Corrective Action Plans

Finding 50594 (2022-001)

Significant Deficiency 2022

Housing Authority of the County of Lawrence

PA

Questioned Costs Cash Management HUD Housing Programs

Program: Low Rent Public Housing AL Number: 14.850 Finding Number: 2022-001 Audit Finding (Copied & Pasted Directly from Auditor?s Report): Condition: During our audit, the Authority transferred PHA cash and charged asset management fees in AMP 2 and AMP 3 in excess of the excess cash amount from th...

Program: Low Rent Public Housing AL Number: 14.850 Finding Number: 2022-001 Audit Finding (Copied & Pasted Directly from Auditor?s Report): Condition: During our audit, the Authority transferred PHA cash and charged asset management fees in AMP 2 and AMP 3 in excess of the excess cash amount from the 2021 audited numbers. Context: AMP 4 and AMP 10 have issues cash flowing and rely on the other AMPS to transfer excess cash every year. In 2021, the other AMPs had less excess cash, so were unable to subsidize AMP 4 and AMP 10 like normal. The Authority did not detect the cash flow issue until after the fiscal year ended. Resulting in noncompliance with the program's rules Cause: Controls were not followed to ensure fungibility rules between each project were followed Criteria: After subsidy (operating) is calculated at a project level, operating subsidy can be transferred as the PHA determines during the PHA's fiscal year to another ACC project(s) if a project's financial information, as described more fully in 240 CFR ? 990.280, produces excess cash flow, and only in the amount up to those excess cash flows. 240 CFR ? 990.205. Corrective Action to Be Taken: Executive Director, Holly Girdwood, is responsible to train/teach the Comptroller, Tara Sheffler, to perform monthly reconciliations to ensure fungibility is properly maintained. This should be completed prior to year-end December 31, 2023. In response to the context, it was our understanding that we could charge asset management fees to all AMPS due to COVID guidelines. Contact Responsible for Corrective Action: Tara Sheffler Comptroller PO Box 988 481 Neshannock Avenue New Castle, PA 16103 724-656-5100 ext. 5100 tsheffler@lawrencecountyha.com

View Audit 43028 Questioned Costs: $1

Finding 50593 (2022-003)

Significant Deficiency 2022

Housing Authority of the City of Nogales

AZ

HUD Housing Programs Internal Control / Segregation of Duties Allowable Costs / Cost Principles

2022-003 Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend the Authority design and implement controls to ensure the required general depository agreements are executed and submitted to HUD utilizing the HUD-51999 form. Explanation of disagreement with audit f...

2022-003 Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend the Authority design and implement controls to ensure the required general depository agreements are executed and submitted to HUD utilizing the HUD-51999 form. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will file the declaration of trust for each property using the acceptable form under HUD guidance. Name(s) of the contact person(s) responsible for corrective action: Terry Ybarra Planned completion date for corrective action plan: June 30, 2023.

View Audit 43026

Finding 50592 (2022-002)

Significant Deficiency 2022

Housing Authority of the City of Nogales

AZ

HUD Housing Programs Allowable Costs / Cost Principles Significant Deficiency

2022-002 Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend the Authority design and implement controls to declaration of trust were prepared and recorded against all public housing properties owned by the Authority. Explanation of disagreement with audit findin...

2022-002 Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend the Authority design and implement controls to declaration of trust were prepared and recorded against all public housing properties owned by the Authority. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will file the declaration of trust for each property using the acceptable form under HUD guidance. Name(s) of the contact person(s) responsible for corrective action: Terry Ybarra Planned completion date for corrective action plan: June 30, 2023.

View Audit 43026

Finding 50559 (2022-001)

Material Weakness 2022

Ohana Homes, Inc.

MD

Questioned Costs HUD Housing Programs Cash Management

Recommendation: Training of staff should be performed to bring the staff up to date with the implementation of all residual receipts compliance requirements. Action Taken: The Organization will request approval from HUD to pay back the excess residual receipt balance.

View Audit 53857 Questioned Costs: $1

Finding 50550 (2022-003)

Material Weakness 2022

Chelsea Jewish Nursing Home, Inc.

MA

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022 ?003 ? Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization operates under a common paymaster agreement with Chelsea Jewish Lifecare, Inc. (CJL), the sole corporate member of the Organization. As such, the Organization transfers funding to cover...

2022 ?003 ? Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization operates under a common paymaster agreement with Chelsea Jewish Lifecare, Inc. (CJL), the sole corporate member of the Organization. As such, the Organization transfers funding to cover its share of payroll and related costs on a weekly basis to CJL. Approximately $192,000 of the advance noted was to cover payroll and related costs for the pay period ending December 31, 2022 which was paid the first week in January 2023. The remaining balance resulted from the weekly transfer amount not being adjusted following a number of terminations at the beginning of November 2022. Amounts transferred in excess were fully utilized to cover payroll and related costs in January 2023. Management has reviewed and revised procedures to ensure excess funds are not transferred in the future. Proposed Completion Date: January 31, 2023

View Audit 53056

Finding 50549 (2022-002)

Material Weakness 2022

Chelsea Jewish Nursing Home, Inc.

MA

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022 ?002 ? Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization was fortunate to have sufficient cash on hand in order to continue to provide the highestquality of care to its residents during the COVID-19 pandemic, primarily as a result of federal ...

2022 ?002 ? Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization was fortunate to have sufficient cash on hand in order to continue to provide the highestquality of care to its residents during the COVID-19 pandemic, primarily as a result of federal and state stimulus funds, which were restricted in usage, received during 2020 and 2021. The Organization made it a priority to ensure that its staff continued to be compensated throughout the pandemic. Accordingly, the Organization kept cash on hand in order to meet the needs of the residents cared for daily and the dedicated staff who serve them. The Organization was not expecting a surplus cash situation at December 31, 2020 or June 30, 2021. Had the Organization not received stimulus funds through programs such as the Provider Relief Fund and Paycheck Protection Program, the Organization would not have had surplus cash at both December 31, 2020 and June 30, 2021. The required deposit due to the residual receipt account for the year ended December 31, 2020 was made on May 31, 2022. The Organization is currently in the process of discussing repayment terms for the deposit due for the period June 30, 2021 with its asset manager. Proposed Completion Date: No later than December 31, 2023.

View Audit 53056

Finding 50548 (2022-001)

Material Weakness 2022

Chelsea Jewish Nursing Home, Inc.

MA

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022 ?001 ? Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization is a community based non-profit and considers supporting local businesses, including a bank, a worthwhile business practice. The Organization is currently in the process of reviewing it...

2022 ?001 ? Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization is a community based non-profit and considers supporting local businesses, including a bank, a worthwhile business practice. The Organization is currently in the process of reviewing its banking relationships, and looking at other scenarios which would involve transferring funds to another institution. Proposed Completion Date: No later than December 31, 2023

View Audit 53056

Finding 50539 (2022-001)

Significant Deficiency 2022

Iowa Finance Authority

IA

Special Tests & Provisions HUD Housing Programs Significant Deficiency

Finding 2022-001 Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Emergency Solutions Grant Program CFDA #14.231 Finding Summary: As part of the auditors testing for special tests and provisions compliance requirements, they noted that the board approval for the ob...

Finding 2022-001 Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Emergency Solutions Grant Program CFDA #14.231 Finding Summary: As part of the auditors testing for special tests and provisions compliance requirements, they noted that the board approval for the obligations was outside the 60 day requirement. The board approval was at 124 days. Responsible Individuals: Brian Sullivan, Chief Programs Officer Corrective Action Plan: After receiving additional Emergency Solutions Grant funding under the CARES act, our program team decided to obligate the ESG CARES Act funding to our partners first due to the immediacy of the need. In doing so, the regular ESG funding was sent after the 60-day requirement. Going forward, we will ensure all grant awards are obligated in accordance with the timeline set forth in the compliance requirements. Anticipated Completion Date: June 30, 2022

View Audit 51353

Finding 50527 (2022-001)

None 2022

Snyder Senior Citizens, Inc.

TX

HUD Housing Programs

USDA RURAL DEVELOPMENT FINDING NO.2022-001: REPLACEMENT RESERVES Recommendation: Project owner needs to deposit $1,963.08 into to the replacement reserves account as soon as possible. Action Taken: Management made the required deposit of $1,963.08 to the replacement reserves account on March...

USDA RURAL DEVELOPMENT FINDING NO.2022-001: REPLACEMENT RESERVES Recommendation: Project owner needs to deposit $1,963.08 into to the replacement reserves account as soon as possible. Action Taken: Management made the required deposit of $1,963.08 to the replacement reserves account on March 16, 2023.

View Audit 44757

Finding 50492 (2022-001)

Significant Deficiency 2022

Bandera Senior Housing Corporation

CA

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Name of auditee: Bandera Senior Housing Corp. HUD auditee identification number: 122-EE112 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended September 30, 2022 CAP prepared by Name: Mary Grace Crisostomo Position: Asset Manager Telephone number: (925) 924-7102...

Name of auditee: Bandera Senior Housing Corp. HUD auditee identification number: 122-EE112 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended September 30, 2022 CAP prepared by Name: Mary Grace Crisostomo Position: Asset Manager Telephone number: (925) 924-7102 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2022-001: Comments on the Finding and Each Recommendation During the year ended September 30, 2022, management made duplicate withdrawals from the reserve for replacements account totaling $14,720. The reserve for replacements account was not reimbursed for these duplicate withdrawals. Management should transfer funds of $14,720 from the operating cash account to the reserve for replacements account. Action(s) taken or planned on the finding Management concurs with the finding and the auditor's recommendation. Management intends to transfer $14,720 from the operating cash account to the reserve for replacements account.

View Audit 52860 Questioned Costs: $1

Finding 50472 (2022-003)

Significant Deficiency 2022

Council Towers IV Housing Development Fund Corporation

NY

HUD Housing Programs Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action 1-The residence director, building office staff, an...

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Action 1-The residence director, building office staff, and accounting staff will be informed of the HUD requirements regarding the timely refund of security deposits. Action 2-The residence director and building office staff will immediately notify the accounting staff of all move outs by email so that a security deposit refund check can be promptly issued. Action 3-The asset management staff will review the accounts payable aging on a weekly basis to ensure that all security deposit refund checks have been issued.

View Audit 41871

Finding 50471 (2022-002)

Significant Deficiency 2022

Council Towers IV Housing Development Fund Corporation

NY

Special Tests & Provisions HUD Housing Programs

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if effectively implemented, should prevent this condition from arising again. Action 1 - Management made all the required monthly dep...

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if effectively implemented, should prevent this condition from arising again. Action 1 - Management made all the required monthly deposits to the replacement reserve through August 31st, 2023. Action 2 - In the event of delayed subsidy payments, management will make the monthly deposits to the replacement reserve as soon as the delayed subsidy payments are received. Action 3 - All staff members will be made aware of the importance of maintaining a fully funded replacement reserve account.

View Audit 41871

Finding 50470 (2022-001)

Significant Deficiency 2022

Council Towers IV Housing Development Fund Corporation

NY

Questioned Costs Special Tests & Provisions HUD Housing Programs

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor?s recommendations. The recommendation, if effectively implemented, should prevent this condition from arising again. Action 1- The issue was communicated to the management ...

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor?s recommendations. The recommendation, if effectively implemented, should prevent this condition from arising again. Action 1- The issue was communicated to the management company and the property was reimbursed for $2,450 on September 26th, 2023. Action 2-To prevent a future overpayment of the management fee, a procedure will be implemented whereby the management fee will be recalculated using the rate included in the current management certification. Any differences will be investigated and resolved before the management fee is paid to the management company.

View Audit 41871 Questioned Costs: $1

Finding 50469 (2022-002)

Significant Deficiency 2022

Home Forward

OR

HUD Housing Programs Eligibility Significant Deficiency

2022-02 Moving to Work Demonstration Program ? Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit findin...

2022-02 Moving to Work Demonstration Program ? Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The files in question were moved from one office to another using Home Forward?s contracted courier system. Moving forward, any file that must be transported from one office to another will require the signature of the individual who is receiving the file as well as the individual relinquishing the file. The department will develop a new policy and train staff on the new procedure. In addition, the department will be conducting an audit of each site to assure that all files are present and accounted for. Name(s) of the contact person(s) responsible for corrective action: Elise Anderson, Celeste King Planned completion date for corrective action plan: 12/31/2023.

View Audit 45210

Finding 50468 (2022-001)

Significant Deficiency 2022

Home Forward

OR

Special Tests & Provisions HUD Housing Programs Significant Deficiency § 200.326

U.S. Department of Housing and Urban Development 2022-01 Moving to Work Demonstration Program ? Assistance Listing No. 14.881 Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requireme...

U.S. Department of Housing and Urban Development 2022-01 Moving to Work Demonstration Program ? Assistance Listing No. 14.881 Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Home Forward?s Procurement group will add an additional layer of contract review to the department?s quarterly review process. Procurement will begin review of the activity input into the agency?s certified payroll reporting system to compare to the payments made to contractors withing the period. Any payment activity will be cross referenced with the certified payroll to ensure receipt of Davis Bacon reporting has been submitted. Procurement will work with the Property Management group to resolve any items that require follow up with the contractors as a result of the review. Name(s) of the contact person(s) responsible for corrective action: Elise Anderson Planned completion date for corrective action plan: 12/31/2023.

View Audit 45210

Finding 50462 (2022-005)

Material Weakness 2022

City of West Allis

WI

HUD Housing Programs Material Weakness Period of Performance

Housing Choice Voucher Program ? Assistance Listing No. 14.871 We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit f...

Housing Choice Voucher Program ? Assistance Listing No. 14.871 We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHA staff will review its current procedures for completing rent reasonableness requirements. As noted above, they will pursue options available under their contract with McCright, data feeds that could work within their existing software, and any other options in use at peer agencies to determine the best specific path forward to ensuring compliance with rent reasonableness requirements. PHA Supervisory Staff have also requested more detailed information on the audit results to help them further analyze the specific rent reasonableness cases where documentation and performance errors were made which led to this finding. This will help supervisory staff conduct a more thorough review and consider additional procedural changes. Also, as noted above the Finance Department suggests the PHA engage its software vendor or a peer agency to review functionality in the software to determine whether additional features could be employed in the software to prevent a HAP payment on a unit where rent reasonableness has not been completed yet. Name(s) of the contact person(s) responsible for corrective action: Steve Schaer Planned completion date for corrective action plan: 3/31/2024

View Audit 45206

Finding 50461 (2022-004)

Significant Deficiency 2022

City of West Allis

WI

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the annual HQS inspection. Explanation of dis...

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the annual HQS inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As mentioned previously, the PHA is currently finalizing a contract with a 3rd party contractor to perform the required HQS inspections. They anticipate that outsourcing the inspection work will lessen the workload on PHA staff to allow for program staff to focus their efforts on improving overall program compliance, including HQS inspection procedures. As the contract arrangement is rolled out staff will review procedures between inspectors and PHA staff to ensure proper communication and clear procedures are in place to ensure all required inspections are completed. The Housing Coordinator or other PHA staff should review summary reports of renewals processed each month and compare them to inspections processed each month to ensure all necessary inspections are completed. PHA Supervisory Staff have also requested more detailed information on the audit results to help them further analyze the specific cases that did not have a documented or completed annual inspection. This will help supervisory staff conduct a more thorough review and consider additional procedural changes. Additionally, the Finance Department suggests the PHA engage its software vendor or a peer agency to review functionality in the software to determine whether additional features could be employed in the software to prevent a HAP payment on a unit with an incomplete inspection, for example. Name(s) of the contact person(s) responsible for corrective action: Steve Schaer Planned completion date for corrective action plan: 3/31/2024

View Audit 45206

Finding 50460 (2022-003)

Significant Deficiency 2022

City of West Allis

WI

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreem...

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding Action taken in response to finding: PHA supervisory staff will review the detailed income verification procedures that are in place, including documentation procedures. Supervisory staff have also requested more detailed information on the audit results to help them review the specific instances that led to this finding so specific procedural changes can be considered and implemented. Staff understand that income verification is essential to ensuring that only eligible participants are provided HAP benefits. Results of the PHA?s internal procedural review will be submitted to the Finance Department for additional review to ensure proper procedural controls are in place. Name(s) of the contact person(s) responsible for corrective action: Steve Schaer Planned completion date for corrective action plan: 3/31/2024

View Audit 45206

Finding 50459 (2022-002)

Material Weakness 2022

City of West Allis

WI

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreem...

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHA staff noted that the current process of finding comparable data for rent reasonableness comparisons is challenging and obtaining accurate, up-todate data has been a struggle. As part of the RFP process for inspection services, staff noted that McCright offers a process that can assist in accessing data and making the rent reasonableness comparisons PHA staff will also pursue options available under its contract with McCright, data feeds that could work within its existing software, and any other options in use at peer agencies to determine the best specific path forward to ensuring compliance with rent reasonableness requirements. PHA Supervisory Staff have also requested more detailed information on the audit results to help them further analyze the specific rent reasonableness cases where documentation and performance errors were made which led to this finding. This will help supervisory staff conduct a more thorough review and consider additional procedural changes. Name(s) of the contact person(s) responsible for corrective action: Steve Schaer Planned completion date for corrective action plan: 3/31/2024

View Audit 45206

Finding 50458 (2022-001)

Material Weakness 2022

City of West Allis

WI

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of HQS enforcement. Explanation of disagreement ...

Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend that the City review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of HQS enforcement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PHA is currently finalizing a contract with a 3rd party contractor to perform the required HQS inspections. They anticipate that outsourcing the inspection work will lessen the workload on PHA staff to allow program staff to focus their efforts on improving overall program compliance, including HQS enforcement procedures. As the contract arrangement is rolled out staff will review procedures between inspectors and PHA staff to ensure proper communication and clear procedures are in place as they relate to enforcement actions. PHA staff also will implement a new standard procedure in which the Housing Coordinator will check a list of units with failed or incomplete inspection records against the payment batch report prior to sending the batch to Finance to issue the HAP payments. PHA Supervisory Staff have also requested more detailed information on the audit results to help them further analyze the 3 specific cases where customers were issued HAP payments despite a failed inspection. This will help supervisory staff conduct a more thorough review and consider additional procedural changes. Additionally, the Finance Department suggests the PHA engage its software vendor or a peer agency to review functionality in the software to determine whether additional features could be employed in the software to prevent a HAP payment on a unit with a failed inspection, for example. Name(s) of the contact person(s) responsible for corrective action: Steve Schaer Planned completion date for corrective action plan: 3/31/2024

View Audit 45206

Finding 50421 (2022-003)

Material Weakness 2022

Housing Authority of the City and County of San Francisco

CA

Questioned Costs HUD Housing Programs Material Weakness

Reference Number: 2022-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspec...

Reference Number: 2022-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections) Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Authority?s Response & Actions Taken The Authority has made considerable progress in addressing the backlog of annual inspections. Since outsourcing the programmatic functions of the HCV program to a third-party contractor. The Authority acknowledges that more progress in this area is required and continues to work diligently with the third-party HCV contractor to ensure this occurs. The Authority will continue to reinforce its current oversight process to ensure HQS inspections are performed in accordance with HUD requirements. The Authority adopted a series of HUD waivers following the COVID-19 pandemic, one of which HQS-5, under Notice PIH 2021-14, allowing the Authority to waive the completion of HQS Inspections through December 31, 2021. The Authority resumed the completion of HQS Inspections and was required by HUD to complete all delayed inspections by December 31, 2022. During fiscal year 2022, the Authority had inspections not completed in a timely manner, however, was not out of compliance as waivers were in place. The Authority is committed to ensuring all units under contract are beyond safe, sanitary, and decent in accordance with HQS requirements and the Authority's Administrative Plan. The Authority uses the Emphasys Elite software to check against HUD's PIH Information Center (PIC) system to identify units with outstanding Housing Quality Standards (HQS) Inspections. The Authority has scheduled HQS Inspections for the units identified to be out of compliance. Some key strategies and controls in place are as follows: ? Review the report of outstanding HQS Inspections on a weekly basis. ? Schedule outstanding HQS Inspections in order of aging date. ? Conduct HQS Inspections prior to anniversary date of previously completed inspection. ? Running a monthly report of failed inspections and comparing them with future scheduled inspections to ensure a timely scheduling of the second inspection. ? Running a monthly report to identify units with two failed inspections to ensure all have been abated correctly. ? Implement weekly monitoring to ensure all units are properly abated and lifted timely when units pass inspections and contracts are properly terminated after being in abatement for 180 days without a cure. The Authority will continue to execute these sound procedures to prevent further findings related to inspections. The Authority has implemented a robust internal audit program starting fiscal year 2021- 22 and will continue to select annually a statistically significant random sample of actions completed by the HCV contractor to ensure that all actions are in compliance and files contain all required documentation. Although the HCV program subscribes to a quality control process, the Authority's internal audit program provides a method to reasonably understand the condition of the program as the Authority fully understands its responsibility to ensure the program complies to all applicable laws and regulations governing HCV operations. The HCV program is a part of our continuous monitoring process. Anticipated Implementation Date September 30, 2023 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractor Kendra Crawford, Director of Housing Operations

View Audit 43529 Questioned Costs: $1

Finding 50420 (2022-004)

Significant Deficiency 2022

Housing Authority of the City and County of San Francisco

CA

Questioned Costs HUD Housing Programs Significant Deficiency

Reference Number: 2022-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation Federal Catalog Number: 14.856 Federal Grant Number: Not Applicable Category of Finding: Eligibility and Sp...

Reference Number: 2022-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation Federal Catalog Number: 14.856 Federal Grant Number: Not Applicable Category of Finding: Eligibility and Special Tests and Provisions ? Housing Quality Standards Inspections Classification of Finding: Significant Deficiency in Internal Control over Compliance Material Noncompliance Authority?s Response & Actions Taken The Authority has made significant progress in addressing the backlog of annual inspections since outsourcing the programmatic functions of the HCV program to a third-party contractor. The Authority remains committed to proactively making substantial movement toward 100% completion of unit inspections by working diligently with its HCV contractor to ensure this occurs. With that said, the Authority maintains that this finding and questioned costs do not consider the three scheduled inspections of the unit in question, between March and August 2022, that all resulted in cancellation or no-show. The auditors refused to take in consideration the evidence of the repeat scheduled inspection dates for this unit and the ?No Show? results. Notwithstanding the fact that in May 2023, the Authority completed the HQS inspection, and the unit passed. This is acceptable documentation which further evidence that the owner did meet its obligations to maintain the unit in decent, safe, and sanitary condition during the audit period. In alignment with the Authority?s HCV administrative plan, both the family and owner are to be provided reasonable notice for all inspections, at least 24 hours prior. The family must allow the Authority to inspect the unit at reasonable times with reasonable notice (24 CFR 982.51 (d)). When a family occupies the unit at the time of inspection, an adult family member must be present for the inspection. If the family misses two scheduled inspections without the Authority?s approval, the Authority will consider the family to have violated its obligation to make the unit available for inspection. This may result in termination of the family?s assistance in accordance with the termination procedures in the HCV administrative plan. If the family?s assistance is to be terminated, the Authority must notify the owner of its intent to terminate the family?s program assistance so the owner can begin eviction procedures. The Authority is obligated to continue to pay the owner until the eviction is completed. Therefore, the potential effect and questionable costs assumed by the auditor are not applicable when the HQS deficiency is due to the tenant?s failure to meet family obligations. The California?s statewide Declaration of Emergency and the City and County of San Francisco?s proclamation of Local Emergency due to COVID-19 was also still in effect during fiscal year 2021-22. The impact COVID-19 pandemic had on housing stability and mental health has been devastating, and disproportionately affected the most vulnerable populations in San Francisco. California State and the City both implemented an eviction moratorium as a mitigating strategy to ensure housing stability. The Authority also made it a priority to ensure health, safety and housing stability of its residents comprised of some of the most vulnerable populations in San Francisco. To that effect, the Authority collaborated closely with landlords and service providers to assess tenants needs and provided needed assistance throughout the COVID-19 emergency period (i.e., processing interims to assist renters experiencing financial hardship, ensuring food security, and delivering personal protective equipment). Anticipated Implementation Date September 30, 2023 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractor Kendra Crawford, Director of Housing Operations

View Audit 43529 Questioned Costs: $1

Finding 50419 (2022-002)

Material Weakness 2022

Housing Authority of the City and County of San Francisco

CA

HUD Housing Programs Eligibility Material Weakness

Reference Number: 2022-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Public and Indian Housing Federal Catalog Number: 14.850 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal C...

Reference Number: 2022-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Public and Indian Housing Federal Catalog Number: 14.850 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Authority?s Response & Actions Taken No corrective action is required for this finding because the Authority?s Sunnydale-Velasco, Potrero Annex and Terrace public housing properties, all part of HOPE SF initiative, have been transferred out of the Low Rent Public Housing Program (LRPH). In 2020, the Authority began the accelerated conversion project (HQS conversion), a major undertaking to transform existing public housing sites owned by the Authority, Sunnydale-Velasco (Sunnydale) and Potrero Hill ? including Potrero Annex and Terrace. The conversion transferred the ownership of the public housing units to SFHA Housing Corporation, a blended component unit. To comply with guidelines from the U.S. Department of Housing and Urban Development (HUD), the public housing department has reviewed and updated the tenant files for each phase of the HQS conversion to ensure completeness and accuracy and compliance of the documents with the HCV program for intake requirements. The Authority has completed the accelerated conversion and the transition of the public housing tenant files to the HCV program on September 30, 2022. The public housing units were brought up to Section 8 physical standards (Housing Quality Standards, HQS) and assigned Project-Based Vouchers (PBV) Housing Assistance Payments (HAP) contracts through the Housing Choice Voucher (HCV) program. SFHA Housing Corporation will operate the properties as Project-Based Section 8, until the time that the units will be disposed to the developers for redevelopment, pursuant to their redevelopment schedule and agreement. Anticipated Implementation Date September 30, 2022 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action Kendra Crawford, Director of Housing Operations

View Audit 43529

Finding 50302 (2022-001)

Significant Deficiency 2022

Housing Authority of the City of Monroe

LA

HUD Housing Programs Eligibility Significant Deficiency

Reference # and title: 2022-001 Public Housing Tenant Files ? Eligibility ? Rent Calculations Federal program and specific federal award identification: Asst. Listing Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Housing and Urban Development Publi...

Reference # and title: 2022-001 Public Housing Tenant Files ? Eligibility ? Rent Calculations Federal program and specific federal award identification: Asst. Listing Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Housing and Urban Development Public and Indian Housing Program 14.850 2021 and 2022 Condition: The Code of Federal regulations, the Housing Authority Admissions and Occupancy Plan and specific HUD guidelines in documenting and maintaining Public Housing tenant files. Our review of seventy-five (75) Public Housing Tenant Files revealed the following discrepancies: ? There were eight (8) instances of income miscalculations. We noted that the income miscalculations were mainly related to wage calculation or child support calculations. We extrapolated the total potential error and found it to be material to the financial statements at both the total and singular AMP level. ? There was one (1) instance of a file missing required childcare deduction verification. Corrective action planned: Monroe Housing Authority will develop more effective processes for measuring, monitoring, and reducing errors in subsidy payments due to rent calculation and tenant underreporting of income. Implementations and strategies to include: ? Resolution of income and rent issues identified in the report and communication to Tenants where applicable. ? Development and implementation of an ongoing quality control review process of income at initial certification and re-examination to mitigate wage/income calculation errors to PHA and tenants by: o Hiring (1) FTE to perform quality control review of verification of income (upfront and/or a third party), and Tenant files upon new lease and re-examinations. o Developing a Tenant File Review checklist to document the result of file reviews. ? Partner with the National Association of Housing and Redevelopment Officials (NAHRO) to train staff on Public Housing Occupancy, Eligibility, Income and Rent training to accurately calculate Tenant Rent and avoid common errors in occupancy and eligibility functions in addition to understanding updates to the HUD-50058. Person responsible for corrective action: Mr. William Smart, Executive Director Anticipated completion date: 6/30/2023

View Audit 48238

Finding 50290 (2022-003)

Significant Deficiency 2022

The Pavilion Housing Development Fund Corporation

NY

HUD Housing Programs

a. Finding 2021-001. Delinquent deposits into the replacement reserve account. Required deposit in the amount of $4,157 was not made. Finding still open. Management will transfer the funds as soon as cash flow permits.

View Audit 48232

Corrective Action Plans

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