Corrective Action Plans

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Oversight Agency for Audit, Evangeline Council Housing for the Elderly, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral S...
Oversight Agency for Audit, Evangeline Council Housing for the Elderly, Inc. respectfully submits the following corrective action plan for the year ended September 30, 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: October 1, 2022 through September 30, 2023 The findings from the September 30, 2023 schedule of findings and questioned costs are discussed below. The findings are 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 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure adequate funding of the security deposits account that equals or exceeds the corresponding security deposits liability. Action Taken: The Security Deposit liability is reconciled to the underlying report to ensure proper amounts are maintained. New procedures have been implemented to reconcile the Security Deposit Liability to cash funding.
1. Current Findings on the Schedule of Findings and Questioned Costs During the year ended December 31, 2023, Grand Manor Mutual Housing Association, Inc. distributed $115,000 in excess of surplus cash available for distribution. 2. Finding 2023-001 a. Comments on the Finding and Each Recommendation...
1. Current Findings on the Schedule of Findings and Questioned Costs During the year ended December 31, 2023, Grand Manor Mutual Housing Association, Inc. distributed $115,000 in excess of surplus cash available for distribution. 2. Finding 2023-001 a. Comments on the Finding and Each Recommendation The funds were repaid too soon. b. Action(s) Taken or Planned on the Finding Our action plan includes documentation, management approval, and will remedy the problem going forward. Advances are to be recorded in a liability account that doesn’t roll up into the AP module. This will eliminate paying advances in error. The payment is only moved into the AP module, for processing, after we determine we have excess cash and have the appropriate supporting documentation and approval. Surplus cash can only be calculated semi-annually and at year-end. If the calculation reflects excess cash, we must make payment within 90 days.
View Audit 305890 Questioned Costs: $1
Name of contact person – Angela Riley, CFO Corrective action – The Corporation agrees with the finding and has continued to implement strategies to address these issues throughout 2023, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in co...
Name of contact person – Angela Riley, CFO Corrective action – The Corporation agrees with the finding and has continued to implement strategies to address these issues throughout 2023, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations. Proposed completion date – Management has begun the corrective action and is expected to have additional internal control and training done by December 31, 2024.
Name of contact person – Angela Riley, CFO Corrective action – The Corporation agrees with the finding and should return the incentive performance fee to the organization. Employees should be reminded of the M2M program requirements and conditions for making incentive performance fee payments. Pro...
Name of contact person – Angela Riley, CFO Corrective action – The Corporation agrees with the finding and should return the incentive performance fee to the organization. Employees should be reminded of the M2M program requirements and conditions for making incentive performance fee payments. Proposed completion date – Management has begun the corrective action and the incentive performance fee has been repaid to the Organization as of March 22, 2024.
View Audit 305779 Questioned Costs: $1
Management has reviewed the policies and procedures surrounding replacement reserve deposits and will ensure personnel are trained to follow the policies and procedures. Management will review required funding's to funding's made and ensure there are no deficiencies.
Management has reviewed the policies and procedures surrounding replacement reserve deposits and will ensure personnel are trained to follow the policies and procedures. Management will review required funding's to funding's made and ensure there are no deficiencies.
View Audit 305768 Questioned Costs: $1
Grant Program: Department of Housing and Urban Development HUD Counseling Program – Assistance Listing #14.169 Description of Deficiency: It is noted that NWMT failed to report subawards greater than $30,000 under the Federal Funding Accountability and Transparency Act (FFATA) and is considered non...
Grant Program: Department of Housing and Urban Development HUD Counseling Program – Assistance Listing #14.169 Description of Deficiency: It is noted that NWMT failed to report subawards greater than $30,000 under the Federal Funding Accountability and Transparency Act (FFATA) and is considered noncompliance as of September 30, 2023. Corrective Action Proposal: NWMT will complete the reporting of the required pass through payments to subrecipients subject to FFATA reporting in the FY23 amount of $201,484. NWMT will also implement the necessary updated procedures to ensure all subrecipients subject to FFATA reporting are properly reported for any further federal awards through the HUD Counseling Program at time of award. Individual(s) Responsible for Corrective Action: Hanna Tester (Homeownership Director) and Kaia Peterson (Executive Director) Corrective Action to be Completed by: All required subjects from 10/1/2022 to present will be properly reported within the Federal Subaward Reporting System no later than June 30, 2024.
Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management will monitor security deposit refunds in order to ensure refunds meet the Regulatory Agreement requirements.
Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management will monitor security deposit refunds in order to ensure refunds meet the Regulatory Agreement requirements.
Finding 396055 (2023-004)
Significant Deficiency 2023
The Department of Labor and Workforce Development (DLWD) continues to monitor all first payment and non-monetary time lapse figures in order to meet the established USDOL Acceptable Levels of Performance (ALP). As workloads return to normal levels after the increased activity from the COVID-19 pand...
The Department of Labor and Workforce Development (DLWD) continues to monitor all first payment and non-monetary time lapse figures in order to meet the established USDOL Acceptable Levels of Performance (ALP). As workloads return to normal levels after the increased activity from the COVID-19 pandemic related claims, greater emphasis will continue to be placed on meeting all ALPs. Specifically relating to first payments and the previously discussed issues with claimants verifying their identity before any payments can be made, the DLWD has made some internal changes to how returned verified IDs from our ID verification partner (ID.me) are handled. These modifications to the internal process used to clear verified IDs are expected to have a positive impact on overall time lapse numbers as verified claimants will not be delayed longer than they previously were under the old process. The month of April starts the new reporting year for these figures to USDOL and New Jersey expects to see significant increases to first payment and non-monetary time lapse figures by the third quarter of calendar year 2024. COMPLETION DATE/ CONTACT PERSON September 2023 Theresa Vallely (609) 984-1779 Theresa.Vallely@dol.nj.gov
The Department of Labor and Workforce Development (DLWD) has controls in place to only allow an FPUC payment to be made when an underlying Unemployment Insurance (UI) payment has also been processed. FPUC payments should not be issued to any claim without the underlying UI payment being made for th...
The Department of Labor and Workforce Development (DLWD) has controls in place to only allow an FPUC payment to be made when an underlying Unemployment Insurance (UI) payment has also been processed. FPUC payments should not be issued to any claim without the underlying UI payment being made for the same week. The FPUC payments issued and noted as exceptions during eligibility testing will be reviewed independently by DLWD to determine if the payments issued were to eligible recipients or not. For the PUA exceptions noted during Eligibility testing, overall the DLWD issued PUA payments to over 680,000 claimants during the COVID-19 pandemic. DLWD had controls in place to require a COVID related reason to make the claim PUA eligible and the weekly PUA certification required claimants to choose a COVID related reason for why they were out of work before they could get paid. The PUA payments in question will be reviewed independently by the DLWD to determine if the payments issued under PUA were appropriate or if they should have been paid instead under the regular UI program. DLWD corrective actions related to FPUC and PUA payments were fully implemented as of September 2023. COMPLETION DATE/ CONTACT PERSON September 2023 Theresa Vallely (609) 984-1779 Theresa.Vallely@dol.nj.gov
View Audit 305672 Questioned Costs: $1
The security deposit was refunded to the tenant on the 44th day subsequent to their move-out. Management has taken measures to improve internal controls over compliance related to tenant security deposit refunds.
The security deposit was refunded to the tenant on the 44th day subsequent to their move-out. Management has taken measures to improve internal controls over compliance related to tenant security deposit refunds.
Management acknowledges noncompliance in the current fiscal year and has addressed all of the health and safety issues as of April 18, 2023
Management acknowledges noncompliance in the current fiscal year and has addressed all of the health and safety issues as of April 18, 2023
Federal Agency: Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Award Period: January 1, 2023 – December 31, 2023 Compliance Requirement Section: Special Provisions Type of Finding: Significant Deficiency in Inter...
Federal Agency: Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Award Period: January 1, 2023 – December 31, 2023 Compliance Requirement Section: Special Provisions Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that the HRA keep a list of properties that have inspections and complete the required re-inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will ensure the necessary re-inspections are completed.
2023-001 – Deposit of Surplus Cash into a Residual Receipts Account Corrective Action Plan No later than 90 days past the end of the fiscal year, we will identify surplus cash in the project funds account and deposit into the residual receipts account. Person(s) Responsible: Greg Shinn, Agency CP...
2023-001 – Deposit of Surplus Cash into a Residual Receipts Account Corrective Action Plan No later than 90 days past the end of the fiscal year, we will identify surplus cash in the project funds account and deposit into the residual receipts account. Person(s) Responsible: Greg Shinn, Agency CPA Timing for Implementation: Immediate
Finding Number: 2023-001. Condition: The Corporation failed to make the required reserve for replacements deposits in the current fiscal year. The Corporation made 3 deposits, a suspension was approved for 5 months, therefore 4 months were underfunded. Planned Corrective Action: Management acknowled...
Finding Number: 2023-001. Condition: The Corporation failed to make the required reserve for replacements deposits in the current fiscal year. The Corporation made 3 deposits, a suspension was approved for 5 months, therefore 4 months were underfunded. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year due to cash flow shortages at the property. Management is seeking to obtain HUD approval for the remaining underfunded amount of $23,200, and if not approved will deposit the required amount during fiscal year ended August 31, 2024. Contact person responsible for corrective action: Jill Kolb, Vice President Housing Accounting Anticipated Completion Date: August 31, 2024
Finding 395924 (2023-001)
Significant Deficiency 2023
HARTFORD VILLAGE HUD PROJECT NO. 044-38023 CORRECTIVE ACTION PLAN Hartford Village respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended December 31, 202...
HARTFORD VILLAGE HUD PROJECT NO. 044-38023 CORRECTIVE ACTION PLAN Hartford Village respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended December 31, 2023 Corporation Contact Person: Bruce Blalock, Director at Management Agent The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding – Federal Award Findings and Questioned Costs Finding 2023-001: Considered a significant deficiency in internal control over compliance. Recommendation: The HUD-prescribed percentage of rental and other receipts used to calculate management fees should be adjusted after changes to rent rates to ensure that the management fees charged are under the per-unit-permonth amount outlines in the management agent certification. Action to be Taken: The Organization concurs with the facts of this finding, and will pay back the $8,928 to the organization in the 2024 audit year.
Finding Reference Number: 2023-003 Statement of Concurrence or Nonconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2023-003. Corrective Action: To ensure supporting documents are maintained to support all HUD-52722 forms, all privately managed ...
Finding Reference Number: 2023-003 Statement of Concurrence or Nonconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2023-003. Corrective Action: To ensure supporting documents are maintained to support all HUD-52722 forms, all privately managed Mixed-Finance developments will submit utility cost and consumption data to include copies of invoices to LMHA monthly. Utility cost and consumption data to include copies of invoices are already collected by LMHA managed sites. Name of Contact Person: Jeff Ralph, Director of Finance, 502-569-4372, ralph@lmha1.org Projected Completion Date: Louisville Metro Housing Authority is actively working with third party managers to ensure that LMHA receives, on a monthly basis, the utility invoices that support the HUD-52722 forms and maintaining the documentation on LMHA network servers along with a secondary review of all HUD-52723 and HUD 52722 forms prior to annual submission to HUD /Secure Systems/Public Housing Portal (PIH Operating Fund). QUESTIONED COSTS Undeterminable per Cherry Bekaert If the (Office of Policy and Management and/ or Oversight Agency) has questions regarding this Plan, please call Jeff Ralph at 502-569-4372.
Finding Reference Number: 2023-002 Statement of Concurrence or N onconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2023-002. Corrective Action: To verify that the hours charged by maintenance staff are reasonable, Central Maintenance superviso...
Finding Reference Number: 2023-002 Statement of Concurrence or N onconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2023-002. Corrective Action: To verify that the hours charged by maintenance staff are reasonable, Central Maintenance supervisors/coordinators will verify the accuracy of the hours recorded to work orders completed. Questionable hours will be reviewed and corrected when appropriate. The report will then be submitted to Finance to be charged to Public Housing development. The Finance Department will perform an additional review for reasonableness prior to posting. Name of Contact Person: Greg Crum, Director of Property Management, 502-569-3416, crum@lmhal.org Projected Completion Date: Louisville Metro Housing Authority implemented the corrective action measure in April 2024. LMHA will monitor the issue on a monthly basis in conjunction with its month end accounting close process to ensure compliance with the special fees charged in related party transactions. QUESTIONED COSTS All costs were corrected and fees were reversed. If the (Office of Policy and Management and/ or Oversight Agency) has questions regarding this Plan, please call Jeff Ralph at 502-569-4372.
View Audit 305538 Questioned Costs: $1
Finding Reference Number: 2023-001 Statement of Concurrence or N onconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2023-001. Corrective Action: LMHA has implemented a comprehensive plan to resolve the backlog of recertifications that necessita...
Finding Reference Number: 2023-001 Statement of Concurrence or N onconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2023-001. Corrective Action: LMHA has implemented a comprehensive plan to resolve the backlog of recertifications that necessitated the roll forward of tenant's prior year form HUD-50058 family report without updating family income and composition. First and foremost, representing the rolling forward of the tenant's HUD-50058 as a biennial recertification has been discontinued. Compliance staff has implemented training of Housing Specialists and other staff to assure biennial recertification and use of HUD-50058 Type 2 ("Annual Recertification") will now be compliant. LMHA has contracted with a vendor to assist with the recertification process. LMHA has also restructured workflows to provide efficiencies and accountability that will promote compliance. LMHA is also working with various HUD departments and personnel to assess noncompliance and how to move forward. In addition to resolving these issues with HUD, LMHA has engaged its Financial Auditor, Cherry Bekaert, to review the Housing Choice Voucher Program for process, compliance, and internal control. Name of Contact Person: Sarah Galloway, Special Assistant to the Executive Director, 502-569-3422, galloway@lmhal.org Projected Completion Date: Louisville Metro Housing Authority implemented the corrective action measure in March 2024. LMHA will monitor the issue on a monthly basis to ensure compliance with the HCV program. QUESTIONED COSTS Undeterminable per Cherry Bekaert If the (Office of Policy and Management and/or Oversight Agency) has questions regarding this Plan, please call Jeff Ralph at 502-569-4372.
Finding No. 2023-002; Federal Assistance Listing Number 14.181 Statement of Condition: The Company did not respond to HUD to indicate that the exigent health and safety deficiencies were resolved in connection with the physical inspection conducted on July 25, 2023 timely. Corrective Action: R...
Finding No. 2023-002; Federal Assistance Listing Number 14.181 Statement of Condition: The Company did not respond to HUD to indicate that the exigent health and safety deficiencies were resolved in connection with the physical inspection conducted on July 25, 2023 timely. Corrective Action: REACH has policies in place to respond to the REAC inspections in a timely manner but due to staffing shortages had issues with timely completion of the filing in 2023. Staff will receive additional assistance to the ensure the property is in compliance.
Finding 2023-001; Federal Assistance Listing Number 14.181 Statement of Condition: In connection with our lease file review, we noted that for one out of three tenants EIV was not performed timely. Corrective Action: REACH has policies in place to complete certifications in a timely manner but ...
Finding 2023-001; Federal Assistance Listing Number 14.181 Statement of Condition: In connection with our lease file review, we noted that for one out of three tenants EIV was not performed timely. Corrective Action: REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2023. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Additional procedures have been implemented in 2023 to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.
Finding 2023-001– Federal Assistance Listing Number 99.999 Statement of Condition: In connection with our lease file testing: 1. one out of three tenant files tested did not have a recertification performed timely. 2. one out of three tenant files tested did not have 3rd party income verificatio...
Finding 2023-001– Federal Assistance Listing Number 99.999 Statement of Condition: In connection with our lease file testing: 1. one out of three tenant files tested did not have a recertification performed timely. 2. one out of three tenant files tested did not have 3rd party income verifications to support tenant income on the HUD 50059. Corrective Action: REACH has policies in place to complete certifications in a timely manner and ensure income support is received for income certifications. Due to staffing shortages and tenant noncompliance issues the property had issues with compiling the necessary information to complete the income certifications in 2023. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Additional procedures have been implemented in 2023 to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance
Finding 2023-001 - Federal Assistance Listing Number 14.157 Statement of Condition: In connection with our lease file review we noted: - two out of three tenants did not have a recertification performed timely - one out of four tenants did not have income verification with the use of the HUD E...
Finding 2023-001 - Federal Assistance Listing Number 14.157 Statement of Condition: In connection with our lease file review we noted: - two out of three tenants did not have a recertification performed timely - one out of four tenants did not have income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. Corrective Action: REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2023. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Additional procedures have been implemented in 2023 to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.
Finding 2023-001– Federal Assistance Listing Number 14.157 Statement of Condition: In connection with our lease file review we noted that two out of three tenants did not have an EIV performed timely. Corrective Action: REACH has policies in place to complete certifications in a timely manne...
Finding 2023-001– Federal Assistance Listing Number 14.157 Statement of Condition: In connection with our lease file review we noted that two out of three tenants did not have an EIV performed timely. Corrective Action: REACH has policies in place to complete certifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2023. As new staff are brought onboard training is provided and annual HUD training is completed by all staff. Additional procedures have been implemented in 2023 to coordinate and provide assistance to on-site staff to ensure that the properties are in compliance.
Finding 2023-004 – Federal Assistance Listing Number 14.239 Statement of Condition: During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspecti...
Finding 2023-004 – Federal Assistance Listing Number 14.239 Statement of Condition: During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Corrective Action: REACH has policies in place to ensure that HQS inspections are done in a timely manner. Staffing shortages at the property had an impact on the completion of HQS inspections in 2023. As new staff are brought onboard training is provided and additional training will be provided to on-site staff to ensure that the inspections are being completed and properties are in compliance.
Finding 2023-003 – Federal Assistance Listing Number 14.157 Statement of Condition: In connection with our lease file testing one out of one move-out tenant files tested did not have a security deposit refunded timely or a move out inspection on file. Corrective Action: REACH has policies in ...
Finding 2023-003 – Federal Assistance Listing Number 14.157 Statement of Condition: In connection with our lease file testing one out of one move-out tenant files tested did not have a security deposit refunded timely or a move out inspection on file. Corrective Action: REACH has policies in place to ensure that move out inspections and the return of tenant security deposits are done in a timely manner. Staffing shortages at the property had an impact on the timeliness of the move out inspection and the return of security deposits. As new staff are brought onboard training is provided and additional training will be provided to on-site staff to ensure that the inspections and the return of security deposits are being completed and properties are in compliance.
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