Corrective Action Plans

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Cognizant or Oversight Agency for Audit U.S. Department of Housing and Urban Development Mortgage Insurance – Hospitals Federal Assistance Listing/CFDA #14.128 Findings Relating to Federal Awards and Questioned Costs Finding 2023-006 Special Tests and Provisions Significant Deficiency in Internal Co...
Cognizant or Oversight Agency for Audit U.S. Department of Housing and Urban Development Mortgage Insurance – Hospitals Federal Assistance Listing/CFDA #14.128 Findings Relating to Federal Awards and Questioned Costs Finding 2023-006 Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance Finding Summary: The Organization did not request prior approval from HUD before entering into a finance lease agreement. A finance lease is identified in the Mortgage Note Insured by HUD as the incurrence of additional indebtedness which, by terms of the agreement, should be approved by HUD in advance of entering into such agreements. Responsible Individuals: Charles Roeder, Vice President Finance/CFO Corrective Action Plan: The Organization has enhanced internal control policies to ensure all lease agreements are evaluated to determine whether the lease should be accounted for as an operation or finance lease prior to entering into the lease. If the lease is concluded to be a finance lease, HUD should be notified, and the Organization should request and receive approval from HUD prior to entering into the lease agreement. Anticipated Completion Date: June 1, 2024
Cognizant or Oversight Agency for Audit U.S. Department of Housing and Urban Development Mortgage Insurance – Hospitals Federal Assistance Listing/CFDA #14.128 Findings Relating to Federal Awards and Questioned Costs Finding 2023-005 Special Tests and Provisions Significant Deficiency in Internal Co...
Cognizant or Oversight Agency for Audit U.S. Department of Housing and Urban Development Mortgage Insurance – Hospitals Federal Assistance Listing/CFDA #14.128 Findings Relating to Federal Awards and Questioned Costs Finding 2023-005 Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance Finding Summary: The Organization did not retain documentation of review and approval of certain invoices or Purchase Orders. Responsible Individuals: Charles Roeder, Vice President Finance/CFO Corrective Action Plan: The Organization has enhanced internal control policies to ensure all cash disbursements are reviewed and approval is documented prior to payment to ensure that all payments are necessary and correct. Anticipated Completion Date: June 1, 2024
Cognizant or Oversight Agency for Audit U.S. Department of Housing and Urban Development Mortgage Insurance – Hospitals Federal Assistance Listing/CFDA #14.128 Findings Relating to Federal Awards and Questioned Costs Finding 2023-004 Reporting Material Weakness in Internal Control Over Compliance an...
Cognizant or Oversight Agency for Audit U.S. Department of Housing and Urban Development Mortgage Insurance – Hospitals Federal Assistance Listing/CFDA #14.128 Findings Relating to Federal Awards and Questioned Costs Finding 2023-004 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Finding Summary: The Department of Housing and Urban Development (HUD) requires a quarterly reporting of financial and statistical data. Amounts reported under “All Non‐Operating Revenue” and “Other Changes in Fund Balance” in the Organization’s third quarter report submitted to HUD were not reconciled to and did not agree with the underlying financial data. The internal financial statements do not present all of the information that is required in the HUD quarterly reports and the differing information was all put to one line on the HUD quarterly report when the differences should have been evaluated and documented. Responsible Individuals: Charles Roeder, Vice President Finance/CFO Corrective Action Plan: To ensure the accuracy of the report, the Organization approved the policy Review of Reports Filed with Federal Agencies which details that the preparer of the report will submit it to the CFO or delegated staff member different from the preparer to review and formally approve before the report is filed with the federal agency. A different staff member will document and date the review and when formal approval was received and maintain a file on the process. Anticipated Completion Date: September 30, 2024
We will monitor monthly to ensure deposits to Replacement Reserve are done on a timely basis.
We will monitor monthly to ensure deposits to Replacement Reserve are done on a timely basis.
Finding 404826 (2023-002)
Material Weakness 2023
Guild
MN
Finding Summary: Guild’s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Corrective Action Plan: Working with all Rental Assistance staff, we will develop a standard for documentation and a chec...
Finding Summary: Guild’s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Corrective Action Plan: Working with all Rental Assistance staff, we will develop a standard for documentation and a checklist for signing off by the responsible official. Responsible Individuals: Keith Rachey, Chief Financial Officer Anticipated Completion Date: Completed and staff trained by September 2024
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the County keep records to show all tenant who had a rent increase during the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in resp...
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the County keep records to show all tenant who had a rent increase during the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have reached out to our software provider to have such a report added. Name(s) of the contact person(s) responsible for corrective action: Kenneth Stratemeyer Planned completion date for corrective action plan: 7/1/2024
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the County maintain a list of all individuals at the top of the waiting list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response t...
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the County maintain a list of all individuals at the top of the waiting list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As recommended, we will seek a method to keeping, and maintaining, a list of those on top of the Wait List. Name(s) of the contact person(s) responsible for corrective action: Kenneth Stratemeyer Planned completion date for corrective action plan: 10/1/2024
Finding 2023-002: Late Submission of Financial Statements to FAC and REAC (Significant Deficiency) Recommendation: The Authority should review and enhance its policies, procedures, and internal controls to ensure the financial reporting package and audited financial statements are submitted by the r...
Finding 2023-002: Late Submission of Financial Statements to FAC and REAC (Significant Deficiency) Recommendation: The Authority should review and enhance its policies, procedures, and internal controls to ensure the financial reporting package and audited financial statements are submitted by the required due date. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response to finding: The Authority will implement a year-end closing process to ensure all accounts are properly reconciled. Due to the delay in receiving the prior year audits, the Agency was unable to submit a timely and accurate current year audit. The Authority has now recently filled several accounting positions, implemented multiple internal controls, policy and procedures over financial reporting as well as changed audit firms to increase financial efficiencies and timeliness. Name of the contact person responsible for corrective action: Dontrelle Young Foster, Executive Director Planned completion date for corrective action plan: We expect to have the finding resolved by March 31, 2025.
CORRECTIVE ACTION PLAN Name and Number of the Project: St. George's Senior Housing, Inc. No. 115-EH057 Audit Firm: M Group, LLP Audit Period: The year ended September 30, 2023 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditor...
CORRECTIVE ACTION PLAN Name and Number of the Project: St. George's Senior Housing, Inc. No. 115-EH057 Audit Firm: M Group, LLP Audit Period: The year ended September 30, 2023 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING 1: Section 202 Supportive Housing for the Elderly, Assistance Listing 14.157 and Section 8 Housing Assistance Payments Program, Assistance Listing 14.195 CORRECTIVE ACTION COMPLETED: On December 19, 2023, the Company deposited $2,941 into the replacement reserve account. Finding CLEARED. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 US. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Ms. Connie Quillen, Vice President, Asset Living.
View Audit 311152 Questioned Costs: $1
The finding identified in the sample is consistent with the Section Eight Management Assessment Program (SEMAP) score submitted at the end of Fiscal Year 22-23. JHA did not claim any points under the Adjusted Income indicator. Consistent with the corrective action plan, JHA’s HCV staff has undergo...
The finding identified in the sample is consistent with the Section Eight Management Assessment Program (SEMAP) score submitted at the end of Fiscal Year 22-23. JHA did not claim any points under the Adjusted Income indicator. Consistent with the corrective action plan, JHA’s HCV staff has undergone extensive training. During April 2024, HCV staff received training through Nan McKay in the following areas: Housing Choice Voucher Specialist Housing Choice Voucher Rent Calculation Specialist Twenty-two (22) Housing Counselors took the class and seventeen (17) passed and will receive certification in this area. The JHA restructured the HCV Department to designate a Quality and Training Manager and currently over 2,000 files have been reviewed to determine compliance with all 14 SEMAP indicators. JHA continues to improve the overall processes and procedures in the HCV department and has already taken corrective action regarding the identified deficiency.
The following steps have been and are being taken regarding tenant certifications: 1. Staff has attended HOTMA training: An In-Depth Review of Programmatic Changes on 5/21/24 2. A new position was created at the Authority. Our most senior Manager is now our dedicated Quality Control Specialist and ...
The following steps have been and are being taken regarding tenant certifications: 1. Staff has attended HOTMA training: An In-Depth Review of Programmatic Changes on 5/21/24 2. A new position was created at the Authority. Our most senior Manager is now our dedicated Quality Control Specialist and will be responsible for reviewing 100% of our files yearly.
The following steps have been and are being taken regarding tenant certifications: 1. Staff has attended HOTMA training: An In-Depth Review of Programmatic Changes on 5/21/24 2. A new position was created at the Authority. Our most senior Manager is now our dedicated Quality Control Specialist and ...
The following steps have been and are being taken regarding tenant certifications: 1. Staff has attended HOTMA training: An In-Depth Review of Programmatic Changes on 5/21/24 2. A new position was created at the Authority. Our most senior Manager is now our dedicated Quality Control Specialist and will be responsible for reviewing 100% of our files yearly.
PLAN OF ACTION RESPONSE TO FY23 FINDINGS & QUESTIONED COSTS SIGNIFICANT DEFICIENCY Action Timeframe Responsible Person Training will be provided to staff on a quality control protocol, specifically, the importance of proper calculations; obtaining necessary documentation; and the importance and p...
PLAN OF ACTION RESPONSE TO FY23 FINDINGS & QUESTIONED COSTS SIGNIFICANT DEFICIENCY Action Timeframe Responsible Person Training will be provided to staff on a quality control protocol, specifically, the importance of proper calculations; obtaining necessary documentation; and the importance and process for following up on inspections July 31, 2024 Beth Ochs Rent Assistance Director Quality control by manager will be performed on all files assigned to probationary employees July 31, 2024 Beth Ochs Rent Assistance Director Establish an updated checklist for staff to follow to ensure proper documentation is obtained on each file September 30, 2024 Beth Ochs Rent Assistance Director Pull reports out of the EIV/PIC system, on a monthly basis, such as the Identity Verification Report, SSA Screening Deficiencies Report and place them in a centrally located OneNote for staff follow up. Note: This has been on pause due to the conversion to new software July 31, 2024 Beth Ochs Rent Assistance Director Establish a plan to schedule overdue inspections and complete inspections December 31, 2024 Beth Ochs Rent Assistance Director Assigned caseworker staff will correct the tenant files that were cited in the “other matter” finding in the FY 23 Audit August 30, 2024 Beth Ochs Rent Assistance Director Randomly select tenant files on a monthly basis for review. Note: This has been on pause due to the conversion to new software and will resume in July 2024 July 31, 2024 Beth Ochs Rent Assistance Director Randomly select an additional 50 HCV tenant files beyond the FY 23 audit sample of 86 and review them for the following compliance finding, to test: 1. Income calculations 2. 214 declarations for all members 3. ID documentation for all members 4. Unit inspections 5. Proof of dependents in Household August 30, 2024 Beth Ochs Rent Assistance Director
The Authority had instances of missing income verification, incorrect utility allowance and incorrect payment standard. Gardner Housing Authority has established a system of internal control over the participant recertification process that meets HUD’s requirements. Seven (7) to ten (10) files will ...
The Authority had instances of missing income verification, incorrect utility allowance and incorrect payment standard. Gardner Housing Authority has established a system of internal control over the participant recertification process that meets HUD’s requirements. Seven (7) to ten (10) files will be reviewed fiscally for quality assurance.
Finding 404721 (2023-003)
Significant Deficiency 2023
Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Federal Pell Grants Assistance listing #: 84.063 Award year: 2023 Corrective Action Plan: College Unbound has increased its administrative capacity and has implemented internal controls to properly monitor stude...
Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Federal Pell Grants Assistance listing #: 84.063 Award year: 2023 Corrective Action Plan: College Unbound has increased its administrative capacity and has implemented internal controls to properly monitor student enrollment status and recalculate Pell Grant awards as required by the Federal Government. We will continue to review these processes to mitigate any further redundancies or mistakes. Timeline for Implementation of Corrective Action Plan: Corrected. Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO
View Audit 311103 Questioned Costs: $1
The Housing Authority understands that our prior procedure was incorrect and inadequate for capital fund drawdowns. The Finance Director has been instructed on the proper procedure of capital fund drawdowns to first reconcile LOCCS requests to vendor billing to properly request and expend funds with...
The Housing Authority understands that our prior procedure was incorrect and inadequate for capital fund drawdowns. The Finance Director has been instructed on the proper procedure of capital fund drawdowns to first reconcile LOCCS requests to vendor billing to properly request and expend funds with the three-day period
The Housing Authority will execute the Depository Agreement with its financial institutions to ensure our banking accounts comply and that a Depository Agreement is in place. Any account that is not in compliance will be reviewed with the banking institution to ensure the bank accounts are following...
The Housing Authority will execute the Depository Agreement with its financial institutions to ensure our banking accounts comply and that a Depository Agreement is in place. Any account that is not in compliance will be reviewed with the banking institution to ensure the bank accounts are following the criteria required in the HUD-51999 Depository Agreement.
CORRECTIVE ACTION PLAN (CAP) Since the end of audit period 9/30/2023 the Richmond Redevelopment and Housing Authority (RRHA) has accomplished a series of activities to improve the quality and accuracy of tenant file information and has created Corrective Action Plans (CAP) for continuous improvement...
CORRECTIVE ACTION PLAN (CAP) Since the end of audit period 9/30/2023 the Richmond Redevelopment and Housing Authority (RRHA) has accomplished a series of activities to improve the quality and accuracy of tenant file information and has created Corrective Action Plans (CAP) for continuous improvement, as outlined below: FY 2023 Activity to date: RRHA requested a review of RRHA policies and procedures regarding rent collection and tenant file management from Nan McKay Consultants. Nan McKay issued a memorandum certifying compliance of the agency’s policies and procedures with all related HUD requirements. CAP: RRHA will update its Standard Operating Procedures regarding tenant file management to comply with Admission and Continued Occupancy and Administrative Plan revisions that were part of the agency’s Annual Plans. FY 2023 Activity to date: Staff attended a Nan McKay Consultants rent calculation training September 26-28, 2023. In addition, RRHA staff attended a six-week training course that included a two-week skills development. In addition, a Corporate Trainer position has been budgeted and will be filled early in the first quarter of FY2025. CAP: RRHA will ensure quarterly refresher training for current staff and comprehensive training for new staff. FY 2023 Activity to date: The RRHA created a Chief Compliance Officer Position that coordinates and reports on all RRHA compliance activities. CAP: The RRHA will develop a Standard Operating Procedure for that Compliance Office that will include more extensive quality control reviews and statistically significant Internal Audit reviews of tenant files. NAME OF RESPONSIBLE PERSON: Tonise Webb, Associate Lead Counsel and Chief Compliance Officer EXPECTED COMPLETION DATE FOR CORRECTIVE ACTION PLANS: September 30, 2024
Reference Number: 2023-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions HQS Enforcement Classification o...
Reference Number: 2023-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions HQS Enforcement Classification of Finding: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance The Authority has made significant progress in addressing the backlog of annual inspections since outsourcing the programmatic functions of the HCV program to third-party contractors. The Authority acknowledges that more progress in this area is required and continues to work diligently with the third-party HCV contractors to ensure this occurs. The Authority uses the Emphasys Elite software to schedule, record, and enforce HQS inspections. The Authority also uses its Customer Relations Management (CRM) system to track units that have failed an HQS inspection. The HCV contractors have implemented a daily review process of units that have failed and/or no-showed two or more consecutive inspections. The inspection department will use this process to accurately review the letter generation and notification process for HQS deficiencies and notices of abatement. The inspection department will manually review and generate both letters to their respective parties (landlord/owner and tenant). In addition to the daily morning review, at the close of business day, the HCV contractors will review the emergency failed inspections and will schedule any emergency re-inspections to ensure compliance with HQS enforcement rules and regulations. Anticipated Implementation Date September 30, 2024 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations
View Audit 311041 Questioned Costs: $1
Reference Number: 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspec...
Reference Number: 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections) Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance The Authority has made considerable progress in addressing the backlog of annual inspections that resulted from the implementation of HUD waivers during the national pandemic. The Authority acknowledges that more progress in this area is required and continues to work diligently with its third-party HCV contractors to ensure completion of this ongoing work. The Authority understands the importance of and is committed to ensuring all units under contract are beyond safe, sanitary, and decent in accordance with HQS requirements and the Authority's Administrative Plan. The Authority uses the Emphasys Elite software to check against HUD's PIH Information Center (PIC) system to identify units with outstanding Housing Quality Standards (HQS) Inspections. The Authority has scheduled HQS Inspections for the units identified to be out of compliance. Some key strategies and controls in place are as follows: Review the report of outstanding HQS Inspections on a weekly basis. Schedule outstanding HQS Inspections in order of aging date. Conduct HQS Inspections prior to anniversary date of previously completed inspection. Run a monthly report of failed inspections and compare them with future scheduled inspections to ensure that a second inspection has been scheduled. Run a monthly report to identify units with two failed inspections to ensure all have been abated correctly. Implement weekly monitoring to ensure all units are properly abated and lifted timely when units pass inspections and contracts are properly terminated after being in abatement for 180 days without a cure. During the pandemic, units were not inspected and legally permitted based upon available HUD regulations. As a result, the Authority has implemented a 100% Annual Inspection requirement for all contracted project-based vouchers (PBVs) and tenant-based vouchers (TBVs) units starting with the 10/1/2023 HUD Section Eight Management Assessment Program (SEMAP) Year. To that end, the HCV contractors have implemented a daily review process for all failed inspections to ensure timely rescheduling and will accurately note inspection extension requests exceeding the 30-day HQS enforcement requirement to bring a unit up to standard. Anticipated Implementation Date September 30, 2024 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations
View Audit 311041 Questioned Costs: $1
The PHA’s HQS enforcement sample of case files with failed HQS inspections shows that for at least 98% of sampled cases, HQS deficiencies were not corrected within the required time frame, the PHA did not stop housing assistance payments beginning no later than the first of the month following the...
The PHA’s HQS enforcement sample of case files with failed HQS inspections shows that for at least 98% of sampled cases, HQS deficiencies were not corrected within the required time frame, the PHA did not stop housing assistance payments beginning no later than the first of the month following the correction period and/or take prompt and vigorous action to enforce the family obligations. Due to the transition to a new software system, the required settings to facilitate necessary reporting and tracking mechanisms were not fully functional until recently. Reports indicating failed inspections, late inspections, and the need for abatements are now being run on a scheduled basis so that action can be taken timely. A new inspection application within the software has now been implemented to aid in recording and tracking deficiencies. Additionally, the PHA is working diligently with the software provider and a software consultant to determine if there are additional features that are able to be put into place to assist in streamlining the abatement process. Staff training for these new features will also be occurring throughout the year.
Finding 404195 (2023-002)
Significant Deficiency 2023
A new HUD lease will be prepared, presented, and signed at the time of the annual recertification for every tenant.
A new HUD lease will be prepared, presented, and signed at the time of the annual recertification for every tenant.
A new HUD lease will be prepared, presented and signed at the time of the annual recertification for every tenant.
A new HUD lease will be prepared, presented and signed at the time of the annual recertification for every tenant.
Criteria: According to PHA Accounting Brief #14, Due To/Due From relationships should not be reported under accrual accounting simply from the result of a PHA using a common checking or working capital account. Because of the basic nature of most Federal and state programs, resources from one progra...
Criteria: According to PHA Accounting Brief #14, Due To/Due From relationships should not be reported under accrual accounting simply from the result of a PHA using a common checking or working capital account. Because of the basic nature of most Federal and state programs, resources from one program cannot be used to support the cost of another program. HUD views Due To’s and Due From’s reported in a PHA ‘s Federal programs as possible indicators of noncompliance. Condition: The Authority has inter-fund receivables and payables that have not been repaid as of fiscal year-end. This results in certain programs having a negative cash balance as of the fiscal year end. Context: The Authority’s reported a material ($134,588 in total, $42,682 in HCV program) amount of interfund receivables and payables, which is a significant red flag for HUD reviewers. Management Response: Management has expanded its controls over cash reconciliations to include a step to verify whether a program, fund, or component unit is accurate along with the entire cash pool.
Criteria: Financial Data Schedule (FDS) submission for unaudited financials are due within 2 months after the fiscal year end (24 CFR section 5.801) Condition: Management missed the deadline for its unaudited REAC FDS submission. Context: The Authority’s unaudited FDS submission was due on Decembe...
Criteria: Financial Data Schedule (FDS) submission for unaudited financials are due within 2 months after the fiscal year end (24 CFR section 5.801) Condition: Management missed the deadline for its unaudited REAC FDS submission. Context: The Authority’s unaudited FDS submission was due on December 15th 2023. The Authority did not submit the submission until December 28th, 2023. Management Response: Management received guidance from HUD Chicago Office of Public Housing, that Section 8 only housing authorities have a 30-day grace period to submit unaudited FDS submission. Which is December 31st. In the future we will submit within the 15-day grace period.
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