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JO DAVIESS RESIDENTIAL SERVICES, INC. 521 S. WEST STREET GALENA, IL 61036 CORRECTIVE ACTION PLAN June 26, 2025 U. S. Department of Housing and Urban Development Ralph Metcalfe Federal Building 77 West Jackson Boulevard Chicago, IL 60604-3507 Jo Daviess Residential Ser...
JO DAVIESS RESIDENTIAL SERVICES, INC. 521 S. WEST STREET GALENA, IL 61036 CORRECTIVE ACTION PLAN June 26, 2025 U. S. Department of Housing and Urban Development Ralph Metcalfe Federal Building 77 West Jackson Boulevard Chicago, IL 60604-3507 Jo Daviess Residential Services, Inc. respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 Period: Year ended June 30, 2024 The findings from the June 30, 2024 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2024-001: Supportive Housing for the Persons with Disabilities (Section 811), CFDA #14.181 Recommendation: We recommend management and the board of directors ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. Management's Response: We agree with Finding 2024-001 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will provide additional oversight to ensure the data collection forms are submitted electronically to the FAC each fiscal year going forward within required due dates. If HUD has questions regarding this corrective action plan, please call (815) 288-6691. Sincerely yours, Jeff Stauter Director Kreider Services, Inc. Managing Agent
Finding 2024-002: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the inte...
Finding 2024-002: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board had reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.
Finding: Under the Uniform Guidance, Section 200.512 Report Submission, the audit must be completed, and the data collection form and single audit package must be submitted to the Federal Audit Clearinghouse (FAC) with the earlier of 30 calendar days after receipt of the auditor's report, or nine mo...
Finding: Under the Uniform Guidance, Section 200.512 Report Submission, the audit must be completed, and the data collection form and single audit package must be submitted to the Federal Audit Clearinghouse (FAC) with the earlier of 30 calendar days after receipt of the auditor's report, or nine months after year end of the audit period. This deadline would have been March 31, 2025, for the Organization's Single Audit reporting for the year ended June 30, 2024. Corrective Action Taken or Planned: Management has reviewed the recommendations and will develop a schedule with auto reminders to ensure that these reporting requirements are completed on a timely basis. The corrective action will be implemented no later than June 30, 2025. The primary designated official is the Chief Financial Officer.
Management agrees with the finding. The financial statements were submitted to HUD on May 9, 2025.
Management agrees with the finding. The financial statements were submitted to HUD on May 9, 2025.
Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action:KMHA's Board has approved new written Tenant policies and procedures, to include a new ACOP (CFR 960), and are in place now.Appropriate staff have begun taking proper safeguards to ensure a waiting list is in place...
Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action:KMHA's Board has approved new written Tenant policies and procedures, to include a new ACOP (CFR 960), and are in place now.Appropriate staff have begun taking proper safeguards to ensure a waiting list is in place and utilized, each tenant application is filed and proper action taken and tenant files are properly maintained and complete. A checklist is placed inside each tenant file to assist in completeness.Proposed Completion Date: Immediately
Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This in...
Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This includes the oversight of processing payments of CFP expenditures, which includes the following procedures for: 1) payment of invoices; 2) requisition of funds; 3) monitoring; and 4) reporting of CFP funds.payment of InvoicesAll CFP invoices will be reviewed and clearly marked as approved and documented to show that the source of funds for payment are CFP grant funds by the Executive Director prior to payment. The Executive Director will specify the general ledger code, including the BLI account to be used for payment processing on the invoice before providing the invoice to the accounts payable clerk.Under no circumstances will a payment be made if KMHA has not drawdown and received the respective CFP funds.With the exception of funds associated with BLI 1406 “Operations”, PHAs have three (3) business days to issue and mail the check once the CFP funds are received.The Executive Director/accounts payable clerk will specify the BLI account and CFP grant year on the check voucher prior to sending the check voucher to the fee accountant for financial statement processing.Requisition of FundsFor each drawdown, the Executive Director will print the associated eLOCCS Voucher Payment form from the eLOCCS system.The Executive Director will document the check number(s) and vendor(s) associated with each CFP draw (i.e., the eLOCCS Voucher Payment form). In addition, each individual draw shall be numbered for reference purposes.A copy of each draw shall be submitted to the fee accountant to ensure proper reporting of the grant drawdown.With the exception of funds associated with BLI 1406 “Operations”, in no case shall a draw be made without the proper approved invoices.MonitoringThe fee accountant's monthly financial statements will include a CFP report for each grant which will be reviewed by the Executive Director for proper coding and accuracy.Folder has been created to track all required information in the management of a CFP grant to include correspondence to and from HUD, expenses, grant reimbursements, budgets, closeout documentation and EPIC management.Proposed Completion Date: Immediately
Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: A budget for FYE 9/30/25 was approved by the Board in their October 2024 meeting.Proposed Completion Date: Immediately
Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: A budget for FYE 9/30/25 was approved by the Board in their October 2024 meeting.Proposed Completion Date: Immediately
The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Contract (ACC), the program receives over $90M from the United States Department of Housing and Urban Development (HU...
The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Contract (ACC), the program receives over $90M from the United States Department of Housing and Urban Development (HUD) and assist over 7,700 families each year. The ACC requires JHA to comply with federal regulations and HUD guidelines, as amended from time to time. Audit Findings Berman Hopkins Wright & LaHam, CPAs and Associates, LLP conducted the recent FY2024 JHA Audit (Period: October 1, 2023 – September 30, 2024) and identified continued material weakness findings within the JHA Housing Choice Voucher (HCV) program including but not limited to: Material Weaknesses in Internal Controls, Material Weaknesses in Non-Compliance and Material Weaknesses in the Housing Quality Standards (HQS) Inspection process. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP previously conducted JHA’s FY2023 audit (Period: October 1, 2022 – September 30, 2023) and FY2022 audit (Period: October 1, 2021 – September 30, 2022) which disclosed consecutive historical material weaknesses in JHAs internal controls and noncompliance of the Housing Choice Voucher (HCV) program. Under new CEO leadership at JHA, a request to the JHA Board of Commissioners is in place for a vote on Friday, June 27, 2025, to authorize the following action of Nan McKay & Associates to Administer, Manage and Operate the JHA Housing Choice Voucher Program for an effective date of Monday July 7, 2025. Pending Resolution: AUTHORIZE THE AWARD OF THE MIAMI-DADE HOUSING & COMMUNITY DEVELOPMENT PIGGYBACK CONTRACT IN THE NOT-TO-EXCEED AMOUNT OF 72% OF THE ADMINISTRATIVE FEES CONCURRENT WITH THE EXISTING CONTRACT TERMS TO NAM MCKAY AND ASSOCIATES, FOR HOUSING CHOICE VOUCHER MANAGEMENT AND OPERATIONS. As evidenced by the increase in overall HCV audit findings, loss of federal revenues, inability to correctly serve existing and future HCV program participants, noncompliance on both a local and federal level for section 8 program funding for the administration and operations of the HCV program, immediate action is requested to authorize Nan McKay & Associates to administer and operate JHA’s HCV program immediately. Combined with a plethora of likely compliance issues and deteriorated financial condition, these concerns pose a significant threat to both the immediate and long-term success of Jacksonville’s HCV program. Responsible: Nan McKay & Associates POINT OF CONTACT: Steven Rosario, Sr. Director EMAIL: srosario@nanmckay.com JHA POC: Roslyn Phillips, Interim COO EMAIL: RPHILLIPS@JAXHA.ORG
The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Development (HUD) and assist over 7,700 families each year. The ACC requires JHA to comply with federal regulations a...
The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Development (HUD) and assist over 7,700 families each year. The ACC requires JHA to comply with federal regulations and HUD guidelines, as amended from time to time. Audit Findings Berman Hopkins Wright & LaHam, CPAs and Associates, LLP conducted the recent FY2024 JHA Audit (Period: October 1, 2023 – September 30, 2024) and identified continued material weakness findings within the JHA Housing Choice Voucher (HCV) program including but not limited to: Material Weaknesses in Internal Controls, Material Weaknesses in Non-Compliance and Material Weaknesses in the Housing Quality Standards (HQS) Inspection process. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP previously conducted JHA’s FY2023 audit (Period: October 1, 2022 – September 30, 2023) and FY2022 audit (Period: October 1, 2021 – September 30, 2022) which disclosed consecutive historical material weaknesses in JHAs internal controls and noncompliance of the Housing Choice Voucher (HCV) program. Under new CEO leadership at JHA, a request to the JHA Board of Commissioners is in place for a vote on Friday, June 27, 2025, to authorize the following action of Nan McKay & Associates to Administer, Manage and Operate the JHA Housing Choice Voucher Program for an effective date of Monday July 7, 2025. Pending Resolution: AUTHORIZE THE AWARD OF THE MIAMI-DADE HOUSING & COMMUNITY DEVELOPMENT PIGGYBACK CONTRACT IN THE NOT-TO-EXCEED AMOUNT OF 72% OF THE ADMINISTRATIVE FEES CONCURRENT WITH THE EXISTING CONTRACT TERMS TO NAM MCKAY AND ASSOCIATES, FOR HOUSING CHOICE VOUCHER MANAGEMENT AND OPERATIONS. As evidenced by the increase in overall HCV audit findings, loss of federal revenues, inability to correctly serve existing and future HCV program participants, noncompliance on both a local and federal level for section 8 program funding for the administration and operations of the HCV program, immediate action is requested to authorize Nan McKay & Associates to administer and operate JHA’s HCV program. Combined with a plethora of likely compliance issues and deteriorated financial condition, these concerns pose a significant threat to both the immediate and long-term success of Jacksonville’s HCV program.
Berman Hopkins Wright & LaHam, CPAs and Associates, LLP recently identified in the FY2024 JHA Audit (Period: October 1, 2023 – September 30, 2024) material weakness findings and noncompliance findings for the JHA Public Housing Program. Please note that the JHA’s Public Housing Program was not teste...
Berman Hopkins Wright & LaHam, CPAs and Associates, LLP recently identified in the FY2024 JHA Audit (Period: October 1, 2023 – September 30, 2024) material weakness findings and noncompliance findings for the JHA Public Housing Program. Please note that the JHA’s Public Housing Program was not tested by the auditors in previous years. Note: JHA will have a finding in FY2025 due to existing months of the public housing program operations that have already commenced for the periods: October 1, 2024 – June 27, 2025. The audit period will end for FY2025 September 30, 2025. JHA will quickly evaluate each PH employee, train, hire skilled employees and streamline organizational inefficiencies, while implementing new internal process controls to address the findings identified in the FY2024 audit report for the Public Housing program. An evaluation of the current employee role structure and staff qualifications will commence July 2025. The entire public housing department will be assessed to ensure that JHA is efficient, productive, utilizes the technology system of record Yardi V7 to adhere to compliance, and works in a collaborative matter to better serve all existing a potential future client of the agency. The Public Housing organizational re-org will be implemented no later than September 1, 2025. Responsible: Jacksonville Housing Authority JHA POC: William Mitchell (a.k.a.Daniel/Danny), Deputy Chief EMAIL: dmitchell@jaxha.org JHA POC: Roslyn Phillips, Interim COO EMAIL: RPHILLIPS@JAXHA.ORG
The City has discussed the finding but must consider the cost of adequate segregation of duties when determining the use of taxpayer resources.
The City has discussed the finding but must consider the cost of adequate segregation of duties when determining the use of taxpayer resources.
2024-005 – ALN 14.871 – Housing Voucher Cluster – Special Tests – HQS Enforcement Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executiv...
2024-005 – ALN 14.871 – Housing Voucher Cluster – Special Tests – HQS Enforcement Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Completion Date: September 30, 2025
2024-004 – ALN 14.871 – Housing Voucher Cluster – Reporting Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Co...
2024-004 – ALN 14.871 – Housing Voucher Cluster – Reporting Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Completion Date: September 30, 2025
2024-003 – ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected ...
2024-003 – ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Completion Date: September 30, 2025
2024-002 – ALN 14.871 – Housing Voucher Cluster – Allowable Activities Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer P...
2024-002 – ALN 14.871 – Housing Voucher Cluster – Allowable Activities Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Completion Date: September 30, 2025
Program: Section 8 Housing Choice Voucher Finding: 2024-007 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Implementation of New Software Sy...
Program: Section 8 Housing Choice Voucher Finding: 2024-007 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Implementation of New Software System: o HACLB has transitioned to the new MRI housing management software platform, which offers fully sufficient functionality and reporting capabilities compared to the prior system. o The new MRI system provides the Inspections Team with advanced tools to organize, schedule, and track Quality Control inspections efficiently and accurately. 2. Improved Reporting and Compliance: o The MRI system’s reporting functions allow HACLB to generate detailed and timely listings of all Housing Quality Control inspections. o This improvement supports HACLB’s ability to meet HUD requirements for inspection scheduling, documentation, and follow-up activities. Expected Completion Date: December 31, 2025
Program: Section 8 Housing Choice Voucher Finding: 2024-006 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Automated Data Validation and Err...
Program: Section 8 Housing Choice Voucher Finding: 2024-006 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Automated Data Validation and Error Detection: o HACLB utilizes the MRI housing management software, which syncs to the HUD’s PIC (Public and Indian Housing Information Center)requirements, ensuring data consistency and validation. o The MRI system incorporates HUD’s mandated validation standards and automatically identifies errors in participant data before submission to the PIC system. o Validation errors flagged by MRI are reviewed and corrected prior to submission to HUD, ensuring data accuracy and compliance. 2. Compliance with HUD Standards and Reporting: o Each recertification is submitted to the HUD PIC system, which further validates the data and alerts HACLB to any errors through the PIC Error Dashboard. o HACLB promptly addresses and corrects errors identified by PIC to maintain program integrity and compliance with HUD reporting standards. 3. Quality Control and Training: o HACLB conducts annual SEMAP (Section Eight Management Assessment Program) evaluations, which include quality control indicators to assess the accuracy of calculations and program administration. o Errors identified through SEMAP and system validations are used proactively as training opportunities for staff. o New Housing Specialists’ work is closely reviewed during their training period to ensure accuracy and compliance. 4. Systematic Tracking and Monitoring: o The MRI system facilitates ongoing quality control tracking, enabling Housing staff to monitor and correct errors effectively. o HACLB’s process includes regular oversight and review of participant files and related transactions to ensure timely and accurate housing assistance payments and reporting. Expected Completion Date: December 31, 2025
Program: Section 8 Housing Choice Voucher Finding: 2024-005 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Process Improvement for Reinspect...
Program: Section 8 Housing Choice Voucher Finding: 2024-005 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Process Improvement for Reinspection Scheduling: o Beginning December 2024, HACLB implemented an enhanced scheduling process to ensure all reinspections are conducted prior to the expiration of the required 30-day remediation period. o The agency has configured its housing software platform (MRI) to automatically schedule reinspections in advance of the 30-day deadline following the identification of deficiencies. This automated process minimizes the risk of delay or oversight. 2. Extension Tracking and Compliance Monitoring: o The MRI system is also configured to flag cases where an extension has been requested or approved, allowing for documented exceptions while maintaining compliance oversight. o Staff monitor reinspection dates regularly through system-generated reports to ensure adherence to HUD standards and to follow up on any outstanding cases. Expected Completion Date: December 31. 2025
Program: Section 8 Housing Choice Voucher Finding: 2024-003 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Staff Augmentation and Training: ...
Program: Section 8 Housing Choice Voucher Finding: 2024-003 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Staff Augmentation and Training: o In January 2025, HACLB submitted requisitions to the Human Resources Department to recruit additional Housing Specialists to improve the management of high volume HCV program participants, documentations, processes, and to meet various requirement deadlines. o As of May 3, 2025, four new Housing Specialists have been hired and are currently undergoing training. Four additional Housing Specialists are in the onboarding process with Human Resources Department. o Several supervisory positions remain unfilled due to the need to renew the hiring list. HACLB has submitted a request to initiate the renewal process in order to recruit from a new list. o In addition, HACLB has hired a Housing Administrative and Financial Services Officer and a Housing Operations Program Officer. These roles are critical in providing oversight of operational workflows, evaluating staff productivity, and developing strategies to optimize staffing levels and resource allocation. 2. Contracted Support Services: o To address a backlog of overdue reexaminations, HACLB renewed its contract with an external agency to provide dedicated assistance in processing pending cases. This contract became effective in May 2025 and has already begun to support the reexamination workload. 3. Technology Upgrade: o HACLB has transitioned to a new housing software platform tailored to improve the tracking and processing of annual recertifications. This system upgrade enhances productivity monitoring, facilitates efficient workflow management, and supports compliance with HUD timeliness standards. Expected Completion Date: September 30, 2026
Program: HOME Investment Partnerships Program (HOME) Finding: 2024-002 Contact Person: April Apodaca Administrative & Financial Services Bureau Manager Community Development Department Phone: (562) 570-6611 Email: April.Apodaca@longbeach.gov Planned Actions: The City has increased the number of p...
Program: HOME Investment Partnerships Program (HOME) Finding: 2024-002 Contact Person: April Apodaca Administrative & Financial Services Bureau Manager Community Development Department Phone: (562) 570-6611 Email: April.Apodaca@longbeach.gov Planned Actions: The City has increased the number of properties inspected each fiscal year. For example, during the FY23 audit period, 204 inspections occurred. In the FY24 period, the number of inspections increased to 227. As of May 2025, the City has inspected 187 units and anticipates a total of 250 inspections will be completed by the end of FY25, thereby eliminating the current backlog and any late inspections. The Community Development Department implemented more proactive measures, including hiring an in-house inspector and an active master inspection log to track and target upcoming inspections. These efforts have resulted in a more streamlined, data-informed approach to HQS compliance, as evidenced by a significant reduction in the inspection backlog. The master inspection log is also being leveraged to optimize inspection scheduling and ensure that the required HOME units per property are inspected as required. To reinforce this approach, the City instituted a structured, monthly review of the log to improve data accuracy, completeness, and early identification of potential delays. The City is confident that these measures will demonstrate compliance with the HQS standards and resolve the auditor’s concerns. Expected Completion Date: 12/31/2025
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-007: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 - Sig...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-007: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 - Significant Deficiency RECOMMENDATION The auditor recommends the Project and management review and attend training on the HUD Handbook. In addition, the auditor recommends the Project and management review its internal control policies and procedures. ACTION TAKEN Carrasquillo Management LLC acknowledges the significant deficiency noted and is committed to improving internal controls to ensure full compliance with all HUD program requirements. 1. Policy and Procedure Review Management has initiated a comprehensive review of internal control policies and procedures to identify gaps and align practices with the HUD Handbook 4350.3 and related program regulations. Updates will be made to strengthen compliance checkpoints and clearly define staff responsibilities for each stage of tenant file processing, income verification, certifications, and documentation retention. 2. Training and Capacity Building Carrasquillo Management LLC has committed to ongoing staff development by enrolling relevant personnel in HUD-compliant training programs focused on regulatory requirements, internal controls, and compliance best practices. All staff involved in leasing, recertifications, and program compliance will be required to complete refresher trainings at least annually. 3. Internal Audit and Quality Control A quarterly internal audit process has been established to monitor the effectiveness of internal controls and ensure consistent application across all major program functions. Findings from these audits will be reviewed by senior management, and corrective actions will be taken immediately when deficiencies are identified. 4. Oversight and Accountability Management will assign a dedicated compliance coordinator responsible for overseeing adherence to HUD regulations and internal policies, providing regular updates to leadership, and ensuring follow-through on all audit-related corrective actions. Carrasquillo Management LLC is committed to fostering a culture of compliance and accountability and will take all necessary steps to prevent future deficiencies and ensure the Project remains in good standing with HUD program requirements.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-006: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-006: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends the Project and management review and attend training on the HUD Handbook 4350.3 Revision 1 requirements for tenant files including eligibility and income calculations. In addition, the auditor recommends the Project obtain necessary recertification signatures timely. ACTION TAKEN Carrasquillo Management LLC acknowledges the findings and is taking the following corrective actions to ensure compliance with HUD Handbook 4350.3 requirements: 1. Enterprise Income Verification (EIV) Reports Management has implemented an internal checklist to ensure that the initial EIV reports are generated within the required 90 days for all move-ins. Staff has been retrained on EIV protocols and timelines to ensure timely compliance going forward. 2. Timely Tenant Signatures on Recertifications A new recertification specialist has been hired, who is fully trained and qualified in HUD income certifications. Carrasquillo Management LLC has implemented a new tracking system and notification schedule to ensure that all recertification documents are signed by tenants on or before the effective date. Management is also increasing tenant engagement through reminder letters and calls. 3. Bank Account Balance Calculations Staff has received additional training on income and asset calculations per HUD guidance. A verification template has been implemented to ensure all checking account balances are calculated using the six-month average, as required. 4. Security Deposit Charges The error identified regarding the incorrect security deposit has been corrected. Going forward, all move-ins will include a verification step to ensure that the correct deposit is charged in accordance with lease and program guidelines. 5. Date and Time-Stamped Applications Management has implemented a new policy requiring staff to date-and time-stamp all tenant applications upon receipt. Staff has been trained accordingly and periodic file reviews will be conducted to ensure compliance. 6. Missing Lease and Application Documents Management has begun a full file audit to identify and correct any remaining deficiencies. Procedures have been updated to ensure original leases and completed applications are filed immediately upon move-in and scanned into the electronic system as a backup. 7. Move -Inspections A revised move-in protocol has been established that includes a checklist confirming inspection completion and file documentation. A copy of the move-in inspection form is now required to be signed by both tenant and management and scanned into the file on the same day of move-in. 8. Training and Oversight Carrasquillo Management LLC will continue to provide regular staff training and compliance reviews to ensure that all HUD file requirements are met. In addition, quarterly internal audits will be conducted to verify proper documentation and adherence to timelines. We are committed to maintaining full compliance with HUD regulations and ensuring tenant file accuracy moving forward.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-005: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-005: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends ensuring all tenant’s paperwork is thoroughly reviewed and accurately used in the calculation of the tenant’s required monthly rent and HUD’s tenant assistance payments. ACTION TAKEN Carrasquillo Management LLC acknowledges the audit finding related to rent miscalculations for five tenant files during the fiscal year ended September 30, 2024. These errors resulted in both minor tenant overcharges and undercharges, as well as corresponding discrepancies in HUD’s rental assistance payments. 1. Financial Corrections ○ The Project will reimburse the two affected tenants a total of $14 to correct the overcharges. ○ The Project will submit a request to HUD to repay the $14 in overpaid rental assistance associated with these tenants. ○ For the three tenants who were undercharged a total of $826, the Project will bill the tenants for the rent differential in accordance with HUD regulations and provide HUD with reimbursement of the $826 in excess rental assistance paid. 2. File Review and Quality Control Measures Management has implemented a secondary file review process for all certifications and recertifications to ensure that income is correctly verified, entered, and calculated in accordance with HUD Handbook 4350.3 requirements. All tenant income documentation will be double-checked by the compliance team prior to finalizing certifications. 3. Staff Training All staff involved in income verification and rent calculation have been retrained on HUD rent calculation guidelines, including handling of paystubs, Social Security statements, and other income documentation. Training includes real-case scenarios and common error prevention techniques. 4. Compliance Oversight Moving forward, Carrasquillo Management LLC will conduct quarterly internal audits of a random sample of tenant files to verify the accuracy of income calculations and ensure compliance with HUD regulations. Carrasquillo Management LLC remains committed to ensuring the accuracy of tenant rent determinations and maintaining compliance with HUD’s income calculation requirements. All necessary reimbursements and corrective actions will be completed promptly and documented for HUD’s records.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-004: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-004: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends the Property receive HUD approval before withdrawing funds from its residual receipts account and repay the $163,679 to the residual receipts account. ACTION TAKEN Carrasquillo Management LLC acknowledges the finding regarding the unauthorized withdrawal of $163,679 from the Project’s residual receipts account during the fiscal year ended September 30, 2024. This withdrawal was related to surplus cash from fiscal year 2023 that had been deposited into the residual receipts account. Due to miscommunication and misunderstanding during the transition between management companies, the withdrawal was made without obtaining prior written approval from HUD, as required under HUD Handbook 4370.2 Revision 1. Corrective Actions: 1. Repayment Agreement with HUD Carrasquillo Management LLC has been in direct communication with the Project’s HUD Account Executive, Nyal McDonough, of the Northeast Region Asset Management Division. HUD has agreed to allow the Project to repay the full $163,679 through monthly installments as part of an interest-free repayment plan until the balance is fully restored to the residual receipts account. This agreement is currently being implemented and tracked in coordination with HUD. 2. Internal Compliance Controls To ensure full compliance going forward, Carrasquillo Management LLC has updated internal policies and procedures to strictly prohibit any withdrawals from the residual receipts account without explicit written authorization from HUD. All future requests for residual receipts will be submitted through HUD’s formal request channels, and no funds will be accessed without prior written approval. 3. Staff Training Relevant personnel have received training on HUD Handbook 4370.2 and HUD financial controls regarding restricted accounts. Additional safeguards are in place to ensure management and accounting teams confirm HUD approval documentation before any restricted account disbursement. 4. Monthly Monitoring and Reporting Carrasquillo Management LLC will include the residual receipts repayment schedule in its monthly financial reporting to ownership and will maintain communication with HUD to ensure full transparency throughout the repayment period. Carrasquillo Management LLC is committed to full regulatory compliance and to restoring the integrity of all project accounts in collaboration with HUD.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-003: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-003: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends management review the HUD Handbook on determining eligible income included in the management fee calculation. ACTION TAKEN Carrasquillo Management LLC acknowledges the auditor’s finding regarding the overcharged management fee of $13,884 for the fiscal year ended September 30, 2024. The overcharge occurred during the management transition in March 2024. The outgoing management company, Mount Holyoke Management LLC, issued and received a management fee payment for the full month of March despite their services ending early in the month. Carrasquillo Management LLC officially took over management of the Project on March 9, 2024, and also received the management fee for services rendered during the remainder of that month. This resulted in both management companies receiving compensation for the same period, causing the annual management fee to exceed HUD’s allowable limits. Corrective Actions: 1. Fee Review and Adjustment Carrasquillo Management LLC is working with the auditor and ownership to correct the management fee overcharge in the Project’s financial records. Any necessary adjustments or reimbursements will be made to bring the project into compliance. 2. HUD Handbook Compliance Training Management has reviewed the relevant guidance in HUD Handbook 4381.5 Revision 2 and is ensuring that all future management fee calculations strictly follow HUD’s criteria for eligible income and fee limits. 3. Transition Protocols To prevent this issue from recurring during future management transitions, Carrasquillo Management LLC has developed a formal transition protocol that includes a reconciliation of income and fees and written confirmation of responsibilities to avoid any overlapping charges. 4. Oversight and Internal Controls All future management fee calculations will be reviewed and approved by the Regional Manager and Accounting Department to verify accuracy and compliance with HUD guidelines prior to disbursement. Carrasquillo Management LLC remains committed to ensuring proper financial stewardship of HUD program funds and maintaining compliance with all applicable regulations.
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