Corrective Action Plans

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Going forward the HA will follow the HUD compliance supplement and obligate the capital funds transferred to operations the same day the voucher request is submitted in LOCCS.
Going forward the HA will follow the HUD compliance supplement and obligate the capital funds transferred to operations the same day the voucher request is submitted in LOCCS.
Recently, HACF has hired a new Assistant Property Manager who will receive Public Housing Occupancy, Eligibility, Income and Rent Calculation (PHOEIR) training from NAHRO. This training will provide knowledge and accurate rent calculation guidance to the HACF’s staff. Additionally, HACF will conduct...
Recently, HACF has hired a new Assistant Property Manager who will receive Public Housing Occupancy, Eligibility, Income and Rent Calculation (PHOEIR) training from NAHRO. This training will provide knowledge and accurate rent calculation guidance to the HACF’s staff. Additionally, HACF will conduct and review up to 20 files bi-annually and will document file errors and needed corrections. All audit files will be signed off by the Property Operations Manager and the staff. Property management staff will receive ongoing training on reviewing income, assets, and rent calculations, tenant record keeping and recertification requirements.
IN THE FUTURE, THE PROJECT MANAGER WILL PERFORM ALL UNIT INSPECTIONS AT THE TIME OF ANNUAL RECERTIFICATION TO ENSURE INSPECTIONS ARE NOT MISSED. THE REGIONAL MANAGER WILL REVIEW ALL UNIT INSPECTIONS ON A MONTHLY BASIS.
IN THE FUTURE, THE PROJECT MANAGER WILL PERFORM ALL UNIT INSPECTIONS AT THE TIME OF ANNUAL RECERTIFICATION TO ENSURE INSPECTIONS ARE NOT MISSED. THE REGIONAL MANAGER WILL REVIEW ALL UNIT INSPECTIONS ON A MONTHLY BASIS.
The Director has added to her monthly checklist to review quality control logs and follow up on any QC reviews that are not being conducted in a timely fashion.
The Director has added to her monthly checklist to review quality control logs and follow up on any QC reviews that are not being conducted in a timely fashion.
I have reached out to the Nebraskaland Bank regarding alternate collateralization. If this bank cannot provide appropriate collateral, a new banking institution will be found.
I have reached out to the Nebraskaland Bank regarding alternate collateralization. If this bank cannot provide appropriate collateral, a new banking institution will be found.
Recommendation: The Project should contact the bank and transfer the funds into a HUD-approved interest-bearing account. In addition, the account should not be subject to monthly service charges or fees. Action Taken: Management acknowledges the finding and has already addressed the issues with t...
Recommendation: The Project should contact the bank and transfer the funds into a HUD-approved interest-bearing account. In addition, the account should not be subject to monthly service charges or fees. Action Taken: Management acknowledges the finding and has already addressed the issues with the bank. The funds have been placed in an interest-bearing bank account and will no longer be subject to monthly fees.
During our annual audit, it was found that our HQS Inspector had been too lenient with our landlords in terms of making repairs to units. To that end, we have established a tracking mechanism for all Failed Inspections, with a timeframe related to when the units will go on abatement. This tracking m...
During our annual audit, it was found that our HQS Inspector had been too lenient with our landlords in terms of making repairs to units. To that end, we have established a tracking mechanism for all Failed Inspections, with a timeframe related to when the units will go on abatement. This tracking mechanism is in line with resources we utilize to track our SEMAP indicators, is updated weekly by our HQS Inspector, and monitored by our HCV Specialist and Housing Operations Director for compliance.
Management notes that the deadline for the June 30, 2023 deposit has already been missed, however, plans to implement additional controls to ensure that future surplus cash (starting with the 2024 required deposit) is deposited into the residual receipts account within 60 days of year-end in accorda...
Management notes that the deadline for the June 30, 2023 deposit has already been missed, however, plans to implement additional controls to ensure that future surplus cash (starting with the 2024 required deposit) is deposited into the residual receipts account within 60 days of year-end in accordance with HUD requirements.
Identifying Number: 2023-001 Finding: The Organization did not hold replacement reserve funds in an interest-bearing account. Contact Person Responsible for Corrective Action: Richard Manall, CFO Corrective Action Taken or Planned: Management reached out to Fulton Bank to move these funds into a fed...
Identifying Number: 2023-001 Finding: The Organization did not hold replacement reserve funds in an interest-bearing account. Contact Person Responsible for Corrective Action: Richard Manall, CFO Corrective Action Taken or Planned: Management reached out to Fulton Bank to move these funds into a federally insured interest-bearing account. Anticipated Completion Date: September 1, 2023.
Management agrees with the finding and will begin an independent review of each tenant file to include examination of proof of disability paperwork to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 811 training regarding the in...
Management agrees with the finding and will begin an independent review of each tenant file to include examination of proof of disability paperwork to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 811 training regarding the initial and recertification process. Additionally, management is staffing the property with a dedicated property manager that will be responsible for reviewing tenant files for compliance with HUD procedures including eligibility requirements and ensure supporting documentation is maintained in each tenant’s file prior to signing new or amended leases. Management has requested proof of disability from the tenant that satisfies HUD guidelines and will not renew lease if it is not received. The training and file review will be completed by November 30, 2023. If the tenant does not produce proof of disability their lease will not be renewed on May 11, 2024.
View Audit 460 Questioned Costs: $1
Management agrees with the finding and will begin an independent review of each tenant file to include examination of EIV reports to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 811 training regarding the initial and recertif...
Management agrees with the finding and will begin an independent review of each tenant file to include examination of EIV reports to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 811 training regarding the initial and recertification process. Additionally, management is staffing the property with a dedicated property manager that will be responsible for reviewing tenant files for compliance with HUD procedures including uses of EIV reports and ensure supporting documentation is maintained in each tenant’s file prior to signing new or amended leases. Estimated completion date is November 30, 2023.
Finding: The Organization had excess funds over $250 remaining in the residual receipts account which have not been remitted to HUD upon PRAC termination. Contact Person Responsible for Corrective Action: Bob Rosvold, CFO Corrective Action Taken or Planned: Residual receipts that are due to HUD will...
Finding: The Organization had excess funds over $250 remaining in the residual receipts account which have not been remitted to HUD upon PRAC termination. Contact Person Responsible for Corrective Action: Bob Rosvold, CFO Corrective Action Taken or Planned: Residual receipts that are due to HUD will be made on or before 9/30/2023. Anticipated Completion Date: 9/30/2023
Finding 176 (2023-001)
Significant Deficiency 2023
Response: Management recorded the adjusting journal entries as proposed by the audit firm. In the future, management will ensure that depreciation and amortization of loan costs and calculated and recorded in the general ledger.
Response: Management recorded the adjusting journal entries as proposed by the audit firm. In the future, management will ensure that depreciation and amortization of loan costs and calculated and recorded in the general ledger.
Finding 2023-005 Deposit Collateralization Material Weakness/Non-Compliance – Special Tests and Provisions Utility Allowance Analysis was not included in my training for this position, I was underway of the need for an analysis until after the deadline has passed. I’ve reached out to our software c...
Finding 2023-005 Deposit Collateralization Material Weakness/Non-Compliance – Special Tests and Provisions Utility Allowance Analysis was not included in my training for this position, I was underway of the need for an analysis until after the deadline has passed. I’ve reached out to our software company, however they were unwilling to complete this take due to the size of our HCV Program. I will be reaching out to companies requesting a proposal, if acceptable this will be completed.
Finding 2023-004 Utility Allowance Material Weakness/Non-Compliance – Special Tests and Provisions I agree with finding I’ve met with City of Grinnell Building and Planning Director to make arrangements for himself and or his staff to perform HQS Quality Control Inspections for the Grinnell Low Re...
Finding 2023-004 Utility Allowance Material Weakness/Non-Compliance – Special Tests and Provisions I agree with finding I’ve met with City of Grinnell Building and Planning Director to make arrangements for himself and or his staff to perform HQS Quality Control Inspections for the Grinnell Low Rent Housing Authority.
Finding 2023-003 Deposit Collateralization Material Weakness/Non-Compliance – Special Tests and Provisions Repeat Finding 2022-03 I agree with finding The requirement of the Depository Agreement was recently brought to my attention as I was not an employee at the time of the last Audit. This corre...
Finding 2023-003 Deposit Collateralization Material Weakness/Non-Compliance – Special Tests and Provisions Repeat Finding 2022-03 I agree with finding The requirement of the Depository Agreement was recently brought to my attention as I was not an employee at the time of the last Audit. This correction is in the process and will be put in place as soon as possible.
Finding 2023-002 Internal Control Structure Material Weakness – Eligibility, Reporting and Special Tests and provisions Repeat Finding 2022-02 I agree with finding The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight boar...
Finding 2023-002 Internal Control Structure Material Weakness – Eligibility, Reporting and Special Tests and provisions Repeat Finding 2022-02 I agree with finding The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board has reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.
Management is appealing to HUD regarding the required deposit. Funds are not currently available to make the prior year required deposit.
Management is appealing to HUD regarding the required deposit. Funds are not currently available to make the prior year required deposit.
View Audit 141 Questioned Costs: $1
Finding 2023-001 The Authority agrees with finding 2023-001 • The Authority, due to increasing interest rates, purchased several CD’s with various banks in order to maximize returns. During this process Form HUD 51999 was unintentionally omitted. o The Authority will immediately begin working with ...
Finding 2023-001 The Authority agrees with finding 2023-001 • The Authority, due to increasing interest rates, purchased several CD’s with various banks in order to maximize returns. During this process Form HUD 51999 was unintentionally omitted. o The Authority will immediately begin working with financial institutions that have Housing Choice Voucher or Public Housing finds on getting Form HUD 51999 completed. By December 31, 2023 the Authority will create an investment policy that outlines the requirements. Upon annual renewal of any investment the HUD website will be checked for updated forms.
Contact Name: Barbara Staggs, CFO Contact Phone Number: 870-863-8194 Audit Period Ending: June 30, 2023 Audit Firm: FORVIS, LLP Federal Program: Supportive Housing for the Elderly, Assistance Listing No. 14.157 Federal Agency: U.S. Department of Housing and Urban Development September 12, 2023 Find...
Contact Name: Barbara Staggs, CFO Contact Phone Number: 870-863-8194 Audit Period Ending: June 30, 2023 Audit Firm: FORVIS, LLP Federal Program: Supportive Housing for the Elderly, Assistance Listing No. 14.157 Federal Agency: U.S. Department of Housing and Urban Development September 12, 2023 Finding 2023-001: Summary of Finding: The Project is required to calculate surplus cash at the end of each fiscal year and any amount greater than zero is required to be deposited to a federally insured residual receipts account within 60 days of year-end. The Project properly calculated surplus cash for fiscal year 2021; however, funds were not deposited into the residual receipts account as of 6/30/2023. Management should create policies and procedures to identify and transfer surplus cash to the residual receipts account to ensure compliance with this requirement. Management’s Corrective Action Plan: Management concurs with the finding. In the 2022 audit, it was found that Creative Housing IV, Inc. failed to make the surplus cash deposit for program year 2021 of $1,508. The deposit was made on September 7, 2023. Anticipated Completion Date: Completed
Funds were needed for temporary cash flow shortage and the funds were returned on 7/18/2023.
Funds were needed for temporary cash flow shortage and the funds were returned on 7/18/2023.
2022-005 – Loss of Internal Controls Over Cash Disbursements – Significant Deficiency Auditor Recommendations: The Authority should perform a complete review of HUD and Housing Authority policies over disbursements to ensure compliance with these policies. Response: We will implement reviews of HUD ...
2022-005 – Loss of Internal Controls Over Cash Disbursements – Significant Deficiency Auditor Recommendations: The Authority should perform a complete review of HUD and Housing Authority policies over disbursements to ensure compliance with these policies. Response: We will implement reviews of HUD and Housing Authority policies, in addition to staffing changes, to ensure that this finding will be cleared by the subsequent fiscal year audit. Timeframe: By completion of the 2027 FYE audit Individual responsible for correction: Mr. Marc Starling, Executive Director
2022-004 – Deficiencies Noted in Documentation of Controls - Housing Choice Voucher Participant Files - Significant Deficiency Auditor Recommendations: The Authority should establish a checklist for the Housing Choice Voucher Coordinator to use during the recertification process to document the proc...
2022-004 – Deficiencies Noted in Documentation of Controls - Housing Choice Voucher Participant Files - Significant Deficiency Auditor Recommendations: The Authority should establish a checklist for the Housing Choice Voucher Coordinator to use during the recertification process to document the procedures performed to ensure all compliance requirements are met. We recommend a complete review of all Housing Choice Voucher Program tenant file regulations to ensure compliance with these policies. Response: The Executive Director will actively oversee all financial aspects of the agency. Additionally, the director will ensure that finances are current and accurate monthly. A complete review of all Housing Choice Voucher Program tenant file regulations will be performed to ensure compliance with these policies. Timeframe: By completion of the 2027 FYE audit Individual responsible for correction: Mr. Marc Starling, Executive Director
Finding 2022-002 Significant Deficiency in Internal Controls Over Compliance – HOME Investment Partnerships Program Finding: The audit identified a tenant file in which a HOME-assisted unit was not properly identified on the Household Eligibility Certification form, resulting in rental charges that ...
Finding 2022-002 Significant Deficiency in Internal Controls Over Compliance – HOME Investment Partnerships Program Finding: The audit identified a tenant file in which a HOME-assisted unit was not properly identified on the Household Eligibility Certification form, resulting in rental charges that exceeded allowable limits under HOME program requirements. Corrective Action Plan: DNDA agrees with the finding and has implemented procedures to strengthen compliance monitoring and tenant file review processes. To address this finding, management has taken the following actions: o Corrected the identified tenant file and reviewed the circumstances that led to the error. o Implemented additional review procedures for Household Eligibility Certification forms to verify unit designation, household income calculations, and applicable rent restrictions. o Established a secondary review process for HOME-assisted units to ensure compliance requirements are accurately reflected in tenant records. o Provided additional training and guidance to staff responsible for tenant certifications and compliance monitoring. o Incorporated periodic compliance reviews into ongoing property management oversight activities. Responsible Party: Shannon Woodard – Interim Executive Director, Danielle Clark-Burfening – Housing Director, Misty Wilson – Area Supervisor (3rd Party Property Management – United Marketing, Inc.), Bonita Salyers – Regional Portfolio Assistant (3rd Party Property Management – United Marketing, Inc.) Implementation Date: Corrective actions began upon identification of the finding. Expected Completion Date: Implemented December 18, 2025, Quarterly Verification of Compliance by Danielle Clark-Burfening Monitoring: Management will conduct periodic reviews of HOME-assisted tenant files and certification documents to verify continued compliance with HUD and HOME program requirements.
Finding 2022-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, Public Housing Capital Fund Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, 14.872, and 21.01...
Finding 2022-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, Public Housing Capital Fund Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, 14.872, and 21.019 Material Noncompliance Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance Criteria: The Authority must maintain complete and accurate accounts and other records for the program in accordance with HUD compliance requirements. Condition: The Authority did not maintain complete and accurate accounts and other records in accordance with HUD compliance requirements regarding Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility, Reporting, and Special Tests and Provisions. Context: The Authority was unable to provide requested documentation at the time of audit to properly test the HUD compliance requirements. Known Questioned Costs: Unknown Cause: There is a material weakness in internal controls over compliance related to the maintenance of tenant files, wait lists, inspection reports and other records. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster, Public and Indian Housing Program and Public Housing Capital fund Program are in material non- compliance with the compliance requirements of the program. Recommendation: We recommend that the Authority implement a process whereby Authority documents are stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority experienced significant turnover in employees during the year and as a result certain 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 internal control over compliance processes and procedures related to the Housing Voucher Cluster, Public and Indian Housing Program and Public Housing Capital fund Program to remedy the aforementioned deficiencies. Byran McClellan, CFO, will be responsible to implement this corrective action by December 31, 2023.
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