Corrective Action Plans

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Finding 2024-001 – Moving to Work Demonstration ALN 14.881 - Income Verification Requirements, Eligibility- Noncompliance & Significant Deficiency Corrective Action Plan: We are using the recommendations provided by the auditor's and are changing our file check list so that the EIV report will be i...
Finding 2024-001 – Moving to Work Demonstration ALN 14.881 - Income Verification Requirements, Eligibility- Noncompliance & Significant Deficiency Corrective Action Plan: We are using the recommendations provided by the auditor's and are changing our file check list so that the EIV report will be included in all the necessary check list. Also, the HA staff will use hierarchy for documentation in order of priority for participants for the HCV program. • Up-front income verification (UIV) using HUD EJV system • Up-front income verification (UIV) using a non-HUD system • Written third-party verification provided by applicant or participant • Written third-party verification form • Oral third-party verification • Self-certification Person Responsible: Doris Jamison and Janie Robinson Anticipated Completion Date: June 30, 2025
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. James Wi...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. James Williams, Executive Director, will be responsible to implement this corrective action by June 30, 2025.
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. James Wi...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. James Williams, Executive Director, will be responsible to implement this corrective action by June 30, 2025.
U.S. Department of Housing and Urban Development The Dowling Park Apartments, Inc. HUD Project No. 063-11059 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 through June 30, 2024 The findings from the schedule of findings and que...
U.S. Department of Housing and Urban Development The Dowling Park Apartments, Inc. HUD Project No. 063-11059 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 through June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY U.S. Department of Housing and Urban Development 2024-001 Section 223(d) Mortgage Insurance for the Purchase or Refinance of Existing Multifamily Housing Projects – Assistance Listing No. 14.155 Recommendation: Recommend Project Management reviews its internal control policies over the recording of transactions to ensure that all transactions are used for their intended purpose. Explanation of disagreement with audit finding: There was no disagreement with the audit finding. Action taken in response to finding: Management agreed that funds were erroneously used for HUD related operational expenditures and were replenished to the reserve account when the error was discovered by accounting staff. Procedures were changed to include all accounting personnel in communications regarding reserve funded projects. The contact person responsible for corrective action: Michael Willis, CFO of Advent Christian Village Planned completion date for corrective action plan: August 2024 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Michael Willis, at (386)-658-5450.
View Audit 341951 Questioned Costs: $1
MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT WILL CONTINUE TO SEEK HUD'S APPROVAL FOR THE RELEASES IN QUESTION.
MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT WILL CONTINUE TO SEEK HUD'S APPROVAL FOR THE RELEASES IN QUESTION.
View Audit 341927 Questioned Costs: $1
MANAGEMENT AGREES WITH THE FINDING. THE FINANCIAL STATEMENTS WERE SUBMITTED TO HUD ON OCTOBER 3, 2023.
MANAGEMENT AGREES WITH THE FINDING. THE FINANCIAL STATEMENTS WERE SUBMITTED TO HUD ON OCTOBER 3, 2023.
View of Responsible Officials and Planned Corrective Action Plan—The City was unaware of the FFATA reporting requirements. As a result of this finding, we have reached out to HUD to obtain reporting instructions and have begun the process of gathering subrecipient information necessary for reporting...
View of Responsible Officials and Planned Corrective Action Plan—The City was unaware of the FFATA reporting requirements. As a result of this finding, we have reached out to HUD to obtain reporting instructions and have begun the process of gathering subrecipient information necessary for reporting. As soon as all pertinent information has been gathered, the Office of Strategic Planning will begin filing all past due reports until we become current.
Finding 522594 (2024-001)
Significant Deficiency 2024
Corrective Action Plan for FYE June 30, 2024 Finding 2024-001 Corrective Action Plan: The Youth Department had a leadership void for the first half of program year 2023 which resulted in having a vacuum on direct leadership in the department which unfortunately led to this finding. I am pleased to r...
Corrective Action Plan for FYE June 30, 2024 Finding 2024-001 Corrective Action Plan: The Youth Department had a leadership void for the first half of program year 2023 which resulted in having a vacuum on direct leadership in the department which unfortunately led to this finding. I am pleased to report that in January 2024 CNY Works welcomed a new Director of Youth Services which has led the department to transform and flourish in the last year. Under the new leadership, the Youth Department has implemented new internal controls, processes and has staff focused and running programs under the Workforce Innovation and Opportunity Act (WIOA). Nonetheless, CNY Work youth staff along with the Executive Director and the Director of Youth Services will review current policies and procedures to ensure these are operating effectively reflecting allowable activities and allowable costs (including hours worked by youth in the program) are allocated and charged accurately to the federal program. Emphasizing the importance of internal controls to ensure documents are signed by designated individuals to comply with requirements. The Director of Youth Services will continue to review timesheets, eligibility forms, and signatures, along with other requirements of the program to ensure internal control procedures are adequate and operating as intended. Finally, management will continue to analyze methods for monitoring the operational effectiveness of the applied internal controls on compliance and document any mitigating controls that are developed and implemented. Contact Person Responsible for Corrective Action Plan: Rosemary Avila-Ticio Executive Director, CNY Works Phone Number: 315-477-6901 Email: ravila@cnyworks.com Anticipated Completion Date of Corrective Action Plan: March 30, 2025
Management agrees with the finding and is in the process of revising internal controls to address this issue.
Management agrees with the finding and is in the process of revising internal controls to address this issue.
View Audit 341811 Questioned Costs: $1
FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2024-003 Statement of Condition: Management made an unauthorized withdrawal of $4,400 from the residual receipts account during the fiscal year ended June 30, 2022; the funds have not been returned to the residual receipts account. Audito...
FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2024-003 Statement of Condition: Management made an unauthorized withdrawal of $4,400 from the residual receipts account during the fiscal year ended June 30, 2022; the funds have not been returned to the residual receipts account. Auditor Recommendation: Management should deposit $4,400 into the residual receipts account to refund the unapproved withdrawals. Management should also contact the HUD Project Manager to develop a plan to get current with vendors and fund the residual receipts account. A rent increase may be necessary. S3800-130: Response Indicator: Agree. S3800-140: Completion Date: February 3, 2025 S3800-150: Action Taken: The board had decided to change property management firms because of the history and severity of financial statement findings and major program fundings prior to the discovery of the unrecorded expenses. The board believes that the new management firm has a properly designed and functioning system of internal controls to prevent such future occurrences. As a result of the discovered unpaid invoices discussed in Finding 2024-001, property management will be unable to make the required residual receipts reserve deposit and pay all vendors without a rent increase from HUD. Management plans to contact the HUD Project Manager to develop a plan to get current with vendors and fund the residual receipts account. A rent increase may be necessary.
FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2024-002 Statement of Condition: Management only made nine (9) of the twelve (12) monthly required reserve deposits, leaving the account underfunded by $4,053 at June 30, 2022; for the year ended June 30, 2023, only $2,702 of the required ...
FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2024-002 Statement of Condition: Management only made nine (9) of the twelve (12) monthly required reserve deposits, leaving the account underfunded by $4,053 at June 30, 2022; for the year ended June 30, 2023, only $2,702 of the required $16,212 in deposits were made, leaving the account behind schedule by another $13,510, for a total deficiency of $17,563; for the year ended June 30, 2024, only $5,404 of the required $16,212 in deposits were made, leaving the account behind schedule by another $10,808, for a total cumulative deficiency of $28,371. Auditor Recommendation: Management should institute a monitoring process to ensure all required monthly deposits to the replacement reserve are made. Such processes could include initiating automatic recurring monthly transfers with the financial institution that maintains the replacement reserve account. We also recommend contacting the HUD project manager to develop a plan to pay all outstanding liabilities and fund the reserve account.. S3800-130: Response Indicator: Agree. S3800-140: Completion Date: February 3, 2025 S3800-150: Action Taken: As a result of the discovered unpaid invoices discussed in Finding 2024-001, property management will be unable to make the required reserve deposits and pay all vendors without a rent increase from HUD. Management plans to contact the HUD Project Manager to develop a plan pay all vendors for amounts owed and fund the reserve account. A rent increase may be necessary.
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT S3800-030 Statement of Condition: Management did make all of the required deposits to the replacement reserve at June 30, 2024. The annual deposits required were $8,892 but only $5,918 was deposited. S3800-045 Reporting Views of Responsible Official...
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT S3800-030 Statement of Condition: Management did make all of the required deposits to the replacement reserve at June 30, 2024. The annual deposits required were $8,892 but only $5,918 was deposited. S3800-045 Reporting Views of Responsible Officials: Management will design controls to ensure all monthly deposits are made timely. S3800-080: Auditor Recommendation: Management should ensure that the required reserve deposits are made by the required due date. S3800-150: Actions Taken or to be Taken: Management concurs with the auditor’s recommendation, and will design controls to ensure all required deposits are made to the replacement reserve.
2024-001-(2023-004) MISSING REQUIRED DOCUMENTATION FROM PUBLIC HOUSING FILES (SIGNIFICANT DEFICINCY) AHA has implemented a training program for staff and is hiring a new position Compliance technical review. Responsible Party: Anticipated Completion Date: Finance Director February 2025
2024-001-(2023-004) MISSING REQUIRED DOCUMENTATION FROM PUBLIC HOUSING FILES (SIGNIFICANT DEFICINCY) AHA has implemented a training program for staff and is hiring a new position Compliance technical review. Responsible Party: Anticipated Completion Date: Finance Director February 2025
U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84....
U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84.425D) ARP Summer Enrichment (Assistance Listing# 84.425U) ARP Comprehensive After School (Assistance Listing# 84.425U) ARP ESSER III (Assistance Listing# 84.425U) Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria - Expenditures must be used to prevent, prepare for, and respond to COVID-19. These programs are authorized, as applicable, by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, 2021, Pub. L. No. 116-260 (December 27, 2020), and the American Rescue Plan (ARP) Act of 2021, Pub. L. No. 117-2 (March 11, 2021). The regulations in 34 CRF Part 76 (State Administration), 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Award and 31 CFR Part 205 (Cash Management Improvement Act) apply to these programs. The School District must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. ( d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local and tribal laws regarding privacy and responsibility over confidentiality. Condition/Context - We haphazardly sampled five COVID-19 - Education Stabilization Fund (ESF) expenditures. Our audit procedures found one disbursement where management overrode documented internal control procedures. We viewed invoices, purchase orders, and payment support and noted the disbursement was processed and paid without proper documentation to support the payment made and the payment was processed without the internal claims auditor's review prior to payment. Cause - Management override of established controls. Effect - Revenues and expenditures for one of the ESF grants were overstated prior to adjustment. Adjustment resulted in recording a receivable from the vendor and an offsetting liability to the passthrough agency providing the grant funding. Questioned Costs - None. The improper payment was subsequently adjusted out of expenditures. Recommendation - We recommend that the School District ensures that only disbursements that have been processed and approved by the internal claims auditor to be paid. Management Response - School District management concurs with the finding and will take corrective action. Corrective Action - The Business Office will review and adhere to all cash disbursements procedures and protocols. Completion Date - Effective immediately. Respectfully Submitted, Dr. Brett Miller, Assistant Supt. for Business
Corrective Action Plan Contact Person Artena Thompson 1834 W 7th Street Grand Island, NE 68803 (308) 385-5530 Finding 2024-001 Management has recognized the finding and will familiarize themselves with the requirements of these documents to ensure the proper procedures are followed and the proper do...
Corrective Action Plan Contact Person Artena Thompson 1834 W 7th Street Grand Island, NE 68803 (308) 385-5530 Finding 2024-001 Management has recognized the finding and will familiarize themselves with the requirements of these documents to ensure the proper procedures are followed and the proper documents are retained in the tenant files. Finding 2024-002 Management will familiarize themselves with the requirements and guidelines of their ACOP to better ensure that the Authority is operating and maintaining its policies. Finding 2024-003 See Finding 2024-001.
Item # 2024-003 Reporting (Compliance Finding) Criteria: Per the grant agreement with the Department of Housing and Urban Development (HUD) the Organization must submit semi-annual performance and financial reports within 30 days of the reporting period end. Condition: Management did not submit the ...
Item # 2024-003 Reporting (Compliance Finding) Criteria: Per the grant agreement with the Department of Housing and Urban Development (HUD) the Organization must submit semi-annual performance and financial reports within 30 days of the reporting period end. Condition: Management did not submit the reports within the time period specified. Cause: Management was unaware of the thirty day deadline submit the required reports. Effect: The Organization is not in compliance with the federal award reporting requirements. Recommendation: The Organization should update its procedures to submit federal reports within the time period specified in the grant agreement. Views of Responsible Officials and Planned Corrective Actions: Management has been making updates to its policies and procedures throughout fiscal year 2025 to be in full compliance with federal award agreements and the Uniform Guidance. This exercise is anticipated to be complete by the end of fiscal year 2025.
1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management concurs that it failed to make required deposits into the Residual Receipt account in the amount of $12,574 for the year ended June 30, 2023, and acknowledges that there was no HUD approval for non-payment. b. Action(s...
1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management concurs that it failed to make required deposits into the Residual Receipt account in the amount of $12,574 for the year ended June 30, 2023, and acknowledges that there was no HUD approval for non-payment. b. Action(s) Taken or Planned on the Finding Management has initiated a transfer of funds into the Residual Receipt account as of 9/23/2024. The General Partner has also assigned a permanent Asset Manager to ensure required payments are made in accordance with agreements.
1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management concurs that the Project withdrew from the residual receipts reserve in the amount of $8,409 without HUD approval. Management is in agreement with the recommendation to deposit $8,409 into the residual receipts reserve...
1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management concurs that the Project withdrew from the residual receipts reserve in the amount of $8,409 without HUD approval. Management is in agreement with the recommendation to deposit $8,409 into the residual receipts reserve. b. Action(s) Taken or Planned on the Finding Management has made changes to internal controls to prevent and detect unauthorized withdrawals from reserves. Management further notes that they have re-trained staff, and reaffirmed the review and approval process to ensure required residual receipt reserve withdrawals are completed with proper HUD authorization. Management will complete the required reimbursement to the residual receipts reserve by October 31, 2024.
View Audit 341508 Questioned Costs: $1
Finding 521998 (2024-001)
Significant Deficiency 2024
U.S. Department of Housing and Urban Development Caritas Manor, Inc., HUD Project No. 065-EE003-CA, respectfully submits the following corrective action plan for the year ended September 30, 2024. Audit Firm: McNorton Ishee & Jones, P.C. P.O. Box 161425 Mobile, Alabama 36616 Audit period: Sep...
U.S. Department of Housing and Urban Development Caritas Manor, Inc., HUD Project No. 065-EE003-CA, respectfully submits the following corrective action plan for the year ended September 30, 2024. Audit Firm: McNorton Ishee & Jones, P.C. P.O. Box 161425 Mobile, Alabama 36616 Audit period: September 30, 2024 Finding 2024-001 – Special Tests and Provisions State of Condition: The project has not made the required residual receipts deposit. Corrective Action: Management will ensure to make the required residual receipts deposit. If the Department of Housing and Urban Development should have any questions or comments regarding this plan, please contact Craig Bounds at (228) 435-1642.
View Audit 341227 Questioned Costs: $1
2024-001 ALN 14.871 – Housing Voucher Cluster – Activities Allowed or Unallowed The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Questioned Costs. In 2021, the Authority was instructed by Keith Landrum of the Colu...
2024-001 ALN 14.871 – Housing Voucher Cluster – Activities Allowed or Unallowed The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Questioned Costs. In 2021, the Authority was instructed by Keith Landrum of the Columbia, South Carolina HUD Field Office to stop making payments until the matter could be further investigated to see what amounts, if any, are still owed. Management will continue to monitor budgets to ensure that funds are adequate. Management has and will continue to make budget revisions to reduce unessential operating costs. The Authority has designed and implemented a Board approved formal repayment agreement. Person Responsible for Correction of Finding: Mark Fountain, Executive Director Projected Completion Date: June 30, 2025
View Audit 341129 Questioned Costs: $1
The senior management team including the Executive Director, interim CFO Jill Hansen, and the Finance Committee of the Governing Board have reviewed and agree with the findings. Regarding the 2024-001 Procurement of Capital Projects, Jill Hansen and I are proposing the corrective action of adding ad...
The senior management team including the Executive Director, interim CFO Jill Hansen, and the Finance Committee of the Governing Board have reviewed and agree with the findings. Regarding the 2024-001 Procurement of Capital Projects, Jill Hansen and I are proposing the corrective action of adding additional communication requirements to the existing procedures, starting with a pre-bid internal meeting including the ED, CFO, and other appropriate mangers. We will also be creating a timeline of meetings to prepare and manage our capital budget for facilities, technology, and other needs where all participants will be educated on the appropriate bid procedures and policies. I will be the point person regarding these corrective actions and these changes to our Accounting and Financial Policies and Procedure Manual, which will be effective 3/1/25, pending Policy Council and Board approval. We have updated all Senior and Fiscal Staff. Project Management Staff will be updated on 1/28/25,
Identifying Number: 2024-001 Finding: The Organization calculated surplus cash of $31,225 as of September 30, 2020 and surplus cash of $39,082 as of September 30, 2021, which includes the undeposited amount from September 30, 2020. This amount was not deposited into a residual receipts fund accou...
Identifying Number: 2024-001 Finding: The Organization calculated surplus cash of $31,225 as of September 30, 2020 and surplus cash of $39,082 as of September 30, 2021, which includes the undeposited amount from September 30, 2020. This amount was not deposited into a residual receipts fund account. The Organization calculated surplus cash of $149,237 as of September 30, 2022, which includes the undeposited amount from September 30, 2021. The Organization has not deposited this amount into a separate residual receipts fund account within 90 days of the fiscal year-end. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Surplus cash was caused by a release from the replacement reserve and a timing difference between the release of the reserve and the addition of building improvments. Building improvements and a related payable were recorded during the year ended September 30, 2023. As of September 30, 2024, the Organization did not have any surplus cash. The construction payable will be paid in full in the near future.
Identifying Number: 2024-001 Finding: The Organization expanded the licensed bed size of the mortgaged property by 12 skilled nursing beds before obtaining an approval from HUD. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management ...
Identifying Number: 2024-001 Finding: The Organization expanded the licensed bed size of the mortgaged property by 12 skilled nursing beds before obtaining an approval from HUD. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management has had multiple communications since May 2013 with their lender to resolve this finding, however it still remains unresolved. Management most recently corresponded with the lender in March 2022 to resolve the finding, and an application to HUD for approval of the license change was filed. Management most recently corresponded with the lender in August 2024. Lender is acquiring Phase I study to send to HUD. Management is currently waiting on HUD’s review for completion.
Identifying Number: 2024-001 Finding: The Organization reduced the licensed bed size of the mortgaged property by 6 skilled nursing beds before obtaining an approval from HUD. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management is in th...
Identifying Number: 2024-001 Finding: The Organization reduced the licensed bed size of the mortgaged property by 6 skilled nursing beds before obtaining an approval from HUD. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management is in the process of obtaining after-the-fact approval from HUD to resolve this finding by sending a letter of request to HUD with additional information on the bed change. Management most recently submitted additional information to the lender in September 2024.
Corrective Action Plan Orion Area Non-Profit Housing Corporation Project No. 044-11113 Year Ended June 30, 2024 January 31, 2025 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2024-002 – Eligibility - Tenant Income Threshold Finding Type. Immaterial noncompliance, Significant deficiency in internal...
Corrective Action Plan Orion Area Non-Profit Housing Corporation Project No. 044-11113 Year Ended June 30, 2024 January 31, 2025 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2024-002 – Eligibility - Tenant Income Threshold Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Section 8 Housing Assistance Payments (ALN# 14.195) Condition. Less than 40% of tenants who moved into the property during the year met the extremely low-income threshold and management did not maintain records of marketing efforts targeted to extremely low-income families, demonstrating that reasonable efforts were made to fill available units accordingly and that such efforts are ongoing. Effect. As a result of this condition, the Project failed to meet the prescribed income targeting requirements and documentation of marketing efforts to reach the target population. Plan. Management agrees with finding 2024-002. Management agrees to target extremely low-income individuals for residence, and to retain marketing records that support this effort. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: June 30, 2025
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