Corrective Action Plans

Views of Responsible Officials Management agrees with this Finding. In June 2022, just before year-end, a transfer was processed from the wrong entity. When management discovered the error shortly thereafter, they immediately transferred the money back to the property's replacement reserve account.

Name of auditee: AHP - Crystal Glen II, LLC HUD auditee identification number: 042-11293 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2022 CAP prepared by Name: Margaret Williamson / Kim Losacker Position: Co-President Telephone number: (317) 587-0320 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition #2022-001: During the year ended December 31, 2022, the Property withdrew $19,627 from the reserve for replacements account without HUD authorization. Corrective action completed: On January 6, 2023, $19,627 was deposited to the reserve for replacements account.

a. Comments on the Finding and Each Recommendation Management concurs with Finding 2022-002 and agrees with the recommendation in the finding. However, the Organization would like to note that it has documentation dating back to 2015, which shows the submission of a deferral package to HUD, and correspondence afterward from HUD stating that due to the government shutdown the package was on hold. Following the hold and the installation of a new Executive Director in May of 2019, the Organization has documentation of correspondence with HUD directly asking for an update on the submitted deferral package, and HUD recognizing that the delays caused the deferral package to be lost in the system and that the old package was deemed incomplete and a new package would need to be submitted. As of November 25, 2020 a Resolution Specialist from HUD was assigned to AHC and since then management has worked closely with her to gather resources and prepare a package for deferral. b. Action(s) Taken or Planned on the Finding Management is currently preparing a deferral package to be submitted to HUD by the upcoming fiscal year end for the deferral and repayment of the Flexible Subsidy Loans. A Capital Needs Assessment was completed on the property July 12, 2021 which provided guidance to the Board of Directors to prepare for future capital needs and the repayment of the loan. In addition, management worked with and met with members of CHFA & DOLA regularly throughout this fiscal year to analyze the CNA and gather information about potential strategies to address capital needs and the repayment of the loan. Management also wrote and received grants for its capital campaign from donors, CHFA, the Colorado Health Foundation and the Community Foundation serving Southwest Colorado. In March of 2022, the board heard a recommendation from RCAC for a large-scale LIHTC rehab project and considered its cost and value. Ultimately, the board decided to term out the HUD loan and continue making upgrades on the units when they turn over, and utilize funds acquired through its capital campaign to make large-scale renovations. Additionally, a successful REAC inspection was completed with a score of 66c on July 14, 2022. Lastly, the HAP Contract for AHC expired September 30, 2022 which caused a delay in the ability to complete the Flex Loan Deferral package, as the Pro Forma depends on the contract rents.

December 28, 2022 SHA CORRECTIVE ACTION Finding Number 2022-002 CFDA No. 14.871 Special Tests and Provisions ? Rent Reasonableness The Authority failed to employ an effective methodology to determine and document the reasonableness of rents charged by owners to Housing Choice Voucher participants in accordance with its written Administrative Plan and HUD regulations. 1. Since the beginning of Covid, SHA has had over 15 Program Specialist resign. Currently there are 4 vacant Program Specialist positions. To fill the positions, SHA employees had to act in many different roles and were unable to audit the files. SHA has hired new Program Specialists and they are in the process of being trained on SHA policy and HUD regulations. Person responsible - Blanca Berrios, Director of RAO, Fidan Gousseynoff, Director of HR. Status ? Hiring ongoing, Training ongoing (to be completed by 4/1/2023) 2. Internal Audits ? Our internal auditor has begun reviewing files to ensure compliance with SHA?s written Administrative Plan and HUD Regulations ? Person Responsible- Sandra West ? Internal Auditor. Status - Ongoing 3. Software implementation ? SHA is in the final stages of implementing YARDI. Yardi will take the place of our current outdated software. This will allow for better documenting. Person Responsible- Blanca Berrios, Director of RAO and Stephen Ethier, Director of IT. Status ?completed by 10/1/2022

12/28/2022 SHA CORRECTIVE ACTION Finding Number 2022-001 CFDA No. 14.871 Special Tests and Provisions The Authority failed to document annual Housing Quality Standards (HQS) inspections in accordance with its Administrative Plan and HUD regulations. 1. Inspector Shortage ? SHA?s two long term inspectors resigned during the Covid-19 pandemic. SHA used a temporary inspection contractor while in the process of hiring three new inspectors during a nationwide staffing shortage. Three inspectors were hired and training is ongoing. Person Responsible ? Blanca Berrios, Director of RAO, Fidan Gousseynoff, Director of HR. Status ? Hiring Complete, Training completed 10/1/2022 2. Software implementation ? SHA is in the final stages of implementing YARDI. Yardi will take the place of our current outdated software. This will allow for better tracking of HQS inspections. Person Responsible- Blanca Berrios, Director of RAO and Stephen Ethier, Director of IT. Status ? Completed 10/1/2022

Finding 2022-001: Plan: Reserve for Replacement transfers will be done at the beginning of each month to insure they are properly deposited into the correct month. New Staff Accountant has created a procedure so that when the Subsidy Deposit is transferred to our bank account at the beginning of the month, she immediately makes the necessary transfer to the Reserve for Replacement account. Anticipated Completion Date: 9/1/22 Contact: Jill Lesmerises, CFO

SIGNIFICANT DEFICIENCY. 2022-001 SEGREGATION OF DUTIES. NAME OF CONTACT PERSON: LEAH WICEVIC, EXECUTIVE DIRECTOR. CORRECTIVE ACTION: THE DUTIES WILL BE SEGREGATED AS MUCH AS POSSIBLE. WE UNDERSTAND THAT IN MOST CASES, THE ADDED COST OF PROVIDING ABSOLUTE SEGREGATION OF DUTIES WILL OUTWEIGH THE PROJECTED BENEFITS OF THE ADDED INTERNAL CONTROLS AND THEREFORE, MAY BE CONSIDERED UNJUSTIFIED. SISTERCARE, INC. WILL ENSURE THAT THE BOARD OF DIRECTORS WILL REMAIN INVOLOVED IN THE FINANCIAL AFFAIRS OF THE ORGANIZATION TO PROVIDE OVERSIGHT AND INDEPENDENT REVIEW FUNCTIONS. PROPOSED COMPLETION DATE: MANAGEMENT WILL IMPLEMENT THE ABOVE ACTION IMMEDIATELY.

Oversight Agency for Audit, North Dade Senior Citizens Housing Development Corporation, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: July 1, 2021 through June 30, 2022 The finding from the June 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III ? FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2022-001: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, CFDA 14.155 Recommendation: The Project should implement procedures to ensure all tenant documentation is properly completed and maintained. Action Taken: Training will be conducted with on-site staff on file requirements and procedures. Going forward Compliance will be reviewing random files for accuracy to prevent future file findings. If the audit Oversight Agency has questions regarding these plans, please call Christine Harris at 954-835-9200. Sincerely yours, Christine Harris Accounting Manager

For the Rockford Supportive Housing Facility FINDING 2022-003: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 HUD SUBSIDY LOAN FROM REPLACEMENT RESERVES NOT REPAID Recommendation: The Project should repay the HUD subsidy loan as soon as funds are available. Action Taken: The Project agrees with the finding. A $15,000 transfer will be made once funds are available. Management will be reminded to carefully review HUD correspondence to make sure HUD subsidy loan terms are being followed. If the Department of Housing and Urban Development has questions regarding this plan, please call Les Russo at 847-424-5601.

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS (CONTINUED) YEAR ENDED DECEMBER 31, 2022 FINDING 2022-002: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 SPONSOR LOAN PAYMENT WITHOUT HUD APPROVAL Recommendation: The Sponsor should work with HUD to determine if the $130,019 needs to be paid back to the Project. Action Taken: The Sponsor will work with HUD to determine if the $130,019 needs to be paid back to the Project.

Over the Rainbow Association and Subsidiaries CORRECTIVE ACTION PLANS YEAR ENDED DECEMBER 31, 2022 Over the Rainbow Association and Subsidiaries respectfully submits the following corrective action plans for the year ended December 31, 2022. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit period: December 31, 2022 The findings from the December 31, 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 For the Hill Housing Facility FINDING 2022-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 SURPLUS CASH NOT DEPOSITED INTO RESIDUAL RECEIPT ACCOUNT Recommendation: The Project should deposit surplus cash as of December 31, 2021 into a residual receipts account as soon as possible. Action Taken: The Project agrees with the finding. Management will deposit $14,079 into a residual receipts account as soon as possible.

Finding 2022 - 003 - Housing Choice Vouchers Tenant Files, Significant Deficiency The Authority will work on strengthening its internal controls to correct this situation and ensure that they will be in compliance with the federal guidelines and the Authority?s policies. Patricia Logan, Executive Director has assumed the responsibility to ensure that controls are put in place to properly maintain the tenant files. She expects the deficiencies which led to this finding to be resolved by December 31, 2023.

Finding 2022 - 002 - Section 8 HQS Inspection Deficiencies The Authority is continuing to work on the procedures for failed inspections to ensure that the reinspections are performed within the 30-day requirement. The Authority is also planning on additional training for employees to make sure they are qualified to meet the HQS re-inspection requirements. Patricia Logan, Executive Director, has assumed the responsibility of ensuring that the inspections will be performed within the timeframe to meet the HUD compliance requirements and expects the deficiencies which led to this finding to be resolved by December 31, 2023.

RICE ARLINGTON SENIOR SUPPORTIVE HOUSING, INC. HUD PROJECT NO. 092-EE060 CORRECTIVE ACTION PLAN YEAR ENDED DECEMBER 31, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Rice Arlington Senior Supportive Housing, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd., 1000 Shelard Parkway, Suite 110, Minneapolis, MN 55426. Audit Period: December 31, 2022 The findings from the December 31, 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 202, ASSISTANCE LISTING NUMBER 14.157 Condition: For one of the tenant files tested, there was a mathematical error in computing the tenant's medical expense deduction in the process of computing the tenant share of monthly rent. Recommendation: The Project should recompute the HUD subsidy and tenant rent for this tenant and adjust a future monthly billing, if necessary. Project managers should be aware of the importance of computing the tenant's medical expense deduction accurately. Action Taken: The Project agrees with the finding. Tenant rent was recomputed and management adjusted a future monthly HUD billing in February 2023. If the Department of Housing and Urban Development has questions regarding this plan, please call Chuck Reuter at 651-645-7271.

April 20, 2023 United Stated Department of Health and Human Services Indiana Health Centers, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2022. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: December 31, 2022 The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCY 2022-001 - Sliding Fee Scale Discount Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Action Taken IHC will improve the sliding fee audit process by implementing the following changes. Each IHC site will be responsible for auditing five accounts per front office staff twice per month that will be reviewed by the Office Manager, Practice Manager, and Director of Operations. The completed audits after review will be sent to the CFO for additional review. Any sliding issues will be addressed with the respective front office staff with re-education. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Tracy Nagel, CFO at (317) 576-1335. Sincerely yours, Mr. Tracy Nagel-Chief financial officer

Finding Number: 2022-001 Condition: The Corporation failed to refund security deposits to 3 tenants within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely. Contact person responsible for corrective action: Jill Kolb, Vice President ? Housing Accounting Completion Date: August 9, 2022

2022-005 Special Tests and Provisions: Public Housing New Admissions and Waiting List Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control, Material Noncompliance Repeat Finding from June 30, 2021 reported as Finding 2021-003 Condition: New Admissions: We selected 5 new admissions (out of a population of 13) and noted the following: ? We are unable to test if the 5 new admissions were properly selected from the waiting list. Normally we are able to verify by checking where the applicant was on the wait list prior to selection and comparing the waiting list ranking (for date/time applied and preferences) to the application submitted. However, the Authority was not able to provide the applications from which would show the date and time they applied as well as any preferences selected so we were unable to determine if the new admissions were properly selected from the waiting list. Waiting list: We selected 25 applicants on the current waiting list (out of approximately of 700 applicants) and noted the following: ? We were unable to test the 25 applicants selected for testing. The Authority was unable to provide the application for each person on the waiting list and therefore we were unable to determine if the waiting list is ranked properly. As discussed with personnel, all active applications are received electronically (when the waiting list is open). The families create the application entering information such as family members, family income and family expenses. However, the on-line system appears to be flawed as it does not provide fields to indicate preferences (such as for being homeless or living locally) which if entered, would give the applicant points so they could be ranked higher on the waiting list and therefore selected faster. Once the applicant is selected to be housed, the Authority manually applies the applicable preferences (but at that point the Authority may have selected someone on the waiting list that should have been selected earlier and defeats the purpose of having preferences). The Authority has addressed this issue with Yardi and has sent notices to all active applicants asking them to update their preferences which the Authority will manually apply and generate the waiting list and the process is expected to be finalized before March 31, 2023. As a result of the above, applicants may not be ranked properly on the waiting list and applicants may be selected out of order. Auditor?s Recommendation: The Authority should review procedures and increase training to employees and reviewers to ensure that the Authority is in compliance with HUD rules for new admissions and waiting list maintenance. In addition, the Authority should implement a review procedure to make sure that all tenants are admitted in the proper order with proper supporting documentation. In addition, the Authority should continue to investigate the issues with the waiting list software. Action Taken: The Authority transitioned its waiting list to Yardi in March 2020. All HCV staff were trained on the use of Yardi?s Wait List module and subsequently trained on wait list administration such as eligibility, preferences, selection, and file processing. Considering the recent audit findings, the following actions items will be implemented in the specified time frame: ? The Authority has fully implemented the use of an electronic system to maintain the waitlist activity. The Yardi system inherently, with proper usage, provides a more thorough approach to waitlist maintenance. The errors noted were data entry errors not a system flaw. As such, a 100% QC will be conducted by the Senior Property Manager for each existing applicant. Task will be completed on or before April 30, 2023. ? The Authority will review all applicants and assign the correct preference status for each. Task will be completed on or before May 15, 2023. ? The site based waiting list will be merged into a centralized wait list and will be managed by the Occupancy Specialists and overseen by the Senior Property Manager. Waitlist merge will be completed on or before May 15, 2023. ? Provide additional hands-on training for staff on the proper wait list procedures and protocol. Hands-on training will include the use of Yardi?s wait list module as well as HUDs rules on wait list administration coupled with the guidance outlined in the Administrative Plan. Task will be completed on or before May 31, 2023. ? Implement a 100% quality control review of all applicant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured before the final completion of leasing activities. Thereby reducing any additional findings with waiting list. Task will begin March 1, 2023 and will continue for one year. ? Repeated noted errors will be reported to the Senior Property Manager and additional hand?s-on training will be completed as necessary. ? Standard Operating Procedures on waitlist management will be developed and implemented. All staff will receive training on the procedures and will be expected to adhere to the protocol and will be made accountable for such work. Effective Date: March 21, 2023 Contact Information Charles Woodyard, Executive Director/CEO Housing Authority of the City of Daytona Beach, Florida 211 N. Ridgewood Avenue, Suite 300 Daytona Beach, Florida 32114 (386) 253-5653

2022-004 Eligibility: Public Housing Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control, Material Noncompliance Repeat Finding from June 30, 2021 reported as Finding 2021-002 Condition: Out of a total tenant population of approximately 300 tenant files, 25 files were selected for testing (but stopped testing after 18 files due to the volume of errors). Exceptions were noted as follows: ? 1 tenant file where the Authority was unable to locate and therefore could not test items such as Form 9986, personal declaration form, birth certificates, social security cards, income and deduction support, and EIV verification. The Authority indicated it was recreating the file. ? 2 tenant files with missing 214 affidavits. ? 1 tenant file where the 214 affidavit was not signed. ? 5 tenant files where the personal declaration form was not in the file. ? 1 tenant file where the Form 9886 was not in the file. ? 1 tenant file where the Form 9886 was signed approximately 3 months after the recertification date. ? 4 tenant files with income issues which may have changed the tenant rent amount: o 1 file where there was no support for the family contribution listed on the 50058. o 1 file where there was no support for the child support listed on the 50058. o 2 files where general assistance income (food stamps) was listed as income on the 50058 but should have been excluded. ? 4 tenant files with deduction issues which may have changed the tenant rent amount: o 1 file where the utility allowance of $91 was not on the 50058. This was corrected subsequently on an interim certification. o 1 file where the ?Disclosure of Information? form listed weekly child care expenses, but no child care expenses were deducted on the 50058 and there was no documentation or support in the file explaining if the child care expenses were deductible. o 1 file where the ?Recertification Summary? form listed weekly medical expenses, but no medical expenses were deducted on the 50058 and there was no documentation or support in the file explaining if the medical expenses were deductible. o 1 tenant file where the prior year utility allowance of $82 was used instead of the current utility allowance of $90. ? 1 file where the tenant is paying a flat rent of $686. However, the flat rent appears to be the amount from the previous year and it doesn?t appear that a current flat rent study was conducted or approved. ? 1 file where the dependent date of birth listed on the 50058 did not agree to the birth certificate. ? 2 files where the birth certificates were missing. ? 2 files where the social security cards were missing. ? 1 file where the EIV was not in the file. Auditor?s 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: As was also instituted for HCV participant files, the Authority has instituted a checklist sheet that will occupy the front interior of all tenant files. This checklist will contain every document that is required to be placed in the tenant file. The Authority has and will affirm the use of its procedures, and continue to implement procedures to ensure all tenant files are maintained in accordance with policies and procedures. Additionally: ? All noted deficiencies will be corrected and cured on or before March 31, 2023. ? The Authority has also taken steps to stabilize staff by hiring a Property Manager and an Occupancy Specialist that will support the Public Housing Department. ? The Authority has implemented a 100% quality control review of all participant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured before the final completion of certification. Thereby reducing any additional findings with tenant files. Task began February 1, 2023, and will continue for one year. ? Repeated noted errors will be reported to the Senior Property Manager and additional hand?s-on training regarding deficient items will be completed as necessary

2022-003 Special Tests and Provisions: HCV Failed Inspections Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Mainstream Vouchers ? CFDA Number 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: Out of a total failed inspection population of approximately 540 units, 25 failed inspections were selected for testing. Exceptions were noted as follows: ? 1 Inspection and HAP abatement error where the tenant?s unit did not pass inspection and HAP payments were not withheld from July 2022 through February 2023. ? 1 HAP abatement error where the Authority pro-rated the HAP payment for August 2022 and abated the HAP payment for September through November 2022, but subsequently, whether due to a user or system error, HAP payments were paid out for the months from September through November 2022. ? 1 HAP abatement error where the Authority pro-rated the HAP payment for January & May 2022 and abated the HAP payment for February through April 2022, but subsequently, whether due to a user or system error, HAP payments were paid out for the months from January through May 2022. ? 1 HAP abatement error where the Authority didn't pro-rate the HAP payment withholding for June & December 2022 nor withhold the HAP payment for the month of July 2022. The Authority properly withheld the HAP payments for the months of August, September, October, and November 2022. Auditor?s Recommendation: The Authority should review procedures and increase training to employees and reviewers to ensure that the Authority is in compliance with HUD rules for HQS inspections. In addition, the Authority should implement a review procedure to make sure that HAP payments are properly abated when required. Action Taken: The Authority has moved to an electronic records management system for the inspections. A third party vendor has been procured to manage this process; such process will be overseen by the Housing Choice Voucher Manager. Additionally, the following action items has been implemented: ? The Authority has access to the vendor database on a 24 hour basis and the vendor also provides the Authority with a daily email of inspection data. Actual inspections will be printed and maintained to assure that greater than 10% of the inspections are readily available for each participant. ? The third-party vendor will perform quality control inspections of each completed inspection and make note of such in the electronic database. ? Warranted and recommended abatements will be entered into the database by the third-party vendor and subsequently monitored by the Housing Choice Voucher Manager ? Contract administration of the third-party vendor?s work will be monitored by the Housing Choice Voucher Manager. ? Training on HUD rules for HQS inspections will be completed on or before April 30, 2023

2022-002 Special Tests and Provisions: HCV Current Waiting List Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Mainstream Vouchers ? CFDA Number 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: Out of a total waiting list population of approximately 1300 applicants, 25 applicants were selected for testing. Exceptions were noted as follows: ? 1 preference point error where the applicant selected the involuntary displacement and homeless preference points on their pre-application, which agrees to the information in Yardi, but doesn?t agree to the generated waiting list. ? 7 preference point errors where the applicants? selected the residency preference points on their pre-applications, which agrees to the information in Yardi, but doesn?t agree to the generated waiting list. As a result of the above, applicants may not be ranked properly on the waiting list and applicants may be selected out of order. Auditor?s Recommendation: The Authority should review procedures and increase training to employees and reviewers to ensure that the Authority is in compliance with HUD rules for new admissions and waiting list maintenance. In addition, the Authority should implement a review procedure to make sure that all tenants are admitted in the proper order with proper supporting documentation Action Taken: The Authority transitioned its waiting list to Yardi in March 2020. All HCV staff were trained on the use of Yardi?s Wait List module and subsequently trained on wait list administration such as eligibility, preferences, selection, and file processing. Considering the recent audit findings, the following actions items will be implemented in the specified time frame: ? The Authority has fully implemented the use of an electronic system to maintain the waitlist activity. The Yardi system inherently, with proper usage, provides a more thorough approach to waitlist maintenance. As such, a 100% QC will be conducted by the HCV Manager for each existing applicant. Task will be completed on or before April 30, 2023. ? The Authority will review all applicants and assign the correct preference status for each. Task will be completed on or before May 15, 2023. ? Provide additional hands-on training for staff on the proper wait list procedures and protocol. Hands-on training will include the use of Yardi?s wait list module as well as HUDs rules on wait list administration coupled with the guidance outlined in the Administrative Plan. Task will be completed on or before May 31, 2023. ? Implement a 100% quality control review of all applicant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured before the final completion of leasing activities. Thereby reducing any additional findings with waiting list. Task will begin March 1, 2023 and will continue for one year. ? Repeated noted errors will be reported to the HCV Manager and additional hand?s-on training will be completed as necessary. ? Standard Operating Procedures on waitlist management will be developed and implemented. All staff will receive training on the procedures and will be expected to adhere to the protocol and will be made accountable for such work.

2022-001 Eligibility: HCV Tenant Files Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Mainstream Vouchers ? CFDA Number 14.879 Material Weakness in Internal Control, Material Noncompliance Repeat Finding from June 30, 2021 (Finding 2021-001 and originally reported in 2017 as Finding 2017-001) Condition: Out of a total tenant population of approximately 1400 vouchers, 26 files were selected for testing. Exceptions were noted as follows: ? 1 utility allowance error where the utility allowance amount of $288 on the 52667 form was reported on the 50058 form for $298. This had no effect on the HAP rent. ? 2 214 affidavit errors where a member of the tenant?s household did not checkmark the box on their 214 forms indicating that they are either a U.S. citizen or a permanent resident. Based on the birth certificates, the member of the households were a U.S. citizen. ? 1 214 affidavit error where the 214 form was missing for a member of the tenant?s household. ? 1 income error where one of the tenant?s pay check was missing for the tenant?s income calculation. Basing the tenant?s wage income calculation on the support in the tenant file would not have changed the HAP rent. ? 1 HAP contract error where the HAP contract is missing from the tenant file. ? 2 9886 errors where members of the household over the age of 18 did not sign and date the 9886 forms. ? 2 deduction errors where members of two households, who were 18 years of age, received a $480 deduction. Correcting this error caused the HAP rent to decrease by $12 for each tenant. ? 1 lead base paint error where the lessor (landlord) did not sign the form to indicate that the information provided to the tenant is accurate. ? 2 EIV errors where the EIV form was not generated or were missing for the tenant?s annual recertification. ? 1 50058 error where the tenant?s childcare support was coded as unemployment benefits on the 50058. ? 1 tenant file unavailable for review due to Hurricane IAN, but no support could be provided. In addition, we also noted as part of our new admissions testing (21 files tested out of approximately 203 new admissions) the following: ? 1 tenant file unavailable for review due to Hurricane IAN, but no support could be provided. Auditor?s 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 implemented a 100% quality control review of all participant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured before the final completion of certification. Thereby reducing any additional findings with tenant files. Task began February 1, 2023, and will continue for one year. Repeated noted errors will be reported to the HCV Manager and additional hand?s-on training regarding deficient items will be completed as necessary

2022-002 Activities Allowed / Un-Allowed Material Weakness/Material Noncompliance This finding was identified during the QAD review that was performed in 2022 and has been corrected as of June 30, 2022, with prior period and current year adjustments. The current revised indirect cost allocation was approved by HUD QAD in July 2022. Indirect costs are being reviewed on a quarterly basis and adjusted as needed. The Comptroller, Jennifer Yager corrected this finding in October 2022. Jennifer can be reached at 203-596-2640.

2022-006 Special Tests and Provisions ? Operating Transfers and Administrative Fees Material Weakness / Material Noncompliance This finding was corrected in October 2022. The interfund transfers were not initially set up correctly in the PHA-Web software. In October 2022 the Comptroller worked with PHA-Web to fix this issue. Jennifer can be reached at 203-596-2640.

2022-005 Special Tests and Provisions ? General Depository Agreements Significant Deficiency / Other Matter This finding has been corrected. General Depository Agreements are in place. This was completed on August 22, 2022, by the Comptroller, Jennifer Yager, which can be reached at 203-596-2640.

2022-004 Special Tests and Provisions ? CARES Act Funding Material Weakness / Material Noncompliance The Housing Authority completed modifications to the main office building with CARES Act funding. The Section 8 specialist employees work in the main office building with the administrative staff of the Housing Authority. Prior to COVID, the Section 8 specialists were working in cubicles which were not compliant with the CDC guidelines of distance. CARES Act funding was used to build separate offices and install an air filtration system. The rest of the main office was only modified to stay uniform with the other modifications such as painting and new flooring. The amount of the total project charged to the HCV program was in relation to what improvements were made as well as which employees were occupying the space. Effective July 2022, Section 8 is leasing this section of the main office, which was approved by HUD QAD. This finding has been corrected. The Comptroller, Jennifer Yager, worked with the outside auditors as well as the CFO consultant to resolve the posting errors. Jennifer can be reached at 203-596-2640.