Corrective Action Plans

Noncompliance with Period of Performance (Public Housing Capital Fund ALN 14.872) We will implement controls to ensure that the amounts reported in ELOCCS for obligations and expenditures are properly supported by an underlying contract or invoice. Date of completion: Ongoing

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. Finding 2024-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021(2021-001), 2022(2022-001), and 2023 (2023-001) Maher Duessel Finding Condition: During our review of 40 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted four instances where a tenant recertification using the HUD-50058, Family Report (Form) (which provides eligibility and reporting information) was not completed, on a timely basis. We also noted one instance where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 was not provided. This includes items such as support for income calculation and medical deductions. These exceptions indicate a lack of functioning internal controls and oversight to ensure compliance with HUD requirements related to timely and accurate tenant recertifications. HACP Management Response/Action Taken: Action Taken: The HACP will continue to monitor and train staff regarding processes and procedures, to include and not limited to the Housing and Urban Development's (HUD) hierarchy of income verification. As noted in previous responses, the HACP continues to experience challenges in hiring and retaining staff as a result of the complexity of the Housing Choice Voucher (HCV) Program. In fiscal year (FY) 2024, the HCV Department had a significant turnover in both line and managerial staff. The HACP promoted an aggressive hiring plan to attract new talent to fill vacant positions due to the great resignation that the HACP, along with other national Agencies, continue to experience. In addition, the HACP has adopted the policy of hiring more staff than needed in the event of turnover. The HACP will continue to utilize the Internal Compliance (IC) Department to review recertifications and compile audit report cards based on the accuracy of recertifications reviewed. The audit report cards are used as an additional management tool to determine whether additional training is needed for staff and the department in general. The HACP continues to: • Send notices regarding re-certifications 120 days in advance of the due date, o Send 10-day notices for missing AR documents o Send 30-day notices when there is no or insufficient response to the 10 day notice sent • Require Managers to review reports to assure timely submission of re-certifications, • Utilize the IC Department to review and sample files from the Occupancy and the HCV portfolio, • Offer periodic staff training on re-certification, • Offer participants the use of technology to complete paperwork In addition to the above noted internal controls, the HACP will institute Bob.ai in FY 2026 as an additional tool to notify both the participant and the HACP staff when the recertifications are due and provide notification of missing documents. The One Stop Shop (OSS) is staffed with three (3) full-time staff members to receive information from participants and landlords to provide timely customer service. In July of 2024, the OSS was equipped with computers for the public to access HACP staff virtually. The use of the computers allows staff to interact with participants regarding minor issues without having the staff physically come to the OSS, thus saving time and money for both the external customer and the Authority. The opening of the One Stop Shop has been successful in receiving the public and responding to concerns.

Corrective Action Management has issued a formal response to HUD’s Finding dated September 30, 2024, outlining specific corrective actions and considers the corrective actions satisfactorily implemented as of September 11, 2025. The Authority’s Chief Finance Officer, Tracy Gann, has assumed responsibility for the continued execution of the corrective actions.

Finding Number 2024-006: Special Tests and Provisions – Material Weakness in Internal Control Over Compliance and Noncompliance Corrective Action: Management will enhance and enforce policies to ensure HUD-compliant rent reasonableness, conduct thorough reviews of tenant files with landlords and property managers, and implement additional oversight procedures for accounting and documentation of tenant rents. FJV compliance staff will perform quarterly checks with sub-recipients, and rent reasonableness forms will be reviewed and updated annually. These measures aim to strengthen controls, ensure compliance, and prevent incorrect charges to federal programs. Name of Responsible Individual(s): Jason Brenier, Maria Rafanan, Jesse Casement, Christina Madriles, Tatyana Gavino and Judy Bokhari Anticipated Completion Date: June 2025

Contact Person Tawnya Taylor, Executive Director Corrective Action Plan The Authority recognizes the deficiency and plans to implement the auditor's recommendations. Planned Completion Date for CAP Immediately.

D. Current Findings on the Schedule of Findings, Section 8 program administration and Recommendations 4. Finding 2024-4 g. Comments on the Finding and Each Recommendation We agree that management fees were miscalculated. h. Action(s) Taken or Planned on the Finding The Managing caught the error on the management fees and reimbursed the cooperative. The management fees have been automated in July of 2025 to ensure accuracy.

C. Current Findings on the Schedule of Findings, Section 8 program administration and Recommendations 3. Finding 2024-3 e. Comments on the Finding and Each Recommendation We concur that EIV reports were not timely filed. Action(s) Taken or Planned on the Finding f. Action(s) Taken or Planned on the Finding Staff has been stabilized and will ensure that reports are run timely. Training and monitoring will be provided.

B. Current Findings on the Schedule of Findings, Physical Inspection and Recommendations 2. Finding 2024-2 c. Comments on the Finding and Each Recommendation This property has suffered post hurricane with reduced population, staffing shortages, and increased costs. The NSPIRE scores reflect the challenges the property faces. Scores have improved but additional work will need to be completed to ensure a passing score. The property is a subsidized cooperative will limited resources. d. Action(s) Taken or Planned on the Finding The property and the Agent will continue to improve conditions at the property to ensure a passing score. Staff is being trained and the managing agent is supplementing the on site staff. Additional training is being provided.

A. Current Findings on the Schedule of Findings, Section 8 program administration and Recommendations 1. Finding 2024-1 a. Comments on the Finding and Each Recommendation We concur that certain 50059s were not signed timely. b. Action(s) Taken or Planned on the Finding We are training staff and monitoring compliance at this property to ensure 50059s are timely signed or residents will be placed in legal.

Current Findings on the Schedule of Findings, Physical Inspection and Recommendations 2. Finding 2024-2 c. Comments on the Finding and Each Recommendation In accordance with HUD program guidelines under which the Project operates, the annual tenant recertification Form 50059 is required to be signed by the tenant prior to the required annual recertification date. d. Action(s) Taken or Planned on the Finding The CRM Compliance Department will schedule bi-annual on-site visits to provide training as well monitoring the all recertifications to ensure that they are completed timely.

A. Current Findings on the Schedule of Findings, Section 8 program administration and Recommendations 1. Finding 2024-1 a. Comments on the Finding and Each Recommendation Management failed to maintain the property in good repair and received a score of 0 on its 2024 NPIRE inspection b. Action(s) Taken or Planned on the Finding Our Maintenance Team performed a 100% property inspection and subsequently made all repairs based on that inspection. As a result the property underwent an NSPIRE inspection on July 17, 2025 which resulted in a score of a 77.

Contact Person Tawnya T, Executive Director Corrective Action Plan The Authority will review its policies and procedures over program compliance requirements and continue to provide occupancy training to staff to prevent future exceptions. Planned Completion Date for CAP December 31, 2025.

Contact Person Tawnya T, Executive Director Corrective Action Plan The Authority will review its policies and procedures over program compliance requirements and continue to provide occupancy training to staff to prevent future exceptions. Planned Completion Date for CAP December 31, 2025.

Contact Person Tawnya T, Executive Director Corrective Action Plan The Authority will review its policies and procedures over program compliance requirements and continue to provide occupancy training to staff. Planned Completion Date for CAP December 31, 2025.

Recommendation: The Organization should follow established controls to ensure timely submission of the Data Collection Form. This should include assignment of responsibility to a designated official and be monitored by management. Corrective Actions: Our accounting department is now fully in-house and all partnerships with the outside accounting firm, Wipfli, have been terminated. This year and moving into the future, we do not anticipate having any issues with completing our audit on time. This audit for 2024 will be completed in a timely manner.

Corrective Action: Management made a deposit for a total of $8,582 to cover the underfunded residual receipts. Management will maintain tracking record every year to ensure that the residual receipts account is appropriately funded. The bookkeeper will maintain the record and ensure that deposits are made as required.

Finding 2024-005: PERIOD OF PERFORMANCE Description of Finding: Capital Funds identified in the PHA's CFP 5-Year Action Plan to be transferred to operations are obligated by the PHA once the funds have been budgeted and drawn down by the PHA. Capital Funds transferred to operations (BLI 1406) are not considered obligated until the PHA has budgeted and drawn down the funds. To meet this requirement, the funds must be budgeted in line BLI 1406 (Operations) and the PHA must submit the voucher request in LOCCS. (24 CFR Section 905.314(I)). Statement of Concurrence or NonConcurrence: The Authority had obligated capital funds related to operations (BLI 1406) for Capital Fund years 2020 and 2022 prior to the voucher request date for these draws. The Authority had six open capital fund grants during fiscal year 2024 (Capital Fund years 2019-2024). The Authority obligated the BLI 1406 funding for Capital Fund 2020 in March 2024 and Capital Fund 2022 in May 2024. The Authority submitted the voucher requests in February 2025. Corrective Action: Funds in 1406 will be drawn down directly after obligation. Name of Contact Person: Cheryl Thibeault Projected Completion Date: 09/30/2025

Finding 2024-003: Cash Management Description of Finding: For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. (2 CFR 200.305 (b)) Once funds are disbursed, i.e. transferred from LOCCS to the PHA’s bank account, the PHA must pay the applicable bill(s) within 3 business days after the deposit of the funds into the PHA’s bank account. (HUD Capital Fund Guidebook; Section 7.9) Statement of Concurrence or NonConcurrence: A sample of 4 drawdowns of capital funds from ELOCCs during the year identified 1 instance in which the Authority did not process payment to the vendor within 3 business days of receiving the funds. Corrective Action: The Authority processes a weekly check run for all payables. The timing of the receipts from ELOCCs missed the run and the invoice was added to the following weekly run. The authority will better monitor the receipt of funds and if necessary perform an additional check run to disburse the funds to the recipient. Name of Contact Person: Cheryl Thibeault Projected Completion Date: 09/30/2025

Finding 2024-002: HOUSING ASSISTANCE PAYMENT Description of Finding: During the term of each assisted lease, and for at least three years thereafter, the PHA must keep: (1) A copy of the executed lease; (2) The HAP contract; and (3) The application from the family. (24 CFR 982.158 (e) The PHA may not pay any housing assistance payment to the owner until the HAP contract has been executed. (24 CFR 982.305 (c)(2)) Statement of Concurrence or NonConcurrence: A sample of 25 participants in the Housing Choice Voucher Program. There were 5 identified instances in which the HAP contract was not properly executed by either the landlord or the PHA. Corrective Action: It was found that the 5 identified instances were completed by staff no longer with the authority. The five have been corrected. Staff have now been trained to perform and review of the contract during any annual or interim certification. All new moves and changes to contracts are given to the manager to ensure utility responsibilities are correctly reflected in the lease, contract, and in the software and that families are correctly credited. The HCV Director will due random review of files to ensure compliance. Name of Contact Person: Maribel Aguliar Projected Completion Date: 09/30/2025

Finding 2024-001: SPECIAL TESTS AND PROVISIONS – HQS ENFORCEMENT Description of Finding: A sample of 40 failed HQS inspections during the year. In 31 out of the 40 failed HQS inspections, the PHA re-inspection did not occur within 30 days. In 2 of the 40, we were not provided with documentation showing the unit passed HQS. Statement of Concurrence or NonConcurrence: The Authority may have made housing assistance payments to landlords for units that failed to meet housing quality standards or failed to properly abate HAP in cases where HQS deficiencies were not corrected in a timely manner. Corrective Action: An internal inspector was hired in November 2024 which will allow for better follow through and communication as opposed to a contracted inspector. The internal inspector will have full access to the inspection module in Pha Web with timely data entry will ensure that abatements are placed on non-compliant properties. The HCV Director will monitor inspections completed for proper disposition and also run reports on units due in the upcoming month to make sure they are executed and updated in Pha Web. Procedures will be strengthened to ensure that documentation is maintained for all inspections and enforcements. Name of Contact Person: Maribel Aguliar Projected Completion Date: 09/30/2025

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-001 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) Description of Finding: The FFATA subawards were not submitted timely to the Federal Funding Accountability and Transparency Act Subaward Reporting System (“FSRS”). The review and approval occurred after the FFATA subaward was submitted to the FSRS. Statement of Concurrence: We concur with the finding above. Corrective Action: BCHN has created a policy regarding the FFATA reporting process. In this process the Electronic Handbook (EHB) is reviewed weekly to ensure that if new awarded funding is released, BCHN is alerted to the need to complete the FFATA report. BCHN has created a spreadsheet to track all the awarded funding and due dates for FFATA reports. Every month, at the board meeting, the spreadsheet is presented to the board with any new awarded funding and when the FFATA report is completed. BCHN has begun a process where the FFATA report is put together by the Finance Manager and reviewed and signed off by the CFO before submitting the report. Completion Date: October 2024. Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-004 – Period of Performance Description of Finding: There was no evidence, such as a signature, evidencing review and approval by a direct supervisor of the timesheets. Time and effort reports were not done. Statement of Concurrence: We concur with the finding above. Corrective Action: BCHN has put together a training program for employees to ensure that timecards are reviewed and approved by both the employee and the supervisor on a bi-weekly basis. Before payroll is processed, approvals by employees and supervisors will be checked. HR will provide a monthly time and effort report to the finance team. This report will provide total number of hours worked by each employee for each assigned cost center. Completion Date: October 2024. Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer

Corrective Action Taken:Although the Business Office has created a Federal Grants Compliance Manual, we are unable to follow the manual with fidelity due to the lack of adequate staffing. The District will continue to request additional staff during the next budget cycle.

Finding ref number: 2024-004 Finding Caption: Housing Voucher Cluster Eligibility Controls and Compliance Name, address, and telephone of Authority contact person: Michael Bishop 2900 NE 10th St. Renton, WA 98056 425-226-1850 x 317 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the forty (40) tenant files sampled by the auditors, seven (7) files did not have utility allowances calculated; two (2) files had 50058’s that did not agree with the HAP payments being paid to the landlords and four (4) files could not be located for testing. RHA had sent all of its paper files to a scanning company to have everything scanned and saved back onto our server for safekeeping. RHA has gone paperless and will not keep paper tenant files again. Some of the files that the auditors requested were either not scanned yet or we could not find. Staff continue to be trained and educated on the importance of ensuring all documents on in the digital tenant file with backup documentation for income / asset verification as well as ensure that the 50058 UA matches the 52667 form and scanned into their digital file of the voucher holder. These issues should begin to decrease as we cycle through and get all paperwork caught up. 2024 Annual Reexams were behind due to staffing issues in 2023 and into 2024. Finding ref number: 2024-004 Finding Caption: Housing Voucher Cluster Eligibility Controls and Compliance Name, address, and telephone of Authority contact person: Michael Bishop 2900 NE 10th St. Renton, WA 98056 425-226-1850 x 317 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the forty (40) tenant files sampled by the auditors, seven (7) files did not have utility allowances calculated; two (2) files had 50058’s that did not agree with the HAP payments being paid to the landlords and four (4) files could not be located for testing. RHA had sent all of its paper files to a scanning company to have everything scanned and saved back onto our server for safekeeping. RHA has gone paperless and will not keep paper tenant files again. Some of the files that the auditors requested were either not scanned yet or we could not find. Staff continue to be trained and educated on the importance of ensuring all documents on in the digital tenant file with backup documentation for income / asset verification as well as ensure that the 50058 UA matches the 52667 form and scanned into their digital file of the voucher holder. These issues should begin to decrease as we cycle through and get all paperwork caught up. 2024 Annual Reexams were behind due to staffing issues in 2023 and into 2024. Finding ref number: 2024-004 Finding Caption: Housing Voucher Cluster Eligibility Controls and Compliance Name, address, and telephone of Authority contact person: Michael Bishop 2900 NE 10th St. Renton, WA 98056 425-226-1850 x 317 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the forty (40) tenant files sampled by the auditors, seven (7) files did not have utility allowances calculated; two (2) files had 50058’s that did not agree with the HAP payments being paid to the landlords and four (4) files could not be located for testing. RHA had sent all of its paper files to a scanning company to have everything scanned and saved back onto our server for safekeeping. RHA has gone paperless and will not keep paper tenant files again. Some of the files that the auditors requested were either not scanned yet or we could not find. Staff continue to be trained and educated on the importance of ensuring all documents on in the digital tenant file with backup documentation for income / asset verification as well as ensure that the 50058 UA matches the 52667 form and scanned into their digital file of the voucher holder. These issues should begin to decrease as we cycle through and get all paperwork caught up. 2024 Annual Reexams were behind due to staffing issues in 2023 and into 2024. Finding ref number: 2024-004 Finding Caption: Housing Voucher Cluster Eligibility Controls and Compliance Name, address, and telephone of Authority contact person: Michael Bishop 2900 NE 10th St. Renton, WA 98056 425-226-1850 x 317 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the forty (40) tenant files sampled by the auditors, seven (7) files did not have utility allowances calculated; two (2) files had 50058’s that did not agree with the HAP payments being paid to the landlords and four (4) files could not be located for testing. RHA had sent all of its paper files to a scanning company to have everything scanned and saved back onto our server for safekeeping. RHA has gone paperless and will not keep paper tenant files again. Some of the files that the auditors requested were either not scanned yet or we could not find. Staff continue to be trained and educated on the importance of ensuring all documents on in the digital tenant file with backup documentation for income / asset verification as well as ensure that the 50058 UA matches the 52667 form and scanned into their digital file of the voucher holder. These issues should begin to decrease as we cycle through and get all paperwork caught up. 2024 Annual Reexams were behind due to staffing issues in 2023 and into 2024. Finding ref number: 2024-004 Finding Caption: Housing Voucher Cluster Eligibility Controls and Compliance Name, address, and telephone of Authority contact person: Michael Bishop 2900 NE 10th St. Renton, WA 98056 425-226-1850 x 317 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the forty (40) tenant files sampled by the auditors, seven (7) files did not have utility allowances calculated; two (2) files had 50058’s that did not agree with the HAP payments being paid to the landlords and four (4) files could not be located for testing. RHA had sent all of its paper files to a scanning company to have everything scanned and saved back onto our server for safekeeping. RHA has gone paperless and will not keep paper tenant files again. Some of the files that the auditors requested were either not scanned yet or we could not find. Staff continue to be trained and educated on the importance of ensuring all documents on in the digital tenant file with backup documentation for income / asset verification as well as ensure that the 50058 UA matches the 52667 form and scanned into their digital file of the voucher holder. These issues should begin to decrease as we cycle through and get all paperwork caught up. 2024 Annual Reexams were behind due to staffing issues in 2023 and into 2024. Finding ref number: 2024-004 Finding Caption: Housing Voucher Cluster Eligibility Controls and Compliance Name, address, and telephone of Authority contact person: Michael Bishop 2900 NE 10th St. Renton, WA 98056 425-226-1850 x 317 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the forty (40) tenant files sampled by the auditors, seven (7) files did not have utility allowances calculated; two (2) files had 50058’s that did not agree with the HAP payments being paid to the landlords and four (4) files could not be located for testing. RHA had sent all of its paper files to a scanning company to have everything scanned and saved back onto our server for safekeeping. RHA has gone paperless and will not keep paper tenant files again. Some of the files that the auditors requested were either not scanned yet or we could not find. Staff continue to be trained and educated on the importance of ensuring all documents on in the digital tenant file with backup documentation for income / asset verification as well as ensure that the 50058 UA matches the 52667 form and scanned into their digital file of the voucher holder. These issues should begin to decrease as we cycle through and get all paperwork caught up. 2024 Annual Reexams were behind due to staffing issues in 2023 and into 2024. Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the forty (40) tenant files sampled by the auditors, seven (7) files did not have utility allowances calculated; two (2) files had 50058’s that did not agree with the HAP payments being paid to the landlords and four (4) files could not be located for testing. RHA had sent all of its paper files to a scanning company to have everything scanned and saved back onto our server for safekeeping. RHA has gone paperless and will not keep paper tenant files again. Some of the files that the auditors requested were either not scanned yet or we could not find. Staff continue to be trained and educated on the importance of ensuring all documents on in the digital tenant file with backup documentation for income / asset verification as well as ensure that the 50058 UA matches the 52667 form and scanned into their digital file of the voucher holder. These issues should begin to decrease as we cycle through and get all paperwork caught up. 2024 Annual Reexams were behind due to staffing issues in 2023 and into 2024.

Finding ref number: 2024-003 Finding Caption: Housing Voucher Cluster HUD Required Reporting Name, address, and telephone of Authority contact person: Michael Bishop 2900 NE 10th St. Renton, WA 98056 425-226-1850 x 317 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prior RHA Administration failed to complete the Single Audit and submitted it to the FASSPHA and SF-SAC websites. The deadline for RHA to submit its Single Audit is September 30th of each year. The last completed Single Audit prior to the new CEO coming on board was done in 2019. The State of Washington had been working on Anticipated date to complete the corrective action: Anticipate FY2024 to be submitted by September 30, 2025, and the CEO will ensure RHA’s Fee Accountant submits the PHA’s Unaudited FDS to FASSPHA by the deadline of March of each year and ensure the Single Audit is completed and submitted on time, per the required HUD deadline of September 30th of each year.