Corrective Action Plans

Finding 1172394 (2025-001)

Material Weakness 2025

HOUSING AUTHORITY OF THE CITY OF STERLING, COLORADO

CO

Cash Management HUD Housing Programs Subrecipient Monitoring

In accordance with HUD requirements, the Authority plans to begin drawing down operating-subsidy funds on a monthly basis. The Executive Director and Board will continue to review monthly financial statements prepared by the accountants and will research and evaluate potential investment options to ...

In accordance with HUD requirements, the Authority plans to begin drawing down operating-subsidy funds on a monthly basis. The Executive Director and Board will continue to review monthly financial statements prepared by the accountants and will research and evaluate potential investment options to increase the return on available funds. The Authority intends to develop and adopt formal written procedures for cash management and investment monitoring during the next fiscal year.

View Audit 385443

Finding 1172392 (2025-001)

Material Weakness 2025

Magnolia Housing Corporation of Natchitoches, Inc.

LA

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

Magnolia Manor Corporation has taken steps to ensure that the Replacement Reserve account will not be underfunded by withdrawing funds to cover the Operating Account. The underfunded amount of $2,688.00 has been deposited on August 20, 2025, and $306.00 has been deposited on September 15, 2025. Magn...

Magnolia Manor Corporation has taken steps to ensure that the Replacement Reserve account will not be underfunded by withdrawing funds to cover the Operating Account. The underfunded amount of $2,688.00 has been deposited on August 20, 2025, and $306.00 has been deposited on September 15, 2025. Magnolia Manor Corporation has reviewed the auditors' recommendation and will ensure that more thorough monthly reviews will be implemented.

View Audit 385441

Finding 1172162 (2025-008)

Material Weakness 2025

School District of Thorp

WI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303

Recommendation: CLA recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases, along with adding controls to ensure that the item purchased was r...

Recommendation: CLA recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases, along with adding controls to ensure that the item purchased was received by the District. CLA also also recommends the District printout the eligibility reports from Wisegrants and sign and date them to indicate review and approval after meeting with CESA 10 each year. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The District will note the date of the budget meeting with CESA 10. When items are purchased for Title I, approval will be made by either the Elementary Principal or Superintendent before purchases are made. Name(s) of the contact person(s) responsible for corrective action: Brooke Rosemeyer, Adrian Foster, Brandon Baldry Planned completion date for corrective action plan: September 1, 2026.

View Audit 385300

Finding 1172146 (2025-002)

Material Weakness 2025

Philadelphia Booth Manor II

PA

HUD Housing Programs Reporting

The security deposit discrepancy will be rectified

View Audit 385295

Finding 1172145 (2025-001)

Material Weakness 2025

Philadelphia Booth Manor II

PA

Procurement, Suspension & Debarment HUD Housing Programs Reporting

The Salvation Army submitted a BBRI which requested increased rents and releases from reserves to pay accounts payable as well as approval of loans from the Sponsor to cover accounts payable that could not be paid from reserves. This would enable the reserves to be paid on a go forward basis. In add...

The Salvation Army submitted a BBRI which requested increased rents and releases from reserves to pay accounts payable as well as approval of loans from the Sponsor to cover accounts payable that could not be paid from reserves. This would enable the reserves to be paid on a go forward basis. In addition, the next step will be a BBRI for the RAD for PRAC conversion.

View Audit 385295

Finding 1172144 (2025-001)

Material Weakness 2025

Philadelphia Booth Manor II

PA

Procurement, Suspension & Debarment HUD Housing Programs Reporting

The Salvation Army submitted a BBRI which requested increased rents and releases from reserves to pay accounts payable as well as approval of loans from the Sponsor to cover accounts payable that could not be paid from reserves. This would enable the reserves to be paid on a go forward basis. In add...

The Salvation Army submitted a BBRI which requested increased rents and releases from reserves to pay accounts payable as well as approval of loans from the Sponsor to cover accounts payable that could not be paid from reserves. This would enable the reserves to be paid on a go forward basis. In addition, the next step will be a BBRI for the RAD for PRAC conversion.

View Audit 385294

Finding 1172004 (2025-001)

Material Weakness 2025

Housing Authority of the City of Norwalk

CT

HUD Housing Programs Special Tests & Provisions Reporting

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. Adam Bov...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. Adam Bovilsky, Executive Director, is responsible for implementing this corrective action by March 31, 2026.

View Audit 385109

Finding 1171972 (2025-002)

Material Weakness 2025

Northeast Oregon Housing Authority

OR

HUD Housing Programs Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Action Plan: The Authority has recognized the significant deficiency in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Sarah Parker, Executive Director, was designa...

Views of Responsible Officials and Planned Corrective Action Plan: The Authority has recognized the significant deficiency in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Sarah Parker, Executive Director, was designated to be responsible for implementing this corrective action by March 31, 2026.

View Audit 385053

Finding 1171943 (2025-001)

Material Weakness 2025

Grange Acres Nonprofit Housing Corporation (phase Ii)

MI

Special Tests & Provisions HUD Housing Programs Significant Deficiency

U.S. Department of Housing and Urban Development Grange Acres Nonprofit (Phase II) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Suite 1 Lansing, MI 4...

U.S. Department of Housing and Urban Development Grange Acres Nonprofit (Phase II) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Suite 1 Lansing, MI 48912 Audit period: July 1, 2024 – June 30, 2025 The finding from the June 30, 2025 schedule of findings and questions costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. Finding Number 2025-001 – Significant Deficiency in Internal Control over Major Federal Program Compliance: Special Tests and Provisions: - Replacement Reserve Requirements Recommendation: The Project should deposit $429 into the replacement reserve account. Additionally, procedures should be followed to ensure management identifies the need for required deposits. Action Taken: The Project has deposited the underfunded amount and will review future HUD communications to identify replacement reserve funding requirements.

View Audit 385022

Finding 1171892 (2025-001)

Material Weakness 2025

Housing Authority of the City of College Park

GA

HUD Housing Programs § 200.05

Finding 2025-001: Capital Fund Program – Cash Management Reference to Audit Report: Auditors noted that the Authority did not comply with HUD’s 3‑day rule for expenditure of drawdowns. Cause: Invoices were not fully verified before requesting drawdowns. Effect: Funds were drawn down before being pay...

Finding 2025-001: Capital Fund Program – Cash Management Reference to Audit Report: Auditors noted that the Authority did not comply with HUD’s 3‑day rule for expenditure of drawdowns. Cause: Invoices were not fully verified before requesting drawdowns. Effect: Funds were drawn down before being payable, resulting in noncompliance with HUD cash management rules. Corrective Action Plan: -Implement an invoice verification checklist prior to drawdowns. -Require dual sign‑off by the Executive Director and Director of Administration/Finance. -Adopt a drawdown timing policy to ensure funds are requisitioned only when invoices are ready for payment. -Maintain a drawdown log and conduct quarterly compliance reviews. Responsible Parties: -Executive Director – oversight and approval. -Director of Administration/Finance – verification and processing. Timeline: -30 days: Checklist and dual sign‑off implemented. -60 days: Staff training completed. -Ongoing: Quarterly reviews. Questioned Costs: None. Management Views: Management agrees.

View Audit 384909

Finding 1171891 (2025-002)

Material Weakness 2025

Housing Authority of the City of College Park

GA

HUD Housing Programs

Finding 2025-002: Housing Choice Voucher Program – Utility Allowance Reference to Audit Report: Auditors found that utility allowances on HUD Form 50058 were not consistently calculated in accordance with Section 242 of the 2014 Appropriations Act. Cause: Software errors and inconsistent application...

Finding 2025-002: Housing Choice Voucher Program – Utility Allowance Reference to Audit Report: Auditors found that utility allowances on HUD Form 50058 were not consistently calculated in accordance with Section 242 of the 2014 Appropriations Act. Cause: Software errors and inconsistent application of procedures. Effect: Tenant payments and Housing Assistance Payments (HAP) were incorrectly calculated. Corrective Action Plan: -Work with software vendor to correct calculation errors. -Conduct a review of tenant files and make adjustments where necessary. -Update internal procedures to require verification of utility allowance at annual reexaminations. -Provide refresher training to program staff. -Perform quarterly spot checks of HUD Form 50058 entries. Responsible Parties: -Executive Director – oversight and compliance. -Program Manager – staff training, file review, and monitoring. Timeline: -30 days: Correct software issue and begin file review. -60 days: Complete file review and training. -Ongoing: Quarterly monitoring. Questioned Costs: None. Management Views: Management agrees. Conclusion The College Park Authority acknowledges both findings and has established corrective action plans with clear responsibilities, timelines, and monitoring procedures to ensure compliance with HUD regulations and prevent recurrence.

View Audit 384909

Finding 1171885 (2025-001)

Material Weakness 2025

Hope Network and Affiliates

MI

Allowable Costs / Cost Principles Cash Management HUD Housing Programs § 200.328 § 200.329

Hope Network acknowledges receipt of the Schedule of Findings and Questioned Costs included in the Single Audit Report dated January 21, 2026, identifying Finding #2025-001: Major Federal Award Finding- Reporting. Hope Network agrees with this finding and the recommended actions to be taken. Correct...

Hope Network acknowledges receipt of the Schedule of Findings and Questioned Costs included in the Single Audit Report dated January 21, 2026, identifying Finding #2025-001: Major Federal Award Finding- Reporting. Hope Network agrees with this finding and the recommended actions to be taken. Corrective Action Plan: Specific Corrective Action: Completion Date File all overdue semiannual performance reports. Completed Submit overdue required written request due upon final funds draw and project completion. Completed Finance department will review all grant agreements to ensure all required reporting, not just financial reports, are tracked and filed in timely within the terms of the grant agreement. 03/31/2026 Finance in conjunction with Hope Network Foundation will review existing grant procedures to develop a uniform process to be utilized across all Hope Network Affiliates. 06/30/2026 We are committed to resolving this issue.

View Audit 384872

Finding 1171710 (2025-002)

Material Weakness 2025

Vista Prairie at Garnette Gardens

MN

Special Tests & Provisions Procurement, Suspension & Debarment Cash Management

A transfer back of $23,000 for the excess surplus cash was made on 8/27/25. It was our first time taking out surplus cash and now have a better process in place to correct this going forward.

View Audit 384739

Finding 1171472 (2025-009)

Material Weakness 2025

City of Baltimore, Maryland

MD

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal contro...

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal controls over federal reporting to ensure accuracy, completeness, and compliance with HUD and Uniform Guidance requirements. Specifically, MOHS will implement a documented reconciliation process requiring all HOPWA expenditures reported in the Federal Financial Report (FFR) to be reconciled to the general ledger prior to regular submission, with supervisory review and approval documented. MOHS will establish a formal reporting calendar and standardized checklist to ensure timely preparation, review, and submission of all required HUD reports, including the FFR, Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting (FSRS), and the Consolidated Annual Performance and Evaluation Report (CAPER). • Written procedures will be developed to clearly define staff roles and responsibilities for federal reporting and FFATA compliance, including identification of reportable first-tier subawards and documentation of FSRS submissions. MOHS will also provide targeted training to program and fiscal staff responsible for federal reporting and will conduct periodic internal monitoring to verify compliance with 2 CFR §200.303 and 2 CFR Part 170. MOHS will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. • Per the GMO’s guidance, MOHS will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: June 30, 2026

View Audit 384683

Finding 1171413 (2025-008)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking HUD Housing Programs Reporting § 200.303

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, t...

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, the Consolidated Planning Division has been conducting a widespread effort to ensure programmatic compliance with all City and Federal requirements. To date, it has prioritized: • Reducing the grant’s at-risk financial exposure from approximately $28M in FY23 to $1.03M in FY25. • Implemented moving all NPO operating contracts to the same Period of Performance (July 1 – June 30 of the grant year) to ensure timely expenditure of funds and reduce compliance burden on staff. • Implemented the use of a form agreement approval process for the Board of Estimates (BOE) which reduced the lag time for contract execution and subsequent reimbursement from over 12 months, to approximately 2 months once the executed grant agreement has been received from HUD and approved by the BOE. • Standardized required subrecipient activity reporting and requests for reimbursement in Neighborly (the City’s reporting system of record for the CDBG grant program) to a quarterly basis. • Required all supporting documentation be submitted and reviewed quarterly to eliminate the possibility of overpayment or reimbursement for ineligible activities. • Hired a Director of CDBG finance to improve fiduciary and compliance oversight of federal funds. • Ensured the HUD-required Cash-on-Hand report is entered into a new screen in HUD’s system of record - Integrated Disbursement and Information System (IDIS) - (reporting that was previously collected through Federal Financial Report (FFR)/Standard Form 425 (SF-425) on a timely basis. Corrective Action Plan: • A new Director of CDBG Finance will be hired before the end of FY26. • The new Director of CDBG Finance will be provided training to complete the Cash on Hand Report and will cross-train additional staff on the completion of this report to ensure redundancy. • Supporting documents will be kept on the divisional shared drive in a clearly named subfolder. Contact Person: Mary Correia, Deputy Commissioner David Fielder, Assistant Commissioner Completion Date: June 30, 2026

View Audit 384683

Finding 1171387 (2025-001)

Material Weakness 2025

The Arc of Cape May County, INC and Affiliate

NJ

HUD Housing Programs

CFO concurs with the finding and agrees with the auditors' recommendation. We are working on implementing policies and procedures to ensure compliance requirements are being met in a timely manner. Management made a deposit of $3,168 on September 29, 2025. No further action is required.

View Audit 384668

Finding 1171375 (2025-001)

Material Weakness 2025

Ehdoc Teamsters Residences, Inc.

FL

HUD Housing Programs

Oversight Agency for Audit, EHDOC Teamsters Residences, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 ...

Oversight Agency for Audit, EHDOC Teamsters Residences, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. 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, 2024 through June 30, 2025 The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENT AUDITS FINDING No. 2025-001: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure that HUD required tenant eligibility procedures are adhered to, and that all documentation is retained in the tenant files. Action Taken: Staff training has been provided with additional HUD training inclusive of recertification deadlines and background check documentation. Tenant file maintenance is stressed and included in monthly reporting procedures. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835- 9200. Sincerely yours, Irene Phillips CFO

View Audit 384665

Finding 1171339 (2025-001)

Material Weakness 2025

Senior Citizens Housing Dev CORP of Chicago Dba Senate Apartments

FL

HUD Housing Programs Reporting

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Chicago respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Cor...

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Chicago respectfully submits the following corrective action plan for the year ended June 30, 2025. 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, 2024 through June 30, 2025 The finding from the June 30, 2025 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. 2025-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Action Taken: We will ensure that RR is fully funded on a monthly basis. New procedures have been implemented to review the deposits each month to ensure proper amounts. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

View Audit 384633

Finding 1171041 (2025-001)

Material Weakness 2025

Louisville Metro Housing Authority

KY

HUD Housing Programs Subrecipient Monitoring Cash Management

Finding Reference: 2025-001 Description of Finding: HUD regulations require certifications to be completed and entered timely to ensure accurate calculation of Housing Assistance Payments (HAP), Total Tenant Payment (TTP) and utility reimbursements. Per 24 CFR section 982.516, the Authority must ree...

Finding Reference: 2025-001 Description of Finding: HUD regulations require certifications to be completed and entered timely to ensure accurate calculation of Housing Assistance Payments (HAP), Total Tenant Payment (TTP) and utility reimbursements. Per 24 CFR section 982.516, the Authority must reexamine family income and composition at least once every two years and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification. Of the 60 Moving to Work files tested, the following items were noted: • 40 instances of certifications not completed timely • 6 instances where the file did not contain income support • 3 instances where housing quality standards inspections were not completed within the last 2 years • 1 instance in which a rent comparison was not completed for a new move in Statement of Concurrence or Nonconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2025-001. Corrective Action: LMHA continues to work through issues around the proper and timely processing of program certifications to support accurate Housing Assistance Payments, Total Tenant Payments and utility reimbursements. Currently, recertifications are processed on a biennial basis schedule, through a three-tiered system outlined in our updated MTW plan. This will address timeliness of recertification while also ensuring compliance and review of supporting documentation. Please note the following rules tied to LMHA’s three-tiered recertification system: 1) When the family is zero income, they will go to an annual recertification. 2) When family is working, (enrolling in KTAP (Kentucky Transitional Assistance Program), receiving Child Support, and other similar sources of income) they will go to a biennial recertification. 3) When a family has fixed income, (receiving Social Security, Supplemental Security Income, and/or Pension payments), they will go to a triennial recertification. The HCV Team is also working with Yardi (ERP system) to maximize the reporting and monitoring of the recertification schedule. The manager initiates the tracking for needed processing and possible termination of participants. With the three-tiered system, staff will be able to review all tenant information closely during recertifications to ensure proper housing assistance payments. Additionally, to improve sufficient controls and internal monitoring, the HCV Team is partnering with the Compliance Team to review tenant files for errors and improper supporting documentation.

View Audit 384423

Finding 1171038 (2025-002)

Material Weakness 2025

Louisville Metro Housing Authority

KY

HUD Housing Programs

Finding Reference: 2025-002 Description of Finding: HUD regulations require certifications to be completed and entered timely to ensure accurate calculation of Housing Assistance Payments (HAP), Total Tenant Payment (TTP) and utility reimbursements. Per 24 CFR section 982.516, the Authority must ree...

Finding Reference: 2025-002 Description of Finding: HUD regulations require certifications to be completed and entered timely to ensure accurate calculation of Housing Assistance Payments (HAP), Total Tenant Payment (TTP) and utility reimbursements. Per 24 CFR section 982.516, the Authority must reexamine family income and composition at least once every two years and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification. Of the 40 Housing Choice Voucher tenant files tested, the following items were noted: • 32 instances of certifications not completed timely • 3 instances where the file did not contain income support or the support in the file did not agree to the amount used on the certification (the file was later updated with the correct income for one of these tenants) • 7 instances where housing quality standards inspections were not completed within the last 2 years • 1 instances where a rent comparison was completed, the rent requested by the landlord was determined to not be reasonable, but the rent was still used in the payment calculation Statement of Concurrence or Nonconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2025-001. Corrective Action: LMHA continues to work through issues around the proper and timely processing of program certifications to support accurate Housing Assistance Payments, Total Tenant Payments and utility reimbursements. Currently, recertifications are processed on a biennial basis schedule, through a three-tiered system outlined in our updated MTW plan. This will address timeliness of recertification while also ensuring compliance and review of supporting documentation. Please note the following rules tied to LMHA’s three-tiered recertification system: 1) When the family is zero income, they will go to an annual recertification. 2) When family is working, (enrolling in KTAP (Kentucky Transitional Assistance Program), receiving Child Support, and other similar sources of income) they will go to a biennial recertification. 3) When a family has fixed income, (receiving Social Security, Supplemental Security Income, and/or Pension payments), they will go to a triennial recertification. The HCV Team is also working with Yardi (ERP system) to maximize the reporting and monitoring of the recertification schedule. The manager initiates the tracking for needed processing and possible termination of participants. With the three-tiered system, staff will be able to review all tenant information closely during recertifications to ensure proper housing assistance payments. Additionally, to improve sufficient controls and internal monitoring, the HCV Team is partnering with the Compliance Team to review tenant files for errors and improper supporting documentation. Name of Contact Person: Sarah Galloway, Chief Policy Officer, 502-569-3422, galloway@lmha1.org and Camille Robinson, Deputy Executive Director of Leased Housing, 502-569-6245, crobinson@lmha1.org

View Audit 384423

Finding 1171035 (2025-001)

Material Weakness 2025

School District of Belleville

WI

Internal Control / Segregation of Duties HUD Housing Programs

2025-001: Segregation of Duties Condition: Management is responsible for the design, implementation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. The following duties lack adequate segregation of duties: • The...

2025-001: Segregation of Duties Condition: Management is responsible for the design, implementation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. The following duties lack adequate segregation of duties: • The same individual that reconciles the bank accounts also approves and codes invoices, creates deposits and processes and initiates debt payments. • This individual is also the primary staff who compiles and reviews grant claims. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the nomrnl course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether sucherror is intentional or unintentional. Recommendation: We recommend that the Board of Education and the Superintendent continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office duties. The Board of Education approves monthly accounts payable checks and the Superintendent reviews payroll timesheets prior to processing payroll. The Superintendent also approves journal entries before they are posted to the accounting ledger. The Board of Education and Superintendent will continue to monitor transactions of the District. Contact Person: Jessie Backes Anticipated Completion: Ongoing

View Audit 384411

Finding 1170981 (2025-001)

Material Weakness 2025

Watkins Glen Central School District

NY

Cash Management Eligibility HUD Housing Programs

Corrective Action Plan: The School District is committed and will be diligent in preparing meals with high quality products. Regular cooked meals and expanded menu choices will be prepared which will result in an increase in expenses. There has been unpredictability with the increase of certain good...

Corrective Action Plan: The School District is committed and will be diligent in preparing meals with high quality products. Regular cooked meals and expanded menu choices will be prepared which will result in an increase in expenses. There has been unpredictability with the increase of certain goods, and we expect this to continue into the 2025-2026 fiscal year as well. The School District also participates in the Community Eligibility Provision (CEP) which provides free breakfast and lunch to every student within the School District. Salaries for School Lunch employees have also been increasing year after year due to the increase of minimum wage in New York State. The minimum wage is expected to increase to $16.00 per hour and entry level wages have increased per contract. The School District does have a practice of transferring BOCES aid gained from the cost of the BOCES management contract to the School Lunch Fund; the aid will not be transferred in upcoming years. The School District has devised a NYSED approved plan to expend the excess funds in the School Lunch Fund through appropriating a substantial amount of fund balance to be planned for and used for the cafeteria and kitchen within the next planned capital project. We are currently in the planning phase of our next capital project with a vote anticipated during the 2025-2026 fiscal year. If needed, we will examine other avenues to ensure we do not exceed the allowable limit of cash at year end.

View Audit 384367

Finding 1170971 (2025-001)

Material Weakness 2025

Talbot Bernard Senior Housing Corporation

MA

HUD Housing Programs

Responsible Official Jeffrey Caputi Plan Detail A calculation was made of the underfunding through December 2025, which amounted to 130,132. The funds were transferred from the operating account to the replacement reserve account making the reserve fully funded as of December 19, 2025. Anticipated C...

Responsible Official Jeffrey Caputi Plan Detail A calculation was made of the underfunding through December 2025, which amounted to 130,132. The funds were transferred from the operating account to the replacement reserve account making the reserve fully funded as of December 19, 2025. Anticipated Completion Date: December 19, 2025.

View Audit 384349

Finding 1170859 (2025-001)

Material Weakness 2025

University of Wyoming

WY

Student Financial Aid Subrecipient Monitoring HUD Housing Programs

Views of Responsible Officials and Planned Corrective Actions - The University’s Office of Student Financial Services agrees with the recommendation and will ensure that Return of Title IV (R2T4) calculations and applicable returns of funds for all students who officially or unofficially withdraw ar...

Views of Responsible Officials and Planned Corrective Actions - The University’s Office of Student Financial Services agrees with the recommendation and will ensure that Return of Title IV (R2T4) calculations and applicable returns of funds for all students who officially or unofficially withdraw are completed within required regulatory time frames. To strengthen internal controls related to R2T4 processing, the Office of Student Financial Services under the direction of the Director of Student Financial Services has taken and will continue the following actions: • Reinforce and update R2T4 procedures to clearly document regulatory timelines, roles, and responsibilities, and to include defined ongoing monitoring practices. These updated procedures incorporate periodic review of R2T4 activity to ensure continued compliance. • Enhance the existing internal tracking mechanism to support timely completion of R2T4 calculations and fund returns. This enhancement includes the ability to generate reports that identify upcoming deadlines, completed actions, and any items requiring follow-up. • Provide refresher training to staff within the Office of Student Financial Services and partner offices involved in R2T4 processing, with emphasis on compliance requirements, timelines, documentation standards, and shared accountability across offices. • Incorporate a secondary review process as part of the existing R2T4 procedure. A designated secondary reviewer within the Office of Student Financial Services will confirm the accuracy and timeliness of each R2T4 calculation and associated fund return, with completion of the review documented within the tracking system. These corrective actions will be implemented upon review and approval and will be effective beginning Spring 2026.

View Audit 384150

Finding 1170833 (2025-001)

Material Weakness 2025

Laceleaf Corporation

OR

Eligibility HUD Housing Programs Reporting

Management will monitor tenant recertifications to ensure that they are being completed in a timely manner. The following measures will be implemented: • Centralized tracking by the Housing Manager on a monthly basis to monitor the recertification timeline for each unit. This will include tracking t...

Management will monitor tenant recertifications to ensure that they are being completed in a timely manner. The following measures will be implemented: • Centralized tracking by the Housing Manager on a monthly basis to monitor the recertification timeline for each unit. This will include tracking the 120, 90, 60, and 30 day reminders to be sent to tenants in advance of the recertification effective dates. • Automated reminders will be provided on a monthly basis by the third party vendor that processes HAP billings to the Housing Manager and site managers, in order to ensure that they are aware of any recertification deadlines. • Additional training will be provided for all staff members involved in the recertification process.

View Audit 384123

Corrective Action Plans

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