Corrective Action Plans

Finding 19868 (2022-003)

Significant Deficiency 2022

LA

HUD Housing Programs Equipment & Real Property Management

September 26, 2023 Postlethwaite and Netterville Findings and Questioned Costs -2022-001 - Accounting and Financial Reporting View of Responsible Official: CFO Corrective action plan: The accounting team will take the necessary actions and implement policies to address the deficiencies prese...

September 26, 2023 Postlethwaite and Netterville Findings and Questioned Costs -2022-001 - Accounting and Financial Reporting View of Responsible Official: CFO Corrective action plan: The accounting team will take the necessary actions and implement policies to address the deficiencies presented. Account reconciliations will be the responsibility of the Sr. Accountant and review/approval by the CFO. There will also be an inventory roll forward review each month in collaboration with the Operations team. The objectives of the Finance Department are two-fold: 1. To prepare accurate financial statements in accordance with generally accepted accounting principles and distribute them in a timely and cost-effective manner. 2. To provide adequate financial information to aid management in decision-making. A monthly set of financial statements shall be prepared, usually by the 15th business day of the subsequent month. Findings and Questioned Costs -2022-002 Non-Compliance with State Audit Law View of Responsible Official: CFO Corrective action plan: The accounting team will establish hard deadlines for completion of items for audits going forward. The CFO shall document, in detail, any obstacles that may occur to account for any delays. This tracking will allow for an ample amount of time to address any issues. ? Planning ? The CFO is responsible for delegating the assignments and responsibilities to accounting staff in preparation for the audit. Assignments shall be based on the historical list of requested schedules and information maintained by the finance department. ? Involvement ? Finance department staff will do as much work as possible to assist the auditors. ? Interim Procedures ? By performing significant portions of audit work as of an interim date, the work required after year-end is reduced. The finance department staff will provide requested schedules and documents and otherwise assist the auditors during any interim audit fieldwork that is performed. ? Streamlined Processes ? The organization implemented a new warehouse management system in Q4 2022 in order to streamline reporting that required manual calculations that routinely pushed the organization?s timelines behind schedule. Example: No longer will the CFO have to manually value each item in inventory by hand via spreadsheets. Throughout the audit process, it shall be the policy of the Organization to make every effort to provide schedules, documents and information requested by the auditors in a timely manner. FEDERAL PROGRAM: Findings and Questioned Costs -2023-003 ? Accountability for USDA-Donated Foods View of Responsible Official: COO/CFO Corrective action plan: The organization implemented a new warehouse management system fully integrated with financials in Q4 2022 to resolve these known weaknesses. These new procedures will account for all documentation issues as the new system allows for ease of storage via electronic logs and filing. Retraining will be held annually to ensure all are fully trained in the expectations of best practices regarding documentation. It will be the responsibility of the logistics team to collect and file all pertinent documentation regarding distributions and receipts, this will be monitored and reported on monthly by the Sr. Logistics Manager and any discrepancies reported, documented, and corrected by the COO.

View Audit 23525

Finding 19843 (2022-005)

Significant Deficiency 2022

Palm Beach County Housing Authority

FL

HUD Housing Programs Reporting Significant Deficiency

Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely.

View Audit 23451

Finding 19842 (2022-004)

Material Weakness 2022

Palm Beach County Housing Authority

FL

HUD Housing Programs Subrecipient Monitoring Eligibility

2022-004 ? Selection from the Waiting List Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. Explanation of disagreement w...

2022-004 ? Selection from the Waiting List Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, increased compliance, and accountability. The PBCHA will continue to develop, train, and enforce procedures related to efficient waitlist management for families placed on the list for the HCV programs; the ongoing maintenance of the waiting lists; and selection of enough families from the list to maximize the PBCHA?s use of available funding. The PBCHA has elected to open its waiting lists beginning in June 2022 for its HCV programs and to leave lists open indefinitely to accurately depict the demand for affordable housing. This will require that PBCHA staff ae trained and annually comply with the procedures outlined in the Administrative Plan related to updating, removal and selection from the wait lists, admission, and eligibility, and that all steps are documented within the tenant file and agency business system accordingly. The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiency will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Name(s) of the contact person(s) responsible for corrective action: Tyler Rasmussen. Carol Jones-

View Audit 23451

Finding 19841 (2022-003)

Material Weakness 2022

Palm Beach County Housing Authority

FL

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022-003 ? Rent Reasonableness Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Explanation of disagreement with audit fin...

2022-003 ? Rent Reasonableness Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, increased compliance, and accountability. The agency will continue to develop, train, and enforce procedures to ensure rent reasonableness is performed on a timely basis as required by federal regulations and documentation is maintained in the tenant file. The agency utilizes an external resource to conduct rent comparison. The PBCHA will continue to train and instruct Housing Specialists on the responsibility to perform the rent reasonableness determination at the time of initial leasing, when there is an increase in rent to owner and at HAP contract anniversary if applicable under HUD rules and regulations. The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiency will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Name(s) of the contact person(s) responsible for corrective action:

View Audit 23451

Finding 19840 (2022-002)

Material Weakness 2022

Palm Beach County Housing Authority

FL

Questioned Costs HUD Housing Programs Material Weakness

2022-002 ? HQS Enforcements Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management s...

2022-002 ? HQS Enforcements Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, increased compliance, and accountability. The PBCHA continues to utilize its third-party vendor to complete all HQS inspections. The PBCHA will also utilize the technology available to make its HQS inspections and enforcement process as efficient as possible. This includes improved functionality within its new software system, new guidelines, and handheld technology and RVI methods as appropriate. The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiency will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Name(s) of the contact person(s) responsible for corrective action: Tyler Rasmussen, Carol Jones- Gilbert

View Audit 23451 Questioned Costs: $1

Finding 19839 (2022-001)

Material Weakness 2022

Palm Beach County Housing Authority

FL

HUD Housing Programs Subrecipient Monitoring Eligibility

Eligibility 2022-001 ? Eligibility Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in ac...

Eligibility 2022-001 ? Eligibility Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, and increased compliance and accountability. The PBCHA will continue to utilize all available resources to recruit, retain and train HCVP staff on the HCV program guidelines, to include training to determine what is included and excluded from annual income, how to identify and calculate assets, correctly calculate adjusted income by applying the HUD defined allowances and expenses, recognize the requirements for verification of income, allowances, and expenses and calculate total tenant payment and housing assistance payment (HAP). The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiencies will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Board of Commissioners Paul Dumars, Chairman Phyllis Choy, Vice Chair Digna Mejia Charlie Fetscher CEO and Executive Director Carol Jones-Gilbert 3432 West 45th Street West Palm Beach, Florida 33407 Office: (561) 684-2160 ext. 104 Mobile: (561) 628-9387 Fax: (561) 455-9965 Name(s) of the contact person(s) responsible for corrective action: Tyler Rasmussen, Carol Jones- Gilbert

View Audit 23451

Finding 19624 (2022-007)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303 § 200.328

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it submitted complete and accurate quarterly performance reports for the Workforce Innovation and Opportunity grant. Questioned Costs: Assistance Listing # ...

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it submitted complete and accurate quarterly performance reports for the Workforce Innovation and Opportunity grant. Questioned Costs: Assistance Listing # 17.258 17.259 17.278 Amount $0 Status: Corrective action in progress Corrective Action: In response to the finding, the Department is in the process of developing a comprehensive system and set of protocols to strengthen internal controls over the completion and submission of quarterly performance reports for the Workforce Innovation and Opportunity Act (WIOA) grant. The Department: ? Executed a Workforce Integrated Technology Replacement Project that focuses on improving case management and data management internal controls. The Department estimates the project will be completed by December 2024. ? Initiated and is in the process of a statewide implementation of the U.S. Department of Labor (DOL) Quarterly Report Analysis data integrity and data quality internal controls system. The Department will: ? Continue to execute the Data Element Validation policy update for the Participant Individual Record Layout (PIRL) report per DOL expectations. ? Continue to provide technical assistance, training, and one-on-one coaching for the local areas, which cover WIOA Title I and WIOA Title III, PIRL reporting, data management, validation, quality, and integrity systems and processes. The conditions noted in this finding were previously reported in findings 2021-007 and 2020-012. Completion Date: Estimated December 2024 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 23129

Finding 16700 (2022-001)

Significant Deficiency 2022

Beacon Senior Housing Corporation

CA

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Name of auditee: Beacon Senior Housing Corporation HUD auditee identification number: 122-EE137 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: (818) 247...

Name of auditee: Beacon Senior Housing Corporation HUD auditee identification number: 122-EE137 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: (818) 247-0420 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 $6,717. The reserve for replacements account was not reimbursed for these duplicate withdrawals. Management should transfer funds of $6,717 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 $6,717 from the operating cash account to the reserve for replacements account.

View Audit 21334 Questioned Costs: $1

Finding 16689 (2022-003)

Significant Deficiency 2022

Tallahassee Housing Authority

FL

HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

2022-003 Special Tests and Provisions ? Housing Quality Standards Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 ? Housing Choice Vouchers 14.879 Mainstream Vouchers Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Condition: ...

2022-003 Special Tests and Provisions ? Housing Quality Standards Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 ? Housing Choice Vouchers 14.879 Mainstream Vouchers Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Condition: Out of a total population of 166 failed inspections, 17 failed inspections were selected for testing in a statistically valid sample. Exceptions were noted as follows: ? 1 error where unit never passed inspection and the Authority continued to make HAP payments when the contract should have been abated. Recommendation: The Authority should more closely monitor failed inspections to make sure that any units that have not passed re-inspection are not issued HAP payments until all repairs are made, and the HAP contract is terminated for any unit for which the owner has not made repairs within the allowed timeframe. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding and will establish more review, oversight and training for the staff responsible for these procedures and assure that HAP payments are properly abated when repairs are not made within the required timeframes.

View Audit 21308

Finding 16688 (2022-002)

Significant Deficiency 2022

Tallahassee Housing Authority

FL

HUD Housing Programs Eligibility Significant Deficiency

2022-002 Eligibility ? Tenant Files Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 ? Housing Choice Vouchers 14.879 Mainstream Vouchers Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Repeat finding from June 30, 2021 as Findin...

2022-002 Eligibility ? Tenant Files Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 ? Housing Choice Vouchers 14.879 Mainstream Vouchers Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Repeat finding from June 30, 2021 as Finding 2021-001 (initially reported June 30, 2010) Condition: Out of a total tenant population of approximately 2,100 tenants, 25 files were selected for testing. Exceptions were noted as follows: ? 1 error where the wrong amount was used to calculate tenant?s wage income. This had no effect on HAP rent. ? 1 error where overtime earnings was not included in calculating tenant?s wage income. This caused HAP rent to decrease by $11. ? 1 error where the utility allowance was calculated incorrectly. This caused the HAP rent to decrease by $61. ? 1 error where the prior year utility allowance schedule was used instead of the current year. This had no effect on HAP rent. ? 1 error where adoption subsidy benefits were calculated incorrectly as well as the amount excluded from income. This decreased HAP rent by $9. ? 1 error where $1,753 in unreimbursed medical expenses was carried forward from the prior year 50058 and file had no support for any medical expenses in current year. This decreased HAP rent by $22 ? 1 error where there was no EIV report in file In addition to the above, we noted the following during our new admissions testing (21 new admissions tested): ? 1 error where there was no signed 214 affidavit in the file for one member of the household Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding and has implemented a robust file review process, enhanced quality control procedures, and provided training on errors noted along with annual program training for all staff. The cited files were corrected.

View Audit 21308

Finding 16624 (2022-001)

None 2022

13west 103rd Street CORP

NY

Cash Management HUD Housing Programs Internal Control / Segregation of Duties

13 West 103rd Street Corporation 290 Lenox, 3rd Floor New York, NY 10027 AUDITEE?S CORRECTIVE ACTION PLAN Name and Number of Project 13 West 103rd Street Corporation, FHA Project Number 012-HD006 Auditor/Audit Firm PKF O?Connor Davies LLP Audit Period June 30, 2022 Finding 2022-001 ? Timely De...

13 West 103rd Street Corporation 290 Lenox, 3rd Floor New York, NY 10027 AUDITEE?S CORRECTIVE ACTION PLAN Name and Number of Project 13 West 103rd Street Corporation, FHA Project Number 012-HD006 Auditor/Audit Firm PKF O?Connor Davies LLP Audit Period June 30, 2022 Finding 2022-001 ? Timely Deposit of Surplus Cash A. Comments on Finding and Recommendations Recommendation ? We recommend that management ensures the surplus cash deposit is done timely in the future. B. Actions Taken or Planned Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Going forward our focus will be to work with the auditor and owner to get the audits finalized earlier so adequate time is left for the deposits to be made. In instances where the final is not going to be issued and allow enough time, the deposit will be made based on the reviewed draft. C. Status of Corrective Action on Prior Findings No prior findings. Ezra Miller, CFO

View Audit 21282

Finding 16546 (2022-001)

Significant Deficiency 2022

Swan Memorial Housing Association

WA

HUD Housing Programs Procurement, Suspension & Debarment Reporting

Finding Reference Number #2022-001 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and is in the process of funding the deficiency. Contact Person Responsible: Tom Anderson Anticipated Completion Date: December 31, 2022

View Audit 20458

Finding 16534 (2022-001)

Significant Deficiency 2022

Caritas Villa

OR

HUD Housing Programs Procurement, Suspension & Debarment Eligibility

Caritas Villa respectfully submits the following corrective action plan for the year ended June 30, 2022. Name & address of public accounting firm: Jones & Roth CPAs 260 Country Club Rd. Ste. 100 Eugene OR 97401 Audit Period: June 30, 2022 Major Federal Award Findings: Finding Reference #: 2022-001 ...

Caritas Villa respectfully submits the following corrective action plan for the year ended June 30, 2022. Name & address of public accounting firm: Jones & Roth CPAs 260 Country Club Rd. Ste. 100 Eugene OR 97401 Audit Period: June 30, 2022 Major Federal Award Findings: Finding Reference #: 2022-001 Significant deficiency Recommendation: We recommend management review the current internal control procedures and implement additional procedures to ensure annual recertifications are performed as required by HUD. Corrective Action: Management will work with Cascade Management to improve the internal control procedures to ensure annual recertifications are performed as required by December 31, 2022. Questions regarding this corrective action plan may be directed to Marci Pierce, Chief Financial and Administrative Officer, at (503) 688-2646.

View Audit 20424

Finding 16395 (2022-001)

None 2022

St. George's Senior Housing, Inc.

TX

Questioned Costs HUD Housing Programs

CORRECTIVE ACTION PLAN Name and Number of the Project: St. George?s Senior Housing, Inc. No. 115-EH057 Audit Firm: M Group, LLP Audit Period: The year ended September 30, 2022 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our au...

CORRECTIVE ACTION PLAN Name and Number of the Project: St. George?s Senior Housing, Inc. No. 115-EH057 Audit Firm: M Group, LLP Audit Period: The year ended September 30, 2022 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN

View Audit 23155 Questioned Costs: $1

Finding 16388 (2022-001)

None 2022

H.o.l.i.e. of Greenfield Avenue, Inc. - Valentino Square Apartments

WI

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Management increased the security deposit bank account by $500 on September 15, 2022 to correct this finding.

View Audit 19955

Finding 16243 (2022-001)

Significant Deficiency 2022

Adam and Bruce Housing Corporation Dba Adam and Bruce Apts. 073-11568

CA

HUD Housing Programs Procurement, Suspension & Debarment Subrecipient Monitoring

Statement of Condition 2022-001 (Assistance Listing No. 14.155): The Property received a score of 35c* on a physical inspection of the Property performed on January 21, 2022 by a representative of HUD. By reference, the REAC inspection is included as a statement of condition. Recommendation: Manag...

Statement of Condition 2022-001 (Assistance Listing No. 14.155): The Property received a score of 35c* on a physical inspection of the Property performed on January 21, 2022 by a representative of HUD. By reference, the REAC inspection is included as a statement of condition. Recommendation: Management should ensure all necessary repairs have been made. Management should continue to conduct routine unit and general property inspections and deficiencies should be corrected in a timely manner. Action(s) taken or planned on the finding: Agree. Management has responded to HUD in regards to this inspection report and has addressed all health and safety issues. Management will continue to correct all remaining deficiencies noted and will implement a process of self-inspection of units and common areas.

View Audit 22324

Finding 16242 (2022-001)

Material Weakness 2022

Pontiac Housing Commission

MI

HUD Housing Programs Internal Control / Segregation of Duties

2022-1 Condition: Deficiencies Noted in Examination of Housing Choice Voucher Program Participant Files We concur with this finding and the Auditor?s recommendation. We will review the internal control procedures over tenant file re-certifications and documents. Management will implement proced...

2022-1 Condition: Deficiencies Noted in Examination of Housing Choice Voucher Program Participant Files We concur with this finding and the Auditor?s recommendation. We will review the internal control procedures over tenant file re-certifications and documents. Management will implement procedures to clear this finding in FY 2023 Timeframe: By the fiscal year end for March 31, 2023 Individual responsible for correction: Mr. Ahmad Taylor, Executive Director

View Audit 21563

Finding 16163 (2022-001)

Significant Deficiency 2022

Neighborhood Legal Services, Inc.

NY

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

Name of Auditee: Neighborhood Legal Services, Inc. Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2022 CAP Prepared by: Lauren Breen, Executive Director Phone: (716) 847-0650 (A) Current Finding on the Schedule of Findings and Questioned Costs Finding 2022-001 (...

Name of Auditee: Neighborhood Legal Services, Inc. Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2022 CAP Prepared by: Lauren Breen, Executive Director Phone: (716) 847-0650 (A) Current Finding on the Schedule of Findings and Questioned Costs Finding 2022-001 (a) Comments with the finding and recommendation - NLS agrees with the finding. NLS also agrees with the recommendation, please see below for action taken. (b) Action taken - In April 2023, Neighborhood Legal Services (NLS) will conduct an office-wide training emphasizing the importance of careful file tracking. In addition, the Housing Unit shall develop a tracking system which will be implemented through the use of NLS?s new case management system. In the event that a staff member unexpectedly leaves on a temporary or permanent basis, inventory of the staff member?s open cases and matters shall be conducted prior to departure, where possible, and where an inventory prior to departure is not possible, it shall be conducted as soon as practicable, but in no event more than two weeks following the staff member?s temporary or permanent departure from the agency. NLS will implement additional office-wide procedural changes in 2023 to ensure that policies and procedures are effectively communicated to staff and that regular internal review of cash files ensures these procedures are followed in practice by staff.

View Audit 19624

Finding 16016 (2022-001)

Significant Deficiency 2022

Caritas Plaza

OR

HUD Housing Programs Procurement, Suspension & Debarment Eligibility

Caritas Plaza respectfully submits the following corrective action plan for the year ended June 30, 2022. Name & address of public accounting firm: Jones & Roth CPAs 260 Country Club Rd. Ste. 100 Eugene OR 97401 Audit Period: June 30, 2022 Major Federal Award Findings: Finding Reference #: 2022-001 ...

Caritas Plaza respectfully submits the following corrective action plan for the year ended June 30, 2022. Name & address of public accounting firm: Jones & Roth CPAs 260 Country Club Rd. Ste. 100 Eugene OR 97401 Audit Period: June 30, 2022 Major Federal Award Findings: Finding Reference #: 2022-001 Significant deficiency Recommendation: We recommend management review the current internal control procedures and implement additional procedures to ensure annual recertifications are performed as required by HUD. Corrective Action: Management will work with Cascade Management to improve the internal control procedures to ensure annual recertifications are performed as required by December 31, 2022. Questions regarding this corrective action plan may be directed to Marci Pierce, Chief Financial and Administrative Officer, at (503) 688-2646.

View Audit 19584

Finding 15952 (2022-001)

None 2022

Pacific Housing Oahu Corporation - Elderly Residence

HI

HUD Housing Programs

1. Ref. No. 2022-001: Deposit Funds Monthly to an Interest-Bearing Replacement Reserve Account Recommendation: The Company should implement a process to adhere to the Regulatory Agreement requirements and ensure that the replacement reserve account deposits are completed monthly. Action Taken: The...

1. Ref. No. 2022-001: Deposit Funds Monthly to an Interest-Bearing Replacement Reserve Account Recommendation: The Company should implement a process to adhere to the Regulatory Agreement requirements and ensure that the replacement reserve account deposits are completed monthly. Action Taken: The Company has instructed Bob Tanaka, Inc. to establish a procedure to ensure $2,000 is deposited into the replacement reserve account every month, preferably via an automated process. Contact person: Patrick Delaney (808) 523-5681, ext. 693 Anticipated Completion Date: October 31, 2023

View Audit 21384

Finding 15951 (2022-002)

None 2022

Pacific Housing Oahu Corporation - Elderly Residence

HI

HUD Housing Programs

2. Ref. No. 2022-002: Ensure Only Authorized Withdrawals are Disbursed from the Replacement Reserve Account Recommendation: Management should transfer $12,817 from the operating cash account to the replacement reserve fund. Action Taken: The Company has removed Locations/MontPac as the property ma...

2. Ref. No. 2022-002: Ensure Only Authorized Withdrawals are Disbursed from the Replacement Reserve Account Recommendation: Management should transfer $12,817 from the operating cash account to the replacement reserve fund. Action Taken: The Company has removed Locations/MontPac as the property managers on March 31, 2023 and hired Bob Tanaka, Inc. as their replacement. The Company has instructed Bob Tanaka, Inc. to transfer $12,817 from the operating bank account to the replacement reserve bank account. The Company has also instructed Bob Tanaka, Inc. to obtain HUD authorization prior to making transfers from the replacement reserve account. Contact person: Patrick Delaney (808) 523-5681, ext. 693 Anticipated Completions Date: Completed.

View Audit 21384

Finding 15949 (2022-001)

Significant Deficiency 2022

Rainbow Heights, Inc.

GA

HUD Housing Programs Internal Control / Segregation of Duties

Reportable Views of Responsible Officials: Management is in agreement with the finding and has started the process to increase to increase the policy coverage amount.

View Audit 20279

Finding 15917 (2022-003)

Significant Deficiency 2022

South Carolina State Housing Finance and Development Authority

SC

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend that the Authority sets up a separate interestbearing account and executes a depository agreement with their financial institution and HUD; alternatively, we recommend that the Authority obtains a waiver ...

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend that the Authority sets up a separate interestbearing account and executes a depository agreement with their financial institution and HUD; alternatively, we recommend that the Authority obtains a waiver from this requirement if local regulation prohibits the Authority from following 24 CFR section 982.156. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Housing Voucher Cluster funds are held by the Treasurer for the State of South Carolina. The depository agreements in place are between the depository institution and the state Treasurer. SC Housing has contacted HUD via email and requested a waiver for this regulatory requirement. An update will be provided when available. Name of the contact person responsible for corrective action: Lisa Wilkerson Planned completion date for corrective action plan: Waiver request submitted to HUD local field office on March 29, 2023.

View Audit 19599

Finding 15914 (2022-001)

Significant Deficiency 2022

South Carolina Regional Housing Authority No. 3

SC

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Finding 2022-001 ? Internal Controls Governing the Public Housing Waiting List ? Significant Deficiency ? CFDA #14.850 Corrective Action Plan: Although we have determined that no one has received housing unjustly and the written process was followed other than the documenting of each applicants fi...

Finding 2022-001 ? Internal Controls Governing the Public Housing Waiting List ? Significant Deficiency ? CFDA #14.850 Corrective Action Plan: Although we have determined that no one has received housing unjustly and the written process was followed other than the documenting of each applicants file verifying the history of offer and contact. We determined that the following internal controls were relevant to our meeting out audit findings: ? We would have to develop an across the board protocol of how we would be handling applications from entry to being housed. We would have to not only enforce written policies but put in place an audit to ensure that the process was being carried out correctly. ? We will be contacting our public housing software company to get the offering process up and running in the computer so that we will be able to document all actions that take place within an applicants file so that it can be viewed by all persons upon opening an applicants file. ? We will be changing our current offer process so that it will be done and documented only through the computer and we will no longer use handwritten documentation. ? We will get with our software company to ensure that we will have the proper written protocol and make sure that we can run activity reports. ? We will train all affected employees with these new changes. Person Responsible: Doris Jamison and Tony Still Anticipated Completion Date: 03/31/2023

View Audit 19555

Finding 15893 (2022-001)

Material Weakness 2022

Home Share 092-Hd017

MN

Internal Control / Segregation of Duties Eligibility HUD Housing Programs § 200.303

March 27, 2023 HOME SHARE HUD PROJECT NO. 092-HD017 Corrective Action Plan Finding: 2022-001 ? Compliance and Controls over Compliance ? Eligibility Supportive Housing for Persons with Disabilities (Section 811), CFDA No. 14.181 Material Weakness & Noncompliance In 2022, Home Share did not have cont...

March 27, 2023 HOME SHARE HUD PROJECT NO. 092-HD017 Corrective Action Plan Finding: 2022-001 ? Compliance and Controls over Compliance ? Eligibility Supportive Housing for Persons with Disabilities (Section 811), CFDA No. 14.181 Material Weakness & Noncompliance In 2022, Home Share did not have controls in place to ensure that eligibility criteria and rent calculations were being reviewed and/or approved by someone other than the individual making the initial determination or annual recertification. Actions Taken or Planned: Management agrees with this finding. Beginning in January 2022, management has contracted out the eligibility determination process to a third-party contractor with significant experience in affordable housing and similar processes. Management is working with the contractor to include a second individual in this process so that there will be a review performed by someone other than the individual making the initial determination or annual recertification. Contact Persons: Ernest Johnson, Housing Associate Director Robert Pickering, Chief Financial Officer

View Audit 19545

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