Corrective Action Plans

To address the noted deficiencies in tenant file documentation, staff and supervisors will continue to follow established processes. Supervisors continue to track and monitor productivity and progress. The current supervisor has implemented clear and concise instructions and rules for completing and managing files. All forms are now saved in tenant files, and not on individual laptops as they were in the past. The supervisor has also implemented schedules and tracking systems for monthly voucher submissions, annual recertifications, quarterly income checks and other processes in the occupancy workflow. In addition, the supervisor and the lead staff for housing compliance perform regular checks on tenant application paperwork and random checks on tenant files to ensure accuracy and completeness and correct any mistakes. Ongoing staff training, support and mentoring continues.

In response to the finding regarding low occupancy rate, management contends that the Project is doing all that is within its control to get the vacant units rented.

Views of responsible officials and planned corrective action: 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. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2026.

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers Program and will implement internal control procedures related to reasonable rent that will ensure compliance with federal regulations. Starting in August 2025, the Authority hired a third party vendor to complete rent reasonableness determinations for all Housing Choice Voucher units. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2026.

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor and will ensure all necessary DOTs are recorded. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2026.

Reference Number: 2025-002 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: 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 substantial progress in resolving the backlog of Housing Quality Standards (HQS) inspections that originated during the COVID-19 period, when HUD waivers and restricted unit access limited the ability to conduct timely inspections. Since that time, the Authority has reestablished normal inspection operations and significantly improved inspection volume and completion rates. All inspections noted in the audit were completed shortly after the required timeframes, and each unit ultimately passed HQS inspection and met HUD’s requirements for safe, decent, and sanitary housing. These results reflect that there was no impact to housing quality or participant eligibility, but rather timing-related delays within an actively managed inspection pipeline. The instances identified in the audit are largely attributable to timing of the audit sample selection, during which certain inspections were in process and scheduled but had not yet been completed. This does not fully reflect the Authority’s current operational performance or the progress achieved in reducing the inspection backlog. The Authority has established ongoing procedures to prioritize and monitor inspection timeliness, including use of the Emphasys Elite system in coordination with HUD’s PIC system to identify and track units approaching or exceeding inspection deadlines. Units identified as nearing noncompliance are actively scheduled and completed, and the Authority continues to work closely with its third-party HCV contractors to maintain consistent inspection coverage. The Authority continues to enhance oversight, tracking, and contractor accountability to ensure sustained compliance with HUD standards. The enhanced oversight and monitoring resulted in SEMAP fiscal year end 9/30/2025 with High Performer status, and current performance trends show the Authority is well positioned to maintain SEMAP High Performer status for the current fiscal year. Specifically for SEMAP Indicator 12 for Annual HQS Inspections, the Authority achieved 10 out of 10 points for fiscal year end 9/30/2025, which was an improvement from the prior fiscal year of 0 out of 10 points, and currently projected to maintain full points for this indicator with 97% timely annual HQS inspections completed. The key strategies and controls in place are as follows: 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. Anticipated Implementation Date September 30, 2026 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

Reference Number: 2025-001 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: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance Authority’s Response & Actions Taken The Authority has taken substantial and measurable steps to address the prior backlog of annual reexaminations, including stabilizing third-party administration and implementing earlier and more structured reexamination processes. As a result of these efforts, all reexaminations identified during the audit period were ultimately completed, and all households were confirmed eligible with accurate housing assistance payments prior to the end of FY2025. The Authority’s current procedures—such as initiating reexaminations 150 days in advance, conducting weekly monitoring, and coordinating closely with property management and service providers—have significantly improved overall performance and strengthened operational consistency. The remaining instances of untimely reexaminations reflected in the audit are largely attributable to tenant non-responsiveness and timing factors associated with the audit sample period, during which a portion of cases were still in process despite being actively worked on and subsequently completed. These results do not fully reflect the progress achieved or the Authority’s current operational status. The Authority maintains a tenant-centered approach to program administration, ensuring that eligible households are not unnecessarily terminated due to documentation delays (this is especially important with the Authority being in shortfall which does not allow for voucher reinstatements). This approach is supported by structured outreach, enforcement protocols, and documented follow-up actions. The Authority continues to work diligently with its third-party HCV contractors, city department partners, onsite service providers and property management companies to ensure timely recertification of all assisted households. At the same time, the Authority has strengthened internal controls to better align tenant flexibility with HUD timeliness requirements. The Authority continues to enhance oversight, tracking, and contractor accountability to ensure sustained compliance with HUD standards. The enhanced oversight and monitoring resulted in SEMAP fiscal year end 9/30/2025 with High Performer status, and current performance trends show the Authority is well positioned to maintain SEMAP High Performer status for the current fiscal year. Specifically for SEMAP Indicator 9 for Annual Reexamination, the Authority achieved 5 out of 10 points for fiscal year end 9/30/2025, which was an improvement from the prior fiscal year of 0 out of 10 points, and currently trending in a positive direction to achieve 10 out of 10 points for FY2026. 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: For the Project-Based program: Two project-based households were cited for late re-exams in relation to finding 2025-001. Prior to this year’s audit, those households were identified and brought into compliance prior to the end of FY2025. In addition to the actions taken in last year’s corrective action plan for finding 2024-002, the Project-Based Voucher Program has begun: 􀁸 Scheduling second notice in-person appointments for households who do not return the Annual Re-examination package in the required timeframe from the first mailing. 􀁸 Maintaining a live shared log of delinquent Annual Re-examinations which the property managers have access to. 􀁸 Including resident services and property management in the intent to terminate process to emphasize the importance of compliance and provide direct support to the resident. 􀁸 Streamlining Annual Re-examinations for senior and/or disabled households with fixed incomes through the triennial process. 􀁸 Scheduling and completing on-site visits for senior-disabled sites and non-restricted sites with large numbers of families out of compliance. 􀁸 Continuing to review discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. For the Tenant-Based Program: Two tenant-based households were cited for late re-exams in relation to finding 2025-001. Prior to the end of FY2025, each household was brought into compliance and had their annual reexaminations completed. In addition to the actions taken in last year’s corrective actions plan for finding 2024-002, the Tenant-Based Program has begun: 􀁸 Updating the administrative plan to allow for verification of documents to be dated with 120- days of submittal instead of 60-days which allows more flexibility and less likelihood of needing additional items from the client. 􀁸 Tracking annual reexaminations for each assigning housing specialist the moment packets are mailed and throughout the process, both through individual tracking sheets and the Authority's Customer Relations Management system. Housing Authority 2025 Corrective Action Plan Page 4 of 6 􀁸 Tracking late re-exams on the management level on a monthly basis and following up with the individual housing specialists. 􀁸 Utilizing case managers for special programs to assist with outreach and completion of the paperwork. 􀁸 Reviewing previous annual reexamination and HUD’s supplemental 92006 form to determine if the household has identified an individual to contact for assistance with the annual reexam and contacting them. 􀁸 Continuing to review discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. Anticipated Implementation Date September 30, 2026 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

2025-001 U.S. Department of Housing and Urban Development Housing Voucher Cluster - 14.871 Section 8 Housing Choice Vouchers and 14.879 Mainstream Vouchers Condition and Criteria: The Agency must inspect the unit leased to a family initially and at least biennially to determine if the unit meets Housing Quality Standards (HQS). The Agency did not perform an initial inspection for one unit in our sample. Cause: Procedures are in place for performing inspections, but this year the client converted some units at this location to project-based housing. It was assumed all the units were inspected at once in 2024 before the client began switching them over. Due to human error, the inspection was not performed during the fiscal year. Effect: There is a possibility that sanctions could be imposed if they do not perform inspections as required by the program. Context: The Agency is aware of the requirement and has a supervisory position to oversee the inspectors and their processes and ensure the Agency is complying with the requirements. CORRECTIVE ACTION PLAN RESPONSE: This complex, along with many others on our program, are now scheduled on one day, to prevent the inspectors from having to make multiple trips to each complex every month. This complex is inspected every May and if ever someone asks for a special inspection. Anticipated completion date: 9/30/26 Responsible party: Michelle Worthington, Section 8 Housing Director Please contact Vicky Pritchett, Finance Director at 573-213-4811 extension #10102 with questions regarding this plan.

We have implemented a plan for proper training to make sure everyone is aware of HUD rules regarding family eligibility. We will complete a quarterly audit of randomly selected files to ensure we are adhering to HUD rules. We will ensure staff monitors eligibility for each resident within the required time frame.

In order to keep cash as accurate as possible, we will work to clear interfund as often as possible. With upcoming development revenue that we will see come in over the next 1-2 years on the non profit side, we will work to prioritize returning funds to the Public Housing Operating Funds. To prevent co-mingling of cash, we will begin a plan to break apart the funds for each program - Spencer, COCC, 3rd and 11th. Each quarter, we access payroll allocations to better reflect employees’ use of time and actual costs incurred by program and by LITC property. Public Housing and COCC training is planned that all finance staff will attend to make sure proper HUD procedures, rules, and guidelines are followed. The plan is to reduce the receivable down to $-0- as soon as possible and within 5 years.

Corrective Action Plan – Single Audit Finding Entity Name: Brocton Housing Development Company, Inc. Audit Period: For the year Ended September 30, 2025 Finding Reference Number: 14.157 Federal Program: Supportive Housing for the Elderly (Section 202) 1. Audit Finding Summary Describe the audit finding and the specific noncompliance identified by the auditor. In accordance with 24 CFR 891.400(e), a separate interest-bearing project fund account shall be maintained in a depository or depositories which are members of the Federal Deposit Insurance Corporation or National Credit Union Share Insurance Fund and all tenant payments, charges, income and revenues arising from project operation or ownership shall be deposited to this account. 2. Root Cause Explain the underlying reasons for the finding, such as process gaps, training issues, or lack of controls. Subsequent to the initial rental assistance contract, changes to HUD regulations resulted in the requirement that the project fund account be an interest-bearing account. This change was an oversight by the Company's management. 3. Corrective Actions Action Item: Use an interest-bearing account for project funds Responsible Person: Chief Financial Officer Completion Date: TBD Status: In process 4. Monitoring Plan Describe how the implementation of corrective actions will be monitored and evaluated. Management inquired with the bank and deemed the cost outweighs the benefit due to the fees charged for an interest bearing account exceeding the interest that would be earned. 5. Contact Information Name: Aaron Hejmowski Title: Chief Financial Officer Phone: 716-884-7791 Email: ahejmowski@belmonthousingwny.org

The Authority will submit its SEMAP certification to HUD within sixty days of its fiscal year-end. Ms. LaTonya Coley-McKenley, Executive Director, has assumed the responsibility of executing this corrective action by November 29, 2026.

The Authority will catalog and maintain all required tenant file documents in accordance with federal requirements and the Authority’s internal policies. Ms. LaTonya Coley-McKenley, Executive Director, has assumed the responsibility of executing this corrective action by August 1, 2026.

Due to inadequate monitoring of grant deadlines and project implementation timelines, the Organization did not obligate certain federal funds before the expiration of the award period. As a result, a portion of the awarded funds remained unused and was no longer available for program activities. The Organization will implement enhanced grant management procedures to ensure that federal funds are obligated and utilized within the approved period of availability. Corrective actions include: 1. Maintaining a centralized grant tracking system that identifies award periods, obligation deadlines, expenditure deadlines, and closeout requirements. 2. Requiring quarterly reviews of grant balances and project progress by program and finance personnel. 3. Establishing written procedures for monitoring unobligated balances and addressing delays in project implementation. Providing training to program managers and fiscal staff regarding federal grant requirements, including obligation and period-of-performance requirements. Requiring management review of all federal awards at least 90 days prior to expiration to identify and address any risk of unexpended or unobligated funds. Anticipated Completion Date: Immediately

Due to inadequate monitoring of grant deadlines and project implementation timelines, the Organization did not obligate certain federal funds before the expiration of the award period. As a result, a portion of the awarded funds remained unused and was no longer available for program activities. The Organization will implement enhanced grant management procedures to ensure that federal funds are obligated and utilized within the approved period of availability. Corrective actions include: 1. Maintaining a centralized grant tracking system that identifies award periods, obligation deadlines, expenditure deadlines, and closeout requirements. 2. Requiring quarterly reviews of grant balances and project progress by program and finance personnel. 3. Establishing written procedures for monitoring unobligated balances and addressing delays in project implementation. Providing training to program managers and fiscal staff regarding federal grant requirements, including obligation and period-of-performance requirements. Requiring management review of all federal awards at least 90 days prior to expiration to identify and address any risk of unexpended or unobligated funds. Anticipated Completion Date: Immediately

Finding Number: 2025-001 Planned Corrective Action: We concur with the finding. We will be meeting with the auditors and the Financial Eligibility staff to monitor the calculation of patient sliding scale levels and put in place additional monitoring checks to ensure correct application of discount to patients. The Finance Administrator will continue to monitor whether the monitoring policies are being followed. Anticipated Completion Date: On-going Responsible Contact Person: Cynthia Diaz, Finance Administrator

The Health System will take the following actions to resolve the noted conditions: 1. To address the noted conditions for user access reviews the Health System will update SOPs and documentation in two separate areas: a. Vendors/Consultants that do work for the Health System will be instructed to only move changes to production with explicit written approval from the business leader of the Human Resources (HR) function or Human Resources Information Systems (HRIS) leadership. Verbal approval in meetings will be insufficient. The updated requirement will be communicated to all business leads in HR. b. Workday Releases are currently reviewed and tested by HRIS prior to implementation. During testing, the auditors noted two releases that did not have documentation of testing. The two releases relate to modules or functionality not used by the Health System. HRIS will update its practice of reviewing Workday releases to include documentation on release items that do not apply to the Health System and, therefore, do not require testing. This change will be incorporated in HRIS’s SOP and communicated to the team conducting the Workday release reviews. 2. HRIS leadership will update its SOP for UAR to require screenshot of the system generated report used for the UAR and require an HR VP to review the Sr. Manager’s (primary individual doing review) access. The HRIS team will be trained on the updates to the new SOP. 3. We have done a comprehensive review of our implementers/vendors and began disabling them from our systems when they no longer require access to our systems upon completion of services. HR business leads will be required to request implementor/vendor access disablement on the completion of their work. The HR business leads will be trained on this process. As a new additional control, implementers/vendors will be reviewed by HRIS on an annual basis mirroring the current security review process for other users. Person Responsible: Karen Alvarado – Senior Manager HRIS E-mail address: Karen.Alvarado@bmc.org

Finding Reference: 2025-001 Program Name: Housing Voucher Cluster (14.871-CL) Description of Finding: HUD regulations require the Agency to inspect the unit leased to a family at least biennially to determine if the unit meets Housing Qualify Standards and must conduct quality control reinspections. Of the 40 files tested, 5 files did not contain documentation that the biennial inspection was performed. Statement of Concurrence or Nonconcurrence: Metropolitan Development and Housing Agency agrees with Cherry Bekaert in reference to audit finding 2025-001. Corrective Action: Management acknowledges the finding and notes that the error was caused by a software issue that has since been corrected. Upon discovery, the agency immediately remedied the issue with all impacted households and conducted a comprehensive review to determine the scope of the issue. The review identified 68 impacted households out of 6,440 total Housing Choice Voucher program households, representing less than 1% of the total program population.

Finding Reference Number: SA2025-001 Late Submission of FDS (Significant Deficiency) Contact Person: Raul Marquez, Accounting Supervisor Corrective Action Plan: Management will establish timelines and interim milestones for completion of the City’s Annual Comprehensive Financial Report (ACFR) that support timely completion and submission of the City’s audited FDS by the 3/31 deadline. Anticipated Completion Date: June 30, 2026

Name of Auditee: Central Falls Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: September 30, 2025 CAP Prepared by: Bridgett Duquette, Executive Director Phone: (401) 727-9090 (A) Current Finding on the Schedule of Findings and Questioned Costs (1) Finding 2025-001 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will submit all required documentation to HUD. (c) Planned implementation date of corrective action - Completed by September 30, 2026.

Finding No. 2025-001: Missing Deadlines for Recertifications and Inspections (Significant Deficiency) Corrective Action Plan: Our goal is to address the underlying cause of the delayed recertifications and inspections identified in Finding 2025-001. Regarding the recertifications, my analysis of the delays indicates that our Housing Voucher team remains understaffed. We have a five-person Housing Voucher Team with well over 900 vouchers to administer across a variety of different programs, including HCV, PBV, Mainstream, VASH, Foster Youth, Port-In1, etc. Additionally, we have 80 public housing units and are administering an additional 80 project-based tenant-protection vouchers in partnership with Montgomery Housing Partnership (MHP) for a senior-housing rehab project (Bethany House) begun this year (2026). In short, we need to expand our housing voucher team, especially since only one member of the team, Eve Garcia Jiminez, specializes in port-ins. Additionally, while Ms. Garcia Jiminez and Ms. Rebecca Niaba, the Housing-Voucher Team Manager, both have considerable experience with HUD programs, the remaining three team members – who handle resident casework, recertifications, waitlist management, inspections, etc. – are relatively junior, all with less than five years of experience. Since RHE’s leadership turnover in late August 2025, we have attempted to supplement the Housing Voucher Team with interns from our YouthBuild program. While this has helped somewhat lessen the burden, the RHE Management Team has determined that we need at least one additional mid-career Housing-Voucher Team member (minimum 5+ years of experience managing HUD voucher programs). We are considering a variety of options, including recruiting a Deputy for the Housing Voucher Team or promoting one of our Team Members to Deputy Director and backfilling a mid-career position. We have also begun discussions with WorkSource Montgomery and AmeriCorps Maryland to potentially supplement the initial costs of onboarding new Voucher Team members. For the inspections finding, we have been having discussions since the RHE leadership turnover about the performance of our current vendor, Gilson Housing Partners. They have been increasingly unreliable since we selected them as our inspections vendor in February 2025. Just in the last few weeks, we havedetermined that we need to terminate the vendor, particularly after we received a video of an inspection where the Gilson representative spent approximately 80 seconds in the unit, never left the entryway, and only asked the resident a few questions before leaving. We have already received one proposal from Archer-Greenwood Companies and expect 2-3 more proposals in the next few weeks, at which point we will submit a notice of termination to Gilson. Responsible Person: James Hedrick, Interim Executive Director Anticipated Completion Date: Recertifications & Voucher Team Hiring - AmeriCorps Maryland – Applications due July 1, 2026. Participants’ terms begin August/September 2026 and last for one year – extendable as full-time employee after the AmeriCorps subsidy. - Housing-Voucher Team Deputy Director/Mid-Career Port-In Specialist – The position requires a particular set of skills and experience in a specialized area. Recruitment and advertisement are expected to take some time. Advertising for the position will begin late Summer 2026, hiring expected before year-end 2026. Inspections Vendor Replacement - Have already received proposals from one potential inspection replacement firm: Archer- Greenwood. We have reached out to additional vendors and expect proposals within the next few weeks. We will send a letter of termination and fully transition to the new vendor by the end of FY2026 (September 30, 2026).

2025-002 – SPECIAL TESTS & PROVISIONS: RENT REASONABLENESS Auditee’s Response and Planned Corrective Action > Rent Reasonable forms will be used for any/all rental increases in program. These will not be compared to the payment standards. > A Certification Checklist has been developed so that these items are addressed at any/all certifications. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Amanda Phillips, Executive Director

2025-001 – ELIGIBILITY Auditee’s Response and Planned Corrective Action > Going forward, utility allowance will not be given for stove or refrigerator unless they are owned by the tenant. > Correct payment standards for the year of the certification will be used. 100% of payment standard only any other amount will require Reasonable Accommodation. > A Certification Checklist has been developed so that these items are addressed at any/all certifications. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Amanda Phillips, Executive Director

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the timing and progress of all tenant annual recertifications to avoid untimely filings in the future. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

Corrective Action Plan: The return of tenant security deposits were not completed on time due to staff turnover. Stanan’s occupancy specialist and supervisor will closely monitor the timing of the return of security deposits. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.