Corrective Action Plans

Finding 406464 (2022-007)

None 2022

NJ

Reporting HUD Housing Programs

Corrective Action: The CFO will work with Departmental Fiscal Officers and grant management staff to ensure that Davis-Bacon reports are filed on a timely basis. Implementation Date: Ongoing

View Audit 311634

Finding 406456 (2022-006)

None 2022

City of Jersey City

NJ

Internal Control / Segregation of Duties Cash Management HUD Housing Programs

Corrective Action: The Chief Financial Officer will oversee this project to close out the old accounts in a timely manner and make sure all systems are reconciled. Internal controls have been set into place to ensure future compliance. The Municipal Comptroller will train and continue to work close...

Corrective Action: The Chief Financial Officer will oversee this project to close out the old accounts in a timely manner and make sure all systems are reconciled. Internal controls have been set into place to ensure future compliance. The Municipal Comptroller will train and continue to work closely with personnel in charge of reporting and processing IDIS and vouchers drawdowns. The Division of Accounts & Control will continue to maintain a sub-ledger to ensure IDIS and the City’s financial system tie out prior to the processing of any payments, and each payment request will require an IDIS activity reference number in order to be processed. Monthly reconciliation of funds has been implemented and copies are sent to US HUD on a monthly basis. In addition, the City has hired a 3rd party grant consultant to help navigate and strengthen our overall processes. Implementation Date: Ongoing

View Audit 311634

Finding 403119 (2022-010)

Material Weakness 2022

State of California

CA

Eligibility Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303

Public Health’s Office of Aids (OA) agrees with the finding and recommendation. OA developed and implemented additional internal quality assurance (QA) processes in April of 2022 to ensure that secondary reviews of AIDS Drug Assistance Program (ADAP) applications are consistently enforcing the exist...

Public Health’s Office of Aids (OA) agrees with the finding and recommendation. OA developed and implemented additional internal quality assurance (QA) processes in April of 2022 to ensure that secondary reviews of AIDS Drug Assistance Program (ADAP) applications are consistently enforcing the existing guidelines, including acceptable supporting documentation and accurate eligibility requirements. Prior to this audit period, and through December 2021, ADAP had issued multiple policy memos to respond to the COVID-19 pandemic, which enabled staff and enrollment workers to defer documentation collection, when necessary, to remain flexible and ensure clients impacted by the pandemic, and associated site closures, did not lose eligibility and access to life-saving medications and comprehensive healthcare. These flexibilities in our guidelines were implemented based on guidance received from our federal funder, the Health Resources and Services Administration, which encouraged ADAP to reassess its organization's eligibility and recertification policies and procedures, and remove any barriers that may impede social distancing, or other public health strategies, necessary to minimize COVID-19 transmission. This documentation deferral was terminated on December 31, 2021, and since January 1, 2022, full documentation and eligibility requirements have been enforced. This, combined with ongoing QA efforts, will help mitigate future findings in ADAP applications. Estimated Implementation Date: Implemented as of April 2022 Contact: Joseph Lagrama, Branch Chief AIDS Drug Assistance Program Branch California Department of Public Health

View Audit 310237

Finding 403107 (2022-003)

Material Weakness 2022

State of California

CA

Eligibility Allowable Costs / Cost Principles HUD Housing Programs § 200.303

The California Department of Public Health (Public Health) Women, Infants, and Children (WIC) Division had agreed that the WIC Web Information System Exchange (WISE) system does not currently store eligibility history that should be included in the “Cert History Report,” and the initial eligibility ...

The California Department of Public Health (Public Health) Women, Infants, and Children (WIC) Division had agreed that the WIC Web Information System Exchange (WISE) system does not currently store eligibility history that should be included in the “Cert History Report,” and the initial eligibility data is overwritten when subsequent eligibility information is keyed into WIC WISE. However, WIC WISE does include preventative internal stops or checkpoints that do not allow ineligible individuals to be certified and issued benefits (e.g., over income, not a California resident, no nutrition risk factor, etc.). User acceptance testing vetted these items prior to system implementation in 2019/20. The certification history condition discussed was remediated via a system Defect Correction to WIC WISE that was in user acceptance testing for implementation in Fall 2023. Public Health/WIC has entered Defect Correction #6972 in TFS (Team Foundation Services), the tracking system previously used to capture system changes and defects. The defect correction supports a system change to ensure initial eligibility information is retained when subsequent eligibility information is entered into WIC WISE. Estimated Implementation Date: August 2023 Contact: William Welch, Assistant Division Chief, Operations Women, Infants, and Children Division California Department of Public Health

View Audit 310237

Finding 400452 (2022-006)

Significant Deficiency 2022

Reach Community Development, Inc.

OR

Special Tests & Provisions HUD Housing Programs § 200.857

Finding No. 2022-006 - Low Income Housing Preservation and Resident Homeownership Act of 1990) Federal Assistance Listing Number #99.999 Statement of Condition: The owner did not provide proof to REAC that all health and safety inspection findings were solved within 72 hours. Corrective Action: ...

Finding No. 2022-006 - Low Income Housing Preservation and Resident Homeownership Act of 1990) Federal Assistance Listing Number #99.999 Statement of Condition: The owner did not provide proof to REAC that all health and safety inspection findings were solved within 72 hours. Corrective Action: REACH responded and resolved all Exigent Health & Safety within the 72 hour period, but did not submit the confirmation report until 5 business days after the review, REACH will retain evidence of same day repairs going forward to allow confirmation that the time frame was met.

View Audit 308469

Finding 400451 (2022-005)

Significant Deficiency 2022

Reach Community Development, Inc.

OR

Questioned Costs HUD Housing Programs Special Tests & Provisions

Finding No. 2022-005 - Low Income Housing Preservation and Resident Homeownership Act of 1990) Federal Assistance Listing Number #99.999 Statement of Condition: The owner was unable to provide the Management Entity Profile HUD 9832 documentation for one of two properties tested and approved Mana...

Finding No. 2022-005 - Low Income Housing Preservation and Resident Homeownership Act of 1990) Federal Assistance Listing Number #99.999 Statement of Condition: The owner was unable to provide the Management Entity Profile HUD 9832 documentation for one of two properties tested and approved Management Agent's Certification HUD 9839-B for one of two properties tested. Corrective Action: REACH has contacted HUD office to request missing copies of HUD approved Management entity profile and certifications.

View Audit 308469 Questioned Costs: $1

Finding 400450 (2022-004)

Significant Deficiency 2022

Reach Community Development, Inc.

OR

Eligibility HUD Housing Programs

Finding No. 2022-004 - Low Income Housing Preservation and Resident Homeownership Act of 1990) Federal Assistance Listing Number #99.999 Statement of Condition: Our testing procedures noted that the owner did not perform certifications and recertifications timely, did not maintain tenant files i...

Finding No. 2022-004 - Low Income Housing Preservation and Resident Homeownership Act of 1990) Federal Assistance Listing Number #99.999 Statement of Condition: Our testing procedures noted that the owner did not perform certifications and recertifications timely, did not maintain tenant files in compliance with HUD Rules in Code of Federal Regulations at 24 CFR Part 92, and did not select tenants from the waitlist appropriately. Corrective Action: Management has policies and procedures in place, compliance has been impacted by being understaffed while recovering from covid-related social distancing/limited on site presence. This resulted in recertification and move-in compliance issues. Compliance team and the new HUD Portfolio Manager have been providing trainings for the HUD managers in 2023 and will continue to do so in 2024. In 2022 and 2023, Compliance Manager ensured that all staff who needed access to EIV took the appropriate steps (Cyber Awareness Training, updated EIV authorizations) to access EIV for their properties to run the reports timely. In 2023, The HUD Portfolio Manager created an EIV workflow training for the HUD managers. Both the Compliance team and HUD managers were present. One Compliance Specialist with HUD experience has been filling in and assisting at the HUD properties where we continue to be understaffed. As a Below Market Interest Rate (“BMIR”), we do not receive HUD subsidy or oversight from HUD. Because both properties are due for Affirmative Fair Housing Marketing Plan (“AFHMP”) updates, we will submit an updated plan to HUD for review and approval in 2024. Management is aware and has been performing Move-out inspections with tenants whenever possible.

View Audit 308469

Finding 400449 (2022-003)

Significant Deficiency 2022

Reach Community Development, Inc.

OR

Eligibility HUD Housing Programs

Finding No. 2022-003 - HUD HOME Investment Partnerships Program, Federal Assistance Listing Number #14.239 Statement of Condition: The owner did not make available to HOME tenants the contracted number and type of HOME units. Corrective Action: A unit will be re-classified the next time there is ...

Finding No. 2022-003 - HUD HOME Investment Partnerships Program, Federal Assistance Listing Number #14.239 Statement of Condition: The owner did not make available to HOME tenants the contracted number and type of HOME units. Corrective Action: A unit will be re-classified the next time there is a vacant unit of the corresponding size/type.

View Audit 308469

Finding 400448 (2022-002)

Significant Deficiency 2022

Reach Community Development, Inc.

OR

Eligibility HUD Housing Programs

Finding No. 2022-002 - HUD HOME Investment Partnerships Program, Federal Assistance Listing Number #14.239 Statement of Condition: In connection with our lease file review we noted one instance of eight tenants tested where management did not perform a 3rd party income verification in accordance ...

Finding No. 2022-002 - HUD HOME Investment Partnerships Program, Federal Assistance Listing Number #14.239 Statement of Condition: In connection with our lease file review we noted one instance of eight tenants tested where management did not perform a 3rd party income verification in accordance with policy. Corrective Action: Community Manager reviewed file noting 2017 and 2018 were both done as self-certifications. REACH is currently doing full reviews for all HOME units during 2023.

View Audit 308469

Finding 400447 (2022-001)

Significant Deficiency 2022

Reach Community Development, Inc.

OR

Special Tests & Provisions HUD Housing Programs Matching / Level of Effort / Earmarking

Finding No. 2022-001 - HUD HOME Investment Partnerships Program, Federal Assistance Listing Number #14.239 Statement of Condition: The owner did not ensure passing HQS inspections were performed during 2022. Corrective Action: Unit inspections are being done for 2023.

View Audit 308469

Finding 400243 (2022-002)

Significant Deficiency 2022

Housing Authority of the City of Annapolis

MD

HUD Housing Programs Reporting Significant Deficiency § 200.512

Finding 2022-002 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 req...

Finding 2022-002 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 with the audit finding. Action Taken in response to finding: The Authority will evaluate its financial reporting, close processes and controls to determine whether additional controls over the preparation of the final trial balances and related schedules should be implemented. As part of this process, we will create a year end checklist with deadlines established and monitor status to ensure deadlines are met. Name of Contact Person responsible for Corrective Action: Cia Cook, Deputy Executive Director & CFO Planned Date for Corrective Action plan: June 30, 2024

View Audit 308359

Finding 400242 (2022-001)

Material Weakness 2022

Housing Authority of the City of Annapolis

MD

HUD Housing Programs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Finding 2022-001 Federal Program Funds Utilized for Non-Federal Programs Recommendation: The Authority should locate additional sources of non-federal funds or reduce costs sufficiently so that the program can have enough cash to cover ongoing operations. Explanation of disagreement with audit findi...

Finding 2022-001 Federal Program Funds Utilized for Non-Federal Programs Recommendation: The Authority should locate additional sources of non-federal funds or reduce costs sufficiently so that the program can have enough cash to cover ongoing operations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Taken: The Authority has reevaluated its cost allocation plan and restructured various departments to better align staffing. This process helps ensure the COCC and funds are being properly charged for actual costs incurred. The Authority is also redeveloping its entire portfolio. This process had been and will continue to bring in developer and management fees to the COCC. Name of Contact Person responsible for Corrective Action: Cia Cook, Deputy Executive Director & CFO Planned Date for Corrective Action plan: June 30, 2024

View Audit 308359

Finding 398255 (2022-005)

Material Weakness 2022

City of Dunkirk Housing Authority

NY

HUD Housing Programs Material Weakness

2022-005 Material Weakness: See finding 2022-005. Federal program: Public Housing Capital Fund CFDA 14.872 Recommendation: We recommend that management of the Authority work with its newly retained fee accountant to better establish policies and procedures to ensure compliance with the grant requ...

2022-005 Material Weakness: See finding 2022-005. Federal program: Public Housing Capital Fund CFDA 14.872 Recommendation: We recommend that management of the Authority work with its newly retained fee accountant to better establish policies and procedures to ensure compliance with the grant requisition processes. Action taken: We concur with the recommendation. The Authority has had some staff turnover over the past several years. A new executive director and a new account clerk were both hired within the past several years. Management is evaluating its processes and procedures related to grant requisitions and is planning on implementing procedures to ensure grants are requisitioned in the future.

View Audit 306946

Finding 398254 (2022-004)

Significant Deficiency 2022

City of Dunkirk Housing Authority

NY

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

2022-004 Significant Deficiency: See finding 2022-004. Federal program: Public Housing Capital Fund CFDA 14.872 Recommendation: We recommend that management of the Authority work with its newly retained fee accountant to prepare an operating budget by AMP location. Action taken: We concur with t...

2022-004 Significant Deficiency: See finding 2022-004. Federal program: Public Housing Capital Fund CFDA 14.872 Recommendation: We recommend that management of the Authority work with its newly retained fee accountant to prepare an operating budget by AMP location. Action taken: We concur with the recommendation. The Authority has had some staff turnover over the past several years. A new executive director and a new account clerk were both hired within the past several years. Management was aware that its budget was not prepare by AMP location. Management engaged the services of a fee-accountant subsequent to year-end who will assist with the budgeting process starting in the 2024-2025 fiscal year.

View Audit 306946

Finding 398253 (2022-003)

Material Weakness 2022

City of Dunkirk Housing Authority

NY

HUD Housing Programs Reporting Material Weakness

2022-003 Material Weakness: See finding 2022-003. Federal program: Public Housing Capital Fund CFDA 14.872 Recommendation: We recommend that management of the Authority review the deadlines for FDS submission and the financial statement submission and work with the newly retained fee accountant t...

2022-003 Material Weakness: See finding 2022-003. Federal program: Public Housing Capital Fund CFDA 14.872 Recommendation: We recommend that management of the Authority review the deadlines for FDS submission and the financial statement submission and work with the newly retained fee accountant to ensure that these deadlines are met in the future. Action taken: We concur with the recommendation. The Authority has had some staff turnover over the past several years. A new executive director and a new account clerk were both hired within the past several years. Management was aware that its submissions were not timely. Management engaged the services of a fee-accountant subsequent to year-end who will assist with these submissions going forward.

View Audit 306946

Finding 398252 (2022-002)

Significant Deficiency 2022

City of Dunkirk Housing Authority

NY

HUD Housing Programs Significant Deficiency

2022-002 Significant Deficiency: See finding 2022-002. Federal program: Special Needs Assistance Program-CFDA 14.238 Recommendation: We recommend that management of the Authority review its processes for closing out all fullyexpended grants with HUD to ensure that, in the future, when grants are...

2022-002 Significant Deficiency: See finding 2022-002. Federal program: Special Needs Assistance Program-CFDA 14.238 Recommendation: We recommend that management of the Authority review its processes for closing out all fullyexpended grants with HUD to ensure that, in the future, when grants are fully expended, the close-out process begins shortly thereafter. Action taken: We concur with the recommendation. The Authority has had some staff turnover over the past several years. A new executive director and a new account clerk were both hired within the past several years. Management was aware that several older grants were still shown as "open" and that the close-out procedures would have to be implemented at some point. Management is evaluating its process and procedures related to closing out grants and is planning on implementing procedures to ensure grants are properly closed.

View Audit 306946

Finding 397077 (2022-005)

Material Weakness 2022

Municipality of Ceiba

PR

HUD Housing Programs Reporting

We concur with the finding. During the fiscal year 2023-2024, both reports for fiscal years 2020 and 2021 were filed. Therefore, the conditions of the findings have been corrected.

View Audit 306497

Finding 397018 (2022-003)

Significant Deficiency 2022

Mobile Housing Authority

AL

Eligibility HUD Housing Programs Significant Deficiency

MHA will review and enhance as necessary the program’s existing quality control (QC) daily data validation reports to include a measure that crosschecks existing reports in the Yardi system of record and aids in validating data routinely submitted to HUD’s PIC system. In 2023, MHA implemented a Hous...

MHA will review and enhance as necessary the program’s existing quality control (QC) daily data validation reports to include a measure that crosschecks existing reports in the Yardi system of record and aids in validating data routinely submitted to HUD’s PIC system. In 2023, MHA implemented a Housing Specialist-II team lead to oversee staff processing annual reexaminations in accordance with 24 CFR 982.516. This team member is responsible for ensuring families are notified in a timely manner and if they do not comply with the annual reexamination requirement, they receive termination notices in compliance with HUD and MHA Administrative Plan requirements. MHA also implemented two compliance analysts in 2023; these staff persons currently report to the Program Management Analyst who monitors HUD’s PIC system and analyzes discrepancies between PIC data and MHA data housed in the Yardi system of record. This information is maintained in the program file. Responsible Person: Magdalene Watkins, Program Administrator Projected Completion Date: April 30, 2024

View Audit 306404

Finding 397016 (2022-002)

Significant Deficiency 2022

Mobile Housing Authority

AL

HUD Housing Programs Internal Control / Segregation of Duties Reporting

Management has reviewed its staffing needs and end of year complexities and requirements necessary to report U.S. GAAP basis financial statements. Management has hired additional staff that possess the necessary accounting and reporting skills and experience to assist with interim reporting, end of ...

Management has reviewed its staffing needs and end of year complexities and requirements necessary to report U.S. GAAP basis financial statements. Management has hired additional staff that possess the necessary accounting and reporting skills and experience to assist with interim reporting, end of year close, reconciliations of all significant account balances, and strengthening the internal controls over financial reporting including amounts reported in the financial data schedule. In addition to these action steps, we will get started earlier in conducting our end of year reconciliations and enhance our over-sight so we can better monitor and evaluate our readiness to report our financial statements in compliance with 24 CFR Section 5.801. Responsible Person: Jeffery J. Bennett, Chief Financial Officer Projected Completion Date: June 30, 2023

View Audit 306404

Finding 397014 (2022-008)

Material Weakness 2022

North Central Housing Authority

ND

HUD Housing Programs Material Weakness

Contact Person Tim Greene, Executive Director Corrective Action Plan The Authority will continue to work with HUD and review staffing as well as work with the fee accountant to ensure the proper supporting documentation is retained. Planned Completion Date for CAP Immediately

View Audit 306400

Finding 397013 (2022-007)

Material Weakness 2022

North Central Housing Authority

ND

HUD Housing Programs Material Weakness

Contact Person Tim Greene, Executive Director Corrective Action Plan The Authority will continue to work with HUD and review staffing as well as work with the fee accountant to ensure the proper supporting documentation is retained. Planned Completion Date for CAP Immediately

View Audit 306400

Finding 397012 (2022-006)

Material Weakness 2022

North Central Housing Authority

ND

HUD Housing Programs Material Weakness

Contact Person Tim Greene, Executive Director Corrective Action Plan The Authority will continue to work with HUD and review staffing as well as work with the fee accountant to ensure the appropriate information is available. Planned Completion Date for CAP Immediately

View Audit 306400

Finding 397011 (2022-005)

Material Weakness 2022

North Central Housing Authority

ND

HUD Housing Programs Material Weakness

Contact Person Tim Greene, Executive Director Corrective Action Plan The Authority will continue to work with HUD and review staffing as well as work with the fee accountant to ensure the proper supporting documentation is retained. Planned Completion Date for CAP Immediately

View Audit 306400

Finding 397010 (2022-004)

Material Weakness 2022

North Central Housing Authority

ND

HUD Housing Programs Material Weakness

Contact Person Tim Greene, Executive Director Corrective Action Plan The Authority will continue to work with HUD and review staffing as well as work with the fee accountant to ensure the proper personnel perform reconciliations within a timely manner of year end. Planned Completion Date for CAP Imm...

Contact Person Tim Greene, Executive Director Corrective Action Plan The Authority will continue to work with HUD and review staffing as well as work with the fee accountant to ensure the proper personnel perform reconciliations within a timely manner of year end. Planned Completion Date for CAP Immediately

View Audit 306400

Finding 397009 (2022-003)

Material Weakness 2022

North Central Housing Authority

ND

HUD Housing Programs Eligibility Material Weakness

Contact Person Tim Greene, Executive Director Corrective Action Plan The Authority will continue to provide occupancy training to staff to prevent future exceptions. Planned Completion Date for CAP Immediately

View Audit 306400

Corrective Action Plans

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