Corrective Action Plans

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Management’s response: Management concurs with the finding. Corrective Action Plan: Management will re-evaluate controls around cost identification and authorization in efforts to minimize potential error going forward.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will re-evaluate controls around cost identification and authorization in efforts to minimize potential error going forward.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management’s response: Management concurs with the finding. Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
MANAGEMENT AGREES WITH THE FINDING. THE FINANCIAL STATEMENTS WERE SUBMITTED TO HUD ON JANUARY 7, 2025.
MANAGEMENT AGREES WITH THE FINDING. THE FINANCIAL STATEMENTS WERE SUBMITTED TO HUD ON JANUARY 7, 2025.
Comments on Finding and Recommendation: The Corporation paid management fees of $1,675 in excess of the amount approved by HUD. The HUD approved management agent certification (Form HUD-9839-B) provides for the payment of management fees equal to 6.97% of residential and miscellaneous income collect...
Comments on Finding and Recommendation: The Corporation paid management fees of $1,675 in excess of the amount approved by HUD. The HUD approved management agent certification (Form HUD-9839-B) provides for the payment of management fees equal to 6.97% of residential and miscellaneous income collected. Action(s) taken or planned on the finding: Management agrees with the recommendation. The Agent intends to reimburse the Corporation the overpayment of management fees.
Program: Housing Choice Voucher (HCV) Program Finding No. 2024-001 Housing Choice Voucher & Emergency Choice Voucher, ALN #14.871 Compliance Requirement: Eligibility Type of Finding: Noncompliance, Significant Deficiency Corrective Action Overview The Authority acknowledges the finding and agrees th...
Program: Housing Choice Voucher (HCV) Program Finding No. 2024-001 Housing Choice Voucher & Emergency Choice Voucher, ALN #14.871 Compliance Requirement: Eligibility Type of Finding: Noncompliance, Significant Deficiency Corrective Action Overview The Authority acknowledges the finding and agrees that improvements are necessary to strengthen oversight and quality control of the annual recertification process. The Authority is committed to ensuring full compliance with HUD regulations and its Administrative Plan by implementing enhanced procedures, staff training, supervisory review, and ongoing monitoring. ________________________________________ Corrective Actions 1. Standardization of Recertification Process The Authority will update and standardize its annual recertification procedures to ensure that all required steps and documentation are completed consistently and in accordance with HUD regulations and the Administrative Plan. This will include the use of a standardized recertification checklist for each household file to verify that all required income verifications, third-party documentation, rent calculations, utility allowances, and eligibility determinations are obtained and retained. 2. Enhanced Supervisory Review and Quality Control The HCV Program Manager or designated supervisor will conduct a mandatory secondary review of all annual recertifications prior to final approval. This review will confirm that required documentation is complete, accurate, and properly filed before Housing Assistance Payments (HAP) amounts are finalized. Supervisory review will be documented and retained in the tenant file. 3. File Remediation and Backlog Review The Authority will conduct a comprehensive review of all active HCV participant files to identify missing or incomplete annual recertification documentation. Where deficiencies are identified, staff will obtain missing documentation and correct tenant rent and HAP calculations, as necessary. Any discrepancies identified during this review will be documented and resolved in accordance with HUD guidance. 4. Staff Training and Technical Assistance All HCV staff involved in the recertification process will receive refresher training on HUD annual recertification requirements, file documentation standards, and Administrative Plan provisions. Training will emphasize income verification requirements, timeliness standards, and proper file maintenance. Training completion will be documented and retained for monitoring purposes. 5. Ongoing Monitoring and Internal Audits The Authority will implement periodic internal file reviews, including quarterly quality control sampling of HCV recertification files, to ensure continued compliance. Results of internal reviews will be documented, deficiencies will be addressed promptly, and corrective actions will be tracked to completion. ________________________________________ Responsible Staff • Executive Director: Oversight and accountability • HCV Program Manager: Implementation of corrective actions and supervision • HCV Specialists: Completion of recertifications and file documentation • Quality Control Reviewer (or Designee): Ongoing monitoring and file reviews ________________________________________ Implementation Timeline • Within 30 days: o Implement standardized recertification checklist o Begin supervisory review of all annual recertifications • Within 60 days: o Complete staff refresher training o Begin file remediation review of active HCV participant files • Within 90 days: o Complete file remediation o Implement quarterly internal quality control reviews Expected Outcome Implementation of these corrective actions will ensure that annual recertifications are completed timely and accurately, required documentation is properly maintained, and tenant rent and HAP determinations are fully supported. These measures will strengthen internal controls, reduce compliance risk, and improve the Authority’s ability to demonstrate adherence to HUD regulations and its Administrative Plan.
Statement of Condition #2025-002: For the year ended March 31, 2025, 1221 Pearl paid management fees to the Agent in excess of the fees earned resulting in prepaid management fees of $1,174 at March 31, 2025. Recommendation: The Agent should repay the prepaid management fee balance of $1,174. Action...
Statement of Condition #2025-002: For the year ended March 31, 2025, 1221 Pearl paid management fees to the Agent in excess of the fees earned resulting in prepaid management fees of $1,174 at March 31, 2025. Recommendation: The Agent should repay the prepaid management fee balance of $1,174. Action(s) taken or planned on the finding: The Agent has transferred $1,174 to 1221 Pearl to refund the overpayment.
Statement of Condition #2025-001: The Corporation did not make $3,866 of the total required reserve for replacement deposits during the year ended March 31, 2025. Recommendation: Management should make all required deposits to the reserve for replacements fund. Management should transfer $3,866 from...
Statement of Condition #2025-001: The Corporation did not make $3,866 of the total required reserve for replacement deposits during the year ended March 31, 2025. Recommendation: Management should make all required deposits to the reserve for replacements fund. Management should transfer $3,866 from the operating account to the reserve for replacements fund. Action(s) taken or planned on the finding: Management concurs with the finding and the auditor's recommendation. The Corporation made additional deposits totaling $3,866 to the reserve for replacements funds. No further action is required.
Finding 1167494 (2025-002)
Material Weakness 2025
2. Finding 2025-002: Replacement Reserve Disbursements Without Required HUD Approval a. Comments on the Finding and Each Recommendation: We concur with this finding. Two disbursements from the replacement reserve account were made without obtaining required HUD approval prior to disbursement. Staff ...
2. Finding 2025-002: Replacement Reserve Disbursements Without Required HUD Approval a. Comments on the Finding and Each Recommendation: We concur with this finding. Two disbursements from the replacement reserve account were made without obtaining required HUD approval prior to disbursement. Staff turnover and the lack of a centralized tracking system contributed to this oversight. We recognize the need to strengthen our processes to ensure all replacement reserve withdrawals are properly authorized before funds are withdrawn from these restricted accounts. b. Action(s) Taken or Planned on the Finding: 1. Plans to Submit Outstanding Approval Requests to HUD: We will submit approval requests to HUD for the two unapproved disbursements by December 12, 2025. If HUD does not approve the withdrawals, we plan to return the $2,544 to the replacement reserve account. 2. Tracking Log and Checklist: We will establish a tracking log to monitor all replacement reserve approval requests, including due dates and responsible staff. A standardized checklist will be implemented to ensure approvals are obtained before any disbursements are made. 3. Staff Training: Staff will receive training on HUD replacement reserve requirements and the approval workflow by February 28, 2026. 4. Supervisor Review: All replacement reserve requests will be subject to supervisory review before submission and disbursement. Packages will be prepared and submitted at least 30 days before the planned disbursement date.
Federal Agency Name: Department of State Assistance Listing Number: 19.510 Program Name: U.S. Refugee Admissions Program Special Tests and Provisions Finding Summary: a. One instance was identified where documentation for both the initial home visit and the 30-day follow-up home visit was missing fr...
Federal Agency Name: Department of State Assistance Listing Number: 19.510 Program Name: U.S. Refugee Admissions Program Special Tests and Provisions Finding Summary: a. One instance was identified where documentation for both the initial home visit and the 30-day follow-up home visit was missing from the participant file. No case activity or other documentation was able to be provided to indicate that these visits were conducted in accordance with the federal program. b. One instance was identified where an expense was paid and reimbursed under the grant without evidence of a formal request, invoice support, review, or approval. Responsible Individuals: Nathan Beyer, Staci Jonson, Dana Boraas Corrective Action Plan: Procedures will be reviewed with staff to ensure staff are fully trained on required documentation needed to maintain a complete case file, and that documentation is being completed and retained. Anticipated Completion Date: December 31, 2025
Federal Agency Name: Department of State Assistance Listing Number: 19.510 Program Name: U.S. Refugee Admissions Program Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: Two instances were identified where the approval over the expense occurred after the check was...
Federal Agency Name: Department of State Assistance Listing Number: 19.510 Program Name: U.S. Refugee Admissions Program Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: Two instances were identified where the approval over the expense occurred after the check was written. Responsible Individuals: Nathan Beyer, Staci Jonson, Dana Boraas Corrective Action Plan: Procedures will be reviewed with staff to ensure staff are fully trained on the proper sequence of approval and release of checks. Where appropriate, procedures may be modified to ensure proper approval is obtained and documented, prior to checks being delivered to clients. Anticipated Completion Date: December 31, 2025
The Greenwood Housing Authority provided a Corrective Action Plan with the audit packet to REAC indicating the housing will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Jackson Office of Public Housing requires...
The Greenwood Housing Authority provided a Corrective Action Plan with the audit packet to REAC indicating the housing will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Jackson Office of Public Housing requires evidence of the following compliance efforts listed in the Corrective Action Plan: Contact Person Responsible For Corrective Action: Dr. Earl V. Hall, Executive Director Anticipated Completion Date: Fiscal Year Ending March 31, 2026
The Greenwood Housing Authority will used the most recent General Depository Agreement for the financial institutions. The Executive Director will ensure that the documentation is appropriate relative to timing.
The Greenwood Housing Authority will used the most recent General Depository Agreement for the financial institutions. The Executive Director will ensure that the documentation is appropriate relative to timing.
2025-011 – ALN 14.872 – Public Housing Capital Fund Program – Cash Management Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Dir...
2025-011 – ALN 14.872 – Public Housing Capital Fund Program – Cash Management Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Director Anticipated Completion Date: December 31, 2025
2025-008 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Wage Rate Requirements Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vi...
2025-008 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Wage Rate Requirements Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Director Anticipated Completion Date: December 31, 2025
2025-009 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Environmental Review Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vick...
2025-009 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Environmental Review Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Director Anticipated Completion Date: December 31, 2025
2025-007 – ALN 14.850 – Public Housing Operating Fund – Eligibility – Other Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Direc...
2025-007 – ALN 14.850 – Public Housing Operating Fund – Eligibility – Other Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Director Anticipated Completion Date: December 31, 2025
2025-006 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Depository Agreements Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vic...
2025-006 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Depository Agreements Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Director Anticipated Completion Date: December 31, 2025
2025-005 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Insufficient Pledged Collateral Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Fi...
2025-005 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Insufficient Pledged Collateral Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Director Anticipated Completion Date: December 31, 2025
Condition: Missing required documentation. Enterprise Income Verification (EIV) reports were not able to be run due to the license expiring and the person with the license no longer working at the organization. Action Plan: We have reviewed the finding regarding the need for a system ensuring that m...
Condition: Missing required documentation. Enterprise Income Verification (EIV) reports were not able to be run due to the license expiring and the person with the license no longer working at the organization. Action Plan: We have reviewed the finding regarding the need for a system ensuring that more than one individual holds an EIV (Enterprise Income Verification) license and that the license does not lapse. We understand the importance of maintaining access to the EIV system and ensuring uninterrupted compliance with HUD requirements. In response to this finding, we have taken the following corrective actions: 1. Designating Multiple EIV Users: We have implemented a policy that ensures at least two staff members are trained and hold active EIV access. This provides continuity in the event that one staff member is unavailable or the license needs to be renewed. 2. Tracking License Expiration: We have established a system to track EIV license expiration dates and will proactively initiate renewal processes well in advance of any license lapsing. A reminder system has been set up to notify both the employee holding the license and the supervisor, ensuring that renewals are completed on time. 3. Backup Procedures: In addition, we have documented backup procedures to ensure that another individual with the appropriate access is available to perform EIV-related tasks in case of staff turnover or other absences. Completion Date: 6/1/2024 Contact: Jackie Oliveira-Director of Affordable Housing
Condition: HUD forms must be certified by an authorized user. Action Plan: Please see below the new process ensuring that all HUD forms are certified by an authorized user: 1) Tracking System: A system has been implemented to monitor certifier assignments and send reminders for updates. 2) Training ...
Condition: HUD forms must be certified by an authorized user. Action Plan: Please see below the new process ensuring that all HUD forms are certified by an authorized user: 1) Tracking System: A system has been implemented to monitor certifier assignments and send reminders for updates. 2) Training & Oversight: Staff training will be enhanced, and management will increase oversight to ensure compliance. 3) Monitoring and Accountability: Management will regularly review the certification process to ensure all forms are signed by the appropriate certifiers and to verify that all necessary updates are made promptly. Completion Date: 7/1/2024 Contact: Jackie Oliveira-Director of Affordable Housing
Condition: Tenant rent and tenant assistance were not calculated correctly and or lacked recertification paperwork. Action Plan: Management will implement a formal procedure requiring that all tenant income and expense calculations be reviewed by the Director of Affordable Housing for final approval...
Condition: Tenant rent and tenant assistance were not calculated correctly and or lacked recertification paperwork. Action Plan: Management will implement a formal procedure requiring that all tenant income and expense calculations be reviewed by the Director of Affordable Housing for final approval. This secondary review will verify accuracy, completeness, and compliance with HUD/PRAC requirements. Documentation of the review will be maintained in the tenant file. This procedure will be implemented immediately and applied to all future certifications and recertifications. Completion Date: 3/1/2026 Contact: Jackie Oliveira-Director of Affordable Housing
Condition: HUD forms must be certified by an authorized user. Action Plan: Please see below the new process ensuring that all HUD forms are certified by an authorized user: 1) Tracking System: A system has been implemented to monitor certifier assignments and send reminders for updates. 2) Training ...
Condition: HUD forms must be certified by an authorized user. Action Plan: Please see below the new process ensuring that all HUD forms are certified by an authorized user: 1) Tracking System: A system has been implemented to monitor certifier assignments and send reminders for updates. 2) Training & Oversight: Staff training will be enhanced, and management will increase oversight to ensure compliance. 3) Monitoring and Accountability: Management will regularly review the certification process to ensure all forms are signed by the appropriate certifiers and to verify that all necessary updates are made promptly. Completion Date: 7/1/2024 Contact: Jackie Oliveira-Director of Affordable Housing
Condition: HUD performed an MOR in September of 2023 for which a response is required within 30 days. The response was not completed timely and the MOR is still open. Action Plan: Management acknowledges this recommendation. Once the management agent is fully staffed, all efforts will be made to ens...
Condition: HUD performed an MOR in September of 2023 for which a response is required within 30 days. The response was not completed timely and the MOR is still open. Action Plan: Management acknowledges this recommendation. Once the management agent is fully staffed, all efforts will be made to ensure that MOR findings are reviewed and responded to within the required 30-day timeframe. This corrective action will be fully implemented in 2026, at which time staffing levels will support timely and consistent compliance with reporting requirements. Completion Date: 9/1/2026 Contact: Jackie Oliveira-Director of Affordable Housing
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