Corrective Action Plans

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To ensure full compliance with prevailing wage requirements, the County will work with ADF to implement a corrective action plan focused on education, oversight, and accountability. This includes conducting regular audits of payroll records and job classifications to identify discrepancies, providin...
To ensure full compliance with prevailing wage requirements, the County will work with ADF to implement a corrective action plan focused on education, oversight, and accountability. This includes conducting regular audits of payroll records and job classifications to identify discrepancies, providing mandatory training for staff and contractors on wage determination and reporting procedures, and establishing a centralized compliance team to monitor ongoing projects. Certified payroll submissions will be reviewed for accuracy, and any violations will be promptly addressed through wage restitution and documentation updates. Clear communication channels will be maintained with subcontractors and employees to reinforce expectations and encourage reporting of concerns. This proactive approach will help safeguard workers’ rights and uphold regulatory standards.
Once the Project’s cash flow improves, the reserve for replacement deposits will be caught up and made monthly thereafter.
Once the Project’s cash flow improves, the reserve for replacement deposits will be caught up and made monthly thereafter.
The tenant recertifications will be monitored by the owner to ensure they are being completed in a timely manner.
The tenant recertifications will be monitored by the owner to ensure they are being completed in a timely manner.
The duties will be segregated as much as possible and the Board of Directors will remain involved in the financial affairs of the Coalition to provide oversight and independent review functions.
The duties will be segregated as much as possible and the Board of Directors will remain involved in the financial affairs of the Coalition to provide oversight and independent review functions.
Finding Number: 2024-039 Audit Type: Single Audit Finding Title: Inadequate Oversight of Davis-Bacon Compliance Related Finding: 2024-010 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Acti...
Finding Number: 2024-039 Audit Type: Single Audit Finding Title: Inadequate Oversight of Davis-Bacon Compliance Related Finding: 2024-010 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will establish a monitoring process to verify contractor compliance with Davis-Bacon wage requirements, including certified payroll reviews. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will ensure oversight responsibilities are clearly assigned and documented. 5. Status of Prior Year Finding This is a new finding.
Finding Number: 2024-033 Audit Type: Single Audit Finding Title: Delayed Availability of Financial Records 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will implement a records retentio...
Finding Number: 2024-033 Audit Type: Single Audit Finding Title: Delayed Availability of Financial Records 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will implement a records retention and access protocol to ensure timely availability of financial records for audit and reimbursement purposes. 3. Ahticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will ensure staff are trained on documentation procedures. 5. Status of Prior Year Finding This is a new finding.
Finding Number: 2024-032 Audit Type: Single Audit Finding Title: Delayed Final Reimbursement Due to Unresolved Agency Requests Related Finding: 2024-023 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned ...
Finding Number: 2024-032 Audit Type: Single Audit Finding Title: Delayed Final Reimbursement Due to Unresolved Agency Requests Related Finding: 2024-023 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will designate a grants coordinator to monitor agency requests and ensure timely responses. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will improve communication with funding agencies. 5. Status of Prior Year Finding This is a newt finding.
Finding Number: 2024-037 Audit Type: Single Audit Finding Title: Citizen Participation Plan Related Finding: 2024-025 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shonnah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will dev...
Finding Number: 2024-037 Audit Type: Single Audit Finding Title: Citizen Participation Plan Related Finding: 2024-025 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shonnah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will develop and adopt a formal Citizen Participation Plan in accordance with HUD requirements. 3. Anticipated Completion Date May 31, 2025 - Darrell stated this was followed 4. Management's Response Management concurs and will ensure the plan is reviewed and approved by the governing body. 5. Status of Prior Year Finding This is a new finding.
Finding Number: 2024-034 Audit Type: Single Audit Finding Title: Internal Control Defieiency over Section 3 Contract Requirements Related Fihding: 2024-030 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Plann...
Finding Number: 2024-034 Audit Type: Single Audit Finding Title: Internal Control Defieiency over Section 3 Contract Requirements Related Fihding: 2024-030 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will develop internal control procedures to ensure compliance with Section 3 contract requirements, including documentation and reporting. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will ensure staff are trained on Section 3 compliance expectations. 5. Status of Prior Year Finding This is a new finding.
Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Housing and Urban Development, Passed through City of Houston, HOME Investment Partnership Fund, Assistance Listing #14.239, Contract period: 08/2008 – 12/2028. Condition and context: ...
Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Housing and Urban Development, Passed through City of Houston, HOME Investment Partnership Fund, Assistance Listing #14.239, Contract period: 08/2008 – 12/2028. Condition and context: We noted the rental rate for 1 out of 6 tenant agreements tested for eligible families did not agree to the actual amount paid by the tenant. The tenant agreement reflected $600 in monthly rent compared to the amount paid of $575. The lease amount paid by the tenant did comply with HUD guidelines. Recommendation: Strengthen procedures to consistently maintain rent roll and ensure lease agreements are correct based on allowable tenant rental rates. Management’s response: Management and the contract bookkeeper will verify rent rolls on a monthly basis. Responsible officer: Previn Jones, Property Manager. Estimated completion date: Immediately.
Authority's Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies related to HQS inspections are being followed on a timely basis. Jessica Hinze, Director of Asset M...
Authority's Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies related to HQS inspections are being followed on a timely basis. Jessica Hinze, Director of Asset Management, will be responsible to implement this corrective action by December 31, 2025.
Management’s Response: Although the Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in th...
Management’s Response: Although the Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.
Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorpo...
Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorporate the recommendations above.
Management’s Response: Although the Corporation does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the...
Management’s Response: Although the Corporation does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.
Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorpo...
Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorporate the recommendations above.
2024-002: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and for both the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tena...
2024-002: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and for both the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not updated before the tenant’s anniversary date. • There was no verification of income by a third party provided. • There was no signed move-in/move-out inspection form provided. • There was no signed lease provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
View Audit 374026 Questioned Costs: $1
MATERIAL WEAKNESS 2024-002: Section 202, Assistance Listing No. 14.157 One tenant file was selected for testing and the following findings were noted: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not updated for the year tested • Move-in...
MATERIAL WEAKNESS 2024-002: Section 202, Assistance Listing No. 14.157 One tenant file was selected for testing and the following findings were noted: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not updated for the year tested • Move-in/move-out inspection form was not provided • Lease was not provided • Annual recertification of income by a third party was not provided Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
View Audit 374024 Questioned Costs: $1
2024-002: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and signatures, as required by HUD regulations, were missing from Form HUD-50059, Owner’s Certification of Compliance. Additionally, our testing indicated that the required deposits to the replacement res...
2024-002: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and signatures, as required by HUD regulations, were missing from Form HUD-50059, Owner’s Certification of Compliance. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
2024-002: Section 811, Assistance Listing No. 14.181 One tenant file was selected for testing and the following items were noted: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not signed • Move-in/move-out inspection form was not provided...
2024-002: Section 811, Assistance Listing No. 14.181 One tenant file was selected for testing and the following items were noted: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not signed • Move-in/move-out inspection form was not provided • Lease was not signed Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
2024-002: Section 202, Assistance Listing No. 14.157 One tenant file was selected for testing, and none of the required documentation to determine eligibility, as required by the HUD regulations, was provided. Additionally, our testing indicated that the required deposits to the replacement reserve ...
2024-002: Section 202, Assistance Listing No. 14.157 One tenant file was selected for testing, and none of the required documentation to determine eligibility, as required by the HUD regulations, was provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
View Audit 374016 Questioned Costs: $1
2024-002: Section 811, Assistance Listing No. 14.181 Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • One of the files was missing Form HUD-50059, Owner’s Certification of Comp...
2024-002: Section 811, Assistance Listing No. 14.181 Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • One of the files was missing Form HUD-50059, Owner’s Certification of Compliance. • One of the files was missing verification of income by a third party. • All three of the files were missing signed move-in/move-out inspection forms. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness. We are committed to compliance and accuracy as required by the U.S. Department of Housing and Urban Development. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Dr. Hawkins at shawkins@ulr.org.
Finding No. 2024-007 HUD Low Income Housing Preservation and Resident Homeownership Act of 1990 Federal Assistance Listing Number #99.999 Statement of Condition The owner was unable to provide support that they ensured passing HQS inspections were performed during 2024. Corrective Action Plan REACH ...
Finding No. 2024-007 HUD Low Income Housing Preservation and Resident Homeownership Act of 1990 Federal Assistance Listing Number #99.999 Statement of Condition The owner was unable to provide support that they ensured passing HQS inspections were performed during 2024. Corrective Action Plan REACH has policies in place for annual HQS inspections. During the audit, we were informed that the inspection form did not include inspection, work orders, and re-inspection. As a result of the 2024 audit, Management implemented using a new form in 2025 to capture inspection, work orders, and re-inspection.
Finding No. 2024-005 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner was unable to provide a listing that detailed the available to HOME tenants the contracted number and type of HOME units and therefore we were unable to test the H...
Finding No. 2024-005 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner was unable to provide a listing that detailed the available to HOME tenants the contracted number and type of HOME units and therefore we were unable to test the HOME program compliance for the audit year. Corrective Action Plan REACH utilizes a 3rd party property management company to manage the two properties located in Washougal, Washington. Management is setting up a new process to ensure that the 3rd party property management company can provide all required information.
Finding No. 2024-004 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. This is considered a temporary noncompliance as follows: "Next Available Unit"...
Finding No. 2024-004 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. This is considered a temporary noncompliance as follows: "Next Available Unit" rule: The owner must rent the next comparable or smaller unit that becomes vacant to a low-income household. Temporary noncompliance: The unit is temporarily out of compliance with HOME requirements, but the property can regain compliance by following the "next available unit" rule. Unit conversion: If the owner fails to comply and rents a comparable vacant unit to a non-low-income tenant, the over-income unit loses its low-income status and the building's compliance is reduced. A two bedroom unit did become available in 2024 and this tenant was not relocated. Corrective Action Plan A new review process is in placed to review the HOME units that will be re-classified the next time there is a vacant unit of the corresponding size/type.
Finding No. 2024-003 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. Corrective Action Plan A new process is in placed to review HOME unit count wh...
Finding No. 2024-003 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. Corrective Action Plan A new process is in placed to review HOME unit count when a unit becomes available.
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