Corrective Action Plans

Finding 52316 (2022-003)

Significant Deficiency 2022

WI

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Supporting Documentation for Family Size Allowable Costs, Eligibility ? Housing Choice Vouchers ? CFDA No. 14.871 Recommendation: ICS should review their current processes and create an internal monitoring system to ensure appropriate forms and supporting documentation are in the file in the future...

Supporting Documentation for Family Size Allowable Costs, Eligibility ? Housing Choice Vouchers ? CFDA No. 14.871 Recommendation: ICS should review their current processes and create an internal monitoring system to ensure appropriate forms and supporting documentation are in the file in the future and/or consider additional training for housing specialist to ensure HAP is appropriately calculated based on information received. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ICS will provide additional training for staff regarding how to document family size, voucher size, and citizenship. Proper documentation will be reviewed and files will continue to be reviewed monthly for compliance. Names of the contact persons responsible for corrective action: Matt Roberts and Megan Walker Planned completion date for corrective action plan: Immediately

View Audit 45610 Questioned Costs: $1

Finding 52315 (2022-002)

Significant Deficiency 2022

Integrated Community Solutions, Inc.

WI

HUD Housing Programs Subrecipient Monitoring Eligibility

Supporting Documentation in Tenant Files Eligibility, Special Tests ? Housing Assistance Payment ? Housing Choice Vouchers ? CFDA No. 14.871 Recommendation: ICS should create an internal monitoring system to ensure that tenant files are scanned/saved appropriately, and the documentation meets all ...

Supporting Documentation in Tenant Files Eligibility, Special Tests ? Housing Assistance Payment ? Housing Choice Vouchers ? CFDA No. 14.871 Recommendation: ICS should create an internal monitoring system to ensure that tenant files are scanned/saved appropriately, and the documentation meets all program guidelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ICS will continue to have specialists scan in their own files. Specialists will review the file to assure that documents have been scanned properly and are legible before saving electronic file. Names of the contact persons responsible for corrective action: Matt Roberts and Megan Walker Planned completion date for corrective action plan: Immediately

View Audit 45610

Finding 52314 (2022-001)

Significant Deficiency 2022

Integrated Community Solutions, Inc.

WI

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Calculating Expenses for Family Income Examinations Allowable Costs, Eligibility ? Housing Choice Vouchers ? CFDA No. 14.871 Recommendation: ICS should review their current processes and create an internal monitoring system to ensure expenses are appropriately calculated in the future and/or consid...

Calculating Expenses for Family Income Examinations Allowable Costs, Eligibility ? Housing Choice Vouchers ? CFDA No. 14.871 Recommendation: ICS should review their current processes and create an internal monitoring system to ensure expenses are appropriately calculated in the future and/or consider additional training for housing specialist to ensure HAP is appropriately calculated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ICS will provide additional training for staff regarding expense calculation. ICS will also continue to review files monthly and review any errors that are occurring with specialists in order to prevent additional errors in the future. Names of the contact persons responsible for corrective action: Matt Roberts and Megan Walker Planned completion date for corrective action plan: Immediately.

View Audit 45610 Questioned Costs: $1

Finding 52186 (2022-002)

Material Weakness 2022

City of Niagara Falls, New York

NY

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Name of Auditee: City of Niagara Falls, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2022 CAP Prepared by: Daniel Morello, City Controller Phone: (716) 286-4346 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (...

Name of Auditee: City of Niagara Falls, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2022 CAP Prepared by: Daniel Morello, City Controller Phone: (716) 286-4346 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2022-002 Management's Response The City is in agreement with this audit finding. Due in part to delays in finalizing both the 2021-2022 annual action plan and the 2022-2023 annual action plan, the City was delayed in being able to utilize those funds until approval was provided by HUD. The City continues to direct funds to projects that have the ability to be completed in a timely manner in order to be consistent with the CDBG regulation related to timeliness. The City is aware of the timeliness requirements and will continue to select projects that better allow the City to operate in accordance with these regulations. Estimated Completion Date - Next HUD verification date of May 1, 2024

View Audit 50058

Finding 52172 (2022-001)

Significant Deficiency 2022

Union Plaza Apartments Ca 16l000119

CA

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

Finding #2022-001 (Assistance Listing 14.195) Comments on the Finding and Each Recommendation The Form SF-SAC Single Audit Data Collection Form for the year ended June 30, 2021 was not submitted within the required timeframe to the federal audit clearinghouse. Management should submit the Form SF-...

Finding #2022-001 (Assistance Listing 14.195) Comments on the Finding and Each Recommendation The Form SF-SAC Single Audit Data Collection Form for the year ended June 30, 2021 was not submitted within the required timeframe to the federal audit clearinghouse. Management should submit the Form SF-SAC Single Audit Data Collection Form within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period. Action(s) Taken or Planned on the Finding Agree. Form SF-SAC Single Audit Data Collection Form for the year ended June 30, 2021 was submitted to the federal audit clearinghouse on May 31, 2022. No further action is required.

View Audit 47372

Finding 52170 (2022-001)

Significant Deficiency 2022

Jennings Manor Housing Corporation

OH

HUD Housing Programs Reporting

Finding Resolution Status: Unresolved Information on Universe Population Size: Not applicable Sample Size Information: Not applicable Identification of Repeat Finding and Finding Reference Number: Not applicable. Criteria:T...

Finding Resolution Status: Unresolved Information on Universe Population Size: Not applicable Sample Size Information: Not applicable Identification of Repeat Finding and Finding Reference Number: Not applicable. Criteria:The Corporation is required to be maintained in good repair and condition. Statement of Condition: REAC physical inspections with scores of 60 or below are referred to HUD?s Departmental Enforcement Center. Cause: The Corporation received a score of 51c on its September 3, 2021 REAC physical inspection. Effect or Potential Effect: The Corporation is required to be maintained in good repair and condition. Auditor Noncompliance Code: I ? Failure to maintain property/open physical inspection. Questioned Cost: $0 Reporting Views of Responsible Officials: See management?s response FHA/Contract Number: 042EE077 Questioned Costs: $0 Context: The Corporation is required to be maintained in good repair and condition. Recommendation: Improvements should be made to the Corporation to maintain good repair and condition. Auditor?s Summary of the Auditee?s Comments on the Finding and Recommendation: Repairs and improvements have been completed by the Corporation. Response Indicator: Agree Response: Management has completed the required repairs to the property and is awaiting for the follow up inspection from HUD. Contact Person: Matthew Bollin

View Audit 43537

Finding 52154 (2022-001)

Significant Deficiency 2022

Ransom Avenue Development Corporation 047-11072

MI

HUD Housing Programs Procurement, Suspension & Debarment Reporting

Finding Number: 2022-001 Condition: The Organization did not deposit surplus cash calculated for the year ended June 30, 2021 of $1,965 90 days after year-end as stated in the Real Estate Assessment Center?s Summary of Financial Reporting and Auditing Guidance for HUD (FRAG Guide) under Section 2.8....

Finding Number: 2022-001 Condition: The Organization did not deposit surplus cash calculated for the year ended June 30, 2021 of $1,965 90 days after year-end as stated in the Real Estate Assessment Center?s Summary of Financial Reporting and Auditing Guidance for HUD (FRAG Guide) under Section 2.8. Planned Corrective Action: Management acknowledges noncompliance has taken measures to improve internal controls over compliance. Management deposited current year surplus cash within 90 days of June 30, 2022. Contact person responsible for corrective action: Kris Endres, Finance Manager Anticipated Completion Date: Completed August 2022.

View Audit 48947

Finding 52126 (2022-003)

Significant Deficiency 2022

Commonwealth of Puerto Rico Municipality of Sabana Grande

PR

HUD Housing Programs Reporting Significant Deficiency

Reports and expense reports have been submitted to CRF Municipalities Closeout. Auditors from the U.S. have visited us twice. We have provided all the information that they have requested in these visits. Finally we did reimbursed the balance not used. Contact Tracing Reports were submitted month...

Reports and expense reports have been submitted to CRF Municipalities Closeout. Auditors from the U.S. have visited us twice. We have provided all the information that they have requested in these visits. Finally we did reimbursed the balance not used. Contact Tracing Reports were submitted monthly in 2021-2022.

View Audit 53614

Finding 52124 (2022-002)

None 2022

Burleson Voa Elderly Housing, INC (thomas Square Apts)

VA

HUD Housing Programs Cash Management Reporting

Finding Reference Number: 2022-002 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to submit to HUD. Completion Date: August 5, 2022

View Audit 51078

Finding 52121 (2022-001)

None 2022

Kerrville Voa Elderly Hsg, INC (kerrville Oaks)

VA

HUD Housing Programs Reporting

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to offset future Section 8 HAP requests. Completion Date: August 12, 20...

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to offset future Section 8 HAP requests. Completion Date: August 12, 2022

View Audit 51071

Finding 52120 (2022-001)

None 2022

Houston Voa Independent Housing, INC (heights Manor)

VA

HUD Housing Programs Cash Management Reporting

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to submit to HUD. Completion Date: August 9, 2022

View Audit 51070

Finding 52119 (2022-001)

None 2022

Fredericksburg Voa Elderly Housing, INC (evergreen Villa)

VA

HUD Housing Programs Reporting

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to offset future Section 8 HAP requests. Completion Date: August 12, 20...

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to offset future Section 8 HAP requests. Completion Date: August 12, 2022

View Audit 50098

Finding 52118 (2022-001)

None 2022

South Texas Voa Elderly Housing, Inc. (country Village Square)

LA

HUD Housing Programs Reporting

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to offset future Section 8 HAP requests. Completion Date: August 12, ...

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to offset future Section 8 HAP requests. Completion Date: August 12, 2022

View Audit 50097

Finding 52117 (2022-001)

Significant Deficiency 2022

Gabriel Manor Housing, Inc.

MS

Procurement, Suspension & Debarment HUD Housing Programs Reporting

U.S. Department of Housing and Urban Development Program Name: Section 223(F) Mortgage Insurance for the Purchase or Refinancing of Exiting Multifamily Housing Projects Federal Assistance Listing Number: 14.155 Grant Number: 065-11078-PM Gabriel Manor Housing, Inc. (the ?Project?) respectfully subm...

U.S. Department of Housing and Urban Development Program Name: Section 223(F) Mortgage Insurance for the Purchase or Refinancing of Exiting Multifamily Housing Projects Federal Assistance Listing Number: 14.155 Grant Number: 065-11078-PM Gabriel Manor Housing, Inc. (the ?Project?) respectfully submits the following corrective action plan for the year ended September 30, 2022. Audit Firm: McNorton Ishee & Jones, PC 3662 Dauphin St., Ste. E Mobile, AL 36608 Audit period: For the year ended September 30, 2022 Finding 2022-001: Other Findings Statement of Condition: The project has not filed their prior year annual single audit reporting package in the Federal Audit Clearinghouse website. Corrective Action: Management will ensure that they submit the project?s annual single audit reporting package in the Federal Audit Clearinghouse website. If the U.S. Department of Housing and Urban Development should have any questions or comments regarding this plan, please contact Craig Bounds at (228) 435-1642.

View Audit 47198

Finding 52103 (2022-002)

Significant Deficiency 2022

Caritas Manor, Inc.

MS

Questioned Costs Special Tests & Provisions Cash Management

U.S Department of Housing and Urban Development - Supportive Housing for the Elderly, Federal Assistance Listing Number 14.157 Caritas Manor, Inc. HUD Project No. 065-EE003-CA, respectfully submits the following corrective action plan for the year ended September 30, 2022. Audit Firm: McNorton Ish...

U.S Department of Housing and Urban Development - Supportive Housing for the Elderly, Federal Assistance Listing Number 14.157 Caritas Manor, Inc. HUD Project No. 065-EE003-CA, respectfully submits the following corrective action plan for the year ended September 30, 2022. Audit Firm: McNorton Ishee & Jones, PC 3662 Dauphin St., Ste. E Mobile, AL 36608 Audit period: September 30, 2022 Finding 2022-002: Special Tests and Provisions ? Residual Receipts Account State of Condition: The required residual receipts deposit was not made timely. Corrective Action: The project made the required residual receipts deposit on December 10, 2022. Management will ensure that the required residual receipts deposits are made timely. If the Department of Housing and Urban Development should have any questions or comments regarding this plan, please contact Craig Bounds at (228) 435-1642.

View Audit 43417 Questioned Costs: $1

Finding 52026 (2022-001)

Material Weakness 2022

The Salvation Army Residence Inc., A Florida Corporation

FL

HUD Housing Programs Reporting Special Tests & Provisions

1 CORRECTIVE ACTION PLAN Project Legal Name: William Booth Towers Orlando, FL (A Project of The Salvation Army Residences, Inc., a Florida Corporation) HUD Project No.: 067-11269 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-9/30/2022 Corrective Action Plan prepared by: Name: Sr...

1 CORRECTIVE ACTION PLAN Project Legal Name: William Booth Towers Orlando, FL (A Project of The Salvation Army Residences, Inc., a Florida Corporation) HUD Project No.: 067-11269 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-9/30/2022 Corrective Action Plan prepared by: Name: Sriparna Mitra Position: HUD Specialist, THQ (Legal) Telephone Number: 404-728-6700 A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation Management is working to get the audit done in a more timely manner so that the calculation for residual receipts can be completed in time to make any necessary deposits within the required deadline. The intent is to begin the FY 23 audit prior to fiscal year end to allow for customary preliminary audit work. b. Action(s) Taken or Planned on the Finding On February 11, 2022 the Project remitted the residual receipts funds to HUD for the fiscal year ended Sep 30, 2021. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Year Findings, Questioned Costs and Recommendations 1. Finding 2021-001 Cleared. 2. Finding 2021-002 Cleared.

View Audit 49453

Finding 52023 (2022-002)

Material Weakness 2022

William Booth Residence, Inc., A Texas Corporation

TX

HUD Housing Programs Eligibility

CORRECTIVE ACTION PLAN Project Legal Name: William Booth Gardens Apartments Houston, TX (? Project of William Booth Residence, Inc., A Texas Corporation) HUD Project No.: 114-EE006-NP-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-5/10/2022 (day before sale) Corrective Action...

CORRECTIVE ACTION PLAN Project Legal Name: William Booth Gardens Apartments Houston, TX (? Project of William Booth Residence, Inc., A Texas Corporation) HUD Project No.: 114-EE006-NP-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-5/10/2022 (day before sale) Corrective Action Plan prepared by: Name: Sriparna Mitra Position: HUD Specialist, THQ (Legal) Telephone Number: 404-728-6700 A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 2. Finding 2022-001 c. Comments on the Finding and Each Recommendation The auditee agrees with the finding that a sample of tenant lease files tested were missing evidence of EIV report data. d. Action(s) Taken or Planned on the Finding Management agrees with the finding. The property was sold prior to the end of FY 2022, with HUD approval, and all tenant files were trasnferred to the buyer. Therefore, we consider this matter closed. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Year Findings, Questioned Costs and Recommendations Finding 2021-001 Cleared.

View Audit 49452

Finding 52022 (2022-001)

Significant Deficiency 2022

William Booth Residence, Inc., A Texas Corporation

TX

Special Tests & Provisions HUD Housing Programs Reporting

CORRECTIVE ACTION PLAN Project Legal Name: William Booth Gardens Apartments Houston, TX (? Project of William Booth Residence, Inc., A Texas Corporation) HUD Project No.: 114-EE006-NP-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-5/10/2022 (day before sale) Corrective Action...

CORRECTIVE ACTION PLAN Project Legal Name: William Booth Gardens Apartments Houston, TX (? Project of William Booth Residence, Inc., A Texas Corporation) HUD Project No.: 114-EE006-NP-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-5/10/2022 (day before sale) Corrective Action Plan prepared by: Name: Sriparna Mitra Position: HUD Specialist, THQ (Legal) Telephone Number: 404-728-6700 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The property obtained a HUD-approved management agent certification effective upon sale of the property on May 11, 2022. Additionally, the management company had prior HUD approval for other entities, and no management fees were paid to the new management agent during the audit period. The property has transitioned to a new owner with a HUD-approved management agent certification. b. Action(s) Taken or Planned on the Finding The Organization agrees with the finding and notes that the property has transitioned to a new owner with a HUD-approved management agent certification. 2. Finding 2022-001 c. Comments on the Finding and Each Recommendation The auditee agrees with the finding that a sample of tenant lease files tested were missing evidence of EIV report data. d. Action(s) Taken or Planned on the Finding Management agrees with the finding. The property was sold May 11, 2022 with HUD approval and all tenant files were transferred to buyer. Therefore, we consider this matter closed. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Year Findings, Questioned Costs and Recommendations Finding 2021-001 Cleared.

View Audit 49452

Finding 52016 (2022-001)

Significant Deficiency 2022

Ucr of Marion, Ohio Inc. D/b/a Brownstone Terrace

OH

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

1. Comments on Findings and Recommendation Management acknowledges failure to comply with timely EIV Master File Reports required to be completed as part of tenant move in certification process and EIV Master File process. 2. Actions Taken or Planned The Corporation will regularly monitor and recon...

1. Comments on Findings and Recommendation Management acknowledges failure to comply with timely EIV Master File Reports required to be completed as part of tenant move in certification process and EIV Master File process. 2. Actions Taken or Planned The Corporation will regularly monitor and reconcile the creation and retention of background checks and Income reports as part of the move in process. Additional training was provided and corrective action was taken. Management is reviewing and revising the EIV policy. 3. Status of Corrective Actions on Prior Findings The Corporation did not remediate the prior year finding for failure to comply with timely EIV Income Reports.

View Audit 47883

Finding 52015 (2022-001)

Significant Deficiency 2022

Ucc Xvii, Inc. D/b/a Biimaadiiziiwiin

OH

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

Corrective Action Plan Finding Number: 2022-001 Condition: HUD guidelines regarding the EIV system were not followed and the EIV system reports were not utilized timely during 2022. Planned Corrective Action: Management has implemented guidelines and trainings surrounding the use of the EIV system....

Corrective Action Plan Finding Number: 2022-001 Condition: HUD guidelines regarding the EIV system were not followed and the EIV system reports were not utilized timely during 2022. Planned Corrective Action: Management has implemented guidelines and trainings surrounding the use of the EIV system. Management will continue to monitor the appropriate use of the EIV system. Contact person responsible for corrective action: Julie Reed, Housing Accounting Manager Anticipated Completion Date: December 31, 2023

View Audit 47574

Finding 52010 (2022-002)

Material Weakness 2022

Salem Lodge of B'nai B'rith Housing Corporation 034-44814-Np

PA

Special Tests & Provisions Allowable Costs / Cost Principles HUD Housing Programs

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS: Internal control over compliance / compliance Finding number 2022-002 Section 207 pursuant to Section 223(f) loan: Federal Agency: U.S. Department of Housing and Urban Development Pass-through entity: None HUD Project number: 034-44814 NP Condi...

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS: Internal control over compliance / compliance Finding number 2022-002 Section 207 pursuant to Section 223(f) loan: Federal Agency: U.S. Department of Housing and Urban Development Pass-through entity: None HUD Project number: 034-44814 NP Condition and criteria: As required by the Section 207 pursuant to Section 223(f) HUD insured loan, the Corporation is required to keep funds collected as a security deposit in the name of the project, in an account separate and apart from all other funds of the project, with the amount of this account at all times equal to or exceeding the aggregate of all outstanding security deposits. All disbursements from the security deposit account must be only for refunds to tenants and for payment of expenses incurred by or on behalf of the tenant. The contracted management company had transferred funds out of the security deposit account to the operating account to cover operations during the fiscal year ended October 31, 2022, leaving insufficient funds in the security deposit account to cover outstanding security deposits. Cause: For the fiscal year ended October 31, 2022, the Corporation did not have adequate internal controls over compliance in place for the area of special tests and provisions to ensure that the security deposit account funds were properly always separated from other funds of the Corporation. Effect: As a result of unallowable disbursements from the security deposit account, the Corporation and management company will not be in compliance with the special tests and provisions compliance requirement, may not have sufficient funds to cover the security deposit liability, and could be restricted from entering into any new business with HUD. Recommendation: The Corporation, along with the contracted management company, should develop effective internal control procedures to ensure that the security deposit account always have sufficient funds to cover the security deposit liability and that no unallowable disbursements from the account occur. The Corporation?s and contracted management company?s response / corrective action: The contracted management company took the appropriate steps to set up controls over the security deposit account to ensure only allowable disbursements occur, and that the account funds are always sufficiently separated to cover the security deposit liability. Sincerely, ____________________________________ Jody Dimpsey, Management Agent Salem Lodge of B?nai B?rith Housing Corporation

View Audit 45379

Finding 52009 (2022-001)

Significant Deficiency 2022

Salem Lodge of B'nai B'rith Housing Corporation 034-44814-Np

PA

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

January 30, 2023 U.S. Department of Housing and Urban Development Salem Lodge of B?nai B?rith Housing Corporation (the Corporation) respectfully submits the following corrective action plan for the year ended October 31, 2022. Name and address of independent accounting firm: Brown Schultz Sherid...

January 30, 2023 U.S. Department of Housing and Urban Development Salem Lodge of B?nai B?rith Housing Corporation (the Corporation) respectfully submits the following corrective action plan for the year ended October 31, 2022. Name and address of independent accounting firm: Brown Schultz Sheridan & Fritz 210 Grandview Avenue Camp Hill, PA 17011 Audit period: November 1, 2021 ? October 31, 2022 Findings #2022-001 and #2022-002 from the schedule of findings and questioned costs for the year ended October 31, 2022 are discussed on the following page. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS: Internal control over compliance / compliance Finding number 2022-001 Section 207 pursuant to Section 223(f) loan: Federal Agency: U.S. Department of Housing and Urban Development Pass-through entity: None HUD Project number: 034-44814 NP Condition and criteria: As required by the Section 207 pursuant to Section 223(f) HUD insured loan, the Corporation is required to prepare and submit monthly reports of excess income (Form HUD-93094) in accordance with HUD instructions and in a timely manner. The contracted management company, on behalf of the Corporation, had failed to timely submit one of the monthly reports of excess income for the fiscal year ended October 31, 2022. Cause: For the fiscal year ended October 31, 2022, the Corporation did not have adequate internal controls over compliance in place for the area of reporting to ensure all required financial reporting was filed timely. Effect: As a result of failing to properly submit required financial reporting in a timely manner, the Corporation and management company will not be in compliance with the reporting compliance requirement, and could have been restricted from entering into any new business with HUD. Recommendation: The Corporation, along with the contracted management company, should develop effective internal control procedures to ensure all required financial reporting is filed timely. The Corporation?s and contracted management company?s response / corrective action: The contracted management company took the appropriate steps to set up automatic reporting for property managers each month. Sincerely, ____________________________________ Jody Dimpsey, Management Agent Salem Lodge of B?nai B?rith Housing Corporation

View Audit 45379

Finding 51969 (2022-004)

Significant Deficiency 2022

Howard County Housing Commission

MD

Questioned Costs HUD Housing Programs Significant Deficiency

2022-004 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated. Explanation of disagreement with audit finding: There is no disagreement with the audit fi...

2022-004 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The following actions are currently taking place to ensure abatement procedures are met when required due to failed inspections: ? The HCHC will ensure that its third-party HQS inspectors provide data on all fails that require abatement. To achieve this, the third-party inspection company has created a working document that will be updated twice a week with units that have failed twice and are recommended for abatement. The document will be shared with the Commission after each update. ? The assigned HCV Specialist will notify the landlord and tenant of the failed inspection and specific deficiencies that must be corrected. ? The assigned HCV Specialist will ensure that the third-party inspection company re-inspects to verify that the repairs have been completed and meet HQS standards. ? If the landlord fails to make the repairs by the established deadline, the HCHC will initiate abatement procedures by withholding or reducing housing assistance payments (HAP) once the unit passes inspection. The Director and Program Manager will review the inspection reports and initiate abatement. ? The assigned HCVP Specialist will provide the tenant with information and assistance to find alternative housing, such as issuing a new voucher, extending the search time, or offering relocation expenses. ? The HCHC will terminate the HAP contract with the landlord if the unit remains abated for more than 180 days or if the landlord fails to comply with other contractual obligations. The Director of Rental Assistance and the Program manager will review all recommended abatements monthly to determine who will be terminated from the HCV program. We will review all Yardi reports and the recommended abatement spreadsheet from the third-party inspector. Name(s) of the contact person(s) responsible for corrective action: Paul Diggs, Director of HCVP Planned completion date for corrective action plan: December 31, 2023

View Audit 49580 Questioned Costs: $1

Finding 51968 (2022-003)

Material Weakness 2022

Howard County Housing Commission

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022-003 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend the Commission review their HQS inspection policies and procedures, and discuss these standards with the third party inspection company that is utilized for these inspections to ensure all inspections are performe...

2022-003 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend the Commission review their HQS inspection policies and procedures, and discuss these standards with the third party inspection company that is utilized for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC has hired a third-party inspector to conduct all inspections. The third party is also responsible for determining rent reasonableness for agency-owned properties. The following actions have been implemented to ensure the integrity of HQS inspections: ? Established a clear communication channel and reporting format with the third-party inspection company. ? Defined the inspection scope, frequency, and criteria to meet the quality standards. ? Conduct regular audits and reviews of the inspection results and reports to ensure accuracy and constancy. The reviews will be conducted monthly by a newly created Quality Control staff member and the Director of Rental Assistance. The monitoring process will consist of a review of (1) 50058 action type 13 submissions in PIC, (2) all failed inspections, and (3) the timeliness and abatement status of the third-party vendor. ? Provide regular feedback and recommendations to the third-party inspection company to improve their quality and efficiency. An established monthly meeting is currently in place; however, additional meetings will be setup if necessary. ? Ensure that the third-party company utilizes real-time data tools to communicate with the HCHC Yardi Software. Yardi has a mobile inspection app that the third-party inspector will begin using. In addition, the Commission will evaluate the existing third-party inspection company to decide if its contract will be renewed or terminated based on performance. If the contract is terminated, the Commission will solicit for a new inspection company. Name(s) of the contact person(s) responsible for corrective action: Paul Diggs, Director of HCVP Planned completion date for corrective action plan: December 31, 2023

View Audit 49580

Finding 51967 (2022-002)

Material Weakness 2022

Howard County Housing Commission

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022-002 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend that the Commission review their policies and ensure that rent reasonableness is determined and documented for all rent changes. Explanation of disagreement with audit finding: There is no disagreement with the au...

2022-002 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend that the Commission review their policies and ensure that rent reasonableness is determined and documented for all rent changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rent Reasonableness is an essential requirement for the HCV program, as it ensures that the rents paid by the program participants are fair and comparable to the market rates. The following actions have been implemented to ensure rent reasonableness calculations are being made and properly applied: ? Staff uses an automated system called ?RentEllect?, that captures data of unassisted units in the Howard County market area and uses it to determine rent reasonableness. ? Staff documents the rent reasonableness determination for each program unit using clear and concise language. The documentation includes the source of information, the comparison units, the method of calculation, and the final rent decision. The documentation is maintained electronically and is attached to the tenant file in HCHC?s Yardi Database. The HCHC uses Yardi Software to manage all HCV program transactions. ? The HCV department trained staff on the rent reasonableness process and procedures and provided appropriate tools, including ?RentEllect,? to ensure accurate data. ? Supervisory staff will review the rent reasonableness determinations periodically and update the procedures as needed, especially when there are changes in the Fair Market Rents (FMRs), the rent to the owner, or the unit condition. Name(s) of the contact person(s) responsible for corrective action: Paul Diggs, Director of HCVP Planned completion date for corrective action plan: December 1, 2023

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