Corrective Action Plans

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A. Comments on the Finding and Each Recommendation During the year ended December 31, 2025, the project did not make the required monthly deposits to the replacement reserve in the amount of $10,616. Avondale is required to make monthly deposits to the reserve of $1,924. Effective July 1, 2025, the ...
A. Comments on the Finding and Each Recommendation During the year ended December 31, 2025, the project did not make the required monthly deposits to the replacement reserve in the amount of $10,616. Avondale is required to make monthly deposits to the reserve of $1,924. Effective July 1, 2025, the monthly deposits required by HUD increased to $2,090. b. Action(s) Taken or Planned on the Finding All required replacement reserve deposits were brought current as of January 13, 2026. Going forward, management will implement enhanced monitoring procedures to ensure timely monthly funding in accordance with HUD requirements. In the event of cash flow constraints, management will proactively reduce nonessential expenditures or seek an owner contribution to maintain compliance with the regulatory agreement.
a. Comments on the Finding and Each Recomendation: Management agrees that the EIV Income Report for certain slected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120...
a. Comments on the Finding and Each Recomendation: Management agrees that the EIV Income Report for certain slected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 day time frame. b. Action(s) Taken or Planned on the Finding: Management compliance is addressing the generating of EIV reports to align with verification dates (<120 days) rather than when annual recertification notices are generated/sent (at least 120 days). Delays in recertification completion have improved; a majority of the certifications reviewed were effective within first 6 months of transition while the site was still adjusting to new software and management. Additional training has been provided to emphasize the importance of timely reporting and completion.
Section 223 Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities – Assistance Listing No. 14.157 Recommendation: The auditor recommends that management update its policies and procedures on monitoring policy coverage to ensure that cover...
Section 223 Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities – Assistance Listing No. 14.157 Recommendation: The auditor recommends that management update its policies and procedures on monitoring policy coverage to ensure that coverage is adequate to cover collections. The auditor also recommends that management update its fidelity policy to bring the Project back into compliance.. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: (1) Management will include an updated policy concerning annual re-verification of its fidelity policy such that the policy limits will exceed HUDs ongoing requirements for coverage. (2) Management will immediately increase limits from the previous limits ($3.5M) to a new higher limit ($5M) that will be well in excess of HUDs current requirements. Name(s) of the contact person(s) responsible for corrective action: Paul Kemp Planned completion date for corrective action plan: March 31, 2026
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Action Taken: The Organization accepts the recommendation of Deming, Malone...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Action Taken: The Organization accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized on the monthly vouchers when a move out is processed. The overpayment of subsidy received should be repaid to HUD. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-...
Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized on the monthly vouchers when a move out is processed. The overpayment of subsidy received should be repaid to HUD. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all move out adjustments processed utilize the proper vacancy date. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billing.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting ...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that all documents related to recertification are acquired. Additionally, tenant files should be reviewed to ensure all supporting documentation is ...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that all documents related to recertification are acquired. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Thompson-Woodlief Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that tenant recertifications are documented in accordance with HUD guidelines and that proper documentation is maintained within the tenant files.
Recommendation: The design of the current controls should be reviewed to ensure that all withdrawals from the reserve for replacement agree to the amount approved by HUD. The Organization should return the excess funds withdrawn to the reserve. Action Taken: The management of Jude’s Place Apartments...
Recommendation: The design of the current controls should be reviewed to ensure that all withdrawals from the reserve for replacement agree to the amount approved by HUD. The Organization should return the excess funds withdrawn to the reserve. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all withdrawals from the reserve for replacement agree to the amount approved by HUD. The excess funds withdrawn were returned to the reserve in May 2025.
Recommendation: The design of the current controls should be reviewed to ensure that information used on Form 50059 in the calculation of tenant payments should agree to the supporting documentation maintained in tenant files. Overpayment of subsidy should be repaid to HUD. Action Taken: The managem...
Recommendation: The design of the current controls should be reviewed to ensure that information used on Form 50059 in the calculation of tenant payments should agree to the supporting documentation maintained in tenant files. Overpayment of subsidy should be repaid to HUD. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that information used on Form 50059 in the calculation of tenant payments should agree to the supporting documentation maintained in tenant files. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before processing. The Organization should repay the overpayment of subsidy to HUD. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommen...
Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before processing. The Organization should repay the overpayment of subsidy to HUD. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all adjustments to monthly billings are reviewed to ensure they are processed correctly. Overpayment of subsidy will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting docu...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before submission. The Organization should repay the overpayment of subsidy to HUD. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recomme...
Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before submission. The Organization should repay the overpayment of subsidy to HUD. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all adjustments to monthly billings are reviewed before submission.. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized in the event of a deceased tenant. The overpayment of subsidy received on behalf of the deceased tenant should be repaid to HUD. Action Taken: The management of Edsil’s Place Apartments,...
Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized in the event of a deceased tenant. The overpayment of subsidy received on behalf of the deceased tenant should be repaid to HUD. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that move-outs as a result of a deceased tenant are processed in accordance with HUD guidelines. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting docu...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Recommendation: The design of the current controls should be reviewed to ensure adjustments made to the monthly billings are accurate before submission. Excess subsidy payments should be repaid to HUD. Action Taken:The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming,...
Recommendation: The design of the current controls should be reviewed to ensure adjustments made to the monthly billings are accurate before submission. Excess subsidy payments should be repaid to HUD. Action Taken:The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all adjustments to monthly billings are reviewed for accuracy before submission. Excess subsidy received will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting ...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure the process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Section 811 – Capital Advances, Section 811 – Project Rental Assistance Recommendation: The Organization should comply with HUD requirements and wait until receipt of HUD approval before withdrawing any funding from the Reserve for Replacement account. Explanation of disagreement with audit finding:...
Section 811 – Capital Advances, Section 811 – Project Rental Assistance Recommendation: The Organization should comply with HUD requirements and wait until receipt of HUD approval before withdrawing any funding from the Reserve for Replacement account. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will take steps to adjust the budget and ensure there is proper approval before withdrawing and funds from the R&R account moving forward. Name(s) of the contact person(s) responsible for corrective action: Phil Pasmanik, Treasurer Planned completion date for corrective action plan: 03/31/2026
Section 811 – Capital Advances, Section 811 – Project Rental Assistance Recommendation: The Organization should review its budgeting process to ensure compliance with HUD funding requirements for the reserve for replacement account. Additionally, they should implement regular monitoring to prevent f...
Section 811 – Capital Advances, Section 811 – Project Rental Assistance Recommendation: The Organization should review its budgeting process to ensure compliance with HUD funding requirements for the reserve for replacement account. Additionally, they should implement regular monitoring to prevent future underfunding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will take steps to adjust the budget and ensure the Reserve for Replacement account is adequately funded moving forward. Name(s) of the contact person(s) responsible for corrective action: Phil Pasmanik, Treasurer Planned completion date for corrective action plan: 03/31/2026
Agree with the facts and circumstances described above. Subsequent to year end, the Organization will be opening a separate security deposit account to hold the cash.
Agree with the facts and circumstances described above. Subsequent to year end, the Organization will be opening a separate security deposit account to hold the cash.
Name of auditee: Benjamin Hershey Memorial Convalescent Home HUD auditee identification number: 074-11175 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Jessica Ward Position: Chief Financial Officer Telephone number: 402...
Name of auditee: Benjamin Hershey Memorial Convalescent Home HUD auditee identification number: 074-11175 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Jessica Ward Position: Chief Financial Officer Telephone number: 402-333-7373 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2025-001: Comments on the Finding and Each Recommendation: The Corporation did not provide HUD with a completed annual financial report by March 31, 2026, as required by HUD. Pursuant to the terms of the Regulatory Agreement, within ninety (90) days following the end of each fiscal year, the Corporation shall provide a complete annual financial report based upon an examination of the books and records of the Community prepared in accordance with the requirements of HUD and certified by a Certified Public Accountant or other person acceptable to the Commissioner. As a result, the Corporation was not in compliance with the Regulatory Agreement. The annual financial statements should be issued in a timely manner pursuant to the time frame set forth by HUD. Action(s) taken or planned on the finding: The audit report as of and for the year ended June 30, 2025 has been submitted to HUD. No further action is required.
Repeat finding 2024-005 The City will establish policies, procedures and internal controls to ensure that all subrecipient CAPER reports are reconciled to the IDIS system and submitted to HUD within 90 days of year end.
Repeat finding 2024-005 The City will establish policies, procedures and internal controls to ensure that all subrecipient CAPER reports are reconciled to the IDIS system and submitted to HUD within 90 days of year end.
Special Tests and Provisions – Assistance Listing No. 14.267 Recommendation: We recommend program managers verify that rent reasonableness checklists and certifications are fully completed by HUD staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...
Special Tests and Provisions – Assistance Listing No. 14.267 Recommendation: We recommend program managers verify that rent reasonableness checklists and certifications are fully completed by HUD staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement a supervisory review process requiring program managers to review and formally sign off on rent reasonableness checklists and certifications. Staff will receive refresher training on completion requirements, and management will periodically review files to ensure documentation is complete and properly approved. Name(s) of the contact person(s) responsible for corrective action: Jamie Rotter Planned completion date for corrective action plan: 6/30/2026
United States Department of Housing and Urban Development Good Shepherd Homes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 01, 2025 - December 31, 2025 The findings from the schedule of findings and questioned costs are d...
United States Department of Housing and Urban Development Good Shepherd Homes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 01, 2025 - December 31, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS United States Department of Housing and Urban Development SIGNIFICANT DEFICIENCY 2025-001 Section 223(f) Mortgage Insurance for the Refinance of Existing Multifamily Housing Projects Federal Assistance Listing #14.155 Recommendation: We recommend that management deposit the remaining $770 to the residual receipts account as soon as possible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management deposited the $770 into the residual receipts account on March 12, 2026. Management will ensure moving forward that if the Project has surplus cash, the correct amount will be deposited into the residual receipts account. Name(s) of the contact person(s) responsible for corrective action: Krista Martini, Chief Financial Officer Planned completion date for corrective action plan: March 12, 2026 If the United States Department of Housing and Urban Development has questions regarding this plan, please call Krista Martini at 320-259-3490.
Section 202 - Supportive Housing for the Elderly Mortgage Financing– Assistance Listing No. 14.157 Recommendation: We recommend the funds over the FDIC limit be collateralized or insured, or invested at a bank with an approved HUD accepted rating. Explanation of disagreement with audit finding: Ther...
Section 202 - Supportive Housing for the Elderly Mortgage Financing– Assistance Listing No. 14.157 Recommendation: We recommend the funds over the FDIC limit be collateralized or insured, or invested at a bank with an approved HUD accepted rating. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will monitor funds held at Busey closely and exercise one of the following two options mentioned above. Name(s) of the contact person(s) responsible for corrective action: Jeff Cottingham, Property Manager Planned completion date for corrective action plan: 2026
Audit Finding 2025-001: Per the HUD management fee schedule for owners and agents, the basic rate for management fees is $50 per unit per month (pupm). The Project qualifies for add-on fees of $8 pupm for having 16 to 30 units in property and $3 pupm for being a Sec 811 property with the total cap o...
Audit Finding 2025-001: Per the HUD management fee schedule for owners and agents, the basic rate for management fees is $50 per unit per month (pupm). The Project qualifies for add-on fees of $8 pupm for having 16 to 30 units in property and $3 pupm for being a Sec 811 property with the total cap of management fees at $61 pupm. - Management fees for the year ended December 31, 2025 were paid in excess of the monthly pupm cap. Response: Management miscalculated the management fees for the year ended December 31, 2025, and hence, fees were paid in excess of the cap by $4,183. The excess fees were paid back to the Project on March 20, 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
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