Corrective Action Plans

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Recommendation: We recommend that the property comply with HUD’s audit requirements and ensure that the audit is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is aware and will comply with this recommendation in the futu...
Recommendation: We recommend that the property comply with HUD’s audit requirements and ensure that the audit is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is aware and will comply with this recommendation in the future.
Management Response and Corrective Action The Finance Department will implement additional internal controls to manage the financial statement process in a timely manner as recommended.
Management Response and Corrective Action The Finance Department will implement additional internal controls to manage the financial statement process in a timely manner as recommended.
Finding 2022-003: The Corporation was unable to furnish the entity's approved Affirmative Fair Housing Marketing Plan. Comments on the Finding and Each Recommendation: The Corporation should request the filed Affirmative Fair Housing Marketing Plan from HUD or submit a new version for approval. Acti...
Finding 2022-003: The Corporation was unable to furnish the entity's approved Affirmative Fair Housing Marketing Plan. Comments on the Finding and Each Recommendation: The Corporation should request the filed Affirmative Fair Housing Marketing Plan from HUD or submit a new version for approval. Action(s) taken or planned on the finding: Management has requested the form from HUD. As of the report date, no response has been received.
Finding 2022-002: The Corporation made a payment to LAHD in the amount of $16,742. The payment does not meet HUD's criteria of eligible Property expenses and the Corporation did not obtain HUD approval. Comments on the Finding and Each Recommendation: The Corporation should request HUD approval for ...
Finding 2022-002: The Corporation made a payment to LAHD in the amount of $16,742. The payment does not meet HUD's criteria of eligible Property expenses and the Corporation did not obtain HUD approval. Comments on the Finding and Each Recommendation: The Corporation should request HUD approval for reimbursement from the residual receipts fund and deposit into the Property's operating account. Action(s) taken or planned on the finding: Management has requested approval from HUD. As of the report date, no response has been received.
View Audit 294494 Questioned Costs: $1
Finding 2022-001: The Corporation's required deposit of $33,484 to the residual receipts account per the December 31, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Comments on the Finding and Each Recommendation: Manage...
Finding 2022-001: The Corporation's required deposit of $33,484 to the residual receipts account per the December 31, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Comments on the Finding and Each Recommendation: Management should make all required residual receipt deposits per the annual Computation of Surplus Cash, Distributions and Residual Receipts within 90 days after fiscal year end. Action(s) taken or planned on the finding: Management deposited $33,484 into the residual receipts fund on June 13, 2022. No further action is required.
View Audit 294494 Questioned Costs: $1
Finding 2022-002 a. Comments on the Finding and Each Recommendation: Management agrees with both the finding and recommendations. b. Action(s) Taken or Planned on the Finding The management overseeing the process has been completely replaced to ensure a fresh perspective and unwavering dedication to...
Finding 2022-002 a. Comments on the Finding and Each Recommendation: Management agrees with both the finding and recommendations. b. Action(s) Taken or Planned on the Finding The management overseeing the process has been completely replaced to ensure a fresh perspective and unwavering dedication to implementing robust internal controls. To address the shortcomings identified in Finding 2022-002, the Authority commits to a targeted action plan aimed at ensuring timely compliance with reporting requirements. Central to our approach is the engagement of a fee accountant, recognized for expertise in HUD reporting and public housing financial management. This specialist will be tasked with overseeing and streamlining our reporting processes. By leveraging this expertise, we aim to quickly rectify past reporting lapses and ensure future submissions are timely and compliant with HUD requirements. The new fee accountant will conduct a comprehensive review of our current reporting mechanisms, identify bottlenecks, and implement best practices tailored to our operations. This decisive action, centered around the expertise of the newly appointed fee accountant, demonstrates our commitment to enhancing our financial management practices and aligning with HUD's reporting expectations. Through these measures, we anticipate not only meeting HUD's deadlines but also setting a new standard for operational excellence within our Authority.
Finding 372057 (2022-007)
Significant Deficiency 2022
In September 2023, a "AP Processing Guidelines & Concur Reference Guide" document was introduced to ensure timeliness, completeness and propriety of books and records. Full dissemination to all Program Managers in connection with in-depth training sessions is still work in process and a result of th...
In September 2023, a "AP Processing Guidelines & Concur Reference Guide" document was introduced to ensure timeliness, completeness and propriety of books and records. Full dissemination to all Program Managers in connection with in-depth training sessions is still work in process and a result of the number of personnel to be trained, combined with limited bandwidth by resources assigned to training. The Concur Expense reporting module is being integrated within the ERP environment, enabling detailed chart of accounts to reflect GL coding by Segment, Grant, and Program. All journal entry support is attached to accounting entry in the ERP. The journal entry is entered by someone on the accounting team and approved by the Controller. Responsible: Annette Nastri, Timing: June 30, 2024
View Audit 293311 Questioned Costs: $1
We will work on monthly cash flows availability to ensure funding the replacement reserve shortfall.
We will work on monthly cash flows availability to ensure funding the replacement reserve shortfall.
We are in communication with HUD on the proposed action plans to meet the required deposits.
We are in communication with HUD on the proposed action plans to meet the required deposits.
Criteria Under the terms of the related regulatory agreement The Homes is required to make timely monthly debt payments and deposits in certain escrow accounts. Condition/Context As part of our compliance testing, we reviewed the debt and escrow schedules and noted that the debt payments and escrow ...
Criteria Under the terms of the related regulatory agreement The Homes is required to make timely monthly debt payments and deposits in certain escrow accounts. Condition/Context As part of our compliance testing, we reviewed the debt and escrow schedules and noted that the debt payments and escrow payments due in February through December of 2022 were not made. Cause The Homes was experiencing significant cash constraints and was not able to make debt payments and escrow payments as they were due and was limited under the terms of the bankruptcy filing as to what payments were allowable. Effect The Homes is out of compliance with the HUD regulatory agreement. Recommendation As HUD servicer is a named secured creditor in the bankruptcy filing, we recommend that The Homes follow the rules of the bankruptcy filing. Management Response The HUD mortgage is a secured creditor under the bankruptcy filing and we expect the lender to be paid under the terms of the bankruptcy agreement at the conclusion of the sale of the Facility that is expected to occur during 2024.
2022-02 Surplus Cash Not Deposited by Due Date Recommendation: We recommend that Levi Towers, Inc. develop specific procedures to ensure that the surplus cash is calculated and deposited by the December 31 deadline. Action Taken: Levi Towers, Inc. will develop procedures to ensure that the surp...
2022-02 Surplus Cash Not Deposited by Due Date Recommendation: We recommend that Levi Towers, Inc. develop specific procedures to ensure that the surplus cash is calculated and deposited by the December 31 deadline. Action Taken: Levi Towers, Inc. will develop procedures to ensure that the surplus cash is calculated and deposited into the residual receipts on or before the December 31 deadline. Name of responsible person responsible for corrective action: David Wilson Anticipated completion date for the corrective action: February 9, 2024
Corrective Action: The Authority will institute corrective policies and procedures including, use of quarterly reviews of tenant files for compliance with applicable HUD compliance requirements prior to audit.
Corrective Action: The Authority will institute corrective policies and procedures including, use of quarterly reviews of tenant files for compliance with applicable HUD compliance requirements prior to audit.
Recommendation: We recommend management should designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response ...
Recommendation: We recommend management should designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response to finding: The Authority will designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Name of the contact person responsible for corrective action: Dontrelle Young Foster, President & Chief Executive Officer Planned completion date for corrective action plan: We expect to have the finding resolved by issuance of next year's audit.
Recommendation: We recommend management should designate one person to oversee the recertifications and inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagre...
Recommendation: We recommend management should designate one person to oversee the recertifications and inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response to finding: The Authority will designate one person to oversee the recertifications and inspections are being performed in a timely manner. Name of the contact person responsible for corrective action: Dontrelle Young Foster, President & Chief Executive Officer Planned completion date for corrective action plan: We expect to have the finding resolved by issuance of next year's audit.
View Audit 291313 Questioned Costs: $1
Views of responsible officials and planned corrective action: The Authority experienced significant turnover in employees during the year and as a result certain processes were not followed and source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired ...
Views of responsible officials and planned corrective action: The Authority experienced significant turnover in employees during the year and as a result certain processes were not followed and source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows it’s the Regulatory Agreements related to the Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects and the HUD compliance requirements to remedy the aforementioned deficiencies. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2023.
View Audit 290411 Questioned Costs: $1
Views of responsible officials and planned corrective action: The Authority experienced significant turnover in employees during the year and as a result certain processes were not followed and source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired ...
Views of responsible officials and planned corrective action: The Authority experienced significant turnover in employees during the year and as a result certain processes were not followed and source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows its Section 8 Administrative Plan and the HUD compliance requirements to remedy the aforementioned deficiencies. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2023.
View Audit 290411 Questioned Costs: $1
Statement of Condition: The Municipality did not submit the required Financial Reports to the US Housing and Urban Development of fiscal year ending June 30, 2022, during the required period. The unaudited Financial Report was not submitted on or before August 31, 2022, also, the audited Financial R...
Statement of Condition: The Municipality did not submit the required Financial Reports to the US Housing and Urban Development of fiscal year ending June 30, 2022, during the required period. The unaudited Financial Report was not submitted on or before August 31, 2022, also, the audited Financial Report was not submitted on or before September 30, 2022. Correction Action Planned for 2022-004: For the upcoming fiscal year, we are actively seeking a company to provide guidance and assistance in reporting issuance, aiming to streamline and address these processes effectively. Anticipated Completion Date JUNE 2023
Finding 2022-004: Special Tests and Provisions - Housing Quality Standards (HQS) Inspections and HQS Enforcement Repeat Finding of Portions of 2021-004 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance L...
Finding 2022-004: Special Tests and Provisions - Housing Quality Standards (HQS) Inspections and HQS Enforcement Repeat Finding of Portions of 2021-004 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.405, the Housing Authority must inspect units prior to the initial term of the lease, at least biennially during assisted occupancy, and at other times as needed, to determine if units meet Housing Quality Standards (HQS). The Housing Authority must also conduct supervisory quality control HQS inspections. Per 24 CFR section 982.404, the Housing Authority must take prompt and vigorous action to enforce the owner obligations for HQS. Housing assistance payments must not be made to units that fail to meet HQS, unless the owner corrects the defect within the required period. Condition/Context: During our testing over the related compliance requirements, we observed the following: The Authority was not able to provide HQS inspections documents for the period under audit for one of the units selected for testing. We were unable to determine whether the Housing Authority performed quality control re inspections, as required by 24 CFR section 982.405(b). Our sample was not statistically valid. Questioned Costs: Not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the HQS inspections done in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old and may have been purged. Effect: Units that fail to meet HQS could endanger the health and safety of tenants. Recommendation: The Housing Authority should ensure the vendor administering the program maintains proper inspection logs and documentation of quality control re-inspections. The Housing Authority should also review its processes to ensure units are inspected based on the requirements in 24 CFR section 982.404. Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation to prove compliance with HQS inspection requirements. We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program.
Finding 2022-003: Special Tests and Provisions - Reasonable Rent Repeat Finding of Portions of 2021-003 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A...
Finding 2022-003: Special Tests and Provisions - Reasonable Rent Repeat Finding of Portions of 2021-003 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.54(d)(15), the Housing Authority must adopt a written administrative plan that establishes local policies for the method of determining that rent paid to an owner is a reasonable rent, initially and during the term of the housing assistance payment contract. Per 24 CFR section 982.507, the Housing Authority must determine that the rent to an owner is reasonable before any subsequent increase in rent is paid to the owner. Condition/Context: We were able to determine that the Housing Authority has a written administrative plan addessing reasonable rent determinations. The Housing Authority was however unable to provide documentation of reasonable rent for the period under audit for the twelve tenants selected for testing. Our sample was not statistically valid. Questioned Costs: Not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the rent reasonableness procedures performed in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old and maybe have been purged. Effect: Rent paid to landlords may not be reasonable in comparison to other comparable unassisted units. Recommendation: The Housing Authority should ensure the vendor administering the program maintains proper records of rent reasonableness. The Housing Authority should also ensure it has a written policy for the method of determining that rent paid to an owner is a reasonable rent as required by 24 CFR section 982.54(d)(15). Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation as required by 24 CFR section 982.54(d)(15). We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program.
Finding 2022-002: Eligibility, Reporting and Special Test and Provision Repeat Finding of Portions of 2021-002 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numb...
Finding 2022-002: Eligibility, Reporting and Special Test and Provision Repeat Finding of Portions of 2021-002 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.516, the Housing Authority must conduct a reexamination of family income and composition at least annually. Third-party verification of family income, value of assets, expenses deducted from income, and other factors that affect adjusted income must be obtained and documented. The Housing Authority must determine income eligibility and calculate the tenant's rent payment using the documentation from third-party verification in accordance with 24 CFR part 5 subpart F. The Housing Authority is also required to submit HUD-50058, Family Report, for each examination per 24 CFR part 908. The amount paid for housing assistance payments (HAP) must correspond to HUD-50058. Condition/Context: No documentation of family income, composition, third-party verification, or HUD‑50058 were provided for two of the twenty five tenants selected for testing for the required reexamination during the fiscal year. Our sample was not statistically valid. Questioned Costs: Housing assistance payments for the tenants noted above is not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the eligibility determinations done in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old. Effect: The Housing Authority may be making inaccurate or ineligible HAP payments on behalf of tenants. Recommendation: The Housing Authority should ensure their vendors properly maintain documentation regarding eligibility determinations. Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation. We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program vouchers.
Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Dutie...
Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or can both make and conceal an error, whether such error is intentional or unintentional. Cause: Limited number of personnel. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities because of the lack of segregation of duties. Recommendation: We recommend that the Village consider the benefits of implementing additional policies and procedures to address key controls related to its significant transaction cycles as noted. Response: We agree with the finding but do not believe it is cost-effective to increase the office staff in an attempt to bring about a more effective segregation of duties. Contact Person: Lynn Yager, Clerk/Treasurer Anticipated Completion: Not Applicable
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Melody Joh...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Melody Johnson-Williams, Executive Director, is responsible for implementing this corrective action by December 31, 2023.
View Audit 289566 Questioned Costs: $1
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. M...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Melody Johnson-Williams, Executive Director, is responsible for implementing this corrective action by December 31, 2023.
View Audit 289566 Questioned Costs: $1
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight on the maintenance of the waiting list and process of housing applicants to better monitor adequacy with compliance requirements. Melody Johns...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight on the maintenance of the waiting list and process of housing applicants to better monitor adequacy with compliance requirements. Melody Johnson-Williams, Executive Director, is responsible for implementing this corrective action by December 31, 2023.
View Audit 289566 Questioned Costs: $1
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Me...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Melody Johnson-Williams, Executive Director, is responsible for implementing this corrective action by December 31, 2023.
View Audit 289566 Questioned Costs: $1
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