Corrective Action Plans

Finding Number: 2022-008 Planned Corrective Action: AMHA is now in contract with the Nelrod company to do our Rent Reasonableness. Anticipated Completion Date: June 2024 Responsible Contact Person: Zackary Dye/Erica Flanders

Finding Number: 2022-007 Planned Corrective Action: The previous director processed payroll using one program (one time). The Finance Director & Accounting Assistant always allocate between properties at the approved amounts. The Director/Finance Director will review all payroll. Anticipated Completion Date: January 1, 2023 Responsible Contact Person: Sherrie Boudinot

Finding Number: 2022-006 Planned Corrective Action: The Executive Director no longer performs any accounting duties. An accounting firm was hired to bring everything up to date and an Accounting Assistant was hired. A new Fiscal Procedures Manual has been approved by the board. Only one Housing Assistance Payment bank account is now used; fraudulent checks were written out of the “general account” that checks are not normally written from, this account has been closed. Anticipated Completion Date: January 1, 2023 Responsible Contact Person: Sherrie Boudinot

Finding Number: 2022-005 Planned Corrective Action: AMHA and our accounting firm are working diligently to meet deadlines. Completed bank recs and financial documents are finished more timely. Anticipated Completion Date: January 1, 2023 Responsible Contact Person: Sherrie Boudinot

Finding Number: 2022-004 Planned Corrective Action: AMHA has contracted with the Inspection Group and is also working on a contract with HAPCAP to also do inspections to ensure that all inspections are done in time. If the unit fails a second inspection, in most cases the HAP is abated, or a formal extension is granted on occasion. Anticipated Completion Date: January 1, 2023 Responsible Contact Person: Erica Flanders

The City currently has a process in place to scan copies of invoices for fixed asset additions as the disbursements are made through the biweekly accounts payable cycle to facilitate reclassification entries at year end. The City will begin to add these items to the fixed asset schedules as soon as the expenditures are incurred to ensure that the depreciation schedules agree with the trial balance at year end. Staffing changes in the personnel responsible for grant management during the year hindered the City?s ability to submit timely grant reimbursement requests. The City has subsequently redistributed the staff assignments for grant management and the finance department staff have been working closely with the newly assigned personnel to ensure accurate reporting going forward. All staff with responsibilities for grant management have access to shared documents on the server to cross check the departmental records to promptly identify and resolve any discrepancies.

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were unable to provide an ongoing quality control review processes and provide ongoing staff training and timely management reviews. We are focused on implementing such procedures and will review staffing levels, skill sets, and case load for each employee.

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8.: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were unable to provide an ongoing quality control review processes and provide ongoing staff training and timely management reviews. We are focused on implementing such procedures and will review staffing levels, skill sets, and case load for each employee.

2022-005 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Recommendation: The Authority should retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit. Action Taken: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to locate hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. We will retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

With the newly hired staff as of October 2022, the process of selecting eligible tenants from the list has been accomplished by identifying the preference and verifying in writing th ereason for such preference to move forward with the housing the applicant. All verification is kep tin the eligible tenant file. the existing staff has had 10-15 years' experience maintaining Federal program waiting list.

When the new director, Robert Weismore, was hired on September 7, 2022, he replaced the former director and 3 staff members. In October he hired the current staff of Ms. Schaefer, Ms. Lynn. Ms. Filipski was hired as a part time employee in the middle of September 2022. For the next 2 months the staff reviewed each file and recalculated the figures using the correct payment standards for the necessary period and also used the September 1, 2022 approved utility schedule installed by the current staff. The recalculations caused the North Syracuse Housing Authority to reimburse $25,463 to previously miscalculated tenants. Also, had to repa HUD $23,000. The current payment standards are up to date and the current utility schedule was updated effective 7/1/2023 and will be updated effective 7/1/24 and each July thereafter.

Please see 2020-008 regarding payment standards and utility schedules. The current staff updated the current rent reasonableness comparisons during the summer of 2023. This was accomplished by completing a survey of area wide rents and amenities for comparable units. Each folder has a rent reasonableness form showing the comparables and justifying the rent being changed is eligible and within reason.

When the current director, Robert Weismore was appointed his first obligation was to inspect 51 units that had been neglected by the former staff. As documentation in the files all previous nspections have been completed. The current staff, Sarah Schaefer, has become a certified inspector after completing the necessary course and passing the exam. All inspections whether annual or bi-annually are all completed within the time frame directed by HUD. The director currently will complete the supervisory inspections based on the percentage of program participation directed by HUD regulations.

The new director and staff know that SEMAP reports are due annually. They also know that the report is the responsibility of the director to complete the SEMAP filing. The director who was in place during the 2019-2020-2021 should have filed the SEMAP report.

Effective 11/1/2022 all recommendations are completed with up to 90 days notice to prospective tenant, with notification as the proper verification needed to complete the recert to completion. Notification is also sent to the owner of the recertification. Once the proper verification is completed calculations are completed the tenant and owner are mailed an addendum stating new rental breakdown. The new current staff has between 10 and 15 years' experience completing recertifications. Please see item 2020-008 regarding utilities and payment standards.

2022-001 Underpayment of the contingent mortgage As of December 31, 2022, $173,798 had been paid through the refinancing of the mortgage on April 26, 2022, which is 26 days after the 90-day period. Surplus cash was paid off with the close of the mortgage in the refinance. Karen Burkett, Managing Agent

On March 22, 2023, the Corporation paid $6,034.05 for overpayment of Management Agent Fees. The Corporation will reimburse the Project for the Management Fee Overpayment and Payroll Cost of the remaining balance due of $12,526.95.

The Corporation will register and apply for PPP Forgiveness via the SBA PPP Direct Forgiveness Portal or contact SBA Customer Service at 877-552-2692.

The Project will adhere to the HUD rent subsidy program in accepting applications, determining eligibility, calculating the tenant's contribution toward rent and utilities, and calculating subsidy in accordance with HUD.

Finding 2022-02: The Project has not received any PRAC receipts in 2022 and 2021 or subsequent to the year end. Recommendation: Management needs to work with HUD to process monthly PRAC submission receipts. Action Taken: Management is working with Darletta Baugh, HUD’s project manager regarding the non-receipt of the PRAC monthly submission. In addition, Management has delegated the oversight of the PRAC process.

Finding 2022-01: The monthly deposits to the Replacement Reserve totaling $12,000 were not made in 2022 as the project assumed HUD would grant a waiver. Recommendation: Deposit past due Replacement Reserve amounts if HUD approval of suspension of monthly deposits is not received. Action Taken: Management funded required Replacement Reserve funding in February 2023.

Finding No. 2022-003; Supportive Housing for the Elderly (Section 202), CFDA 14.157 Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended November 30, 2022, the project paid expenses in the amount of $326,282 on behalf of other affiliates from project cash without HUD approval. The amount due to the project as of November 30, 2022 is $326,282. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $326,282 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $326,282 Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: B – Allowable Costs/Cost Principles Views of Responsible Officials and Planned Corrective Actions Because the PRAC renewals were so delayed, therefore there was no money available to pay back the project. Furthermore, the insurance costs are tremendous and had to be financed. In order to ensure the payments are applied and paid timely it is best to have the entire amount pulled from one bank account. If each entity were to pay its share it would cause confusion and may result in possible cancellation. Upon finalizing the audits and submitting to HUD, management intends to request funds from the replacement reserve to enable them to pay down the due from affiliates.

Finding No. 2022-002; Supportive Housing for the Elderly (Section 202), CFDA 14.157 Criteria The regulatory agreement required that the project make monthly deposits to its replacement reserve. Condition During the year ended November 30, 2022, the project did not make the required monthly deposits to the replacement reserve as disclosed. The project was required to make monthly deposits to the reserve in the amount of $5,000 and $9,160 related to Finding 2021-1. Total cumulative deposits due to the replacement reserve during the year ended November 30, 2022 were $69,160 of which the project made deposits of $54,569 leaving an amount remaining due to the reserve of $14,431. Cause Due to COVID-19, the Property experienced delays in receiving its annual PRAC renewal and monthly PRAC subsidy funding. Effect or Potential Effect Underfunding of the replacement reserve and a noncompliance of the regulatory agreement. Questioned Costs: $14,431 Recommendation Management should make timely deposits to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement. Auditor Noncompliance Code: N – Special Tests and Provisions Views of Responsible Officials and Planned Corrective Actions: Due to COVID-19, delays were encountered by HUD while reviewing and renewing the annual PRAC which did not afford management enough time to settle outstanding vendor payments and make the increased reserve for replacement deposit.

Finding 2022-002 Unauthorized loans from project assets Comments on the Finding and Each Recommendation Statement of Condition During the year ended September 30, 2022, the project paid expenses in the amount of $81,886 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of September 30, 2022 is $81,886. Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $81,886 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $ 81,886. Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code B – Allowable Cost/Costs Principles Reporting Views of Responsible Officials The Corporation agrees with the finding and the auditor's recommendations have been adopted. Upon finalizing the audits and submitting to HUD, management intends to request funds from the replacement reserve to enable them to pay down the due from affiliates..