Corrective Action Plans

Finding 388512 (2023-003)

Significant Deficiency 2023

IL

Allowable Costs / Cost Principles HUD Housing Programs Reporting

Finding 2023-003: Overpayments to Landlords (Significant Deficiency) Corrective Action Plan: DHA Management has worked with our financial institution to ensure that the positive pay function is working and duplicate payments will not be posted to Landlord accounts. Name of Responsible Person: Cheron...

Finding 2023-003: Overpayments to Landlords (Significant Deficiency) Corrective Action Plan: DHA Management has worked with our financial institution to ensure that the positive pay function is working and duplicate payments will not be posted to Landlord accounts. Name of Responsible Person: Cheron Corbett Completion Date: July 31, 2023

View Audit 300217

Finding 388511 (2023-002)

Significant Deficiency 2023

Dupage Housing Authority

IL

HUD Housing Programs Internal Control / Segregation of Duties Reporting

Finding 2023-002: Late Submission of Unaudited Data to REAC (Significant Deficiency) Corrective Action Plan: Due to the abrupt quitting of our previous Comptroller cause a delay in the submission of our unaudited financials. DHA has hired a new Comptroller and we have monthly meetings to ensure that...

Finding 2023-002: Late Submission of Unaudited Data to REAC (Significant Deficiency) Corrective Action Plan: Due to the abrupt quitting of our previous Comptroller cause a delay in the submission of our unaudited financials. DHA has hired a new Comptroller and we have monthly meetings to ensure that all accounting data is being recorded timely. This will allow us to submit timely financials to HUD. . Name of Responsible Person: Cheron Corbett, Executive Director Projected Completion Date: December 31, 2024

View Audit 300217

Finding 388425 (2023-001)

Material Weakness 2023

Christus Health

TX

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding 2023-001 Federal Program Information Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: ...

Finding 2023-001 Federal Program Information Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: July 1, 2020 to June 30, 2023 Corrective Action Planned: Management agrees that certain expenses to the COVID department were not reviewed and approved at the order entry level in specific cases. Although evidence of review was not retained for every charge to the COVID department, we believe the appropriateness of the charge was reasonable. Additionally, based on monthly review of departmental expenses and full-time equivalent (FTE) analysis at the facility level, we believe that these expenditures are subject to the appropriate level of review to identify unexpected variances. As it relates to the COVID Activity Code, this code was created as a means to track certain COVID hours worked, but was not configured to calculate the amounts associated with those hours, resulting in the need to make reasonable estimates. Even using the base pay rate at the time the hours were incurred would not have been accurate since it would omit adjustments for shift differentials, weekend hours, and overtime. We performed internal analyses and reviewed the results of samples selected by the auditors and concluded that the risk of a material overcharge to the program was minimal. Further, we have almost $40 million of unused lost revenues after our final PRF submission for Period 5, such that any questioned costs would easily be covered by other eligible uses of PRF funds. We have reviewed our processes related to the retention of expense documentation to improve audit evidence should this program ever be awarded in future periods. Responsible party: Lee Sonne, Vice President of Finance and Controller Implementation Date: Procedures were reviewed and analysis completed along with the Period 5 portal filing in September 2023.

View Audit 300159 Questioned Costs: $1

Finding 388280 (2023-001)

Significant Deficiency 2023

City of Pomona

CA

HUD Housing Programs

The City will commence quality control re-inspections as soon as possible, either by contracting with another public housing agency, or by hiring or contracting with a part-time inspector.

View Audit 300062

Finding 388130 (2023-001)

None 2023

Loretto Apts at O'Brien Road Hdfc, Inc. (o'brien Rd SR Appts 2)

NY

HUD Housing Programs Cash Management

U.S. Department of Housing and Urban Development Loretto Apartments at O’Brien Road Housing Development Fund Company, Inc. (O’Brien Road Senior Apartments 2), HUD Project No. 014-EE287/NY06-S101-004 respectfully submits the following corrective action plan for the year ended December 31, 2023. Nam...

U.S. Department of Housing and Urban Development Loretto Apartments at O’Brien Road Housing Development Fund Company, Inc. (O’Brien Road Senior Apartments 2), HUD Project No. 014-EE287/NY06-S101-004 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 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: January 1, 2023 – December 31, 2023 The findings from the 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2023-001: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 Recommendation: Our auditors recommended that we ensure residual receipts are made within 60 days of year-end in accordance with the HUD Regulatory Agreement. Action Taken: O’Brien Road Senior Apartments 2 made the required payment in August 2023. Name of Contact Person Responsible for Corrective Action: Kyle Lyskawa, CFO, (315) 424-1821. Completion Date: August 2023

View Audit 299948

Finding 388129 (2023-001)

None 2023

Taylor Brown Hdf CO (east Main Street Apartments

NY

HUD Housing Programs

U.S. Department of Housing and Urban Development Taylor Brown Housing Development Fund Company, Inc. (East Main Street Apartments), FHA Project No. 014-11145 respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accou...

U.S. Department of Housing and Urban Development Taylor Brown Housing Development Fund Company, Inc. (East Main Street Apartments), FHA Project No. 014-11145 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 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: January 1, 2023 – December 31, 2023 The findings from the 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2023-001: Mortgage Insurance – Rental Housing (Section 207), federal assistance listing number 14.134 Recommendation: East Main Street Apartments should ensure residual receipts are made within 60 days of year-end in accordance with the HUD Regulatory Agreement. Action Taken: East Main Street Apartments made the required payment was made after the 60-day timeline. Completion Date: March 2024 Name of Contact Person Responsible for Corrective Action: Kyle Lyskawa, CFO (315) 424-1821

View Audit 299944

Finding 388122 (2023-010)

Significant Deficiency 2023

Delaware State Housing Authority

DE

HUD Housing Programs Special Tests & Provisions Significant Deficiency

DSHA will implement controls to monitor and verify required periodic inspections are performed timely by implementing the following controls: 1. All biannual inspections will be performed by the Housing Manager and the Housing Asset Manager (supervisor). 2. Letters will be sent to residents notifyi...

DSHA will implement controls to monitor and verify required periodic inspections are performed timely by implementing the following controls: 1. All biannual inspections will be performed by the Housing Manager and the Housing Asset Manager (supervisor). 2. Letters will be sent to residents notifying them of the date of scheduled inspections. 3. A work order will be generated in the computer for all units indicating the date of the inspection and list all maintenance/housekeeping deficiencies. 4. Housing Managers will use their Outlook calendar as a means of tracking/alerting them of the due date for all future inspections. 5. All documents will be scanned into the resident file on Ap-extender. This will include a copy of the inspection letter and inspection work order. Responsible Official: Doris Hall, Director of Housing Management Completion Date: July 2023

View Audit 299937

Finding 388120 (2023-008)

Significant Deficiency 2023

Delaware State Housing Authority

DE

Questioned Costs Matching / Level of Effort / Earmarking Eligibility

DSHA will ensure accurate calculation of applicant income. This will include implementing standardized procedures for verifying income sources, documenting calculations, and reviewing income determinations for accuracy. Additional training will be available to the processing team responsible for cal...

DSHA will ensure accurate calculation of applicant income. This will include implementing standardized procedures for verifying income sources, documenting calculations, and reviewing income determinations for accuracy. Additional training will be available to the processing team responsible for calculating applicant income. This will focus on proper methods for verifying income, calculating income eligibility, and identifying common errors that may lead to overpayments. The HAF Program Manager will coordinate with the Vendor to ensure accuracy of income calculations and prevent overpayments on assistance received. This corrective plan will be implemented immediately. Responsible Official: Brian Rossello, Director of Housing Finance Completion Date: March 2024

View Audit 299937 Questioned Costs: $1

Finding 388093 (2023-001)

Significant Deficiency 2023

Elizabeth City Housing Authority

NC

Eligibility HUD Housing Programs Reporting

Corrective Action Plan For the year ended june 30,2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Sandra Perry Executive Director Corrective Action: We will implement proper internal c...

Corrective Action Plan For the year ended june 30,2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Sandra Perry Executive Director Corrective Action: We will implement proper internal control procedures for the Low Rent Public Housing eligibility requirements. Proposed Completion Date: Immediately.

View Audit 299931

Finding 387790 (2023-003)

Material Weakness 2023

Housing Authority of the City of Allentown

PA

Questioned Costs HUD Housing Programs Eligibility

Action taken in response to finding: Create a third party verification policy and procedure SOP. Name(s) of the contact person(s) responsible for corrective action: Doryan Campo Planned completion date for corrective action plan: April 2024

View Audit 299848 Questioned Costs: $1

Finding 387788 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Allentown

PA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Action taken in response to finding: Create a reasonable rent management SOP. Name(s) of the contact person(s) responsible for corrective action: Aida Núñez Planned completion date for corrective action plan: April 2024

View Audit 299848

Finding 387786 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of Allentown

PA

HUD Housing Programs Reporting Significant Deficiency

Action taken in response to finding: To avoid future scheduling conflicts and delays, secure vendor several month in advance. Name(s) of the contact person(s) responsible for corrective action: Aida Núñez Planned completion date for corrective action plan: April 2024

View Audit 299848

Finding 387737 (2023-002)

Significant Deficiency 2023

Wyoming Energy Authority

WY

Internal Control / Segregation of Duties HUD Housing Programs Reporting

2023-002: Segregation of Duties (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority will implement controls when feasible. In addition, the Executive Director and the Board of Directors will continue to review ...

2023-002: Segregation of Duties (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority will implement controls when feasible. In addition, the Executive Director and the Board of Directors will continue to review the Accounting Manager’s monthly financials and backup documentation. Another avenue the Authority will explore is to hire an external accounting firm to review all transactions on a quarterly basis. Completion Date - June 2024 Contact Person - Jami Blosmo, Accounting Manager

View Audit 299811

Finding 387721 (2023-002)

Significant Deficiency 2023

Housing Authority of Seymour

TX

Questioned Costs Procurement, Suspension & Debarment HUD Housing Programs

Corrective Action Plan - Online Purchases. Contact Person - Executive Director. Corrective Action Planned - The PHA will ensure that supporting documentation is maintained for all online purhases. Anticipated Completion Date - Within the next fiscal year.

View Audit 299775 Questioned Costs: $1

Finding 387720 (2023-001)

Significant Deficiency 2023

Housing Authority of Seymour

TX

Questioned Costs HUD Housing Programs Significant Deficiency

Corrective Action Plan - Unauthorized ACH Payments. Contact Person - Executive Director. Corrective Action Planned - The PHA will ensure that all ACH payments are adequately documented and approved. Anticipated Completion Date - Within the next fiscal year.

View Audit 299775 Questioned Costs: $1

Finding 387660 (2023-002)

Significant Deficiency 2023

Village of Spring Valley Housing Authority

NY

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

Finding 2023-002 Eligibility Auditee's Response and Planned Corrective Action The Authority has had staff and consultant turnover during the 2022 audit period. Additionally, the eviction moratorium and lasting effects from the COVID-19 pandemic have resulted in delayed or nonexistent response from ...

Finding 2023-002 Eligibility Auditee's Response and Planned Corrective Action The Authority has had staff and consultant turnover during the 2022 audit period. Additionally, the eviction moratorium and lasting effects from the COVID-19 pandemic have resulted in delayed or nonexistent response from tenants regarding obtaining the necessary documentation for eligibility requirements. The Authority has evidentiary documentation supporting their attempts to obtain the required documents from the tenants, including certified letters. The courts suspended evictions during the eviction moratorium that resulted from the COVID-19 pandemic, which includes evictions for nonpayment and noncompliance. The Authority has been working with legal counsel on these matters and continues to pursue this vigorously. The Authority's staff and consultants have been diligently working to implement improvements to the administrative systems related to recertifications. Additionally, the Authority has put in place a checklist for occupancy documents that are reviewed during recertification and when processing new tenants that must have annotations, check mark, that confirm that all required papers are in compliance and signed where appropriate. This check list will have at least one redundant review by the Authority's directors or designee. Planned Implementation Date of Corrective Action: March 2024 Person Responsible for Corrective Action: Keith Burrell, Executive Director

View Audit 299738

Finding 387195 (2023-001)

Significant Deficiency 2023

Idaho Housing and Finance Association

ID

HUD Housing Programs Reporting Significant Deficiency

2023-001 U.S. Department of Housing and Urban Development CFDA # 14.182, 14.195, 2023 Award Year, Award Number: Not Provided Section 8 Project – Based Cluster Compliance Requirement: Reporting Type of Finding: Compliance Finding Summary: As part of the testing for wait list applicants, the auditors ...

2023-001 U.S. Department of Housing and Urban Development CFDA # 14.182, 14.195, 2023 Award Year, Award Number: Not Provided Section 8 Project – Based Cluster Compliance Requirement: Reporting Type of Finding: Compliance Finding Summary: As part of the testing for wait list applicants, the auditors selected a sample of 60 applications. Of the 60, one instance of the required documentation for the applicant was not available by the property manager. Responsible Individuals: Cory Phelps, VP Project Finance Corrective Action Plan: IHFA Compliance staff will send a memo to all owner/agents in the Project Based Section 8 program that wait list applications must be retained. IHFA will further explain that failure to have proper documentation in the maintained will result in a deficiency on the Management and Occupancy Review. Anticipated Completion Date: December 30, 2023

View Audit 299469

Finding 387094 (2023-005)

Material Weakness 2023

Isd # 682 Roseau

MN

School Nutrition Programs Eligibility HUD Housing Programs

CContact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – December 29, 2023

View Audit 299411

Finding 387086 (2023-003)

Material Weakness 2023

Isd # 682 Roseau

MN

Reporting Cash Management HUD Housing Programs

Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District has implemented new meal count procedures effective May 2023. Completion Date – May 1, 2023

View Audit 299411

Finding 387083 (2023-001)

Material Weakness 2023

Housing Authority of the City of Everett

WA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We starte...

The Housing Authority’s strategy to address the backlog of biennial inspections is to scale our inspection capacity and develop a sustainable inspections plan for normal operations. We have steadily increased EHA staffing bandwidth for housing inspections since June of 2022, as follows: • We started the process on 6/29/2022 to replace our Housing Inspector that left EHA 5/04/2022. The person that filled this Housing Inspector position started at EHA on 1/05/2023, completed training and began taking on an inspection workload in February 2023. • In March 2023, twenty-five (25) staff in EHA’s Housing Management Department attended an HQS inspections training. EHA Housing Management staff began completing initial and annual HQS inspections at EHA PBV properties on 7/01/2023. • EHA budgeted for a second Housing Inspector position in EHA’s FYE2023 budget. We started the process to hire the second Housing Inspector on 7/13/2023. The person that filled this second Housing Inspector position started at EHA on 9/19/2023, completed training and began taking on an inspection workload at the end of October 2023. • EHA budgeted for an Inspections Coordinator position in EHA’s FYE2023 budget. We started the process to hire the Inspections Coordinator on 8/14/2023. The person that filled the Inspections Coordinator position started on 11/06/2023. • On 10/30/2023, EHA’s Executive Director decided to add a third Housing Inspector to the EHA inspections team to assist with the backlog of biennial inspections. We started the process to hire the third Housing Inspector on 10/31/2023. The person that filled this third Housing Inspector position started in the position on 1/16/2024, completed training and began taking on an inspection workload in February 2024. • On 2/23/2024, an HCV Manager was appointed to supervise the inspections team (three Housing Inspectors and one Inspections Coordinator), to provide increased oversight over EHA’s inspections workload. The HCV Manager is responsible for monitoring progress towards addressing the biennial inspections backlog, delegating inspections workload to the inspections team, and providing guidance and support to the inspections team. The HCV Manager meets with the inspections team on a weekly basis as well as conducts individual check-ins with all inspections team members. Our increased inspections capacity has allowed us to make significant progress on addressing the pandemic-caused backlog of biennial inspections. Based on our expanded internal staffing resources, we expect to complete all late biennial inspections by 12/31/2024.

View Audit 299403

Finding 386971 (2023-001)

Significant Deficiency 2023

City of Westland, Michigan

MI

Subrecipient Monitoring HUD Housing Programs Reporting

Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for...

Finding Number: 2023-001 Condition: The City did not submit the Consolidated Annual Performance and Evaluation Report (CAPER) for the program year ended June 30, 2023 within 90 days after the close of the program year. Planned Corrective Action: Upon recognizing the delay in submitting the CAPER for the program year ended June 30, 2023, we have taken immediate and strategic steps to address and prevent future occurrences. These include streamlining our data collection and reporting processes for greater efficiency, enhancing staff training on reporting responsibilities, and implementing robust internal monitoring to ensure adherence to reporting deadlines. These measures, designed to address both the immediate issue and bolster our overall reporting framework, demonstrate our commitment to transparency, accountability, and continuous improvement in our program operations. Contact person responsible for corrective action: Joanne Campbell Anticipated Completion Date: October 10, 2023

View Audit 299310

Finding 386943 (2023-001)

Material Weakness 2023

Eaton Place 202, Inc.

MA

Questioned Costs HUD Housing Programs Cash Management

Recommendation: Management should establish internal controls and procedures to ensure that required residual receipt remittances are made when required. Action Taken: The Corporation agrees with the finding and the auditor’s recommendations have been adopted.

View Audit 299288 Questioned Costs: $1

Finding 386909 (2023-009)

Significant Deficiency 2023

City of Wilmington

DE

HUD Housing Programs Reporting Subrecipient Monitoring

The City of Wilmington, Real Estate and Housing Department as the HOPWA grantee remains responsible for collecting, reviewing (for accuracy and completeness), and transmitting to HUD the Consolidated APR/CAPER workbooks. Submission of the complete set of Grantee and Provider Workbooks together cons...

The City of Wilmington, Real Estate and Housing Department as the HOPWA grantee remains responsible for collecting, reviewing (for accuracy and completeness), and transmitting to HUD the Consolidated APR/CAPER workbooks. Submission of the complete set of Grantee and Provider Workbooks together constitutes the Grantee’s annual performance report to HUD. Included in this submission is the Grantee Performance Report and all of the Provider Performance Reports together. Staff in the Real Estate and Housing Department review them to the best of our ability for accuracy and completeness. The finding notes that the documentary evidence of this review was not retained other than the subsequent data validation which occurs with HUD’s Technical Assistance (TA) HOPWA Data Validation team and through Cloudburst email. In the future the Real Estate and Housing Department will note to file the email confirmation of the received report is as complete and error free as possible.

View Audit 299217

Finding 386896 (2023-003)

Material Weakness 2023

Pittsfield Housing Authority

RI

Eligibility HUD Housing Programs Material Weakness

At the beginning of FY2024, under the terms of PHA's Recovery Agreement with HUD, PHA's consultants conducted PIH internal QCs and staffing assessments. As a result of those findings, PHA has reorganized and increased the PHA staff, with a new Public Housing Manager. Staff are being fully trained re...

At the beginning of FY2024, under the terms of PHA's Recovery Agreement with HUD, PHA's consultants conducted PIH internal QCs and staffing assessments. As a result of those findings, PHA has reorganized and increased the PHA staff, with a new Public Housing Manager. Staff are being fully trained regarding eligibility determinations and rent calculations, checklists are being developed and regular internal QCs performed, with an objective of full compliance by the end of calendar year 2024.

View Audit 299209

Finding 386895 (2023-002)

Material Weakness 2023

Pittsfield Housing Authority

RI

Questioned Costs HUD Housing Programs Special Tests & Provisions

Effective 3/3/23, PHA switched from manual calculations of rent reasonableness to a web-based Rental Reasonableness software designed to meet HUD standards. PHA began conducting reasonableness determinations utilizing the Rent Reasonableness software, beginning March 2023. Rent reasonableness determ...

Effective 3/3/23, PHA switched from manual calculations of rent reasonableness to a web-based Rental Reasonableness software designed to meet HUD standards. PHA began conducting reasonableness determinations utilizing the Rent Reasonableness software, beginning March 2023. Rent reasonableness determinations are now being made for all participants prior to initial HAP contract execution and in conjunction with any requested rent increases. Continuing compliance will be internally reviewed during a July 2024 SEMAP QC review.

View Audit 299209 Questioned Costs: $1

Corrective Action Plans

Filters