Corrective Action Plans

Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The new grants policy will be reviewed and approved by the City Manager and implemented by March 2025. Planned Implementation Date: March 2025 Responsible Person(s): City Manager

Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The HR and payroll policies will be updated to incorporate the above recommendations. Planned Implementation Date: March 2025 Responsible Person(s): City Manager

2022-004 – REPORTING Material Weakness/noncompliance Auditee’s Response and Planned Corrective Action See auditee’s response to Finding 2022-001 Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

2022-003 – ELIGIBILITY Material Weakness/noncompliance Auditee’s Response and Planned Corrective Action The Windsor Housing Authority currently contracts with J.D. A’melia for all Housing Choice Voucher Program services. HCV staff have a broad range of duties covering activities from application, waitlist management, initial briefing for new participants, resident processing through termination of assistance. They will also perform all property activities related to compliance with WHA’s lease for all our properties and they will have extensive contact with landlords and tenants participating in the HCV programs. More specifically, HCV staff responsibilities include but are not limited to:  Lease-ups including new tenant orientation Monthly close-out  Waitlist Management Administrative & clerical functions  Inspection coordination Processing applications  Annual and interim recertification HUD reporting  Landlord services Determining eligibility  Direct deposit set-up EIV  Calculations & payment authorization to landlords & tenants admin fees calculation and payment Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

FINDING 2022-003 Finding Subject: CDBG – Entitlement Grants Cluster—Program Income Summary of Finding: Condition and Context: The County received program income through various loan programs it offered to qualifying individuals. Once the County received a loan payment, the receipt was posted into the financial accounting system of the County and recorded in a grant fund. The amount received was also to be recorded in the Department of Housing and Urban Development’s (HUD) Integrated Disbursement & Information System (IDIS) website. The recorded program income in IDIS would then appear on the Drawdown Report by Voucher Number report (PR07). No internal control process had been established over the program income compliance requirement. One individual was responsible for notifying the Auditor's office when program income money was received, in order for it to be receipted in the County’s financial accounting system. The same individual was also responsible for reporting the same on IDIS site. No controls were established to ensure the program income that was recorded in the financial accounting system was also reported on IDIS site and the PR07 report. Additionally, four receipts totaling $38,960 were selected for testing from the County’s receipt ledger. These four receipts were unable to be located on the PR07 report provided for audit. One of the four receipts was recorded in the IDIS system after information regarding the receipt was requested. The receipt was not in the PR07 report that had been provided for audit when we were provided information documenting it being recorded in IDIS. Furthermore, we were unable to verify the total amount recorded in receipt ledger to the total reported on PR07 report. The County’s ledger was greater than the PR07 report by $30,324 and is primarily attributed to under reporting of program income in IDIS as identified above. Recommendation: We recommended that the management of the County establish a system of internal controls to ensure that all program income received is properly reported in the IDIS system and expended prior to drawing down federal awards. Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 and brownta@lakecountyin.org Views of Responsible Officials: LCCEDD concurs with the audit finding. LAKE COUNTY COMMUNITY ECONOMIC DEVELOPMENT DEPARTMENT 2293 N. Main Street - Crown Point, In 46307 Tel. (219) 755-3225 www.lakecountyin.org INDIANA STATE BOARD OF ACCOUNTS 36 Description of Corrective Action Plan: LCCEDD staff have already adopted changes in internal controls to correct the Program Income reporting deficiencies. The process is as follows: 1. All incoming checks into the department are first reviewed by the Deputy Director. The Deputy Director determines the source of income (i.e. CDBG, HOME, NSP) and the correct receipt type (program income, repayment, homebuyer). The Deputy Director records the IDIS number of the project on the check before giving it to the Fiscal Officer. 2. The Fiscal Officer records the receipt on an internal schedule of receipts and submits the check to the County Auditor with the check deposit form with the IDIS number and correct fund and account number for deposit. 3. Once the County Auditor posts the receipt to the County’s general ledger, the Fiscal Officer records the Auditor’s receipt into HUD’s IDIS Online reporting system. 4. At the close of each quarter, the Fiscal Officer will prepare and submit the Cash on Hand Report within thirty days of the close of the quarter. The Fiscal Officer will reconcile all expenses and receipts posted in the County’s general ledger system with the receipts (report PR09) and drawdown requests (report PR07) in HUD’s IDIS Online reporting system. Before submitting the Cash on Hand Report in the IDIS Online system, the Deputy Director will review and approve the prepared reconciliation and Cash on Hand Report. Any discrepancies between the two systems will be reported to the Auditor and the Department Director to determine corrective actions. 5. Within 30 days of the close of each calendar quarter, the Fiscal Officer will submit the Cash on Hand Report via IDIS Online. The Fiscal Officer will maintain a copy of the Cash on Hand report and the corresponding reconciliation in their program files. 6. On an on-going basis, the Director will meet with Department staff to determine if training or technical assistance is needed to complete HUD reporting requirements in a timely and accurate manner. Anticipated Completion Date: A policy and procedure amendment will be written by the end of this year and presented to the Lake County Redevelopment Commission for their March 2025 meeting for adoption.

Finding 2022-016 U.S Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Management’s Response: Management agrees it is critical to ensure spending occurs within the applicable expenditure periods. In the new financial management system (Workday), we have established parameters to fence the applicable expenditure periods. Further we are making gains to close out awards to further disallow spend outside the applicable expenditure periods. There was departmental turnover within the department at the end of 2022 with a loss of knowledge transfer during the change in personnel. Views of Responsible Officials and Corrective Action: With the aid of technology available through our new ERP system, management plans to enhance operations by having training documents and processes for various awards so as personnel attrition occurs there is continuity in processes. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Finding 2022-015 U.S Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Management’s Response: Management agrees that the matching component should be tracked to ensure compliance with the terms of the award. Views of Responsible Officials and Corrective Action: With our new ERP system, in the grant/award module, the Unified Government of Wyandotte County & Kansas City KS are working with departments to establish match components and trackable spend items to enhance compliance with award terms. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

2022-005 Condition: Deficiencies Noted in Our Examination of Emergency Rental Assistance (ERA) Files Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2024

2022-003 Condition: Deficiencies Noted in Maintenance of the Cash Receipts and Deposits and the Tenant Accounts Receivable Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2024

2022-002 Condition: Deficiencies Noted in Cash Disbursements Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2024

2022-001 Condition: Deficiencies Noted in Maintenance of Tenant Files Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2024

Finding No. 2022-005 KCHC disagrees with the finding that it is in noncompliance with the applicable period of performance requirements. The sample request was received after the August 19 meeting with the CEO and board representative, during which it was noted that no further samples would be accepted as the audit had extended beyond one year. The delays were due to staffing challenges both on the part of the auditor and within KCHC. In FY 2025, KCHC has started the following corrective actions ensuring that all records are systematically filed and digitized for easy retrieval, regardless of changes in staff. This new system allows for seamless access to documents and a clear audit trail: 1. DocuSign for Document Management: In FY2025, KCHC adopted DocuSign to facilitate the management of financial documents. While DocuSign does not automatically upload supporting documents to the accounting software, it provides an efficient way to manage approvals and ensure an audit trail. After approval, the assigned accountant is responsible for manually uploading the supporting documents into the accounting software to ensure they are properly recorded and retrievable for audit purposes. 2. Timely Upload and Filing of Documentation: To address the delays, KCHC has updated its procedures requiring that all financial staff upload supporting documents at the time of expenditure approval or payment. This process will ensure that no documentation is missing or delayed, and all records are maintained in compliance with federal guidelines. 3. Ongoing Monitoring and Reporting: The CFO will oversee quarterly internal audits to ensure that the enhanced recordkeeping system is functioning effectively and that all expenditures continue to comply with the period of performance requirements. Progress will be reported to the Board of Directors to ensure transparency and ongoing compliance. By taking these corrective actions, KCHC will ensure that all expenditures are supported by proper documentation, uploaded timely, and readily available for audit review, preventing any future delays or compliance issues. Implementation Timeline: Completed as of August 31, 2024 with continued updates and monitoring. Responsible person: Arlene Deleon Guerrero, CFO

Finding No. 2022-003 KCHC agrees with the finding and understands the importance of maintaining robust recordkeeping and documentation procedures to comply with federal cost principles. We acknowledge the discrepancies noted in the audit findings regarding non-payroll expenditures. To address these issues, KCHC has implemented the following actions: • Strengthening Documentation Controls: KCHC has reinforced its recordkeeping procedures, requiring that all expenditures be fully supported by accurate documentation before approval. The accounting department has implemented additional review layers to ensure that all supporting documents, including receipts and invoices, are properly matched and retained. • Enhanced Training for Staff: Staff responsible for processing and documenting expenditures have undergone training to improve awareness of federal cost principles and documentation requirements. This training will ensure that all expenditures are supported by accurate, complete, and timely documentation. • Monitoring and Oversight: KCHC has introduced regular internal audits to monitor compliance with documentation standards. These audits will help identify any potential discrepancies early and ensure timely corrective action. Implementation Timeline: KCHC began implementation of these changes in FY 2025 under the CFO. The organization remains confident that these measures will address the audit findings and improve compliance with 2 CFR section 200.403(e). KCHC is committed to maintaining the highest standards of financial management and accountability. Responsible person: Arlene DeleonGuerrero, CFO

Other- Significant Deficiency in Internal Control over Compliance with respect to record retention Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that management continue to recruit for staff to fill the needed positions in the finance department as they continue to grow. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Organization is actively seeking to hire additional staffing for the finance department. It has currently been operated on a parttime basis and our growth has exceeded that capacity. Name of the contact person responsible for corrective action: John C. Jones, President and CEO Planned completion date for corrective action plan: December 31, 2024 If the U.S. Department of Treasury has questions regarding this plan, please call John C. Jones at 419- 720-4281.

Reporting Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that reports are prepared and reviewed by separate individuals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Organization will add a layer of review for the prepared reports prior to submission to the grantor. Name of the contact person responsible for corrective action: John C. Jones, President and CEO Planned completion date for corrective action plan: October 31, 2024

Finding 2022-005 -Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: We take this matter seriously and are committed to addressing and rectifying the identified issues. 1. Immediate Corrections: We have initiated immediate corrective actions to rectify the inaccuracies and deficiencies found in the waitlist. Our team is working diligently to update and maintain an accurate waitlist to ensure transparency and fairness in our processes. 2. Training and Awareness: Recognizing the importance of proper waitlist management, we are implementing additional training for relevant staff members involved in the waitlist maintenance process. This training will emphasize the importance of accuracy, timely updates, and compliance with organizational policies. 3. Enhanced Monitoring and Oversight: We are strengthening our internal monitoring mechanisms to ensure ongoing compliance with waitlist maintenance protocols. This includes implementing regular audits and reviews to identify and address emerging issues promptly. 4. Communication with Stakeholders: We understand the importance of transparent communication. We will inform CMS of the corrective measures implemented through our MOR finding correction response. We are committed to continuous improvement and appreciate the opportunity to enhance our processes based on your audit findings.

Finding 2022-004 -Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: We appreciate the audit team's diligence in reviewing our financial processes and acknowledge the finding related to the untimely reserve deposit. 1. Explanation: Example: "The delay in making the reserve deposit was primarily due to management not fully understanding HUD fund authorization per the HUD Handbook 4350. 2. Corrective Actions Taken: We have taken the following corrective actions: All reserve funds have been deposited in the appropriate reserve accounts at our bank. We have implemented a revised deposit schedule that will deposit reserve funds as required after receipt of direct deposit voucher payment from CMS. 3. Preventive Measures: To prevent a recurrence of this issue, we have instituted additional preventive measures, including producing monthly financial reports showing the deposits in a bank reconciliation line of the item and on the balance sheet. 4. Commitment to Compliance: We uphold the highest financial responsibility and compliance standards. Moving forward, we will remain vigilant to ensure timely reserve deposits and will continue to prioritize adherence to all relevant regulations and internal policies.

Finding 2022-003 Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: Explanation: We acknowledge the oversight and would like to provide context to understand better the circumstances that led to the delay. We had internal challenges when our previous management company departed, leaving us with incomplete files and late recertifications or recertifications that never started, making it next to impossible to catch up promptly. Next, staff staffing issues contributed to the delays because staff members were not properly trained. Despite these challenges, we recognize the importance of adhering to HUD regulations and are committed to taking corrective measures. Corrective Actions Taken: We initiated immediate corrective actions to rectify the situation upon discovering the late recertifications. We have instituted the following measures to prevent the recurrence of late annual recertifications: 1. Created a recertification schedule and calendar with the annual recertification date, specific dates to notify residents that their annual recertification is due, and dates for submitting the information to CMS and to trac. The schedule and calendar are submitted to the executive director every two weeks to monitor progress, and a meeting is scheduled with staff every two weeks to review recertification issues. 2. We hired a consultant specializing in recertification to train the staff and work with staff daily to answer questions concerning our certification. Our recertification consultant is permanently on call to answer certification issues and continuous staff training. These measures are designed to ensure timely compliance with HUD regulations and to strengthen our internal processes.

Finding 2022-002 Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: Reviewing the audit report, we acknowledge discrepancies in our income calculation and verification processes. We understand the critical importance of accurate income assessments in determining HUD HAP eligibility and share your commitment to maintaining the program's integrity. To rectify the identified issues, we have initiated the following corrective actions. 1. Review and Update Procedures: We have thoroughly reviewed our existing income calculation and verification procedures. Based on this review, we are revising and updating our procedures to ensure compliance with HUD regulations and guidelines. 2. Staff Training: Recognizing the importance of well-trained staff in accurately executing income verification processes, we are implementing a comprehensive training program. This program will cover HUD guidelines, income calculation methods, and verification protocols to enhance the skills of our staff involved in the eligibility determination process. 3. Internal Audits and HUD Compliance Control: We are implementing an internal audit and compliance control program to regularly review and assess our income calculation and verification This proactive approach will help identify and address potential issues before they escalate. We have hired an outside consultant skilled in HUD compliance to review all new applications for compliance and to communicate with staff the corrections needed before tenant applications are submitted to CMS and Trac for final approval and payment. 4. Enhanced Documentation: We understand the significance of maintaining detailed and accurate documentation. Our organization is implementing measures to enhance documentation practices, ensuring that all relevant information is recorded and readily available for audit purposes. By doing this, we assure you that this will not be a repeat finding. 5. Communication and Collaboration with HUD: We are committed to maintaining open lines of communication with the HUD office. Any changes to our procedures, policies, or protocols related to income calculation and verification will be promptly communicated to the HUD office for review and feedback. We aim to ensure that our organization fully complies with HUD requirements and that we continue to provide accurate and reliable information for HAP eligibility.

Condition 2: The Authority did not submit its audited financial statements to the Federal Audit Clearinghouse and to REAC by the required due dates. Corrective Action 2: The Authority has retained an accounting firm to serve as a fee accountant. Our fee accountants will complete the unaudited Financial Data Schedule submission and provide workpapers to the auditors to enable a timely audited submission. Completion Date: September 30, 2023

View of Responsible Officials and Planned Corrective Action This finding relates to the late deposit of the required amount to the Replacement for Reserve as required by HUD. The late deposits were due to the timing of cash flows and the deficiency of cash available to make the deposit. The property manager is in the process of working with HUD to increase rents and make the property more financially self-sufficient. The late deposits were made to the Replacement for Reserve before the end of the Organization’s year end, September 30, 2022. Therefore, no further corrective action plan is deemed necessary at this time.

Phillips County Housing Authority respectfully submits the following corrective action plan for the year ended December 31, 2022. Contact person responsible for corrective action: Ms. Edna Turner, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Audit period: Year ended December 31, 2022 Oversight Agency: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing No. 14.871 Housing Choice Voucher 2022-001 Tenant Files 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 the thirty-seven files revealed the following deficiencies: 1. One file lacked proper utility allowance documentation. 2. One file revealed an incorrect Housing Assistance Payment. 3. One file in which a lease and housing assistance payment contract was not executed. Recommendation for Corrective Action: A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Responsible Official’s Response: We will comply with the auditor’s recommendation. We continue to strive to eliminate any deficiencies in this area. We have instituted checklists and review procedures to preclude any errors in documentation. Anticipated Completion Date: November 1, 2023

The management overseeing the process has been completely replaced to ensure a fresh perspective and unwavering dedication to implementing robust internal controls. To address the shortcomings identified in Finding 2022-003, the Authority commits to a targeted action plan aimed at ensuring timely compliance with reporting requirements. Central to our approach is the engagement of a fee accountant, recognized for expertise in HUD reporting and public housing financial management. This specialist will be tasked with overseeing and streamlining our reporting processes. By leveraging this expertise, we aim to quickly rectify past reporting lapses and ensure future submissions are timely and compliant with HUD requirements. The new fee accountant will conduct a comprehensive review of our current reporting mechanisms, identify bottlenecks, and implement best practices tailored to our operations. This decisive action, centered around the expertise of the newly appointed fee accountant, demonstrates our commitment to enhancing our financial management practices and aligning with HUD's reporting expectations. Through these measures, we anticipate not only meeting HUD's deadlines but also setting a new standard for operational excellence within our Authority.

n response to this finding regarding non-compliance in Housing Quality Standards (HQS) enforcement, the new management team at the Authority has developed a focused corrective action plan. This plan includes comprehensive staff training on HUD regulations and HQS compliance, with a completion target of September 2024. Concurrently, our CEO will oversee the revision and implementation of enhanced HQS monitoring procedures, aiming for completion by September 2024. This involves updating inspection protocols, instituting regular internal audits for compliance, and establishing clear procedures for re-inspections, HAP abatement, and voucher cancellations. Recognizing the oversight of the previous management, the new team is committed to rectifying these issues and ensuring ongoing compliance. We will maintain thorough documentation of all actions taken and provide regular updates on the progress. The HCV Coordinator will be responsible for ongoing compliance monitoring and reporting, ensuring that the program adheres to HUD's Housing Quality Standards and effectively serves its participants. This approach reaffirms our dedication to upholding the integrity and effectiveness of the Housing Voucher Cluster programs

Finding Number: 2022-009 Planned Corrective Action: Monthly financial statements are now completed to ensure evidence for each entity. The staff in finance is working on more timely audits. Anticipated Completion Date: September 2024 Responsible Contact Person: Sherrie Boudinot