Corrective Action Plans

Finding 540746 (2024-001)

Significant Deficiency 2024

Interfaith Residence D/b/a Doorways and Related Entities

MO

Subrecipient Monitoring HUD Housing Programs Reporting

Finding 2024-001 Personnel Responsible for Corrective Actions: Megan Robinson, Chief Financial Officer and Carrie Bagwell, Director of Government Grants and Compliance Anticipated Completion Date: February 2025 Corrective Action Plan: Management recognized the need for additional staff capacity t...

Finding 2024-001 Personnel Responsible for Corrective Actions: Megan Robinson, Chief Financial Officer and Carrie Bagwell, Director of Government Grants and Compliance Anticipated Completion Date: February 2025 Corrective Action Plan: Management recognized the need for additional staff capacity to administer all required duties and hired an Outstate Program and Grants Manager on February 1, 2025 to focus on these tasks. The position is overseen by the Director of Government Grants and Compliance, who is knowledgeable about the service and reporting requirements of this program. Additionally, starting in February 2025, the team implemented bi-monthly meetings to update the Chief Financial Officers on progress and timely filing of all grants related reporting to ensure all deadlines are met.

View Audit 350444

Finding 540713 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Arkadelphia, Arkansas

AR

HUD Housing Programs Reporting

Housing Authority of the City of Arkadelphia respectfully submits the following corrective action plan for the year ended June 30, 2024. Responsible Official: Bobbi Partain, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR ...

Housing Authority of the City of Arkadelphia respectfully submits the following corrective action plan for the year ended June 30, 2024. Responsible Official: Bobbi Partain, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Audit period: Year ended June 30, 2024 Oversight Agency: U.S. Department of Housing and Urban Development The findings from the June 30, 2024 audit are discussed below. The findings are numbered to correspond to the auditing findings disclosed in Section C of the Schedule of Findings and Questioned Costs. B. FINDINGS - FINANCIAL STATEMENTS AUDIT None C. FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAMS AUDIT Department of Housing and Urban Development FALN 14.872 – Public Housing Capital Fund 2024-001 Compliance with Public Housing Capital Fund Criteria: Capital funds transferred to operation are not considered obligated until the funds have been budgeted and drawn down. The voucher request date must occur before those funds are reported as obligated in LOCCS. PHAs shall submit HUD-53001, Actual Modernization Cost Certificate within 90 days of the expenditure end date for each grant. Condition: We noted two instances when capital funds transferred to operations for Capital Fund Programs (CFP) 501-20 and 501-21 were obligated before the date the funds were requisitioned from eLOCCS. HUD-53001 was completed for CFP 501-20 on January 29, 2024, which was past the 90-day reporting period after the conclusion pf the program’s expenditures. The final expenditure on this grant was July 19, 2023. HUD-53001 was completed for CFP 501-21 on January 23, 2025, which was past the 90-day reporting period after the conclusion of the program’s expenditures. The final expenditure on this grant was February 7, 2024. Recommendation: The Authority should not obligate funds designated for transfers to operation until the funds have been budgeted and drawn down. We did note the funds for transfers to operations for CFP 201-22 and CFP 201-23 were properly obligated when the funds were drawn down. The Authority should promptly complete HUD-53001 at the conclusion of a CFP program to ensure it complies with the 90-day reporting period. Views of responsible officials and planned corrective actions: We will comply with the auditors’ recommendations. Anticipated Completion Date: June 30, 2025

View Audit 350400

Finding 540603 (2024-001)

Significant Deficiency 2024

Grand Rapids Housing Commission

MI

HUD Housing Programs Eligibility Significant Deficiency

GRHC Response & Corrective Action Plan The GRHC does not dispute the finding and acknowledges the deficiencies identified. Due to staff shortages and turnover, GRHC experienced challenges in maintaining consistent file management, eligibility determinations, and recertifications in strict complian...

GRHC Response & Corrective Action Plan The GRHC does not dispute the finding and acknowledges the deficiencies identified. Due to staff shortages and turnover, GRHC experienced challenges in maintaining consistent file management, eligibility determinations, and recertifications in strict compliance with HUD requirements. However, prior to the auditor’s testing that resulted in this finding, the GRHC had already begun discussing strategies to address these issues. Recognizing the need for stronger internal controls and process improvements, the GRHC initiated a plan to enhance file management, compliance monitoring, and process reviews. This plan includes: Process Mapping of Critical Functions to standardize workflows, ensure consistency, and eliminate inefficiencies. Digitization of forms to improve efficiency and reduce errors. Electronic document signing to streamline tenant file processing. Internal control checklists to ensure completeness and accuracy before file submission. Quality control (QC) review of all files by a manager before final submission to ensure compliance with HUD regulations. Strategies for these improvements began in August 2024 and are scheduled for full implementation by July 2025. GRHC leadership has been actively monitoring these efforts and meeting regularly to ensure progress toward compliance. Corrective Actions & Implementation Plan Corrective Action Responsible Group Completion Date Status Process mapping of critical workflows to ensure standardized procedures for eligibility and recertifications. Policy and Program Feb 2025 Completed Implement digitization of forms to streamline eligibility and recertification processes. Policy and Program 30-Apr-25 In Progress Introduce electronic document signing to enhance efficiency and reduce processing time. Policy and Program /IT 30-Apr-25 In Progress Develop and enforce internal control checklists for eligibility and recertifications. Policy and Program/IT 31-May In Progress Provide staff training on new processes and HUD compliance requirements. Policy and Program 30-Apr-25 Planned Conduct internal audits to evaluate the effectiveness of the new controls before manager QC begins. Policy and Program 30-Jun-25 Planned Require manager-level QC review of all tenant files before submission. Program Managers 01-Jul-25 Planned Implement a formal backup plan to ensure timely eligibility processing during staff absences or workload surges. ED/Program Directors 01-July-25 Planned Regular reporting to GRHC leadership on the status of tenant file compliance improvements. ED/Policy and Program Ongoing Planned Expected Outcome Full compliance with HUD requirements for eligibility and recertifications. Improved internal controls to prevent future deficiencies. A sustainable QC system for ongoing compliance monitoring. Monitoring & Follow-Up The Policy and Program Implementation Manager will oversee corrective actions and provide bi-weekly progress updates. The Executive Director will present the Corrective Action Plan at the next board meeting. Contact Person: Jose L. Capeles Title: Policy and Program Planning and Implementation Manager Date: 03/28/2025

View Audit 350376

Finding 540589 (2024-001)

Significant Deficiency 2024

The Housing Authority of the City of Hot Springs

AR

HUD Housing Programs Eligibility

2024-001 Eligibility $ 0 Condition and Criteria: The Authority’s purpose for existence is providing decent, safe and affordable housing to low- ...

2024-001 Eligibility $ 0 Condition and Criteria: The Authority’s purpose for existence is providing decent, safe and affordable housing to low- income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of rent assistance to be paid on the family’s behalf. HUD regulations prescribe the content of these family files. These requirements consist of the following: a. As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. c. Determine income eligibility and calculate the tenant’s rent payment in accordance with HUD regulations. d. Select tenants from the public housing waiting list in accordance with the PHA’s tenant selection policies. e. Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary. Population and Items Tested: Testing of seventy-one family files revealed the following deficiencies: 1. Two lacked documentation of rent reasonableness. 2. One file lacked an HQS inspection in the file. 3. Three files calculated an incorrect housing assistance payment. 4. One file lacked a utility allowance calculation. 5. One file lacked income verification at lease up. Auditor’s Recommendation: A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Grantee Response: We will comply with the auditor’s recommendation. Anticipated Completion Date: June 30, 2025

View Audit 350355

Finding 540509 (2024-005)

Material Weakness 2024

State of Hawaii, Department of Accounting and General Services

HI

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No: 2024 005 ALN No.: 10.179 Program Title: Micro Grants for Food Security Program Grant Award No.: AM200100XXXXG132 2020 21MGFSPHI1003-00 2021 AM22MGFSPHI1007-04 2022 23MGFSPHI1011-00 2023 Condition The audit identified 25 instances totaling $55,000 where grantee disbursements were not mad...

Finding No: 2024 005 ALN No.: 10.179 Program Title: Micro Grants for Food Security Program Grant Award No.: AM200100XXXXG132 2020 21MGFSPHI1003-00 2021 AM22MGFSPHI1007-04 2022 23MGFSPHI1011-00 2023 Condition The audit identified 25 instances totaling $55,000 where grantee disbursements were not made as soon as administratively possible after the drawdown of Federal Funds. Audit staff determined 25 days to be a reasonable period to disburse cash after drawdown from the Federal Government. Corrective Action Plan Concur. The Hawaii Department of Agriculture (HDOA) will change administrative procedures for disbursement of Federal funds under the Micro Grants for Food Security Program. Going forward, HDOA will process the grant contracts and payments in batches of roughly 100 micro grants per month. Federal Drawdown will not occur until the full batch of 100 contracts have been executed. HDOA fiscal staff will then expedite the payment process to ensure conformity with the 25 day disbursement timeline. Person Responsible Brendan Akamu, Market Development Branch Manager Anticipated Date of Completion The updated work process will be implemented in April 2025. The first batch of grant contracts and payments for the 2023 Fiscal year awards are scheduled for April 2025.

View Audit 350263

Finding 540441 (2024-002)

Significant Deficiency 2024

City and County of Honolulu

HI

HUD Housing Programs Period of Performance Program Income

Finding No. 2024-002: Period of Performance (Significant Deficiency – Federal Awards) Federal Award: 14.218 - CDBG – Entitlement Grants Cluster Audit Recommendation: We recommend the City adhere to the workout plan submitted to HUD to comply with the CDBG timely expenditure requirements. Admin...

Finding No. 2024-002: Period of Performance (Significant Deficiency – Federal Awards) Federal Award: 14.218 - CDBG – Entitlement Grants Cluster Audit Recommendation: We recommend the City adhere to the workout plan submitted to HUD to comply with the CDBG timely expenditure requirements. Administration’s Comments: The City will adhere to procedures to comply with the CDBG timeliness standard specified. Anticipated Completion Date: June 30, 2025 Contact Person(s): Holly Kawano, Department of Budget and Fiscal Services, Federal Grants Coordinator

View Audit 350255

Finding 540436 (2024-005)

Significant Deficiency 2024

Fairbanks Community Homes 176-Hd-021

AK

HUD Housing Programs Reporting

Failure to submit REAC report Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus cash to the...

Failure to submit REAC report Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus cash to the residual receipts account. Proposed Completion Date: June 30, 2025

View Audit 350252

Finding 540435 (2024-004)

Significant Deficiency 2024

Fairbanks Community Homes 176-Hd-021

AK

HUD Housing Programs Cash Management

Failure to Return Residual Receipts to HUD Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus ca...

Failure to Return Residual Receipts to HUD Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus cash to the residual receipts account. Proposed Completion Date: June 30, 2025

View Audit 350252

Finding 540434 (2024-003)

Significant Deficiency 2024

Fairbanks Community Homes 176-Hd-021

AK

HUD Housing Programs Cash Management Reporting

Failure to deposit Surplus Cash in the Residual Receipts accounts Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus ca...

Failure to deposit Surplus Cash in the Residual Receipts accounts Name of Contact:Kendrick D. Blais, President Management's view:Management agrees with the finding. Corrective Action: Management will transfer surplus cash to the residual receipts account. Proposed Completion Date: June 30, 2025

View Audit 350252

Finding 540423 (2024-002)

Material Weakness 2024

County of Fresno

CA

Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies a...

Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies and procedures, as necessary, to address all current regulatory requirements. The Department’s multifamily monitoring for all projects in the HOME period of affordability will be completed prior to June 30, 2025. As part of the monitoring process, the Department will document all records requiring annual or semi-annual oversight and review for compliance with HOME requirements. Should the monitoring result in any findings requiring corrective action, the Department will ensure all findings are addressed by September 30, 2025. Anticipated Completion Date May 2025 Contact Information of Responsible Official Name: Augustine Ramirez Title: Division Manager, DPWP Community Development Division Phone: 559-600-4266

View Audit 350241

Finding 540410 (2024-005)

Material Weakness 2024

Department of Human Services

HI

Special Tests & Provisions Eligibility HUD Housing Programs

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. The Supplemental Nutrition and Assistance Program office (“SNAPO”) has addressed these issues within the division to make efforts to improve our payment accuracy which include electronic cas...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. The Supplemental Nutrition and Assistance Program office (“SNAPO”) has addressed these issues within the division to make efforts to improve our payment accuracy which include electronic case documentation and data entry accuracy. Corrective Action Taken or Planned: SNAPO has worked with Statewide Branch Administration (“SBA”) to address these types of deficiencies as Hawaii is presently under corrective action for payment error rates. A mandatory refresher training to address budgeting and household composition had been implemented starting in January 2024 to improve core eligibility fundamentals such as budgeting. SNAPO will share the findings provided from this audit to include this as a part of our broader corrective strategy being implemented across the division through the partnership of SNAPO and SBA to address root causes for these errors. Regular case reviews are planned on being conducted to address areas of concern and will be addressed accordingly through supervisory channels to improve payment accuracy and case documentation. Completion Date: This is an on going activity and started for planning purposes from December 2024. SNAPO and Statewide Branch will be implementing the inaugural training/review with the Quality Maintenance and their review of the Quality Control (“QC”) Reports from Audit, Quality Control and Research Office (“AQCRO”). The Quality Control office conduct monthly reviews of all SNAP cases to provide to USDA Food and Nutrition Services on payment errors and will notate administrative deficiencies such as incorrect data entry for both income and deduction amounts used to calculate benefits when determining SNAP eligibility. The regular review cadence is monthly for the QC reports with a tentative quarterly discussion on findings to determine further assistance that can be provided through a collaboration between SNAPO and Staff Development office with policy guidance and staff training. Responding Official(s): Ginet Hayes, Benefit, Employment, and Support Services Division Supplemental Nutrition and Assistance Program Administrator

View Audit 350226

Finding 540343 (2024-001)

Significant Deficiency 2024

City of San Diego

CA

Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact t...

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact that the FSRS.gov system has since been retired and integrated into the SAM.gov system acknowledges the need for reducing duplicate recording in favor of an integrated system. Staff’s understanding of the process was in line with available guidance currently still posted on HUD’s website (https://www.hud.gov/sites/dfiles/CPD/documents/CPD_FSRS_Learning_Session_Final_8.26.21.pdf). The City of San Diego did not receive notification of the FSRS deadline from HUD for Fiscal Year (FY) 2024. With regard to the dates entered in the FSRS.gov system, the agreements’ effective dates cover the entire fiscal year, and the awards were approved by our City Council to be in effect for the full fiscal year. Hence, staff entered the date July 1, 2023. Management accepts that going forward, dates should be entered based on the date the agreements are fully executed. Management agrees to include specific FFATA training and procedures in all CDBG manuals and checklists including procedures for compliance, if and when federal agency communication is late or lacking. Implementation Date: The conditions described above have already been corrected. FFATA training and procedures will be implemented within 30 days. Contact: Michele Marano Assistant Deputy Director, Community Development Economic Development Department City of San Diego Email: mmarano@sandiego.gov Phone: 619.236.6381

View Audit 350217

Finding 540332 (2024-002)

Significant Deficiency 2024

People Incorporated of Virginia and Affiliates

VA

Reporting HUD Housing Programs Significant Deficiency

Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Res...

Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Response PINC management acknowledges that some funds were inadvertently excluded from the Schedule of Expenditures of Federal Awards due to a combination of a recent CFO leadership transition and an outdated accounting system. However, these issues were not a result of fraud or misuse of funds, and the discrepancies were quickly addressed without any negative impact on the financial statements or audit timeline. The company is actively working to implement a new accounting system with an improved grants module to prevent similar issues in the future. These proactive steps reflect our commitment to compliance, financial accuracy, and continuous improvement in reporting processes. Contact Person Responsible for Corrective Action: Joshua Pevarnik, VP & CFO Anticipated Completion Date: Ongoing and by 6/30/2025

View Audit 350213

Finding 540331 (2024-001)

None 2024

Hughes Neighborhood Housing, Inc.c/o L.hayes & Associates

MD

Questioned Costs Cash Management HUD Housing Programs

A. Comments on Finding and Recommendations Comments: It is important to note that at no time did L. Hayes & Associates, Inc. (LHA), Managing Agent, use project funds for unrelated costs. This finding No. 2024-001 refers specifically to fraudulent check charges that were posted to the Hughes operatin...

A. Comments on Finding and Recommendations Comments: It is important to note that at no time did L. Hayes & Associates, Inc. (LHA), Managing Agent, use project funds for unrelated costs. This finding No. 2024-001 refers specifically to fraudulent check charges that were posted to the Hughes operating account in March 2024 by an unknown person. There was a total of three (3) checks written by the same person. This person is unknown to us and did not have access to our check stock nor our office. Therefore, it appears that the perpetrator used some type of machine to reproduce copies of our checks and the signature of Ms. Voundy-Thomas, Operations Manager. Recommendations: Based on the recommendation of our auditor, our office contacted the Maryland Banking Commission to report and pursue reimbursement of the fraudulent charges deducted from the Hughes Neighborhood Housing operating bank account and they referred us to contact the Office of the Comptroller of Currency. Our auditor also suggested that we discuss potential solutions with our HUD Account Executive. B. Actions Taken or Planned Actions Taken: Upon reconciliation of the Project’s March 2024 bank accounts and the discovery of the fraudulent charges, Ms. Voundy, Thomas immediately contacted Wells Fargo’s Fraud Claims Department to report our findings, request reimbursement of the charges, and to place an alert of the account. In addition, Ms. Voundy-Thomas and Mr. Merrick, Hughes, BOD President, visited a Wells Fargo branch to discuss this matter directly with an Account Representative. Unfortunately, the bank denied our request for reimbursement of the fraudulent charges stating that our claim was not processed within 30-days of the posted charges. Actions Planned: Per the guidance from the Maryland Banking Commission, our office has contacted the Office of the Comptroller of Currency to further pursue reimbursement of the fraudulent charges. Also, upon completion and submission of the above-mentioned audit, we plan to pursue any further actions recommended by our HUD Account Executive regarding this finding. Status of Corrective Action on Prior Findings No prior findings were noted.

View Audit 350209 Questioned Costs: $1

Finding 539713 (2024-011)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency § 200.1 § 200.302 § 200.307

Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of ...

Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of the program. UMMC will make efforts to ensure that all practices and policies are clearly documented and evaluated periodically. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539634 (2024-003)

None 2024

Argus Manor Association

WA

HUD Housing Programs Reporting

S3800-010: Finding Reference Number 2024-003 S3800-030: Statement of Condition: Management did not make all of the required deposits to the replacement reserve at June 30, 2024. The mortgage company billed $2,398 per month with the monthly mortgage statement which was the required deposit that we...

S3800-010: Finding Reference Number 2024-003 S3800-030: Statement of Condition: Management did not make all of the required deposits to the replacement reserve at June 30, 2024. The mortgage company billed $2,398 per month with the monthly mortgage statement which was the required deposit that went into effect on December 1, 2019. That deposit was increased by HUD each year thereafter effective each December 1; however, management believes that they were not notified of the increases in deposit requirements, and maintain that they did not receive copies of the revised HUD 9250 forms establishing the effective dates and amounts of deposit requirements changes for the years ended December 31, 2020 through December 31, 2022. The total amount of the replacement reserve deposit shortage was calculated to be $13,302. S3800-080: Auditor Recommendation: Management should review policies and procedures to ensure all required deposits to the reserve account are properly billed and deposited into the escrow account with the lender. Management should also deposit the shortage of $13,302 in the replacement reserve escrow account held by the lender. S3800-045: Actions Taken or to be Taken: Management will follow up with the lender about the new deposit requirement and deposit the funding shortage of $13,302 in the replacement reserve escrow account held by the lender. They will also request all missing copies of the HUD 9250 forms for the effective dates of December 1, 2020 through December 1, 2022.

View Audit 350177

Finding 539632 (2024-002)

None 2024

Argus Manor Association

WA

HUD Housing Programs Subrecipient Monitoring Reporting

S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in...

S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in these months, resulting in a deficiency in the account. Although the funding deficit amounts were not always significant, it is important that the security deposit cash account be fully funded at all times. S3800-080: Auditor Recommendation: We recommend that property management implement a more robust process for monitoring and reconciling the security deposit cash account on a monthly basis. This process should ensure that the account balance is consistently maintained at the required level. Furthermore, management should conduct periodic reviews of the security deposit balances to identify and address any discrepancies promptly. Training for staff involved in managing security deposits should be considered to ensure compliance with HUD regulations and internal policies. FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT (Continued) S3800-010: Finding Reference Number 2024-002 (Continued) S3800-045: Actions Taken or to be Taken: It is management’s policy to fully fund the security deposit account so the balance in cash meets or exceeds the total liability of deposits collected from tenants. Management discussed the importance of reviewing funding monthly with the Project Accountant, and new procedures have been implemented to include a monthly process to compare the security deposit liability to the bank account and fund any shortages to ensure the security deposit bank account is consistently maintained at the required level.

View Audit 350177

Finding 539631 (2024-001)

Material Weakness 2024

Argus Manor Association

WA

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

S3800-010: Finding Reference Number 2024-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an indep...

S3800-010: Finding Reference Number 2024-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an independent contractor prior to finalization of new tenant move-in. However, during our testing, we noted five (5) move-in files out of five (5) move-in files tested where tenants were approved for move-in prior to review and approval by the independent contractor, circumventing the control. S3800-080: Auditor Recommendation: We recommend that the client immediately implement corrective actions to ensure compliance with internal control procedures. Specifically: 1. The compliance specialist should be required to wait for proper approval of tenant eligibility files before processing them. 2. Review and reinforce the approval process through additional training for staff to ensure they understand the critical importance of obtaining necessary approvals before proceeding. 3. Implement stronger oversight and monitoring mechanisms to ensure that files are not processed before approval. S3800-045: Actions Taken or to be Taken: Management has reviewed the policies and procedures with the property manager, who also serves as the compliance specialist. The property manager was instructed that no tenants are to be granted occupancy until the file has been approved by the independent contractor conducting the compliance review.

View Audit 350177

Finding 539628 (2024-001)

Significant Deficiency 2024

Friendship I Co.

ID

HUD Housing Programs Cash Management

MANAGEMENT’S OR DEPARTMENT’S RESPONSE: WE CONCUR. VIEWS OF RESPONSIBLE OFFICIALS AND CORRECTION ACTION: AMOUNT HAS BEEN DEPOSITED. ADDITIONALLY, ALL RESTRICTED ACCOUNTS WILL BE REVIEWED ANNUALLY TO ENSURE TRANSFERS ARE MADE.

View Audit 350169

Finding 539624 (2024-003)

None 2024

City of Seaside

CA

HUD Housing Programs

The City is in agreement with the audit finding and it will make sure to attach the Indirect Cost Rate(s) Schedule as described in the “Special Conditions” of the contracts that are returned to HUD. The City already took action on this submission and the Indirect Cost Rate Schedule was attached as a...

The City is in agreement with the audit finding and it will make sure to attach the Indirect Cost Rate(s) Schedule as described in the “Special Conditions” of the contracts that are returned to HUD. The City already took action on this submission and the Indirect Cost Rate Schedule was attached as an “Addendum” to the contract B-24-MC-06-0006 executed with HUD for FY 24-25.

View Audit 350160

Finding 539623 (2024-002)

None 2024

City of Seaside

CA

Reporting HUD Housing Programs

The City is in agreement with the audit finding. As of the date of the Single Audit Report, the City is caught up on its Financial Reports submission in IDIS-CPD Grant Portal. The City still needs to update its CDBG policies and procedures to specify required CDBG reporting requirements and obligati...

The City is in agreement with the audit finding. As of the date of the Single Audit Report, the City is caught up on its Financial Reports submission in IDIS-CPD Grant Portal. The City still needs to update its CDBG policies and procedures to specify required CDBG reporting requirements and obligations, per reporting compliance required under 24 CFR Section 570.507(d) - Other reports and 2 CFR 200.302(b)(2) – Financial management.

View Audit 350160

Finding 539578 (2024-002)

Significant Deficiency 2024

Housing Authority of the City of Annapolis

MD

Special Tests & Provisions HUD Housing Programs Significant Deficiency

Corrective Action Plan: The Authority concurs with the finding. The following corrective actions are being implemented:  Reinstating and enhancing the inspection tracking log to monitor timely completion of all required inspections;  Utilizing property management software to schedule and track ins...

Corrective Action Plan: The Authority concurs with the finding. The following corrective actions are being implemented:  Reinstating and enhancing the inspection tracking log to monitor timely completion of all required inspections;  Utilizing property management software to schedule and track inspections;  Assigning oversight responsibility for inspections to the Property Manager and Safety Inspection Supervisor;  Conducting quarterly management reviews of inspection compliance;  Hired additional inspection sta􀀳, including Maintenance Operations Supervisor to complete any backlog and ensure ongoing compliance.  Requested funding from City, State, and County to assist in inspections compliance to address federal funding and revenue shortages due to rental income delinquency. Anticipated Completion Date: June 30, 2025 Responsible Party: Senior Manager of Housing Operations/Maintenance Manager

View Audit 350123

Finding 539577 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Annapolis

MD

Eligibility HUD Housing Programs Significant Deficiency

Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include:  Updating internal policies and procedures related to tenant file documentation and income verification requirements;  Providing targeted sta􀀳 training on proper...

Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include:  Updating internal policies and procedures related to tenant file documentation and income verification requirements;  Providing targeted sta􀀳 training on proper file documentation and third-party income verification procedures;  Implementing a mandatory checklist to ensure all required documentation is obtained and verified before finalizing recertifications;  Establishing a quality control process where supervisory sta􀀳 conduct periodic file reviews to ensure compliance;  Maintaining an audit trail of verification documentation to ensure proper retention.  Hired third-party service provider, Quadel to assist with tenant file documentation compliance, annual and interim recertifications and rent calculations.  Hiring Senior Housing Manager to assist with monitoring verification documentation, income calculation, citizenship and/or legal residency documentation, and signed release documentation compliance. Anticipated Completion Date: June 30, 2025 Responsible Party: Senior Manager of Housing Operations and PH Property Managers

View Audit 350123

Finding 539544 (2024-004)

None 2024

The Housing Authority of the City of Opelika

AL

Questioned Costs HUD Housing Programs Procurement, Suspension & Debarment

Finding 2024-004 - HUD Comprehensive Review, Section 8 Housing Choice Voucher Program – CFDA No. 14.871; Grant period – year ended June 30, 2024 Corrective Action: The Authority submitted corrective actions to HUD dated August 17, 2023, which included implementing HUD’s recommended corrective action...

Finding 2024-004 - HUD Comprehensive Review, Section 8 Housing Choice Voucher Program – CFDA No. 14.871; Grant period – year ended June 30, 2024 Corrective Action: The Authority submitted corrective actions to HUD dated August 17, 2023, which included implementing HUD’s recommended corrective actions. Responsible Party: Matthew McClammey, Executive Director, (334)745-4171. Anticipated Completion Date: June 30, 2025.

View Audit 350086 Questioned Costs: $1

Finding 539543 (2024-003)

None 2024

The Housing Authority of the City of Opelika

AL

HUD Housing Programs Internal Control / Segregation of Duties

Finding 2024 - 003 - Housing Choice Vouchers Tenant Files Housing Choice Vouchers - CFDA No. 14.871; Grant period - year ended June 30, 2024 Corrective Action: The Authority will work on strengthening its internal controls to correct this situation and ensure that they will be in compliance with the...

Finding 2024 - 003 - Housing Choice Vouchers Tenant Files Housing Choice Vouchers - CFDA No. 14.871; Grant period - year ended June 30, 2024 Corrective Action: The Authority will work on strengthening its internal controls to correct this situation and ensure that they will be in compliance with the federal guidelines and the Authority’s policies. Responsible Party: Matthew McClammey, Executive Director, (334)745-4171. Anticipated Completion Date: June 30, 2025.

View Audit 350086

Corrective Action Plans

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