Corrective Action Plans

Finding 1227152 (2025-001)

Material Weakness 2025

Senior Citizens Housing Development Corporation of Mt. Lebanon

FL

Cash Management HUD Housing Programs Reporting

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Mt. Lebanon, Inc., respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive,...

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Mt. Lebanon, Inc., respectfully submits the following corrective action plan for the year ended December 31, 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: January 1, 2025 through December 31, 2025 The finding from the December 31, 2025 schedule of findings and questioned costs is discussed below. The finding is 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 the Elderly, ALN 14.157 Recommendation: The Project should implement procedures to monitor the expiration of all contracts to ensure timely preparation and approval. Additionally, the Project should obtain reimbursement for any amounts paid subsequent to the expiration of form HUD-9839-B. Action Taken: Management is in the process of renewing all management certifications and will provide the accountant extra training to monitor and not charge fees for expired certifications. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO

View Audit 409319

Finding 1227107 (2025-008)

Material Weakness 2025

City of Manchester, Nh

NH

Special Tests & Provisions HUD Housing Programs Significant Deficiency § 200.303

2025-008 Community Development Block Grants/Entitlement Grants - Assistance Listing Number 14.218 Recommendation: We recommend the City strengthen procedures and internal controls to ensure that environmental review certifications are prepared and retained, evidencing that the environmental reviews ...

2025-008 Community Development Block Grants/Entitlement Grants - Assistance Listing Number 14.218 Recommendation: We recommend the City strengthen procedures and internal controls to ensure that environmental review certifications are prepared and retained, evidencing that the environmental reviews were completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding:  CIP will update the Environmental Review section of the CIP Procedures Manual to ensure Environmental Reviews are completed and documentation is kept on file. Additionally a SOP will also be created for how to conduct an Environmental Review. Name(s) of the contact person(s) responsible for corrective action:  Chelcie Pinsonneault, Community Grants Manager Planned completion date for corrective action plan:  Planning and Community Development will ensure the implementation of this corrective action plan is completed by October 31, 2026

View Audit 409307

Finding 1227052 (2025-004)

Material Weakness 2025

County of Columbus

NC

HUD Housing Programs

2025-004 Significant Deficiency over Reporting (Repeat Finding) Information on the Federal Program: Low Income Housing Assistance Program (Section 8), Assistance Listing Number 14.871, U.S. Department of Housing and Urban Development. Criteria: Public Housing Agencies (PHAs) are required to submit t...

2025-004 Significant Deficiency over Reporting (Repeat Finding) Information on the Federal Program: Low Income Housing Assistance Program (Section 8), Assistance Listing Number 14.871, U.S. Department of Housing and Urban Development. Criteria: Public Housing Agencies (PHAs) are required to submit timely a Financial Assessment Sub-system (FASS-PH): GAAP-based unaudited and audited financial information electronically to HUD. Name of Contact Person: Heather Woody, Finance Director Corrective Action Plan: The County will continue its efforts to complete audits in a timely manner. The Section 8 program is audited in conjunction with the audit of the county. Proposed Completion Date: December 31, 2026

View Audit 409231

Finding 1227049 (2025-001)

Material Weakness 2025

Brazos Valley Council of Governments

TX

HUD Housing Programs Material Weakness Reporting

We agree with the auditor’s assessment of a state of noncompliance with respect to the 2025 audited REAC submission. However, we do not believe that the noncompliance resulted from weaknesses in BVCOG’s controls over the REAC submission itself; rather, the noncompliance resulted from delays in compl...

We agree with the auditor’s assessment of a state of noncompliance with respect to the 2025 audited REAC submission. However, we do not believe that the noncompliance resulted from weaknesses in BVCOG’s controls over the REAC submission itself; rather, the noncompliance resulted from delays in completing the fiscal year 2025 audit, which must be finished before the REAC audited submission is completed. Ultimately, the audit’s timely completion was delayed because of significant turnover in key positions and unanticipated time requirements to fill those positions. In particular, both the executive director and chief financial officer positions were vacant for several months dating from the end of FY25 well into FY26. Additionally, comptroller and senior accountant positions were open during FY25 and FY26, during the time that audit preparation normally occurs. Because of this, BVCOG achieved audit readiness in early June 2026, a timeframe which did not permit its outside auditors enough time to complete their audit before the REAC submission deadline. As of July 2026, these positions have all been filled. We do not expect that additional corrective action will be necessary to ensure that the 2026 audit and audited REAC submission will be completed timely.

View Audit 409224

Finding 1226974 (2025-005)

Material Weakness 2025

Operation Hope of Fairfield, Inc.

CT

Questioned Costs Subrecipient Monitoring Eligibility

Management has updated the policies and procedures manual to address this finding. For each housing unit, we are using the Department of Housing and Urban Development (HUB) rent reasonableness form at lease signing. This form will be updated annually for each unit. We will also be following the HUD ...

Management has updated the policies and procedures manual to address this finding. For each housing unit, we are using the Department of Housing and Urban Development (HUB) rent reasonableness form at lease signing. This form will be updated annually for each unit. We will also be following the HUD fair market rent determinations.

View Audit 409146

Finding 1226482 (2025-007)

Material Weakness 2025

Reach Community Development, Inc.

OR

Questioned Costs Special Tests & Provisions HUD Housing Programs

REACH has policies in place for annual unit inspections. Management created a new unit inspection form to capture inspection, work orders, and re-inspection in 2025. Portfolio Managers reviewed these new forms with site teams and provided training on how to complete these forms. Property management ...

REACH has policies in place for annual unit inspections. Management created a new unit inspection form to capture inspection, work orders, and re-inspection in 2025. Portfolio Managers reviewed these new forms with site teams and provided training on how to complete these forms. Property management team also sent emails and Teams reminders to the site team to ensure unit inspection, work orders, and re-inspections are completed on time and properly. During the second quarter of 2026, REACH outsourced both property management and compliance functions to a third-party management company to address outstanding compliance issues.

View Audit 409109

Finding 1226481 (2025-006)

Material Weakness 2025

Reach Community Development, Inc.

OR

Eligibility Questioned Costs HUD Housing Programs

REACH has policies in place to ensure recertifications and income verification are performed timely, tenant eligibility is correctly determined, and the tenant files are properly maintained. During the second quarter of 2026, REACH outsourced property management and compliance functions to a third-p...

REACH has policies in place to ensure recertifications and income verification are performed timely, tenant eligibility is correctly determined, and the tenant files are properly maintained. During the second quarter of 2026, REACH outsourced property management and compliance functions to a third-party management company to address the outstanding compliance issues.

View Audit 409109

Finding 1226479 (2025-005)

Material Weakness 2025

Reach Community Development, Inc.

OR

Eligibility Questioned Costs HUD Housing Programs

Once REACH Asset Management Team was notified of this audit finding, our Asset Management team communicated this finding to Ad-West. They would set up a new process to ensure the reporting of HOME units, HOME unit types, and compliance would be met on all HOME units.

View Audit 409109

Finding 1226478 (2025-004)

Material Weakness 2025

Reach Community Development, Inc.

OR

Eligibility Questioned Costs HUD Housing Programs

Once REACH was notified about this audit finding, Property Management established a new review process to review the HOME units that would be re-classified the next time there is a vacant unit of the corresponding size/type. This is a “next available unit” rule. It will be addressed when the existin...

Once REACH was notified about this audit finding, Property Management established a new review process to review the HOME units that would be re-classified the next time there is a vacant unit of the corresponding size/type. This is a “next available unit” rule. It will be addressed when the existing resident moves out. Our third-party Property Management company will continue to monitor this finding.

View Audit 409109

Finding 1226477 (2025-003)

Material Weakness 2025

Reach Community Development, Inc.

OR

Eligibility Questioned Costs HUD Housing Programs

REACH’s 2024 consolidated audit report was issued in mid-November 2025. Once we were notified about this audit finding, Compliance Management conducted an in-depth review of this finding and determined that one extra 3-bedroom and one fewer 4-bedroom at Covington Commons were incorrectly set up in o...

REACH’s 2024 consolidated audit report was issued in mid-November 2025. Once we were notified about this audit finding, Compliance Management conducted an in-depth review of this finding and determined that one extra 3-bedroom and one fewer 4-bedroom at Covington Commons were incorrectly set up in our Yardi system. REACH have since corrected this issue in the Yardi system. REACH will continue to monitor vacant two-bedrooms at Cascadia Village as they become available. There are only two 2-bedrooms that are not designated as HOME. We noted that unit #72 was not set up properly in our Yardi system. REACH have corrected this issue in the system.

View Audit 409109

Finding 1226476 (2025-002)

Material Weakness 2025

Reach Community Development, Inc.

OR

Eligibility Questioned Costs HUD Housing Programs

REACH’s 2024 consolidated audit report was issued in mid-November 2025. REACH has policies and procedures in place to monitor compliance of recertifications, and correct income verification procedures are performed timely. Once we were notified of this finding, Compliance Management Compliance team ...

REACH’s 2024 consolidated audit report was issued in mid-November 2025. REACH has policies and procedures in place to monitor compliance of recertifications, and correct income verification procedures are performed timely. Once we were notified of this finding, Compliance Management Compliance team conducted a full review of all HOME regulatory agreements in the portfolio, including County, City and Commerce HOME funding. Compliance Management also created a spreadsheet to track which units are due for the appropriate HOME recertification.

View Audit 409109

Finding 1226338 (2025-002)

Material Weakness 2025

Retired Steelworkers Housing and Health Development Corporation

FL

HUD Housing Programs Reporting Eligibility

FINDING No. 2025-002: Section 236 Interest Reduction Payments, ALN 14.103 Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV repo...

FINDING No. 2025-002: Section 236 Interest Reduction Payments, ALN 14.103 Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

View Audit 408975

Finding 1226337 (2025-001)

Material Weakness 2025

Retired Steelworkers Housing and Health Development Corporation

FL

HUD Housing Programs Reporting

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite...

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 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: January 1, 2025 through December 31, 2025 The findings from the December 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 236 Interest Reduction Payments, ALN 14.103 Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Action Taken: We are researching the underfunding and will ensure the RR account is fully funded on a monthly basis. New procedures have been implemented to review the deposits each month to ensure amounts are proper.

View Audit 408975

Finding 1226206 (2025-003)

Material Weakness 2025

Thomasville Housing Authority

NC

HUD Housing Programs

Submission of Required Forms Condition - During the audit, we noted that the HUD-53001 form was not completed or filed with HUD as required. Cause - The Authority thought this was already submitted for the grant years, but there was Miscommunication Plan of Action - The Housing Authority will implem...

Submission of Required Forms Condition - During the audit, we noted that the HUD-53001 form was not completed or filed with HUD as required. Cause - The Authority thought this was already submitted for the grant years, but there was Miscommunication Plan of Action - The Housing Authority will implement procedures to ensure compliance with the above regulations as it relates to all federal awards. Person Responsible: Ms. Rosemary Steele (Executive Director) Period of Action: The review will ensure compliance with the above regulations as it relates to all federal awards. If you have any further questions, please advise.

View Audit 408852

Finding 1226187 (2025-003)

Material Weakness 2025

Low Rent Housing Agency of Burlington

IA

HUD Housing Programs

In the future all public housing files for both the Section 8 Voucher Program and Public Housing Program will have a checklist of required items. The checklist will be verified and documented by either the Executive Director or qualified employee. This will include who performed the review, the date...

In the future all public housing files for both the Section 8 Voucher Program and Public Housing Program will have a checklist of required items. The checklist will be verified and documented by either the Executive Director or qualified employee. This will include who performed the review, the date, and items reviewed.

View Audit 408828

Finding 1226186 (2025-002)

Material Weakness 2025

Low Rent Housing Agency of Burlington

IA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Questioned Costs

To properly ensure internal controls, all segregation of duties will be documented beyond what is currently being done. For additional oversight of monthly reconciliation, it will be documented that this has had a secondary review. Additionally, a board member or another individual will review month...

To properly ensure internal controls, all segregation of duties will be documented beyond what is currently being done. For additional oversight of monthly reconciliation, it will be documented that this has had a secondary review. Additionally, a board member or another individual will review monthly bank statements, invoices, and related documentation. The board will review policy and focus on stricter internal controls to prevent any form of fraud.

View Audit 408828

Finding 1226116 (2025-001)

Material Weakness 2025

Kokomo Housing Authority

IN

HUD Housing Programs Reporting

2025-001 – ALN 14.871 – Housing Voucher Cluster – Eligibility – Payment Standards Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. D. Steele, Chief Executive...

2025-001 – ALN 14.871 – Housing Voucher Cluster – Eligibility – Payment Standards Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. D. Steele, Chief Executive Officer Projected Completion Date: December 31, 2026

View Audit 408789

Finding 1226107 (2025-002)

Material Weakness 2025

City of Hempstead, Texas

TX

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs § 200.303 § 200.328

Finding 2025-002: Insufficient Documentation of Management Review of Section 3 Quarterly and Annual Reporting Planned Corrective Action: Management concurs with the finding. Although the related grant concluded during fiscal year 2025, the City will implement procedures to ensure that future federal...

Finding 2025-002: Insufficient Documentation of Management Review of Section 3 Quarterly and Annual Reporting Planned Corrective Action: Management concurs with the finding. Although the related grant concluded during fiscal year 2025, the City will implement procedures to ensure that future federal program reports, including any applicable Section 3 or similar compliance reports, are subject to documented management review and approval prior to submission. The procedures will require the preparer to provide each report and supporting documentation to City management for review, and evidence of approval, such as a signed review checklist, email approval, or electronic sign-off, will be retained in the grant files. The City Secretary will be responsible for ensuring that documented review and approval procedures are applied to future federal reporting requirements. Anticipated Completion Date: July 2026

View Audit 408755

Finding 1226097 (2025-002)

Material Weakness 2025

Magnolia Manor of MacOn Supportive Housing, Inc.

GA

HUD Housing Programs Special Tests & Provisions

Magnolia Manor of Macon (Pacesetter Manor) has identified a posting error for a resident date of discharge that resulted in an overpayment by HUD. The correction has been submitted to HUD for processing/recovery of this overpayment. Beginning with the quarter ending June 30, 2026, we will implement ...

Magnolia Manor of Macon (Pacesetter Manor) has identified a posting error for a resident date of discharge that resulted in an overpayment by HUD. The correction has been submitted to HUD for processing/recovery of this overpayment. Beginning with the quarter ending June 30, 2026, we will implement a review of our census & billing system records for admissions and discharges and compare them to what has been submitted to HUD to ensure consistent/accurate recordkeeping. This review will take place by the end of the calendar month following the end of the calendar quarter. The facility Administrator has ultimate responsibility for ensuring that the review & reconciliation is complete. As this is an audit related item, the Magnolia Manor Director of Finance will monitor compliance annually in advance of the annual audit. Any items found to be incorrect will be investigated and resolved as part of the review process with any necessary adjustments submitted by the next processing cycle.

View Audit 408753

Finding 1226096 (2025-001)

Material Weakness 2025

Magnolia Manor of MacOn Supportive Housing, Inc.

GA

HUD Housing Programs Special Tests & Provisions

Magnolia Manor of Macon (Pacesetter Manor) has implemented an annual review schedule for the facility Administrator, Maintenance Supervisor and Community Relations Director to review and ensure that the annual physical inspection of all residential units has been completed. The review window will be...

Magnolia Manor of Macon (Pacesetter Manor) has implemented an annual review schedule for the facility Administrator, Maintenance Supervisor and Community Relations Director to review and ensure that the annual physical inspection of all residential units has been completed. The review window will be between April 1st and July 15th of each year. The facility Administrator has ultimate responsibility for ensuring that the inspections are complete. As this is an audit related item, the Magnolia Manor Director of Finance will monitor compliance annually in advance of the annual audit. Any units found not to have a physical copy of that fiscal year’s inspection report, will be re-inspected and documented before July 31st. A copy of each physical inspection report will be kept in a three-ring binder by the facility Administrator or their designee, as well as scanned into a network storage location.

View Audit 408753

Finding 1226022 (2025-003)

Material Weakness 2025

Brush Hill Development Corporation

MA

HUD Housing Programs

Management is committed to implementing timely reconciliations and review procedures for key accounts to support quality and timely financial reporting. Management plans to work with their new outsourced accountants to have timely and accurate reporting.

View Audit 408724

Finding 1226017 (2025-001)

Material Weakness 2025

Gethsemane Manor Housing Development Fund Co., Inc.

NY

HUD Housing Programs

Finding #2025-001 Current Year Audit Submission to REAC was late: Recommendation: We recommend that management implement procedures to ensure that audit material is provided to the auditor in a timely manner to produce the audit for the REAC submission within 90-days. Action taken: Gethsemane Manor ...

Finding #2025-001 Current Year Audit Submission to REAC was late: Recommendation: We recommend that management implement procedures to ensure that audit material is provided to the auditor in a timely manner to produce the audit for the REAC submission within 90-days. Action taken: Gethsemane Manor Apartments agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Dawn Olmstead, VP – Director of Asset Management, at (315) 337-1401.

View Audit 408708

Finding 1226011 (2025-002)

Material Weakness 2025

Housing Authority of the City of Greensboro

NC

HUD Housing Programs Special Tests & Provisions

Finding 2025-002 – Section 8 Project-Based Voucher Program – Eligibility; Special Tests and Provisions – Waitlist Selection & Management Noncompliance and Significant Deficiency Housing Choice Voucher Program - ALN #14.871 Correction Action Plan: The Greensboro Housing Authority (GHA) will continue ...

Finding 2025-002 – Section 8 Project-Based Voucher Program – Eligibility; Special Tests and Provisions – Waitlist Selection & Management Noncompliance and Significant Deficiency Housing Choice Voucher Program - ALN #14.871 Correction Action Plan: The Greensboro Housing Authority (GHA) will continue implementing enhancements within its operating software platform (YARDI) to streamline and automate waitlist selection and management oversight through the following actions: • GHA immediately conducted a thorough assessment of the wait list process and implemented ongoing monitoring and quality assurance reviews, file checks, and internal audits to ensure sustained compliance. Accountability measures include management sign off for elderly designated selections, tracking within YARDI of documentation completeness, and performance expectations aligned with compliance standards. • Without delay, GHA immediately implemented real time system usage by requiring and prohibiting reliance on static reports. GHA is conducting a retrospective review to identify any applicants improperly bypassed and take corrective action as warranted. • GHA will provide ongoing mandatory training on eligibility criteria, preference application, YARDI usage, and compliance requirements to ensure team member proficiency in the wait list selection process. • GHA will conduct a comprehensive review and correction of YARDI system configurations to ensure alignment with the HCVP Administrative Plan, including proper implementation of grandfathering workflows. A reconciliation will be performed to identify potentially affected applicants and determine appropriate remediation. • GHA is working with YARID to implement standardized documentation and applicant management protocols across all stages of the waitlist and eligibility process, supported by system based workflow controls that require status updates prior to advancement. Anticipated Completion Date: Corrective actions are being implemented immediately and will be continuously monitored. GHA anticipates stabilization and sustained improvement no later than December 31, 2026. Responsible Parties: Carmen Maniak, Vice President of Property Management

View Audit 408690

Finding 1226010 (2025-001)

Material Weakness 2025

Housing Authority of the City of Greensboro

NC

HUD Housing Programs

Finding 2025 001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance & Significant Deficiency Housing Choice Voucher Program – ALN #14.871 Correction Action Plan: The Greensboro Housing Authority (GHA) will continue implementing enhanced systems, ...

Finding 2025 001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance & Significant Deficiency Housing Choice Voucher Program – ALN #14.871 Correction Action Plan: The Greensboro Housing Authority (GHA) will continue implementing enhanced systems, controls, and oversight processes to correct internal control deficiencies within the Housing Choice Voucher Program (HCVP) participant files through the following actions: • In 2025, GHA strengthened its organizational oversight and internal controls by appointing new Vice Presidents for the Voucher Administration and Property Management divisions. • To further mitigate risk and ensure consistent compliance, GHA will continue strengthening its internal control framework through: o Enhancing file reviews using a risk based monitoring model; o Performing expanded file reviews withing the first and second quarters; and o Prioritizing targeted oversight of higher risk actions and key regulatory requirements. • GHA will conduct ongoing internal reviews, and augment third-party reviews of selected files throughout the year to identify deficiencies, implement corrective actions, and proactively address emerging risk areas. • GHA will implement preventive controls by reinforcing upfront income and asset verification requirements and requiring management review prior to certification approval to mitigate errors. • GHA will continue providing targeted training to HCVP team members, informed by the results of reviews conducted, to bolster team member proficiency. • GHA will also continue implementing improvements within its corporate software operating system (YARDI) to streamline and automate HCVP workflows. These improvements will: o Improve timeliness and accuracy of annual and interim recertifications; o Strengthen documentation controls and file completeness; and, o Enhance file readiness through standardized, system-based workflows. Anticipated Completion Date: Corrective actions are being implemented immediately and will be continuously monitored. GHA anticipates stabilization and sustained improvement no later than December 31, 2026. Responsible Parties: Donna Mills, Vice President of Voucher Administration Carmen Maniak, Vice President of Property Management

View Audit 408690

Finding 1226002 (2025-001)

Material Weakness 2025

Meadow Lane Housing Development Fund Company, Inc.

NY

Eligibility Questioned Costs HUD Housing Programs

An age waiver has been submitted to HUD and is currently being reviewed. We are awaiting their decision. While we await a decision, Meadow Lane will review all existing application for eligibility and advise any existing applicants who are not of age that they are no longer eligible via mail. Antici...

An age waiver has been submitted to HUD and is currently being reviewed. We are awaiting their decision. While we await a decision, Meadow Lane will review all existing application for eligibility and advise any existing applicants who are not of age that they are no longer eligible via mail. Anticipated Completion Date: Pending HUD approval of age waiver

View Audit 408679

Corrective Action Plans

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