Corrective Action Plans

Finding 575125 (2022-002)

Material Weakness 2022

City of Davis

CA

Cash Management HUD Housing Programs Matching / Level of Effort / Earmarking

Finding Reference Number: SA 2022-002 Cash Management AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housin...

Finding Reference Number: SA 2022-002 Cash Management AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-15-MC-06-0037, B-16-MC-06-0037, B-17-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037, B-21-MC-06-0037 • Fiscal Year of Initial Finding: 2021 • Name(s) of the contact person: Jennifer Block, Management Analyst • Corrective Action Plan: At the end of FY 2023, the City brought the program back in-house to the newly-created Department of Social Services and Housing (SSH). In FY 2024, staff developed a process to ensure timely and consistent draws, with reconciliation to the general ledger at the point of each draw. SSH staff have developed and implemented a timeline of required actions for the program to ensure compliance with deadlines. Staff performs drawdowns of CDBG funding through HUD's IDIS online system monthly. Staff will now report the quarterly drawdowns and reconciliation in the Funds Projected/ Funds Drawn spreadsheet to improve monitoring and identification of problems early. This will increase the speed by which Davis spends down its credit line, and reduce gaps in expenditure recording between IDIS and the City's financial management system. In addition, an updated draw-down process, paired with quarterly reconciliation and reporting through the quarterly cash transaction report, will help staff correctly draw entitlement funds. • Anticipated Completion Date: June 30, 2024

View Audit 365226

Finding 571636 (2022-001)

Significant Deficiency 2022

Cornerstone Homes River Gardens, Inc.

LA

HUD Housing Programs Cash Management

The management agent agrees with the finding and the auditors’ recommendations have been adopted. Surplus cash will be calculated upon the completion of an annual fiscal period. If it is concluded that surplus cash exists at the end of the annual fiscal period, and further determined that the surplu...

The management agent agrees with the finding and the auditors’ recommendations have been adopted. Surplus cash will be calculated upon the completion of an annual fiscal period. If it is concluded that surplus cash exists at the end of the annual fiscal period, and further determined that the surplus cash was received within that fiscal period, that amount of surplus cash will be deposited into the Residual Receipts Account within ninety days of the close of that fiscal period.

View Audit 362570

Finding 570778 (2022-007)

Material Weakness 2022

Joint Programs of the Shoshone and Arapaho Tribes of the Wind River Reservation

WY

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Individual(s) Responsible: Chelsea BadHawk, Chief Financial Officer Action: Management will prepare and implement an internal control system that provides effective oversight of operations, reporting, and compliance. The systems and controls will be designed based on standards set forth in the Go...

Individual(s) Responsible: Chelsea BadHawk, Chief Financial Officer Action: Management will prepare and implement an internal control system that provides effective oversight of operations, reporting, and compliance. The systems and controls will be designed based on standards set forth in the Government Accountability Office Green Book. Anticipated Completion Date: 12/31/2025.

View Audit 361721

Finding 565072 (2022-002)

Significant Deficiency 2022

Milltwee Housing Development Fund Co, Inc.

NY

HUD Housing Programs Reporting

January 29, 2025 Management's Planned Corrective Action Plan For the Year Ended September 30, 2022 Names of contact person(s) responsible for corrective action: Derrick Taitt, President. Planned Corrective Action: The Board of Directors acknowledges the reporting deadline was not met. The Board wa...

January 29, 2025 Management's Planned Corrective Action Plan For the Year Ended September 30, 2022 Names of contact person(s) responsible for corrective action: Derrick Taitt, President. Planned Corrective Action: The Board of Directors acknowledges the reporting deadline was not met. The Board was in the process of engaging a new audit firm. We have implemented significant changes in internal controls over compliance to ensure the audit is completed and submitted by the required deadlines.

View Audit 359011

Finding 562198 (2022-004)

Material Weakness 2022

Mississippi County Public Facilities Board

AR

HUD Housing Programs

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September...

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September 1st 2024 for a management contract. These findings will be corrected by the executive team that is managing the housing authority. We plan to have everything corrected and in place by July 1st 2026. This staff will follow all rules and regulations in the future and will bring everything up to date. Wixson Huffstetler, Executive Director 5/6/2025

View Audit 357802

Finding 562196 (2022-002)

Significant Deficiency 2022

Mississippi County Public Facilities Board

AR

HUD Housing Programs Reporting

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September...

Views of Responsible Officials and Planned Corrective Actions: The Mississippi County Public Facilities Board has several findings in their past years audit. These findings were under the past administration that was let go on June 30th 2024. We were contacted by the board and took over on September 1st 2024 for a management contract. These findings will be corrected by the executive team that is managing the housing authority. We plan to have everything corrected and in place by July 1st 2026. This staff will follow all rules and regulations in the future and will bring everything up to date. Wixson Huffstetler, Executive Director 5/6/2025

View Audit 357802

Finding 561169 (2022-001)

Significant Deficiency 2022

M. Carter Plaza

OR

HUD Housing Programs Allowable Costs / Cost Principles Reporting § 200.512

Finding no.: 2022-001 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: The late filing was due to the fiscal manager position at PCRI experiencing turnover in September of 2019, this, along with the onset of COVID-19 in the first quarter of 2020 led ...

Finding no.: 2022-001 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: The late filing was due to the fiscal manager position at PCRI experiencing turnover in September of 2019, this, along with the onset of COVID-19 in the first quarter of 2020 led to delays in the normal review and submission of the data collection form. The fiscal manager position has been staffed and is aware of the deadline related to the submission of the data collection form. Anticipated completion date: October 2023

View Audit 356760

Finding 561167 (2022-002)

Significant Deficiency 2022

Portland Community Reinvestment Initiatives, Inc.

OR

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.512

Finding no.: 2022-002 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: As has been addressed earlier in management’s response to Finding 2022-001, PCRI had created and filled two new positions in the Fiscal Department — the Controller and an additional...

Finding no.: 2022-002 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: As has been addressed earlier in management’s response to Finding 2022-001, PCRI had created and filled two new positions in the Fiscal Department — the Controller and an additional Staff Accountant. The additional staff led to better internal controls and more timely reconciliations throughout 2022. Notwithstanding these efforts, time was needed to train personnel on PCRI systems and emphasis was put on the completion of the subsidiary audits for King Parks Apartments Limited Partnership and MLK & Cook Apartments Limited Partnerships, which are an integral part of the consolidated PCRI audit report, in the early months of 2022 leading to the noted delay in reconciliations for the PCRI audit. In addition to these delays, PCRI once again experienced turnover in the added Staff Accountant position in June of 2023, leading to delays and the employee in the Controller position went on an extended medical leave and subsequently ended employment with PCRI, leading to further delays. Further contributing to delays was the turnover of accounting staff at the property management company with whom PCRI contracts for management of the Maya Angelou and Park Terrace properties which lead to delays in starting those audit engagements which are integral to the consolidated PCRI audit report. In response to this cycle of staff turnover, PCRI contracted with an external service to fill the Staff Accountant position while the search for a permanent employee to fill the position continues to this day, and PCRI has subsequently hired a well-qualified person as Fiscal Director. The property manager for the Maya Angelou and Park Terrace properties has also taken steps to stabilize their accounting operations. These responses have mitigated the risk of delay of future audits as the additional personnel hired in response to the 2021 finding was effective were it not for the untimely turnover of staff during the time when the 2022 PCRI audit was being prepared for and conducted. Anticipated completion date: December 2023

View Audit 356759

Finding 560828 (2022-010)

Material Weakness 2022

Housing Authority of Alto

TX

HUD Housing Programs Reporting

Corrective action planned: Compliance calendar implemented; reports finalized at least 2 weeks before due date. Contact person: Candice Ivory, Executive Director. Anticipated completion date: June 1, 2025/ Ongoing Monitoring

View Audit 356581

Finding 560827 (2022-009)

Material Weakness 2022

Housing Authority of Alto

TX

HUD Housing Programs Internal Control / Segregation of Duties

Corrective action planned: Revised control procedures and checklist system for future SEMAP submissions with backup file requirements. Updated ADMIN plan to enforce Quality Assurance procedure, to be performed quarterly. Contact person: Candice Ivory, Executive Director / Deputy Director Anticip...

Corrective action planned: Revised control procedures and checklist system for future SEMAP submissions with backup file requirements. Updated ADMIN plan to enforce Quality Assurance procedure, to be performed quarterly. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipated completion date: May 31, 2025/ Ongoing Monitoring

View Audit 356581

Finding 560826 (2022-008)

Material Weakness 2022

Housing Authority of Alto

TX

HUD Housing Programs

Corrective action planned: Staff retrained on HUD requirements. Standard audit process implemented for incoming and annual recertifications. Quarterly file reviews and a new checklist for income verification implemented. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipat...

Corrective action planned: Staff retrained on HUD requirements. Standard audit process implemented for incoming and annual recertifications. Quarterly file reviews and a new checklist for income verification implemented. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipated completion date: July 31, 2025/ Ongoing Monitoring

View Audit 356581

Finding 559798 (2022-006)

Significant Deficiency 2022

Redevelopment Authority of the County of Berks

PA

HUD Housing Programs Reporting Significant Deficiency

REPORTING - SIGNIFICANT DEFICIENCY Federal Program Community Development Block Grant/Entitlement Grant ALN 14.218; passed through the County of Berks Emergency Rental Assistance ALN 21.023; passed through the County of Berks Condition/Cause The Authority did not maintain documentation of internal ...

REPORTING - SIGNIFICANT DEFICIENCY Federal Program Community Development Block Grant/Entitlement Grant ALN 14.218; passed through the County of Berks Emergency Rental Assistance ALN 21.023; passed through the County of Berks Condition/Cause The Authority did not maintain documentation of internal controls over reporting for the programs. For required Community Development Block Grant Reporting under Section 3 of the Housing and Urban Development Act of 1968, total Labor Hours reported for 2022 did not agree to support maintained. Additionally, for the Emergency Rental Assistance program, while reporting spreadsheets were provided, supporting documentation for the amounts reported were not maintained. Recommendation We recommend that all grant reports are reviewed by a person independent of the preparer who has knowledge of the grant requirements. This review should include comparing the amounts reported to detailed support for accuracy. We also recommend the Authority review their recordkeeping procedures for documentation related to grant reporting. There should be a process in place to ensure all required documentation is maintained and filed in an orderly system that allows the Authority to locate and provide documentation when required. Management Response The Authority contracted with Neighborly Software for a program to use with ERAP. At the beginning of ERAP, the Authority relied upon the data from the Neighborly program to generate its reports. By the 4th quarter of 2021, the Authority realized it could only utilize a portion of the Neighborly program for the data required for the reports and needed to supplement or add its own internal data. This method of utilizing Neighborly and internal data is now being used for reports.

View Audit 355767

Finding 559743 (2022-001)

Significant Deficiency 2022

Hoover Seniors

CA

HUD Housing Programs

The Corporation should file the December 31, 2022 financial statements as soon as possible and should ensure the annual financial report is filed within 90 days in future periods or within nine months of fiscal year end if an owner certified submission was furnished to HUD.

View Audit 355678

Finding 555141 (2022-006)

Significant Deficiency 2022

Valencia Shelter for Victims of Domestic Violence

NM

Questioned Costs Matching / Level of Effort / Earmarking HUD Housing Programs § 200.303

Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal and grantor requirements regarding the program requirements. Explanation of disagreement with audit finding: There is no disagr...

Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal and grantor requirements regarding the program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS agrees with CLA and has updated our financial policies. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Fair Market Rents will be reviewed along with the HQS worksheet and Income Limits during annual recertification for active participants in the HUD program. Name(s) of the contact person(s) responsible for corrective action: Jessica Franco, Director of Finance Planned completion date for corrective action plan: XXX

View Audit 353736 Questioned Costs: $1

Finding 554484 (2022-003)

Material Weakness 2022

Holbrook Housing Authority

MA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

2022-003 –REPORTING Auditee’s Response and Planned Corrective Action The Authority is now under the management of the Quincy Housing Authority and all controls and processes have been updated to account for the needs of the Holbrook Housing Authority, including internal controls over financial repo...

2022-003 –REPORTING Auditee’s Response and Planned Corrective Action The Authority is now under the management of the Quincy Housing Authority and all controls and processes have been updated to account for the needs of the Holbrook Housing Authority, including internal controls over financial reporting, documentation retention, and timeliness of reporting. Planned Implementation Date of Corrective Action: June 30, 2024 Person Responsible for Corrective Action: James Marathas, Executive Director

View Audit 353118

Finding 554483 (2022-002)

Material Weakness 2022

Holbrook Housing Authority

MA

Questioned Costs HUD Housing Programs Material Weakness § 200.302

2022-002 – Internal Control Over Compliance Auditee’s Response and Planned Corrective Action The Authority is now under the management of the Quincy Housing Authority and all controls and processes have been updated to account for the needs of the Holbrook Housing Authority, including internal cont...

2022-002 – Internal Control Over Compliance Auditee’s Response and Planned Corrective Action The Authority is now under the management of the Quincy Housing Authority and all controls and processes have been updated to account for the needs of the Holbrook Housing Authority, including internal controls over financial reporting, documentation retention, and timeliness of reporting. Planned Implementation Date of Corrective Action: June 30, 2024 Person Responsible for Corrective Action: James Marathas, Executive Director

View Audit 353118 Questioned Costs: $1

Finding 553711 (2022-002)

Material Weakness 2022

Ao: Advocating Opportunity, Inc.

OH

HUD Housing Programs Material Weakness Reporting

Reporting Services for Victims of Human Trafficking – Assistance Listing No. 16.320 Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Explanation of di...

Reporting Services for Victims of Human Trafficking – Assistance Listing No. 16.320 Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained. Name of the contact person responsible for corrective action: Megan Mattimoe, Executive Director Planned completion date for corrective action plan: June 1, 2025

View Audit 352319

Finding 547563 (2022-004)

Material Weakness 2022

Housing Authority of the County of Monterey

CA

Questioned Costs HUD Housing Programs Material Weakness

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs and will implement internal control procedures that will...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs and will implement internal control procedures that will ensure compliance with federal regulations. Diana Ruiz, Interim Director of Housing Programs, will be responsible to implement this corrective action by June 30, 2023.

View Audit 351745 Questioned Costs: $1

Finding 547562 (2022-003)

Material Weakness 2022

Housing Authority of the County of Monterey

CA

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. Management unintentionally did not request owner's certifications during the audit period as required by Notice PIH 2021-14(HA). The Authority has recognized the deficiencies in the...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. Management unintentionally did not request owner's certifications during the audit period as required by Notice PIH 2021-14(HA). The Authority has recognized the deficiencies in the Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs and will implement internal control procedures that will ensure compliance of federal regulations, including PIH notices. Diana Ruiz, Interim Director of Housing Programs, will be responsible to implement this corrective action by June 30, 2023.

View Audit 351745

Finding 547561 (2022-002)

Material Weakness 2022

Housing Authority of the County of Monterey

CA

Questioned Costs HUD Housing Programs Eligibility

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to ...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to staff that will ensure that when files are archived the original application must be placed in the current working file going forward. Diana Ruiz, Interim Director of Housing Programs, will be responsible to implement this corrective action by June 30, 2023.

View Audit 351745 Questioned Costs: $1

Finding 540863 (2022-108)

Significant Deficiency 2022

Pancare of Florida, INC

FL

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.328

2021-108 Lack of Documentation Related to Reporting Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance ...

2021-108 Lack of Documentation Related to Reporting Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. Source documentation for grant reporting is retained and maintained in grant folders on the shared drive for future reference. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: Implemented

View Audit 350520

Finding 540862 (2022-105)

Material Weakness 2022

Pancare of Florida, INC

FL

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Condition: The Organization made drawdowns after month-end based on budgeted period expenses rather than actual salary expenses to support the amounts being requested for reimbursement. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional support...

Condition: The Organization made drawdowns after month-end based on budgeted period expenses rather than actual salary expenses to support the amounts being requested for reimbursement. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: Implemented

View Audit 350520

Finding 540860 (2022-101)

Material Weakness 2022

Pancare of Florida, INC

FL

Subrecipient Monitoring Special Tests & Provisions Matching / Level of Effort / Earmarking § 200.303

2022-101 Lack of Internal Controls over the Application of the Sliding Fee Scale Condition: The Organization lacks consistently applied processes and procedures related to the application of the sliding fee scale. The Organization also lacks a clear review process related to the sliding fee scale ...

2022-101 Lack of Internal Controls over the Application of the Sliding Fee Scale Condition: The Organization lacks consistently applied processes and procedures related to the application of the sliding fee scale. The Organization also lacks a clear review process related to the sliding fee scale to identify errors quickly to allow for corrections to be made in a timely manner. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization’s policies for the sliding fee scale were recently updated during fiscal year 2022, by management, based on findings during the monitoring by HRSA performed in 2022, but management will consider discussing potential improvements to their policy with the grantor to potentially update it to allow for certain exceptions. The Billing and Collections Policy will be updated to waive co-pays for students in the School-Based Program. The Billing Department will audit and implement periodic feedback & training sessions for the Operations Department for training and compliance for the Sliding Fee Discount Program. The Organization expects to have the corrective action implemented by May 1, 2025. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: May 1, 2025

View Audit 350520

Finding 538269 (2022-001)

Significant Deficiency 2022

Clinton Ecumenical Housing INC

IA

HUD Housing Programs

The Executive Director agreed with the recommendation to make surplus cash deposits into the Organization's residual receipts reserve account in a timely manner in the future in accordance with their HUD agreement.

View Audit 349263

Finding 538268 (2022-001)

Significant Deficiency 2022

Clinton Ecumenical North INC

IA

HUD Housing Programs

The Executive Director agreed with the recommendation to make surplus cash deposits into the Organization's residual receipts reserve account in a timely manner in the future in accordance with their HUD agreement.

View Audit 349260

Corrective Action Plans

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