Corrective Action Plans

Material Weaknesses identified was from 2022-01 - Housing Quality Standards Inspections During audit procedures, it was identified that the Unit's Inspections were completed but if there was a failure, re-inspections were not completed as required within the 30-day period. The cause was identified that we did not have the necessary internal controls over compliance in place. That we are not re-inspecting units timely. The failure rate of 40 units examined during audit resulted in 14 failures for re-inspection. The recommendation was that we implement internal control processes and procedures to ensure that re-inspections are completed on a timely basis. Management Response: We became aware of a concern and performance issues with our HCV manager in the summer of 2021. She provided her notice of intent to resign effective December 31, 2021. We began a search for a manager in the fall of 2021 through many processes, including posting the position, inquiring of other housing authorities of our open position and networking. Additionally, we brought in a consultant to complete requirements of our contract effective January 1, 2022. This is a specialized position and one that requires experience for the position. We hired an experienced manager in May 2022 to organize the HCV program. During this audit period HUD had in place a moratorium on inspections due to COVID outbreak. We did not at this.time need to inspect units. However we did inspect units, of the 40 that had inspections we recognize as a result of the audit that we failed 14. We requested a listing of the 14 failed inspected units as a result of the audit. Senior Management was not informed during the audit process, rather during the reporting phase of the audit. Once we received the 14 names we reviewed them. Upon first inspection two of the names immediately were known. One of the persons was living in a situation where she would not have been able to pass inspection, she was a Choice for Independent living recipient approved for services by Medicaid. She was assigned to a case manager and should have been receiving services in her existing housing, however area agencies were unable to provide services per her eligibility requirements and therefore we placed her on our waitlist and worked towards housing her. She was transferred to our housing and is receiving services effective January 2022. During her first months with us she received inspections regularly to ensure that she would not fail and be in jeopardy of eviction. She is now receiving services, doing well and passing inspections. The second person was one of our Choice for Independent living residents in one of our units, his unit failed inspection on Sept. 20, 2021 and a work order for repairs was completed on October 14, 2021, which was within the 30 day re-inspection process. However this was not reported in our housing software, rather was in our work order software. We identified that three of the additional tenants that failed inspection had been re- inspected in May of 2021 and had passed within a few days of their inspection which was under 30 days, however once again was not reflected in our software. During our review process it became known to us that there is a flaw in our software package that we have been addressing with PHA Web for some time. We are working towards accurate notifications within our software. Additionally, during the period of time reviewed we had staff shortages due to COVID positive employees and a needed to change work schedules to maintain our properties effectively. We had created a practice of quarantining due to exposure and or symptoms which affected our HCV inspection staff members, both having tested positive with symptoms. Corrective Actions: We recognize and appreciate the information to work towards improvement of our HCV program. In May 2022 we hired a new Manager for our HCV program. The new Manager is working on preparing a new administration plan to be implemented for our HCV program. The new Manager is working on hiring a team and organizing existing staff to ensure that necessary details including inspections and follow up inspections are kept on track as required and documented properly. There is a process in place for HQS inspections to be followed and reports will be utilized. We have worked on training additional staff members and certifying them in HQS inspection process to ensure inspections are done timely. All our current voucher holders will be receiving a scheduled inspection to create a baseline and to move forward effectively. We anticipate completion of inspections according to our plan to be within six months of this report.

HENDERSON SUPPORTIVE HOUSING, INC. HUD PROJECT NO. 125-HD074 CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Henderson Supportive Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit Period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2022-001: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 The Project paid the expense of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it pays the correct amount. Action Taken: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. If the Department of Housing and Urban Development has questions regarding this plan, please call Chuck Reuter at 651-645-7271.

Koinonia, Inc. Lenoir, North Carolina CORRECTIVE ACTION PLAN June 26, 2023 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Koinonia, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended December 31, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - Financial Statement Audit and Federal Award Program Audit Finding 2022-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects (Section 223(f)/207) Recommendation: We recommend that the Project funds are only used for expenses of the Project. Additionally, we recommend the related entity reimburse the operating cash of the Project $2,000 for the accounting fees paid. Action Taken: Management acknowledges the Project funds were used for expenses of another entity. Management will ensure the related entity reimburses the operating cash of the Project $2,000 for the accounting fees paid and ensure that the Project funds are only used for expenses of the Project. Finding 2022-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend management review/enhance its accounting and internal control procedures to ensure that all key accounts are reconciled and reviewed with supporting evidence of such review. Action Taken: We agree with Finding 2022-002 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will review the accounting and financial procedures, system of internal controls and policies. FINDING - Federal Award Program Audit Finding 2022-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend that the Project continuously monitor cash balances to ensure that funds are always covered by FDIC insurance limits, collateral agreements are obtained, or funds are invested in government securities. Action Taken: Management acknowledges the Project funds were in excess of FDIC insured limits and will transfer funds to provide adequate FDIC insurance coverage for all cash accounts. If HUD has questions regarding this corrective action plan, please call 828-758-2617. Sincerely yours, Chassidy Triplett Project Administrator Koinonia, Inc.

Koinonia, Inc. Lenoir, North Carolina CORRECTIVE ACTION PLAN June 26, 2023 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Koinonia, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended December 31, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - Financial Statement Audit and Federal Award Program Audit Finding 2022-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects (Section 223(f)/207) Recommendation: We recommend that the Project funds are only used for expenses of the Project. Additionally, we recommend the related entity reimburse the operating cash of the Project $2,000 for the accounting fees paid. Action Taken: Management acknowledges the Project funds were used for expenses of another entity. Management will ensure the related entity reimburses the operating cash of the Project $2,000 for the accounting fees paid and ensure that the Project funds are only used for expenses of the Project. Finding 2022-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend management review/enhance its accounting and internal control procedures to ensure that all key accounts are reconciled and reviewed with supporting evidence of such review. Action Taken: We agree with Finding 2022-002 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will review the accounting and financial procedures, system of internal controls and policies. FINDING - Federal Award Program Audit Finding 2022-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend that the Project continuously monitor cash balances to ensure that funds are always covered by FDIC insurance limits, collateral agreements are obtained, or funds are invested in government securities. Action Taken: Management acknowledges the Project funds were in excess of FDIC insured limits and will transfer funds to provide adequate FDIC insurance coverage for all cash accounts. If HUD has questions regarding this corrective action plan, please call 828-758-2617. Sincerely yours, Chassidy Triplett Project Administrator Koinonia, Inc.

Koinonia, Inc. Lenoir, North Carolina CORRECTIVE ACTION PLAN June 26, 2023 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Koinonia, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended December 31, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - Financial Statement Audit and Federal Award Program Audit Finding 2022-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects (Section 223(f)/207) Recommendation: We recommend that the Project funds are only used for expenses of the Project. Additionally, we recommend the related entity reimburse the operating cash of the Project $2,000 for the accounting fees paid. Action Taken: Management acknowledges the Project funds were used for expenses of another entity. Management will ensure the related entity reimburses the operating cash of the Project $2,000 for the accounting fees paid and ensure that the Project funds are only used for expenses of the Project. Finding 2022-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend management review/enhance its accounting and internal control procedures to ensure that all key accounts are reconciled and reviewed with supporting evidence of such review. Action Taken: We agree with Finding 2022-002 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will review the accounting and financial procedures, system of internal controls and policies. FINDING - Federal Award Program Audit Finding 2022-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend that the Project continuously monitor cash balances to ensure that funds are always covered by FDIC insurance limits, collateral agreements are obtained, or funds are invested in government securities. Action Taken: Management acknowledges the Project funds were in excess of FDIC insured limits and will transfer funds to provide adequate FDIC insurance coverage for all cash accounts. If HUD has questions regarding this corrective action plan, please call 828-758-2617. Sincerely yours, Chassidy Triplett Project Administrator Koinonia, Inc.

Name and Number of the Project: Waters at James Crossing, LP FHA/CONTRACT NO. VA36-L000-130 Audit Firm: M Group, LLP Audit Period: The period from December 9, 2021 (Inception) through December 31, 2022 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN OR TO BE TAKEN FINDING #2022-002: Section 8 Housing Assistance Payments Program, CFDA: 14.195 CORRECTIVE ACTION TO BE COMPLETED: The Partnership is in the process of making repairs to the affected units and recertifying tenants. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Michael Nguyen, President of Atlantic Housing Management, Inc.

CORRECTIVE ACTION PLAN Name of the Project: Waters at Magnolia Bay, LP No. 054-35898 Audit Firm: M Group, LLP Audit Period: The period ended December 31, 2022 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING #2022-006: Section 22l(d)(4) HUD Insured Loan, CFDA 14.135 CORRECTIVE ACTION COMPLETED: Management has reviewed the Regulatory Agreement to ensure they are familiar with all the terms of the agreement. The Partnership had sufficient surplus cash at December 31, 2022. Finding CLEARED. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Michael N. Nguyen.

CORRECTIVE ACTION PLAN Name and Number of the Project: See below Audit Firm: M Group, LLP Audit Period: The period from December 9, 2021 (Inception) through December 31, 2022 Gretna Village, LP VHDA (Project No. 02-1709-HF/SP and 02-1710-HCD) $ Unknown Waters at James Crossing, LP (FHA/Contract No. VA36-L000-130) $ Unknown Waters at Augusta, LP (FHA/Contract No. SC16-M000-060) $ Unknown Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN OR TO BE TAKEN FINDING #2022-003: Section 8 Housing Assistance Payments Program. CFDA: 14.195 CORRECTIVE ACTION TO BE COMPLETED: The Project's will review and monitor tenant eligibility and documentation procedures to ensure compliance. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 US. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Michael Nguyen, President of Atlantic Housing Management, Tnc.

CORRECTIVE ACTION PLAN Name of the Project: Waters at Augusta, LP FHA/Contract No. SC 16-M000-026 Aduit Firm: M Group, LLP Audit Period: The year ended December 31, 2022 Compliance Review: COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING #2022-001: Section 8 Housing Assistance Payments Program, CFDA: 14.195 CORRECTIVE ACTION: The Partnership will submit the HAP Vouchers on a timely basis. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Un(form Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Michael Nguyen, President of Atlantic Housing Management, Inc.

CORRECTIVE ACTION PLAN Name and Number of the Project: See below Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2022 Projects: Waters at Berryhill, LP (HUD Project No. 054-35841) $2,995 Afton Gardens, LLC (FHA/Contract No. VA36L00002) $1,587 Spring Grove, LLC (FHA/Contract No. SC16L00003 and SC160056002) $4,214 Temple Court, LLC (FHA/Contract No. FL29A002001) $1,101 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN OR TO BE TAKEN FINDING 2022-005: Section 8 Housing Assistance Payments Program, CFDA: 14.195 Section 221(d)(4) HUD Insured Loan, CFDA 14.135 CORRECTIVE ACTION TO BE COMPLETED: The Projects listed above have deposited the amounts noted into their respective security deposit accounts. Finding CLEARED. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 US. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Michael N. Nguyen, President & CEO of Atlantic Housing Management, Inc.

CORRECTIVE ACTION PLAN Name and Number of the Project: See below Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2022 Projects: Afton Gardens, LLC (FHA/Contract No. VA36L00002) $1,223 Boulder Creek, LLC (FHA/Contract No. SC 16M000064) $2,897 Brentwood Crossing, LLC (FHA/Contract No. NC19M000070) $4,457 Brittany Woods/Park Chase, LLC (FHA/Contract No. GA06L00060) $7,933 Cedar Moor, LLC (FHA/Contract No. NC19L000146) $2,296 Crescent Hills, LLC (FHA/Contract No. SC16M000062) $5,071 Spring Grove, LLC (FHA/Contract No. SC 16L000003 and SC 160056002) $3,122 Temple Court, LLC (FHA/Contract No. FL29A002001) $239 Timber Ridge, LLC (FHA/Contract No. NC19M000088) $8,980 Roosevelt Gardens, LLC (FHA/Contract No. SC16M00005l) $1,754 Gretna Village, LP (FHA/Contract No. 02-1709-HF/SP and 02-1710-HCD) $1,722 Compliance Review We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN OR TO BE TAKEN FINDING 2022-004: Section 8 Housing Assistance Payments Program, CFDA: 14.195 CORRECTIVE ACTION TO BE COMPLETED: During 2022, the Projects attempted to remit utility reimbursement funds to HUD. However, the remittance was not accepted by HUD due to insufficient information. The Projects will remit tenant utility reimbursement checks not cashed to HUD. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Michael N. Nguyen, President & CEO of Atlantic Housing Management, Inc.

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor?s recommendations. The recommendation, if effectively implemented, should prevent this condition from arising again. Action 1- Management made all the required monthly deposits to the replacement reserve through August 31st, 2023. Action 2-In the event of delayed subsidy payments, management will make the monthly deposits to the replacement reserve as soon as the delayed subsidy payments are received. Action 3-All staff members will be made aware of the importance of maintaining a fully funded replacement reserve account.

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor?s recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action 1-The residence director, building office staff, and accounting staff will be informed of the HUD requirements regarding the timely refund of security deposits. Action 2-The residence director and building office staff will immediately notify the accounting staff of all move outs by email so that a security deposit refund check can be promptly issued. Action 3-The asset management staff will review the accounts payable aging on a weekly basis to ensure that all security deposit refund checks have been issued.

CORRECTIVE ACTION PLAN Auditee: Mt. Zion Housing Authority of Hammond, Inc. d/b/a Pleasant View HUD Project Number: 073-11344-REFI Audit Firm: MCM CPAs & Advisors LLP Audit Period Ended December 31, 2022 Corrective Action Plan Prepared by: Name: Kathleen Taylor Position: Accounting Manager Telephone Number: (317) 921-1950 A. Current Findings on the Schedule of Findings and Questioned Costs Finding No. 2022-01 A. Comments on the Finding and Each Recommendation: We agree with the finding that the required residual receipts deposit was not made timely. B. Action Taken or Planned on the Finding: Management made the required residual receipt deposit on March 31, 2023. Respectfully submitted, Kathleen Taylor Accounting Manager Triangle Associates, Inc.

118 East 111th Street Corporation 290 Lenox, 3rd Floor New York, NY 10027 AUDITEE?S CORRECTIVE ACTION PLAN Name and Number of Project 118 East 111th Street Corporation, FHA Project Number 012-HD010 Auditor/Audit Firm PKF O?Connor Davies LLP Audit Period June 30, 2022 Finding 2022-001 ? Timely Deposit of Surplus Cash A. Comments on Finding and Recommendations Recommendation ? We recommend that management ensures the surplus cash deposit is done timely in the future. B. Actions Taken or Planned Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Going forward our focus will be to work with the auditor and owner to get the audits finalized earlier so adequate time is left for the deposits to be made. In instances where the final is not going to be issued and allow enough time, the deposit will be made based on the reviewed draft. C. Status of Corrective Action on Prior Findings No prior findings. Ezra Miller, CFO

FUNDACION DE HOGARES PARA TRABAJADORES PO Box 11798 - Fernandez Juncos Sta. - San Juan, PR 00910-1798 Tel. (787) 268-0222, Fax (787) 268-0311 Villas de Monterrey Apartments HUD Project No. 056-44036-NP Year ended June 30, 2022 CORRECTIVE ACTION PLAN Finding No. 2022-001 Condition: Vacancy losses is extremely high when compared to last year vacancy losses. Vacancy losses increased in fiscal year 2022 by $92,164, from $76,077 to $168,241, representing a 7.26% of gross potential income. Effect: Negative impact in cash flows to the Project. Response: The actual number of Vacant Units as of 01/09/2023 is 6, which represent a 2.17% of all units at the property. Fundaci6n de Hogares para Trabajadores is currently undersigned Voluntary Compliance Agreement #02-20-5450-8, which requires rehabilitation of 13 units, as identified in the Agreement. The property currently has 14 units reserved and in Rehabilitation Status, to serve as temporary housing while the major accessibility changes are completed. January 10, 2023 Brenda Marquez Executive Director of FHT

B. Finding 2022-002 a. Comments on Findings and Recommendations 2022-002: All tenant income is verified at initial move in and at each annual and interim certification. The instance of non-compliance pertained to a tenant that only had social security income for her March 1, 2022, Annual Recertification, meaning that her verification would have been through the HUD EIV system and would not have been transmitted electronically to the auditors. Management believes the report was properly run. Additionally, our policies include running EIV master file reports on a monthly basis which would have alerted management to the presence of a new job or unreported income in the household had there been any.

A. Finding 2022-001 a. Comments on Findings and Recommendations 2022-001: Management has made the required residual receipts deposit based upon December 31, 2021, surplus cash in the amount of $12,564 on June 30, 2022.

Corrective Action Plan Finding No. 2022-001 ? Segregation of Duties Jeff Cottingham, Management agent, and Patti Gratton, sponsor of project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.

Responsible Official?s Response: Rochester Prep is implementing procedures to ensure accurate and timely submission of federal nutrition claims. Specifically: To ensure claims for reimbursement are accurately consolidated, the Charter School will evaluate their point of service accountability system and implement appropriate changes. The Charter School will also conduct edit checks to ensure accountability. Effective July 20, 2022, the school implemented a Meal Counting and Claiming Implementation Plan with the purpose of submitting accurate meal claims to the state and federal child nutrition programs. This implementation plan seeks to eliminate discrepancies between meal counting at the homeroom level, reporting at the school level, and claiming at the state and federal levels.

2022-001 ALN 14.871 ? Housing Voucher Cluster ? Activities Allowed or Unallowed The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Questioned Costs. In 2021, the Authority was instructed by Keith Landrum of the Columbia, South Carolina HUD Field Office to stop making payments until the matter could be further investigated to see what amounts, if any, are still owed. Management will continue to monitor budgets to ensure that funds are adequate. Management has and will continue to make budget revisions to reduce unessential operating costs. The Authority has designed and implemented a Board approved formal repayment agreement. Person Responsible for Correction of Finding: Mark Fountain, Executive Director Projected Completion Date: June 30, 2023

Finding 2022-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding In 2022 we hired additional oversight staff at the corporate level and changed the procedure for reviewing and approving annual certifications as well as monitoring EIV reporting. We have implanted new EIV procedures to ensure timely EIV reporting. All HUD staff has been trained on the new procedures.

Finding 2022-002 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding The Residual Receipts deposit was not made timely due to a turnover in staff. Management has trained all accounting staff on this process and the Controller has implemented tracking procedures to insure timely deposits.

Finding #2022-001 - Segregation of Duties (Prior Year Finding #2021-001) Condition: Proper segregation of duties is an important aspect of any control system. Management is responsible for the design, installation and maintenance of an appropriate system of internal control. The limited size of the District?s office staff prevents the ideal segregation of functions. The following duties lack adequate segregation of duties: The District uses e-signatures to approve purchase orders. Two individuals have access to the e-signatures and have the ability to create new vendors, enter invoices, print checks, record journal entries and record activity on the general ledger. Both individuals also have access to the payroll system. The person reviewing free and reduced food service eligibility can also enter information into the system to determine eligibility. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. 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 has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: The Board of Education and the Superintendent should continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. Response: We agree with this 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. The Superintendent approves purchase orders and the Board of Education approves monthly accounts payable checks, and one of the school secretaries or the board treasurer reviews the bank reconciliations. The Board of Education and Superintendent will continue to monitor transactions of the District. Finding #2022-001 - Segregation of Contact Person: Heather Droessler Anticipated Completion: Not applicable

2022-003 - Eligibility ? Tenant Files Section 8 Housing Choice Vouchers ? CFDA Number 14.871 Material Weakness in Internal Control, Material Noncompliance Repeat of 9/30/21 Finding 2021-005 (Originally reported as finding 2020-005 at 09/30/20) Condition: Out of a total tenant population of approximately 884 leased vouchers, 25 files were selected for testing in a statistically valid sample. Exceptions were noted as follows: ? 1 error where the lease agreement was not signed by the owner ? 1 error where the file did not contain a signed lease agreement ? 1 error where the file did not contain a signed HAP contract. Also, during our New Admissions testing (11 tested out of 108 new admissions) we noted the following: ? 1 error where the HAP contract was signed but not dated by the Authority. ? 1 error where the lease agreement was not signed by the owner. ? 4 errors where the RFTA was signed but not dated by the landlord and/or by the tenant. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority has hired an outside CPA firm to conduct quarterly reviews of files and to assist in training staff on HUD compliance requirements. The noted deficiencies in the tested files are being corrected and staff will continue to receive adequate training involving the compliance of all the Department of Housing Urban Development (HUD) requirements.