Corrective Action Plans

Comments on Findings and Recommendation: The Corporation's required deposit into the residual receipts account per the June 30, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Management should make all required residual receipts deposits per the annual Computation of Surplus Cash, Distributions and Residual Receipts within 90 days after the fiscal year end. Action(s) taken or planned on the finding: Agree. Management deposited $10,879 into the residual receipts fund on May 2, 2022.

Identifying Number: 2022-001 Finding: The Organization did not deposit cash surplus into the residual receipts account in a timely manner. Contact Person Responsible for Corrective Action: Richard Manall, CFO Corrective Action Taken or Planned: Review of the financial statement now includes the process of making the cash surplus cash transfer into the residual receipts account. Anticipated Completion Date: September 14, 2022.

Finding 2022-001 Federal Agency Name: Department of Housing and Urban Development, Passed through Hearth Connections Program Name: Continuum of Care CFDA # 14.267 Finding Summary: Identified five instances where the participant?s file did not have documentation that the rent reasonableness test was performed in a timely manner. In addition, we identified 19 instances where the participant?s file did not have documentation that the rent reasonableness test was reviewed. Creating Inadequate internal controls over compliance could result in noncompliance with the federal program. Responsible Individuals: Paul Bloomer, VP of Finance Corrective Action Plan: A complete review and policy and procedures along with proper training for new staff. The findings occurred during position vacancy and onboarding training. Additional steps are taken to ensure training is completed and random spot checks of client files. Anticipated Completion Date: Ongoing in nature.

Finding No. 2022-014 Department(s) New York City Human Resources Administration Program(s) Assistance Listing Number 14.241, Housing Opportunities for Persons with AIDS Corrective Action(s) The auditors selected a non-statistical sample of nineteen (19) units that were subject to an initial inspection by HRA during fiscal 2022 and noted that for three (3) selections, HRA was unable to provide a copy of the inspection checklist that was completed by the QA Inspector prior to assistance being provided for the unit. Unfortunately, during the height of the COVID-19 pandemic, many housing vendor staff were working remotely, and a few documents may have been mislaid. To ensure continual compliance with federal HOPWA grant requirements, HRA will enhance its efforts to confirm that housing vendors properly maintain a copy of inspection checklists completed prior to initial move in. Monitoring visits conducted by HRA will include a review of the checklists. Anticipated Completion Date April 2023 and ongoing Person(s) Responsible for Implementation Pamela Xiomara Farquhar Assistant Deputy Commissioner FarquharX@hra.nyc.gov

Finding No. 2022-011 Department(s) New York City Human Resources Administration Program(s) Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s) HRA is committed to better understand the Housing Quality Standards (HQS) inspection process and strengthen our monitoring to ensure future compliance. Corrective Actions: ? Hire an Executive Director for the TBRA. ? Advance HRA understanding of the inspection process, deliverables and compliance including intentional notifications and requesting, collecting, and maintaining of documentation. ? Review and update, as determined, HRA procedures to strengthen monitoring of HQS inspections and ensure appropriate documentation is maintained. Anticipated Completion Date May 2023 and ongoing Person(s) Responsible for Implementation Dori Hopkins-Figeroux Director, TBRA (929) 252-6089 Dwana Abraham Assistant Deputy Commissioner (929) 221-6726

Finding No. 2022-003 Department(s) New York City Human Resources Administration Program(s) Assistance Listing Number 14.231, Emergency Shelter Grants Program Corrective Action(s) Because the ESG expense construct had to be vetted and approved before obligating the total grant amount, we were unable to do so within the prescribed 180 days. We will ensure in the future that we strengthen our internal controls to ensure that 100% of the total ESG grant amount is obligated within 180 days of the signed grant agreement. This will include an added layer of review by the Associate Commissioner of Homeless Policy and Innovation, who oversees the unit that obligates the funds in IDIS. Anticipated Completion Date April 2023 and ongoing Person(s) Responsible for Implementation Kristen Mitchell Associate Commissioner, Homeless Policy & Innovation MitchellKr@dss.nyc.gov

Finding 2022-022 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Provider Eligibility Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS will amend the managed care contracts to require that signatures are obtained on the Provider Screening Information Collection Tool (PSICT) forms when contracts and waivers are renewed and extended. Annually, MDHHS will send a reminder to the managed care entities to report any change in ownership to MDHHS within 35 days. In addition, MDHHS has incorporated a review of provider agreements as part of their monitoring process conducted for all MI Choice Waiver Program (MI Choice) entities. Anticipated Completion Date MDHHS will send the annual reminder to managed care entities beginning August 2023. MDHHS anticipates that signatures will be obtained on the PSICTs effective October 2023 for the fiscal year 2024 contract cycle. MDHHS expects to complete its current review of provider agreements for MI Choice entities by July 2023 and reviews will be ongoing. Responsible Individual(s) Elizabeth Gallagher, MDHHS Latina McCausey, MDHHS

2022-002 Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-001 from September 30, 2021 (Other Matter and Significant Deficiency in Internal Control over Compliance). Originally reported as finding 2019-001 from September 30, 2019 (Material Weakness in Internal Control and Material Noncompliance) Statement of Condition: Out of a total tenant population of approximately 1,114 vouchers, 25 files were selected for testing. Exceptions were noted as follows: ? 1 tenant file had the following errors: o The tenant?s annual recertification application is missing. o The tenant?s signed 9886 form is missing. o The wrong utility allowance schedule was used to calculate the tenants? utility allowance. Correcting this error would cause the HAP rent to increase by $9. o The tenant?s signed HAP contract is missing. ? 1 tenant file had the following errors: o The name and social security number for one of the tenant?s dependents was reported incorrectly on the 50058 form. o The tenant?s utility allowance was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would cause the HAP rent to increase by $56. ? 1 tenant file had the following errors: o The lease agreement was not signed by the tenant. o The tenant?s assets was reported in error. Correcting this error would cause the rent to increase by $8. ? 2 tenant files where the tenants? income was miscalculated. Correcting the errors would cause the HAP rent for one of tenant files to decrease by $12 and the other to increase by $181. ? 2 tenant files where the wrong utility allowance schedule was used to calculate the tenants? utility allowance. Correcting these errors would cause the HAP rent for one of the tenant files to decrease by $13 and the other to increase by $14. ? 1 tenant file where the family?s assets was reported in error. Correcting the errors had no effect on the HAP rent. ? 1 tenant file where a member of the household moved but was reported on the 50058 form. ? 1 tenant file where the tenant?s signed HAP contract is missing. ? 1 tenant file where the EIV report was never generated or was misplaced. In addition to the above, we noted the following during our new admissions testing (out of a total of 118 new admission, 18 files were selected for testing.): ? 1 tenant file where the member of the household did not checkmark the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen or permanent resident. However, the member?s birth certificate confirms that the member is a U.S. Citizen. ? 1 tenant file where the tenant?s signed 214-affidavit is missing. However, the member?s birth certificate confirms that the member is a U.S. Citizen. 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 concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested will have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an Other Adult packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant?s file. The Counselor?s caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors? strength and weaknesses, and to determine if additional training and/or monitoring is needed. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor?s processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV staff will attend Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training. Effective Date: June 20, 2023 Contact Information Gwendolyn B. Dawson, CEO Ocala Housing Authority 1629 NW 4th Street Ocala, Florida 34475 (352) 369-2636

2022-006 Special Tests and Provisions ? Internal Control and Compliance over Obligation, Expenditure, Payment Requirements City?s Corrective Action Plan: When invoices from subrecipients are received, they are reviewed thoroughly by staff. Documentation sent may range from a few pages to several hundred pages. The larger the packet submitted, the longer the review process. In the review process, it may be determined that the information sent is not sufficient to support the claim/amount for reimbursement. This initiates a back and forth between staff and the subrecipient that could take up to several weeks to resolve. The department continuously holds workshops with all vendors/subrecipients on best practices, and invoicing procedures to cut down on the time spent reviewing invoices. The department makes great effort in working with all subrecipients to expedite documentation review and payment process and continues to make great improvement in this area. Staff will also maintain records of any delays in processing as a result of insufficient documentation submitted by the subrecipient. Responsible Person: Julisa Villalobos (Program Admin), Raquel Chavarria (Fiscal) Expected Implementation Date: July 2023

Corrective Action Plan Year Ended December 31, 2022 Name and Number of Project: Cedar Lane Senior Living Community I, Inc. HUD Project Number 052-11225 Auditor/Audit Firm: PKF O?Connor Davies LLP Audit Period: December 31, 2022 Finding 2022-001 ? Use of Project Funds Federal Assistance Listing Number Name of Federal Programs 14.155 Mortgage Insurance for the purchase or Refinancing of Existing Multifamily Housing Projects 14.195 Section 8 Project-Based Cluster Section 8 Housing Assistance Payments Program A. Comments on Finding and Recommendations Recommendation ? We recommend that management reconcile and repay intercompany activity in a timely manner. B. Actions Taken or Planned The Entity has instituted policies and procedures to reconcile and rectify intercompany activities timely and is working with their HUD representative to consolidate their Federal Programs which will rectify the issue and simplify the intercompany activity. C. Status of Corrective Action on Prior Findings N/A Eric Golden, President and CEO Cedar Lane Senior Living Community I, Inc.

RE: HELP HOUSING FOR THE DISABLED, INC. 26900 Euclid Avenue Euclid, Ohio 44132 SUBJECT: Corrective Action Plan 042EH430 HELP HOUSING FOR THE DISABLED Reporting Period Ending Date ? June 30, 2022 Finding 2022-001 CFDA: 14.157 Section 202 Direct Loan Criteria: Internal controls over compliance should be in place to ensure the deposit of surplus cash amounts into the residual receipts account occurs within ninety days after year end. Condition: A deficiency in internal control over compliance existed due to the prior year excess surplus cash amount not being deposited into the residual receipts account within ninety days after the end of the annual fiscal period for which the surplus cash was calculated. Recommendation: The Project should establish procedures to ensure that surplus cash is deposited within ninety days after the end of the annual fiscal period for which the surplus cash is calculated. CORRECTIVE ACTION: Management has agreed to implement the process of depositing surplus cash on the day the audited financial statements are issued. Thorough review of financial statement notes and conversations with audit team during the review process will establish the amount of funds to be deposited. Once this internal review is complete and audited statements are issued the internal management team will routinely make the required deposit and follow up by providing payment confirmation to the outside audit team. This accountability confirmation process will ensure that the deposit is made timely and routinely. Any questions regarding this plan should be directed to: Belinda Glavic Grassi MA, CPA Chief Financial Officer Help Housing for the Disabled, Inc. (216) 432-4810

ALTURAS DE SAN JUAN CORRECTIVE ACTION PLAN FINANCIAL STATEMENT Fiscal Year June 30, 2022 NAME OF PROJECT: NUMBER OF PROJECT: AUDITOR I AUDIT FIRM: Alturas de San Juan 056-EH-195-WAH-L8 Jose Luis Mendoza & Co., LLP FINDING NO. 2022-001 SECURITY DEPOSITS We agree. The accounting error recording the transaction has been corrected during the month of July 2022. Combined Building & Housing Consultants, Inc. Management Agent Name of Contact Person: Rebecca Palacios Position: President Combined Building

Carbondale Senior Housing Corporation Phase II, dba Crystal Meadows IV (?CSHC Phase II?) respectfully submits the following corrective action plan for the year ended June 30, 2022.CSHC Phase II agrees that the surplus cash calculation for June 30, 2021 is correct and that the required deposit was not made to a separate bank account. Moving forward, management will review and calculate surplus cash following the close of each fiscal year to ensure the deposit, if applicable, is made within the 60-day period as required by HUD. Jerilyn Nieslanik, Executive Director In August 2022, a new bank account for CSHC Phase II was opened, with the June 30, 2021 calculated surplus cash transferred. No additional deposit is required for the June 30, 2022 fiscal year end.

Finding Number: 2022-001 Condition: HUD requires the Corporation to refund the security deposit to tenants within 30 days of the move out. The Corporation failed to monitor the deposit refund requirements for the security deposits as specified by the regulatory agreement and failed to return security deposits within 30 days. Planned Corrective Action: Management acknowledged the errors that occurred during the year ended September 30, 2022 and has taken measures to change their process of issuing refunds to reduce the likelihood of late refunds. Contact person responsible for corrective action: Jill Kolb, Vice President ? Housing Accounting Completion Date: December 14, 2021 and January 25, 2022

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The replacement reserve deficiency was funded on September 8, 2022 in the amount of $846. Management will ensure that the replacement reserve deposits are made on a timely basis in the future. Completion Date: September 8, 2022

2022-001 Special Tests and Provisions/Utility Allowance Condition and Criteria: The entity must maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and adjust its utility allowance schedule if there has been a rate change of 10 percent or more. Certain utility rate categories did appear to have increases in excess of the 10% threshold. A revised utility allowance schedule was not available. Effect: Participant housing assistance payments may not be calculated correctly. Auditor?s Recommendation: The entity should document its annual review of utility rate data and revise its schedule of utility allowances as appropriate. Grantee Response: We gathered utility rates from the various suppliers and forwarded this data to a company specializing in utility allowance studies in early April 2022. The company failed to provide the Agency with revised utility allowances. The Agency followed-up with the company on the utility allowance study in April, June and September. A revised utility allowance was never received. We will ensure a utility study will be completed and utility allowance schedules revised by October 31, 2023.

Finding 2022-02 Federal Award Programs View of Responsible Official: Management concurs with this finding that quarterly reporting was done late, mainly due to staff turnover. Of note, 2 of the disasters had occurred in 2008 and 2019 and the reports had zero activity to report as they are in holding phase waiting for the Federal government to close out the programs. The Parish had become aware of these delinquent filings prior to this audit and had addressed the situation. Going forward, the Parish will ensure that all reports are filed in a timely manner. Anticipated Completion Date: 7/12/2023 Responsible Contact Person: Robert Figuero Jr., Chief Financial Officer

Finding 2022-006 ? Unauthorized distribution A. Comments on Finding and Recommendations Recommendation ? Auditor recommend that management evaluate its process and implement policies to mitigate the chances of distributing funds from net assets without HUD approval. B. Actions Taken or Planned Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for distributing funds as well as oversight from the Board of Directors. Auditee is in the process of requesting HUD approval for the distribution. If accepted by HUD, this will clear this finding for the amount distributed during this fiscal year. C. Status of Corrective Action on Prior Findings No prior finding.

Finding 2022-004 ? Timely Deposit of Surplus Cash A. Comments on Finding and Recommendations Recommendation ? We recommend that management ensures the surplus cash deposit is done timely in the future. B. Actions Taken or Planned Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Going forward our focus will be to work with the auditor and owner to get the audits finalized earlier so adequate time is left for the deposits to be made. In instances where the final is not going to be issued and allow enough time, the deposit will be made based on the reviewed draft. C. Status of Corrective Action on Prior Findings Finding 2017-001 et seq. remains uncleared.

Finding 2022-003 ? Residual Receipts A. Comments on Finding and Recommendations Recommendation ? We recommend that management evaluate its process and implement policies to mitigate the chances of withdrawing funds from the residual receipts without HUD approval. B. Actions Taken or Planned Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for withdrawing funds as well as oversight from the Board of Directors. Auditee has been in discussion with HUD and will submit a letter with justification of withdrawals upon receipt of the notice of violation as requested from HUD. If accepted by HUD, this will clear this finding for the amount transferred during this fiscal year. C. Status of Corrective Action on Prior Findings Finding 2021-004 is uncleared.

Finding 2022-002 ? Replacement Reserve A. Comments on Finding and Recommendations Recommendation ? We recommend that management evaluate its process and implement policies to mitigate the chances of withdrawing funds from the replacement reserve without HUD approval. B. Actions Taken or Planned Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for withdrawing funds as well as oversight from the Board of Directors. Auditee has been in discussion with HUD and will submit a letter with justification of withdrawals upon receipt of the notice of violation as requested by HUD. If accepted by HUD, this will clear this finding for the amount transferred during the fiscal year. C. Status of Corrective Action on Prior Findings Finding 2021-003 is cleared. A new Executive Director has taken over responsibility for withdrawing funds as well as oversight from the Board of Directors. A letter was submitted to HUD notifying them of the withdrawals by the previous director with a plan to correct. In addition to the letter, invoices were submitted to justify the transfers. HUD approval for the justification for the withdrawals was received on 2/21/2023 and 4/04/23. No amounts remain due to the account.

CORRECTIVE ACTION PLAN 2022-001 - Special Tests & Provisions- HQS Enforcement Auditee's Response and Planned Corrective Action The period of the inspections was during Covid and the files audited were Enhanced vouchers leased at Orchard Hill Estates. The development had several issues with retaining maintenance to correct the deficiencies. The development also struggled with receiving parts in a timely manner. The Oxford Housing Authority had been in contact with the development throughout the period of held HAP to maintain that these units were to be corrected. The Oxford housing Authority withheld HAP payments until the units were corrected, then released payment. The Oxford Housing Authority bas revised its Ad.min Plan to include the corrective procedure for abated units, along with a revised notice to the landlord. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Barry Nadon Jr.

Finding 2022-002 Responsible Party Name: Fred Gibbs Position: President ? Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N ? Special Tests and Provisions Finding Type Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will deposit the shortfall of $868 into the reserve for replacement account, as soon as possible. We will also deposit the shortfall for 2019, 2020, and 2021 once funds become available. We will follow our process to deposit and reconcile the reserve for replacement account on a monthly basis. Anticipated Completion Date June 30, 2023

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2022 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 ? Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor?s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2022. Finding 2022-001 Responsible Party Name: Fred Gibbs Position: President ? Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N ? Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will follow our policies and procedures to ensure that our accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date June 30, 2023

2021-004 Housing Voucher Cluster ? Assistance Listing No. 14.871 Recommendation: The Authority should review their HQS inspection policies to ensure that all repairs are made timely and if not, that the necessary actions are taken by the Authority. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NOHA has reviewed its updated HQS policies, including its HQS enforcement policies. NOHA continues to refine software functionality and reporting to monitor HQS repair due dates, and to take action when necessary. Name(s) of the contact person(s) responsible for corrective action: Sandra Soucie, HCV Manager, HCVManager@nwoha.org Planned completion date for corrective action plan: 3/31/2023