Corrective Action Plans

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Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations and has implemented reviews of the financial statements by senior management prior to approving transfers to ensure accuracy of information.
Management agrees with the findings and recommendations and has implemented reviews of the financial statements by senior management prior to approving transfers to ensure accuracy of information.
Management agrees with the finding and is working with ownership on reimbursement to the property. Management will collect in accordance with HUD going forward.
Management agrees with the finding and is working with ownership on reimbursement to the property. Management will collect in accordance with HUD going forward.
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance wi...
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance with the requirements of the HUD Handbook4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. FG Companies has also implemented a bi-weekly file audit system that will continue to be completed by the Regional Manager. This system is to ensure all files are current with certifications and all required state and local forms are completed and filed accordingly.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will collect in accordance with HUD going forward.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will collect in accordance with HUD going forward.
Management agrees with the findings and recommendations, however due to insufficient funds at the property, we will collaborate with HUD to secure appropriate funding.
Management agrees with the findings and recommendations, however due to insufficient funds at the property, we will collaborate with HUD to secure appropriate funding.
Name of Auditee: Herkimer Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: June 30, 2025 CAP prepared by; Richard Dowe, Executive Director (A) Current Finding on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a) Comments on the finding an...
Name of Auditee: Herkimer Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: June 30, 2025 CAP prepared by; Richard Dowe, Executive Director (A) Current Finding on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action. (b) Action taken - The Authority will strengthen internal controls and training of staff to ensure compliance deadlines are met and immediately obtain the missing leases. (c) Planned implementation date - The Authority expects to complete the corrective actions by June 30, 2026.
The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure deposits are made as required by the regulatory agreement.
The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure deposits are made as required by the regulatory agreement.
The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure withdrawals are made as required by the regulatory agreement.
The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure withdrawals are made as required by the regulatory agreement.
Finding # 2025 -001- Lack of Segregation of Duties Over Payroll (Prior Year Finding # 2024 -001) Condition: Management is responsible for the design, installation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. ...
Finding # 2025 -001- Lack of Segregation of Duties Over Payroll (Prior Year Finding # 2024 -001) Condition: Management is responsible for the design, installation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. The limited size of the District's office staff prevents the ideal segregation of functions over payroll. The Payroll and Human Resources Administrative Assistant is the only employee responsible for entering employee salaries and hourly pay rates and has access to process payroll. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties over payroll. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: We recommend employee salary and hourly pay rates be reviewed and approved by someone independent of the payroll process. We also recommend an independent review and approval of payroll registers prior to distribution or direct deposit processing. Response: We agree with this finding. Due to staffing limitations, full segregation of payroll duties is not currently feasible, however, the District will implement additional compensating controls, including independent review and approval of employee salaries and hourly rates and payroll registers prior to processing. Contact Person Ryan Bohnsack Anticipated Completion: Not Applicable
Condition: The County did not perform required on-site inspections of four out of six HOME-assisted properties evaluated during FY 2025, as mandated by 24 CFR §§ 92.209(i), 92.251(f), and 92.504(d). These inspections are required every one to three years, depending on the number of units per project...
Condition: The County did not perform required on-site inspections of four out of six HOME-assisted properties evaluated during FY 2025, as mandated by 24 CFR §§ 92.209(i), 92.251(f), and 92.504(d). These inspections are required every one to three years, depending on the number of units per project. Recommendation: Establish and maintain a formal inspection schedule with assigned accountability to ensure timely completion of all required HOME inspections. Implement tracking tools and cross-training to mitigate delays caused by staff turnover. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Planned in Response to Finding The County agrees with the finding and is implementing the following corrective actions to strengthen internal controls over HOME inspection compliance and ensure inspections are conducted in accordance with federal requirements. 1. Cross-Training of Inspection Staff Housing & Grants staff will conduct formal cross-training with inspectors from Environmental Health and/or the Marin Housing Authority by June 30, 2026. This training will cover HOME inspection requirements, including property standards, documentation expectations, and inspection frequency requirements. Cross-training will ensure sufficient technical expertise and backup coverage to perform and review HOME inspections in compliance with federal regulations and to maintain continuity during staffing changes.2. Implementation of Inspection Tracking Software The Community Development Agency will implement and utilize inspection tracking software by June 30, 2026 to track, schedule, and document HOME program inspections. The system will maintain inspection dates, inspection type (desk audit or physical), findings, corrective actions, and follow-up status. This tool will strengthen monitoring controls, provide management visibility, and help ensure inspections are conducted timely and consistently. 3. Conducting HOME Inspections in Accordance with HOME Regulations Housing & Grants staff will conduct HOME inspections in accordance with HOME program regulations by June 30, 2026, including both desk audits and physical inspections, as follows: • Desk Audits: Staff will review program documentation, tenant eligibility, income certifications, rent limits, and other compliance documentation using standardized desk audit procedures. • Physical Inspections: Physical property inspections will be performed in accordance with HOME property standards to assess health and safety compliance. • Monitoring and Documentation through JotForm Desk Audits: Desk audits will be documented using JotForm inspection and monitoring tools to ensure consistent documentation, clear audit trails, and management oversight of HOME compliance activities. 4. Formal Inspection Schedule and Ongoing Oversight The Community Development Agency has initiated development of a comprehensive HOME on-site inspection schedule that identifies all HOME-assisted properties, applicable inspection frequencies, and assigned staff responsibilities. The schedule will be maintained and reviewed at least quarterly by program management to ensure inspections are completed timely and any overdue inspections are promptly addressed. Responsible Officials • Leelee Thomas, Deputy Director, Community Development Agency Leelee.Thomas@marincounty.gov • Chris Miranda, Senior Program Coordinator, Community Development Agency Chris.Miranda@marincounty.gov Planned Completion Date All corrective actions described above are expected to be fully implemented by June 30, 2026.
Finding 2025.001 Special Tests and Provisions - Sliding Fee Discounts Recommendation Kalihi-Palama Health should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken: Effective February 9,...
Finding 2025.001 Special Tests and Provisions - Sliding Fee Discounts Recommendation Kalihi-Palama Health should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken: Effective February 9, 2026, we will implement the following changes to ensure clients are appropriately charged according to the sliding fee scale. -Update the frequency of our sliding fee scale employee training sessions -Implement monthly spot checks to ensure compliance to the sliding fee scale and provide timely feedback
PLANNED CORRECTIVE ACTIONS PLANNED: The Organization acknowledges the finding and agrees with the recommendation. The Organization also notes that the percentage of adults maintaining or increasing income was impacted by several participants exiting the program near the end of the fiscal year. Due t...
PLANNED CORRECTIVE ACTIONS PLANNED: The Organization acknowledges the finding and agrees with the recommendation. The Organization also notes that the percentage of adults maintaining or increasing income was impacted by several participants exiting the program near the end of the fiscal year. Due to their shorter timeframe in the program, these participants had limited opportunity to achieve employment goals or secure increased income. The Organization will review program exit timing and case planning procedures to better ensure participants have adequate time to engage in employment-related services before exit, when possible. To address the finding and improve future performance, the Organization is implementing the following corrective actions: 1. Improved Income-Tracking System: A revised income-tracking process will be integrated into case-management to ensure income information is consistently updated at program entry, during routine case reviews, and at exit. 2. Enhanced Staff Training: Case managers and program staff will receive updated training on income documentation requirements, including timely data entry and verification procedures. 3. Quarterly Internal Monitoring: The Finance Manager will conduct quarterly reviews of participant files to ensure accurate income tracking and identify areas needing corrective attention. 4. Program Exit and Case Planning Adjustments: Program leadership will work with case managers to strengthen exit planning protocols, helping ensure participants have sufficient time to pursue employment goals before program completion whenever possible. 5. Regular Coordination Between Finance and Program Teams: Monthly cross-departmental check-ins will be established to keep financial and program data aligned and identify issues early.
Subject: Corrective Action Plan for finding 2025-001 Utilities Allowance Calculation Please find our response in regards to the utility allowance calculation: Finding No. 2025-001: Utilities Allowance Calculation Marlboro Housing Authority was made aware of this finding during the audit file process...
Subject: Corrective Action Plan for finding 2025-001 Utilities Allowance Calculation Please find our response in regards to the utility allowance calculation: Finding No. 2025-001: Utilities Allowance Calculation Marlboro Housing Authority was made aware of this finding during the audit file process. We discovered that the error has to do with the changing of bedroom sizes within our SACS software. This is a process that staff must manually change when household sizes change, as it will not automatically correct when an interim or recertification is processed. Our staff has been briefed about this matter, and they will make sure that the household size and bedroom size is reflected correctly in our software, each time they review a participant file. This should resolve any error in utility allowance calculation going forward. I hope this plan for corrective action will satisfy this finding. Please feel free to contact me if you have any questions. Sincerely, Pamela Stevens Pamela Stevens Executive Director
Corrective Action Plan: Upon assuming the role of Executive Director in July 2024, it became clear that rent reasonableness studies were not being conducted under the previous administration, as required. Recognizing the importance of compliance with HUD regulations, I initiated the implementation o...
Corrective Action Plan: Upon assuming the role of Executive Director in July 2024, it became clear that rent reasonableness studies were not being conducted under the previous administration, as required. Recognizing the importance of compliance with HUD regulations, I initiated the implementation of a rent reasonableness policy and process. To support this effort, we entered into a contract with MRI to provide us with the rent reasonableness software. Last year we supplied MRI with the necessary property addresses and zip codes to begin the analysis. Due to the complexity of the implementation and the volume of data required, the setup process took time. We are now actively incorporating rent reasonableness determinations into all tenant files during annual recertifications and interims. With nearly 700 families in our program, this is an ongoing process, but significant progress has been made. Our team is fully committed to ensuring full compliance with HUD regulations, and we continue to work diligently toward that goal. In addition, to ensure continued compliance and to maintain the integrity of our files, the HCV Supervisor will be conducting weekly audits. This internal quality control measure helps us identify and address any inconsistencies or issues in a timely manner.
FINDING No. 2025-002: Section 202 Supportive Housing for Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure tenant eligibility is verified in a timely manner and tenant files are properly maintained. Action Taken: Staff training has been provided with additional HU...
FINDING No. 2025-002: Section 202 Supportive Housing for Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure tenant eligibility is verified in a timely manner and tenant files are properly maintained. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO
Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Bell respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral ...
Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Bell respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: July 1, 2024 through June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 202 Supportive Housing for Elderly, ALN 14.157 Recommendation: The Project should refund security deposits timely. Action Taken: Staff training has been provided and included in monthly reporting procedures. A system glitch caused the delay.
Supportive Housing for the Elderly (Section 202) Mortgage Financing– FAL No. 14.157 Section 202 Project Rental Assistance Contract – FAL No. 14.157 Recommendation: The Organization should ensure move-out notifications are provided to the accounting office in a timely manner to ensure the tenant's se...
Supportive Housing for the Elderly (Section 202) Mortgage Financing– FAL No. 14.157 Section 202 Project Rental Assistance Contract – FAL No. 14.157 Recommendation: The Organization should ensure move-out notifications are provided to the accounting office in a timely manner to ensure the tenant's security deposit is processed and refunded within 30 days of the move out date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will process the related move-out notifications in a timely manner and ensure future security deposits are refunded within the required timeline. Name(s) of the contact person(s) responsible for corrective action: Jennifer Medearis Planned completion date for corrective action plan: January 30, 2026
Comments on the Finding and Each Recommendation: During the year ended June 30, 2025, the Property overpaid management fees by $1,741. Action(s) taken or planned on the finding: Management concurs with the finding recommendation. Management will review its calculation of management fees and the Agen...
Comments on the Finding and Each Recommendation: During the year ended June 30, 2025, the Property overpaid management fees by $1,741. Action(s) taken or planned on the finding: Management concurs with the finding recommendation. Management will review its calculation of management fees and the Agent will reimburse $1,741 to the Property.
CORRECTIVE ACTION: Management is in agreement with the auditor’s recommendations and has already implemented procedures to correct the issue. The prior executive director’s contract was not renewed and a new executive director has been hired. If there are questions regarding this corrective action p...
CORRECTIVE ACTION: Management is in agreement with the auditor’s recommendations and has already implemented procedures to correct the issue. The prior executive director’s contract was not renewed and a new executive director has been hired. If there are questions regarding this corrective action plan, please contact Ms. Betsy Soto, Executive Director at (860) 379-4573.
Atwood Elder Housing, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The finding fr...
Atwood Elder Housing, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The finding from the October 31, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Federal Award Findings and Questioned Costs Finding 2025-001 - Eligibility - Significant Deficiency Recommendation: Management should review its internal controls over performing tenant recertification procedures to ensure compliance with eligibility requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility is done in accordance with guidelines specified by federal regulations. Action Taken: Management agrees with the assessment and resulting finding. Corrective actions have been implemented to strengthen compliance controls, including calendar reminders for compliance team members, enhanced documentation in recertification checklists to clarify specific program requirements, and routine review of compliance expectations during monthly staff training and meetings. Management has also increased supervisory oversight and implemented periodic internal file audits to monitor adherence to recertification procedures and prevent future occurrences.
The non-compliance resulted primarily from operational and system limitations rather than the absence of policy or guidance. The PHA had inspection procedures and documentation expectations in place and communicated to inspection staff; however, the inspection software that we use, Tenmast, currentl...
The non-compliance resulted primarily from operational and system limitations rather than the absence of policy or guidance. The PHA had inspection procedures and documentation expectations in place and communicated to inspection staff; however, the inspection software that we use, Tenmast, currently does not adequately support printing, retention, tracking and follow-up of former HQS inspection documentation and present NSPIRE documentation, reinspection deadlines or enforcement actions. As HUD oversight expectations increased and NSPIRE requirements were implemented, reliance on manual tracking and workarounds created a risk of incomplete documentation and delayed follow-up. While inspections were conducted as required, system constraints limited the PHA's ability to consistently document failed items, record actual passing dates and initiate timely enforcement actions, including HAP abatement. To further strengthen compliance and address these risks, the PHA updated its Administrative Plan effective July 1, 2025, to more clearly define NSPIRE compliance standards, documentation requirements, reinspection timelines, enforcement procedures and abatement actions. STEPS TO IMPROVE: 1. Reinforce NSPIRE inspection procedures previously issued to inspectors, including documentation, notification, reinspection and enforcement requirements. 2. Implement refresher training for inspection staff to ensure consistent application of HUD and PHA NSPIRE policies, including life-threatening and non-life-threatening deficiencies. 3. Require retention of complete HUD-52580 inspection reports for all failed and passed inspections, including accurate documentation of deficiency correction dates. 4. 4. Strengthen review of inspection files to ensure timely follow-up, reinspection scheduling and enforcement actions by the Section 8 Director. 5. Transition inspection tracking and compliance enforcement from our current software company, Ten mast, to a new software company, Yardi, to improve system controls, documentation retention and monitoring capabilities. This implementation should occur in 2026. 6. Apply the updated Administrative Plan effective July 1, 2025, to ensure consistent enforcement of HAP abatement and contract termination requirements. Effective December 1, 2024, the PHA began utilizing NSPIRE to support a more modernized inspection system. Existing landlords were formally notified of the new inspection and enforcement requirements on September 1, 2024. The Section 8 Director will conduct periodic supervisory file reviews to verify that inspection notices, HUD- 52580 reports, reinspection documentation and enforcement actions are properly maintained and timely. The PHA is currently in the process of implementing Yardi as its primary inspection and case-management system. Once fully operational, Yardi will provide enhanced capabilities for tracking failed inspections, monitoring reinspection deadlines, documenting compliance and enforcing HAP abatement in accordance with HUD and NSPIRE requirements. Management will utilize system-generated reports and ongoing internal reviews to identify and promptly address compliance issues. The Section 8 Director acknowledges the deficiencies identified and is committed to strengthening NSPIRE enforcement through improved system controls, clarified policy, staff training and ongoing monitoring. These corrective actions are intended to ensure program integrity, protect tenant safety and maintain compliance with HUD regulations. Additional Remarks: Under our finding, the finding was reported for HOS Enforcement. Our agency changed to the NSPIRE Protocol for inspections as of 12/1/2024. Out of the 25 failed inspections sampled, 7 fell under the previous HQS protocol and the other 18, NSPIRE
HQS inspections will be documented in each tenant’s file in accordance with applicable standards, along with the corresponding inspection log maintained by the PHA. Any required reinspection will also be completed and documented accordingly in the tenant’s file.
HQS inspections will be documented in each tenant’s file in accordance with applicable standards, along with the corresponding inspection log maintained by the PHA. Any required reinspection will also be completed and documented accordingly in the tenant’s file.
FINDING No. 2025-003: Section 8 Project Based Rental Assistance (PBRA), ALN 14.195 Recommendation: The Project should refund security deposits timely. Action Taken: Staff training has been provided and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regardin...
FINDING No. 2025-003: Section 8 Project Based Rental Assistance (PBRA), ALN 14.195 Recommendation: The Project should refund security deposits timely. Action Taken: Staff training has been provided and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO
FINDING No. 2025-002: Section 8 Project Based Rental Assistance (PBRA), ALN 14.195 Recommendation: The Project should rebuild the waiting list based on the date stamps on the original tenant applications and implement procedures to ensure that all future applications are recorded accurately and main...
FINDING No. 2025-002: Section 8 Project Based Rental Assistance (PBRA), ALN 14.195 Recommendation: The Project should rebuild the waiting list based on the date stamps on the original tenant applications and implement procedures to ensure that all future applications are recorded accurately and maintained in chronological order. Action Taken: Staff training has been provided to ensure that there are date stamps on the wait list tenants.
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