Corrective Action Plans

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a. Comments on the Finding and Each Recommendation During the year ended December 31, 2024, management did not submit Form HUD-9250, "Fund Authorization" to HUD upon termination of the PRAC. As a result, management did not remit excess residual receipts of $418 as of April 30, 2025, to HUD. b. Actio...
a. Comments on the Finding and Each Recommendation During the year ended December 31, 2024, management did not submit Form HUD-9250, "Fund Authorization" to HUD upon termination of the PRAC. As a result, management did not remit excess residual receipts of $418 as of April 30, 2025, to HUD. b. Action(s) Taken or Planned on the Finding The 2025 Manor renewal was submitted to HUD before the excess income was in the account. A 9250 for $584.59 has been submitted to HUD for approval of returning in excess residual receipts.
a. Comments on the Finding and Each Recommendation During the year ended December 31, 2025, management withdrew $3,169 from the replacement reserve account without HUD approval. b. Action(s) Taken or Planned on the Finding On 03.04.2026, management corrected this issue by depositing $3,169 into the ...
a. Comments on the Finding and Each Recommendation During the year ended December 31, 2025, management withdrew $3,169 from the replacement reserve account without HUD approval. b. Action(s) Taken or Planned on the Finding On 03.04.2026, management corrected this issue by depositing $3,169 into the replacement reserve account. Furthermore, management has implemented a strengthened internal control process requiring a three-level review and approval of all replacement reserve withdrawals. Specifically, the Vice President of Operations, Regional Manager, and Controller must each review and approve the request prior to any transfer of funds to ensure compliance with HUD approved withdrawals.
a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for two selected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 da...
a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for two selected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 day time frame. b. Action(s) Taken or Planned on the Finding Management compliance is addressing the generating of EIV reports to align with verification dates (<120 days) rather than when annual recertification notices are generated/sent (at least 120 days). Delays in recertification completion have improved; a majority of the certifications reviewed were effective within first 6 months of transition while the site was still adjusting to new software and management. Additional training has been provided to emphasize the importance of timely reporting and completion.
a.Comments on the Finding and Each Recommendation During the year ended December 31, 2025, the project did not make required monthly deposits to the replacement reserve in the amount of $15,431. Victory Oaks is required to make monthly deposits to the reserve of $2,204.Action(s) Taken or Planned on ...
a.Comments on the Finding and Each Recommendation During the year ended December 31, 2025, the project did not make required monthly deposits to the replacement reserve in the amount of $15,431. Victory Oaks is required to make monthly deposits to the reserve of $2,204.Action(s) Taken or Planned on the Finding b.Action(s) Taken or Planned on the Finding On January 13, 2026, management funded the replacement reserve in full.
a.Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120...
a.Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 day time frame. b. Action(s) Taken or Planned on the Finding Management compliance is addressing the generating of EIV reports to align with verification dates (<120 days) rather than when annual recertification notices are generated/sent (at least 120 days). Delays in recertification completion have improved; a majority of the certifications reviewed were effective within first 6 months of transition while the site was still adjusting to new software and management. Additional training has been provided to emphasize the importance of timely reporting and completion.
a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 12...
a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 day time frame and that an error was made on a rent calculation. b. Action(s) Taken or Planned on the Finding Management compliance is addressing the generating of EIV reports to align with verification dates (<120 days) rather than when annual recertification notices are generated/sent (at least 120 days). Delays in recertification completion have improved; a majority of the certifications reviewed were effective within first 6 months of transition while the site was still adjusting to new software and management. Additional training has been provided to emphasize the importance of timely reporting and completion. There has also been a change in site staff.
a. Comments on the Finding and Each Recommendation: Management agrees with the finding b. Action(s) Taken or Planned on the Finding Management has updated the policies and procedures and monitoring of EIV processes. All employees renew EIV training annually and are monitored by the compliance depart...
a. Comments on the Finding and Each Recommendation: Management agrees with the finding b. Action(s) Taken or Planned on the Finding Management has updated the policies and procedures and monitoring of EIV processes. All employees renew EIV training annually and are monitored by the compliance department to ensure compliance.
a. Comments on the Finding and Each Recommendation Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 day time frame. b. Action(s) Taken or Planned on the Finding Delays in recertification completion have improved; a majority of the certifica...
a. Comments on the Finding and Each Recommendation Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 day time frame. b. Action(s) Taken or Planned on the Finding Delays in recertification completion have improved; a majority of the certifications reviewed were effective within first 6 months of transition while the site was still adjusting to new software and management. Additional training has been provided to emphasize the importance of timely reporting and completion.
A. Comments on the Finding and Each Recommendation During the year ended December 31, 2025, the project did not make the required monthly deposits to the replacement reserve in the amount of $10,616. Avondale is required to make monthly deposits to the reserve of $1,924. Effective July 1, 2025, the ...
A. Comments on the Finding and Each Recommendation During the year ended December 31, 2025, the project did not make the required monthly deposits to the replacement reserve in the amount of $10,616. Avondale is required to make monthly deposits to the reserve of $1,924. Effective July 1, 2025, the monthly deposits required by HUD increased to $2,090. b. Action(s) Taken or Planned on the Finding All required replacement reserve deposits were brought current as of January 13, 2026. Going forward, management will implement enhanced monitoring procedures to ensure timely monthly funding in accordance with HUD requirements. In the event of cash flow constraints, management will proactively reduce nonessential expenditures or seek an owner contribution to maintain compliance with the regulatory agreement.
a. Comments on the Finding and Each Recomendation: Management agrees that the EIV Income Report for certain slected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120...
a. Comments on the Finding and Each Recomendation: Management agrees that the EIV Income Report for certain slected files were not generated in a timely manner, as required by HUD guidelines. Management agrees that a portion of the tenant lease files reviewed were not signed/completed within the 120 day time frame. b. Action(s) Taken or Planned on the Finding: Management compliance is addressing the generating of EIV reports to align with verification dates (<120 days) rather than when annual recertification notices are generated/sent (at least 120 days). Delays in recertification completion have improved; a majority of the certifications reviewed were effective within first 6 months of transition while the site was still adjusting to new software and management. Additional training has been provided to emphasize the importance of timely reporting and completion.
Section 223 Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities – Assistance Listing No. 14.157 Recommendation: The auditor recommends that management update its policies and procedures on monitoring policy coverage to ensure that cover...
Section 223 Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities – Assistance Listing No. 14.157 Recommendation: The auditor recommends that management update its policies and procedures on monitoring policy coverage to ensure that coverage is adequate to cover collections. The auditor also recommends that management update its fidelity policy to bring the Project back into compliance.. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: (1) Management will include an updated policy concerning annual re-verification of its fidelity policy such that the policy limits will exceed HUDs ongoing requirements for coverage. (2) Management will immediately increase limits from the previous limits ($3.5M) to a new higher limit ($5M) that will be well in excess of HUDs current requirements. Name(s) of the contact person(s) responsible for corrective action: Paul Kemp Planned completion date for corrective action plan: March 31, 2026
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Action Taken: The Organization accepts the recommendation of Deming, Malone...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Action Taken: The Organization accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized on the monthly vouchers when a move out is processed. The overpayment of subsidy received should be repaid to HUD. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-...
Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized on the monthly vouchers when a move out is processed. The overpayment of subsidy received should be repaid to HUD. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all move out adjustments processed utilize the proper vacancy date. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billing.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting ...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that all documents related to recertification are acquired. Additionally, tenant files should be reviewed to ensure all supporting documentation is ...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that all documents related to recertification are acquired. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Thompson-Woodlief Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that tenant recertifications are documented in accordance with HUD guidelines and that proper documentation is maintained within the tenant files.
Recommendation: The design of the current controls should be reviewed to ensure that all withdrawals from the reserve for replacement agree to the amount approved by HUD. The Organization should return the excess funds withdrawn to the reserve. Action Taken: The management of Jude’s Place Apartments...
Recommendation: The design of the current controls should be reviewed to ensure that all withdrawals from the reserve for replacement agree to the amount approved by HUD. The Organization should return the excess funds withdrawn to the reserve. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all withdrawals from the reserve for replacement agree to the amount approved by HUD. The excess funds withdrawn were returned to the reserve in May 2025.
Recommendation: The design of the current controls should be reviewed to ensure that information used on Form 50059 in the calculation of tenant payments should agree to the supporting documentation maintained in tenant files. Overpayment of subsidy should be repaid to HUD. Action Taken: The managem...
Recommendation: The design of the current controls should be reviewed to ensure that information used on Form 50059 in the calculation of tenant payments should agree to the supporting documentation maintained in tenant files. Overpayment of subsidy should be repaid to HUD. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that information used on Form 50059 in the calculation of tenant payments should agree to the supporting documentation maintained in tenant files. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before processing. The Organization should repay the overpayment of subsidy to HUD. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommen...
Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before processing. The Organization should repay the overpayment of subsidy to HUD. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all adjustments to monthly billings are reviewed to ensure they are processed correctly. Overpayment of subsidy will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting docu...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before submission. The Organization should repay the overpayment of subsidy to HUD. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recomme...
Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before submission. The Organization should repay the overpayment of subsidy to HUD. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all adjustments to monthly billings are reviewed before submission.. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized in the event of a deceased tenant. The overpayment of subsidy received on behalf of the deceased tenant should be repaid to HUD. Action Taken: The management of Edsil’s Place Apartments,...
Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized in the event of a deceased tenant. The overpayment of subsidy received on behalf of the deceased tenant should be repaid to HUD. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that move-outs as a result of a deceased tenant are processed in accordance with HUD guidelines. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting docu...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Recommendation: The design of the current controls should be reviewed to ensure adjustments made to the monthly billings are accurate before submission. Excess subsidy payments should be repaid to HUD. Action Taken:The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming,...
Recommendation: The design of the current controls should be reviewed to ensure adjustments made to the monthly billings are accurate before submission. Excess subsidy payments should be repaid to HUD. Action Taken:The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all adjustments to monthly billings are reviewed for accuracy before submission. Excess subsidy received will be repaid to HUD through adjustments to monthly billings.
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting ...
Recommendation: The design of the current controls should be reviewed to ensure tenants receive proper notice of the annual recertification process and that the process is completed by the tenants certification anniversary date. Additionally, tenant files should be reviewed to ensure all supporting documentation is included. Action Taken: The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will provide timely notice of annual recertifications to all tenants in accordance with HUD guidelines to ensure the process is completed on time and will ensure all supporting documentation is maintained in tenant files.
Section 811 – Capital Advances, Section 811 – Project Rental Assistance Recommendation: The Organization should comply with HUD requirements and wait until receipt of HUD approval before withdrawing any funding from the Reserve for Replacement account. Explanation of disagreement with audit finding:...
Section 811 – Capital Advances, Section 811 – Project Rental Assistance Recommendation: The Organization should comply with HUD requirements and wait until receipt of HUD approval before withdrawing any funding from the Reserve for Replacement account. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will take steps to adjust the budget and ensure there is proper approval before withdrawing and funds from the R&R account moving forward. Name(s) of the contact person(s) responsible for corrective action: Phil Pasmanik, Treasurer Planned completion date for corrective action plan: 03/31/2026
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