Corrective Action Plans

Finding 562237 (2025-002)

Significant Deficiency 2025

CA

HUD Housing Programs

2025-002 Reportable Condition — Compliance: Condition: The Organization did not receive HUD authorization for two withdrawals from the Reserves for Replacement account totaling $2,500 during the year. Action taken: $2,000 has been returned to the Reserves for Replacement account. Contact person: Nan...

2025-002 Reportable Condition — Compliance: Condition: The Organization did not receive HUD authorization for two withdrawals from the Reserves for Replacement account totaling $2,500 during the year. Action taken: $2,000 has been returned to the Reserves for Replacement account. Contact person: Nancy Jordan Completion date: May 15, 2025 Explanation of Disagreement: Not applicable Repeat finding: No

View Audit 357832

Finding 562236 (2025-001)

Significant Deficiency 2025

Desert Willow Apartments

CA

HUD Housing Programs Cash Management

2025-001 Reportable Condition — Compliance: Condition: The Organization did not receive HUD authorization for three withdrawals from the Residual Receipts account totaling $18,354 during the year. Action taken: $5,000 has been returned to the Residual Receipts account. Contact person: Nancy Jordan C...

2025-001 Reportable Condition — Compliance: Condition: The Organization did not receive HUD authorization for three withdrawals from the Residual Receipts account totaling $18,354 during the year. Action taken: $5,000 has been returned to the Residual Receipts account. Contact person: Nancy Jordan Completion date: May 15, 2025 Explanation of Disagreement: Not applicable Repeat finding: No

View Audit 357832

Finding 559914 (2025-002)

Significant Deficiency 2025

Houston Rhf Housing, Inc. Dba Creekbend Gardens 114-Ee52

IN

HUD Housing Programs Subrecipient Monitoring

Statement of Condition 2025-002 (Assistance Listing 14.157): During the year ended January 31, 2025, 1 move-out resident file selected for testing under the compliance supplement were missing necessary documents required by the PRAC and HUD Handbook 4350.3. Recommendation: Management should ensure ...

Statement of Condition 2025-002 (Assistance Listing 14.157): During the year ended January 31, 2025, 1 move-out resident file selected for testing under the compliance supplement were missing necessary documents required by the PRAC and HUD Handbook 4350.3. Recommendation: Management should ensure that all resident files are maintained at the site for each resident of the Property in accordance with the HUD Handbook 4350.3. Management Response: Management agrees with the recommendation and will ensure that resident files are retained in accordance with the HUD Handbook 4350.3. The resident moved-out on June 13, 2024. No further action is required.

View Audit 355850

Finding 559913 (2025-001)

Significant Deficiency 2025

Houston Rhf Housing, Inc. Dba Creekbend Gardens 114-Ee52

IN

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Statement of Condition 2025-001 (Assistance Listing 14.157): During the year ended January 31, 2025, HUD approved $83,950 of withdrawals as a pre-release to pay for HVAC replacements and boilers at the Property. The Corporation used $24,300 of the pre-release to fund operations, instead of paying th...

Statement of Condition 2025-001 (Assistance Listing 14.157): During the year ended January 31, 2025, HUD approved $83,950 of withdrawals as a pre-release to pay for HVAC replacements and boilers at the Property. The Corporation used $24,300 of the pre-release to fund operations, instead of paying the invoices approved by HUD and had not paid as of January 31, 2025. Recommendation: Management should ensure that HUD approved reserve for replacement withdrawals are used for the approved purposes. Management Response: Agree. The Corporation paid the remaining costs included in the HUD approved withdrawal on March 3, 2025. There is no further action required.

View Audit 355850 Questioned Costs: $1

Finding 559068 (2025-001)

Significant Deficiency 2025

Harlem Tenants Association, Inc.

FL

HUD Housing Programs

The responsible official for the corrective action plan is Valerie Vallee, Vice President. The anticipated completion date is April 9, 2025. Response: Unpaid replacement reserve escrow from August 2024 was paid in April 2025.

View Audit 355338

Finding 1225611 (2024-002)

Material Weakness 2024

Net Treatment Services, Inc. D/b/a Net Community Care

PA

Internal Control / Segregation of Duties Student Financial Aid Cash Management

Type of Finding: Material Weakness in Internal Controls over Compliance- Cash Management Recommendation: We recommend that management ensure that all invoices are reviewed and approved before submission. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding....

Type of Finding: Material Weakness in Internal Controls over Compliance- Cash Management Recommendation: We recommend that management ensure that all invoices are reviewed and approved before submission. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a policy which requires each drawdown to be reviewed and to be based only on expenses incurred for the period, prohibiting the use of a straight-line calculation to draw down funds. Invoices are also approved by the CFO or CEO prior to submission. Name of the contact person responsible for corrective action: Regan Kelly, CEO of Net Treatment Services, Inc. dba: NET Community Care (215) 451-7000 Planned completion date for corrective action plan: December 31, 2026.

View Audit 408500

Finding 1224527 (2024-003)

Material Weakness 2024

Harvest Homes Corporation 094-Hd005-Np-Cmi

ND

HUD Housing Programs Internal Control / Segregation of Duties Material Weakness § 200.512

Contact Person – Terry Hanson, Executive Director Corrective Action Plan – The Project will review its policies and procedures over timely reporting submissions. Completion Date – 12/31/26

View Audit 407778

Finding 1224360 (2024-001)

Material Weakness 2024

Center for Independent Living of North Florida Inc.

FL

Subrecipient Monitoring HUD Housing Programs Program Income

"Management concurs that stronger documentation surrounding the collection and monitoring of Continuum of Care program income would have strengthened internal controls and the audit trail. The finding relates to a program that has since been discontinued. Throughout the audit period, all program inc...

"Management concurs that stronger documentation surrounding the collection and monitoring of Continuum of Care program income would have strengthened internal controls and the audit trail. The finding relates to a program that has since been discontinued. Throughout the audit period, all program income that was collected was used for allowable program purposes; however, management acknowledges that documentation supporting assessment, collection, monitoring, and reconciliation procedures should have been more comprehensive. Although this activity is no longer part of the Organization's operations, Ability1st has strengthened its overall documentation standards. Should the Organization administer future programs involving program income, written policies and procedures will be implemented prior to program implementation and will include: • documented fee assessment methodology; • collection and deposit procedures; • reconciliation requirements; • supervisory review; • record retention standards; and • periodic internal monitoring. Management believes these procedures will provide an appropriate level of accountability and compliance with federal requirements should program income be collected in the future. Responsible Official: Executive Director Implementation Date: Completed for discontinued program; procedures will be implemented before any future program income activity."

View Audit 407668

Finding 1223694 (2024-002)

Material Weakness 2024

145 SO. 3RD STREET HOUSING DEVELOPMENT FUND CORPORATION

NY

HUD Housing Programs Eligibility

Management has implemented the following corrective actions to address the deficiencies noted in tenant file maintenance and eligibility determinations: A. Strengthening Recertification Compliance 1. Implementation of a Recertification Tracking System: a. A digital tracking log will be used to monit...

Management has implemented the following corrective actions to address the deficiencies noted in tenant file maintenance and eligibility determinations: A. Strengthening Recertification Compliance 1. Implementation of a Recertification Tracking System: a. A digital tracking log will be used to monitor upcoming recertifications with alerts at 90, 60, and 30 days before due dates. b. The Senior Housing Specialist will oversee timely completion and issue weekly progress reports to the Director of Asset Management. c. Non-compliant files will be flagged for immediate follow-up with tenants. d. PMCS, a third-party group, will assist with recertifications. 2. Enforcing Timely Recertifications: a. Recertifications must be completed no later than 30 days before expiration. b. Staff will receive monthly reminders, and escalation measures will be implemented for delays. 3. Quarterly Internal Audits: a. PMCS and internal staff will conduct random file audits every three months to ensure adherence. b. Deficiencies will be addressed in real-time, and corrective steps will be logged. B. Ensuring EIV System Compliance 1. Standardizing EIV Compliance Procedures: a. A formal checklist will be created for EIV report reviews, ensuring all required reports are generated before lease renewals. b. EIV data will be cross-referenced with tenant files every quarter to ensure completeness. 2. Internal Monthly EIV Reviews: a. The Senior Housing Specialist will generate and review EIV reports on the 1st of each month. b. The Director of Asset Management, Third-Party Compliance Officer (PMCS), and Senior Housing Specialist will verify compliance before reports are finalized. 3. Quarterly Compliance Reports: a. The Compliance Officer will submit a quarterly compliance report documenting completion rates and deficiencies. C. Enhancing Staff Training and Accountability 1. Mandatory Quarterly Training: a. Staff will undergo quarterly compliance training covering HUD Handbook 4350.3, recertifications, and EIV compliance. b. Training sessions will be documented, and staff performance assessed. 2. Clarification of Responsibilities: a. Staff roles will be clearly outlined in a Standard Operating Procedure (SOP) document. b. Staff will be required to acknowledge their roles in compliance processes. 3. PMCS Involvement for Training Support: a. PMCS will offer supplementary training sessions as needed. D. Documentation and Oversight Enhancements 1. Maintaining Complete and Auditable Files: a. All lease and EIV documentation will be stored both physically and digitally. b. A real-time compliance dashboard will track completion rates. 2. Routine Management Reviews: a. The Senior Housing Specialist and Director of Asset Management will conduct monthly spot checks to verify document accuracy and completion. b. Non-compliance will result in formal corrective actions.

View Audit 407198

Finding 1223693 (2024-001)

Material Weakness 2024

145 SO. 3RD STREET HOUSING DEVELOPMENT FUND CORPORATION

NY

HUD Housing Programs Material Weakness Matching / Level of Effort / Earmarking

Management will immediately reimburse the property’s operating account for the unauthorized $10,000 distribution. Procedures will be implemented to ensure that all future loan repayments and cash distributions comply with HUD surplus cash requirements and the regulatory agreement. Surplus cash calcu...

Management will immediately reimburse the property’s operating account for the unauthorized $10,000 distribution. Procedures will be implemented to ensure that all future loan repayments and cash distributions comply with HUD surplus cash requirements and the regulatory agreement. Surplus cash calculations will be reviewed and approved prior to authorizing any distributions. Staff responsible for financial oversight will receive additional training on HUD surplus cash rules to prevent recurrence.

View Audit 407198

Finding 1223449 (2024-101)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions HUD Housing Programs Matching / Level of Effort / Earmarking § 200.303

The Program Integrity Unit has established SOPPs which identifies the method for identifying fraud cases, investigating cases, and developed procedures in collaborating and cooperating with legal authorities, for referring credible allegations of fraud cases to law enforcement officials.

View Audit 406809

Finding 1223447 (2024-099)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

During the audit period, the Department did not complete the required ADP Risk Analysis and System Security Review for systems supporting the Medicaid Program, and certain monitoring controls were not operating at a sufficient level of precision to ensure compliance with federal requirements. To add...

During the audit period, the Department did not complete the required ADP Risk Analysis and System Security Review for systems supporting the Medicaid Program, and certain monitoring controls were not operating at a sufficient level of precision to ensure compliance with federal requirements. To address this finding, the Department recently issued Requests for Qualifications (RFQs) to seven qualified vendors to perform comprehensive security risk assessments of the Medicaid Enterprise Systems (MES), including the VIBES Eligibility and Enrollment System, Provider Enrollment Application (PEA), Pharmacy Benefit Management (PBM) solution, and related supporting systems. Vendor responses are due within three weeks, after which the Department will evaluate submissions and proceed with the procurement process. The selected vendor will conduct the required risk assessments, identify control deficiencies and security vulnerabilities, and provide recommendations to strengthen the Department's security posture and compliance framework. The Department will work collaboratively with its technology partners, system vendors, and oversight entities to implement corrective actions identified through the assessments and enhance monitoring controls to ensure ongoing compliance with applicable federal requirements.

View Audit 406809

Finding 1223218 (2024-008)

Material Weakness 2024

Williston Basin Public School District #7

ND

Subrecipient Monitoring Procurement, Suspension & Debarment HUD Housing Programs § 200.303 § 200.317 § 200.318 § 200.327

2024-008 – CORONAVIRUS CAPITAL PROJECT FUND – LACK OF SUPPORT FOR PROCUREMENT – ALN 21.029 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain support surrounding the selection process for the construction management at-risk (CMAR) fo...

2024-008 – CORONAVIRUS CAPITAL PROJECT FUND – LACK OF SUPPORT FOR PROCUREMENT – ALN 21.029 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain support surrounding the selection process for the construction management at-risk (CMAR) for the CTE Center. Therefore, we were unable to determine if the CMAR selection was properly completed. In addition, Willison Basin Public School did not have a procurement policy. Management’s Response: We agree. The District will work to ensure that future projects are properly procured within state law and federal guidelines. Anticipated Completion Date: FY 2025

View Audit 406706

Finding 1222996 (2024-001)

Material Weakness 2024

Housing Authority of the City of Yakima

WA

HUD Housing Programs Reporting Internal Control / Segregation of Duties § 200.512

2024-001 Reporting – Late Report Submission to Federal Audit Clearinghouse and HUD Recommendation: Develop internal controls that provide month-end and year-end accounting close milestones that include deadlines that will ensure external reporting deadlines are able to be met. Explanation of disagre...

2024-001 Reporting – Late Report Submission to Federal Audit Clearinghouse and HUD Recommendation: Develop internal controls that provide month-end and year-end accounting close milestones that include deadlines that will ensure external reporting deadlines are able to be met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Authority has reviewed and updated its financial reporting and closing processes and controls for the preparation of the final trial balances and related schedules. As part of this process, the Authority has created a year-end checklist with deadlines and status meetings to monitor the progress. Name(s) of the contact person(s) responsible for corrective action: Lowel Kruger, Executive Director. Planned completion date for corrective action plan: December 31, 2024.

View Audit 406526

Finding 1221747 (2024-007)

Material Weakness 2024

Young Womens Christian Association of Greater Lafayette

IN

Allowable Costs / Cost Principles HUD Housing Programs Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges gaps in VOCA employee file documentation.  Implement a standardized checklist for VOCA and other grant-funded employees that includes required acknowledgements (nondiscrimination, drug-free workplace, confidentiality, ...

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges gaps in VOCA employee file documentation.  Implement a standardized checklist for VOCA and other grant-funded employees that includes required acknowledgements (nondiscrimination, drug-free workplace, confidentiality, and related forms).  Educate HR staff in auditing best practices, emphasizing complete and accurate employee files and the specific grant documentation required.  Schedule periodic reviews of VOCA-funded employee files (at least quarterly) to verify that all required documents are present and current, with results reported to management.

View Audit 406008

Finding 1221445 (2024-001)

Material Weakness 2024

HIGHLAND PARK HOUSING COMMISSION

MI

HUD Housing Programs

Planned Corrective Action: Organization of recertification / eligibility files by effective date, 100% completion of all recertifications by 2/28/2025 Contact Name and Title Responsible for Corrective Action Joy Flood, Executive Director

View Audit 405730

Finding 1221394 (2024-006)

Material Weakness 2024

Village of Ontario

WI

Cash Management HUD Housing Programs Material Weakness

Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants, Assistance Listing Number 14.251 Award Period: March 9, 2022 through August 31, 2030 Recommendation: The Village should im...

Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants, Assistance Listing Number 14.251 Award Period: March 9, 2022 through August 31, 2030 Recommendation: The Village should implement controls to report accurate information in Federal Reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Village continues to work at updating its policy and procedures manuals. The Village will amend policies as necessary. Name(s) of the contact person(s) responsible for corrective action: Teresa Taylor, Village Clerk-Treasurer. Planned completion date for corrective action plan: The Village will adopt reporting policies in accordance with Uniform Guidance by December 31, 2025.

View Audit 405707

Finding 1218259 (2024-007)

Material Weakness 2024

Housing Authority of the City of Columbia

SC

HUD Housing Programs

Finding 2024-007: During the year ended June 30, 2024, Housing Choice Voucher Program funds were used by other federal programs, resulting in Housing Choice Voucher Program funds being used to cover expenses for other federal programs and defederalized funds. a. Comments on the Finding We agree with...

Finding 2024-007: During the year ended June 30, 2024, Housing Choice Voucher Program funds were used by other federal programs, resulting in Housing Choice Voucher Program funds being used to cover expenses for other federal programs and defederalized funds. a. Comments on the Finding We agree with finding 2024-007 b. Action(s) Taken or Planned on the Finding The Authority has hired a new CFO who will provide the leadership and technical assistance needed to ensure the Finance department operates effectively within regulations. The Authority has created new policies ensuring monthly reconciliations and implemented the process of reconciling interfund balances to ensure balances are settled monthly, to ensure funds are not intermingled with other federal programs. Columbia Housing is also in the process of implementing a new software system that will provide software solutions to ensure accurate financial processing.

View Audit 404506

Finding 1218258 (2024-006)

Material Weakness 2024

Housing Authority of the City of Columbia

SC

HUD Housing Programs Special Tests & Provisions

Finding 2024-006: No electronic income verification was done within the required time period for 1 of 40 participant selections. No abatement of housing assistance payments of failed unit inspections after 30 day maintenance windows was completed on 25 participant selections. a. Comments on the Find...

Finding 2024-006: No electronic income verification was done within the required time period for 1 of 40 participant selections. No abatement of housing assistance payments of failed unit inspections after 30 day maintenance windows was completed on 25 participant selections. a. Comments on the Finding We agree with finding 2024-006 b. Action(s) Taken or Planned on the Finding Annual training on program rules has been established for the Housing Choice Voucher Program, to ensure staff are aware of the proper implementation of the program rules. Additionally, a quality control protocol will be established that will require a review of at least 15% of all files. All failed inspection actions will be reviewed to ensure compliance with abatement protocols.

View Audit 404506

Finding 1218176 (2024-006)

Material Weakness 2024

Athens Metropolitan Housing Authority

OH

HUD Housing Programs

Finding Number: 2024-006 Planned Corrective Action: AMHA will require staff to follow all requirements set forth in 24 CFR 982 regarding income documentation such as obtaining third party verification and documenting the file as to why it was not available, related to annual income, assets, expenses...

Finding Number: 2024-006 Planned Corrective Action: AMHA will require staff to follow all requirements set forth in 24 CFR 982 regarding income documentation such as obtaining third party verification and documenting the file as to why it was not available, related to annual income, assets, expenses, etc. Staff will be instructed to double check calculations before inputting the information into the computer/50058 and to check to make sure calculations are accurate prior to adding the 50058 for submission. AMHA will continue to send staff to the appropriate training courses and AMHA has contracted with Nelrod for online training and will ensure this also includes EIV training courses. AMHA staff will conduct quality control on the files at random. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director

View Audit 404372

Finding 1218174 (2024-005)

Material Weakness 2024

Athens Metropolitan Housing Authority

OH

HUD Housing Programs

Finding Number: 2024-005 Planned Corrective Action: The Housing Authority has contracted with the Nelrod Company a national technical consulting firm specializing in Federal Assisted Housing Programs to perform our rent reasonableness determinations. Anticipated Completion Date: 6/11/2026 Responsibl...

Finding Number: 2024-005 Planned Corrective Action: The Housing Authority has contracted with the Nelrod Company a national technical consulting firm specializing in Federal Assisted Housing Programs to perform our rent reasonableness determinations. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director

View Audit 404372

Finding 1218172 (2024-004)

Material Weakness 2024

Athens Metropolitan Housing Authority

OH

HUD Housing Programs Subrecipient Monitoring § 200.328

Finding Number: 2024-004 Planned Corrective Action: The Housing Authority along with Leggins Casterline & Company LLC accounting will continue working to rectify the accounting issues resulting from the former Executive Director and have all submissions done in a timely manner. Anticipated Completio...

Finding Number: 2024-004 Planned Corrective Action: The Housing Authority along with Leggins Casterline & Company LLC accounting will continue working to rectify the accounting issues resulting from the former Executive Director and have all submissions done in a timely manner. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director

View Audit 404372

Finding 1218170 (2024-003)

Material Weakness 2024

Athens Metropolitan Housing Authority

OH

HUD Housing Programs Special Tests & Provisions

Finding Number: 2024-003 Planned Corrective Action: Housing Quality Standards are now done internally by the Executive Director and the authority has one dedicated staff member monitoring and they assure a re-inspection is automatically scheduled and notice sent to landlord and tenant. Anticipated C...

Finding Number: 2024-003 Planned Corrective Action: Housing Quality Standards are now done internally by the Executive Director and the authority has one dedicated staff member monitoring and they assure a re-inspection is automatically scheduled and notice sent to landlord and tenant. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director

View Audit 404372

Finding 1217228 (2024-005)

Material Weakness 2024

Family Promise of Hendricks County Inc.

IN

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs § 200.303

Management acknowledges the importance of maintaining appropriate segregation of duties and documented independent review for match calculations and supporting documentation. Corrective actions implemented include the development and implementation of written procedures for preparing, reviewing, and...

Management acknowledges the importance of maintaining appropriate segregation of duties and documented independent review for match calculations and supporting documentation. Corrective actions implemented include the development and implementation of written procedures for preparing, reviewing, and approving match calculations and supporting documentation as well as requiring independent review and documented approval of match calculations by a staff member not involved in the preparation.

View Audit 403362

Finding 1217227 (2024-004)

Material Weakness 2024

Family Promise of Hendricks County Inc.

IN

Subrecipient Monitoring Eligibility HUD Housing Programs § 200.303

Management acknowledges the need to ensure that required documentation is complete and retained in each tenant file, including executed leases, required forms, inspection documentation, and other required program documents. Corrective actions implemented include the creation and use of a standardize...

Management acknowledges the need to ensure that required documentation is complete and retained in each tenant file, including executed leases, required forms, inspection documentation, and other required program documents. Corrective actions implemented include the creation and use of a standardized eligibility determination checklist that requires documented supervisory sign-off in each tenant file to ensure all required documentation is complete prior to assistance approval. Staff have completed refresher training on timing requirements, documentation standards, and calculation procedures.

View Audit 403362

Corrective Action Plans

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