Corrective Action Plans

Reference Number: 2024-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions – HQS Enforcement Classification of Finding: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance Authority’s Response & Actions Taken The Authority has made considerable progress in addressing the backlog of annual Housing Quality Standards (HQS) inspections and enforcement since transitioning the programmatic functions of the Housing Choice Voucher (HCV) program to third-party contractors. While significant strides have been made, the Authority acknowledges that further progress is necessary and remains actively engaged with its third-party HCV contractors to ensure that all HCV-assisted units meet and consistently maintain HUD’s HQS requirements. The Authority remains committed to ensuring that all units under contract are not only compliant but provide safe, sanitary, and decent housing in accordance with HQS regulations and the Authority’s Administrative Plan. The discrepancies noted in the audit were primarily due to inconsistencies in the application of enforcement timelines and insufficient documentation related to landlord extension requests and their corresponding approvals. Importantly, all delayed follow-up inspections identified during the audit were successfully completed outside the required timeframes. Each unit passed inspection and was found to be compliant with HUD HQS standards. Housing assistance payments (HAP) were accurately processed for these units, and no abatements were necessary. The Authority continues to refine its inspection protocols, improve documentation practices, and reinforce contractor accountability to ensure timely and compliant HQS inspections across the entire HCV portfolio. The Authority uses the Emphasys Elite software to schedule, record, and enforce HQS inspections. The Authority also uses its Customer Relations Management (CRM) system to track units that have failed an HQS inspection. To prevent recurrence, the Authority has already implemented the following corrective steps: • Daily review process of units that have failed and/or no-showed two or more consecutive inspections. The inspection department uses this process to accurately review the letter generation and notification process for HQS deficiencies and notices of abatement. The inspection department manually reviews and generates both letters to their respective parties (landlord/owner and tenant). • In addition to the daily morning review, at the close of business the HCV contractor will review the failed emergency inspections and will schedule any emergency re-inspections to ensure compliance with HQS enforcement rules and regulations. The Authority’s corrective steps outlined above will significantly strengthen its compliance efforts, reduce risk, and enhance the overall quality and integrity of the HCV program. Anticipated Implementation Date September 30, 2025 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

Reference Number: 2024-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Special Tests and Provisions (Housing Quality Standards Inspections) Classification of Finding: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance Authority’s Response & Actions Taken The Authority has made considerable progress in addressing the backlog of annual inspections that resulted from restricted unit access and the temporary implementation of HUD waivers during the COVID-19 national pandemic. These necessary public health measures, while appropriate at the time, contributed to delays in fulfilling Housing Quality Standards (HQS) inspection requirements. The Authority acknowledges that additional progress is still needed and remains actively engaged with its third-party Housing Choice Voucher (HCV) contractors to ensure timely completion of all outstanding inspections. The Authority is fully committed to ensuring that all units under contract meet and exceed HUD’s standards for safe, decent, and sanitary housing, in accordance with HQS and the Authority’s Administrative Plan. All five annual inspections with exceptions noted during the audit were inspected after the required timeframes and ultimately passed inspection with the units determined to be in full compliance with HUD requirements. The Authority uses the Emphasys Elite software to check against HUD's PIH Information Center (PIC) system to identify units with outstanding Housing Quality Standards (HQS) Inspections. The Authority has scheduled HQS Inspections for the units identified to be out of compliance. Key strategies and controls in place are as follows: Project-Based Program: For the PBV program, the Authority has already implemented the following procedures to result in timely HQS inspections of all units. 1. Matching data between the Emphasys Elite system of records to ensure the most overdue inspections are scheduled. 2. A bulk inspection process was implemented effective November 1, 2024. Through this process, all units for a particular PBV site are scheduled for their annual inspections in the same month each year. This ensures that all units are inspected annually. The scheduling process includes: a. Posting the bulk inspection schedule on the website. This is an annual schedule which identifies properties, property management, and the month the project will be inspected. b. Providing notice to the applicable site owner/manager of the inspection date and the units to be inspected. The notice will include information on how to prepare for the inspection, a request to have site staff accompany the inspector, and a reminder to notify residents so access can be gained even if no one is home. c. Sending individual inspection notices to the owner and participant for each scheduled inspection. For the PBV portfolio, staff will work directly with property management and developers to ensure access to units is continuously granted. Upcoming bulk inspections are also discussed on calls with owners. This allows for increased planning and respect for noticing timelines. Tenant-Based Program: • Review the report of outstanding HQS Inspections on a weekly basis. • Schedule outstanding HQS Inspections in order of aging date. • Conduct HQS Inspections prior to the anniversary date of previously completed inspection. • Running a monthly report of failed inspections and comparing them with future scheduled inspections to ensure that a second inspection has been scheduled. • Running a monthly report to identify units with two failed inspections to ensure all have been abated correctly. • Implement weekly monitoring to ensure all units are properly abated and lifted timely when units pass inspections and contracts are properly terminated after being in abatement for 180 days without a cure. The Authority has worked with Emphasys to identify the best ways to sort aged HQS inspections due and generate/schedule in bulk, as well as maximize the Inspector’s workday by routing the tenantbased units in a way that flows in a clear and orderly manner. Similar to the handling of delinquent annual reexaminations, the Authority is checking the data in PIC with the system of records and processing 50058 corrections where inspections have been completed but rejected in PIC due to out of sequence effective dates and any other fatal errors that require corrective action. The procedures for the project-based and tenant-based programs are already in effect, and the backlog of inspections has been substantially reduced as illustrated by a reporting rate of 99% for SEMAP Indicator 12 annual HQS inspections as of May 31, 2025. Monthly performance reports are also reviewed by management to ensure inspection timeliness is maintained. Anticipated Implementation Date September 30, 2025 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

Reference Number: 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Authority’s Response & Actions Taken The Authority has made considerable progress in addressing the backlog of annual re-examinations that resulted from the transition of a third-party contractor to new third-party contractors to administer its Project-Based and Tenant-Based Voucher Programs. The material weakness was further exasperated by tenants not responding to re-examination notices or failing to provide the required income and household documentation by established deadlines. In an effort to avoid unnecessary subsidy terminations and protect vulnerable tenants, the Authority’s administrative plan allows for extended grace periods and repeated follow-ups. While this tenant-centered approach helped mitigate adverse outcomes for families, it also contributed to delays and ultimately resulted in noncompliance with HUD’s timeliness requirements. The Authority recognizes the critical importance of conducting timely and accurate annual reexaminations to maintain program integrity, ensure proper subsidy determination, and remain in compliance with HUD regulations. With that said, the Authority continues to work diligently with its third-party HCV contractors, city department partners, onsite service providers and property management companies to ensure the Authority is timely recertifying all assisted households. Although the Authority has established procedures to initiate reexaminations 150 days in advance of their due dates, a significant portion of the delays cited in the recent audit were the result of tenant non-responsiveness—specifically, the failure to provide required documentation despite multiple notices and outreach efforts. Importantly, all overdue reexaminations identified during the audit were ultimately completed. Each of the affected households was determined to be eligible under HUD guidelines, and housing assistance payments (HAPs) were accurately processed based on verified household information. The Authority remains committed to its tenant-centered mission, which prioritizes preventing unnecessary subsidy terminations and supporting household stability. At the same time, the Authority fully recognizes the importance of complying with HUD’s reexamination timelines. The corrective actions outlined below are designed to ensure that tenant-related delays are minimized, documented, and managed in a way that prevents the recurrence of this material weakness. To address this finding and in accordance with the Authority’s Administrative Plan and HUD rules and regulations, the Authority has already implemented the following actions starting fiscal year 2023-24: • Initiating the Annual Re-examination process 150 days before the required anniversary date to give households more time to comply. • Reviewing the report of outstanding Annual Re-examinations on a weekly basis. • Scheduling additional partner calls with property management and resident services to assist non-compliant families. • Enforcing Annual Reexamination compliance through the Intent to Terminate process • Scheduling and completing on-site visits for senior-disabled sites and non-restricted sites with large numbers of families out of compliance. • Reviewing discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. Per CFR 24 985.3, Section 8 Management Assessment Program (SEMAP) Indicator 9 for Annual Reexamination, 95% of all households must be recertified within 14 months of their last annual recertification to maintain full compliance, and 90% of all households must be recertified within 14 months to maintain partial compliance with the SEMAP Assessment standards required by HUD. The Authority expects to hit 90% by the end of the SEMAP year September 30, 2025. Anticipated Implementation Date September 30, 2025 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

Title: Housing Choice Voucher Program Name: Section 8 Housing Choice Vouchers ALN: 14.871 Description: During the audit of the Authority, it was noted that federal funds were inappropriately loaned to affiliated entities without proper authorization or adherence to federal cash management requirements. Specifically, the entity disbursed $43,533 in federal funds to the Housing Authority of Florence under the guise of a temporary loan, which was not supported by a formal agreement, lacked board approval, and was not repaid within the fiscal year. Planned Corrective Action: Today’s Marlboro County Housing Authority management concurs with the auditor’s finding that federal funds were disbursed to an affiliated entity without proper authorization, documentation, or compliance with federal cash management requirements. The Authority acknowledges that this disbursement represented a lapse in internal controls and was not consistent with the requirements outlined in 2 CFR §200.305(b). During the fiscal year ended September 30, 2024, the Authority also had a payable to the same affiliate in its Public Housing Program totaling $37,658. During the current 2024-2025 fiscal year, the Authority reimbursed its HCV program the amount loaned from its HCV program by the funds owed to the affiliate in its Public Housing Program. Today’s Marlboro County Housing Authority currently has an amount of $2,015 due to its affiliate as of May 31, 2025.

2024-002 – REPORTING Other Matter/Significant Deficiency Auditee’s Response and Planned Corrective Action The Authority hired a new Executive Director in November 2023. Under new management, the year-end financial statements will be prepared and submitted timely and formalized guidelines for financial reporting will be created. New controls over financial close process will ensure more accurate financial reporting prior to the audit. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Kayla Potter, Executive Director

The Management of the Authority agrees with the findings; we will implement improved internal controls to ensure that all annual recertifications are performed in a timely manner and that all required documents are kept in an organized manner. The Authority hired a Compliance Specialist in May 2025 to perform quality control checks on the files to eliminate errors. The HCV Program Director is the responsible party, and controls will be in place by the end of the September 30, 2025 fiscal year.

The Management of the Authority agrees with the findings; we will implement improved internal controls to ensure that all annual recertifications are performed in a timely manner and that all required documents are kept in an organized manner. The Authority hired a Compliance Specialist in May 2025 to perform quality control checks on the files to eliminate errors. The Public Housing Director is the responsible party, and controls will be in place by the end of the September 30, 2025 fiscal year.

Planned Implementation Date of Corrective Action: July 2025 Person Responsible for Correctove Action: Krishonna Murray, Executive Director I. 2024-001 Eligibility Rent Calculation Other Matter/Significant Deficiency The Authority had instances of missing income verifcation. Gardner Housing Authority has establised a system of internal control over the participant recertification process that meets HUD's requirements. Seven (7) to ten (10) files will be reviewed fiscally for quality assurance.

The Authority will obtain SEMAP training for personnel to ensure proper SEMAP reporting and documentation. The Authority will also use the computer system for SEMAP documentation.

FINDING No. 2024-003: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure all documentation related to applicants and tenants are properly executed and maintained, and that the manager verifies eligibility by obtaining all required documents for potential tenants while verifying and maintaining support for tenant income eligibility through the EIV system in a timely manner. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding this plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

FINDING No. 2024-002: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should comply with state law and HUD regulations for refunding security deposits timely. Action Taken: Staff training has been provided and included in monthly reporting procedures.

Oversight Agency for Audit, Piazza Apartments respectfully submits the following corrective action plan for the year ended September 30, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: October 1, 2023, through September 30, 2024 The findings from the September 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2024-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: Management should implement procedures to ensure the Project submits PRAC renewal requests in accordance with HUD requirements. Action Taken: New staff has been put in place to monitor and submit all renewals in a timely fashion.

The Housing Commission has a better understanding of the Federally Insured requirements. We will monitor the bank accounts rather than strictly rely on the financial institutions. We have moved the funds over to another financial institution to receive the proper coverage.

Audit Report Reference: 2024-003 Program name: Research and Development Completion Date: September 30, 2025 Finding 2024-003 is a repeat finding (2023-001) from fiscal year end September 30, 2023. The Health System implemented change controls and audit of employee permissions per the corrective action plan for 2023-001.The corrective actions for repeat finding 2024-003 addresses documentation of performed controls and training for employees involved in the control activities. Workday Change Review: The HRIS team will continue with a change review audit as they have done in the previous year with a few enhancements to increase auditability. The Sr. HRIS Manager will send official communication to the HRIS team to initiate the end-of-year change review. This email will provide a clear timeline for the audit period with a hard deadline. Once complete, the HR Compliance Manager and/or the Sr. HRIS Manager will issue a written communication to document the completion of the review summary of findings (if any), and corrective actions taken (if applicable). This will remedy the issue of missing approval documentation. The team will also be reeducated around the need to document written approval and testing for changes throughout the year. Workday Security Review: The HRIS team will continue to conduct an audit of security roles and users within Workday to ensure that permissions are updated appropriately. The HRIS Analyst will generate reports for the Sr. HRIS Manager's review, identifying any required changes. The analyst will then make these updates in Workday, followed by a new report for verification. Upon successful verification, the Sr. HRIS Manager will send a formal written communication of the approved changes. Workday Terminations: To address the access provisioning deficiency as it relates to terminating employees, the management team will be re-trained in the importance of adhering to timely terminations of employees in Workday. Person Responsible: Ashley Cesarano - HR Compliance and Workplace Accommodations Manager; Karen Alvarado – Senior Manager HRIS E-mail address: Ashley.Cesarano@bmc.org; Karen.Alvarado@bmc.org

Corrective Action Plan: The Project is doing all that is within its control to get the vacant units rented. Auditee Contact: Bryant Edgerton, Board Chairman

Corrective Action Plan: The Project is doing all that is within its control to get the vacant units rented. Auditee Contact: Lisa Poteat (The Arc of North Carolina, Inc.), Management Agent

Corrective Action Plan: The Project is doing all that is within its control to get the vacant units rented. Auditee Contact: Lisa Poteat (The Arc of North Carolina, Inc.), Management Agent

Corrective Action Plan: The Project is doing all that is within its control to get the vacant units rented. Auditee Contact:Lisa Poteat (The Arc of North Carolina, Inc.), Management Agent

Corrective Action Plan: The Project is doing all that is within its control to get the vacant units rented. Auditee Contact: Lisa Poteat (The Arc of North Carolina, Inc.), Management Agent

CORRECTIVE ACTION PLAN Name of auditee: Bellflower Oak Street Manor Name of audit firm: Propp Christensen Caniglia LLP Period covered by the audit: October 1, 2023 through September 30, 2024 CAP prepared by: Name: Sean Calendar Position: Director of Accounting Telephone: (916) 357-5300 Comments: Management agrees with the 2024-001 finding. Actions: Management will implement policies and procedures to ensure the monthly deposit to the replacement reserve is made in accordance with HUD regulations. Additionally, management will fund $19,824 of additional reserve deposits to make the account whole; $9,912 for the current period’s unfunded deposits and an additional $9,912 for unfunded deposits from prior period, as reported in finding 2023-01.

Policy is being updated. The Maintenance Supervisor will obtain the required 3 bids that include wage rates and review them with the director before final decisions are made. Obtained bids will be kept on file for the period of time required for auditing purposes.

Financial information will be relayed to the fee accountant in a timely manner so that we can meet HUD reporting deadlines.

As already indicated, income from tenant payments were not being properly applied to the correct revenue streams, all monies received were being coded to dwelling rents and not extra utility and cable charges as applicable. See response to 2024-001. Also, we have raised the fee charged to the tenants for cable to ensure that the expense is being adequately covered.

A new procedure is being implemented. Flat rents will be reviewed annually in October when HUD releases their FMR reports. Then, as annual recertifications are being completed, the latest flat rent will be applied.

Corrective Action Plan (CAP) Date: June 23, 2025 From: Dallas County Health & Human Services (DCHHS) Subject: Response and CAP to Finding 2024-002: Reporting – Significant Deficiency in Controls over Compliance and Noncompliance - ALN # 14.871 & 14.879 – Housing Voucher Cluster – Contract # TX559 – Section 8 Housing Choice Vouchers (“HCV Program”). Responsible Party - Thomas Lewis, Assistant Director of Housing Services - Ganesh Shivaramaiyer, Deputy Director of Finance and Operations Implementation Date: July 01, 2025 Cause - The HCV Program did not have controls in place to compare all electronic HUD-50058 forms against the original related hard copy form. DCHHS Response: The hard copy HUD Form 50058 included in each file is a printed version of the corresponding electronic submission sent to HUD. Program Monitors review this same form during their file assessments. Current Practice – HUD Form 50058 Submission Process: To support timely compliance with HUD reporting requirements, the Dallas County Housing Authority (DCHA) Housing Choice Voucher Program (HCVP) follows a structured and efficient process for the submission of HUD Form 50058 Family Reports. Case Managers complete the transaction upon verification of all required documentation in the client file. At this point, the Data Analyst gathers the batch file and submits the HUD Form 50058 Family Reports electronically. The Data Analyst generates error reports and forwards the report to the Case Manager Supervisor. The Supervisor assigns the error report along with a designated correction and return deadline to the appropriate Case Manager. This structured workflow ensures timely submission and resubmission of any current or rejected reports. The current model balances timeliness and quality control, aligning with HUD’s programmatic and compliance expectations. Proposed Process - HUD Error Reports or Rejections: To improve the efficiency of resolving rejected or erroneous HUD Form 50058 submissions, DCHHS will implement an additional layer of oversight. Program Monitors will now have access to the "History" section within the Housing software HAPPY, to verify the submission dates of HUD Form 50058 Family Reports. This process serves as a checks-and-balances system, ensuring alignment between the submission date and the effective date, and provides a secondary review to confirm that the appropriate transaction code is submitted within HUD’s 60-day window from the effective date noted on the form.