Corrective Action Plans

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Management will obtain retroactive approval for the unauthorized withdrawals of $30,453 or redeposit these funds into the replacement reserve account.
Management will obtain retroactive approval for the unauthorized withdrawals of $30,453 or redeposit these funds into the replacement reserve account.
The required residual receipts deposit will be deposited to the residual receipts account. New management has taken over and will ensure any required deposits are made on time.
The required residual receipts deposit will be deposited to the residual receipts account. New management has taken over and will ensure any required deposits are made on time.
Management will ensure the financial statements are submitted to REAC within 90 days of year-end.
Management will ensure the financial statements are submitted to REAC within 90 days of year-end.
Finding 2025-003: The Corporation did not file its required 2024 and 2025 audit reporting packages by the required due dates. Name of Contact Person: Judith Lima, Chief Financial Officer Corrective Actions Plan: Management agrees with the finding. As stated, the transition to a new audit firm and th...
Finding 2025-003: The Corporation did not file its required 2024 and 2025 audit reporting packages by the required due dates. Name of Contact Person: Judith Lima, Chief Financial Officer Corrective Actions Plan: Management agrees with the finding. As stated, the transition to a new audit firm and the sale of the Corporation impacted management’s ability to file its 2025 financial statements timely. Management evaluated the circumstances noted above and plans to have the 2026 books and records closed and ready for the audit firm to complete the 2026 by the HUD due date.
Authority's Response and Planned Corrective Action Plan: 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 are being followed on a timely basis. Kinteh Darboe, Chief of Fi...
Authority's Response and Planned Corrective Action Plan: 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 are being followed on a timely basis. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.
Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe,...
Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.
Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe,...
Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.
We have instructed Hawaii Affordable Properties to withdraw $300,000 from the replacement reserve account and purchase two $150,000 6 month certificate of deposits, which are to be rolled over every six months until the funds are needed.
We have instructed Hawaii Affordable Properties to withdraw $300,000 from the replacement reserve account and purchase two $150,000 6 month certificate of deposits, which are to be rolled over every six months until the funds are needed.
This issue occurred during Bob Tanaka, lnc.’s period of managing the project. Bob Tanaka, Inc. was replaced by Hawaii Affordable Properties, Inc. on January 1, 2025, and instructions have been given to the new property management company to maintain the tenant waiting list in accordance with 24 CFR ...
This issue occurred during Bob Tanaka, lnc.’s period of managing the project. Bob Tanaka, Inc. was replaced by Hawaii Affordable Properties, Inc. on January 1, 2025, and instructions have been given to the new property management company to maintain the tenant waiting list in accordance with 24 CFR Section 891.410(a). The wait list will be reviewed at quarterly site inspections.
The noncompleted replacement reserve contributions were due to the Project not receiving PRAC subsidies during 2025. This left the Project with not enough revenue to fund normal operations, and a replacement reserve withdraw was allowed by HUD to cover operating cash shortfalls. The issue with recei...
The noncompleted replacement reserve contributions were due to the Project not receiving PRAC subsidies during 2025. This left the Project with not enough revenue to fund normal operations, and a replacement reserve withdraw was allowed by HUD to cover operating cash shortfalls. The issue with receiving the PRAC subsidies was resolved by the property managers in April 2026 and the Project is now paying back the replacement reserve withdraw for the shortfall and catch up with replacement reserve contributions. Continuing monitoring of the Project’s financial statements and replacement reserve contributions will be performed on a monthly basis.
The Agency is working with a CPA to catch up on missed filings, and has noted future deadlines for going forward.
The Agency is working with a CPA to catch up on missed filings, and has noted future deadlines for going forward.
Finding 2025-002: 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 ...
Finding 2025-002: 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 $5,400, $4,200, and $3,000, all respectively, to be returned to the Corporation during the years ended December 31, 2025, 2024 and 2023. The Board of Directors returned $0, $1,400, and $250, all respectively, during the years ended December 31, 2025, 2024, and 2023. At December 31, 2025, 2024, and 2023, the Board of Directors owes $53,350, $53,350, and $54,750, all respectively, to the Corporation. 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. Action(s) taken or planned on the finding 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, 2024, 2025, and all future deposits as required in the repayment agreement entered into with HUD on June 10, 2022.
Finding 2025-001: Comments on the Finding and Each Recommendation The Corporation has not filed the 2017, 2018, 2019, 2020, 2021, 2022, 2023, or 2024 federal income tax returns. Tax returns should be filed on a timely basis and all delinquent tax returns should be filed as soon as possible. Action(s...
Finding 2025-001: Comments on the Finding and Each Recommendation The Corporation has not filed the 2017, 2018, 2019, 2020, 2021, 2022, 2023, or 2024 federal income tax returns. Tax returns should be filed on a timely basis and all delinquent tax returns should be filed as soon as possible. Action(s) taken or planned on the finding 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.
Special Test & Provisions – Contract Rent Adjustment Name of Contact Person: Mona Barnes, President Corrective Action: Management is working on compiling the documentation needed to submit the request for renewal of the PRAC and rent adjustment. Proposed Completion Date: July 31, 2026
Special Test & Provisions – Contract Rent Adjustment Name of Contact Person: Mona Barnes, President Corrective Action: Management is working on compiling the documentation needed to submit the request for renewal of the PRAC and rent adjustment. Proposed Completion Date: July 31, 2026
Finding 1240166 (2025-002)
Material Weakness 2025
The County Commissioners and Auditor will monitor this internally.
The County Commissioners and Auditor will monitor this internally.
Finding 1240165 (2025-001)
Material Weakness 2025
The County Commissioners and Auditor will monitor this internally.
The County Commissioners and Auditor will monitor this internally.
CORRECTIVE ACTION PLAN September 24, 2026 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bonadio & Co., LLP 171...
CORRECTIVE ACTION PLAN September 24, 2026 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully’s Trail Pittsford, NY 14534 Audit Period: January 1, 2025 - December 31, 2025 The findings from the December 31, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARD PROGRAMS AUDIT FINDING 2025-001: Section 232, CFDA 14.129 Recommendation: Adhere to the HUD regulatory agreement in relation to obtaining prior written approval from HUD before encumbering the Project. Action Taken: The Home executed these transactions as a prudent business decision to meet operating expenses and improve the facility to promote enhanced revenue generation. The Home has implemented procedures to ensure that prior written approval is obtained from HUD before encumbering the Project in the future. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Sabrina McLeod at (585)-760-1401. Sincerely yours, _______________________________ Sabrina McLeod Chief Financial Officer
UNAUTHORIZED CHANGE IN REQUIRED MONTHLY DEPOSIT IN REPLACEMENT RESERVE Supportive Housing for the Elderly – Assistance Listing Number 14.155 Recommendation: CLA recommends that processes and procedures be evaluated to strengthen internal control over compliance relating to HUD-restricted accounts. E...
UNAUTHORIZED CHANGE IN REQUIRED MONTHLY DEPOSIT IN REPLACEMENT RESERVE Supportive Housing for the Elderly – Assistance Listing Number 14.155 Recommendation: CLA recommends that processes and procedures be evaluated to strengthen internal control over compliance relating to HUD-restricted accounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions Taken: Management will review compliance requirements for HUD programs related to replacement reserve withdrawals to ensure they are followed in the future. Name of the contact person(s) responsible for corrective action: Lindsey Beyer, Administrator Planned completion date for corrective action plan: September 2026
2025-002 UNAUTHORIZED WITHDRAWAL FROM REPLACEMENT RESERVE Supportive Housing for the Elderly – Assistance Listing Number 14.155 Recommendation: CLA recommends that processes and procedures be evaluated to strengthen internal control over compliance relating to HUD-restricted accounts. Explanation of...
2025-002 UNAUTHORIZED WITHDRAWAL FROM REPLACEMENT RESERVE Supportive Housing for the Elderly – Assistance Listing Number 14.155 Recommendation: CLA recommends that processes and procedures be evaluated to strengthen internal control over compliance relating to HUD-restricted accounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions Taken: Management will review compliance requirements for HUD programs related to replacement reserve withdrawals to ensure they are followed in the future. Name of the contact person(s) responsible for corrective action: Lindsey Beyer, Administrator Planned completion date for corrective action plan: September 2026
Evaluate the outstanding checks and deposits and close them out.
Evaluate the outstanding checks and deposits and close them out.
Corrective Action Plan – Finding 2025-001 Program: Supportive Housing for Persons with Disabilities Section 811 Assistance Listing: 14.181 Federal Agency: U.S. Department of Housing and Urban Development (HUD) Finding Reference: 2025-001 – Activities Allowed or Unallowed (Significant Deficiency) Man...
Corrective Action Plan – Finding 2025-001 Program: Supportive Housing for Persons with Disabilities Section 811 Assistance Listing: 14.181 Federal Agency: U.S. Department of Housing and Urban Development (HUD) Finding Reference: 2025-001 – Activities Allowed or Unallowed (Significant Deficiency) Management’s Planned Corrective Action: Management will discontinue the use of the Regular Operating account for payments on residual receipt notes and instead will use the Capitalized MHP Debt Service Reserve to fund annual interest payments, consistent with applicable regulatory requirements. Additionally, management will: - Implement procedures to ensure all disbursements are reviewed for allowability prior to payment - Require documented verification of the required agency approval, when applicable, before payments are made from restricted accounts. Anticipated Completion Date: 7/31/2026 Questioned Costs Resolution: Management will evaluate the $13,442 in questioned costs and pursue reimbursement of HUD funds, as required.
Corrective Action Plan – Finding 2025-001 Program: Section 202 (Supportive Housing for the Elderly) Assistance Listing: 14.157 Federal award Identification number:121-EE151-NP-WAH Federal Agency: U.S. Department of Housing and Urban Development (HUD) Federal Award Year: 2025 Finding Reference: 2025-...
Corrective Action Plan – Finding 2025-001 Program: Section 202 (Supportive Housing for the Elderly) Assistance Listing: 14.157 Federal award Identification number:121-EE151-NP-WAH Federal Agency: U.S. Department of Housing and Urban Development (HUD) Federal Award Year: 2025 Finding Reference: 2025-001 – Reportable Finding Considered a Significant Deficiency - Special Tests and Provisions: Reserve for Replacement is underfunded by $43,149 Management’s Planned Corrective Action: Management will work with new Property Management personnel and HUD account executive to improve cash flow at the project and submit required deposits to reserve accounts. Anticipated Completion Date: 12/31/2026
During the year ended December 31, 2025, Cohn Rezneck noted 10 instances of noncompliance during audit procedures applied to a sample of 40 tenant lease files with HUD regulations regarding dissemination of Electronic Income Verification (EIV) information and regarding maintenance of tenant lease fi...
During the year ended December 31, 2025, Cohn Rezneck noted 10 instances of noncompliance during audit procedures applied to a sample of 40 tenant lease files with HUD regulations regarding dissemination of Electronic Income Verification (EIV) information and regarding maintenance of tenant lease files. EIV information was provided in electronic format to the independent public accountant. Planned Corrective Action: Decatur Housing has established additional procedures and monitoring of compliance with those procedures in accordance with guidelines specified by HUD to include: • A standardized HCV EIV Review and Documentation Form; • A step-by-step EIV review and documentation guide for staff; • A separate, access-restricted electronic EIV folder for each family; • A requirement that the EIV report and completed review form be stored together in the family’s secure EIV folder rather than the main Annual or Interim Reexamination folder; • A consistent file-naming and document cross-reference process; • Staff certification and supervisory quality-control requirements; • Procedures for documenting and resolving discrepancies and open items; • Refresher training and ongoing monitoring to confirm continued compliance; and • Corrective procedures for any future documentation or filing errors. These measures are intended to establish a clear audit trail, protect EIV information, strengthen supervisory oversight, and prevent recurrence of the deficiencies. Name of Contact Person: Larry H. Padilla, CEO Anticipated completion date: August 28, 2026
In connection with the procedures applied to a sample of two tenants that moved in and out of the Project during the year, we noted one instance where the tenant's security deposit amount listed in the lease and collected was not deposited in a timely manner and thus the amount per the lease did not...
In connection with the procedures applied to a sample of two tenants that moved in and out of the Project during the year, we noted one instance where the tenant's security deposit amount listed in the lease and collected was not deposited in a timely manner and thus the amount per the lease did not agree to the amount recorded in the accounting records. a. Comments on the Finding and Each Recommendation Management agrees with the finding and recommendation. As part of the transition from TD Bank to IDB Bank, there was a delay in establishing the new security deposit accounts. Once the accounts were finalized, the funds were transferred to the IDB security deposit accounts in December 2025. c. Action(s) Taken or Planned on the Finding Security deposit accounts were established and funded in December 2025. The Project closed its TD Bank accounts and opened new accounts with IDB Bank. Due to delays in establishing the new security deposit accounts at IDB, the funds remained at TD Bank until the accounts were finalized and were subsequently transferred to the IDB security deposit accounts in December 2025.
During the period ended December 31, 2025, the Company distributed $20,931 in excess of surplus cash available for distribution. a. Comments on the Finding and Each Recommendation Management agrees with the finding and recommendation. Adequate procedures were not in place to ensure distributions wer...
During the period ended December 31, 2025, the Company distributed $20,931 in excess of surplus cash available for distribution. a. Comments on the Finding and Each Recommendation Management agrees with the finding and recommendation. Adequate procedures were not in place to ensure distributions were reviewed and limited to available surplus cash in accordance with HUD requirements. b. Action(s) Taken or Planned on the Finding The project's management agrees with the auditor’s finding. As of December 31, 2025, there is $51,268 of available surplus cash. Had the questioned costs of $20,931 not been paid, then surplus cash would have been $72,199. Therefore, since current year surplus cash has been reduced, the questioned costs are deemed to be repaid.
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