Corrective Action Plans

Name of auditee: The Pavilion Housing Development Fund Corporation HUD auditee identification number: 012-EE247 Name of audit firm: WithumSmith+Brown, PC Period covered by the audit: Year Ended September 30, 2024 CAP prepared by: Name: Father Ronald Giannone Position: Executive Director Telephone: 646-996-4234 1. Current Findings on the Schedule of Findings, and Questioned Costs a. Finding 2024-001. Delinquent deposits into the replacement reserve account. i. Comments on the Finding and Each Recommendation: Management concurs with the finding and the auditor’s recommendation to transfer the funds to the replacement reserve account. ii. Actions Taken on the Finding: Management will transfer the funds as soon as cash flow permits. b. Finding 2024-002. Special Tests and Provisions – Project Funds. i. Comments on the Finding and Each Recommendation: Management concurs with the finding and the auditor’s recommendation to utilize an interest-bearing account for project funds. ii. Actions Taken on the Finding: Management is in the process of evaluating the recommendation to determine that appropriate course of action. 2. Status of Corrective Actions on Findings Reported in the Prior Audit Schedule of Findings, and Questioned Costs. Finding 2023-001 for delinquent deposits in the aggregated amount of $54,061 were funded in 2024.

Name of auditee: The Pavilion Housing Development Fund Corporation HUD auditee identification number: 012-EE247 Name of audit firm: WithumSmith+Brown, PC Period covered by the audit: Year Ended September 30, 2024 CAP prepared by: Name: Father Ronald Giannone Position: Executive Director Telephone: 646-996-4234 1. Current Findings on the Schedule of Findings, and Questioned Costs a. Finding 2024-001. Delinquent deposits into the replacement reserve account. i. Comments on the Finding and Each Recommendation: Management concurs with the finding and the auditor’s recommendation to transfer the funds to the replacement reserve account. ii. Actions Taken on the Finding: Management will transfer the funds as soon as cash flow permits. b. Finding 2024-002. Special Tests and Provisions – Project Funds. i. Comments on the Finding and Each Recommendation: Management concurs with the finding and the auditor’s recommendation to utilize an interest-bearing account for project funds. ii. Actions Taken on the Finding: Management is in the process of evaluating the recommendation to determine that appropriate course of action. 2. Status of Corrective Actions on Findings Reported in the Prior Audit Schedule of Findings, and Questioned Costs. Finding 2023-001 for delinquent deposits in the aggregated amount of $54,061 were funded in 2024.

Management concurs with the finding. Beginning in fiscal 2025, management will open an interest bearing account insured by the Federal Deposit Insurance Corporation (“FDIC”) and transfer funds to the account to comply with HUD requirements. Our policies and procedures manual will be updated to more clearly specify this HUD compliance requirement. We will continuously monitor HUD’s overall requirements, in order to maintain compliance on an ongoing basis.

The Corporation concurs that they did not deposit surplus cash for the year ended September 30, 2023 into the residual receipts account within 60 days after year-end. The Corporation has deposited surplus cash into the residual receipts account as of September 30, 2024 and has implemented procedures to ensure any future surplus cash deposits into the residual receipts account are made within 60 days after year-end.

McSherrystown Interfaith Housing Corporation 40 E. High Street, Gettysburg, PA 17325 Phone (717) 334-1518 • Fax (717) 334-8326 TDD/TTY Relay Service: 1-800-654-5984 www.adamscha.org CORRECTIVE ACTION PLAN JANUARY 8, 2025 McSherrystown Interfaith Housing Corporation respectfully submits the following corrective action plan for the year ended September 30, 2024. Cognizant or Oversight Agency for Audit: Mortgage Insurance Rental Housing, ALN #14.134 Name and address of independent public accounting firm: Hamilton & Musser, PC 176 Cumberland Parkway Mechanicsburg, PA 17055 Audit Period: October 1, 2023 - September 30, 2024 The finding from the September 30, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings and Questioned Costs - Major Federal Award Programs Audit: #2024-002 - Significant Deficiency-Reconciliation of Escrow Accounts Mortgage Insurance Rental Housing, ALN #14.134 Recommendation We recommend that McSherrystown Interfaith Housing Corporation request a revised PUPM rate from HUD as the management fee expensed has not reached the maximum of 6.04% outlined in the management agreement with the management agent, but is capped below this level due to the original PUPM rate agreed upon. View of responsible officials and planned corrective action We agree that this compliance requirement is listed in the compliance supplement. We will work with HUD to increase the PUPM rate going forward and implement controls to ensure the management fees stay within the agreed upon limits. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call McSherrystown Interfaith Housing Corporation Executive Director, Stephanie McIIwee at (717) 334-1518.

Catholic Charities respectfully submits the following corrective action plan for the year ended June 30, 2024. Name & address of public accounting firm: Kernutt Stokes 1600 Executive Parkway, Suite 110 Eugene OR 97401 Audit Period: June 30, 2024 Major Federal Award Findings: Finding Reference #: 2024-001 Significant deficiency Recommendation: We recommend management design and implement internal controls over compliance to ensure tenant recertification is performed within the timeframe specified by HUD. Corrective Action: Renaissance Court has contracted with a new property management company, effective April 1, 2024. Due to the transition, certain tenant recertifications were completed late. Management will work with Guardian Management to improve the procedures and ensure tenant recertifications are completed in a timely manner, as specified by HUD. Questions regarding this corrective action plan may be directed to Marci Pierce, Chief Financial and Administrative Officer, at (503) 688-2646.

Recommendation: We recommend that the Cooperative receive approval from HUD before withdrawing funds from the general operating reserve in excess of 20% of the total balance as of the close of the preceding annual period. Action Taken: The Cooperative will first receive approval from HUD before withdrawing funds over 20% of the total balance in the general operating reserve as of the close of the preceding annual period. Planned Completion Date: January 31, 2025

Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance - E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority's files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 9,051 units. Of a sample size of eighty-nine (89) tenant files, the following was noted: • HUD-9886 Authorization for Release of lnformation was missing in 4 files Our sample size is statistically valid. Known Questioned Costs: $24,363 Cause: There is significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: Of the Eighty Nine (89) tenant files audited, four (4) tenant files contained a deficiency in the same indicator---the Authorization for the Release of lnformation/ Privacy Act Notice (HUD Form 9886) retained in the tenant file was executed after the audit date range, not within the audit period (4/1/23- 3/31/24) or within the three months prior. The HACCC discovered two contributing factors for this deficiency and identified a plan to ensure compliance with this requirement which is detailed below. First, the HACCC's Housing Choice Voucher program entered into a partnership with Paul Edwards Management and Consulting (PEM) on May 1st 2024. This partnership provides the HACCC's Housing Choice Voucher program with technical assistance and coverage of vacant positions within the Housing Choice Voucher program Continued Eligibility team. The PEM team members assigned to Continued Eligibility are responsible for completing timely Annual Recertifications for all assigned Housing Choice Voucher program participants---including the collection of any signature documents required by HUD annually. To ensure compliance with this requirement, contract performance indicators related to those positions temporarily assigned to PEM (including the timeliness of Annual Recertifications and a consolidated report of findings within the Electronic File Protocol Quality Control Audit Checklists) will be included in a corrective action plan. The enhanced monitoring provided by the corrective action plan will a) ensure the continued collection of the performance indicator data and b) provide timely feedback regarding the partnerships ability to mediate the deficiency. Second, HUD removed the expiration date from the 9886 form. Effective 01/01/2024, HUD requires Housing Authorities to collect a signature on the 9886 form once throughout the course of participation instead of requiring Housing Authorities to collect a signature on the form annually (or every 15 months). HUD issued PIH Notice 2023-27 on 09/29/2023. The notice indicated "In accordance with the final rule, all applicants must sign the consent form at admission, and participants must sign the consent form no later than their next interim or regularly scheduled income reexamination. After an applicant or participant has signed and submitted a consent form either on or after January 1, 2024 (regardless of the PHA/MFH Owner's compliance date), they do not need to sign and submit subsequent consent forms at the next interim or regularly scheduled income examination ... ". The HACCC' s Housing Choice Voucher program began to request tenant signatures on the updated 9886 form effective 1/1/2024 (within our online recertification workflows) and effective 3/29/24 (within our paper recertification packets). Internal procedures for the storage of electronic documents ("HACCC Electronic File Protocol") related to the 9886 form were updated in accordance with the change, to in effect, retain the 9886 document as any other "vital document" or one-time verification would be stored and retained (ex. birth certificate, social security card, etc)--- storing and retaining only the most recent version of the document. The HACCC agrees that the requirement to retain a 9886 executed within the audit date range for these 4 files was not fulfilled despite the above-mentioned updates taking place within the audit date range. To ensure compliance with this requirement, Electronic File Protocol QC Checklist Procedure Training will be included in a corrective action plan. The training requirement will a) ensure the continued collection and review of the Electronic File Protocol Quality Control reports and b) provide timely feedback regarding whether having a single retention requirement applied throughout an entire fiscal year will effectively mediate this deficiency. We agree with the Auditor's observations on the inspection of the tenant files and will implement internal control procedures that will ensure compliance of federal regulations. Ingrid Layne, Director of Assisted Housing, will be responsible to implement this corrective action by March 31, 2025.

Finding 2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers, Mainstream Vouchers and Emergency Housing Vouchers Programs Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance - N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority's files and on discussions with management, the Authority did not properly abate one (1) out of thirty-seven (37) annual failed inspections selected for testing. Context: The Authority did not properly abate one (1) out of thirty-seven (37) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Our sample size is statistically valid. Known Questioned Costs: $398 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance with Notice PIH 2021-14(HA). Effect: The Housing Voucher Cluster is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views ofresponsible officials and planned corrective action: Of the Thirty-Seven (37) tenant files audited, one (1) tenant file contained a deficiency--- the file did not contain adequate verification of the abatement cure request date justifying the HACCC's subsequent cancellation of this abatement after the deficiencies were verified as corrected. The HACCC discovered a contributing factor for this deficiency and identified a plan to ensure compliance with this requirement which is detailed below. HUD requires HACCC's Housing Choice Voucher program to abate (permanently withhold) housing assistance payments no later than the first of the month following the specified correction period (including any approved extension) when HQS deficiencies are discovered during biennial HQS inspections of subsidized units. To improve housing opportunities to families with vouchers and support landlord retention on our programs, the HACCC (in accordance with applicable regulations) offers to end the period of HAP abatement "effective on the earlier of the day the unit passes inspection or the date the correction was reported completed' as a courtesy. In this case, the unit failed inspection for non-life threatening deficiencies (ex. overgrown grass) on 6/20/2023. The deficiencies were not corrected prior to the reinspection which took place on 7/18/2023, prompting the placement of a HAP abatement on 7/26/2023 to withhold all HAP payments effective 8/1/2023 on. A reinspection was requested and the unit passed inspection in August. On 8/31/23 the abatement was subsequently cancelled in the HACCC's software and a memo was entered indicating that the landlord had requested the abatement cure reinspection prior to the abatement effective date of 8/1/23. However, it was discovered that the necessary verification of this abatement cure request was not attached to the tenant record. Due to the HACCC's inability to reproduce verification of the request date (being earlier than the day the unit passed inspection), the HACCC agrees with this finding. To ensure compliance with this requirement, the Internal HCV Inspection Procures will be updated to include systems for ensuring that necessary verification of any abatement cure request date is stored. A File Memo containing a timeline and necessary verification ofrequest date will be submitted to a manager for approval any time an abatement is ended or cancelled. The manager will be responsible for storing the executed File Memo and verification in the tenant file. The Authority has recognized the deficiencies in the Housing Voucher Cluster and has implemented internal control procedures that will ensure compliance of federal regulations. Ingrid Layne, Director of Assisted Housing, will be responsible to implement this corrective action by March 31, 2025.

Finding Summary: Catholic Charities internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid for two of the transactions reviewed by the auditors. Corrective Action Plan: The organization’s Sr Division Director Housing Stability will implement a rent reasonableness completion and review process. Responsible Individuals: Chief Program Officer Anticipated Completion Date: June 30, 2025

The City's Department of Housing has an established policy in place for determination of initial program eligibility as well as determination of continued program eligibility. The City's Department of Housing will review its procedures for executing Housing Assistance Payment (HAP) contracts and amendments and make any necessary procedural adjustments to ensure that ineligible families do not receive program assistance. The City's Department of Housing will enhance its quality control review in this area and provide additional guidance to staff as necessary.

The City's Department of Housing has an established policy for outlining and tracking documents required for determining initial program eligibility for applicants as well as continued program eligibility for program participants. The policy also addresses the determination and documentation of rent reasonableness. The department will enhance its quality control review in this area and provide additional guidance to staff as necessary.

The City's Director of Housing will keep abreast of when the "General Depository Agreement," HUD Form 51999 (GDA) expires and will promptly notify the Director of Finance. The City's Director of Finance will ensure a new depository agreement is signed.

The City's Housing Department has reviewed its policy on Housing Quality Standards (HQS) deficiencies and extensions for correction of identified deficiencies and has made procedural adjustments to ensure that any deficiency correction extension is included in the participant file.

When cash becomes available, the Organization will deposit the underfunded amount into the replacement reserve account.

Management agrees with the finding and has made the transfer into the replacement reserve account.

Management agrees with the finding and has made the transfer into the replacement reserve account.

CORRECTIVE ACTION PLAN FOR AUDIT FINDING 2024-001 The Organization agrees with the finding. The Organization has agreed to start performing physical inspections again, as required by HUD. Contact: Kalisha France, Regional Property Manager Completion Date: November 6, 2024

MCHA has hired a full time HCV Specialist who is attending training. With a fulltime HCV Specialist MCHA will now be able to have another employee perform quality control on the files to make sure the correct utility allowances and voucher sizes are being used. We will address any discrepancies promptly to avoid any excessive rent burdens for tenants or incorrectly calculated HAP payments.

When the Section 202 projects are able to reimburse the Authority for expenses paid on their behalf, the inter-program receivable will be settled.

Federal Program, Assistance Listing Number and Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description - The City is required to track and report program income within HUD’s Integrated Disbursement and Information System (IDIS) and the general ledger. The city reported fiscal 2024 program income in fiscal 2025. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Regina Greear, Julie Schneider; Anticipated completion date: June 2025 Planned Corrective Action - The city is in the process of enhancing processes and controls to ensure timely, accurate and consistent receipts of the program income and the reconciliations.

Federal Program, Assistance Listing Number and Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description - The City’s on-site inspections for compliance with the housing quality standards are triggered by City’s process to audit developers for compliance with HOME eligibility requirements. This basis is more restrictive than Federal requirements for Housing Quality Inspections At the end of an inspection cycle a certificate of completion is completed and signed by the responsible inspector. The City did not have effective controls to ensure the certificate of completion, is reviewed for completeness and accuracy. The City did not inspect the 20% of the units, as required by their policy. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Julie Schneider; Anticipated completion date: June 2025 Planned Corrective Action - The City will review its processes and implement additional controls to ensure certificates of completion are reviewed for completeness and accuracy and to verify 20% of the units are inspected to comply with the HOME Program manual and federal regulations related to Housing Quality Standards.

Federal Agency Name: U.S. Department of Housing and Urban Development Assistance Listing Number: 14.128 Program Name: Mortgage Insurance for Hospitals Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Over Compliance and Noncompliance Finding Summary: The Hospital has amounts due from affiliate of $697,310 that are older than 90 days and is in violation of a loan covenant from HUD. Responsible Individuals: Gail Jestila, CFO Corrective Action Plan: Management implemented a repayment plan with affiliate to reduce amounts outstanding. Anticipated Completion Date: Ongoing

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. Adam Bovilsky, Executive Director, is responsible for implementing this corrective action by March 31, 2025.

HUD Section 202, Capital Advance – Assistance Listing No. 14.157 Recommendation: Management should implement a review process of the management fee rate upon any changes to that rate or system utilized to calculate that rate to ensure the HUD approved rate is utilized. Management should repay the amount due the Organization. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The controller will annually review the calculation of the management fee that is being billed to the property by the accounting manager to validate the amount is in compliance with HUD form 9839-B. The overpayment from fiscal year 2024 was corrected in October 2024 Name of the contact person responsible for corrective action: Troy Marschel. Planned completion date for corrective action plan: 10/1/2024