Corrective Action Plans

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2025-001: Segregation of Duties Condition: Management is responsible for the design, implementation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. The following duties lack adequate segregation of duties: • The...
2025-001: Segregation of Duties Condition: Management is responsible for the design, implementation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. The following duties lack adequate segregation of duties: • The same individual that reconciles the bank accounts also approves and codes invoices, creates deposits and processes and initiates debt payments. • This individual is also the primary staff who compiles and reviews grant claims. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the nomrnl course of their responsibilities as a result of the lack of segregation of duties. 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 sucherror is intentional or unintentional. Recommendation: We recommend that the Board of Education and the Superintendent continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office duties. The Board of Education approves monthly accounts payable checks and the Superintendent reviews payroll timesheets prior to processing payroll. The Superintendent also approves journal entries before they are posted to the accounting ledger. The Board of Education and Superintendent will continue to monitor transactions of the District. Contact Person: Jessie Backes Anticipated Completion: Ongoing
Corrective Action Plan: The School District is committed and will be diligent in preparing meals with high quality products. Regular cooked meals and expanded menu choices will be prepared which will result in an increase in expenses. There has been unpredictability with the increase of certain good...
Corrective Action Plan: The School District is committed and will be diligent in preparing meals with high quality products. Regular cooked meals and expanded menu choices will be prepared which will result in an increase in expenses. There has been unpredictability with the increase of certain goods, and we expect this to continue into the 2025-2026 fiscal year as well. The School District also participates in the Community Eligibility Provision (CEP) which provides free breakfast and lunch to every student within the School District. Salaries for School Lunch employees have also been increasing year after year due to the increase of minimum wage in New York State. The minimum wage is expected to increase to $16.00 per hour and entry level wages have increased per contract. The School District does have a practice of transferring BOCES aid gained from the cost of the BOCES management contract to the School Lunch Fund; the aid will not be transferred in upcoming years. The School District has devised a NYSED approved plan to expend the excess funds in the School Lunch Fund through appropriating a substantial amount of fund balance to be planned for and used for the cafeteria and kitchen within the next planned capital project. We are currently in the planning phase of our next capital project with a vote anticipated during the 2025-2026 fiscal year. If needed, we will examine other avenues to ensure we do not exceed the allowable limit of cash at year end.
Responsible Official Jeffrey Caputi Plan Detail A calculation was made of the underfunding through December 2025, which amounted to 130,132. The funds were transferred from the operating account to the replacement reserve account making the reserve fully funded as of December 19, 2025. Anticipated C...
Responsible Official Jeffrey Caputi Plan Detail A calculation was made of the underfunding through December 2025, which amounted to 130,132. The funds were transferred from the operating account to the replacement reserve account making the reserve fully funded as of December 19, 2025. Anticipated Completion Date: December 19, 2025.
Views of Responsible Officials and Planned Corrective Actions - The University’s Office of Student Financial Services agrees with the recommendation and will ensure that Return of Title IV (R2T4) calculations and applicable returns of funds for all students who officially or unofficially withdraw ar...
Views of Responsible Officials and Planned Corrective Actions - The University’s Office of Student Financial Services agrees with the recommendation and will ensure that Return of Title IV (R2T4) calculations and applicable returns of funds for all students who officially or unofficially withdraw are completed within required regulatory time frames. To strengthen internal controls related to R2T4 processing, the Office of Student Financial Services under the direction of the Director of Student Financial Services has taken and will continue the following actions: • Reinforce and update R2T4 procedures to clearly document regulatory timelines, roles, and responsibilities, and to include defined ongoing monitoring practices. These updated procedures incorporate periodic review of R2T4 activity to ensure continued compliance. • Enhance the existing internal tracking mechanism to support timely completion of R2T4 calculations and fund returns. This enhancement includes the ability to generate reports that identify upcoming deadlines, completed actions, and any items requiring follow-up. • Provide refresher training to staff within the Office of Student Financial Services and partner offices involved in R2T4 processing, with emphasis on compliance requirements, timelines, documentation standards, and shared accountability across offices. • Incorporate a secondary review process as part of the existing R2T4 procedure. A designated secondary reviewer within the Office of Student Financial Services will confirm the accuracy and timeliness of each R2T4 calculation and associated fund return, with completion of the review documented within the tracking system. These corrective actions will be implemented upon review and approval and will be effective beginning Spring 2026.
Management will monitor tenant recertifications to ensure that they are being completed in a timely manner. The following measures will be implemented: • Centralized tracking by the Housing Manager on a monthly basis to monitor the recertification timeline for each unit. This will include tracking t...
Management will monitor tenant recertifications to ensure that they are being completed in a timely manner. The following measures will be implemented: • Centralized tracking by the Housing Manager on a monthly basis to monitor the recertification timeline for each unit. This will include tracking the 120, 90, 60, and 30 day reminders to be sent to tenants in advance of the recertification effective dates. • Automated reminders will be provided on a monthly basis by the third party vendor that processes HAP billings to the Housing Manager and site managers, in order to ensure that they are aware of any recertification deadlines. • Additional training will be provided for all staff members involved in the recertification process.
2025-001 ALN 14.872 – Public Housing Capital Fund Program – Cash Management The CEO agrees with the finding and will follow the Auditor's recommendations as listed on the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. Robert Dull, CEO Projected Completio...
2025-001 ALN 14.872 – Public Housing Capital Fund Program – Cash Management The CEO agrees with the finding and will follow the Auditor's recommendations as listed on the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. Robert Dull, CEO Projected Completion Date: June 30, 2026
Condition: The Commission did not submit the required financial and performance reports promptly. Planned Corrective Action: The Capital Team Project Manager continues to reconcile HUD’s EPIC and ELOCC systems with Yardi monthly to ensure timely filing of capital projects' closeouts. This tracking c...
Condition: The Commission did not submit the required financial and performance reports promptly. Planned Corrective Action: The Capital Team Project Manager continues to reconcile HUD’s EPIC and ELOCC systems with Yardi monthly to ensure timely filing of capital projects' closeouts. This tracking critical spreadsheet, created by the Lead Performance Officer, will trigger key reporting dates for the DHC Capital Fund Program to remain in compliance with HUD reporting deadlines. At a minimum, monthly, this critical spreadsheet is distributed to the Supervisor of Capital and the Lead Performance Officer to ensure compliance. However, this was on the radar and continues the process of cleaning older items for corporate hygiene. As of December 2025, this was closed out and approved in EPIC by HUD. Contact person responsible for corrective action: Michael Edwards, Capital Asset & Skilled Trades Supervisor Anticipated Completion Date: 12/31/2025
Condition: The Commission did not complete fiscal year 2025 recertifications. Planned Corrective Action: Staff have been retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Rental Assistance Department Manager and Continued Occupancy Superviso...
Condition: The Commission did not complete fiscal year 2025 recertifications. Planned Corrective Action: Staff have been retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Rental Assistance Department Manager and Continued Occupancy Supervisor. The Department Manager and Supervisor continue to utilize all Yardi monitoring reports to ensure the Department is operating in accordance with industry standards. Reporting is be done and monitored monthly to meet set goals. Weekly, Department Manager has review the certification pipeline to ensure compliance and follow up with the Housing Specialist to ensure compliance and meeting set weekly and monthly goals and metrics. We continue to work in accordance with HUD rules and regulations where Annual Recertification processes are concerned. Per HUD communication provided to us, as of June 30, 2025, HCV is 100% compliant with HUD recertification requirements. Contact person responsible for corrective action: Felicia Burris, HCV Program Manager Anticipated Completion Date: 7/1/2025
Finding 2025-001: During the year ended September 30, 2025, the Company loaned funds totaling $10,850 to two other Communities under common management and affiliated with the Sole Member of the Company to help fund operating shortfalls of the other Communities. Comments on the Finding and Each Recom...
Finding 2025-001: During the year ended September 30, 2025, the Company loaned funds totaling $10,850 to two other Communities under common management and affiliated with the Sole Member of the Company to help fund operating shortfalls of the other Communities. Comments on the Finding and Each Recommendation: Management and/or the Sole Member should reimburse the Company for the funds that were loaned to the two other Communities. If there are further operating shortfalls in the future, these should be funded by Management and/or the Sole Member and not borrowed from other Communities. Action(s) taken or planned on the finding: Management concurs with the finding and agrees with the recommendation. On November 7, 2025, Management deposited $10,850 into the Community's operating account. No further action is required.
Finding #2025-001: During the year ended September 30, 2025, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Recommendation: Management should transfer $5,119 from the operating account to the reserve for replacements account when there is cash avail...
Finding #2025-001: During the year ended September 30, 2025, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Recommendation: Management should transfer $5,119 from the operating account to the reserve for replacements account when there is cash available. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. Management deposited $5,119 into the replacement reserve on November 18, 2025, and will continue to make monthly deposits to the reserve as cash flow allows to ensure compliance.
Finding #2025-001: During the year ended September 30, 2025, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Recommendation: Management should transfer $3,535 from the operating account to the reserve for replacements account when there is cash avail...
Finding #2025-001: During the year ended September 30, 2025, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Recommendation: Management should transfer $3,535 from the operating account to the reserve for replacements account when there is cash available. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. Management deposited $3,535 into the replacement reserve on November 7, 2025, and will continue to make monthly deposits to the reserve as cash flow allows to ensure compliance.
MANAGEMENT AGREES WITH THE FINDING. THE RESIDUAL RECEIPTS ACCOUNT DEFICIENCY WAS FUNDED ON NOVEMBER 18, 2024 IN THE AMOUNT OF $575. MANAGEMENT WILL ENSURE THAT THE RESIDUAL RECEIPTS ACCOUNT IS PROPERLY FUNDED IN THE FUTURE.
MANAGEMENT AGREES WITH THE FINDING. THE RESIDUAL RECEIPTS ACCOUNT DEFICIENCY WAS FUNDED ON NOVEMBER 18, 2024 IN THE AMOUNT OF $575. MANAGEMENT WILL ENSURE THAT THE RESIDUAL RECEIPTS ACCOUNT IS PROPERLY FUNDED IN THE FUTURE.
Views of Responsible Officials: Management concurs with the recommendations and will provide instruction and policy to all individuals in the reserve for replacement funding activities of the Project. Since it was discovered prior to September 30, 2025, management worked with the bank and made depos...
Views of Responsible Officials: Management concurs with the recommendations and will provide instruction and policy to all individuals in the reserve for replacement funding activities of the Project. Since it was discovered prior to September 30, 2025, management worked with the bank and made deposits into the reserve for replacement to make up the shortfall. Management will work with the Bank and HUD to ensure the accuracy of the “true-up” payments made.
3. Finding 2025-003 - delinquent deposits to the residual receipts reserve a. Issue: During the year ended June 30, 2025, management did not make the required residual receipts reserve deposit in the amount of $117,570, within 90 days of year end as required by HUD. The residual receipts amount was ...
3. Finding 2025-003 - delinquent deposits to the residual receipts reserve a. Issue: During the year ended June 30, 2025, management did not make the required residual receipts reserve deposit in the amount of $117,570, within 90 days of year end as required by HUD. The residual receipts amount was deposited in June 2025. Additionally, residual receipt offsets for balances in excess of the retained balance are not being offset on a monthly basis. b. Recommendation: Management should establish internal controls and procedures to ensure that required residual receipts reserve deposits are made timely and residual receipt offsets are requested on a monthly basis. c. Action taken: Management has re-implemented a surplus cash calculation spreadsheet which is prepared by the Senior Cash Management Accountant on a monthly basis and reviewed by the Assistant Controller. This spreadsheet will allow visibility of surplus cash and timely transfer of any surplus cash at year end into the Residual Receipts account.
Finding 2025-002 - replacement reserves not deposited timely a. Issue: During the year ended June 30, 2025, the Projects were delinquent in making the required monthly deposits to the replacement reserve. BC HUD I required deposits for the period July 2024 through February 2025 in the amount of $60,...
Finding 2025-002 - replacement reserves not deposited timely a. Issue: During the year ended June 30, 2025, the Projects were delinquent in making the required monthly deposits to the replacement reserve. BC HUD I required deposits for the period July 2024 through February 2025 in the amount of $60,928 were funded in February 2025. BC HUD II required monthly deposits for the period July through September 2024 in the amount of $7,278 were funded in February 2025, for the period October through December 2024 in the amount of $7,416 were funded in March 2025, and for the period January through April 2025 in the amount of $9,888 were funded in April 2025. BC HUD Ill required monthly deposits for the period July 2024 through May 2025 in the amount of $26,015 were funded In May 2025. b. Recommendation: Management should establish or undertake a review of internal controls over monitoring of the replacement reserve requirements to ensure deposits are made as required. c. Action taken: A tracking spreadsheet is now being used which lists the monthly amounts required to be transferred to the reserves and has a column for staff to input the date that the transfers were made. This spreadsheet is now reviewed on a weekly basis by both the Senior Cash Management Accountant and the Assistant Controller as part of the weekly check run to ensure that the monthly transfers to the reserves are made early in the month prior to paying other liabilities.
1. Finding 2025-001 - tenant rent payments not deposited timely a. Issue: During the year ended June 30, 2025, Bay Cove Human Services, Inc., an affiliate and sponsor agency for Juliette Corporation, collected rent and other client fees related to its clients who are also tenants in the Projects. Fo...
1. Finding 2025-001 - tenant rent payments not deposited timely a. Issue: During the year ended June 30, 2025, Bay Cove Human Services, Inc., an affiliate and sponsor agency for Juliette Corporation, collected rent and other client fees related to its clients who are also tenants in the Projects. For a portion of the year ended June 30, 2025, Bay Cove Human Services, Inc. did not timely remit the tenant rent portion of these payments to the Projects. Delinquent rent payments for the period July 2024 through February 2025 amounted to $104,547 and were deposited in February and March 2025. Additionally, June 2025's rents were outstanding and owed to the Projects as of June 30, 2025 in the amount of$19,785 and were deposited in July 2025. b. Recommendation: Management should establish or undertake a review of internal controls over monitoring of the tenant rent deposits to ensure deposits are timely made into the Project accounts. a. Action taken: The tenant rent transfers are now prepared on a monthly basis, with the Assistant Controller reviewing them. In addition, the accounting team is now performing a monthly reconciliation of the related balance sheet accounts which show the amounts due to/from the entities for the tenant rents in order to identify any problems with the timeliness of the transfers. The Assistant Controller is reviewing these reconciliations on a monthly basis as well.
Condition and Context: HUD requires that all units under the Housing Choice Vouchers Program meet specific Housing Quality Standards (HQS). In cases of failed inspections, timely re-inspections are mandatory, and if compliance is not achieved, abatement of Housing Assistance Payments (HAP) or vouche...
Condition and Context: HUD requires that all units under the Housing Choice Vouchers Program meet specific Housing Quality Standards (HQS). In cases of failed inspections, timely re-inspections are mandatory, and if compliance is not achieved, abatement of Housing Assistance Payments (HAP) or voucher cancellation is required. During the audit, it was noted that in seven (7) instances, a unit that failed its HQS inspection did not undergo a subsequent re-inspection or no inspection was documented. Consequently, the required abatement of HAP or cancellation of the housing voucher was not executed. Recommendation: The Auditors recommended to Implement more stringent procedures for monitoring HQS compliance, including timely reinspection and enforcement of HAP abatement or voucher cancellation. Enhance training for staff involved in the HQS process to ensure a thorough understanding of compliance requirements. Establish a system of regular audits to identify and rectify lapses in HQS enforcement promptly. Plan for Corrective Action: Management is establishing an internal procedure to conduct monthly reviews of HQS inspection requirements to ensure all mandated inspections are completed promptly and in compliance with program standards. Actions Taken: KHA has scheduled all pending re-inspections and is actively working to complete any remaining ones.
2025-001 – ALN 14.850 – Public Housing Operating Fund – Eligibility Current management acknowledges the finding and is following the auditor’s recommendations. Person Responsible for Correction of Exception: Mr. Tony Webster, Executive Director Projected Completion Date: June 30, 2026
2025-001 – ALN 14.850 – Public Housing Operating Fund – Eligibility Current management acknowledges the finding and is following the auditor’s recommendations. Person Responsible for Correction of Exception: Mr. Tony Webster, Executive Director Projected Completion Date: June 30, 2026
The Accounting Manager and Executive Director for the year ended June 30, 2025 were terminated in October 2025, and the former Executive Director has returned to assist in implementing necessary controls and processes and train property level staff.
The Accounting Manager and Executive Director for the year ended June 30, 2025 were terminated in October 2025, and the former Executive Director has returned to assist in implementing necessary controls and processes and train property level staff.
The Accounting Manager and Executive Director for the year ended June 30, 2025 were terminated in October 2025, and the former Executive Director has returned to assist in implementing necessary controls and processes and train property level staff.
The Accounting Manager and Executive Director for the year ended June 30, 2025 were terminated in October 2025, and the former Executive Director has returned to assist in implementing necessary controls and processes and train property level staff.
A. Finding Finding 2025-001 – Moving to Work Resident Files – Eligibility – Rent Calculations & HAP Disbursements Noncompliance & Material Weakness – ALN #14.881 B. Condition and Cause The auditor reviewed fifteen (15) Housing Choice Voucher (HCV) project-based voucher (PBV) participant files and tw...
A. Finding Finding 2025-001 – Moving to Work Resident Files – Eligibility – Rent Calculations & HAP Disbursements Noncompliance & Material Weakness – ALN #14.881 B. Condition and Cause The auditor reviewed fifteen (15) Housing Choice Voucher (HCV) project-based voucher (PBV) participant files and twenty (20) HCV tenant-based voucher (TBV) participant files for a total of thirty-five (35) participant files. It was noted that fourteen (14) TBV files were non-compliant. C. Background Information The HCV Department has had numerous staff turnover in recent years. Due to organizational restructuring, Shannon Walters was moved from HCV Manager to Multi-Family Housing Director in March 2024 and Todd James was promoted to Interim HCV Manager in March 2024. Todd was moved to the HCV Operations Administrator position in February 2025, and Charlotte Bowen was hired as HCV Manager in March 2025. Mary Cameron was hired as HCV Caseworker (TBV) in December 2023 and received extensive one-on-one training. Due to performance concerns, she was given a Performance Improvement Plan. Upon completion, her performance was found to be unsatisfactory. Mary was transferred to Property Manager at the LaFayette Housing Authority site in October 2025. D. Controls to Correct the Deficiency To correct the finding noted above, the Auburn Housing Authority (AHA) will proceed as follows: a. The HCV Manager will perform a comprehensive audit of all TBV files and correct appliable deficiencies. b. Implement other internal control measures to eliminate future audit findings. E. Person Responsible: Sharon N. Tolbert, CEO F. Anticipated Completion Date: June 30, 2026
Finding 2025-003 – Eligibility – Rent Calculations ALN 14.850 – Noncompliance & Material Weakness Recommendation: We recommend that the agency complete a current review of all participant files to identity and correct calculations still including permissive deductions. Explanation of disagreement wi...
Finding 2025-003 – Eligibility – Rent Calculations ALN 14.850 – Noncompliance & Material Weakness Recommendation: We recommend that the agency complete a current review of all participant files to identity and correct calculations still including permissive deductions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will strengthen compliance oversight by implementing a quality control review process for participant files. This process will ensure accurate rent calculations and identify any instances of noncompliance. Reviews will be conducted on a regular basis and documented for accountability. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Navonya Kolani, Executive Director
Address weaknesses in eligibility verification and waiting list management: 1. Policy Review: Review and verify that the Admissions and Continued Occupancy Policy (ACOP) clearly states the requirement that all admissions originate from the approved waiting list and what documentation is required to ...
Address weaknesses in eligibility verification and waiting list management: 1. Policy Review: Review and verify that the Admissions and Continued Occupancy Policy (ACOP) clearly states the requirement that all admissions originate from the approved waiting list and what documentation is required to be in the participate file as waitlist verification 2. Staff Training: Provide refresher training for Public Housing staff on eligibility verification and waiting list procedures. Require dual staff sign-off on all new admissions to confirm eligibility and waiting list documentation before lease execution. 3. Waiting List Audit: Conduct a semi-annual audit of waiting list transactions to ensure documentation accuracy and selection order compliance. 4. Software Updates: Review and select a new software to assist with income item collection. Software should allow residents to upload and store documentation. This will allow greater transparency as the residents and staff will view the same information. In addition, all information would be date and time stamped to ensure tasks were completed in a timely manner.
Ensure compliance with Housing Quality Standards (HQS) and enforce owner accountability: 1. Staff Training: Retrain inspection and program staff on HQS enforcement protocols under 24 CFR §982.404(a)(3), as well as Admin Plan specific timeframes and escalation procedures when HQS deficiencies are not...
Ensure compliance with Housing Quality Standards (HQS) and enforce owner accountability: 1. Staff Training: Retrain inspection and program staff on HQS enforcement protocols under 24 CFR §982.404(a)(3), as well as Admin Plan specific timeframes and escalation procedures when HQS deficiencies are not corrected within the required 24-hour (life-threatening) or 30-day (non-life-threatening) periods. 2. Monitoring: Establish a monthly compliance report that is presented by the Inspections Coordinator reviewed by management to ensure HAP payments are stopped timely for noncompliant units. Work to move all reporting to electronic files which will provide time and date stamps. 3. Landlord Communication: Issue updated landlord written notices outlining enforcement expectations and consequences for noncompliance. Make the Admin Plan publicly accessible to allow tenants and landlords to reference specific timeframes based on deficiencies. 4. Begin a Landlord Training: Staff to work to create a yearly or bi-yearly landlord training to review issues, expectations, processes, and timeframe associated with HCV program. Also gives landlord’s the opportunity to provide feedback for staff which may help address shortfalls.
Corrective Action: The Public Housing Authority (PHA) will strengthen eligibility determination procedures for the Housing Choice Voucher Program by implementing the following measures: 1. Policy Reinforcement: Review and update, if necessary, the Administrative Plan to explicitly outline required e...
Corrective Action: The Public Housing Authority (PHA) will strengthen eligibility determination procedures for the Housing Choice Voucher Program by implementing the following measures: 1. Policy Reinforcement: Review and update, if necessary, the Administrative Plan to explicitly outline required eligibility documentation and verification steps. 2. Staff Training: Conduct training sessions for HCV Specialists on verifying income, assets, and household composition. Staff to begin using HUD’s CPD calculator to calculate income. 3. Quality Control Review: Implement a quarterly supervisory review, by the Housing Manager, of a random 10% sample of tenant files to ensure accuracy in income calculation and documentation. 4. File Checklist: Implement file checklists in each file to ensure all items are collected correctly and available for compliance review. 5. Software Updates: Review and select a new software to assist with income item collection. Also implement the use of DocuSign to obtain signatures.
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