Corrective Action Plans

Finding 513121 (2024-001)

Significant Deficiency 2024

AL

HUD Housing Programs Eligibility Reporting

2024-001 ALN 14.195 – Section 8 Housing Assistance Payments Program – 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: Cole Carroll, Executive Direct...

2024-001 ALN 14.195 – Section 8 Housing Assistance Payments Program – 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: Cole Carroll, Executive Director Projected Completion Date: June 30, 2025

View Audit 331082

Finding 513086 (2024-002)

Material Weakness 2024

Housing Authority of the City of Paterson

NJ

Questioned Costs HUD Housing Programs Material Weakness

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Voucher & Emergency Housing Vouchers Assistance Listing Number: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Complia...

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Voucher & Emergency Housing Vouchers Assistance Listing Number: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: Section 8 Housing Choice Vouchers - Yes Emergency Housing Vouchers - No Material Weakness and 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 fifteen (15) out of twenty-nine (29) annual failed inspections selected for testing. Context: The Authority did not properly abate fifteen (15) out of twenty-nine (29) 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: Section 8 Housing Choice Vouchers $50,873 Emergency Housing Vouchers $1,308 Cause: There is a material weakness in Section 8 Housing Choice Vouchers and a significant deficiency in Emergency Housing Vouchers in internal controls over 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. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to HQS inspections and the Emergency Housing Vouchers Program is in non-compliance 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 assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: We agree with the Auditor’s observations on the re-inspection of the failed units. The Authority had an independent contractor whose contract was terminated due to their unacceptable performance with HQS inspections. As a result, two HQS inspectors were recently hired, and a clerical person to assist in improving the quality control component of the program as it relates to HQS inspections. In addition, the Authority recently hired a Director of Leasing and Occupancy, and a Supervisor of the department, and has implemented a more stringent oversight to ensure that internal control policies are being followed in a timely manner to show improvement in this area, and an overall improvement to the entire function of this department. We are also actively seeking to fill two vacant Tenant Interviewer/Investigator positions. The current staffing change mentioned above puts the agency in a position to implement and ensure a tracking system being able to capture areas on Annual HQS unit status, First Inspection if failed for life threatening HQS deficiencies rescheduled within 24 hours and 30 days for all other deficiencies. Abatements are placed on all units having two failed HQS inspections. All current occupied units are being reviewed for HQS inspection status, and a resolving issues to those units not in compliance with the program. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2025.

View Audit 331015 Questioned Costs: $1

Finding 513039 (2024-001)

Significant Deficiency 2024

Nba/gpva Accessible Housing II Inc.

MO

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Statement of condition 2024-001: For the year ended June 30, 2024, the Corporation did not have a HUD approved Project Owner's/Management Agent's Certification (HUD-9839-B). Recommendation: Management should continue to request the executed Project Owner's/Management Agent's Certification (HUD-9839...

Statement of condition 2024-001: For the year ended June 30, 2024, the Corporation did not have a HUD approved Project Owner's/Management Agent's Certification (HUD-9839-B). Recommendation: Management should continue to request the executed Project Owner's/Management Agent's Certification (HUD-9839-B) from HUD. Management should not pay any management fees until the executed Project Owner's/Management Agent's Certification (HUD-9839-B) is received. Action(s) taken or planned on the finding: Agree. Management received email correspondence from HUD on August 12, 2021 that stated the Agent is approved to take over management immediately and the Project Owner's/Management Agent's Certification (HUD-9839-B) would be retroactively effective. Management has continued to seek the executed Project Owner's/Management Agent's Certification (HUD-9839-B) from HUD.

View Audit 330935 Questioned Costs: $1

Finding 513038 (2024-001)

Significant Deficiency 2024

Nba/gpva Accessible Housing, Inc.

MO

Questioned Costs HUD Housing Programs Procurement, Suspension & Debarment

Statement of condition 2024-001: For the year ended June 30, 2024, the Corporation did not have a HUD approved Project Owner's/Management Agent's Certification (HUD-9839-B). Recommendation: Management should continue to request the executed Project Owner's/Management Agent's Certification (HUD-9839-...

Statement of condition 2024-001: For the year ended June 30, 2024, the Corporation did not have a HUD approved Project Owner's/Management Agent's Certification (HUD-9839-B). Recommendation: Management should continue to request the executed Project Owner's/Management Agent's Certification (HUD-9839-B) from HUD. Management should not pay any management fees until the executed Project Owner's/Management Agent's Certification (HUD-9839- B) is received. Action(s) taken or planned on the finding: Agree. Management received email correspondence from HUD on August 12, 2021 that stated the Agent is approved to take over management immediately and the Project Owner's/Management Agent's Certification (HUD-9839-B) would be retroactively effective. Management has continued to seek the executed Project Owner's/Management Agent's Certification (HUD-9839-B) from HUD.

View Audit 330933 Questioned Costs: $1

Finding 512852 (2024-001)

Significant Deficiency 2024

Collins' Way, Inc.

MD

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Department of Housing and Urban Development Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Submit the $315.75 immediately to the Replacement Reserve Account and train employees involved in the requirements of HUD in regards to timely and accurate ...

Department of Housing and Urban Development Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Submit the $315.75 immediately to the Replacement Reserve Account and train employees involved in the requirements of HUD in regards to timely and accurate Replacement Reserve contributions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The amount of $315.75 was submitted to the Replacement Reserve via a transfer on September 26, 2024. Training to review the Replacement Reserve funding requirements will be completed. Name(s) of the contact person(s) responsible for corrective action: Thomas Evans, Chief Financial Officer. Planned completion date for corrective action plan: October 31, 2024 If the Department of Housing and Urban Development has questions regarding this plan, please call Thomas Evans at 301-663-8811 X1120.

View Audit 330617

Finding 512715 (2024-001)

Significant Deficiency 2024

Ide Center Apartments Ii, Inc. 042-Hd045

OH

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unauthorized Withdrawal from Replacement Reserve Account Recommendation: Conduct training with all those who are involved with the Project to review HUD requirements for making withdrawals from the Replacement Reserve a...

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unauthorized Withdrawal from Replacement Reserve Account Recommendation: Conduct training with all those who are involved with the Project to review HUD requirements for making withdrawals from the Replacement Reserve and create a documentation process for requests and approvals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: o conduct training to review all HUD requirements regarding the process for withdrawing funds from the Replacement Reserve Account. Name(s) of the contact person(s) responsible for corrective action: Stacy Lawson, Chief Financial Officer, Jacob Schimming, Project Accountant. Planned completion date for corrective action plan: October 31, 2024

View Audit 330580

Finding 512689 (2024-001)

Significant Deficiency 2024

Janus Youth Programs, Inc.

OR

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Contact person(s) responsible: Tiffany Tucker, Fiscal Director Corrective Action Planned: All Janus’ Rental Assistance Programming will be consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obta...

Contact person(s) responsible: Tiffany Tucker, Fiscal Director Corrective Action Planned: All Janus’ Rental Assistance Programming will be consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obtaining required documentation have been updated and include a mandatory documentation checklist submitted together with all initial payment requests, and a new policy has been created for the rare circumstances when youth are housed outside our primary service area of Multnomah, Clark or Cowlitz counties requiring Program Director sign off prior to payment. Anticipated Completion Date: November 15, 2024

View Audit 330494

Finding 512439 (2024-001)

Significant Deficiency 2024

The Housing Authority of the City of Fairfield

AL

Procurement, Suspension & Debarment HUD Housing Programs

Corrective Action Management has issued a formal response to HUD’s Findings dated August 12, 2024, outlining specific corrective actions and considers the corrective actions satisfactorily implemented as of November 5, 2024. The Authority’s Executive Director, Shannon Eady has assumed the responsib...

Corrective Action Management has issued a formal response to HUD’s Findings dated August 12, 2024, outlining specific corrective actions and considers the corrective actions satisfactorily implemented as of November 5, 2024. The Authority’s Executive Director, Shannon Eady has assumed the responsibility of continued execution of the corrective actions.

View Audit 330174

Finding 512285 (2024-003)

Material Weakness 2024

Sixteenth Street Community Health Centers, Inc.

WI

Special Tests & Provisions HUD Housing Programs Internal Control / Segregation of Duties

Planned Corrective Action Finding: The Organization did not have adequate and effective controls over compliance in place as it relates to applying the sliding fee discount. We found two (2) instances where an individual was not appropriately charged based on the sliding fee policy in place. Crite...

Planned Corrective Action Finding: The Organization did not have adequate and effective controls over compliance in place as it relates to applying the sliding fee discount. We found two (2) instances where an individual was not appropriately charged based on the sliding fee policy in place. Criteria: Uniform Guidance requires that controls are implemented to ensure the Organization is in compliance with special tests and provisions. This includes charging the appropriate sliding fee discount based on the Organization's policy. Corrective Response: Before the audit testing, management discovered there were situations where the sliding fee wasn’t being correctly applied. Discounts were being calculated by staff because the system calculations were wrong. The Sliding Fee Scale system rebuild has undergone successful testing and is now in the process of being implemented. Management has suggested adjustments to the sliding fee scale to guarantee accurate calculation of patient balances. The board has already approved those changes, and the updated Sliding Fee Scale involves removing the percentage-based charges and setting fixed payments for nominal and minimum fees per visit. The system rebuild for the Sliding Fee Scale has already been tested and is being rolled out. Alternatively, management has proposed changes to the sliding fee scale to ensure that the system will be able to properly calculate the amount due from patients by taking away the percentage due and making the nominal and minimum charges a flat amount per visit. These policy changes will make the application of the sliding fee scale easier to manage for the system, staff, and patients. Anticipated Completion Date 12/31/2024 Responsible Contact Person CFO/Revenue Cycle Director

View Audit 330056

Finding 511960 (2024-001)

Material Weakness 2024

Comprehend Properties Inc.

KY

Eligibility HUD Housing Programs

The property manager will be responsible for the calculation. The income verification documentation will be reviewed and signed off by the property manager supervisor which is the COO for Comprehend.

View Audit 329691

Finding 511942 (2024-002)

Significant Deficiency 2024

Lutheran Social Services of Central Ohio Mansfield Housing, Inc.

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Managemen...

Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Management is in the process of improving controls to ensure that all approved residual receipt recaptures requested by HUD are timely remitted to HUD. Contact person responsible for corrective action: Fikru Nigusse, CFO Anticipated Completion Date: June 30, 2025

View Audit 329671

Finding 509762 (2024-001)

Significant Deficiency 2024

Decatur Housing Authority

IL

HUD Housing Programs

Corrective Action Plan Audit Finding Number: 2024-001 – Capital Funds Draws for Operations Agency: Public Housing Capital Fund Responsible Person, Title: Shara LeBeau, Executive Director Completion date: 1/1/2024 Agency Response: Concur Corrective Action Plan: Management concurs with the recommen...

Corrective Action Plan Audit Finding Number: 2024-001 – Capital Funds Draws for Operations Agency: Public Housing Capital Fund Responsible Person, Title: Shara LeBeau, Executive Director Completion date: 1/1/2024 Agency Response: Concur Corrective Action Plan: Management concurs with the recommendation and has already implemented controls in January 2024 that operation draws (BLI 1406) are obligated & expensed the same day the voucher is submitted to LOCCS.

View Audit 329434

Finding 509724 (2024-004)

Material Weakness 2024

Jacksonville Towers, INC

FL

Questioned Costs HUD Housing Programs Reporting

SECTION II AND SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENTS AUDITS (CONTINUED) FINDING No. 2024-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Projec...

SECTION II AND SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENTS AUDITS (CONTINUED) FINDING No. 2024-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Project should implement procedures to monitor the expiration of HUD required documents to ensure timely preparation and approval. Action Taken: Management is in the process of obtaining a new management agent certification. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips Irene Phillips CFO

View Audit 329376 Questioned Costs: $1

Finding 509723 (2024-003)

Material Weakness 2024

Jacksonville Towers, INC

FL

Questioned Costs HUD Housing Programs Reporting

SECTION II AND SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENTS AUDITS FINDING No. 2024-003: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Project should co...

SECTION II AND SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENTS AUDITS FINDING No. 2024-003: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Project should comply with HUD regulations for executing the required rent change as of its effective date when approved. Action Taken: New manager has been trained to implement gross rent changes immediately and new procedures have been implemented to ensure timely changes.

View Audit 329376 Questioned Costs: $1

Finding 509722 (2024-002)

None 2024

Jacksonville Towers, INC

FL

HUD Housing Programs Reporting

FINDING No. 2024-002: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure that the correct amount is deposited into the replacement reserve account each month. Action T...

FINDING No. 2024-002: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure that the correct amount is deposited into the replacement reserve account each month. Action Taken: Escrows were underfunded due primarily to a high increase in insurance rates. The Project will fund the shortfall. Escrow balances will be reviewed on a regular basis to ensure adequate funding.

View Audit 329376

Finding 509721 (2024-001)

None 2024

Jacksonville Towers, INC

FL

HUD Housing Programs Eligibility Reporting

Oversight Agency for Audit, Jacksonville Towers, Inc., respectfully submits the following corrective action plan for the year ended March 31, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audi...

Oversight Agency for Audit, Jacksonville Towers, Inc., respectfully submits the following corrective action plan for the year ended March 31, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: April 1, 2023 through March 31, 2024 The findings from the March 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2024-001: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Rental Housing Projects, ALN 14.155 Recommendation: The Project should implement procedures to ensure that tenant eligibility is verified, tenant files are properly maintained, and tenant signatures are obtained in a timely manner. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and included in monthly report procedures.

View Audit 329376

Finding 509666 (2024-001)

None 2024

Community Link, Programs of Travelers Aid Society of Central Carolinas

NC

Matching / Level of Effort / Earmarking HUD Housing Programs

Continuum of Care – Assistance Listing No. 14.267 Recommendation: The Organization has not met its matching requirement for the NC0045 grant or the NC0221 grant. The Organization has determined that these awards have become too costly to administer and is now in discussions with HUD regarding the o...

Continuum of Care – Assistance Listing No. 14.267 Recommendation: The Organization has not met its matching requirement for the NC0045 grant or the NC0221 grant. The Organization has determined that these awards have become too costly to administer and is now in discussions with HUD regarding the objective of transferring these award programs to another entity. We recommend that the Organization continue these discussions with HUD in order to end its responsibilities for award programs that it has determined it is unable to comply with. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will continue working with HUD to transfer these award programs to another entity that has more capacity of complying with all requirements. As of July 2024, grant NC0045 was transferred to Brick Capital. The Organization is continuing to work with HUD to transfer the NC0221 grant. Name(s) of the contact person(s) responsible for corrective action: Tameka Gunn, President and Chief Executive Officer Planned completion date for corrective action plan: March 2025

View Audit 329305

Finding 509646 (2024-001)

None 2024

Genesis II Apartments, Inc. 054-Ee081-Wah

SC

HUD Housing Programs Reporting

GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN November 6, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Genesis II Apartments,...

GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN November 6, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Genesis II Apartments, Inc., HUD Project No. 054-EE081-WAH, respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Bernard Robinson & Company, L.L.P. Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended June 30, 2024 The findings from the Schedule of Findings and Questioned Costs for the year ended June 30, 2024 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2024-001: U.S. Department of Housing and Urban Development, Supportive Housing for the Elderly (Section 202), Assistance Listing #14.157 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due date. Action Taken: We agree with Finding 2024-001 described in the accompanying schedule of findings and questioned costs. The management company will ensure the annual financial statements are submitted once the audits are back on track with the scheduled due dates. If HUD has questions regarding this plan, please call (803) 808-3966. Sincerely yours, Reese Quick, President Southern Development Management Company, Inc.

View Audit 329247

Finding 509371 (2024-001)

Significant Deficiency 2024

Jubilee Senior Homes, Inc.

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

JUBILEE SENIOR HOMES, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action pla...

JUBILEE SENIOR HOMES, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2023, to 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. FINDINGS-FINANCIAL STATEMENT AUDIT None noted. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.157. Program - Section 202 Supportive Housing for Elderly Persons Significant Deficiency Recommendation: Jubilee Senior Homes should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Senior management now recognizes that additional resources must be utilized during periods of progressive discipline with a frontline employee, to ensure the timely completion of recertifications. A new Manager was hired for Jubilee Senior Homes through an internal transfer and this individual is in the process of catching up on all needed paperwork as a top priority. The John Stewart Compliance Department will perform a 100% file audit upon completion of the outstanding certifications. Additionally, the assigned Regional Manager is performing monthly spot checks on files and reviewing a recertification status report for monitoring of progress and ongoing compliance. The property management company has implemented a roving support team that will assist managers who are struggling to meet their deadlines, ensuring compliance and helping to maintain performance standards moving forward. The roving support team was established in 2024, partly due to our commitment to ensure HUD deadlines are met. The property management company has also implemented monthly monitoring at their corporate office by the Property Management Document Information Specialist and HUD Secure Coordinator. This individual is monitoring monthly submissions to TRACs by all properties, and flagging underperformance on annual recertifications in addition to other HUD key performance metrics. The report of data from TRACs is circulated to Regional Managers, Directors, and senior leadership every month. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 329158

Finding 509369 (2024-001)

Significant Deficiency 2024

3250 Sacramento Housing, Inc.

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

3250 SACRAMENTO HOUSING, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective acti...

3250 SACRAMENTO HOUSING, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2023, to 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. FINDINGS-FINANCIAL STATEMENT AUDIT None noted. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.157. Program - Section 202 Supportive Housing for Elderly Persons Significant Deficiency Recommendation: 3250 Sacramento should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Senior management now recognizes that additional resources must be utilized during periods of progressive discipline with a frontline employee, to ensure the timely completion of recertifications. A new Manager was hired for 3250 Sacramento through an internal transfer and this individual is in the process of catching up on all needed paperwork as a top priority. The John Stewart Compliance Department will perform a 100% file audit upon completion of the outstanding certifications. Additionally, the assigned Regional Manager is performing monthly spot checks on files and reviewing a recertification status report for monitoring of progress and ongoing compliance. The property management company has implemented a roving support team that will assist managers who are struggling to meet their deadlines, ensuring compliance and helping to maintain performance standards moving forward. The roving support team was established in 2024, partly due to our commitment to ensure HUD deadlines are met. The property management company has also implemented monthly monitoring at their corporate office by the Property Management Document Information Specialist and HUD Secure Coordinator. This individual is monitoring monthly submissions to TRACs by all properties, and flagging underperformance on annual recertifications in addition to other HUD key performance metrics. The report of data from TRACs is circulated to Regional Managers, Directors, and senior leadership every month. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 329156

Finding 509357 (2024-004)

Material Weakness 2024

Clinton Township Housing Commission

MI

Questioned Costs HUD Housing Programs Eligibility

Management’s Response- New Management has taken over responsibilities as of May 2024 and will review and implement stronger policies and procedures pertaining to tenant files

View Audit 329150 Questioned Costs: $1

Finding 508405 (2024-003)

Significant Deficiency 2024

Housing and Redevelopment Authority of Detroit Lakes

MN

HUD Housing Programs Eligibility Significant Deficiency

Contact Person Nichole Bristlin, Executive Director. Corrective Action Plan Management plans on adding a signed lease step to the quality control worksheet to ensure signed leases are included in all files. Planned Completion Date for CAP June 30, 2025

View Audit 329032

Finding 508380 (2024-003)

Significant Deficiency 2024

Housing Authority of the City of Independence

MO

HUD Housing Programs Significant Deficiency Special Tests & Provisions

Independence Housing Authority (IHA) received an audit finding for failing to properly document the reinspection of a failed HQS inspection. During the previous year, IHA had 3 contractors inspecting for HCV and not using the internal software which led to multiple issues including missing documenta...

Independence Housing Authority (IHA) received an audit finding for failing to properly document the reinspection of a failed HQS inspection. During the previous year, IHA had 3 contractors inspecting for HCV and not using the internal software which led to multiple issues including missing documentation. IHA hired a full time, HQS/NSPIRE certified inspector in August 2023 to ensure HQS inspections are completed in a timely manner and within regulation. IHA has also purchased the BOB.AI software which monitors and schedules upcoming initial, reinspection’s, annual and special inspection requests. Inspection letters are generated in this program as well as results/finding items. Inspections spreadsheets have been created for tracking purposes by the HCV Director. The inspector reviews his weekly schedule with the HCV Director for accuracy.

View Audit 328993

Finding 508379 (2024-002)

Significant Deficiency 2024

Housing Authority of the City of Independence

MO

HUD Housing Programs Cash Management Internal Control / Segregation of Duties

Independence Housing Authority (IHA) also received an audit finding for failing to calculate the utility allowances correctly. This was caused by previous management instructing staff to provide an appliance credit to all tenants at move-in. All staff members have been retrained in the proper proced...

Independence Housing Authority (IHA) also received an audit finding for failing to calculate the utility allowances correctly. This was caused by previous management instructing staff to provide an appliance credit to all tenants at move-in. All staff members have been retrained in the proper procedures for calculations and allowances. All HCV program specialists have received rent calculations certifications and have been instructed to correct any prior errors immediately. The Compliance Officer is also doing random tenant file audits on a monthly basis. This should make finding

View Audit 328993

Finding 508378 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Independence

MO

HUD Housing Programs Subrecipient Monitoring

Independence Housing Authority (IHA) received an audit finding for failing to clear Interprogram Due To/Due From Activities from the financials at fiscal year-end. In order to remedy the situation, IHA has revised its internal monthly checklist to ensure that interfund transfers are cleared on a mon...

Independence Housing Authority (IHA) received an audit finding for failing to clear Interprogram Due To/Due From Activities from the financials at fiscal year-end. In order to remedy the situation, IHA has revised its internal monthly checklist to ensure that interfund transfers are cleared on a monthly basis to prevent the accumulation of interfund receivables and payables. IHA will also strengthen its cash management practices by reviewing and reconciling inter-program balances on a monthly basis. This process will include a detailed review to ensure that program-level cash components are accurate, and resources are being used exclusively for their intended purposes.

View Audit 328993

Corrective Action Plans

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