Corrective Action Plans

Finding 479180 (2023-002)

Material Weakness 2023

TX

HUD Housing Programs Material Weakness Reporting

Planned Corrective Action: While we agree that the submission dates lagged the scheduled dates, we do not agree that this condition rises to the level of a material weakness in internal controls over reporting. BVCOG submitted their audited financial statements for fiscal year 2022 through the Feder...

Planned Corrective Action: While we agree that the submission dates lagged the scheduled dates, we do not agree that this condition rises to the level of a material weakness in internal controls over reporting. BVCOG submitted their audited financial statements for fiscal year 2022 through the Federal Audit Clearinghouse (FAC) on June 30, 2023, which is prior to June 30, 2023. BVCOG awaits receipt of their audited financial fiscal year 2023 in order to submit them to the FAC. The audited fiscal year 2022 financial statements were submitted separately to HUD on November 22, 2023. HUD approved our submission without notice of delay. Unaudited financial statements for the fiscal year ending 2023 were submitted and accepted by HUD, with no point score deduction penalties or requests for corrective action. The timing of HUD’s Real Estate Assessment Center (REAC) report submission depends on acceptance of the previous unaudited or audited financial statements. The REAC submissions require that each year’s unaudited submission be approved by HUD before the audited submission can be submitted; further, both submissions for a year must be accepted by HUD before the next year’s submissions can be completed. Due to various factors including the COVID-19 pandemic and Winter Storm Uri in 2021, the Fiscal Year 2020 unaudited submission process completed April 2022. Subsequent staff turnover delayed the submission of the audited 2020 submission until August 2023. Once that submission was approved by HUD, the 2021 and 2022 submissions were completed by the end of November 2023. BVCOG realizes its REAC submission procedures rely on institutional knowledge and addressed this risk by engaging an outside CPA firm with personnel knowledgeable of the REAC system. This arrangement ensures additional cross-training opportunities in the future for current finance staff such that, if a key staff person leaves, there will be others in the department who know and understand the procedures necessary for compliance with HUD deadlines. Contact Person Responsible for Corrective Action: Janet Dudding, MBA, CPA, CGFO, Director of Finance Anticipated Completion Date: July 2024

View Audit 315724

Finding 479166 (2023-001)

Material Weakness 2023

Pine Hills, Inc.

MS

HUD Housing Programs

2023-001 The management company over the operations during 2023 was replaced effective November 1, 2023.

View Audit 315712

Finding 479164 (2023-002)

Material Weakness 2023

Housing Authority of Aitkin County

NE

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Moving forward, a supervisory review of the move in files will be performed by a different staff member for the Authority than the staff member who initially determined eligibility. This will ensure that the Authority continues compliance with eligibility requirements.

View Audit 315674

Finding 479163 (2023-001)

Material Weakness 2023

Housing Authority of Aitkin County

NE

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

It was discovered that our financial institution was pledging securities based on book value and not on market value which led to the deposits not being fully collateralized according to HUD requirements and State Statutes. The Authority will review the collateral reports at least quarterly to dete...

It was discovered that our financial institution was pledging securities based on book value and not on market value which led to the deposits not being fully collateralized according to HUD requirements and State Statutes. The Authority will review the collateral reports at least quarterly to determine that pledging requirements are adequate to ensure compliance in the future.

View Audit 315674

Finding 479147 (2023-001)

None 2023

Baptist Community Health Services, Inc.

LA

Internal Control / Segregation of Duties HUD Housing Programs

BCHS will implement adequate internal control procedures related to account reconciliations and ensure that control process for approval of expenditures is followed.

View Audit 315640

Finding 479063 (2023-001)

Significant Deficiency 2023

Genesis Nonprofit Housing Corporation

MI

Eligibility HUD Housing Programs Significant Deficiency

The Corporation contacted the local Continuum of Care and regional HUD office in an effort to verify the required number of units occupied by individuals meeting the definition of "homeless". The local Continuum of Care had no record of the original grant agreement or required number of "homeless" t...

The Corporation contacted the local Continuum of Care and regional HUD office in an effort to verify the required number of units occupied by individuals meeting the definition of "homeless". The local Continuum of Care had no record of the original grant agreement or required number of "homeless" to be served. The Corporation contacted three staff in the regional HUD office, including the staff that had been our representative for annually renewed operation and support service grants for the two projects. Regional HUD staff were not able to provide a copy of the original grant agreements which would indicate the number of persons to be served by each project. HUD staff stated that they do not keep copies of grant agreements longer than seven years. Corporation management will continue to work with HUD personnel to determine the continuing compliance requirements of the Continuum of Care funding received for initial construction or rehabilitation. Corporation management will continue to serve individuals meeting the definition of homelessness at its two projects and document evidence in the file.

View Audit 315585

Finding 479030 (2023-003)

Material Weakness 2023

West Central Nebraska Joint Housing Authority

NE

Internal Control / Segregation of Duties Special Tests & Provisions Eligibility

Finding 2023-003: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the inte...

Finding 2023-003: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board had reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.

View Audit 315549

Finding 479014 (2023-002)

Significant Deficiency 2023

Arapahoe County, Colorado

CO

Special Tests & Provisions HUD Housing Programs Significant Deficiency

HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County con...

HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County continue to train personnel so that the inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2023, performance issues with the administration of the HOME program were discovered, to include the absence of required inspections. With significant turnover of tenured leadership and employees within the Community Resources Department, Arapahoe County Community Resources took proactive measures in 2023 for review of the Community Development Housing and Homeless Services (CDHHS) programs by recognized consultants within the field. Community Resources has contracted with two consultants, to assist in a full review and re-development of policies and procedures (Civitas) for the CDBG and HOME programs as well as a full review of all case files (Affordable Housing Consultants). Included with this response are the contracts with both Civitas and Affordable Housing Consultants for verification purposes. The County anticipates their work to be completed and an implementation of updated policies and procedures for these programs by fall of 2024. The role of Program Administrator over the HOME program was not filled until April of 2024. This role will be responsible for all future HOME program inspections. Community Resources CDHHS employees will be taking part in a two-day training in June 2024 (June 11th and 12th, 2024) for the following:  Davis Bacon & Related Acts (Applicability, wage determinations, payroll review, interviews, common errors and how to correct)  Section 3 (Applicability, Safe Harbor benchmarks, documenting compliance, qualitative efforts)  TBRA Inspections (National Standards for the Physical Inspection of Real Estate (NSPIRE) administrative procedures)  HOME Program - Implementation and Best Practices - Arapahoe County, CO - June 12, 2024  This HOME training is an introductory course focusing on underwriting and subsidy layering requirements.  Eligible Activities (Homeowner rehab programs, Homebuyer programs, Rental housing)  Underwriting (Subsidy layering and underwriting requirements and best practices)  Community Housing Development Organization (CHDO) (Requirements, best practices, management, etc)  Long-term Compliance (HOME Match, eligible beneficiaries, income limits, subsidy layering & limits, affordability, written agreements, etc)  IDIS and Reporting Arapahoe County staff will be conducting monitoring of the two Tenant Based Rental Assistance (TBRA) programs and projects within in the affordability period (20-year span) between mid-June to mid-August of 2024. The remaining HOME program projects, within the affordability period (20-year span) will have audits completed by the end of our 2023 grant cycle, September 30th, 2024. Name of the contact person responsible for corrective action: Katherine Smith Planned completion date for corrective action plan: September 30, 2024

View Audit 315527

Finding 478886 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Seattle

WA

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties § 200.302

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payme...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Housing Choice Voucher department is addressing inspection controls in multiple ways. The Department has added additional staffing and also has created new tracking that makes it easier to review and identify units that have not passed inspection and not been abated. The Department has also instituted an ongoing process that has the inspections manager conducting a monthly review of units moving through the abatement process to ensure timely processing and cessation of HAP payments as needed. As part of this review the Department is also conducting a comprehensive review of units that have prior failed inspections to ensure abatement occurred. Name of the contact person responsible for corrective action: Mark La Brayere Planned completion date for corrective action plan: Three elements are continuous with no final completion date. The singular comprehensive review is scheduled to be completed within three months.

View Audit 315516 Questioned Costs: $1

Finding 478876 (2023-001)

None 2023

Palermo Lakes, Inc.

FL

HUD Housing Programs Reporting

Oversight Agency for Audit, Palermo Lakes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit per...

Oversight Agency for Audit, Palermo Lakes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2023 through December 31, 2023 The finding from the December 31, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2023-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should make sufficient deposits to the escrow accounts in a timely manner. Action Taken: New procedures have been implemented to ensure appropriate amounts are reserved in escrow. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

View Audit 315508

Finding 478772 (2023-003)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

HUD Housing Programs Reporting Significant Deficiency § 200.303

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that performance reports are prepared and reviewed by separate individuals. Documentation will be ...

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that performance reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of annual report.

View Audit 315421

Finding 478682 (2023-001)

None 2023

Nueces County Housing Assistance, Inc.

TX

Cash Management HUD Housing Programs

Management will prepare the surplus cash calculation in a matter timely enough to ensure any required deposit to the residual receipts account is made within 90 days of year-end.

View Audit 315316

Finding 478658 (2023-001)

Significant Deficiency 2023

Northwest Regional Housing Authority

AR

HUD Housing Programs

Northwest Regional Housing Authority Abatement process will be enforced. There were several issues last year with inability to get materials and labor. Northwest Regional Housing Authority over road abatement when this was the issue. We will keep better records of abatements. Moving forward, we will...

Northwest Regional Housing Authority Abatement process will be enforced. There were several issues last year with inability to get materials and labor. Northwest Regional Housing Authority over road abatement when this was the issue. We will keep better records of abatements. Moving forward, we will follow the abatement requirements as required.

View Audit 315249

Finding 478560 (2023-001)

None 2023

Carlisle Senior Housing Associates

PA

Cash Management HUD Housing Programs

The delinquent deposit will be made Tuesday May 21, 2024. In the future, the calculation will be done in February and if there is surplus cash, the funds will be deposited within the required time period.

View Audit 315189

Finding 478409 (2023-003)

Significant Deficiency 2023

Johnnie B. Moore Towers, Inc.

GA

HUD Housing Programs

Management is in agreement with the finding and will adhere to the requirements set forth in the HUD Handbook going forward and reinstate the fidelity bond insurance policy in accordance with HUD regulations.

View Audit 315100

Finding 478408 (2023-002)

Significant Deficiency 2023

Johnnie B. Moore Towers, Inc.

GA

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

In accordance with HUD regulations, entities should not make unauthorized distributions of project funds. The project paid expenses for an adjacent property. The Corporation paid non-project expenses from Project funds. The Project is noncompliant with the HUD regulatory agreement. Expense allocatio...

In accordance with HUD regulations, entities should not make unauthorized distributions of project funds. The project paid expenses for an adjacent property. The Corporation paid non-project expenses from Project funds. The Project is noncompliant with the HUD regulatory agreement. Expense allocations should be closely monitored to ensure Project funds are not used for non-project expenses.

View Audit 315100 Questioned Costs: $1

Finding 478371 (2023-001)

Significant Deficiency 2023

Boston Tremont Housing Development Fund Corporation

NY

Eligibility HUD Housing Programs Reporting

Corrective Action Plan Project Legal Name: Boston Tremont Housing Development Fund Corporation HUD Project Nos.: NY 36L000080 and NY 36L000081 Audit Firm: CohnReznick LLP Period covered by the audit: December 31, 2023 Corrective Action Plan prepared by: Name: Lukeman Ogunyinka Position: Chief Financ...

Corrective Action Plan Project Legal Name: Boston Tremont Housing Development Fund Corporation HUD Project Nos.: NY 36L000080 and NY 36L000081 Audit Firm: CohnReznick LLP Period covered by the audit: December 31, 2023 Corrective Action Plan prepared by: Name: Lukeman Ogunyinka Position: Chief Financial Officer Telephone Number: (212) 243-9090 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2023-1 a. Comments on the Finding and Each Recommendation 4 out of 26 tenants tested did not have an annual tenant recertification Form HUD 50059 completed timely. Moving forward, management will follow established procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with the guidelines specified by HUD. b. Action(s) Taken or Planned on the Finding Management has addressed the issue by recertifying the tenant and does not expect a late recertification to occur again based on procedures in place.

View Audit 315050

Finding 478356 (2023-004)

Material Weakness 2023

Alpena Housing Commission

MI

Questioned Costs Special Tests & Provisions HUD Housing Programs

Capital Fund Program – CFDA 14.872 Recommendation: The Commission should review the obligation and expenditure of capital grants on an ongoing basis and implement policies and procedures to ensure all federal compliances are followed pertaining to obligation and expenditures verification. Action Tak...

Capital Fund Program – CFDA 14.872 Recommendation: The Commission should review the obligation and expenditure of capital grants on an ongoing basis and implement policies and procedures to ensure all federal compliances are followed pertaining to obligation and expenditures verification. Action Taken: New Management has taken over as of March 2023 and will review and implement stronger policies and procedures pertaining to capital fund grants. Anticipated Completion Date of Action: December 31, 2024.

View Audit 315015 Questioned Costs: $1

Finding 478278 (2023-004)

Significant Deficiency 2023

Crookston Housing and Economic Development Authority

MN

HUD Housing Programs Reporting Significant Deficiency

1. Correcting Plan CHEDA staff are aware of Voucher for Payment of Annual Contributions and Operating Statement report monthly to HUD via the Voucher Management System (VMS) requirements and will implement appropriate review of statements prior to submission. 2. Explanation of Disagreement with the ...

1. Correcting Plan CHEDA staff are aware of Voucher for Payment of Annual Contributions and Operating Statement report monthly to HUD via the Voucher Management System (VMS) requirements and will implement appropriate review of statements prior to submission. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 314956

Finding 478277 (2023-003)

Significant Deficiency 2023

Crookston Housing and Economic Development Authority

MN

HUD Housing Programs Eligibility Significant Deficiency

1. Correcting Plan CHEDA staff are aware of income eligibility documentation and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – Execut...

1. Correcting Plan CHEDA staff are aware of income eligibility documentation and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 314956

Finding 478276 (2023-002)

Material Weakness 2023

Crookston Housing and Economic Development Authority

MN

Allowable Costs / Cost Principles HUD Housing Programs

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – E...

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum – Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 314956

Finding 478275 (2023-001)

Significant Deficiency 2023

Watertown Housing Authority

MA

Eligibility HUD Housing Programs Allowable Costs / Cost Principles

Name of Auditee: Watertown Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2023 CAP Prepared by: Michael Lara, Executive Director Phone: (617) 923-3950 (A) Current Findings on the Schedule of Findings and Questioned Costs (1) Finding 2023-001 (a...

Name of Auditee: Watertown Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2023 CAP Prepared by: Michael Lara, Executive Director Phone: (617) 923-3950 (A) Current Findings on the Schedule of Findings and Questioned Costs (1) Finding 2023-001 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action taken. (b) Action taken - The Authority’s HCV program coordinator will review records in each tenant’s file to ensure all required documents are present. (c) Planned implementation date of corrective action - Completed by December 31, 2024.

View Audit 314952

Finding 478208 (2023-001)

Significant Deficiency 2023

Archdiocesan Housing Authority

WA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Management has implemented a quarterly inspection schedule of all units with documentation centrally located for visibility.

View Audit 314901

Finding 478206 (2023-001)

Significant Deficiency 2023

Providence Manor Development Corporation

GA

Questioned Costs HUD Housing Programs

Amounts paid to management company exceed amounts dictated in agreement and approved by HUD. Management fees were overpaid during the year ended December 31, 2023. Controls were not in place to ensure managemennt fees were calculated and paid in accordance with the agreement. The effect is that the ...

Amounts paid to management company exceed amounts dictated in agreement and approved by HUD. Management fees were overpaid during the year ended December 31, 2023. Controls were not in place to ensure managemennt fees were calculated and paid in accordance with the agreement. The effect is that the project is not in compliance with HUD requirements. Policies and procedures will be reviewed to ensure management fees are paid in accordance with executed agreements as required by HUD.

View Audit 314896 Questioned Costs: $1

Finding 478202 (2023-003)

Significant Deficiency 2023

Anderson Place Apartments, Inc.

IN

HUD Housing Programs Cash Management

The management of Anderson Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will contact HUD to ensure that all excess residual receipts are remitted to HUD as soon as possible.

View Audit 314892

Corrective Action Plans

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