Corrective Action Plans

Finding 1160296 (2024-002)

Material Weakness 2024

DC

HUD Housing Programs

Recommendation The Board and management should hire an accountant with HUD experience to help correct the books and records in order to comply with HUD regulations and to conform with generally accepted accounting principles. Management/Owner Response The Board agrees with the findings is taking act...

Recommendation The Board and management should hire an accountant with HUD experience to help correct the books and records in order to comply with HUD regulations and to conform with generally accepted accounting principles. Management/Owner Response The Board agrees with the findings is taking action to correct the findings and implement the recommendations.

View Audit 370685

Finding 1160295 (2024-001)

Material Weakness 2024

Asbury Dwellings, Inc.

DC

HUD Housing Programs

Recommendation Management must perform the corrective actions as required by the MOR by the target completion date. Management/Owner Response The Board agrees with the findings is taking action to correct the findings and implement the recommendations.

View Audit 370685

Finding 1160276 (2024-002)

Material Weakness 2024

Housing Authority of the County of Chester

PA

HUD Housing Programs Special Tests & Provisions Eligibility

Action Taken: Housing Authority of the County of Chester agrees with the above recommendations and has already instituted policies and procedures designed to address the findings. Please see the list of procedures. HACC Recertification & Documentation Checklist (Quick Reference – 1 Page) 1. Recertif...

Action Taken: Housing Authority of the County of Chester agrees with the above recommendations and has already instituted policies and procedures designed to address the findings. Please see the list of procedures. HACC Recertification & Documentation Checklist (Quick Reference – 1 Page) 1. Recertification Timeline • Annual: Start process 120 days before due date. • Interim: Complete within 30 days of household change. • Missed/Delayed: Notify Program Manager immediately and document reason. 2. Required Documentation • Income verification (pay stubs, benefits, child support). • Asset verification (bank/retirement statements). • Family composition docs (birth certificates, SSNs). • HUD-required forms. • Use EIV when available; seek third-party verification first. • All docs must be collected within 60 days of effective date. 3. File Standards • Use Resident File Checklist for each household. • Files must include all signed forms & verifications. • Store in approved secure system (electronic or paper). • Retain files 3 years after end of participation (longer if litigation/audit pending). 4. Internal Controls • Supervisory Review: 10% of files checked monthly. • Maintain clear audit trail (date notices, interviews, verifications). • Correct any deficiencies within 30 days. 5. Staff & Training • Staff handling certifications = annual HUD/HACC compliance training. • Document training completion in personnel file. 6. Monitoring • Quarterly compliance report on timeliness & file completeness. • Issues shared with Executive Director and Board. • Policies reviewed annually for updates. Roles • Housing Specialists: Complete recerts & file docs. • Supervisors: Monitor timeliness & review files. • Compliance Officer: Audit & reporting. • Executive Director: Oversight & resources. n Follow this checklist to ensure timely recertifications, complete documentation, and avoid audit findings.

View Audit 370665

Finding 1160273 (2024-001)

Material Weakness 2024

Housing Authority of the County of Chester

PA

HUD Housing Programs

Action Taken: Housing Authority of the County of Chester agrees with the above recommendations and has already instituted policies and procedures designed to address the findings. Please see the list of procedures. HACC Recertification & Documentation Checklist (Quick Reference – 1 Page) 1. Recertif...

Action Taken: Housing Authority of the County of Chester agrees with the above recommendations and has already instituted policies and procedures designed to address the findings. Please see the list of procedures. HACC Recertification & Documentation Checklist (Quick Reference – 1 Page) 1. Recertification Timeline • Annual: Start process 120 days before due date. • Interim: Complete within 30 days of household change. • Missed/Delayed: Notify Program Manager immediately and document reason. 2. Required Documentation • Income verification (pay stubs, benefits, child support). • Asset verification (bank/retirement statements). • Family composition docs (birth certificates, SSNs). • HUD-required forms. • Use EIV when available; seek third-party verification first. • All docs must be collected within 60 days of effective date. 3. File Standards • Use Resident File Checklist for each household. • Files must include all signed forms & verifications. • Store in approved secure system (electronic or paper). • Retain files 3 years after end of participation (longer if litigation/audit pending). 4. Internal Controls • Supervisory Review: 10% of files checked monthly. • Maintain clear audit trail (date notices, interviews, verifications). • Correct any deficiencies within 30 days. 5. Staff & Training • Staff handling certifications = annual HUD/HACC compliance training. • Document training completion in personnel file. 6. Monitoring • Quarterly compliance report on timeliness & file completeness. • Issues shared with Executive Director and Board. • Policies reviewed annually for updates. Roles • Housing Specialists: Complete recerts & file docs. • Supervisors: Monitor timeliness & review files. • Compliance Officer: Audit & reporting. • Executive Director: Oversight & resources. n Follow this checklist to ensure timely recertifications, complete documentation, and avoid audit findings.

View Audit 370665

Finding 1160194 (2024-001)

Material Weakness 2024

N L Resort, INC

VI

Special Tests & Provisions HUD Housing Programs

The funds were subsequently returned to the account.

View Audit 370562

Finding 1160123 (2024-002)

Material Weakness 2024

Tuscan Brotherhood Homes Ii, Inc.

CT

Questioned Costs HUD Housing Programs

Major Federal Award Programs Audit:Mortgage Insurance Rental Housing, Federal Assistance Listing Number 14.134 Comments on the Finding and Recommendation During lhe year ended December 31, 2024, the p-oject paid payroll expenses in the amount of $4,342: on behalf of an affiliate from project cash wi...

Major Federal Award Programs Audit:Mortgage Insurance Rental Housing, Federal Assistance Listing Number 14.134 Comments on the Finding and Recommendation During lhe year ended December 31, 2024, the p-oject paid payroll expenses in the amount of $4,342: on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of December 31, 2024 is $4,342. Action(s) Taken or Planned on the Finding The amount of $4,342 was located and the affiliate property has returned the amount paid in error lo Tuscan as of February 28, 2025. Plans were put in to place to have the approval process go through a two-step verification process.

View Audit 370521 Questioned Costs: $1

Finding 1160122 (2024-001)

Material Weakness 2024

Tuscan Brotherhood Homes Ii, Inc.

CT

HUD Housing Programs Eligibility

Major Federal Award Programs Audit: Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Nunber 14.182 a. Comments on the Finding and Recommendation We concur with the auditors finding as follows: In connection with out lease file review, we noted the following defic...

Major Federal Award Programs Audit: Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Nunber 14.182 a. Comments on the Finding and Recommendation We concur with the auditors finding as follows: In connection with out lease file review, we noted the following deficiencies: 3 out of 16 existing tenants tested did not have the Enterprise Income Verification (EIV) form completed within 120 days, as required by HUD. 1 out out of 16 existing tenants tested income reported on HUD Form 50059 did not agree to income verified using the Enterprise lncome Verification (EIV). 10 out of 16 existing tenants tested did not have the annual recertifications done timely. 1 out of 2 former tenants tested did not have security deposit returned within 30 days of departure, as required by HUD.- b. Action(s) Taken or Planned on the Finding At the time of tenant file review, the current staff was not made aware of EIV documents stored in a separate area in the office. This since has been corrected and the EIV information is now in the tenant files. Management was aware due to staffing issues of the annual recertifications being behind. We have resolved the staffing issues and have a Compliance Manager that monitors this now whom help the site with any questions to bring all tenants up to date. With staffing issues being updated we are working with them to make sure to process security deposit refunds in a tinely matter.

View Audit 370521

Finding 1160121 (2024-003)

Material Weakness 2024

Shiloh Manor, Inc.

CT

Special Tests & Provisions HUD Housing Programs Reporting

Major Federal Award Programs Audit Comments on the Finding and Recommendation During the year ended December 31, 2024, the project did not make the required monthly deposits to the replacement reserve in the amount of $66,000 as $5,500 was not made timely. The project is required to make timely mont...

Major Federal Award Programs Audit Comments on the Finding and Recommendation During the year ended December 31, 2024, the project did not make the required monthly deposits to the replacement reserve in the amount of $66,000 as $5,500 was not made timely. The project is required to make timely monthly deposits to the reserve in the amount of $5,500 per month. Action(s) Taken or Planned on the Finding As of December 31, 2024 the reserve funding amount owed for 2024 in the amount of $5,500. This was deposited to the reserve account on February 9, 2025.

View Audit 370520

Finding 1160120 (2024-002)

Material Weakness 2024

Shiloh Manor, Inc.

CT

HUD Housing Programs Matching / Level of Effort / Earmarking

Major Federal Award Programs Audit Comments on the Finding and Recommendation During the year ended December 31, 2023, the project paid payroll xpenses in the amount of $76 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of December 31, 2024 is $76....

Major Federal Award Programs Audit Comments on the Finding and Recommendation During the year ended December 31, 2023, the project paid payroll xpenses in the amount of $76 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of December 31, 2024 is $76. Action(s) Taken or Planned on the Finding As of December 31, 2024 the $76 of payroll expenses was not reimbursed from the affiliate project account. This has been processed in the current year on September 5,2025.

View Audit 370520

Finding 1160119 (2024-001)

Material Weakness 2024

Shiloh Manor, Inc.

CT

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

Major Federal Award Programs Audit Comments on the Finding and Recommendation We concur with the auditors finding as follows: On December 31, 2017, HUD had approved a loan to operations from the reserve for replacement of $40,239 to be repaid upon receipt of the past due subsidy. When the past due s...

Major Federal Award Programs Audit Comments on the Finding and Recommendation We concur with the auditors finding as follows: On December 31, 2017, HUD had approved a loan to operations from the reserve for replacement of $40,239 to be repaid upon receipt of the past due subsidy. When the past due subsidy was received, the property was unable to repay the loan because of an unexpected increase in vacancies as a result of tenant turnover. As of December 31, 2024, management had not repaid $40,239 due to reserve for replacement Action(s) Taken or Planned on the Finding As of December 31, 2024, management has not repaid $40,239 due to reserve for replacement. Additionally, no deposits were made into the reserve for replacement. The owner and agent met with HUD on September 15, 2022 to discuss the loan repayment. It was determined that the loan payment would be deferred and absorbed into the budget-based increase submitted lo HUD and currently in review. This would cover the loan repayment that has been impossible to repay because the property has not operated efficiently since the Residual Receipt swipe of $241,000 in 2017. The finding is repeated as Finding No. 2024-001

View Audit 370520

Finding 1159861 (2024-007)

Material Weakness 2024

Opportunities Credit Union

VT

Allowable Costs / Cost Principles HUD Housing Programs Internal Control / Segregation of Duties

Management acknowledges the oversight and agrees with the recommendation. At the time of the finding, the Credit Union had not established written policies and procedures specific to the administration of the CDFI ERP program, which was required under the grant agreement. However, this finding relat...

Management acknowledges the oversight and agrees with the recommendation. At the time of the finding, the Credit Union had not established written policies and procedures specific to the administration of the CDFI ERP program, which was required under the grant agreement. However, this finding relates to the pre-merger entity’s administration of the CDFI ERP program. Since the merger, the current Credit Union is no longer a member of the CDFI Fund and therefore does not participate in federal programs subject to these requirements. Accordingly, the development of written policies and procedures related to federal grant administration is no longer applicable. To address the finding: • The issue has been documented as part of merger due diligence. • Management has confirmed that no further actions are required, as the current Credit Union does not administer CDFI or federal grant programs. CU1 will prepare adequate policies and procedures if it becomes applicable in the future. Expected Completion Date – Completed Responsible Parties – Wendy Gorevan, CFO (FAFCU pre-merger) and Scott McDonald, CFO (post-merger)

View Audit 370401

Finding 1159698 (2024-003)

Material Weakness 2024

County of Luzerne, Pennsylvania

PA

Reporting HUD Housing Programs Significant Deficiency § 200.303

U.S. Department of Housing and Urban Development 2024-003 Community Development Block Grants – Assistance Listing No. 14.218 Recommendation: We recommend that management identify its collections related to program income in a timely manner, modify its draw request appropriately, and report the accur...

U.S. Department of Housing and Urban Development 2024-003 Community Development Block Grants – Assistance Listing No. 14.218 Recommendation: We recommend that management identify its collections related to program income in a timely manner, modify its draw request appropriately, and report the accurate amounts to HUD. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The county will continue to report the correct amount of program income to HUD. Receipts will be entered more timely to include as much December program income in the IDIS system prior to that system’s 12/31 close, as any entries made after 12/31 are considered for the future year. Name of the contact person(s) responsible for corrective action: Director of Community Development Planned completion date for corrective action plan: 12/31/25

View Audit 370288

Finding 1159686 (2024-002)

Material Weakness 2024

Restart Housing Services, Inc.

MO

HUD Housing Programs

Management concurs with the findings and is working to ensure all employees adhere to control procedures and compliance requirements set by HUD. For finding 2024-002, the Organization has transferred the funds into an interest-bearing account.

View Audit 370278

Finding 1159586 (2024-001)

Material Weakness 2024

607 Concord Avenue Hdfc

NY

HUD Housing Programs

September 25, 2025 Person responsible: Steve Kadin, Executive Vice President Fiscal Year Ended November 30, 2024 Section III – Federal Awards Findings and Questioned Costs Item 2024 – 001 Federal Assistance Listing Number: 14.181 Supportive Housing for Persons with Disabilities Condition Surplus cas...

September 25, 2025 Person responsible: Steve Kadin, Executive Vice President Fiscal Year Ended November 30, 2024 Section III – Federal Awards Findings and Questioned Costs Item 2024 – 001 Federal Assistance Listing Number: 14.181 Supportive Housing for Persons with Disabilities Condition Surplus cash was not deposited into the residual receipts account within 60 days following the end of the fiscal year. Views of Responsible Officials and Corrective Action The Project was planning on the capital improvements in the fiscal year 2024, but it did not happen as planned. Management will deposit the excess cash to the residual receipts account and obtain HUD approval for the future fund release for capital projects. Management will ensure that the residual receipts account is properly funded in the future.

View Audit 370244

Finding 1159583 (2024-001)

Material Weakness 2024

Loretto Rest Realty Corporation

NY

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs

Management has implemented procedures internally to track HUD filing deadlines and monitor and submit the REAC FDS timely. Management has ensured multiple individuals within the organization have appropriate access to HUD systems to ensure appropriate coverage is available as needed in the future.

View Audit 370224

Finding 1159439 (2024-001)

Material Weakness 2024

Montefiore Health System, Inc.

NY

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

Finding Reference Number: 2024-001 Identification of the Federal Program: Grantor: United States Department of Health and Human Services Program Name: Health Centers Cluster Assistance Listing No.: 93.224, 93.527 Name of responsible official: James Geraghty Associate Vice President, Faculty Practice...

Finding Reference Number: 2024-001 Identification of the Federal Program: Grantor: United States Department of Health and Human Services Program Name: Health Centers Cluster Assistance Listing No.: 93.224, 93.527 Name of responsible official: James Geraghty Associate Vice President, Faculty Practice Group Phone: (718) 430-3255 Email: james.geraghty@einsteinmed.edu Projected completion date: October 1, 2025 Condition In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The Health System was unable to demonstrate that internal controls were operating effectively to ensure proper application of the Health System’s policy relating to the sliding fee discount schedule (SFDS). Specifically, documentation supporting the application of the SFDS was not obtained within a year of the visit in line with the Health System’s policy. Views of responsible officials and planned corrective actions Management concurred with the audit finding and implemented standardized procedures to enhance screening and enrollment of patients. Additional controls are in place to ensure timely documentation of income and family size. In order to ensure compliance with the SFDS policy including documentation and retention, a policy was adopted requiring reviews on the day before visit, during visit and day after visit, as well as periodic retrospective reviews. There will be regular staff training on eligibility, determination and documentation requirements.

View Audit 370177

Finding 1159418 (2024-001)

Material Weakness 2024

Fort Lee Housing Authority

NJ

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Views of Responsible Officials and Planned Corrective Action: The Authority contracted with an Agency which performed all rent reasonableness calculations, however, a copy of the calculations could not be located at the time of audit. The Authority has implemented a process whereby all completed ren...

Views of Responsible Officials and Planned Corrective Action: The Authority contracted with an Agency which performed all rent reasonableness calculations, however, a copy of the calculations could not be located at the time of audit. The Authority has implemented a process whereby all completed rent reasonableness calculations will be stored in the related tenant file. Terrence Corriston, Executive Director, is responsible for implementing this corrective action by December 31, 2025.

View Audit 370143

Finding 1158224 (2024-001)

Material Weakness 2024

Housing Authority of the City of Yakima

WA

HUD Housing Programs Reporting Internal Control / Segregation of Duties § 200.512

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Authority has reviewed and updated its financial reporting and closing processes and controls he preparation of the final trial balances and related schedules...

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Authority has reviewed and updated its financial reporting and closing processes and controls he preparation of the final trial balances and related schedules. As part of this process, we will create a year-end checklist with deadlines established and set up status meetings to monitor the progress. Name(s) of the contact person(s) responsible for corrective action: Lowel Kruger, Executive Director. Planned completion date for corrective action plan: December 31, 2024

View Audit 370115

Finding 1158131 (2024-001)

Material Weakness 2024

County of Essex

NJ

Cash Management HUD Housing Programs

Finding SA-2024-01:

View Audit 370058

Finding 1158131 (2024-001)

Material Weakness 2024

County of Essex

NJ

Cash Management HUD Housing Programs

Condition:

View Audit 370058

Finding 1158131 (2024-001)

Material Weakness 2024

County of Essex

NJ

Cash Management HUD Housing Programs

Our review of the cash management compliance regulations developed the following fiknding:

View Audit 370058

Finding 1158131 (2024-001)

Material Weakness 2024

County of Essex

NJ

Cash Management HUD Housing Programs

*In a sample of seventeen (17) transactions, one (1) instane was noted where the requested drawdown amount exceeded the actual expenditure paid by the County.

View Audit 370058

Finding 1158131 (2024-001)

Material Weakness 2024

County of Essex

NJ

Cash Management HUD Housing Programs

*In a sample of seventeen (17) transactions, we noted one (1) instance in which the drawdown was not submitted on a timely basis following the incurrence of eligible expenditures.

View Audit 370058

Finding 1158131 (2024-001)

Material Weakness 2024

County of Essex

NJ

Cash Management HUD Housing Programs

*In a sample of seventeen (17) transactions, we noted one (1) instance in which the program funds were drawn in advance of making actual payments of eligible expenditues.

View Audit 370058

Finding 1158131 (2024-001)

Material Weakness 2024

County of Essex

NJ

Cash Management HUD Housing Programs

*In a sample of seventeen (17) transactions, we noted one (1) instance in which amounts approved and expended related to eligible project activities that were not drawn from the IDIS system.

View Audit 370058

Corrective Action Plans

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