Corrective Action Plans

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2025-002 Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over compliance of federal awards John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsib...
2025-002 Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over compliance of federal awards John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2026.
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: We have implemented a training plan and discussed efficiencies by operations staff to improve accuracy and timeliness. This has been a priority since Januar...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: We have implemented a training plan and discussed efficiencies by operations staff to improve accuracy and timeliness. This has been a priority since January 2025. We will be transitioning to a new eligibility system starting October 2026 which should assist in improving the accuracy. Expected Completion Date: Ongoing Responding Official(s): Ginet Hayes, Benefit, Employment, and Support Services Division Supplemental Nutrition and Assistance Program Administrator
2025-006. Under-funded Account Balance - Section 8 Administrative Equity Net Deficit. Corrective action planned: To adjust as soon as possible and ensure it is not an issue in the future Contact person: Suzanne Smith, Interim Executive Director Anticipated completion date: 0-90 days, depending on th...
2025-006. Under-funded Account Balance - Section 8 Administrative Equity Net Deficit. Corrective action planned: To adjust as soon as possible and ensure it is not an issue in the future Contact person: Suzanne Smith, Interim Executive Director Anticipated completion date: 0-90 days, depending on the availability of Fee Accountant
2025-005. Interfund Receivable / Payable. Corrective action planned: To adjust as soon as possible and ensure it is not an issue in the future Contact person: Suzanne Smith, Interim Executive Director Anticipated completion date: 0-90 days, depending on the availability of Fee Accountant
2025-005. Interfund Receivable / Payable. Corrective action planned: To adjust as soon as possible and ensure it is not an issue in the future Contact person: Suzanne Smith, Interim Executive Director Anticipated completion date: 0-90 days, depending on the availability of Fee Accountant
COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024...
COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2025-006 Statement of Concurrence or Non concurrence: We concur with the findings. Corrective Action: For the delay in issuance of participant voucher we will issue a voucher for the participant as soon as the next voucher becomes available, in accordance with the program’s budget allocation. The participant has been assigned priority status and will be served immediately once funding permits. Checklists will be implemented and staff retraining will be performed to ensure all documents are included. Monthly monitoring schedules will be established by the compliance officer. Forms will be reviewed by the administrative assistant before submission. To strengthen internal controls, manuals will be updated and training will be provided. Staff will validate income and eligibility documentation prior to approval and mandatory training sessions will be conducted on a quarterly basis. Implementation Date: Fiscal Year 2025-2026. Responsible Person: Héctor L. Rosado Calderón Federal Program’s Director
Name of Contact Person: Tarsha Dudley, Executive Director. Corrective Action: Management will review the recertification process and plan to monitor recertifications. Proposed Completion Date: Immediately.
Name of Contact Person: Tarsha Dudley, Executive Director. Corrective Action: Management will review the recertification process and plan to monitor recertifications. Proposed Completion Date: Immediately.
2025-004 ALN 14.850 – Public Housing Operating Fund – Special Test – Depository Agreements The Executive Director agrees with the finding as listed in the Schedule of Findings and Questioned Costs and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khrist...
2025-004 ALN 14.850 – Public Housing Operating Fund – Special Test – Depository Agreements The Executive Director agrees with the finding as listed in the Schedule of Findings and Questioned Costs and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Executive Director Projected Completion Date: June 30, 2026
2025-002 ALN 14.850 – Public Housing Operating Fund – Allowable Costs – Bonus/Incentive Payments The Executive Director agrees with the finding as listed in the Schedule of Findings and Questioned Costs and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. ...
2025-002 ALN 14.850 – Public Housing Operating Fund – Allowable Costs – Bonus/Incentive Payments The Executive Director agrees with the finding as listed in the Schedule of Findings and Questioned Costs and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Executive Director Projected Completion Date: June 30, 2026
2025-001 ALN 14.850 – Public Housing Operating Fund – Eligibility The Executive Director agrees with the finding as listed in the Schedule of Findings and Questioned Costs and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Executive Dire...
2025-001 ALN 14.850 – Public Housing Operating Fund – Eligibility The Executive Director agrees with the finding as listed in the Schedule of Findings and Questioned Costs and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Executive Director Projected Completion Date: June 30, 2026
Finding Number: 2025-027 Planned Corrective Action: FDCF continues the phased approach of modernizing its eligibility (ACCESS) system. The modernization of the FLORIDA legacy eligibility system started development in State Fiscal Year 2025-2026 and includes the operational analysis of the state’s da...
Finding Number: 2025-027 Planned Corrective Action: FDCF continues the phased approach of modernizing its eligibility (ACCESS) system. The modernization of the FLORIDA legacy eligibility system started development in State Fiscal Year 2025-2026 and includes the operational analysis of the state’s data exchange processes. Anticipated Completion Date: June 30, 2027 Responsible Contact Person: Chris Presnell, Director of Data and Information Technology
Recommendation: The design of the current internal controls should be reviewed to ensure tenant files are complete and accurate. The information in the files should support the data used in preparing the Form 50059, and procedures for calculating income using HUD guidelines should be reviewed. The i...
Recommendation: The design of the current internal controls should be reviewed to ensure tenant files are complete and accurate. The information in the files should support the data used in preparing the Form 50059, and procedures for calculating income using HUD guidelines should be reviewed. The information in the files should also support that proper eligibility screening procedures have been completed, and updated lease agreements should be obtained for any tenant whose lease is not the correct model lease document. A corrected Form 50059 should be prepared to correct the tenant income discrepancy noted in the audit, and the required adjustment processed through the HUD voucher. In addition, management should review all files and report any additional discrepancies to HUD in a timely manner. Action Taken: Day Spring Baxter Avenue, Inc. will review all tenant files and report any discrepancies in calculated tenant rent and rental subsidy to HUD and make the necessary adjustments on the 50059 forms as soon as possible. Tenant files will be reviewed to ensure proper documentation is maintained and the proper model lease is being used.
2025-001 Eligibility – Tenant Files Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 – Housing Choice Vouchers 14.879 Mainstream Vouchers Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Statement of Condition: Out of a total tenant...
2025-001 Eligibility – Tenant Files Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 – Housing Choice Vouchers 14.879 Mainstream Vouchers Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Statement of Condition: Out of a total tenant population of approximately 2,025 tenants, a sample of 25 files was selected for testing. Exceptions were noted in 9 of the 25 files, categorized as follows: • 3 tenant file errors where the Authority did not generate the required EIV form. • 1 tenant file had the following errors: o The Authority did not generate the required EIV form. o The child support income was miscalculated and SNAP benefits were included in the income calculation. Correcting the income errors increased the HAP rent from $774 to $869. • 1 tenant file error where the child support income was miscalculated. Correcting the error would decrease the HAP rent from $1,500 to $1,476. • 1 tenant file error where the tenant’s income was miscalculated. Correcting the error would decrease HAP rent from $552 to $279. • 1 tenant file where the tenant’s income was miscalculated. Correcting the issue would increase the HAP rent from $501 to $517. • 1 tenant file error where medical expenses were erroneously reported on the HUD-50058 form. Correcting the error would decrease the HAP rent from $524 to $500. • 1 tenant file error where the utility allowance was miscalculated. Correcting this error would increase the HAP rent from $1,027 to $1,145. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing, secondary quality control review process for a sample of the entire tenant population to ensure proper compliance with eligibility requirements. Furthermore, management should provide ongoing staff training, conduct timely reviews of tenant files, and evaluate current staffing levels, skill sets and caseloads to ensure staff have the capacity to execute their duties accurately. Action Taken: The Authority concurs with this finding and has implemented a robust file review process, enhanced quality control procedures, and provided training on errors noted along with annual program training for all staff. The cited files were corrected.
Name of Contact Person: Amanda John, Executive Director. Corrective Action: We will implement proper internal control procedures for the Housing Choice Voucher program eligibility requirements. Proposed Completion Date: Immediately.
Name of Contact Person: Amanda John, Executive Director. Corrective Action: We will implement proper internal control procedures for the Housing Choice Voucher program eligibility requirements. Proposed Completion Date: Immediately.
Program: Housing Voucher Cluster Federal Financial Assistance Listing Number: 14.871 / 14.879 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: Multiple Compliance Requirements: Special Tests and Provisions – HQS Enforcement Type of Finding: Significant Deficiency...
Program: Housing Voucher Cluster Federal Financial Assistance Listing Number: 14.871 / 14.879 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: Multiple Compliance Requirements: Special Tests and Provisions – HQS Enforcement Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: The 2025 OMB Compliance Supplement requires that for dwellings under Housing Assistance Payment (HAP) contracts that fail a Housing Quality Standards (HQS) inspection, the County must enforce HQS requirements. Specifically, upon notification that a unit has failed HQS, the County must inspect the unit within 15 days to confirm the deficiency and notify the owner if the deficiency is confirmed. Once notified, the owner is required to make the necessary repairs within the prescribed time frame. If the owner does not correct the cited HQS deficiencies within the specified correction period, the County must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. Condition: For one sample selected for testing, the County did not timely enforce HQS requirements. Cause: The cause of the finding was an administrative oversight that resulted in delays in issuing the final inspection notice following a missed inspection appointment. The County’s existing procedures did not adequately ensure timely follow-up and escalation when an inspection resulted in a noshow. Effect: Because the required inspection and notification were not completed timely, the County did not fully comply with the HQS enforcement requirements. This delay increased the risk that housing assistance payments could continue for a unit that did not meet HUD’s minimum housing quality standards, potentially affecting program compliance and participant health and safety. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of sixty (60) out of a total population of 1,029 instances of failed HQS were selected. The condition noted above was identified during our procedures related to special tests and provisions – HQS enforcement. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its HQS enforcement procedures by implementing controls to ensure timely follow-up on failed inspections, including missed appointments. Such controls may include automated tracking of inspection deadlines, supervisory review of no-show appointments, and escalation procedures to ensure owners are notified within required time frames. Management Response and Corrective Action Plan: 1. Person Responsible: Linda Tarzjani, Leasing Manager 2. Corrective action plan: Concur. We will strengthen our HQS enforcement procedures by implementing controls to ensure timely follow-up on failed inspections, including missed appointments. In doing so we will consider automated tracking of inspection deadlines, supervisory review of noshow appointments, and escalation procedures to ensure owners are notified within required time frames. 3. Anticipated Implementation date: February 1, 2026
Finding: 2025-005 Name of Contact Person: Linda Higuet, Interim Finance Director Corrective Action: Management will make organizational changes as needed to ensure that each program is self-sustaining. Upper level management will obtain training for allowable costs/cost principles and activities all...
Finding: 2025-005 Name of Contact Person: Linda Higuet, Interim Finance Director Corrective Action: Management will make organizational changes as needed to ensure that each program is self-sustaining. Upper level management will obtain training for allowable costs/cost principles and activities allowed/unallowed under the Uniform Guidance and specific program regulations. Additionally, all upper level management will obtain training for financial and program specific reporting. Financial reports will be reviewed monthly by program directors, and program specific reporting will undergo monthly review by program directors. Proposed Completion Date: As soon as possible.
Finding: 2025-006 Name of Contact Person: Charshae Phillips, Section 8 Director Corrective Action: Document retention requirements will be re-emphasized to all staff, and all staff will attend training to ensure that all required documentation is obtained and maintained in accordance with program re...
Finding: 2025-006 Name of Contact Person: Charshae Phillips, Section 8 Director Corrective Action: Document retention requirements will be re-emphasized to all staff, and all staff will attend training to ensure that all required documentation is obtained and maintained in accordance with program regulations. Proposed Completion Date: As soon as possible.
OHA agrees with the finding. In October 2024, management implemented changes to the inspection scheduling process to ensure that no annual inspections are conducted on Thursdays preceding an alternating Friday off, as well as on working Fridays. The inspections referenced in the findings were conduc...
OHA agrees with the finding. In October 2024, management implemented changes to the inspection scheduling process to ensure that no annual inspections are conducted on Thursdays preceding an alternating Friday off, as well as on working Fridays. The inspections referenced in the findings were conducted by OHA’s independent inspector. The deficiencies occurred due to an oversight. Although the independent provided the inspection results (Pass/Fail) to the OHA inspector, the OHA inspector did not review the detailed failed items. Since the finding, management implemented a process requiring the OHA inspector to be on standby during our alternating Fridays off in the event that any 24-hour deficiencies are identified, allowing next-day re-inspection. The independent inspector is now required to inform the OHA inspector of any life-threatening deficiencies. Additionally, the independent inspectors’ schedule was adjusted around the same time, and inspections are now conducted on OHA’s working Fridays, which supports more effective and timely communication.
FINDING NUMBER 2025-001 Reporting views of responsible officials: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Auditors' summary of auditee's comments on t...
FINDING NUMBER 2025-001 Reporting views of responsible officials: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Auditors' summary of auditee's comments on the findings and recommendations: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Response indicator: Agree. Response: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Completion date: September 9, 2025
Student Support and Academic Enrichment – Assistance Listing No. 84.424 Recommendation: We recommend Boston Public Schools review and enhance internal controls and procedures to ensure that they retain copies of correspondence with private schools to ensure completeness and accuracy of the calculati...
Student Support and Academic Enrichment – Assistance Listing No. 84.424 Recommendation: We recommend Boston Public Schools review and enhance internal controls and procedures to ensure that they retain copies of correspondence with private schools to ensure completeness and accuracy of the calculation. Action taken in response to finding: In August 2025, Boston Public Schools developed and implemented a revised policy on equitable services that ensures that all communication is stored in a centralized folder for standard reviews. Name(s) of the contact person(s) responsible for corrective action: Marcela Mahecha, Director of Federal & State Grants, Programs, and Compliance Boston Public Schools Planned completion date for corrective action plan: August 31, 2025
English Language Acquisition State Grants – Assistance Listing No. 84.365 Recommendation: We recommend Boston Public Schools review and enhance internal controls and procedures to ensure that they retain copies of correspondence with private schools to ensure completeness and accuracy of the calcula...
English Language Acquisition State Grants – Assistance Listing No. 84.365 Recommendation: We recommend Boston Public Schools review and enhance internal controls and procedures to ensure that they retain copies of correspondence with private schools to ensure completeness and accuracy of the calculation. Action taken in response to finding: In August 2025, Boston Public Schools developed and implemented a revised policy on equitable services that ensures that all communication is stored in a centralized folder for standard reviews. Name(s) of the contact person(s) responsible for corrective action: Marcela Mahecha, Director of Federal & State Grants, Programs, and Compliance Boston Public Schools Planned completion date for corrective action plan: August 31, 2025
Housing Opportunities for Persons with Aids – Assistance Listing No. 14.241 Recommendation: We recommend the Mayor’s Office of Housing review and enhance internal controls and procedures to ensure that required inspections are performed timely. Action taken in response to finding: The Mayor’s Office...
Housing Opportunities for Persons with Aids – Assistance Listing No. 14.241 Recommendation: We recommend the Mayor’s Office of Housing review and enhance internal controls and procedures to ensure that required inspections are performed timely. Action taken in response to finding: The Mayor’s Office of Housing, as the HOPWA Grantee, identifies deficiencies in timely completions and documentations of HQS inspections performed by the project sponsor. The sponsor has now fully transitioned to using the Yardi system for property management activities, which will enhance inspection tracking and reporting, and has established monthly inspection monitoring reports to identify upcoming or past-due inspections. These corrective actions address the cause of missing yearly inspections and strengthen internal controls for ongoing compliance. The Mayor’s Office of Housing will ensure continued compliance through quarterly reviews of HQS inspection reports (submitted by the sponsor) and complete targeted file monitoring to verify timely completion and documentation, including any deficiency corrections. Name(s) of the contact person(s) responsible for corrective action: Kiarah Perdomenico, Housing Development Officer HOPWA program manager Planned completion date for corrective action plan: April 3, 2026
Finding 1201228 (2025-001)
Material Weakness 2025
FINDING NUMBER 2025-001 Reporting views of responsible officials: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Auditors' summary of auditee's comments on t...
FINDING NUMBER 2025-001 Reporting views of responsible officials: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Auditors' summary of auditee's comments on the findings and recommendations: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Response indicator: Agree. Response: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Completion date: September 9, 2025
Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Housing Assistance Payments Recommendation: We recommend the Authority strengthen its controls to ensure proper documentation is maintained and that HAP contracts, payment standards, and HAP amounts are accurately applied and re...
Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Housing Assistance Payments Recommendation: We recommend the Authority strengthen its controls to ensure proper documentation is maintained and that HAP contracts, payment standards, and HAP amounts are accurately applied and reviewed for compliance by its Agents. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Virginia Housing is evaluating enhancements to its quality control framework. This evaluation includes reviewing best practices from peer agencies with strong compliance outcomes and consistent audit performance. Many of these agencies utilize more structured oversight models that provide independent file review functions while maintaining coordination with program operations. Virginia Housing is currently assessing options that may include: - Expanding centralized quality control review functions - Increasing file sampling and review throughout the year - Implementing additional HAP calculation validation steps - Enhancing payment standard cross-check procedures Implementation details will be finalized following this evaluation process and may include structural adjustments, enhanced tools, or expanded oversight protocols. Name of the contact person responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: December 31, 2026
Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Waiting List Recommendation: We recommend the Authority review its Agent’s internal controls over the waiting list process to ensure all documentation is maintained at the time each applicant is selected from the waiting list an...
Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Waiting List Recommendation: We recommend the Authority review its Agent’s internal controls over the waiting list process to ensure all documentation is maintained at the time each applicant is selected from the waiting list and that applicants are added to the waitlist accurately. We recommend the Authority implements uniform documentation standards and requirements across all local housing agencies (LHAs) and agents of the Authority. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority recognizes the need to strengthen documentation controls at the point of applicant selection. As part of its broader compliance review, the Authority is evaluating improvements to waiting list procedures. This includes reviewing documentation requirements, selection verification protocols, and file completeness standards. Enhancements under consideration include: - Providing training to LHAs on waiting list management, referral processes, extension documentation, and documentation retention requirements - Incorporating a quality control (QC) review of referrals to special purpose voucher programs to ensure documentation, eligibility verification, and notification records are consistently maintained - Strengthening monitoring procedures to validate that required documentation is retained at the time of selection Name of the contact person responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: December 31, 2026
Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – HQS Annual and Failed Inspections Recommendation: We recommend that the Authority reviews its Agent’s processes related to annual and failed HQS inspections to ensure that inspections are completed in a timely manner and in comp...
Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – HQS Annual and Failed Inspections Recommendation: We recommend that the Authority reviews its Agent’s processes related to annual and failed HQS inspections to ensure that inspections are completed in a timely manner and in compliance with HUD and the Authority’s requirements. We further recommend that the Authority review its Agent’s procedures to ensure appropriate follow up is performed to confirm that tenants or landlords make required corrections timely, or that housing assistance payments (HAP) are properly abated for the unit until such corrections are made. We recommend the Authority work with its Agent’s to alleviate any inspector shortage. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has taken proactive steps to enhance its inspection process to ensure compliance with HUD requirements. As part of these efforts, the Authority has contracted with a third-party vendor to manage all inspection activities statewide. This partnership is designed to improve the efficiency, consistency, and timeliness of inspections, strengthen follow-up procedures for failed inspections, and support more uniform enforcement of abatement requirements when necessary. Full implementation of the third-party inspection services occurred on April 1, 2025, approximately two months prior to the end of the audit reporting period. While the timing limited the impact reflected in this audit cycle, the Authority believes this represents an effective control enhancement. Virginia Housing will continue to monitor inspection timeliness, reinspection compliance, and abatement processing trends to evaluate performance and confirm that this action results in measurable improvement in future audit outcomes. Virginia Housing is evaluating the possibility of implementing a tracking dashboard for inspection timelines and abatement periods and will continue to meet with the third-party vendor bi-weekly to ensure progress is made. Name of the contact person responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives
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