Corrective Action Plans

HOMECorp will make use of Yardi Breeze Premier Affordable Property Management CRM feature which allows both HOMECorp and our tenants to track their program compliance, maintenance requests, leases, lease renewals and annual recertifications. This information will be saved/stored in the cloud. This w...

HOMECorp will make use of Yardi Breeze Premier Affordable Property Management CRM feature which allows both HOMECorp and our tenants to track their program compliance, maintenance requests, leases, lease renewals and annual recertifications. This information will be saved/stored in the cloud. This was implemented on 05/01/23 through coordination of the Yardi Implementation Team and the executive director. During 2021 – 2022, HOMECorp’s management team was significantly impacted by COVID and despite PPP loan retention efforts we lost all our staff and transitioned our HUD Certified Housing Counselor to Property Manager. During this time, the executive Director left as well as two (2) interim Executive Directors, who responsibilities were general management. They lacked the training and experience in Affordable Housing Management to help our property manager to maintain our program compliance procedures. Since the new Executive Director, onboarded in April 2023, the property manager has been trained on our policy and procedure for verifying tenant eligibility and calculating rent amounts in compliance with HOME program requirements, tenant intake, income verification, and rent calculations to ensure compliance with federal regulations. This is done in Yardi Affordable compliance worksheet. Quarterly periodic reviews and audits of tenant files and rent schedules are performed to ensure ongoing compliance.

View Audit 385755

Finding 1172527 (2022-003)

Material Weakness 2022

HOMES OF MONTCLAIR ECUMENICAL CORP

NJ

Subrecipient Monitoring HUD Housing Programs Material Weakness

During 2020 – 2022, HOMECorp’s management team was significantly impacted by COVID and despite PPP loan retention efforts we lost all our staff and transitioned our HUD Certified Housing Counselor to Property Manager. Due to staffing shortages and restricted to access to apartments as a result of he...

During 2020 – 2022, HOMECorp’s management team was significantly impacted by COVID and despite PPP loan retention efforts we lost all our staff and transitioned our HUD Certified Housing Counselor to Property Manager. Due to staffing shortages and restricted to access to apartments as a result of health concerns, our property manager was unable to perform Housing Quality Standards Inspections. The new Executive Director has contracted with a General Contractor to help assist our property manager with Housing Quality Standards Inspections. These inspections are conducted annually with detailed inspection logs for HVAC, Painting, Fire Safety, and major unit renovations maintained and tracked in our digital database. These logs are reviewed and updated on a quarterly basis to ensure timeliness in compliance and maintenance requests.

View Audit 385755

Finding 1172526 (2022-002)

Material Weakness 2022

HOMES OF MONTCLAIR ECUMENICAL CORP

NJ

Eligibility HUD Housing Programs Material Weakness

HOMECorp will make use of Yardi Breeze Premier Affordable Property Management CRM feature which allows both HOMECorp and our tenants to track their program compliance, maintenance requests, leases, lease renewals and annual recertifications. This information will be saved/stored in the cloud. This w...

HOMECorp will make use of Yardi Breeze Premier Affordable Property Management CRM feature which allows both HOMECorp and our tenants to track their program compliance, maintenance requests, leases, lease renewals and annual recertifications. This information will be saved/stored in the cloud. This was implemented on 05/01/23 through coordination of the Yardi Implementation Team and the executive director. During 2021 – 2022, HOMECorp’s management team was significantly impacted by COVID and despite PPP loan retention efforts we lost all our staff and transitioned our HUD Certified Housing Counselor to Property Manager. During this time, the Executive Director, left as well as two (2) interim Executive Directors, who responsibilities were general management. They lacked the training and experience in Affordable Housing Management to help our property manager to maintain our program compliance procedures. Since the new Executive Director onboarded in April 2023, the property manager has been trained on our policy and procedure for verifying tenant eligibility and calculating rent amounts in compliance with HOME program requirements, tenant intake, income verification, and rent calculations to ensure compliance with federal regulations. This is done in Yardi Affordable compliance worksheet. Quarterly periodic reviews and audits of tenant files and rent schedules are performed to ensure ongoing compliance.

View Audit 385755

Finding 1166291 (2022-005)

Material Weakness 2022

Rehoboth McKinley Christian Health Care Services, Inc.

NM

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Eligibility § 200.302

Management will enforce existing internal control procedures and train staff to maintain appropriate documentation.

View Audit 377383

Finding 1163588 (2022-001)

Material Weakness 2022

CHESTERFIELD SQUARE MUTUAL HOMES, INC.

VA

HUD Housing Programs

Finding: 2022-001 Agency: Chesterfield Square Mutual Homes, Inc. Name of Contact Person and Title: Sharon B. Stover, Controller, Drucker & Falk, LLC, Agent Anticipated Completion Date: 06/29/2023 Agency's Response: Concur Chesterfield Square Mutual Homes agrees with this finding and will implement t...

Finding: 2022-001 Agency: Chesterfield Square Mutual Homes, Inc. Name of Contact Person and Title: Sharon B. Stover, Controller, Drucker & Falk, LLC, Agent Anticipated Completion Date: 06/29/2023 Agency's Response: Concur Chesterfield Square Mutual Homes agrees with this finding and will implement the following: Drucker & Falk, LLC will immediately remit a catch-up contribution for the deficient reserve contributions. Sharon B. Stover, Controller Drucker & Falk, LLC Agent

View Audit 373331

Finding 1160576 (2022-002)

Material Weakness 2022

Town of Guilderland

NY

HUD Housing Programs Reporting

Finding Reference: 2022-002 Compliance with Reporting to Housing and Urban Development Description: The financial information submission was not submitted timely. Recommendation: The Town should follow federal guidelines by submitting the audited financial statement to HUD through the REAC submissio...

Finding Reference: 2022-002 Compliance with Reporting to Housing and Urban Development Description: The financial information submission was not submitted timely. Recommendation: The Town should follow federal guidelines by submitting the audited financial statement to HUD through the REAC submission in a timely manner. Corrective Action: The Town of Guilderland Comptroller’s Office suffered significant turnover in key positions during the fiscal years of 2019 and 2021 including the retirement of the Town Comptroller and Fiscal Officer. In addition, the COVID-19 pandemic had significant impact to the Town, particularly during 2020 when remote work was encouraged. This combination and sequence of events made it impossible to meet the required external audit reporting deadlines. Since these events, the Town has filed the vacant positions and has scheduled all remaining audits. The auditors are working as expeditiously as possible to complete the remaining audits. The Town receives an accepted audited REAC submission from HUD each year and has been submitting timely since 2022. Once the audited financial statements are caught up, they will be included in the REAC submission timely. Person(s) Responsible for Corrective Action: Darci Efaw, Comptroller & Jessica Gulliksen, Fiscal Officer Anticipated Completion Date for Corrective Action: The remaining audits that are left to become fully in compliance have been tentatively scheduled with the external auditors since 2022. The Town of Guilderland works as efficiently as possible with the auditors to complete these remaining audits.

View Audit 370881

Finding 1157824 (2022-054)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Allowable Costs / Cost Principles Eligibility § 200.303

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the findings related to the participation of private school children in the COVID-19 Education Stabilization Fund (ESF-SEA) program. VIDE is committed to rectifying these issues and enhancing our systems to ens...

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the findings related to the participation of private school children in the COVID-19 Education Stabilization Fund (ESF-SEA) program. VIDE is committed to rectifying these issues and enhancing our systems to ensure equitable services for private school children. OMB will develop and implement a formal policy and procedures that outline the process for ensuring the participation of private school children in compliance with federal regulations. This will include guidelines for timely consultation with nonpublic schools and documentation of services provided. OMB will create a consultation schedule to ensure that timely consultations with nonpublic schools are conducted each fiscal year. The schedule will outline key dates for initiating and completing consultations to meet compliance requirements. OMB will collaborate with the Department of Education to develop control measure to ensure that all private schools expenditures are equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel.

View Audit 369907

Finding 1157798 (2022-038)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

The Government concurs with the auditor's findings and recommendations. VIDOL will be implementing a RESEA case management system for reporting and program services. This case management system is currently in configuration phase of the project. Live production is expected by the 2nd quarter 2025. T...

The Government concurs with the auditor's findings and recommendations. VIDOL will be implementing a RESEA case management system for reporting and program services. This case management system is currently in configuration phase of the project. Live production is expected by the 2nd quarter 2025. This system will be the official system of record for recording all services for RESEA claimants that participate in the program.

View Audit 369907

Finding 1153700 (2022-004)

Material Weakness 2022

Vermont Seniors

CA

Questioned Costs HUD Housing Programs

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.

View Audit 366836 Questioned Costs: $1

Finding 1153694 (2022-001)

Material Weakness 2022

Vermont Seniors

CA

HUD Housing Programs

The Corporation should file the December 31, 2022 financial statements as soon as possible and should ensure the annual financial report is filed within 90 days in future periods or within nine months of fiscal year end if an owner certified submission was furnished to HUD.

View Audit 366836

Finding 1153050 (2022-003)

Material Weakness 2022

Michigan Ability Partners

MI

HUD Housing Programs Material Weakness

Michigan Ability Partners strives to maintain compliance with all HUD requirements, however due to the challenges of social distancing and the requirement of remote work during the COVID era, meeting in person with clients and landlords to obtain signed documents became much more difficult. Staff tr...

Michigan Ability Partners strives to maintain compliance with all HUD requirements, however due to the challenges of social distancing and the requirement of remote work during the COVID era, meeting in person with clients and landlords to obtain signed documents became much more difficult. Staff transitions also contributed to these challenges. The Voucher Manager position—responsible for verifying rent reasonableness and filling open HUD vouchers—was vacated in July 2022 after a brief tenure. Although the role was refilled quickly, the transition resulted in information gaps during lease renewal periods due to the disruption in continuity and knowledge transfer. To help support the growing difficulty of the work, a new position, Housing Administrative Team Lead, was created in November 2022 to have direct responsibility of the Voucher Manager, maintain compliance, and update systems and workflows. More recently, in August 2024, Michigan Ability Partners created an additional position, Sr. Manager of Programs to provide an additional level of review to ensure compliance. To recruit and retain qualified staff, the salaries for these three position have been adequately adjusted. Michigan Ability Partners (MAP) provides outstanding services to the unhoused population of Washtenaw County. Although many staffing disruptions have recently affected some of its operations, MAP is committed to continue to provide exceptional services and maintain a high standard of compliance. Going forward, MAP will continue to work diligently to complete Single Audit Packages in a timely manner

View Audit 366303

Finding 1153049 (2022-002)

Material Weakness 2022

Michigan Ability Partners

MI

HUD Housing Programs Material Weakness

Michigan Ability Partners strives to maintain compliance with all HUD requirements, however due to the challenges of social distancing and the requirement of remote work during the COVID era, meeting in person with clients and landlords to obtain signed documents became much more difficult. Staff tr...

Michigan Ability Partners strives to maintain compliance with all HUD requirements, however due to the challenges of social distancing and the requirement of remote work during the COVID era, meeting in person with clients and landlords to obtain signed documents became much more difficult. Staff transitions also contributed to these challenges. The Voucher Manager position—responsible for verifying rent reasonableness and filling open HUD vouchers—was vacated in July 2022 after a brief tenure. Although the role was refilled quickly, the transition resulted in information gaps during lease renewal periods due to the disruption in continuity and knowledge transfer. To help support the growing difficulty of the work, a new position, Housing Administrative Team Lead, was created in November 2022 to have direct responsibility of the Voucher Manager, maintain compliance, and update systems and workflows. More recently, in August 2024, Michigan Ability Partners created an additional position, Sr. Manager of Programs to provide an additional level of review to ensure compliance. To recruit and retain qualified staff, the salaries for these three position have been adequately adjusted.

View Audit 366303

Finding 575125 (2022-002)

Material Weakness 2022

City of Davis

CA

Cash Management HUD Housing Programs Matching / Level of Effort / Earmarking

Finding Reference Number: SA 2022-002 Cash Management AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housin...

Finding Reference Number: SA 2022-002 Cash Management AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-15-MC-06-0037, B-16-MC-06-0037, B-17-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037, B-21-MC-06-0037 • Fiscal Year of Initial Finding: 2021 • Name(s) of the contact person: Jennifer Block, Management Analyst • Corrective Action Plan: At the end of FY 2023, the City brought the program back in-house to the newly-created Department of Social Services and Housing (SSH). In FY 2024, staff developed a process to ensure timely and consistent draws, with reconciliation to the general ledger at the point of each draw. SSH staff have developed and implemented a timeline of required actions for the program to ensure compliance with deadlines. Staff performs drawdowns of CDBG funding through HUD's IDIS online system monthly. Staff will now report the quarterly drawdowns and reconciliation in the Funds Projected/ Funds Drawn spreadsheet to improve monitoring and identification of problems early. This will increase the speed by which Davis spends down its credit line, and reduce gaps in expenditure recording between IDIS and the City's financial management system. In addition, an updated draw-down process, paired with quarterly reconciliation and reporting through the quarterly cash transaction report, will help staff correctly draw entitlement funds. • Anticipated Completion Date: June 30, 2024

View Audit 365226

Finding 571636 (2022-001)

Significant Deficiency 2022

Cornerstone Homes River Gardens, Inc.

LA

HUD Housing Programs Cash Management

The management agent agrees with the finding and the auditors’ 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 surplu...

The management agent agrees with the finding and the auditors’ 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.

View Audit 362570

Finding 570778 (2022-007)

Material Weakness 2022

Joint Programs of the Shoshone and Arapaho Tribes of the Wind River Reservation

WY

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Individual(s) Responsible: Chelsea BadHawk, Chief Financial Officer Action: Management will prepare and implement an internal control system that provides effective oversight of operations, reporting, and compliance. The systems and controls will be designed based on standards set forth in the Go...

Individual(s) Responsible: Chelsea BadHawk, Chief Financial Officer Action: Management will prepare and implement an internal control system that provides effective oversight of operations, reporting, and compliance. The systems and controls will be designed based on standards set forth in the Government Accountability Office Green Book. Anticipated Completion Date: 12/31/2025.

View Audit 361721

Finding 565072 (2022-002)

Significant Deficiency 2022

Milltwee Housing Development Fund Co, Inc.

NY

HUD Housing Programs Reporting

January 29, 2025 Management's Planned Corrective Action Plan For the Year Ended September 30, 2022 Names of contact person(s) responsible for corrective action: Derrick Taitt, President. Planned Corrective Action: The Board of Directors acknowledges the reporting deadline was not met. The Board wa...

January 29, 2025 Management's Planned Corrective Action Plan For the Year Ended September 30, 2022 Names of contact person(s) responsible for corrective action: Derrick Taitt, President. Planned Corrective Action: The Board of Directors acknowledges the reporting deadline was not met. The Board was in the process of engaging a new audit firm. We have implemented significant changes in internal controls over compliance to ensure the audit is completed and submitted by the required deadlines.

View Audit 359011

Finding 562198 (2022-004)

Material Weakness 2022

Mississippi County Public Facilities Board

AR

HUD Housing Programs

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September...

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September 1st 2024 for a management contract. These findings will be corrected by the executive team that is managing the housing authority. We plan to have everything corrected and in place by July 1st 2026. This staff will follow all rules and regulations in the future and will bring everything up to date. Wixson Huffstetler, Executive Director 5/6/2025

View Audit 357802

Finding 562196 (2022-002)

Significant Deficiency 2022

Mississippi County Public Facilities Board

AR

HUD Housing Programs Reporting

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September...

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September 1st 2024 for a management contract. These findings will be corrected by the executive team that is managing the housing authority. We plan to have everything corrected and in place by July 1st 2026. This staff will follow all rules and regulations in the future and will bring everything up to date. Wixson Huffstetler, Executive Director 5/6/2025

View Audit 357802

Finding 561169 (2022-001)

Significant Deficiency 2022

M. Carter Plaza

OR

HUD Housing Programs Allowable Costs / Cost Principles Reporting § 200.512

Finding no.: 2022-001 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: The late filing was due to the fiscal manager position at PCRI experiencing turnover in September of 2019, this, along with the onset of COVID-19 in the first quarter of 2020 led ...

Finding no.: 2022-001 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: The late filing was due to the fiscal manager position at PCRI experiencing turnover in September of 2019, this, along with the onset of COVID-19 in the first quarter of 2020 led to delays in the normal review and submission of the data collection form. The fiscal manager position has been staffed and is aware of the deadline related to the submission of the data collection form. Anticipated completion date: October 2023

View Audit 356760

Finding 561167 (2022-002)

Significant Deficiency 2022

Portland Community Reinvestment Initiatives, Inc.

OR

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.512

Finding no.: 2022-002 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: As has been addressed earlier in management’s response to Finding 2022-001, PCRI had created and filled two new positions in the Fiscal Department — the Controller and an additional...

Finding no.: 2022-002 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: As has been addressed earlier in management’s response to Finding 2022-001, PCRI had created and filled two new positions in the Fiscal Department — the Controller and an additional Staff Accountant. The additional staff led to better internal controls and more timely reconciliations throughout 2022. Notwithstanding these efforts, time was needed to train personnel on PCRI systems and emphasis was put on the completion of the subsidiary audits for King Parks Apartments Limited Partnership and MLK & Cook Apartments Limited Partnerships, which are an integral part of the consolidated PCRI audit report, in the early months of 2022 leading to the noted delay in reconciliations for the PCRI audit. In addition to these delays, PCRI once again experienced turnover in the added Staff Accountant position in June of 2023, leading to delays and the employee in the Controller position went on an extended medical leave and subsequently ended employment with PCRI, leading to further delays. Further contributing to delays was the turnover of accounting staff at the property management company with whom PCRI contracts for management of the Maya Angelou and Park Terrace properties which lead to delays in starting those audit engagements which are integral to the consolidated PCRI audit report. In response to this cycle of staff turnover, PCRI contracted with an external service to fill the Staff Accountant position while the search for a permanent employee to fill the position continues to this day, and PCRI has subsequently hired a well-qualified person as Fiscal Director. The property manager for the Maya Angelou and Park Terrace properties has also taken steps to stabilize their accounting operations. These responses have mitigated the risk of delay of future audits as the additional personnel hired in response to the 2021 finding was effective were it not for the untimely turnover of staff during the time when the 2022 PCRI audit was being prepared for and conducted. Anticipated completion date: December 2023

View Audit 356759

Finding 560828 (2022-010)

Material Weakness 2022

Housing Authority of Alto

TX

HUD Housing Programs Reporting

Corrective action planned: Compliance calendar implemented; reports finalized at least 2 weeks before due date. Contact person: Candice Ivory, Executive Director. Anticipated completion date: June 1, 2025/ Ongoing Monitoring

View Audit 356581

Finding 560827 (2022-009)

Material Weakness 2022

Housing Authority of Alto

TX

HUD Housing Programs Internal Control / Segregation of Duties

Corrective action planned: Revised control procedures and checklist system for future SEMAP submissions with backup file requirements. Updated ADMIN plan to enforce Quality Assurance procedure, to be performed quarterly. Contact person: Candice Ivory, Executive Director / Deputy Director Anticip...

Corrective action planned: Revised control procedures and checklist system for future SEMAP submissions with backup file requirements. Updated ADMIN plan to enforce Quality Assurance procedure, to be performed quarterly. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipated completion date: May 31, 2025/ Ongoing Monitoring

View Audit 356581

Finding 560826 (2022-008)

Material Weakness 2022

Housing Authority of Alto

TX

HUD Housing Programs

Corrective action planned: Staff retrained on HUD requirements. Standard audit process implemented for incoming and annual recertifications. Quarterly file reviews and a new checklist for income verification implemented. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipat...

Corrective action planned: Staff retrained on HUD requirements. Standard audit process implemented for incoming and annual recertifications. Quarterly file reviews and a new checklist for income verification implemented. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipated completion date: July 31, 2025/ Ongoing Monitoring

View Audit 356581

Corrective Action Plans

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