility – Document Retention Name of Contact Person(s): Allison Gallagher, Director of Housing Choice Vouchers Management’s Views and Corrective Action Plan: Signed HAP contracts and lease agreements are required for every new lease up and MaineHousing will...

2023-003: Housing Voucher Cluster – Eligibility – Document Retention Name of Contact Person(s): Allison Gallagher, Director of Housing Choice Vouchers Management’s Views and Corrective Action Plan: Signed HAP contracts and lease agreements are required for every new lease up and MaineHousing will not release payment to the owner until those signed documents are received. These agreements state the contract rent and subsidy amounts at the time of the initial lease. Annually, each tenant is recertified and a contract amendment is generated with the current contract rent and subsidy amounts listed. These amendments are filed with the original documents. Management is certain that proper rent and subsidy payments were made based on annual and interim recertification documents on file. A new electronic file retention process was implemented in 2022, which involved organizing and converting volumes of physical files to electronic files. Since implementation of the new process, we have determined that some unit information for certain tenants was inadvertently discarded during conversion. Program staff are identifying missing unit information as they process annual recertification or when an outside party requests it and reaching out to the owner to obtain a copy of the signed original documents. The two HAP and lease contracts identified in this finding have been obtained. Management believes that the electronic file retention process currently in place is working well and this was isolated to the period of time when files were being organized and scanned from physical files to electronic files. Proposed Completion Date: Completed

View Audit 320643

Finding 497965 (2023-002)

Material Weakness 2023

Housing Authority of the City of New Britain

CT

HUD Housing Programs Material Weakness Special Tests & Provisions

HQS Enforcement Description of Findging: Reinspection, follow up and/or abatement documentation was missing for 5 out of 25 initial failed inspections. Statement of Concurrence or NonConcurrence: Procedures were not in place to properly document the corrections of deficiencies and abate the housin...

HQS Enforcement Description of Findging: Reinspection, follow up and/or abatement documentation was missing for 5 out of 25 initial failed inspections. Statement of Concurrence or NonConcurrence: Procedures were not in place to properly document the corrections of deficiencies and abate the housing assistance payments when necessary. EFFECT The Authority may have made housing assistance payments to landlords for units that failed to meet housing quality standards. Corrective Action: Interviews are underway to hire an internal inspector which will allow for better follow through and communication as opposed to a contracted inspector. The HCV Director will monitor inspections completed for proper disposition and also run reports on units due in the upcoming month to make sure they are executed and updated in Pha Web. Procedures be strengthened to ensure that documentation is maintained for all inspections and enforcements. Maribel Aguliar

View Audit 320625

Finding 497954 (2023-001)

Significant Deficiency 2023

Housing Authority of Monroe County

PA

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority has updated the practice to follow the HUD compliance supplement. Linda Kaufman, Executive Director, is responsible for implementing this corrective action by Decembe...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority has updated the practice to follow the HUD compliance supplement. Linda Kaufman, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 320577

Finding 497921 (2023-001)

Material Weakness 2023

Housing Authority of the City of Easton

PA

Questioned Costs HUD Housing Programs Special Tests & Provisions

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 Program to ensure that established internal control policies are being followed on a timely basis. Tyler Martin, ...

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 Program to ensure that established internal control policies are being followed on a timely basis. Tyler Martin, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 320526 Questioned Costs: $1

Finding 497920 (2023-004)

Significant Deficiency 2023

New Brighton Borough

PA

Internal Control / Segregation of Duties HUD Housing Programs

Recommendation: Ideally, the Borough would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because th...

Recommendation: Ideally, the Borough would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the Borough’s financial position. Management’s Response: The Borough recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Assistant Borough Manager has to take an active role in the day-to-day operations of the Business Unit. She actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, Borough Council approves all disbursements.

View Audit 320523

Finding 497910 (2023-001)

Significant Deficiency 2023

St John's Health Care Corporation

NY

HUD Housing Programs Matching / Level of Effort / Earmarking

CORRECTIVE ACTION PLAN August 29, 2024 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 171...

CORRECTIVE ACTION PLAN August 29, 2024 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully’s Trail Pittsford, NY 14534 Audit Period: January 1, 2023 – December 31, 2023 The findings from the December 31, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARD PROGRAMS AUDIT FINDING 2023-001: Section 232, CFDA 14.129 Recommendation: Adhere to the HUD regulatory agreement in relation to obtaining prior written approval from HUD before encumbering the Project. Action Taken: The Home obtained the related-party loan as a prudent business decision to meet operating expenses. The Home has implemented procedures to ensure that prior written approval is obtained from HUD before encumbering the Project in the future. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Robert Earl at (585)-760-1473. Sincerely yours, Robert Earl Chief Financial Officer

View Audit 320493

Finding 497906 (2023-003)

Material Weakness 2023

Howard County Housing Commission

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Enforcement Recommendation: We recommend the Commission review their abatement procedures to ensure that any unit that has not met the HQS standards that HAP is properly abated as well as review their procedures for enforcing correction of de...

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Enforcement Recommendation: We recommend the Commission review their abatement procedures to ensure that any unit that has not met the HQS standards that HAP is properly abated as well as review their procedures for enforcing correction of deficiencies to tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The following actions are currently taking place to ensure abatement procedures are met when required due to failed inspections: • Hired a new Inspection company. • The HCHC will ensure that its third-party HQS inspectors provide data on all fails that require abatement as part of the weekly report. • The assigned HCV Specialist will notify the landlord and tenant of the failed inspection and the specific deficiencies that must be corrected. • The assigned HCV Specialist will notify the tenant and landlord of potential termination for not complying with inspection requirements as a result of two consecutive no shows. • The assigned HCV Specialist will ensure that the third-party inspection company re-inspects in a timely manner to verify that the repairs have been completed and meet HQS standards. • If the landlord fails to make the repairs by the established deadline, the HCHC will initiate abatement procedures by withholding or reducing housing assistance payments (HAP) once the unit passes inspection. • The assigned HCVP Specialist will provide the tenant with information and assistance to find alternative housing, such as issuing a new voucher, extending the search time, or offering relocation expenses. • The HCHC will terminate the HAP contract with the landlord if the unit remains abated for more than 60 days or if the landlord fails to comply. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: The new inspection protocols were put into place as of July 1, 2024. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Crystal Gorham at 443-518-7818.

View Audit 320485

Finding 497905 (2023-002)

Material Weakness 2023

Howard County Housing Commission

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Annual HQS Inspections Recommendation: We recommend the Commission review its HQS inspection policies and procedures and discuss these standards with the third-party inspection company that is utilized for these inspections to ensure all inspecti...

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Annual HQS Inspections Recommendation: We recommend the Commission review its HQS inspection policies and procedures and discuss these standards with the third-party inspection company that is utilized for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC employs a third-party inspection company. Many of the issues caused by the previous inspection company did not surface until early in 2023. HCHC then attempted to work with the inspection company, however, ultimately that company was not able to comply with inspection requirements and HCHC ended the contract as of June 30, 2024. A contract with a new third-party inspection firm became effective on July 1, 2024. To ensure the HQS inspections are done on time, HCHC now also: • Meets weekly with the third-party contractor. • Receives and reviews weekly reports of inspection status and results. • Ensures that the third-party inspector utilizes real-time data tools to communicate with the HCHC Yardi Software. Yardi has a mobile inspection app that the third-party inspector will begin using. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: The new inspection protocols were put into place as of July 1, 2024.

View Audit 320485

Finding 497904 (2023-001)

Significant Deficiency 2023

Howard County Housing Commission

MD

HUD Housing Programs Eligibility Significant Deficiency

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Eligibility Recommendation: We recommend that the Commission review its process for collecting third party income support to ensure the accurate data is used as part of the tenant rent and HAP calculations. Explanation of disagreement with audit...

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Eligibility Recommendation: We recommend that the Commission review its process for collecting third party income support to ensure the accurate data is used as part of the tenant rent and HAP calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrected data is essential in determining the correct rent responsibility and HAP. To ensure that the data and rent calculations are correct, HCHC has taken the following steps: • Staff members have taken additional Housing Specialist training offered by Nan McKay. • HCHC has created and hired a quality control specialist who selects housing specialist 50058 actions to ensure that HCHC has data integrity, and all information is true and accurate. • The supervisor also selects housing specialist 50058 actions for review, ensuring that all required documentation is intact and that the proper rent responsibility and HAP calculations are correct. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Completion date for corrective action plan: 6/30/2024

View Audit 320485

Finding 497899 (2023-002)

Significant Deficiency 2023

Sawyer County Housing Authority

WI

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency

Recommendation: We recommend, the entity develop a method to track actual time spent on various programs to time allocated to federal award programs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Auth...

Recommendation: We recommend, the entity develop a method to track actual time spent on various programs to time allocated to federal award programs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Authority will work on developing proper time and effort documentation. Name of the contact person responsible for corrective action: Sheila Young Planned completion date for corrective action plan: December 31, 2024

View Audit 320468

Finding 497898 (2023-001)

Significant Deficiency 2023

Sawyer County Housing Authority

WI

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that Authority implement procedures to verify reinspections done within 30 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Authority will review processes to make sure...

Recommendation: We recommend that Authority implement procedures to verify reinspections done within 30 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Authority will review processes to make sure all reinspections are done within the required time. Name of the contact person responsible for corrective action: Sheila Young Planned completion date for corrective action plan: December 31, 2024

View Audit 320468

Finding 497897 (2023-001)

Significant Deficiency 2023

Hamlet Housing Authority

NC

Eligibility HUD Housing Programs Reporting

Hamlet Housing Authority Corrective Action Plan For the Year Ended December 31, 2023 Section II - Financial Statement Findings None Reported. Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Gary Jones Executive Director Corrective Action: Man...

Hamlet Housing Authority Corrective Action Plan For the Year Ended December 31, 2023 Section II - Financial Statement Findings None Reported. Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Gary Jones Executive Director Corrective Action: Management will review the recertification process and plan to monitor recertifications. Proposed Completion Date: Immediately

View Audit 320466

Finding 497640 (2023-002)

Material Weakness 2023

Silver Lake Regional School District

MA

Subrecipient Monitoring Internal Control / Segregation of Duties HUD Housing Programs

I concur with the auditor’s findings. The District is reviewing current staffing of the Business Office. The District Leadership team has requested additional staffing, potentially in the roles of Grants Management, additional Accounting staff, and additional Treasurer staff. These positions were no...

I concur with the auditor’s findings. The District is reviewing current staffing of the Business Office. The District Leadership team has requested additional staffing, potentially in the roles of Grants Management, additional Accounting staff, and additional Treasurer staff. These positions were not provided for in FY25 due to a challenging budget cycle. It is understood that these additional staff will assist in addressing the issues of: Reliability of District’s financial reporting; Effectiveness and efficiency of its operations; Compliance with applicable laws and regulations. In addition, Business Office policies and procedures will be documented and staff will receive professional development to ensure their understanding. The School Committee has been made aware that lack of additional staff has hampered progress on this.

View Audit 320436

Finding 497621 (2023-001)

Significant Deficiency 2023

Bladenboro Housing Authority

NC

HUD Housing Programs Eligibility Reporting

Corrective Action Plan For the year ended December 31, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Becky Tatum Interim Director Corrective Action: Mangagement will implement pr...

Corrective Action Plan For the year ended December 31, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Becky Tatum Interim Director Corrective Action: Mangagement will implement proper internal control procedures for the Housing Choice Voucher Program eligibility requirements. Proposed Completion Date: Immediately

View Audit 320414

Finding 497620 (2023-001)

Significant Deficiency 2023

South Carolina Regional Housing Authority No. 1

SC

HUD Housing Programs Eligibility Significant Deficiency

Finding No. 2023-001 Eligibility: Public Housing Tenant Files Public and Indian Housing Program – CFDA Number 14.850 Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Condition: Out of a total tenant population of 1,275, 25 files were sel...

Finding No. 2023-001 Eligibility: Public Housing Tenant Files Public and Indian Housing Program – CFDA Number 14.850 Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Condition: Out of a total tenant population of 1,275, 25 files were selected for testing. Exceptions were noted as follows: • 3 out of 25 tenants where an outdated flat rent was used instead of the current amount. • 1 tenant where wage income was calculated as paid bi-weekly when it was actually paid semi-monthly. • 2 tenants where the prior year social security income was used when the current year amount was known. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff. The cited files have been corrected. Effective Date: September 19, 2024 Contact Information Brian Griswell, Executive Director SC Regional Housing Authority No.1 218 Spring Street Laurens, SC 29360 (864) 984-6568

View Audit 320403

Finding 497576 (2023-001)

Material Weakness 2023

Village of Blanchardville

WI

Internal Control / Segregation of Duties HUD Housing Programs

Finding #2023-001- Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional error...

Finding #2023-001- Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. 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. Cause: Limited number of personnel. 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. Recommendation: We recommend that the Village 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 the finding but do not believe it is cost-effective to increase the office staff in an attempt to bring about a more effective segregation of duties. Contact Person: Amy Barnes, Village Clerk/Treasurer, 608-523-4521, Email: clerk@blanchardvillewi.gov Anticipated Completion: Not Applicable

View Audit 320340

Finding 497547 (2023-003)

Significant Deficiency 2023

Canaan Manor Detroit

LA

HUD Housing Programs Reporting

We will ensure that going forward, processes are in place to allow for the timely submission of the financial reporting requirements. Further, we request that this finding be removed as the late filing occurred in 2024 and should be given in 2024 pursuant to AU-C 935.

View Audit 320277

Finding 497546 (2023-002)

Significant Deficiency 2023

Canaan Manor Detroit

LA

HUD Housing Programs

Pursuant to HUD Notice H-2012-14, the Owner/Agent is responsible for depositing Residual Receipts into the designated Residual Receipts account. Withdrawals from this account will be made only with the approval of HUD and for project purposes, including the reduction of housing assistance payments. ...

Pursuant to HUD Notice H-2012-14, the Owner/Agent is responsible for depositing Residual Receipts into the designated Residual Receipts account. Withdrawals from this account will be made only with the approval of HUD and for project purposes, including the reduction of housing assistance payments. Further guidance reflects that Project Based Section 8 Contracts will remit Residual Receipts through the offset process at HUD’s written direction. We have complied with the requirement to deposit Residual Receipts into the designated account, and we did not receive notice from HUD to submit to the offset of the assistance payments to recover the Residual Receipts. Upon receipt of HUD’s notice, we will comply with the offset process. We continue to work on preparing to submit HUD form 91186 for “Multifamily Housing Service Coordinator-First Time Funding Request” to request the approval for a Part-time Service Coordinator at the property. If approved, this will provide services to our frail and at-risk residents. To accomplish this, we will be requesting approval from HUD to use Residual Receipts to begin the program.

View Audit 320277

Finding 497544 (2023-005)

Significant Deficiency 2023

Rj Gordon

LA

HUD Housing Programs Reporting

We will ensure that going forward, processes are in place to allow for the timely submission of the financial reporting requirements. Further, we request that this finding be removed as the late filing occurred in 2024 and should be given in 2024 pursuant to AU-C 935.

View Audit 320276

Finding 497543 (2023-004)

Significant Deficiency 2023

Rj Gordon

LA

HUD Housing Programs

In October 2023, management was notified by the banking institution of fraudulent activities that had taken place with some of the Reserve for Replacement accounts held at their institution. The banking institution closed all accounts and restricted all routine depository activity. When the new acco...

In October 2023, management was notified by the banking institution of fraudulent activities that had taken place with some of the Reserve for Replacement accounts held at their institution. The banking institution closed all accounts and restricted all routine depository activity. When the new accounts were established, all required deposits for 2023, including the adjustment for the increase in the monthly deposit amount, were made.

View Audit 320276

Finding 497539 (2023-002)

Significant Deficiency 2023

Enon Plaza

LA

HUD Housing Programs Reporting

We will ensure that going forward, processes are in place to allow for the timely submission of the financial reporting requirements. Further, we request that this finding be removed as the late filing occurred in 2024 and should be given in 2024 pursuant to AU-C 935.

View Audit 320275

Finding 497537 (2023-003)

Significant Deficiency 2023

Canaan Manor Dayton

LA

HUD Housing Programs Reporting

We will ensure that going forward, processes are in place to allow for the timely submission of the financial reporting requirements. Further, we request that this finding be removed as the late filing occurred in 2024 and should be given in 2024 pursuant to AU-C 935.

View Audit 320274

Finding 497536 (2023-002)

Significant Deficiency 2023

Canaan Manor Dayton

LA

HUD Housing Programs

The required annual deposit was made into the property’s reserve for replacement account. However, in October 2023, management was notified by the banking institution of fraudulent activities that had taken place with some of the Reserve for Replacement accounts held at their institution. The bankin...

The required annual deposit was made into the property’s reserve for replacement account. However, in October 2023, management was notified by the banking institution of fraudulent activities that had taken place with some of the Reserve for Replacement accounts held at their institution. The banking institution closed all accounts and restricted all routine depository activity. The banking institution established new accounts in January 2024 at which time management could resume making deposits. Management’s records reflect that 12 checks were drafted and in 2023.

View Audit 320274

Finding 497535 (2023-001)

Significant Deficiency 2023

Canaan Manor Dayton

LA

HUD Housing Programs Cash Management

Residual Receipts in the amount of $12,257 was not incurred in the fiscal year of 2023. This surplus cash was incurred in prior years. Excess residual receipts have not been remitted for two reasons 1) funds are needed for improvements which we are pursuing to 3 bids for as required and 2) HUD has n...

Residual Receipts in the amount of $12,257 was not incurred in the fiscal year of 2023. This surplus cash was incurred in prior years. Excess residual receipts have not been remitted for two reasons 1) funds are needed for improvements which we are pursuing to 3 bids for as required and 2) HUD has not notified management of the method to remit.

View Audit 320274

Corrective Action Plans

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