Corrective Action Plans

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Veterans Place of Washington Boulevard, Inc. submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Herbein + Company, Foster Plaza 10, 680 Andersen Drive, Suite 205, Pittsburgh, PA 15220 Audit period: Year ended Dec...
Veterans Place of Washington Boulevard, Inc. submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Herbein + Company, Foster Plaza 10, 680 Andersen Drive, Suite 205, Pittsburgh, PA 15220 Audit period: Year ended December 31, 2024 The finding from the December 31, 2024 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. Section III - Federal Award Findings and Questioned Costs 2024-001 MISSING DOCUMENTATION AND DUPLICATE INVOICE SUBMISSION - MATERIAL WEAKNESS Federal Program Economic Development Initiative, Community Project Funding and Miscellaneous Grants - ALN 14.251 Criteria In order to be allowable under federal awards, costs must meet general criteria, which includes adequate documentation. Under OMB guidance, Public Law (Pub. L) No. 116-117, Payments Integrity Information Act of 2019, and Executive Order 13520 on reducing improper payments, federal agencies are required to take actions to prevent improper payments, review federal awards for such payments, and as applicable, recover improper payments, including any duplicate payment. Condition While performing tests over activities allowed or unallowed and allowable costs/cost principles, we noted documentation for one invoice charged to the grant could not be located. As a result, we were unable to determine that the cost was allowable per the terms of the grant award. We also noted that a second invoice charged to the grant was submitted for reimbursement twice. Cause This is a new grant in the current year to cover the portion of the cost for a new building. While management submitted invoices to the Department of Housing and Urban Development for review and approval prior to reimbursement, they did not maintain a record of the costs submitted for each reimbursement request by either listing the invoices and amounts charged or other means. Effect The Organization was unable to provide documentation for one of the invoices charged to the program, and a second invoice was charged to the program twice. Questioned Costs $54,461 Context The grant was for a portion of construction costs with the difference coming from donations or other assets of Veterans Place of Washington Boulevard, Inc. In order to receive reimbursement for expenses, the Organization was required to submit invoices to the Department of Housing and Urban Development (HUD) for approval prior to uploading the invoices for reimbursement. The expenses in question were approved by HUD prior to requesting or receiving reimbursement. Furthermore, there were approximately $96,000 of construction costs that were incurred but not reimbursed by HUD that appear to meet the terms and conditions of the grant. Repeat Finding No Recommendation We recommend that detailed documentation of the costs submitted for reimbursement are maintained in a separate file so that costs charged to the program are easily identified. Management Response In the situation concerning our inability to identify invoices associated with a requested reimbursement, costs for a particular area were submitted for review and approval by HUD and the costs were not clearly attributed to one singular invoice but reflected as portions of the total invoice submitted by one vendor. In the future, when requesting reimbursement, costs will be more clearly indicated to a specific invoice and identified so they can be more easily tracked. In the case of a duplicate invoice, we typically checked against our records of paid invoices and in this case, our belief was that it was paid but not marked as submitted for reimbursement. In the future, invoices will be verified against both our record of paid invoices as well as a separate record of reimbursed invoices.
View Audit 369640 Questioned Costs: $1
2024-003. Special Tests and Provisions United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: There were instances in which comparable rents for the area were not documented and maintained in tenant files. Recommendation: The Organization should im...
2024-003. Special Tests and Provisions United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: There were instances in which comparable rents for the area were not documented and maintained in tenant files. Recommendation: The Organization should implement procedures for supervisory review of documentation and approval for all tenant files to ensure reasonable rent charged is demonstrated. Corrective Action: The Organization will ensure written documentation is maintained in tenant files, to support that the grant funds to pay rent were used for reasonable rent in relation to comparable rent in the area. Responsible Contact Person(s): Louis Bamonte, Director of Finance Brighter Tomorrows, Inc., - P.O. Box 706 – Shirley, New York 11967 Anticipated Completion Date: December 31, 2025.
Replacement Reserves Funding Auditee agrees that twelve monthly payments were not made to the replacement reserve for the fiscal year ended December 31, 2024. We recommend that management make an additional deposit funding the shortfall as soon as possible to fully fund the replacement reserve. Audi...
Replacement Reserves Funding Auditee agrees that twelve monthly payments were not made to the replacement reserve for the fiscal year ended December 31, 2024. We recommend that management make an additional deposit funding the shortfall as soon as possible to fully fund the replacement reserve. Auditee has submitted a HUD-9250 request for the suspension of deposits to the replacement reserve account for 2025 and will fund the shortfall as soon as adequate funding from operations is available and will consult with HUD for future use on operations.
Unauthorized Replacement Reserve Withdrawal Auditee agrees that an unauthorized withdrawal of $6,720.61 was made from replacement reserve account. We recommend that management evaluate its internal controls and implement policies to mitigate the chances of withdrawing funds from the replacement rese...
Unauthorized Replacement Reserve Withdrawal Auditee agrees that an unauthorized withdrawal of $6,720.61 was made from replacement reserve account. We recommend that management evaluate its internal controls and implement policies to mitigate the chances of withdrawing funds from the replacement reserve account without HUD approval. Auditee has submitted a funds authorization withdrawal request for the replacement reserve withdrawal. Funds were transferred to the replacement reserve account and the Auditee is in the process of subsequently gaining approval.
Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request ...
Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request a waiver if allowed. Views of Responsible Officials and Planned Corrective Actions –Management will calculate an estimated surplus cash calculation amount and deposit them into the residual receipts account within the required time frame. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – Once the funds are received.
View Audit 369603 Questioned Costs: $1
Recommendation – Management needs to monitor the reserve for replacement account and when funds are borrowed, they need to comply with the terms of the agreement. Views of Responsible Officials and Planned Corrective Actions – Management will track any loans from the Replacement Reserve account and ...
Recommendation – Management needs to monitor the reserve for replacement account and when funds are borrowed, they need to comply with the terms of the agreement. Views of Responsible Officials and Planned Corrective Actions – Management will track any loans from the Replacement Reserve account and reimburse the Replacement Reserve account once the HUD subsidy is received. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – Deposited repayment September 26, 2025
View Audit 369603 Questioned Costs: $1
Condition: During the tenant file testing for the Public Housing program, we reviewed a sample of forty tenant files and identified deficiencies in the Authority's documentation and reporting practices: 1. For two tenants the rent amounts did not match the amounts documented on the HUD-50058 forms. ...
Condition: During the tenant file testing for the Public Housing program, we reviewed a sample of forty tenant files and identified deficiencies in the Authority's documentation and reporting practices: 1. For two tenants the rent amounts did not match the amounts documented on the HUD-50058 forms. 2. For seven tenants the unit inspection forms were not available. Questioned Costs: $3,251 Recommendation: We recommend that the Authority enhance its internal control environment to ensure compliance with HUD requirements under Assistance Listing 14.850. This includes implementing procedures to verify that all required documentation-such as Unit Inspection records-is consistently obtained and retained in tenant files. Additionally, the Authority should establish a reconciliation process to confirm that rent amounts charged align with those calculated on the HUD-50058 forms. Planned Corrective Action: During 2024 there were some employee changes in Public Housing management as well as a computer virus that affected our server. We have implemented new procedures to include a hard copy of required documents as well as an electronic copy. The Senior Public Housing manager will also be conducting file reviews to verify that these records are complete for each tenant file. The housing authority changed software vendors during 2024. The software is designed to calculate rent amounts and report that amount on the HUD 50058 form. The conversion between the two software systems led to inaccurate information on the HUD- 50058. This should not be an ongoing issue as the conversion has been completed and corrections made.
View Audit 369599 Questioned Costs: $1
Finding 2024-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements:...
Finding 2024-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Inspections. Per the Authority's HCV Admin Plan, the PHA must inspect the unit leased to a family at least annually to determine if the unit meets HQS standards and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management there were inspection reports that were unavailable for examination at the time of audit. Context: Of a sample size of thirty-three (33) units, two (2) units did not have annual HQS inspections performed timely. Our sample size is statistically valid. Known Questioned Costs: $5,004 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance related to HQS inspections in accordance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the significant deficiency in the Housing Voucher Cluster Programs and will implement internal control procedures that will ensure compliance with federal regulations. Joanna Lara, Director of Housing Administration is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring by December 31, 2025.
View Audit 369595 Questioned Costs: $1
Significant Deficiency in Internal Control over Compliance, Other Matters – Annual HQS Inspection Housing Choice Voucher Program – Assistance Listing No. 14.871 – HQS Enforcement Recommendation: We recommend that the Authority implement processes to ensure that inspections are completed on time. Exp...
Significant Deficiency in Internal Control over Compliance, Other Matters – Annual HQS Inspection Housing Choice Voucher Program – Assistance Listing No. 14.871 – HQS Enforcement Recommendation: We recommend that the Authority implement processes to ensure that inspections are completed on time. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has implemented enhanced procedures to ensure timely completion of Housing Quality Standards (HQS) inspections. A scheduling and tracking system has been established to monitor upcoming inspections, and staff have been trained on these updated procedures. Additionally, the HCV supervisor conducts weekly reviews to ensure inspections are completed on schedule and any delays are addressed promptly. Name(s) of the contact person(s) responsible for corrective action: Lanesha Combs, Vice President of Housing Choice Voucher Program Planned completion date for corrective action plan: December 31, 2025 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Hector Ordonez, Vice President of Finance and Administration at (817) 333-3421 or hordonez@fwhs.org.
Significant Deficiency in Internal Control over Compliance, Other Matters – Rent Reasonableness Housing Choice Voucher Program – Assistance Listing No. 14.871 - Rent Reasonableness Recommendation: We recommend that the Authority implement processes to ensure that rent reasonableness determinations a...
Significant Deficiency in Internal Control over Compliance, Other Matters – Rent Reasonableness Housing Choice Voucher Program – Assistance Listing No. 14.871 - Rent Reasonableness Recommendation: We recommend that the Authority implement processes to ensure that rent reasonableness determinations are completed on time. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has strengthened its internal controls to ensure timely completion of rent reasonableness determinations. We will implement a tracking process in the department to flag upcoming rent reasonableness reviews before the deadline. Staff have been trained on the updated procedures, and a monthly compliance review will be conducted by the HCV supervisor to verify that all determinations are completed on time and documented appropriately. Name(s) of the contact person(s) responsible for corrective action: Lanesha Combs, Vice President of Housing Choice Voucher Program Planned completion date for corrective action plan: December 31, 2025
Corrective Action Plan: The ARC of Delaware will ensure that there are appropriate procedures in place to ensure that the required calculation of surplus cash is completed with 60-days of year end. ARC of Delaware will also ensure that individuals have appropriate access to HUD Reporting tools to en...
Corrective Action Plan: The ARC of Delaware will ensure that there are appropriate procedures in place to ensure that the required calculation of surplus cash is completed with 60-days of year end. ARC of Delaware will also ensure that individuals have appropriate access to HUD Reporting tools to ensure timely calculation. Contact Person Responsible for Correction Action: Stanley Kihara, Controller Completion Date:
Corrective Action Plan: The ARC of Delaware will update monthly replacement reserve deposit amounts upon notification from HUD. The Arc will perform an analysis every 30 days to ensure deposits have been made for the appropriate amount. ARC completed this corrective action plan when it was notified ...
Corrective Action Plan: The ARC of Delaware will update monthly replacement reserve deposit amounts upon notification from HUD. The Arc will perform an analysis every 30 days to ensure deposits have been made for the appropriate amount. ARC completed this corrective action plan when it was notified during the prior period single audit. Contact Person Responsible for Correction Action: Stanley Kihara, Controller Completion Date: July 15, 2024
Greenwich Communities' Response This finding is mainly due to delays in the processing/payment of utility invoices which was in part attributed to staff shortage in accounts payable and increase in the number of properties under management, whereby the volume of utility invoices increased. In August...
Greenwich Communities' Response This finding is mainly due to delays in the processing/payment of utility invoices which was in part attributed to staff shortage in accounts payable and increase in the number of properties under management, whereby the volume of utility invoices increased. In August 2024, we hired an accountant where his responsibilities include the accounting for utility expenses. We have implemented additional procedures to straighten utility processing to ensure invoices are processed/paid timely including a process to maintain monthly analysis of utility expenses to track invoices and to ensure invoices are processed timely and/or accrued. We also perform variance analysis of expenses whereby significant variations are investigated and resolved. Effective for 2024/2025 utility cost reporting, we have implemented a robust review process whereby the utility cost reports will be prepared by the staff accountant, reviewed by the Controller with final approval by the Chief Financial Officer. We understand that given the timing, this may be a repeat finding for fiscal year December 31, 2025.
September 29, 2025 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully’s Trail Pittsfor...
September 29, 2025 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully’s Trail Pittsford, NY 14534 Audit Period: January 1, 2024 – December 31, 2024 The findings from the December 31, 2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARD PROGRAMS AUDIT FINDING 2024-001: Section 232, CFDA 14.129 Recommendation: Adhere to the HUD regulatory agreement in relation to obtaining prior written approval from HUD before encumbering the Project. Action Taken: The Home obtained the additional related-party loan as a prudent business decision to meet operating expenses. The Home has implemented procedures to ensure that prior written approval is obtained from HUD before encumbering the Project in the future. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Sabrina McLeod at (585)-760-1401. Sincerely yours, _______________________________ Sabrina McLeod Chief Financial Officer
Contact Person(s): Calli Clevinger and Cobie Sparks-Howard Corrective Actions in Progress: 1. Policy Reinforcement: Staff will be re-trained on Wellspring’s rent reasonableness policy, with emphasis on the requirement to include comparable unit data on every form. 2. Integration with Move-In Assessm...
Contact Person(s): Calli Clevinger and Cobie Sparks-Howard Corrective Actions in Progress: 1. Policy Reinforcement: Staff will be re-trained on Wellspring’s rent reasonableness policy, with emphasis on the requirement to include comparable unit data on every form. 2. Integration with Move-In Assessment: The rent reasonableness form will now be a required document attached to the move-in assessment. A unit will not be approved for move-in until the rent reasonableness form is fully completed and attached. 3. Secondary Review: Supervisors will conduct a review of all move-in assessments, including the attached rent reasonableness form, prior to final approval. Anticipated Completion Date: Staff re-training: Completed by September 30, 2025 Integration of rent reasonableness into move-in assessment in Salesforce: October 2025 Secondary review and monitoring: Ongoing, beginning immediately Expected Outcome: These actions will ensure that all future rent reasonableness forms are completed, attached to the move-in assessment, and reviewed prior to approval of move-in. This will bring Wellspring into full compliance with both internal policy and audit requirements.
Action Taken: The Project is waiting for HUD’s approval on the waiver. If the waiver is denied the sponsor will return the distributed funds in excess of the amount allowed by the GPR grant terms and deposit them into a Residual Receipts account. If the waiver is approved the sponsor will be allowed...
Action Taken: The Project is waiting for HUD’s approval on the waiver. If the waiver is denied the sponsor will return the distributed funds in excess of the amount allowed by the GPR grant terms and deposit them into a Residual Receipts account. If the waiver is approved the sponsor will be allowed to retain the distributed funds.
View Audit 369518 Questioned Costs: $1
2024-002 – Allowable Activities – Moving to Work Demonstration Program - 14.881 Significant Deficiency Statement of Condition and Criteria The Authority does not appropriately evaluate and settle inter-program balances on a periodic basis. The Authority is required to implement and utilize HUD progr...
2024-002 – Allowable Activities – Moving to Work Demonstration Program - 14.881 Significant Deficiency Statement of Condition and Criteria The Authority does not appropriately evaluate and settle inter-program balances on a periodic basis. The Authority is required to implement and utilize HUD program funds in accordance with activities approved in the annual MTW plan. Recommendation We recommend the Authority evaluate and update the system coding of interfund transactions to assist with periodic settlement of balances. In addition, operating transfers should be identified and differentiated from the routine, reciprocal transactions and treated according to their purpose to assist with management of cash balances. Corrective Action The Authority is converting its accounting software to better enable it to manage the various activities of the Authority. Upon conversion, all program balances are to be formally settled. In addition, a process is being developed to capture and identify transactions generated by MTW funded activities to assist with timely and accurate recording.
2024-001 – Eligibility – Moving to Work Demonstration Program - 14.881 Significant Deficiency Statement of Condition and Criteria The audit noted instances of late recertifications. PHA’s are required to determine income eligibility, calculate participant rent and housing assistance payments in acco...
2024-001 – Eligibility – Moving to Work Demonstration Program - 14.881 Significant Deficiency Statement of Condition and Criteria The audit noted instances of late recertifications. PHA’s are required to determine income eligibility, calculate participant rent and housing assistance payments in accordance with approved MTW plan and HUD regulations. Recommendation We recommend the Authority continue its work in addressing staff workload and review document workflow to ensure tasks are carried out on schedule. Corrective Action There will be an intensive focus on program integrity throughout the programs, including staff capability, training and monitoring. In addition, the Authority is converting its programmatic and accounting software to better enable it to manage the various activities of the Authority.
Corrective Action: The finding was a result of prior staff that was replaced in the current fiscal year. Management has designated a resident intake and compliance manager to be responsible for monitoring tenant recertification schedule across all HOME-assisted unites. Any exceptions will be correct...
Corrective Action: The finding was a result of prior staff that was replaced in the current fiscal year. Management has designated a resident intake and compliance manager to be responsible for monitoring tenant recertification schedule across all HOME-assisted unites. Any exceptions will be corrected immediately and reported to management.
At the time of the audit period, TRAC was newly independent from CitySquare and had not yet integrated supervisor approval of timecards into its internal control systems. This gap contributed to missing approvals during the transition year. As of September 2024, TRAC implemented employee and supervi...
At the time of the audit period, TRAC was newly independent from CitySquare and had not yet integrated supervisor approval of timecards into its internal control systems. This gap contributed to missing approvals during the transition year. As of September 2024, TRAC implemented employee and supervisor approvals of timecards within the time keeping system. Additionally, the organization has and will continue to implement a thorough review process that will include the following:  Employee acknowledgement of their individual grant allocation  Employee approval of their timecard  Manager acknowledgment of their individual grant allocation as well as the allocation of each employee they supervise  Manager approval of each employee’s timecard  The finance team will review each timecard individually prior to charging salary costs to grants. This process ensures that time and effort documentation is complete, approved, and compliant with federal and state requirements. Compliance with this policy will be monitored monthly by the Finance Director to ensure continued adherence.Completion Date: October 1, 2025.Responsible Parties: Nicole Binkley, Chief Executive Officer Josh Runnels, Director of Finance and Operations
The security deposit was refunded to the tenant on the 58th day subsequent to their move-out. Management has taken measures to improve internal controls over compliance related to tenant security deposit refunds.
The security deposit was refunded to the tenant on the 58th day subsequent to their move-out. Management has taken measures to improve internal controls over compliance related to tenant security deposit refunds.
All five (5) properties were SOLD
All five (5) properties were SOLD
View Audit 369463 Questioned Costs: $1
We have hired an outside independent company, Infinity File Compliance, LLC to work with us on updating and maintaining all HUD documentation requirements. We are working on applying all the new policies and procedures and will be implementing trainings to ensure future compliance.
We have hired an outside independent company, Infinity File Compliance, LLC to work with us on updating and maintaining all HUD documentation requirements. We are working on applying all the new policies and procedures and will be implementing trainings to ensure future compliance.
Management has updated its compliance responsibility procedures to clarify roles and responsibilities and to ensure accountabilities for all federal reporting requirements. Specifically: • A compliance calendar will be established to track all non-standard reporting deadlines (other than monthly or ...
Management has updated its compliance responsibility procedures to clarify roles and responsibilities and to ensure accountabilities for all federal reporting requirements. Specifically: • A compliance calendar will be established to track all non-standard reporting deadlines (other than monthly or quarterly cost reimbursement grant request). • Responsibility for preparing and submitting DRGR reports has been formally assigned to Finance Department. • Verification procedures have been implemented to confirm that all reports are filed timely. • Periodic internal reviews will be conducted to ensure compliance with reporting requirements.
Authority's Response and Planned Corrective Action: Management agrees with the Auditors' finding and will implement the required updates and safeguards to ensure that the Authority complies with Section 19 of the ACC to remedy the aforementioned deficiencies. Donald Paredez, Executive Director, is r...
Authority's Response and Planned Corrective Action: Management agrees with the Auditors' finding and will implement the required updates and safeguards to ensure that the Authority complies with Section 19 of the ACC to remedy the aforementioned deficiencies. Donald Paredez, Executive Director, is responsible for implementing this corrective action by December 31, 2025.
View Audit 369361 Questioned Costs: $1
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