Corrective Action Plans

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Finding: 2024-001 Program Name: Section 8 Project-Based Cluster (14.195/14.249) Federal Awarding Agency: Department of Housing and Urban Development Compliance Requirement: Housing Quality Standards Type of Finding: Significant Deficiency; Nonmaterial Noncompliance Condition: Of the 40 tenant files ...
Finding: 2024-001 Program Name: Section 8 Project-Based Cluster (14.195/14.249) Federal Awarding Agency: Department of Housing and Urban Development Compliance Requirement: Housing Quality Standards Type of Finding: Significant Deficiency; Nonmaterial Noncompliance Condition: Of the 40 tenant files tested, 7 files did not contain documentation that the annual inspection was performed. Auditor Recommendation: We recommend the Agency uilize a tracking system to ensure inspections are completed annually and documentation is maintained regarding the results of the annual inspections. Management’s Response: The Property Management department will coordinate with the Information Technology team to ensure appropriate documentation and tracking of annual inspections.
Finding 2024-002: Comments on the Finding and Each Recommendation During prior years, the Board of Directors disbursed funds from the replacement reserve to fund development of other housing developments. Effective June 10, 2022, the Board of Directors entered into a repayment agreement with HUD t...
Finding 2024-002: Comments on the Finding and Each Recommendation During prior years, the Board of Directors disbursed funds from the replacement reserve to fund development of other housing developments. Effective June 10, 2022, the Board of Directors entered into a repayment agreement with HUD to return funds to the Corporation. The agreement required $3,000 and $6,950, respectively, to be returned to the Corporation during the years ended December 31, 2024 and 2023. The Board of Directors returned $250 and $1,400, respectively, during the years ended December 31, 2024 and 2023. At December 31, 2024 and 2023, the Board of Directors owes $53,350 and $54,750, respectively, to the Corporation. Action(s) taken or planned on the finding The Board of Directors should replace the funds that were disbursed from the reserve for replacements without HUD approval in accordance with the repayment agreement entered into with HUD on June 10, 2022. Management and the Board of Directors concur with the finding and the auditor's recommendation. The Board of Directors is working on making the delinquent deposits for 2023 and 2024 and all future deposits as required in the repayment agreement entered into with HUD on June 10, 2022.
Finding 2024-001: Comments on the Finding and Each Recommendation The Corporation has not filed the 2017, 2018, 2019, 2020, 2021, 2022, or 2023 federal income tax returns. Action(s) taken or planned on the finding Tax returns should be filed on a timely basis and all delinquent tax returns shou...
Finding 2024-001: Comments on the Finding and Each Recommendation The Corporation has not filed the 2017, 2018, 2019, 2020, 2021, 2022, or 2023 federal income tax returns. Action(s) taken or planned on the finding Tax returns should be filed on a timely basis and all delinquent tax returns should be filed as soon as possible. Management and the Board of Directors concur with the finding and the auditor's recommendation. Management and the Board of Directors are taking steps to file the previous tax returns and have the Corporation's not-for-profit designation reinstated.
Finding 2024-005: U.S. Department of Housing and Urban Development – CFDA #14.155 Mortgage Insurance for the Purchase or Refinance of Existing Multifamily Housing Projects Applicable Federal Award Number and Year – HUD loan under section 207/223(f), HUD Project No. 101-11316 Allowable Costs/ Allowab...
Finding 2024-005: U.S. Department of Housing and Urban Development – CFDA #14.155 Mortgage Insurance for the Purchase or Refinance of Existing Multifamily Housing Projects Applicable Federal Award Number and Year – HUD loan under section 207/223(f), HUD Project No. 101-11316 Allowable Costs/ Allowable Activities Name of contact Person: Renee Gallegos, Finance Manager Anticipated completion date: Completed Planned Corrective Action: • Management has updated internal controls to include that all costs charged to the project are for allowable costs.
View Audit 354976 Questioned Costs: $1
Finding 2024-004: U.S. Department of Housing and Urban Development – CFDA #14.871 Housing Choice Vouchers Applicable Federal Award Number and Year- HCV2024 HQS Enforcement Name of contact Person: Jenette Jemison, Director of Housing Operations Anticipated completion date: In Progress Planned Correct...
Finding 2024-004: U.S. Department of Housing and Urban Development – CFDA #14.871 Housing Choice Vouchers Applicable Federal Award Number and Year- HCV2024 HQS Enforcement Name of contact Person: Jenette Jemison, Director of Housing Operations Anticipated completion date: In Progress Planned Corrective Action: • SMHO will provide additional staff training and testing of understanding through a thirdparty training platform for inspections and re-inspections procedures. Management will quarterly review each file that requires re-inspection to ensure all documents are present in the file.
Finding 2024-003: U.S. Department of Housing and Urban Development – CFDA #14.871 Housing Choice Vouchers Applicable Federal Award Number and Year- HCV2024 Eligibility Name of contact Person: Jenette Jemison, Director of Housing Operations Anticipated completion date: Completed Planned Corrective Ac...
Finding 2024-003: U.S. Department of Housing and Urban Development – CFDA #14.871 Housing Choice Vouchers Applicable Federal Award Number and Year- HCV2024 Eligibility Name of contact Person: Jenette Jemison, Director of Housing Operations Anticipated completion date: Completed Planned Corrective Action: • SMHO will require managerial file review/approval for income used at new move-ins, port-ins and annual re-exams and the manager/lead will initial the new income line item added to the check sheet for each file to indicate the review/approval has been completed.
Finding 2024-002: U.S. Department of Housing and Urban Development – CFDA #14.871 Housing Choice Vouchers Applicable Federal Award Number and Year- HCV2024 Eligibility Name of contact Person: Jenette Jemison, Director of Housing Operations Anticipated completion date: Completed Planned Corrective Ac...
Finding 2024-002: U.S. Department of Housing and Urban Development – CFDA #14.871 Housing Choice Vouchers Applicable Federal Award Number and Year- HCV2024 Eligibility Name of contact Person: Jenette Jemison, Director of Housing Operations Anticipated completion date: Completed Planned Corrective Action: • SMHO will require managerial file review/approval for all new move-ins, port-ins and annual re-exams and the manager/lead will sign the check sheet for each file to indicate the review/approval has been completed.
Ensure full compliance with HUD regulations and internal policies related to eligibility documentation, income verification, utility allowances, and rent reasonableness determinations in the Housing Choice Voucher (HCV) program. 1. Correct the Deficiencies in the Identified Files Issue Missing 214...
Ensure full compliance with HUD regulations and internal policies related to eligibility documentation, income verification, utility allowances, and rent reasonableness determinations in the Housing Choice Voucher (HCV) program. 1. Correct the Deficiencies in the Identified Files Issue Missing 214 Declaration Form Utility Allowance Calculation (2 files) Missing Third-Party Income Verification Missing Rent Reasonableness Determination Action Contact tenant to obtain and file the signed 214 declaration. Recalculate and document the utility allowance using the current approved utility schedule. Request and obtain third-party verification; if unavailable, follow up with tenant and document efforts per HUD guidelines. Conduct and document rent reasonableness review for the current unit. Responsible Party Housing Specialist Housing Specialist Housing Specialist HQS/Rent Reasonableness Officer Timeline Within 10 business days Within 10 business days Within 10 business days Within 10 business days 2. Expand Review to Broader File Population Action Details Responsible Party Timeline Risk-based Review of Additional Files Identify Systemic Issues Report Findings Identify a representative sample of 100-200 files from the broader tenant population to assess the prevalence of the noted deficiencies. Track and categorize findings to identify patterns of noncompliance. Present findings to leadership and recommend procedural changes if systemic issues are found. Quality Assurance (QA) Team QA Manager QA Manager Within 45 days Within 60 days Within 75 days 3. Strengthen Policies, Procedures, and Staff Training Update Procedures Revise Standard Operating Procedures (SOPs) for file documentation, utility allowances, and rent reasonableness. Include clear checklists. Program Manager Within 90 days Staff Training Conduct mandatory refresher training on eligibility documentation,income verification protocols, rent reasonableness, and utility allowance schedules. File Audit Checklist Implement a standardized checklist for file reviews before final approval. 4. Ongoing Monitoring and Compliance Quarterly File Audits Continue random quarterly audits of tenant files to ensure ongoing compliance. Compliance Reporting Include compliance metrics in monthly management reports. Corrective Action Tracking Maintain a tracking system for noted deficiencies and corrective actions taken.
View of Responsible Officials: The Project agrees and will replenish the replacement reserve account. Responsible Party: Sherri Friedrich Estimated Completion: Funds will be replenished by April 30, 2025
View of Responsible Officials: The Project agrees and will replenish the replacement reserve account. Responsible Party: Sherri Friedrich Estimated Completion: Funds will be replenished by April 30, 2025
Finding 556197 (2024-001)
Significant Deficiency 2024
Action(s) taken or planned on the finding: A transfer was made to fully fund the reserve for replacements account on March 6, 2025.
Action(s) taken or planned on the finding: A transfer was made to fully fund the reserve for replacements account on March 6, 2025.
View Audit 354882 Questioned Costs: $1
FINDING 2024-002: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement internal controls to ensure timely monthly contributions to the replacement reserve and will address the shortfall by making up the missed deposits in th...
FINDING 2024-002: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement internal controls to ensure timely monthly contributions to the replacement reserve and will address the shortfall by making up the missed deposits in the subsequent period alongside the normal required contributions. Action Taken: The Organization will make the necessary required deposits to bring the balance of the reserve for replacement in alignment with requirements of Section 811 Capital Advance Program Regulatory Agreement.
FINDING 2024-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement a comprehensive internal control system to ensure all tenant files include required documentation, and will conduct a thorough review of all current tena...
FINDING 2024-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement a comprehensive internal control system to ensure all tenant files include required documentation, and will conduct a thorough review of all current tenant files to verify compliance and completeness. Action Taken: Ownership agrees with the auditor’s finding and recommendation and has hired a new management agent to oversee the implementation of a comprehensive internal control system, ensuring all tenant files include required documentation.
FINDING 2024-002: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement a comprehensive internal control system to ensure all tenant files include required documentation, and will conduct a thorough review of all current tena...
FINDING 2024-002: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement a comprehensive internal control system to ensure all tenant files include required documentation, and will conduct a thorough review of all current tenant files to verify compliance and completeness. Action Taken: Ownership agrees with the auditor’s finding and recommendation and Housing Opportunities Corporation will oversee the implementation of a comprehensive internal control system, ensuring all tenant files include all required documentation.
FINDING 2024-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement internal controls to ensure timely monthly contributions to the replacement reserve and will address the shortfall by making up the missed deposits in th...
FINDING 2024-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Management will implement internal controls to ensure timely monthly contributions to the replacement reserve and will address the shortfall by making up the missed deposits in the subsequent period alongside the normal required contributions. Action Taken: Management will make the necessary required deposits to bring the balance of the reserve for replacement in alignment with requirements of Section 811 Capital Advance Program Regulatory Agreement.
Residual receipts were not remitted to the residual receipts account in a timely manner. Residual receipts are required to be remitted within 90 days of year-end. In order to avoid this issue in the future, surplus cash will be calculated prior to the audit.
Residual receipts were not remitted to the residual receipts account in a timely manner. Residual receipts are required to be remitted within 90 days of year-end. In order to avoid this issue in the future, surplus cash will be calculated prior to the audit.
Please see below the new process ensuring replacement reserve requests are being made in a timely manner: 1) Quarterly Assessment: Quarterly review are now in place to assess reserve balances and ensure funds are used for necessary repairs. Monthly cash flow reports will align reserve balances with...
Please see below the new process ensuring replacement reserve requests are being made in a timely manner: 1) Quarterly Assessment: Quarterly review are now in place to assess reserve balances and ensure funds are used for necessary repairs. Monthly cash flow reports will align reserve balances with property needs. Formal Utilization Procedure: A written procedure has been established for requesting and using replacement reserve funds. This includes clear guidelines, approval workflows, and thresholds for reserve levels based on property needs. 3) Monitoring & Reporting: Periodic audits will ensure funds are spent according to HUD guidelines. 4) Staff Training & Oversight: Staff will receive training on proper reserve management, and management will increase oversight to ensure funds are used appropriately. Completion Date: 6/30/2025 Contact: Jackie Oliveira-Director of Affordable Housing
Please see below the new process ensuring that all HUD forms are certified by an authorized user: 1) Tracking System: A system has been implemented to monitor certifier assignments and send reminders for updates. 2) Training & Oversight: Staff training will be enhanced, and management will increase...
Please see below the new process ensuring that all HUD forms are certified by an authorized user: 1) Tracking System: A system has been implemented to monitor certifier assignments and send reminders for updates. 2) Training & Oversight: Staff training will be enhanced, and management will increase oversight to ensure compliance. 3) Monitoring and Accountability: Management will regularly review the certification process to ensure all forms are signed by the appropriate certifiers and to verify that all necessary updates are made promptly. Completion Date: 7/1/2024 Contact: Jackie Oliveira-Director of Affordable Housing
Please see below the process for obtaining correct documentation including 50059’s. 1. Notification: Tenants are notified in advance to submit required documentation. 2. Tenant Submission: Tenants provide updated income and household info 3. Verification: Property management verifies the submit...
Please see below the process for obtaining correct documentation including 50059’s. 1. Notification: Tenants are notified in advance to submit required documentation. 2. Tenant Submission: Tenants provide updated income and household info 3. Verification: Property management verifies the submitted information (e.g., contacting employers, reviewing documents). 4. Rent Calculation: Rent is recalculated based on updated income and family composition, per HUD guidelines. 5. 50059 Form: Completing the 50059 form accurately is crucial. It documents eligibility, income, and rent calculations. Errors can lead to incorrect rent, delays, or compliance issues. 6. Finalizing Recertification: After verification and accurate completion of the 50059, tenants are informed of any rent changes. 7. Record-Keeping: All recertification documents, including the 50059 form, are filed for compliance and audit purposes. By ensuring that recertifications are done annually, all tenant information is updated, and 50059 forms are accurately completed, doing so maintains program compliance and ensure that tenants are paying the correct rent based on their current financial situation. This is critical not only for HUD compliance but also for ensuring that tenants receive the appropriate level of assistance. Completion Date: 6/30/2025 Contact: Jackie Oliveira-Director of Affordable Housing
We have reviewed the finding regarding the need for a system ensuring that more than one individual holds an EIV (Enterprise Income Verification) license and that the license does not lapse. We understand the importance of maintaining access to the EIV system and ensuring uninterrupted compliance wi...
We have reviewed the finding regarding the need for a system ensuring that more than one individual holds an EIV (Enterprise Income Verification) license and that the license does not lapse. We understand the importance of maintaining access to the EIV system and ensuring uninterrupted compliance with HUD requirements. In response to this finding, we have taken the following corrective actions: 1. Designating Multiple EIV Users: We have implemented a policy that ensures at least two staff members are trained and hold active EIV access. This provides continuity in the event that one staff member is unavailable or the license needs to be renewed. 2. Tracking License Expiration: We have established a system to track EIV license expiration dates and will proactively initiate renewal processes well in advance of any license lapsing. A reminder system has been set up to notify both the employee holding the license and the supervisor, ensuring that renewals are completed on time. 3. Backup Procedures: In addition, we have documented backup procedures to ensure that another individual with the appropriate access is available to perform EIV-related tasks in case of staff turnover or other absences. Anticipated Completion Date: 6/1/2024 Contact: Jackie Oliveira-Director of Affordable Housing
Please see below the new process ensuring that all HUD forms are certified by an authorized user: 1) Tracking System: A system has been implemented to monitor certifier assignments and send reminders for updates. 2) Training & Oversight: Staff training will be enhanced, and management will in...
Please see below the new process ensuring that all HUD forms are certified by an authorized user: 1) Tracking System: A system has been implemented to monitor certifier assignments and send reminders for updates. 2) Training & Oversight: Staff training will be enhanced, and management will increase oversight to ensure compliance. 3) Monitoring and Accountability: Management will regularly review the certification process to ensure all forms are signed by the appropriate certifiers and to verify that all necessary updates are made promptly. Completion Date: 7/1/2024 Contact: Jackie Oliveira-Director of Affordable Housing
We have reviewed the finding regarding the need for a system ensuring that more than one individual holds an EIV (Enterprise Income Verification) license and that the license does not lapse. We understand the importance of maintaining access to the EIV system and ensuring uninterrupted compliance wi...
We have reviewed the finding regarding the need for a system ensuring that more than one individual holds an EIV (Enterprise Income Verification) license and that the license does not lapse. We understand the importance of maintaining access to the EIV system and ensuring uninterrupted compliance with HUD requirements. In response to this finding, we have taken the following corrective actions: 1. Designating Multiple EIV Users: We have implemented a policy that ensures at least two staff members are trained and hold active EIV access. This provides continuity in the event that one staff member is unavailable or the license needs to be renewed. 2. Tracking License Expiration: We have established a system to track EIV license expiration dates and will proactively initiate renewal processes well in advance of any license lapsing. A reminder system has been set up to notify both the employee holding the license and the supervisor, ensuring that renewals are completed on time. 3. Backup Procedures: In addition, we have documented backup procedures to ensure that another individual with the appropriate access is available to perform EIV-related tasks in case of staff turnover or other absences. Anticipated Completion Date: 6/1/2024 Contact: Jackie Oliveira-Director of Affordable Housing
Management is currently conducting a comprehensive review of the process to ensure alignment with compliance requirements and identify areas for improvement.
Management is currently conducting a comprehensive review of the process to ensure alignment with compliance requirements and identify areas for improvement.
View Audit 354707 Questioned Costs: $1
Management is currently conducting a comprehensive review of the process to ensure alignment with compliance requirements and identify areas for improvement. Status of finding: Corrective Action
Management is currently conducting a comprehensive review of the process to ensure alignment with compliance requirements and identify areas for improvement. Status of finding: Corrective Action
View Audit 354707 Questioned Costs: $1
CORRECTIVE ACTION PLAN Name of Auditee: L. W. Fraser Independent Living Project, Inc., Sheridan Court HUD Auditee Identification Number: 092-11227 Name of Audit Firm: Boulay PLLP Period Covered by Audit: Year Ended December 31, 2024 CAP Prepared by: Name: James Strickland Position: Controller Teleph...
CORRECTIVE ACTION PLAN Name of Auditee: L. W. Fraser Independent Living Project, Inc., Sheridan Court HUD Auditee Identification Number: 092-11227 Name of Audit Firm: Boulay PLLP Period Covered by Audit: Year Ended December 31, 2024 CAP Prepared by: Name: James Strickland Position: Controller Telephone Number: 612-861-1688 CURRENT FINDING ON THE SCHEDULE OF FINDINGS, QUESTIONED COSTS, AND RECOMMENDATIONS 2024-01: Monthly Deposits to the Replacement Reserve Comments on Finding: The Project is required by HUD to make monthly deposits to the replacement reserve in an amount prescribed by HUD. Payments for a portion of the year were lower than the required deposits, due to missed communication between HUD and the Project. The Project corrected the shortfall during 2024 and began making the required deposits. Statement of Concurrence or Nonconcurrence: We concur with the finding and recommendation. Corrective Action: Management has implemented additional procedures to ensure the monthly deposit to the replacement reserve is timely updated.
Management made the deposit.
Management made the deposit.
View Audit 354678 Questioned Costs: $1
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