Corrective Action Plans

Finding 1205928 (2025-002)

Material Weakness 2025

TX

HUD Housing Programs Allowable Costs / Cost Principles Cash Management

Special Tests – Significant Deficiency in Internal Controls over Compliance (Utility Allocation – Section 811 Program) Management Response Management acknowledges that utility allocation errors occurred in a limited number of instances due to a miscalculation in the allocation spreadsheet. Specifica...

Special Tests – Significant Deficiency in Internal Controls over Compliance (Utility Allocation – Section 811 Program) Management Response Management acknowledges that utility allocation errors occurred in a limited number of instances due to a miscalculation in the allocation spreadsheet. Specifically, utility expenses were allocated among four tenants instead of five occupied tenants, resulting in an overallocation of utility costs to certain residents. The error was due to an input/calculation issue within the allocation spreadsheet and not a deficiency in the underlying allocation methodology. The organization’s documented utility allocation policy requires that total utility costs be allocated equally among occupied tenants, which is consistent with HUD requirements. Management has evaluated the exceptions identified and determined that the issue was isolated to specific instances of spreadsheet error rather than a systemic failure of the allocation methodology. Corrective Actions Implemented / To Be Implemented • The utility allocation spreadsheet will be corrected to ensure that the total number of occupied tenants is accurately reflected in the allocation calculation. • A two-level review control will be implemented over utility allocations. The Leasing Assistant/Clerk will prepare the allocation, and the Leasing Manager will independently verify accuracy prior to finalization. • Verification will include tenant count validation to the rent roll or occupancy report, recalculation of the per-tenant allocation, and confirmation that total allocations agree to the original utility invoice. • Allocation schedules will be supported by rent roll or occupancy documentation. • A standardized checklist will be implemented for monthly allocation procedures. • Any identified allocation errors will be promptly corrected to ensure tenants are not overcharged. Training Training on utility allocation procedures will be conducted by May 1, 2026, for leasing staff and management, with annual refresher training. Responsible Staff: Leasing Assistant/Clerk – Preparation Leasing Manager – Review and verification Controller – Oversight Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions are being implemented immediately upon identification of the finding. Ongoing monitoring will occur monthly.

View Audit 397748

Finding 1205927 (2025-001)

Material Weakness 2025

Accessible Residences, Inc. 113-Hd003

TX

Internal Control / Segregation of Duties Special Tests & Provisions HUD Housing Programs

Special Tests and Provisions – Material Weakness in Internal Controls over Compliance (Replacement Reserve Disbursement – HUD Approval Requirement) Management Response Management acknowledges that a disbursement of $15,000 was made from the replacement reserve account without obtaining prior written...

Special Tests and Provisions – Material Weakness in Internal Controls over Compliance (Replacement Reserve Disbursement – HUD Approval Requirement) Management Response Management acknowledges that a disbursement of $15,000 was made from the replacement reserve account without obtaining prior written approval from HUD, as required under the Capital Advance Regulatory Agreement. Management recognizes that appropriate controls were not in place to prevent disbursement of restricted reserve funds without required approval, resulting in noncompliance. Management has initiated communication with HUD to disclose the transaction and request guidance on the appropriate resolution. The organization will comply with all directives issued by HUD and will continue to follow up as necessary to ensure timely resolution. Corrective Actions Implemented / To Be Implemented • A formal control will be implemented requiring documented written HUD approval prior to any disbursement from the replacement reserve account. • All reserve disbursements will require documented HUD approval prior to processing and will be subject to Controller review to ensure compliance with HUD requirements. • Replacement reserve accounts will be formally designated as restricted funds within internal financial procedures. • A formal policy governing replacement reserve disbursements will be established. • Alternative funding sources will be used when HUD approval is not available. • Training will be provided to relevant staff on HUD requirements and reserve controls.Training Training on reserve account procedures will be conducted by May 1, 2026, with refresher training annually. Responsible Staff: Controller – Oversight of compliance Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions related to implementation of review controls will be implemented immediately. Resolution will follow HUD guidance.

View Audit 397748

Finding 1205904 (2025-001)

Material Weakness 2025

Community Connections, Inc. and Affiliate

DC

HUD Housing Programs Internal Control / Segregation of Duties § 200.303

Finding Reference Number: 2025-001 – Significant Deficiency in Internal Control Over Compliance and Non-Material Non-Compliance Finding: One instance where a unit failed its inspection and re-inspection was not performed or scheduled within the required timeframe. The Organization also failed to aba...

Finding Reference Number: 2025-001 – Significant Deficiency in Internal Control Over Compliance and Non-Material Non-Compliance Finding: One instance where a unit failed its inspection and re-inspection was not performed or scheduled within the required timeframe. The Organization also failed to abate the housing assist payments (HAP) or terminate the HAP contract for this unit in a timely manner. Additionally, for this unit the inspection was not performed on the required biennial basis. Planned Corrective Action: The housing team utilizes Yardi to manage the housing program. The team has been using the software to schedule inspections. Through their internal review, the team confirmed Yardi's reporting capabilities within the system were not being fully utilized to monitor overdue reinspections or trigger abatement actions. This gap contributed to the oversight cited in the audit finding. A retraining on Yardi is being scheduled for April 2026 to ensure the full reporting capabilities within the system will be utilized to ensure proper monitoring of overdue inspections. In addition, there are adequate policies and procedures in place to ensure inspection and reinspection of units, but we will revise current policy to strengthen this area. Anticipated Completion Date: Ongoing with a completion date of April 30, 2026. Name(s) of the Contact Person(s) Responsible for Corrective Action: Ronald Walker, CPA, Vice President, Finance, 202-893-9907, ronald.walker@ccdc1.org Sanique Lyn, MPH, AVP-Clinical Housing, 202-870-5090, slyn@ccdc1.org

View Audit 397707

Finding 1205807 (2025-001)

Material Weakness 2025

Cleveland Supported Housing INC

TX

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Audit Finding 2025-001: Management fees for the year ended December 31, 2025 were paid in excess of the monthly per unit per month cap. - Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $4,452. A receivable was reco...

Audit Finding 2025-001: Management fees for the year ended December 31, 2025 were paid in excess of the monthly per unit per month cap. - Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $4,452. A receivable was recorded for the overpaid management fees at December 31, 2025. The excess fees were refunded to the Project on March 12, 2026. - Name and Title of contact person responsible for corrective action: -Steve Colella, Making a Difference in Property Management, LLC - Management Agent - 6800 Park Ten Blvd, Ste 184-W - San Antonio, TX 78213

View Audit 397556

Finding 1205806 (2025-003)

Material Weakness 2025

Independence Communities INC

TX

HUD Housing Programs

During the year ended December 31, 2025, four tenant move-out files of former tenants could not be located by the staff and management at the Project site. - Management asserts that this was a one-time incident where the previous community director, at the time of leaving, may have inadvertently des...

During the year ended December 31, 2025, four tenant move-out files of former tenants could not be located by the staff and management at the Project site. - Management asserts that this was a one-time incident where the previous community director, at the time of leaving, may have inadvertently destroyed or misplaced the files for the tenants who had moved out.

View Audit 397551

Finding 1205805 (2025-002)

Material Weakness 2025

Independence Communities INC

TX

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Management fees for the year ended December 31, 2025 were paid in excess of the monthly per unit per month cap. - Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $2,629. A receivable was recorded for the overpaid ma...

Management fees for the year ended December 31, 2025 were paid in excess of the monthly per unit per month cap. - Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $2,629. A receivable was recorded for the overpaid management fees at December 31, 2025. The excess fees were refunded to the Project on March 13, 2026.

View Audit 397551

Finding 1205757 (2025-001)

Material Weakness 2025

Jubilee Senior Homes, Inc.

CA

HUD Housing Programs Procurement, Suspension & Debarment Cash Management

JUBILEE SENIOR HOMES INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action plan for th...

JUBILEE SENIOR HOMES INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Timely Deposit of Annual Residual Receipts No. 14.157. Program –Section 202 Supportive Housing for Elderly Personal Significant Deficiency Jubilee should reevaluate its policies and procedures to ensure that required residual receipts deposits are made timely each year. Action Taken: This was an isolated incident for fiscal year ending 6/30/24. As soon as the oversight was realized, we took action to remedy it. In addition, we have updated our process to send out residual receipts deposits once we have a draft audit completed versus waiting until after the final audit to ensure deposits are made before the 9/30 deadline. If there are any changes post audit completion, they should be immaterial and would be deposited as soon as we have final numbers. This will ensure timely deposits. Confirmation of deposits are tracked and will be followed up on regularly to ensure we do not miss the residual receipts distributions from surplus cash in the future. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 397481

Finding 1205754 (2025-001)

Material Weakness 2025

3250 Sacramento Housing, Inc.

CA

HUD Housing Programs Procurement, Suspension & Debarment Cash Management

3250 SACRAMENTO HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan ...

3250 SACRAMENTO HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Timely Deposit of Annual Residual Receipts No. 14.157. Program –Section 202 Supportive Housing for Elderly Personal Significant Deficiency 3250 Sacramento Housing should reevaluate its policies and procedures to ensure that required residual receipts deposits are made timely each year. Action Taken: This was an isolated incident for fiscal year ending 6/30/24. As soon as the oversight was realized, we took action to remedy it. In addition, we have updated our process to send out residual receipts deposits once we have a draft audit completed versus waiting until after the final audit to ensure deposits are made before the 9/30 deadline. If there are any changes post audit completion, they should be immaterial and would be deposited as soon as we have final numbers. This will ensure timely deposits. Confirmation of deposits are tracked and will be followed up on regularly to ensure we do not miss the residual receipts distributions from surplus cash in the future. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 397480

Finding 1205752 (2025-001)

Material Weakness 2025

Bay Bridge Corporation

CA

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

BAY BRIDGE CORPORATION 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Bay Bridge Corporation respectfully submits the following corrective action plan for the year...

BAY BRIDGE CORPORATION 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Bay Bridge Corporation respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.181. Program –Supportive Housing for Persons with Disabilities Significant Deficiency Recommendation: Bay Bridge should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: We hired a new Property Manager for Bay Bridge Apartments, who has worked diligently to complete outstanding recertifications and this property is back on track. All recertifications are now current with one exception due to a lack of tenant cooperation which is being properly managed with legal action. To ensure that staff changes and vacancies do not result in late recertifications in the future, we have employed Property Operations Specialists (roving personnel) to provide coverage if there is staff turnover. We have also increased oversight by the Regional Manager to ensure roving staff remain on track and that recertifications are completed timely. Additionally, senior leadership at the John Stewart Company has implemented enhanced tracking of recertifications across the full portfolio and conducts monthly progress meetings with the management team to monitor compliance, identify risks early, and ensure accountability. We are confident that these corrective actions will result in sustained improvement and ongoing compliance. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 397479

Finding 1205750 (2025-001)

Material Weakness 2025

Vernon Street Housing, Inc.

CA

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

VERNON STREET HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Vernon Street Housing, Inc. respectfully submits the following corrective action plan for ...

VERNON STREET HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Vernon Street Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.181. Program –Supportive Housing for Persons with Disabilities Significant Deficiency Vernon Street Housing, Inc. should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Unanticipated staff shortages created gaps in performance of annual recertifications at this location. New staff has since been hired in the Regional Manager role and the Director role. Both new employees are providing greater oversight and visiting the property regularly to track progress. In addition to our permanent staffing efforts, we have deployed a Property Operations Specialist to bring recertifications current at Vernon Street Housing This specialist is focused specifically on compliance tasks and critical deadlines. Additionally, senior leadership at the John Stewart Company has implemented enhanced tracking of recertifications across the full portfolio and now conducts monthly progress meetings with management team to monitor compliance, identify risks early, and ensure accountability. We are confident that these corrective actions will result in sustained improvement and ongoing compliance. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 397478

Finding 1205743 (2025-001)

Material Weakness 2025

St. Lucy's Senior Living, Inc.

AK

Cash Management HUD Housing Programs Subrecipient Monitoring

We will deposit the delinquent amount when there is sufficient funds to do so.

View Audit 397472

Finding 1205687 (2025-001)

Material Weakness 2025

Mount Zion Madison Street Properties

WA

HUD Housing Programs Cash Management Reporting

Management agrees with the finding and funds will be moved from replacement reserve to residual receipts account.

View Audit 397404

Finding 1205661 (2025-001)

Material Weakness 2025

Sto-Rox Plaza, Inc.

PA

HUD Housing Programs

Finding 2025-001 Department of Housing and Urban Development Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, ALN 14.155. Recommendation: The Property should ensure that established procedures are followed to review the Form HUD-50059 ensuring all document...

Finding 2025-001 Department of Housing and Urban Development Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, ALN 14.155. Recommendation: The Property should ensure that established procedures are followed to review the Form HUD-50059 ensuring all documentation used to calculate the tenant rent and assistance payment is supported and properly calculated. In addition, the Property should calculate the amount owed to the affected tenant as a result of the error and correct it through either a tenant credit or a reimbursement payment, in accordance with HUD requirements. Action taken: The Property Management Company will review with the on-site manager the proper protocols to ensure that established procedures are being followed to review the Form HUD-50059 ensuring all documentation used to calculate the tenant rent and assistance payment is supported and properly calculated. The Property Management Company has reviewed the process with the on-site manager regarding the process of calculating the amount owed to an affected tenant in the event of an error. The management company has recapped with the on-site manager the proper method to correct it through either a tenant credit or a reimbursement payment, in accordance with HUD requirements. If the Department of Housing and Urban Development has questions regarding this plan, please call Dan Barbusio at 412-646-5193.

View Audit 397361

Finding 1205655 (2025-001)

Material Weakness 2025

Independence Heights INC

TX

HUD Housing Programs Reporting

Audit Finding 2025-0001 Funds were withdrawn from the replacement reserve without HUD’s written authorization. Management response: The Project had shortfalls of operational cash and used some funds from the reserve for replacement account to pay for operating expenses and also used some of the fund...

Audit Finding 2025-0001 Funds were withdrawn from the replacement reserve without HUD’s written authorization. Management response: The Project had shortfalls of operational cash and used some funds from the reserve for replacement account to pay for operating expenses and also used some of the funds to replace funds previously withdrawn from the security deposit account. Management will deposit the unauthorized funds as soon as funds are available.

View Audit 397352

Finding 1205646 (2025-001)

Material Weakness 2025

St Camillus Residential Health Care Facility

NY

HUD Housing Programs

CORRECTIVE ACTION PLAN St. Camillus Residential Health Care Facility respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 N. Franklin Street, Suite 100 Syracuse, New York 13204 A...

CORRECTIVE ACTION PLAN St. Camillus Residential Health Care Facility respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 N. Franklin Street, Suite 100 Syracuse, New York 13204 Audit Period: January 1, 2025 – December 31, 2025 The finding from the 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding 2025-001 - Section 232 HUD Insured Mortgage, 14.129 Condition: St. Camillus Residential Health Care Facility (the Facility) has an outstanding receivable from its affiliate, Integrity Home Care Services, Inc. (Integrity), amounting to $463,081. Recommendation: The Facility management should contact HUD representative if the previously communicated repayment plan changed significantly. Action Taken: Integrity Home Care Services, Inc is in the process of being sold to Constant Care 247, LLC. All proceeds from the sale will go towards the repayment of the receivable balance. On December 8, 2025, the Public Health and Health Planning Council approved the change of ownership, certificate of need. The effective date of the change in ownership is expected to be final on or about March 31, 2026. If you have any questions regarding this plan, please contact Michael Zingaro at 315-703-0646 or via email at Michael.Zingaro@St-Camillus.org Sincerely, Michael Zingaro Vice President of Finance St. Camillus RHCF

View Audit 397299

Finding 1205638 (2025-002)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid HUD Housing Programs Material Weakness

Finding 2025-002 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Program (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit regarding the Federal Work-Study (FWS) P...

Finding 2025-002 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Program (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit regarding the Federal Work-Study (FWS) Program for the period ending June 30, 2025. We recognize the gravity of the "material weakness" designation and the systemic nature of the documentation exceptions noted. As the Vice President overseeing these services, I am committed to a rigorous overhaul of our FWS administrative protocols to ensure full compliance with 34 CFR 675.16. To address the root causes of these findings, the College is implementing the following measures immediately: • Mandatory Supervisor Training: All department heads and direct supervisors of FWS students must complete a mandatory compliance seminar. This training emphasizes that no student may be scheduled to work during designated class times and that no wages will be disbursed without a verified, contemporaneous timesheet. • Enhanced Timesheet Verification: We are transitioning to a standardized digital submission process. This system will require: o Verification of the student’s course schedule against hours worked to prevent overlap. o Electronic signatures from both the student and supervisor, timestamped to ensure they are captured prior to payroll processing. • Documentation and Record Retention: The Office of Financial Aid, in coordination with Payroll, will implement a "No Document, No Pay" policy. Documentation for any pay rate changes must now be uploaded and approved by the VP for Enrollment Management and Student Services before being reflected in the Jenzabar system. • Internal Monthly Audits: Starting next month, our internal compliance team will conduct random monthly spot-checks of FWS files (10% of active participants) to ensure all timesheets are present, complete, and accurately reflect hours worked. The College is currently reviewing the identified questioned costs of $10,830.00. We will work closely with the U.S. Department of Education to determine the appropriate restitution or adjustment required for any overpayments resulting from missing documentation. We are dedicated to rectifying these systemic issues and ensuring this does not remain a repeat finding in future audit cycles. Our goal is to maintain the highest level of integrity in our Title IV Student Financial Aid Programs.

View Audit 397293

Finding 1205528 (2025-001)

Material Weakness 2025

Alpha One

ME

Internal Control / Segregation of Duties HUD Housing Programs Significant Deficiency

Management agrees with this finding. Upon identification of the issue, we initiated immediate corrective actions to reinforce our internal control environment and ensure full compliance with our cash disbursement approval policy. We have completed re-training for all accounting staff to reaffirm the...

Management agrees with this finding. Upon identification of the issue, we initiated immediate corrective actions to reinforce our internal control environment and ensure full compliance with our cash disbursement approval policy. We have completed re-training for all accounting staff to reaffirm the requirements of our payment approval policy and to emphasize the importance of verifying documented approval prior to processing any invoice, regardless of the payment method (check, automated withdrawals, or portals). Additionally, management has implemented a system upgrade, transitioning from a manual approval workflow to an automated approval process. This upgraded system is designed to require approval before an invoice can proceed to payment, thereby preventing invoices from being disbursed without documented written authorization. We expect this automated control to significantly reduce the risk of future exceptions and strengthen overall compliance. Management will continue to monitor disbursement activity to ensure ongoing adherence to policy and the effectiveness of the new control measures. The anticipated completion date for this corrective action is 11/1/2025.

View Audit 397202

Finding 1205507 (2025-001)

Material Weakness 2025

City of Pensacola

FL

HUD Housing Programs

The finding from the September 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. The City of Pensacola Housing Department’s direct action in response to the finding is to meet with the Housing Placeme...

The finding from the September 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. The City of Pensacola Housing Department’s direct action in response to the finding is to meet with the Housing Placement Specialists to discuss the finding, review Pensacola Housing’s Administrative Plan and 24 CFR 982.516, clarify the proper procedures for accepting self-declared income, and monitoring for ongoing compliance. Program Manager Nicole Louie will randomly select files from each Housing Placement Specialist’s caseload to complete a quality control review over the next 60 days to ensure proper income-verification procedures are followed. In addition, SEMAP (Section 8 Management Assessment Program) quality control is conducted quarterly by the Housing Office Coordinator as part of the self-scoring assessment submitted to HUD. Any non-compliance identified during the SEMAP quarterly review will be brought to the attention of the Section 8 Program Manager and the Housing Placement Specialist. Name of Contact Person for Completing Corrective Action Plan: Nicole Louie, Program Manager 850-858-0316 nlouie@cityofpensacola.com Expected date of completion is April 30, 2026 FINDING 2025-001 During the review of 40 tenant files, there were three instances a tenant file did not document why third-party income verification was not utilized. After review, the Housing Placement Specialists calculated the income correctly, and there was no resulting over subsidy. However, their notation regarding the acceptance of self-declared income was not captured electronically in the Housing Pro software. Prior to transitioning to electronic files, such notations were documented in the physical file. Moving forward, Housing Eligibility Specialists will be required to record all notes regarding self-declared income directly in the Housing Pro software.

View Audit 397193

Finding 1205469 (2025-002)

Material Weakness 2025

Little City for Community Development

IL

HUD Housing Programs Internal Control / Segregation of Duties

Auditors Recommendation: We recommend that management implement and enforce procedures to ensure Replacement Reserve deposits are made in the required amounts and at the required frequency, including periodic review by management to ensure ongoing compliance with HUD requirements. Action Taken: Goin...

Auditors Recommendation: We recommend that management implement and enforce procedures to ensure Replacement Reserve deposits are made in the required amounts and at the required frequency, including periodic review by management to ensure ongoing compliance with HUD requirements. Action Taken: Going forward, we will create a procedure for the Finance team to make the required deposits to the HUD reserve accounts In the future, noting, dates, and amounts to make. They will be added to our month end reconciliations. We have caught up, and made necessary deposits to date, and are current.

View Audit 397143

Finding 1205468 (2025-001)

Material Weakness 2025

Little City for Community Development

IL

HUD Housing Programs Internal Control / Segregation of Duties

Auditors Recommendation: We recommend that management implement and enforce procedures requiring documented HUD approval prior to any use of replacement reserve funds, including review and approval by appropriate management personnel, to ensure compliance with HUD requirements. Action Taken: We were...

Auditors Recommendation: We recommend that management implement and enforce procedures requiring documented HUD approval prior to any use of replacement reserve funds, including review and approval by appropriate management personnel, to ensure compliance with HUD requirements. Action Taken: We were not aware that use of these funds required HUD approval. We are creating a policy to prevent any use of the HUD Reserve Account funds, without prior approval from HUD. We have subsequently returned all funds that were borrowed with prior HUD authorization, and will not access them in the future, without proper approval from HUD.

View Audit 397143

Finding 1205459 (2025-003)

Material Weakness 2025

Housing Authority of the County of Dauphin

PA

HUD Housing Programs Reporting

Finding Number: 2025-003; Planned Corrective Action:Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all client HUD-50058 reports are completed accurately. A...

Finding Number: 2025-003; Planned Corrective Action:Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all client HUD-50058 reports are completed accurately. Anticipated Completion Date: 6/30/26; Responsible Contact Person: Kristen Runion, HCV Supervisor

View Audit 397134

Finding 1205456 (2025-002)

Material Weakness 2025

Housing Authority of the County of Dauphin

PA

Special Tests & Provisions HUD Housing Programs Internal Control / Segregation of Duties

Finding Number: 2025-002; Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all client files contain documentation ensuring complia...

Finding Number: 2025-002; Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all client files contain documentation ensuring compliance with Rent Reasonableness requirements. Anticipated Completion Date: 6/30/26; Responsible Contact Person: Kristen Runion, HCV Supervisor

View Audit 397134

Finding 1205453 (2025-001)

Material Weakness 2025

Housing Authority of the County of Dauphin

PA

HUD Housing Programs Special Tests & Provisions

Finding Number: 2025-001; Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all clients complete an annual family income reexaminat...

Finding Number: 2025-001; Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all clients complete an annual family income reexamination in accordance with Eligibility, Reporting, and Housing Assistance Payment requirements. Anticipated Completion Date: 6/30/26; Responsible Contact Person: Kristen Runion, HCV Supervisor

View Audit 397134

Finding 1205393 (2025-003)

Material Weakness 2025

City of Dunkirk Housing Authority

NY

HUD Housing Programs

Finding: 2025-001 Policies and procedures Corrective Action Plan: Management will work to develop, formalize, and implement a complete set of accounting policies and procedures. Responsible Party and Anticipated Completion Date: Elizabeth Cardona, Executive Director June 30, 2027 Finding: 2025-002 N...

Finding: 2025-001 Policies and procedures Corrective Action Plan: Management will work to develop, formalize, and implement a complete set of accounting policies and procedures. Responsible Party and Anticipated Completion Date: Elizabeth Cardona, Executive Director June 30, 2027 Finding: 2025-002 NYSERS submissions Corrective Action Plan: Management will work to submit all overdue ERS submissions as soon as possible. Additionally, Management will work to develop processes and procedures to ensure that future submissions are made timely. Management will attempt to obtain any requisite training for the employee(s) who is charged with this task. Responsible Party and Anticipated Completion Date: Elizabeth Cardona, Executive Director June 30, 2026 Finding: 2025-003 Federal grants Corrective Action Plan: Management will work to develop and implement better and more comprehensive policies and procedures to ensure that its grant accounting and management processes are more accurate, more efficient, and in compliance with HUD regulation. Responsible Party and Anticipated Completion Date: Elizabeth Cardona, Executive Director June 30, 2027

View Audit 397082

Finding 1205371 (2025-001)

Material Weakness 2025

Council for Jewish Elderly and Subsidiaries

IL

HUD Housing Programs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding: The company did not implement the HUD approved rent adjustments for October 2024 in a timely fashion. Corrective Actions Taken: Management subsequently made the retroactive adjustments to HUD which have been approved by and paid to HUD. In addition, management has implemented a formal revie...

Finding: The company did not implement the HUD approved rent adjustments for October 2024 in a timely fashion. Corrective Actions Taken: Management subsequently made the retroactive adjustments to HUD which have been approved by and paid to HUD. In addition, management has implemented a formal review and corss-verification process to ensure that rent adjustments are completed accurately and in a timely manner.

View Audit 397066

Corrective Action Plans

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