Corrective Action Plans

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The outstanding balance currently reflected in the books represents unreconciled funds resulting from the transfer of assets and liabilities during the conversion of the Public Housing Program to the RAD Project-Based Rental Assistance (PBRA) Program. These funds were carried forward following the t...
The outstanding balance currently reflected in the books represents unreconciled funds resulting from the transfer of assets and liabilities during the conversion of the Public Housing Program to the RAD Project-Based Rental Assistance (PBRA) Program. These funds were carried forward following the transition of ownership and operations from the PHA to Athens Housing Management, LLC, as the new ownership entity. By HUD RAD guidance, including the RAD Notice Revision 4 (H-2019-09/PIH-2019-23), when a public housing project converts to PBRA under RAD, the PHA is required to transfer assets and liabilities to the new ownership entity to ensure continuity and financial integrity of the property. Specifically, Attachment 1A to the RAD Notice outlines the obligation to transfer project-specific assets and liabilities from the public housing ledger to the new entity, including cash, receivables, and project-level obligations. The amounts in question were initially anticipated to be reconciled as part of that process. However, due to the complexity of the transition and lack of adequate internal controls at the time, the residual balance has remained unreconciled for the past five fiscal years. These amounts are not expected to be repaid or resolved in FY 2025. As such, this is a one-time, non-recurring issue, and corrective action is underway. Staff will formally seek HUD’s approval and submit a resolution to the Boards of both the Housing Authority (the management entity) and Athens Housing Management LLC (the ownership entity), requesting that the outstanding balance be written off. This action will appropriately clear the books of legacy items tied to the conversion and align the accounting records of both entities. This write-off recommendation aligns with best practices in governmental accounting for long-standing inter-entity balances that are no longer collectible or relevant to current operations. Additional internal controls have since been implemented to prevent recurrence, including improved cash management oversight, inter-entity reconciliation protocols, and timely financial reporting.
Finding 2024-006 I. Procurement, Suspension and Debarment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. As background context, the previous Chief Legal Officer, at the request of the previous CEO, reviewed the original inte...
Finding 2024-006 I. Procurement, Suspension and Debarment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. As background context, the previous Chief Legal Officer, at the request of the previous CEO, reviewed the original intergovernmental agreement (IGA) and determined that the agreement had not expired and required no additional board approval or agreement. This is why each year since, Legal has provided authorization for purchase order creation and payment to Chicago Police Department (CPD). The agency is working with CPD to formalize a new IGA. Contact Person: Shelia Johnson, Deputy Chief Procurement Anticipated Completion Date: End of 4th Qtr. 2025
View Audit 366932 Questioned Costs: $1
Finding 2024-005 N. Special Tests and Provisions: N1. Wage Rate Requirements – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. A review of the process was completed, and the procedure will be updated to include language that no...
Finding 2024-005 N. Special Tests and Provisions: N1. Wage Rate Requirements – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. A review of the process was completed, and the procedure will be updated to include language that notes until all documents are received, the contract file should be notated and remain open. The checklist will be updated as well. A review of the pending invoice payments will be completed by Internal Audit of the User Groups to ensure timely close out of projects can be completed. Contact Person: Shelia Johnson, Deputy Chief Procurement Anticipated Completion Date: End of 4th Qtr. 2025
Finding 2024-004 N. Special Tests and Provisions: N4. NSPIRE/Housing Quality Standards (HQS) Inspections – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The inspections identified as findings during the audit were part of HQS Inspections compliance controls enacted ...
Finding 2024-004 N. Special Tests and Provisions: N4. NSPIRE/Housing Quality Standards (HQS) Inspections – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The inspections identified as findings during the audit were part of HQS Inspections compliance controls enacted in accordance with direction from HUD to ensure inspections missed due to COVID-19 waivers were completed. CHA will continue to monitor HQS inspections scheduling program-wide via Yardi reporting and Power BI dashboards to ensure compliance with HUD mandated timelines. Contact Person: Cheryl Burns, Chief HCV Officer Anticipated Completion Date: End of 3rd Qtr. 2025
Finding 2024-003 N. Special Tests and Provisions: N3. Utility Allowance Schedule – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The Authority acknowledges the finding regarding the retention of supporting documentation for the utility allowance schedule analysis an...
Finding 2024-003 N. Special Tests and Provisions: N3. Utility Allowance Schedule – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The Authority acknowledges the finding regarding the retention of supporting documentation for the utility allowance schedule analysis and related approvals. To address this, the CHA has established a Compliance Team to oversee documentation retention and review processes. In 2025, CHA has instituted procedures to ensure all supporting documentation is retained, including: • Inputs from the third-party vendor’s analysis of utility allowance schedule changes; • Evidence of management’s review and approval of the annual utility allowance schedule; • Signed and dated utility allowance notice with effective date instructions and copies of the new schedules. • The final report is maintained in a central location by the user group, ensuring accessibility for reference and audit purposes. Timeline • Implementation began Quarter 3 2025 and is ongoing. Contact Person: Leonard Langston, Jr., Interim Chief Property Officer Anticipated Completion Date: End of 3rd Qtr. 2026
Finding 2024-002 N. Special Tests and Provisions: N17. Environmental Contaminants Testing and Remediation – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Under the recent Property and Asset Management (PAM) reorganization and CHA’s Year of Renewal, the Healthy Homes...
Finding 2024-002 N. Special Tests and Provisions: N17. Environmental Contaminants Testing and Remediation – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Under the recent Property and Asset Management (PAM) reorganization and CHA’s Year of Renewal, the Healthy Homes Division was established to identify and address historic indoor environmental health hazards and proactively engage CHA programs in primary prevention strategies. In addition to regulatory lead and asbestos compliance, the Healthy Homes team will engage on mold, pest/pesticides, indoor air quality, and other indoor environmental concerns. Strategies include, but are not limited to: • Establish a compliance assurance protocol and tracking system and engage appropriate regulatory agencies (HUD, Illinois Department of Public Health, U.S. Environmental Protection Agency, Chicago Department of Public Health) • Establish records management schedule related to inspections, abatement or remediation, and clearance testing • Draft Quality Assurance Performance Plan and Scientific Integrity Policy • Track, route, and review applicable healthy homes-related work orders • Create screening and assessment criteria (for inspection schedules) • Provide basic environmental health training to CHA staff and media-specific training to appropriate programs (for instance, mold cleanup for Property Operations Managers) • Coordinate training and review certification/license of CHA contractors (construction vendors and property management firms) • Establish policies, procedures, and best practices guidance Timeline: Spring/Summer 2025: - Healthy Homes Team (within PAM) established and full team build out begins. Team hiring will be complete by September 2025. o Healthy Homes Director (1) o Environmental Health and Safety Managers (2) o Environmental Health and Safety Analysts (2) o Quality Assurance/Quality Control Analyst (1) - Coordinated renovation, repair, and painting (RRP) training for construction vendors, inhouse construction project management, and Property Management firms (16 courses, 20 participants each, between June and October). RRP is a federal regulation that requires lead-safe work practices in targeted housing. Established CHA’s RRP Policy that requires all construction and maintenance staff and vendors to be RRP certified by November 2025. All maintenance, repair, renovation, rehabilitation, or construction work will be done under RRP, in both target and non-target housing. Current and ongoing into 2026: - Drafting policies, procedures, and best practices guidance for construction and property operations, including but not limited to life-cycle abatement manual, lead safe work practices, safe mold clean-up and best practices, and lead abatement during unit turns - Creating a data management system which includes relevant unit inventory and recurrent inspection schedules. Contact Person: Leonard Langston, Jr., Interim Chief Property Officer Anticipated Completion Date: Q1 2026
Finding 2024-001 E. Eligibility, L. Reporting (Form HUD-50058 MTW), and N. Special Tests and Provisions – N1. Waiting List, N2. Reasonable Rent, N3. Utility Allowance Schedule, N6. Housing Assistance Payment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Since Janu...
Finding 2024-001 E. Eligibility, L. Reporting (Form HUD-50058 MTW), and N. Special Tests and Provisions – N1. Waiting List, N2. Reasonable Rent, N3. Utility Allowance Schedule, N6. Housing Assistance Payment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Since January 2025, CHA’s Property and Asset Management Division has been engaged in an extensive reorganization to expand resources that will improve compliance and increase controls around program compliance. With this restructuring, precise policies, procedures, and internal controls are being implemented as outlined below. Timeline: February 2025 • Added additional Property Operations Managers to allow for more oversight of day-to-day site activity April 2025 • Creation of a new Compliance team, who will function as a hub on both regulatory and contract compliance for Public Housing and RAD programs. Part of this team was created to focus specifically on program eligibility—either directly or through oversight of third-party management firms—and is staffed accordingly: o Director of Compliance o Senior Manager of Compliance o Compliance Specialist June 2025 • Worked to finalize solicitation for third party firm to perform monthly tenant file reviews, provide comprehensive reporting on general findings, patterns, training needs, and gross compliance concerns. CHA staff will implement trainings and contract enforcement as necessary to ensure compliance standards are raised, and controls are being adhered to. These monthly tenant file reviews are expected to continue in addition to the routine file audits conducted by Property Operations Managers. October 2025 • Updated manuals for Property Operations will be completed, distributed, and trained on to ensure site operations meet compliance standards and controls are being adhered to. Initiated and ongoing actions • Frequent business meetings with third party firms to discuss performance and expectations • Trainings required as necessary • Contract enforcement, up to and including contract termination, when chronic disregard for or misapplication of policies and/or procedures are noted Contact Person: Leonard Langston, Jr, Interim Chief Property Officer Anticipated Completion Date: Q4 2025 Response/Planned Actions: The CHA will review quality control procedures currently in place by Housing Choice Voucher (HCV) program administration to ensure processes are sound and efficient and proper prevent controls are in place. All quality control processes in place must effectively ensure accuracy and timeliness of completed recertifications, including submission of Form HUD-50058s to the U.S. Department of Housing and Urban Development’s (HUD’s) PIH Information Center (PIC) system. CHA will also develop internal detect control reports to monitor the timelines for recertification scheduling and tracking. CHA conducts monthly follow-up to ensure corrections are made to records identified as “fails” during the monthly quality control review. All “fails” items are tracked and monitored until resolution for final determination has been achieved. Contact Person: Cheryl Burns, Chief HCV Officer Anticipated Completion Date: End of 3rd Qtr. 2025
Finding Reference: 2024-001 Description of Finding: The Authority was unable to provide documentation to show that the three (3) new applicants tested for the project-based voucher development Cromwell Hills Apartments were housed in accordance with the Authority’s administrative plan. Statement of ...
Finding Reference: 2024-001 Description of Finding: The Authority was unable to provide documentation to show that the three (3) new applicants tested for the project-based voucher development Cromwell Hills Apartments were housed in accordance with the Authority’s administrative plan. Statement of Concurrence or Nonconcurrence: The Authority agrees with the finding. Corrective Action: The Authority has hired a staff person to oversee the selection of applicants for Cromwell Hills Apartments. The Authority is conducting weekly meetings with staff to provide ongoing guidance and review of the process. Name of Contact Person: Curtis Lokey, Director of Finance, 432-752-4893, clokey@chahousing.org
The Corporation will register the PPP loan with the SBA to determine the course of action that can be taken.
The Corporation will register the PPP loan with the SBA to determine the course of action that can be taken.
On April 10, 2025, the Corporation reimbursed the Project for the Management Fee Overpayment and Payroll Cost for the balance due of $12,526.95.
On April 10, 2025, the Corporation reimbursed the Project for the Management Fee Overpayment and Payroll Cost for the balance due of $12,526.95.
Utility Allowances not reviewed at least annually (Housing Choice Voucher Program ALN# 14.871) We will implement controls to ensure utility allowances are reviewed annually. Date of completion: July 8, 2025
Utility Allowances not reviewed at least annually (Housing Choice Voucher Program ALN# 14.871) We will implement controls to ensure utility allowances are reviewed annually. Date of completion: July 8, 2025
Noncompliance with Cash Management (Public Housing Capital Fund CFDA 14.872) We will implement controls to ensure all future eligible Capital Fund draws are made within 3 business days of expenditures. Date of completion: July 8, 2025
Noncompliance with Cash Management (Public Housing Capital Fund CFDA 14.872) We will implement controls to ensure all future eligible Capital Fund draws are made within 3 business days of expenditures. Date of completion: July 8, 2025
Maxton Housing Authority Corrective Action Plan for the year ended December 31, 2024 Section II - Financial Statement Findings Finding 2024-001 Name of Contact Person: Teresa Bethea, Executive Director Corrective Action: We will monitor budgeted expenditures and make budget amendments as necessary. ...
Maxton Housing Authority Corrective Action Plan for the year ended December 31, 2024 Section II - Financial Statement Findings Finding 2024-001 Name of Contact Person: Teresa Bethea, Executive Director Corrective Action: We will monitor budgeted expenditures and make budget amendments as necessary. Proposed Completion Date: Immediately Section III - Federal Award Findings and Questioned Costs Finding 2024-002 Name of Contact Person: Teresa Bethea, Executive Director Corrective Action: Management will review the recertification process and plan to monitor recertifications. Proposed Completion Date: Immediately
Finding #2024-004 Comments on the Finding and Each Recommendation: Hollywood House Limited Partnership did not furnish HUD with a complete annual financial report within ninety (90) days following the end of the fiscal year ending December 31, 2024. Action(s) taken or planned on the finding: Managem...
Finding #2024-004 Comments on the Finding and Each Recommendation: Hollywood House Limited Partnership did not furnish HUD with a complete annual financial report within ninety (90) days following the end of the fiscal year ending December 31, 2024. Action(s) taken or planned on the finding: Management concurs with the finding and the recommendation. Management is in the process of implementing internal control processes to ensure compliance with applicable regulations. The audit report for the year ended December 31, 2024 has been submitted to HUD. No further action is required.
Finding #2024-003 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, Hollywood House Limited Partnership paid entity expenses of $278,645 in excess of surplus cash. Action(s) taken or planned on the finding: Management concurs with the finding and the recommend...
Finding #2024-003 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, Hollywood House Limited Partnership paid entity expenses of $278,645 in excess of surplus cash. Action(s) taken or planned on the finding: Management concurs with the finding and the recommendation.
Finding #2024-002 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, AR Preservation, LP prepaid management fees of $42,201. Action(s) taken or planned on the finding: The Agent will reduce the fees charged in the following periods by $42,201.
Finding #2024-002 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, AR Preservation, LP prepaid management fees of $42,201. Action(s) taken or planned on the finding: The Agent will reduce the fees charged in the following periods by $42,201.
Finding #2024-001 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, Villagebrook Apartments did not recertify all residents timely as required by HUD Handbook 4350.3. As of December 31, 2024, 67 of the units are not in compliance. Action(s) taken or planned on...
Finding #2024-001 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, Villagebrook Apartments did not recertify all residents timely as required by HUD Handbook 4350.3. As of December 31, 2024, 67 of the units are not in compliance. Action(s) taken or planned on the finding: The Agent reported this concern and agrees with the finding and recommendation. The Agent is working to address the staffing issues at Villagebrook Apartments and to provide additional training to the employees regarding recertification requirements. As of December 31, 2024, the Agent has implemented the use of a third-party service to aid in the recertification process. Management intends to correct all noncompliance in 2025.
1. Description: There were discrepancies noted on the HUD‐50058 forms used to determine eligibility for the Housing Choice Voucher Program. (Finding 2023‐003). 2. Analysis: The Uniform Guidance and the compliance statement must be adhered to and complied with when determining eligibility for partici...
1. Description: There were discrepancies noted on the HUD‐50058 forms used to determine eligibility for the Housing Choice Voucher Program. (Finding 2023‐003). 2. Analysis: The Uniform Guidance and the compliance statement must be adhered to and complied with when determining eligibility for participation in the Housing Choice Voucher Program. 3. Corrective Action: The Bloomfield Housing Agency design and implement control procedures with respect to eligibility determinations that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. 4. Implementation Date: Ongoing
View Audit 366862 Questioned Costs: $1
Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. We acknowledge that while the missing file was an isolated incident, internal controls over document retention need improvement to ensure all required tenant files are preserved and r...
Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. We acknowledge that while the missing file was an isolated incident, internal controls over document retention need improvement to ensure all required tenant files are preserved and retrievable. Actions taken or planned The organization is in the process of implementing an electronic document management system with automatic backup features. Additionally, a formal file retention policy is being developed, which will include supervisory review prior to any deletion or purging of files. Staff responsible for document handling will receive training to reinforce compliance with the policy. Anticipated completion date September 30, 2025
Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. We acknowledge that while the missing file was an isolated incident, internal controls over document retention need improvement to ensure all required tenant files are preserved and r...
Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. We acknowledge that while the missing file was an isolated incident, internal controls over document retention need improvement to ensure all required tenant files are preserved and retrievable. Actions taken or planned The organization is in the process of implementing an electronic document management system with automatic backup features. Additionally, a formal file retention policy is being developed, which will include supervisory review prior to any deletion or purging of files. Staff responsible for document handling will receive training to reinforce compliance with the policy. Anticipated completion date September 30, 2025
Action plan for two missing leases For FY25, only 2 months exist. During this time, leases were signed and placed in physical files in the business office on the property. The property closed on 12/1/2024 so the new owners do have the signed leases. proposed completion date: Immediately.
Action plan for two missing leases For FY25, only 2 months exist. During this time, leases were signed and placed in physical files in the business office on the property. The property closed on 12/1/2024 so the new owners do have the signed leases. proposed completion date: Immediately.
Action plan to improve the filing process for Ridgecrest Surplus cash deposit. Per the corrective action plan for FY24, "Mary Clements, CFO, the only accounting professional left at Richfield, was set an annual reminder for 45 days after the end of the fiscal year. HUD form 93486 will be completed a...
Action plan to improve the filing process for Ridgecrest Surplus cash deposit. Per the corrective action plan for FY24, "Mary Clements, CFO, the only accounting professional left at Richfield, was set an annual reminder for 45 days after the end of the fiscal year. HUD form 93486 will be completed and funds will be sent to the reserve within 60 days after the end of the fiscal year. The FY22 deposit is combined with the FY23 deposit on form 93486. The deposit for FY23 is also late. I have notified Evangeline Hilboldt at Lument. When she receives the payment, she will mark both years as complying. The deposit is being sent today, 8/2/2024." However, several days after the transfer, the transfer was rejected. I booked the rejection and did not resend the funds. I set a reminder for FY24, so I was reminded on November 15th to send the funds and the form 93486 by 11/29/2024. However, by this date, we knew that the closing of the property was happening on 12/1/2024. No funds were sent in. The loan was paid off on 12/5/2024, and no future payments will be needed. The reserve was accounted for in the closing. proposed completion date: Immediately.
Action plan to improve the filing process for Ridgecrest Surplus cash deposit. Per the corrective action plan for FY24, "Mary Clements, CFO, the only accounting professional left at Richfield, was set an annual reminder for 45 days after the end of the fiscal year. HUD form 93486 will be completed a...
Action plan to improve the filing process for Ridgecrest Surplus cash deposit. Per the corrective action plan for FY24, "Mary Clements, CFO, the only accounting professional left at Richfield, was set an annual reminder for 45 days after the end of the fiscal year. HUD form 93486 will be completed and funds will be sent to the reserve within 60 days after the end of the fiscal year. The FY22 deposit is combined with the FY23 deposit on form 93486. The deposit for FY23 is also late. I have notified Evangeline Hilboldt at Lument. When she receives the payment, she will mark both years as complying. The deposit is being sent today, 8/2/2024." However, several days after the transfer, the transfer was rejected. I booked the rejection and did not resend the funds. I set a reminder for FY24, so I was reminded on November 15th to send the funds and the form 93486 by 11/29/2024. However, by this date, we knew that the closing of the property was happening on 12/1/2024. No funds were sent in. The loan was paid off on 12/5/2024, and no future payments will be needed. The reserve was accounted for in the closing. proposed completion date: Immediately.
Unauthorized Change in Management Agent and Unauthorized Distribution We agree with this finding. During 2023, the Organization hired and transitioned the operational management to a management agent which is not approved by HUD. Subsequent to year end, the Organization has changed to a new property...
Unauthorized Change in Management Agent and Unauthorized Distribution We agree with this finding. During 2023, the Organization hired and transitioned the operational management to a management agent which is not approved by HUD. Subsequent to year end, the Organization has changed to a new property management company during 2025 which is approved by HUD.
View Audit 366819 Questioned Costs: $1
Late submission of the Single Audit Reporting Package and Data Collection Form to the Federal Audit Clearinghouse (FAC) We agree with this finding. The annual financial statement audit for the year ending December 31, 2023 was not completed and submitted to the Federal Audit Clearinghouse by the sta...
Late submission of the Single Audit Reporting Package and Data Collection Form to the Federal Audit Clearinghouse (FAC) We agree with this finding. The annual financial statement audit for the year ending December 31, 2023 was not completed and submitted to the Federal Audit Clearinghouse by the statutory due date of September 30, 2024 and the HUD REAC AFS was not submitted by September 30, 2024 as required. The prior property manager for 2024 was terminated effective March 31, 2025 and has been replaced by a new property management company. The new property management agent is familiar with HUD and federal reporting requirements and will submit future reports in a timely manner.
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