Corrective Action Plans

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Corrective Action Plan Provided from Management: Philadelphia Legal Assistance Center, Inc. (PLA) agrees with the finding. PLA is in the process of developing an enhanced training program for case handlers to ensure that case handlers remember to obtain citizenship attestations and documentation of ...
Corrective Action Plan Provided from Management: Philadelphia Legal Assistance Center, Inc. (PLA) agrees with the finding. PLA is in the process of developing an enhanced training program for case handlers to ensure that case handlers remember to obtain citizenship attestations and documentation of immigration eligibility whenever the LSC regulations require it. We are also in the process of developing an enhanced system of overseeing case files so that if the documentation is missing in a case, that case is deselected from the annual Case Service Reports. Corrective Action Plan Contact: Jonathan Pyle, Contract Performance Officer Philadelphia Legal Assistance 718 Arch Street, Suite 300N Philadelphia, PA 19106
Finding 381083 (2022-003)
Significant Deficiency 2022
Execute the transfer of cash into the residual receipts reserve account.
Execute the transfer of cash into the residual receipts reserve account.
The Silver Lake Regional School District will develop and then adhere to Business Office Procedure Manual. This manual will address day-to-day implementation of the Silver Lake Regional School Committee Policies related to Finance and Operations. Once created, this manual will assist in clarifying ...
The Silver Lake Regional School District will develop and then adhere to Business Office Procedure Manual. This manual will address day-to-day implementation of the Silver Lake Regional School Committee Policies related to Finance and Operations. Once created, this manual will assist in clarifying the roles and relationship of the School Committee (as defined by law) and School Administration (as defined by policy). It will also serve to communicate how the school organization functions-who is doing what, as well as where, when, and why so that resources are allocated and tracked both efficiently and effectively. Silver Lake Regional School District administration requested additional business office staffing positions at the January 11, 2024 School Committee Meeting. This request includes additional hours for current positions and/or additional positions listed below: District Accountant, District Treasurer, Grants Management, Transportation Coordinator Silver Lake will contract for a risk assessment in the Spring of 2024 and will continue to do so at recommended intervals. Once the Business Office is adequately staffed, these additional staff will assist in addressing the issues of timely centralized reporting and compliance.
Recommendation: The Authority should review and enhance its internal controls to ensure: • management obtains and reviews documentation supporting United States of America citizenship; • tenants provide release forms prior to obtaining necessary documentation; • management verifies income listed on ...
Recommendation: The Authority should review and enhance its internal controls to ensure: • management obtains and reviews documentation supporting United States of America citizenship; • tenants provide release forms prior to obtaining necessary documentation; • management verifies income listed on the HUD Form 50058; and • recertifications are consistently reviewed and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority specialist responsible for file maintenance and recertifications during fiscal year 2022 is no longer with the Agency. The Authority has experienced staff now in place to perform these services. The Authority will revisit our policy and procedures over recertification and file maintenance to ensure documentation is maintained and is in compliance with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2023
Recommendation: We recommended that the Authority develop procedures to ensure that future reporting packages and FDS reports are submitted by the respective deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findin...
Recommendation: We recommended that the Authority develop procedures to ensure that future reporting packages and FDS reports are submitted by the respective deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will review and enhance our policies and procedures over year end close, to ensure all adjustments are made timely to allow for timely audit facilitation to ensure we are meeting the DCF and FDS deadlines. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2023
Missing Depository Agreements (Non Compliance) Recommendation: The Commission should enter into depository agreements with all financial institutions holding Federal funds for the Commission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action take...
Missing Depository Agreements (Non Compliance) Recommendation: The Commission should enter into depository agreements with all financial institutions holding Federal funds for the Commission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission has had prior communications with the Bank regarding the depository agreements requirements. The Bank would not sign due to internal policies. The Commission will coordinate discussions between our HUD local field office and the Bank to discuss the requirements for obtaining a depository agreement. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2023
Data Collection Form and Financial Data Schedule (Non Compliance) Recommendation: We recommended that the Commission develop procedures to ensure that future reporting packages and FDS reports are submitted by the respective deadlines. Explanation of disagreement with audit finding: There is no dis...
Data Collection Form and Financial Data Schedule (Non Compliance) Recommendation: We recommended that the Commission develop procedures to ensure that future reporting packages and FDS reports are submitted by the respective deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will review and enhance our policies and procedures over year end close, to ensure all adjustments are made timely to allow for timely audit facilitation to ensure we are meeting the DCF and FDS deadlines. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2023
Depository Agreements (Non Compliance) Recommendation: The Authority should enter into depository agreements with all financial institutions holding Federal funds for the Authority. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in re...
Depository Agreements (Non Compliance) Recommendation: The Authority should enter into depository agreements with all financial institutions holding Federal funds for the Authority. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has had prior communications with the Bank regarding the depository agreements requirements. The Bank would not sign due to internal policies. The Commission will coordinate discussions between our HUD local field office and the Bank to discuss the requirements for obtaining a depository agreement. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2023
Data Collection Form and Financial Data Schedule (Non Compliance) Recommendation: We recommended that the Authority develop procedures to ensure that future reporting packag s and FDS reports are submitted by the respective deadlines. Explanation of disagreement with audit finding: There is no disa...
Data Collection Form and Financial Data Schedule (Non Compliance) Recommendation: We recommended that the Authority develop procedures to ensure that future reporting packag s and FDS reports are submitted by the respective deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will review and enhance our policies and procedures over year end close, to ensure all adjustments are made timely to allow for timely audit facilitation to ensure we are meeting the DCF and FDS deadlines. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2023
Finding 2022-004: Eligibility Determination and Documentation Condition: The Authority failed to obtain, verify, and/or maintain required documentation to indicate participants’ eligibility under the Housing Choice Voucher Program in tenants’ files as required under CFR Title 24: Housing and Urban D...
Finding 2022-004: Eligibility Determination and Documentation Condition: The Authority failed to obtain, verify, and/or maintain required documentation to indicate participants’ eligibility under the Housing Choice Voucher Program in tenants’ files as required under CFR Title 24: Housing and Urban Development. Plan: The Authority has two Compliance Analysts (CA) whose primary responsibilities are audits of tenant files and training. The Authority will consider adding another CA. The CAs perform audits on a random sample of tenant files. The purpose of this review is to make sure the participants’ are eligible under the Housing Choice voucher Program. The Authority has experienced significant turnover of staff in the HCV department this past year. The Authority has filled these positions and has implemented programs to train the HCV staff. Also, there will be on the job training (OJT) by the CAs. CAs review the results of audits with management and discuss errors with the staff responsible for the tenant files. Checklists are utilized to ensure staff follow all processes and procedures for eligibility and other documentation requirements. Staff who fail to correctly process eligibility certifications, annual recertifications and move ins to new units are subject to progressive discipline. Supervisors will conduct random reviews on the files processed by staff each month. The Authority has corrected the issue noted in the two tenant files. Employee Responsible for the CAP: Sheryl Seiling, Director of Rental Assistance Planned Completion Dates for CAP: March 2024
Recommendation: The management agent should compute an estimate of surplus cash (residual receipts) for the fiscal year upon completion of that period. In the event that surplus cash exists at the completion of the fiscal period, the management agent must further ensure that all required deposits a...
Recommendation: The management agent should compute an estimate of surplus cash (residual receipts) for the fiscal year upon completion of that period. In the event that surplus cash exists at the completion of the fiscal period, the management agent must further ensure that all required deposits are made to the residual receipts account within the required time frame and that the balance in that account meets the minimum required balance in accordance with the regulatory agreement between the Entity and HUD. Views of Responsible Officials and Planned Corrective Action: The management agent agrees with the finding and the auditor’s recommendations have been adopted. Surplus cash will be calculated upon the completion of an annual fiscal period. If it is concluded that surplus cash exists at the end of the annual fiscal period, and further determined that the surplus cash was received within that fiscal period, that amount of surplus cash will be deposited into the Residual Receipts Account within ninety days of the close of that fiscal period.
Recommendation: We recommend that the property comply with all continuing compliance requirements and ensure that the data collection form is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is now aware of the continuing c...
Recommendation: We recommend that the property comply with all continuing compliance requirements and ensure that the data collection form is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is now aware of the continuing compliance requirement and will comply with this recommendation in the future.
Recommendation: We recommend that the property comply with HUD’s audit requirements and ensure that the audit is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is aware and will comply with this recommendation in the futu...
Recommendation: We recommend that the property comply with HUD’s audit requirements and ensure that the audit is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is aware and will comply with this recommendation in the future.
Management Response and Corrective Action The Finance Department will implement additional internal controls to manage the financial statement process in a timely manner as recommended.
Management Response and Corrective Action The Finance Department will implement additional internal controls to manage the financial statement process in a timely manner as recommended.
Finding 2022-003: The Corporation was unable to furnish the entity's approved Affirmative Fair Housing Marketing Plan. Comments on the Finding and Each Recommendation: The Corporation should request the filed Affirmative Fair Housing Marketing Plan from HUD or submit a new version for approval. Acti...
Finding 2022-003: The Corporation was unable to furnish the entity's approved Affirmative Fair Housing Marketing Plan. Comments on the Finding and Each Recommendation: The Corporation should request the filed Affirmative Fair Housing Marketing Plan from HUD or submit a new version for approval. Action(s) taken or planned on the finding: Management has requested the form from HUD. As of the report date, no response has been received.
Finding 2022-002: The Corporation made a payment to LAHD in the amount of $16,742. The payment does not meet HUD's criteria of eligible Property expenses and the Corporation did not obtain HUD approval. Comments on the Finding and Each Recommendation: The Corporation should request HUD approval for ...
Finding 2022-002: The Corporation made a payment to LAHD in the amount of $16,742. The payment does not meet HUD's criteria of eligible Property expenses and the Corporation did not obtain HUD approval. Comments on the Finding and Each Recommendation: The Corporation should request HUD approval for reimbursement from the residual receipts fund and deposit into the Property's operating account. Action(s) taken or planned on the finding: Management has requested approval from HUD. As of the report date, no response has been received.
View Audit 294494 Questioned Costs: $1
Finding 2022-001: The Corporation's required deposit of $33,484 to the residual receipts account per the December 31, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Comments on the Finding and Each Recommendation: Manage...
Finding 2022-001: The Corporation's required deposit of $33,484 to the residual receipts account per the December 31, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Comments on the Finding and Each Recommendation: Management should make all required residual receipt deposits per the annual Computation of Surplus Cash, Distributions and Residual Receipts within 90 days after fiscal year end. Action(s) taken or planned on the finding: Management deposited $33,484 into the residual receipts fund on June 13, 2022. No further action is required.
View Audit 294494 Questioned Costs: $1
Finding 2022-002 a. Comments on the Finding and Each Recommendation: Management agrees with both the finding and recommendations. b. Action(s) Taken or Planned on the Finding The management overseeing the process has been completely replaced to ensure a fresh perspective and unwavering dedication to...
Finding 2022-002 a. Comments on the Finding and Each Recommendation: Management agrees with both the finding and recommendations. b. Action(s) Taken or Planned on the Finding 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 2022-002, 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.
Finding 372057 (2022-007)
Significant Deficiency 2022
In September 2023, a "AP Processing Guidelines & Concur Reference Guide" document was introduced to ensure timeliness, completeness and propriety of books and records. Full dissemination to all Program Managers in connection with in-depth training sessions is still work in process and a result of th...
In September 2023, a "AP Processing Guidelines & Concur Reference Guide" document was introduced to ensure timeliness, completeness and propriety of books and records. Full dissemination to all Program Managers in connection with in-depth training sessions is still work in process and a result of the number of personnel to be trained, combined with limited bandwidth by resources assigned to training. The Concur Expense reporting module is being integrated within the ERP environment, enabling detailed chart of accounts to reflect GL coding by Segment, Grant, and Program. All journal entry support is attached to accounting entry in the ERP. The journal entry is entered by someone on the accounting team and approved by the Controller. Responsible: Annette Nastri, Timing: June 30, 2024
View Audit 293311 Questioned Costs: $1
We will work on monthly cash flows availability to ensure funding the replacement reserve shortfall.
We will work on monthly cash flows availability to ensure funding the replacement reserve shortfall.
We are in communication with HUD on the proposed action plans to meet the required deposits.
We are in communication with HUD on the proposed action plans to meet the required deposits.
Criteria Under the terms of the related regulatory agreement The Homes is required to make timely monthly debt payments and deposits in certain escrow accounts. Condition/Context As part of our compliance testing, we reviewed the debt and escrow schedules and noted that the debt payments and escrow ...
Criteria Under the terms of the related regulatory agreement The Homes is required to make timely monthly debt payments and deposits in certain escrow accounts. Condition/Context As part of our compliance testing, we reviewed the debt and escrow schedules and noted that the debt payments and escrow payments due in February through December of 2022 were not made. Cause The Homes was experiencing significant cash constraints and was not able to make debt payments and escrow payments as they were due and was limited under the terms of the bankruptcy filing as to what payments were allowable. Effect The Homes is out of compliance with the HUD regulatory agreement. Recommendation As HUD servicer is a named secured creditor in the bankruptcy filing, we recommend that The Homes follow the rules of the bankruptcy filing. Management Response The HUD mortgage is a secured creditor under the bankruptcy filing and we expect the lender to be paid under the terms of the bankruptcy agreement at the conclusion of the sale of the Facility that is expected to occur during 2024.
2022-02 Surplus Cash Not Deposited by Due Date Recommendation: We recommend that Levi Towers, Inc. develop specific procedures to ensure that the surplus cash is calculated and deposited by the December 31 deadline. Action Taken: Levi Towers, Inc. will develop procedures to ensure that the surp...
2022-02 Surplus Cash Not Deposited by Due Date Recommendation: We recommend that Levi Towers, Inc. develop specific procedures to ensure that the surplus cash is calculated and deposited by the December 31 deadline. Action Taken: Levi Towers, Inc. will develop procedures to ensure that the surplus cash is calculated and deposited into the residual receipts on or before the December 31 deadline. Name of responsible person responsible for corrective action: David Wilson Anticipated completion date for the corrective action: February 9, 2024
Corrective Action: The Authority will institute corrective policies and procedures including, use of quarterly reviews of tenant files for compliance with applicable HUD compliance requirements prior to audit.
Corrective Action: The Authority will institute corrective policies and procedures including, use of quarterly reviews of tenant files for compliance with applicable HUD compliance requirements prior to audit.
Recommendation: We recommend management should designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response ...
Recommendation: We recommend management should designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response to finding: The Authority will designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Name of the contact person responsible for corrective action: Dontrelle Young Foster, President & Chief Executive Officer Planned completion date for corrective action plan: We expect to have the finding resolved by issuance of next year's audit.
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