Corrective Action Plans

Finding 1169160 (2025-001)

Material Weakness 2025

Senior Citizens Housing Dev CORP of Chicago Dba Senate Apartments

FL

HUD Housing Programs Eligibility Reporting

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Chicago respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Cor...

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Chicago respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: July 1, 2024 through June 30, 2025 The finding for the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Project Based Rental Assistance Program, ALN 14.195 Recommendation: The Project should implement procedures to ensure that proper initial eligibility procedures are conducted for potential tenants and that tenant files are accurately maintained. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding this plan, please call Irene Phillips at 954- 835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

View Audit 382034

Finding 1169139 (2025-003)

Material Weakness 2025

Lighthouse Living Centers No. 2, Inc.

TX

HUD Housing Programs Significant Deficiency

Finding #2025-003 – Significant Deficiency and Other Noncompliance. Condition and context: The required monthly replacement reserves deposit amount increased from $842 to $885 during the year, but Living Centers No. 2 failed to increase the monthly deposit. Recommendation: Reemphasize current polici...

Finding #2025-003 – Significant Deficiency and Other Noncompliance. Condition and context: The required monthly replacement reserves deposit amount increased from $842 to $885 during the year, but Living Centers No. 2 failed to increase the monthly deposit. Recommendation: Reemphasize current policies and procedures to ensure that the required monthly deposit is made in accordance with HUD requirements. Planned corrective action: Following turnover that resulted in accounting challenges, we hired a CFO to develop standard operating procedures and best practices to ensure we maintain operational excellence in non-profit accounting. We implemented strategies to address opportunities in training, best practices and oversight. Responsible officer: Terry Vaughn, Vice President of Operations and Sales. Estimated completion date: November 2025.

View Audit 381962

Finding 1169138 (2025-002)

Material Weakness 2025

Lighthouse Living Centers No. 2, Inc.

TX

HUD Housing Programs Material Weakness

Findings #2025-001 and #2025-002 – Material Weakness and Other Noncompliance. Condition and context: Adjustments were required to properly state accrued interest payable and interest expense, depreciation and accumulated depreciation, maintenance expense and building equipment, tenant deposits held ...

Findings #2025-001 and #2025-002 – Material Weakness and Other Noncompliance. Condition and context: Adjustments were required to properly state accrued interest payable and interest expense, depreciation and accumulated depreciation, maintenance expense and building equipment, tenant deposits held in trust and tenant charges, salary expense and related payables, and accounts payable and related expense. These adjustments decreased the change in net assets by approximately $59,500. Additionally, an audit adjustment of approximately $24,350 was required to properly state cash and intercompany payables. Recommendation: Policies and procedures should be designed and implemented to ensure that transactions are appropriately recognized in the accounting records, supported by appropriately approved documentation and that accounts, including accruals, are timely reviewed and reconciled. Planned corrective action: Following turnover that resulted in accounting challenges, we hired a CFO to develop standard operating procedures and best practices to ensure we maintain operational excellence in non-profit accounting. We implemented strategies to address opportunities in training, best practices and oversight. Responsible officer: Terry Vaughn, Vice President of Operations and Sales. Estimated completion date: November 2025.

View Audit 381962

Finding 1169081 (2025-002)

Material Weakness 2025

Northland Pines School District

WI

School Nutrition Programs Internal Control / Segregation of Duties Cash Management

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. Explanation of Disagreement with Audit Finding: There is no ...

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The Business Manager and School Food Service Director met regarding the finding and agreed that the Food Service Director will continue to gather the required claim data and enter the appropriate data into DPIs required Excel template monthly. All supporting documentation as well as the Excel documents will be emailed to the Business Manager monthly. The Business Manager will verify the numbers in the Excel documents using the supporting documentation. If the Business Manager agrees with the numbers in the Excel files, they will be uploaded to DPI as is. If any discrepancies are discovered, the Food Service Director and the Business Manager will work together to ensure the correct data is sent to DPI. Name of Responsible Official: Tera Fritz, Business Manager Expected Completion Date: September 1, 2025

View Audit 381821

Finding 1169069 (2025-002)

Material Weakness 2025

Chehalem Valley Housing Corporation

OR

HUD Housing Programs

Management will ensure that any distributions of project assets are approved by HUD in advance. A formal written policy has been adopted that requires all proposed distributions to be submitted to HUD for prior written approval before any disbursement. The policy clearly defines roles, responsibilit...

Management will ensure that any distributions of project assets are approved by HUD in advance. A formal written policy has been adopted that requires all proposed distributions to be submitted to HUD for prior written approval before any disbursement. The policy clearly defines roles, responsibilities, and the approval workflow. No distributions are to be processed without documented evidence of HUD’s written approval. This verification is required before processing any transaction.

View Audit 381763

Finding 1169068 (2025-001)

Material Weakness 2025

Chehalem Valley Housing Corporation

OR

HUD Housing Programs

The Project will make catch-up deposits when operating cash is available. In addition, the following measures have been implemented: 􀁸 A monthly compliance checklist has been established to verify timely reserve for replacement deposits. 􀁸 The Housing Accountant is required to provide monthly confir...

The Project will make catch-up deposits when operating cash is available. In addition, the following measures have been implemented: 􀁸 A monthly compliance checklist has been established to verify timely reserve for replacement deposits. 􀁸 The Housing Accountant is required to provide monthly confirmation to the Executive Director that deposits have been made, with documentation. 􀁸 Cash flow forecasting is now conducted monthly to identify potential shortfalls in advance. This allows management to prioritize HUD-mandated deposits and, if necessary, seek HUD approval for a rent increase to improve financial stability. 􀁸 A financial policy was adopted to temporarily defer discretionary or non-essential expenditures when cash flow is tight, ensuring compliance with HUD obligations.

View Audit 381763

Finding 1169018 (2025-001)

Material Weakness 2025

Hrca Brookline Housing 1550 Beacon Plaza Mark and Diane Goldman

MA

HUD Housing Programs

Condition: The Organization had cash balances that exceeded federally insured limits, and management did not monitor or maintain documentation of the financial institutions’ ratings Criteria: HUD guidelines require cash to be maintained in financial institutions that meet minimum GNMA ratings when b...

Condition: The Organization had cash balances that exceeded federally insured limits, and management did not monitor or maintain documentation of the financial institutions’ ratings Criteria: HUD guidelines require cash to be maintained in financial institutions that meet minimum GNMA ratings when balances exceed federally insured limits. Financial institution ratings are to be monitored by management on a quarterly basis, and documentation is to be maintained for at least three years as required by the HUD handbook 4350.1 Cause: The cause of this issue was the absence of established procedures requiring periodic review of cash balances exceeding federally insured limits and the lack of a documented process for monitoring and retaining financial institution rating information. Effect: There were no negative effects on the Organization. Action Plan: The Organization has maintained a strong partnership with our banking institution for several years, and this relationship continues to provide meaningful support to our residents and community. Management acknowledges that certain cash balances exceeded federally insured limits and that documentation of financial institution ratings was not consistently monitored or maintained. To address this, management will (1) evaluate opportunities to rebalance cash holdings to remain within insured limits where feasible, and (2) implement a formal process to review, document, and retain financial institution credit ratings on at least a quarterly basis. This process will be incorporated into the Organization’s ongoing treasury and risk-management procedures to ensure compliance going forward.

View Audit 381686

Finding 1169017 (2025-002)

Material Weakness 2025

Hrca Housing for Elderly, Inc. D/b/a Jack Satter House

MA

HUD Housing Programs Internal Control / Segregation of Duties Procurement, Suspension & Debarment

Criteria: HUD requires the Organization to maintain fidelity bond coverage of at least two months' cash collections Cause: Following completion of the 2025 Mark-to-Market process for HRCA Housing for Elderly Inc., we failed to update our fidelity bond coverage to reflect the revised requirements. Ac...

Criteria: HUD requires the Organization to maintain fidelity bond coverage of at least two months' cash collections Cause: Following completion of the 2025 Mark-to-Market process for HRCA Housing for Elderly Inc., we failed to update our fidelity bond coverage to reflect the revised requirements. Action Plan: Once the finding was identified, we immediately contacted our insurance broker and requested an increase to the fidelity bond coverage. The bond has since been raised to a $2M limit, and the updated policy became effective on 11/14/25. Going forward, the fiscal team will incorporate an annual verification of bond coverage into its routine monitoring procedures to ensure timely updates after significant organizational or regulatory changes. In addition, we are implementing an internal audit component to enhance our review of all HUD requirements. This added oversight will help mitigate future risk and ensure continued compliance with all applicable regulations.

View Audit 381685

Finding 1169016 (2025-001)

Material Weakness 2025

Hrca Housing for Elderly, Inc. D/b/a Jack Satter House

MA

HUD Housing Programs

Condition: The Organization had cash balances that exceeded federally insured limits, and management did not monitor or maintain documentation of the financial institutions’ ratings Criteria: HUD guidelines require cash to be maintained in financial institutions that meet minimum GNMA ratings when b...

Condition: The Organization had cash balances that exceeded federally insured limits, and management did not monitor or maintain documentation of the financial institutions’ ratings Criteria: HUD guidelines require cash to be maintained in financial institutions that meet minimum GNMA ratings when balances exceed federally insured limits. Financial institution ratings are to be monitored by management on a quarterly basis, and documentation is to be maintained for at least three years as required by the HUD handbook 4350.1 Cause: The cause of this issue was the absence of established procedures requiring periodic review of cash balances exceeding federally insured limits and the lack of a documented process for monitoring and retaining financial institution rating information. Effect: There were no negative effects on the Organization. Action Plan: The Organization has maintained a strong partnership with our banking institution for several years, and this relationship continues to provide meaningful support to our residents and community. Management acknowledges that certain cash balances exceeded federally insured limits and that documentation of financial institution ratings was not consistently monitored or maintained. To address this, management will (1) evaluate opportunities to rebalance cash holdings to remain within insured limits where feasible, and (2) implement a formal process to review, document, and retain financial institution credit ratings on at least a quarterly basis. This process will be incorporated into the Organization’s ongoing treasury and risk-management procedures to ensure compliance going forward.

View Audit 381685

Finding 1169013 (2025-001)

Material Weakness 2025

Housing Alliance and Community Partnership

ID

HUD Housing Programs Subrecipient Monitoring

HACP has implemented the following corrective actions: Continued oversight of two current inspectors to ensure compliance with HQS and federal regulations; Retention of a Compliance Coordinator to oversee inspection processes and documentation; implementation of improved documentation standards rela...

HACP has implemented the following corrective actions: Continued oversight of two current inspectors to ensure compliance with HQS and federal regulations; Retention of a Compliance Coordinator to oversee inspection processes and documentation; implementation of improved documentation standards related to inspections, re-inspections, and abatements; Regular file audits conducted by the ED or Deputy Director to verify timely rescheduling and enforcement of rent abatements.

View Audit 381681

Finding 1168965 (2025-001)

Material Weakness 2025

Good Samaritan Village, Inc.

TN

Subrecipient Monitoring Cash Management HUD Housing Programs

Finding #2025-001: Comments on the Finding and Each Recommendation: The Corporation received a reimbursement from the reserve for replacements, as approved by HUD, for $17,400 for HVAC services based on a proposal during the year ended September 30, 2025; however the proposal was never accepted and ...

Finding #2025-001: Comments on the Finding and Each Recommendation: The Corporation received a reimbursement from the reserve for replacements, as approved by HUD, for $17,400 for HVAC services based on a proposal during the year ended September 30, 2025; however the proposal was never accepted and the scheduled repairs never incurred. At September 30, 2025, the $17,400 had not been deposited back into the reserve for replacements. Management should transfer $17,400 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. On November 6, 2025, management transferred $17,400 from the operating account to the reserve for replacements.

View Audit 381595

Finding 1168963 (2025-001)

Material Weakness 2025

Pittsfield Lowry, LLC

IL

HUD Housing Programs

Identifying Number: 2025-001 Finding: The Organization calculated surplus cash of $31,225 as of September 30, 2020 and surplus cash of $39,082 as of September 30, 2021, which includes the undeposited amount from September 30, 2020. This amount was not deposited into a residual receipts fund account....

Identifying Number: 2025-001 Finding: The Organization calculated surplus cash of $31,225 as of September 30, 2020 and surplus cash of $39,082 as of September 30, 2021, which includes the undeposited amount from September 30, 2020. This amount was not deposited into a residual receipts fund account. The Organization calculated surplus cash of $149,237 as of September 30, 2022, which includes the undeposited amount from September 30, 2021. The Organization has not deposited this amount into a separate residual receipts fund account within 90 days of the fiscal year-end. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management disagrees with the finding because surplus cash was caused by a release from the replacement reserve and a timing difference between the release of the reserve and the addition of building improvements. Building improvements and a related payable were recorded during the year ended September 30, 2023. As of September 30, 2025, the Organization did not have any surplus cash; therefore, management does not intend to make a deposit into a residual receipts account. The construction payable will be paid in full as funds become available. Management has had discussions with their lender and intends to contact HUD directly to resolve this finding. Due to the necessary involvement of third parties to complete the corrective action, the Organization cannot determine an anticipated completion date.

View Audit 381591

Finding 1168962 (2025-001)

Material Weakness 2025

Marion Williamson County Parkway, LLC

IL

HUD Housing Programs

Identifying Number: 2025-001 Finding: The Organization expanded the licensed bed size of the mortgaged property by 12 skilled nursing beds before obtaining an approval from HUD. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management has had m...

Identifying Number: 2025-001 Finding: The Organization expanded the licensed bed size of the mortgaged property by 12 skilled nursing beds before obtaining an approval from HUD. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management has had multiple communications since May 2013 with their lender to resolve this finding, however it still remains unresolved. Management corresponded with the lender in March 2022 to resolve the finding, and an application to HUD for approval of the license change was filed. Management most recently corresponded with the lender in August 2024. Management is currently waiting on HUD’s review for completion. Due to the necessary involvement of third parties to complete the corrective action, the Organization cannot determine an anticipated completion date.

View Audit 381588

Finding 1168961 (2025-001)

Material Weakness 2025

Jerseyville North State, LLC

IL

HUD Housing Programs

Identifying Number: 2025-001 Finding: The Organization reduced the licensed bed size of the mortgaged property by 6 skilled nursing beds before obtaining an approval from HUD. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management is in the p...

Identifying Number: 2025-001 Finding: The Organization reduced the licensed bed size of the mortgaged property by 6 skilled nursing beds before obtaining an approval from HUD. Corrective Action Taken or Planned: Ron Wilson is responsible to ensure corrective actions are taken. Management is in the process of obtaining after-the-fact approval from HUD to resolve this finding by sending a letter of request to HUD with additional information on the bed change. Management most recently submitted additional information to the lender in September 2024. Due to the necessary involvement of third parties to complete the corrective action, the Organization cannot determine an anticipated completion date.

View Audit 381584

Finding 1168931 (2025-001)

Material Weakness 2025

Santa Monica Rhf Housing, Inc. Dba Wilshire House 122-Eh476

CA

HUD Housing Programs Subrecipient Monitoring Cash Management

Statement of Condition 2025-001 (Assistance Listing 14.155): The Corporation did not make the required residual receipts deposit computed at September 30, 2024 in the amount of $642,483 within 90 days of fiscal year end. Recommendation: Management should implement a system to ensure the required res...

Statement of Condition 2025-001 (Assistance Listing 14.155): The Corporation did not make the required residual receipts deposit computed at September 30, 2024 in the amount of $642,483 within 90 days of fiscal year end. Recommendation: Management should implement a system to ensure the required residual receipts deposit is made within 90 days of fiscal year end. Management response: Agree. Management made the required residual receipts deposit on June 9, 2025.

View Audit 381439

Finding 1168919 (2025-001)

Material Weakness 2025

Villa Caridad 122-Ee183-Wah-Np

CA

Eligibility HUD Housing Programs

The management compnay acknowledges the important regulatory requirements for EIV documentation and timeliness required for generating reports for documentation and review within specified deadlines. To ensure ongoing compliance with these regulations, management will continue the training protocol ...

The management compnay acknowledges the important regulatory requirements for EIV documentation and timeliness required for generating reports for documentation and review within specified deadlines. To ensure ongoing compliance with these regulations, management will continue the training protocol that is in place for 2025 by reviewing and signing the EIV rules of Behavior and the EIV System Security Policy forms and completing the Cyber Awareness training annually. Management is working with on-site managers to provide additional back-up support from other departments during staffing shortages. Management also strengthened oversight procedures to ensure there are mandatory manager protocols that require an EIV report be generated and reviewed within 90 days for every new tenant move-in. For example, management implemented a checklist that the property manager must sign to confirm the EIV and other documents are properly reviewed and included in tenant files. For new tenants, the property manager will calendar the 90-day review to confirm receipt of EIV for inclusion in the tenant file. Management's housing manager and broker will also review each tenant file checklist for compliance to verify that all required EIV and other reports are in the tenant file. Additionally, management will conduct periodic reviews of files to ensure these procedures are properly followed. These additional checks and balances will ensure we are compliant with regulatory requirements.

View Audit 381382

Finding 1168869 (2025-001)

Material Weakness 2025

Ahepa 284-Iv, Inc.

SC

HUD Housing Programs Reporting Internal Control / Segregation of Duties

The property was repaid $61,198 and internal controls were properly updated.

View Audit 381213

Finding 1168860 (2025-001)

Material Weakness 2025

Ahepa 250-Ii, Inc.

CT

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Management agrees with the finding and the funds were deposited to the reserve on July 16, 2024.

View Audit 381211

Finding 1168850 (2025-001)

Material Weakness 2025

Ahepa 78 Phase Iv, Inc.

IN

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

The management agent will repay the funds on behalf of the related party housing project until that property has funds available, pending HUD approval.

View Audit 381206

Finding 1168847 (2025-002)

Material Weakness 2025

AHEPA 23, Inc.

AL

HUD Housing Programs

Management agrees and is working to submit a RAD for PRAC application that would include this property and two other properties.

View Audit 381204

Finding 1168846 (2025-001)

Material Weakness 2025

AHEPA 23, Inc.

AL

Procurement, Suspension & Debarment HUD Housing Programs Reporting

Management agrees and is working to submit a RAD for PRAC application that would include this property and two other properties.

View Audit 381204

Finding 1168798 (2025-001)

Material Weakness 2025

Morgan County Housing Authority

IL

HUD Housing Programs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

The Non-Profit Affiliate has secured a pre-development loan to reimburse the Authority in FY2026. Additionally, the COCC reimbursed over 50% of the amount due at 06/30/2025 to the Public Housing Programs in July 2025. The remaining funds are being paid down quarterly and will be paid off by end of F...

The Non-Profit Affiliate has secured a pre-development loan to reimburse the Authority in FY2026. Additionally, the COCC reimbursed over 50% of the amount due at 06/30/2025 to the Public Housing Programs in July 2025. The remaining funds are being paid down quarterly and will be paid off by end of FY2026.

View Audit 380960

Finding 1168754 (2025-001)

Material Weakness 2025

Center for Housing and Health

IL

HUD Housing Programs

Finding: We noted through audit procedures that one out of forty selections did not include support that the Organization's housing quality survey was completed or other supplemental documentation to satisfy the requirement. Corrective Action Taken or Planned: Management is putting safeguards in pla...

Finding: We noted through audit procedures that one out of forty selections did not include support that the Organization's housing quality survey was completed or other supplemental documentation to satisfy the requirement. Corrective Action Taken or Planned: Management is putting safeguards in place to ensure all documentation, including the housing quality survey, is maintained related to inspection of rental units prior to authorizing lease execution and move_x0002_in. These safeguards include internal program audits of a sample of files on a quarterly basis. Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Beth Frantz, Chief Finance Officer

View Audit 380849

Finding 1168738 (2025-001)

Material Weakness 2025

Town of Waynesville Housing Authority

NC

HUD Housing Programs Eligibility

Finding # 2025-001- Finding Description: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5. 2301 5. 6091 982.516) Corrective A...

Finding # 2025-001- Finding Description: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5. 2301 5. 6091 982.516) Corrective Action Plan: WHA prioritized and immediately completed all annual recertifications that were overdue, implemented standard operating procedures to initiate annual reexaminations 120 days before the tenant's anniversary date, ensured all relevant staff are properly trained on HUD requirements, and established a monitoring system to track the status of all upcoming annual recertifications. Anticipated Completion Date: Completed Contact Person: Name, Title: Belinda Kahl, Executive Director Address: 48 Chestnut Park Drive, Waynesville NC 28786 Phone#: 828-456-6377 Contact Person Signature: ~d-{

View Audit 380802

Finding 1168669 (2025-001)

Material Weakness 2025

Belmont Housing Associates, Inc.

CO

Cash Management HUD Housing Programs

Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account

View Audit 380644

Corrective Action Plans

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