Corrective Action Plans

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The finding of missing income verifications for eligibility and recertification rent calculations is being addressed as part of a holistic review under the Recovery Agreement of Section 8 program compliance. Following an internal SEMAP QC review in July 2023, staff have been retrained and certificat...
The finding of missing income verifications for eligibility and recertification rent calculations is being addressed as part of a holistic review under the Recovery Agreement of Section 8 program compliance. Following an internal SEMAP QC review in July 2023, staff have been retrained and certification/recertification checklists have been created. Initial and annual recertifications are currently being conducted in accordance with the applicable HUD regulations and guidance and will be internally reviewed during a July 2024 SEMAP QC review .
Finding: Management did not remit payment to HUD for the amount in excess of $250 per unit for their fifteen units. Uniform Guidance states that controls should be implemented to ensure the Project is in compliance with special tests and provisions. As stated in the Coronavirus Disease 2019 memorand...
Finding: Management did not remit payment to HUD for the amount in excess of $250 per unit for their fifteen units. Uniform Guidance states that controls should be implemented to ensure the Project is in compliance with special tests and provisions. As stated in the Coronavirus Disease 2019 memorandum released by HUD, remittance of residual receipts were suspended through December 31, 2021. Residual receipts were due to HUD by the next Project Rental Assistance Contracts renewal which was October 1, 2022. Management was unaware the funds needed to be remitted back to HUD in the time frame noted. We recommend management review their processes and controls surrounding residual receipts to ensure amounts due to HUD are properly remitted. Corrective Action: Management has updated their internal controls to ensure a proper review of residual receipts is conducted quarterly. This review will be completed by an assigned staff member, with a secondary review completed by management. Residual receipts in excess of allowed amounts will be properly accounted for as a liability on the books and records of the Project. Residual receipts in excess of the allowed amounts will be remitted when due.
View Audit 299197 Questioned Costs: $1
Response Management has completed the required deposit to the prohibited amenities escrow of $3,971 in September 2023.
Response Management has completed the required deposit to the prohibited amenities escrow of $3,971 in September 2023.
Response: Management has completed the required deposit to the reserve for replacement of $3,450 in September 2023.
Response: Management has completed the required deposit to the reserve for replacement of $3,450 in September 2023.
Finding: Management did not complete the search for a tenant prior to move-in. According to Chapter 9 ofthe HUD Multifamily Occupancy Handbook, HUD requires an Existing Tenant Search through the Enterprise Income Verification System (EIV) be completed for all new tenants prior to move in. Due to a c...
Finding: Management did not complete the search for a tenant prior to move-in. According to Chapter 9 ofthe HUD Multifamily Occupancy Handbook, HUD requires an Existing Tenant Search through the Enterprise Income Verification System (EIV) be completed for all new tenants prior to move in. Due to a clerical error, an incorrect social security number was entered while running the EIV. We recommend management verify the information entered into the EIV. Corrective Action: Management acknowledges the error and will continue to verify the social security numbers being entered.
Program Affected: 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services, agreement period February 15, 2021 through August 14, 2023. Condition and Context: Of the one report haphazardly selected for testing, it was unable to be tested as it was not provided. Correct...
Program Affected: 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services, agreement period February 15, 2021 through August 14, 2023. Condition and Context: Of the one report haphazardly selected for testing, it was unable to be tested as it was not provided. Corrective Action Plan: Reporting for the Federal Award is maintained within the SAMHSA website. Reporting information should have been made available as requested. The new Finance Director will serve as the point of contact for future audits and will make reports available as requested. The new Finance Director will establish procedures to capture report submissions that are managed via a portal. The procedures will include parameters that can be used to verify timely submission. Responsible Official: Dale Hamilton, Executive Director & Kathie Norwood, Finance Director Implementation Date: April 1, 2024
Program Affected: 93.498 Provider Relief Fund and American Rescue Plan Rural Distribution, agreement period January 1, 2020 through June 30, 2023. Condition and Context:Of the one report haphazardly selected for testing, it was unable to be tested as it was not provided. Corrective Action Pla...
Program Affected: 93.498 Provider Relief Fund and American Rescue Plan Rural Distribution, agreement period January 1, 2020 through June 30, 2023. Condition and Context:Of the one report haphazardly selected for testing, it was unable to be tested as it was not provided. Corrective Action Plan:The new Finance Director will establish procedures to capture report submissions that are managed via a portal. The procedures will include parameters that can be used to verify timely submission. Responsible Official: Dale Hamilton, Executive Director & Kathie Norwood, Finance Director Implementation Date: April 1, 2024
Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Finding 386521 (2023-003)
Significant Deficiency 2023
SPM terminated the employment of the person responsible for this oversight and has implemented an internal control for its Financial Planning & Analysis department to monitor the management team’s compliance with these deadlines.
SPM terminated the employment of the person responsible for this oversight and has implemented an internal control for its Financial Planning & Analysis department to monitor the management team’s compliance with these deadlines.
Finding 386520 (2023-002)
Significant Deficiency 2023
SPM has hired a new Director of Treasury with responsibility for this activity. Additionally, SPM is investigating moving these funds to the lender held reserve account to avoid this issue in the future and eliminate the impact to the financial statement.
SPM has hired a new Director of Treasury with responsibility for this activity. Additionally, SPM is investigating moving these funds to the lender held reserve account to avoid this issue in the future and eliminate the impact to the financial statement.
Condition and Criteria: The Authority’s purpose for existence is providing decent safe and affordable housing to low-income persons. As such, HUD requires the Authority to comply with special tests and provisions relating to its Housing Choice Voucher program. The Authority must inspect the unit le...
Condition and Criteria: The Authority’s purpose for existence is providing decent safe and affordable housing to low-income persons. As such, HUD requires the Authority to comply with special tests and provisions relating to its Housing Choice Voucher program. The Authority must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The Authority must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Population and Items Tested: Per Table 10-1 of the Housing Choice Voucher Guidebook, the Authority was required to perform 19 quality control housing reinspections. Ten quality control re-inspections could be documented. Auditor’s Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Grantee Response: We will comply with the auditor’s recommendation. Anticipated Completion Date: June 30, 2024
Condition and Criteria: The Authority’s purpose for existence is providing decent, safe and affordable housing to low- income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of...
Condition and Criteria: The Authority’s purpose for existence is providing decent, safe and affordable housing to low- income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of rent assistance to be paid on the family’s behalf. HUD regulations prescribe the content of these family files. These requirements consist of the following: a. As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. c. Determine income eligibility and calculate the tenant’s rent payment in accordance with HUD regulations. d. Select tenants from the public housing waiting list in accordance with the PHA’s tenant selection policies. e. Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary. Population and Items Tested: Testing of sixty family files revealed the following deficiencies: 1. Two lacked documentation of rent reasonableness. 2. One file contained a HAP contract not signed by the owners. 3. Two files calculated an incorrect housing assistance payment. 4. One file lacked signed Form 9886 authorization for the period under review. Auditor’s Recommendation: A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Grantee Response: We will comply with the auditor’s recommendation.
Condition: The Commission did have required written policies in place during the year under audit or retained copies of grant agreements once they became the direct recipient of the grants. Planned Corrective Action: Management agrees with the finding as reported. To correct this finding, the Commis...
Condition: The Commission did have required written policies in place during the year under audit or retained copies of grant agreements once they became the direct recipient of the grants. Planned Corrective Action: Management agrees with the finding as reported. To correct this finding, the Commission reviewed its policies and procedures and revised as needed to comply with federal regulations. The policies were presented and approved at the August 2023 board meeting. The Commission has sent revised policies to HUD for their review and approval. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024
Condition: The Commission was unable to provide adequate source documentation to support that the match requirement was met. Planned Corrective Action: Management agrees that match requirements for Continuum of Care awards have not been maintained as required by the Uniform Guidance. In July 2023, m...
Condition: The Commission was unable to provide adequate source documentation to support that the match requirement was met. Planned Corrective Action: Management agrees that match requirements for Continuum of Care awards have not been maintained as required by the Uniform Guidance. In July 2023, management was notified by HUD after completion of an on-site monitoring visit that the Commission's claimed matching expenses that were not adequately supported by source documentation. In response, management has placed in service additional controls to ensure the compliance requirements are being monitored and in place for the new program. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024
View Audit 298666 Questioned Costs: $1
Condition: For a sample of tenants selected in conjunction with eligibility testing, the Commission did not correctly calculate family income composition, and did not retain required documentation supporting eligibility determinations. Planned Corrective Action: The Commission is implementing a plan...
Condition: For a sample of tenants selected in conjunction with eligibility testing, the Commission did not correctly calculate family income composition, and did not retain required documentation supporting eligibility determinations. Planned Corrective Action: The Commission is implementing a plan to audit internally 100 percent of all tenant files in our Low Income Public Housing (LIPH) program. This plan involves both the use of experienced employees and an outside consultant. The plan includes updating and automating files, identifying recurring compliance issues, and expanding formal training and specific training from the consultant. In addition, an additional level of review will be put in place to assist in catching any inconsistencies. The Commission has added additional employees to the LIPH program, which include an operations manager and a staff person. These additional resources will be incorporated into our overall plan to increase our compliance controls. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024
Condition: For a sample of tenants, a recertification was not completed properly, resulting in an incorrect calculation of housing assistance payments to be received. Planned Corrective Action: The Commission acknowledges the incorrect subsidy calculations and has issued refunds to the tenants in th...
Condition: For a sample of tenants, a recertification was not completed properly, resulting in an incorrect calculation of housing assistance payments to be received. Planned Corrective Action: The Commission acknowledges the incorrect subsidy calculations and has issued refunds to the tenants in the amount of underpayment of subsidy. The Commission has also adjusted future funding requests for the overpayment of subsidy. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024
The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely.
The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely.
As a result of changes in Municipality’s Federal Affairs Office management, supervision personnel were assigned to ensure that the reports are filed on time. As part of this internal control, the deadlines were scheduled with the personnel involved with the preparation of such reports. Also, correct...
As a result of changes in Municipality’s Federal Affairs Office management, supervision personnel were assigned to ensure that the reports are filed on time. As part of this internal control, the deadlines were scheduled with the personnel involved with the preparation of such reports. Also, corrections were made to reports for some months as required by the HUD monitor, in order to reflect the correct numbers. In addition, since march 2023 the Internal Audit Office gives follow-up in and require evidence of the remittance in compliance with this action. Implementation Date: Immediately. Responsible Individuals: Ms. Ada Bones, Federal Affairs Office Director
Finding 386129 (2023-001)
Significant Deficiency 2023
The City was not aware of the CDBG quarterly PR29 (SF-425) reporting errors. The City has trained staff and implemented revised policies and procedures when preparing the CDBG PR29 (SF-425) quarterly reports to ensure proper reporting of program income on hand and the appropriate federal expenditur...
The City was not aware of the CDBG quarterly PR29 (SF-425) reporting errors. The City has trained staff and implemented revised policies and procedures when preparing the CDBG PR29 (SF-425) quarterly reports to ensure proper reporting of program income on hand and the appropriate federal expenditures utilizing both federal grant and program income.
CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to pr...
CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended June 30, 2023. Finding 2023-001 Responsible Party Name: Amy Spaeth Position: Co-CEO – Management Agent Telephone Number: 816-236-2435 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities (Section 811) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We have deposited the shortfall of $4,320 into the reserve for replacement account in July 2023. We will follow our process to deposit and reconcile the reserve for replacement account on a monthly basis. Anticipated Completion Date N/A
View Audit 298479 Questioned Costs: $1
Corrective Action Plan: Sacred Heart Village II Inc. will contact its HUD representative to discuss this matter and determine if there is an obligation to repay any previous subsidies received. Contact Person Responsible for Corrective Action: Karen Smith, CFO Anticipated Completion Date of Correcti...
Corrective Action Plan: Sacred Heart Village II Inc. will contact its HUD representative to discuss this matter and determine if there is an obligation to repay any previous subsidies received. Contact Person Responsible for Corrective Action: Karen Smith, CFO Anticipated Completion Date of Corrective Action: Immediately
Corrective Action Plan: Beginning July 2023, Sacred Heart Village II Inc. began increasing its monthly deposits to the reserve for replacement account by $1,000. The Organization plans to continue making these additional payments until the account is fully funded. Contact Person Responsible for Corr...
Corrective Action Plan: Beginning July 2023, Sacred Heart Village II Inc. began increasing its monthly deposits to the reserve for replacement account by $1,000. The Organization plans to continue making these additional payments until the account is fully funded. Contact Person Responsible for Corrective Action: Karen Smith, CFO Anticipated Completion Date of Corrective Action: Approximately six years
2023-002 - Insufficient Collateral Corrective Action Planned: The Authority will closely monitor all deposits to make sure that the amount of funds on deposit are protected by federal deposit insurance, corporate surety bond, or collateral. Completion Date: June 30, 2024
2023-002 - Insufficient Collateral Corrective Action Planned: The Authority will closely monitor all deposits to make sure that the amount of funds on deposit are protected by federal deposit insurance, corporate surety bond, or collateral. Completion Date: June 30, 2024
The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely.
The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely.
2023-001 ALN 14.871 – Housing Voucher Cluster – Activities Allowed or Unallowed The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Questioned Costs. In 2021, the Authority was instructed by Keith Landrum of the Colu...
2023-001 ALN 14.871 – Housing Voucher Cluster – Activities Allowed or Unallowed The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Questioned Costs. In 2021, the Authority was instructed by Keith Landrum of the Columbia, South Carolina HUD Field Office to stop making payments until the matter could be further investigated to see what amounts, if any, are still owed. Management will continue to monitor budgets to ensure that funds are adequate. Management has and will continue to make budget revisions to reduce unessential operating costs. The Authority has designed and implemented a Board approved formal repayment agreement. Person Responsible for Correction of Finding: Mark Fountain, Executive Director Projected Completion Date: June 30, 2024
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