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Cash Management Moving to Work Demonstration Program AL No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of the 66 grant drawdowns during the year, 19 drawdowns were tested and it was noted that 1 of the drawdowns was made in advance of the supportin...
Cash Management Moving to Work Demonstration Program AL No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of the 66 grant drawdowns during the year, 19 drawdowns were tested and it was noted that 1 of the drawdowns was made in advance of the supporting invoices being paid to the vendors and subsequently the invoices were not paid within three business days, as required. Auditor’s Recommendations: The Agency should continue to develop and implement internal controls over grant management to coordinate capital fund draws with the timing of invoice payments. Action Taken: Action Due Date Responsible Person This finding occurred prior to the staff receiving the results of the previous audit. There have been no additional invoice payments outside of the 3-day allowable time. Staff developed and implemented an internal tracking document to ensure payments are made within three days of the draw. Complete – May 2025 Accounting Technician, Kary Smith, Lauren Hodgens and Ryan Bates
Eligibility Moving to Work Demonstration Program AL. No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Reported from 2024 audit (see prior year finding 2024-002) Condition: Out of an approximate population of approximately 4,800 tenants, 40 tenant files were tested ...
Eligibility Moving to Work Demonstration Program AL. No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Reported from 2024 audit (see prior year finding 2024-002) Condition: Out of an approximate population of approximately 4,800 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Two files did not have 214 documentation available for a member of the household, ▪ One file had the incorrect income calculated, which impacted the HAP received, ▪ One file had the incorrect income calculated, which did not impact the HAP received, ▪ One file received the incorrect HAP for which no subsequent correction was made, ▪ One file did not have a required rent reasonableness performed during the year, and ▪ One file did not have a quality control checklist maintained in the file. Auditor Recommendations: The Authority should re-evaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Due Date Responsible Person Conduct a review of cases with identified audit findings to confirm the accuracy of the determinations and implement corrections as needed. Eligibility checklists were implemented on July 31, 2024, in response to the FY23 audit findings. An additional checklist specific to annual and recertification processes was implemented in October 2025 to further strengthen compliance and quality control. Some households are on a triannual recertification cycle and have not undergone a recertification since the prior audit; these cases will be reviewed as applicable. The accuracy and effectiveness of all checklists will be reviewed and updated as needed by August 31, 2026. September 30, 2026 Program Manager, Christi Champ To address findings related to incorrect income calculations, the agency conducts monthly quality assurance reviews through random case sampling, consistent with HUD-recommended practices. Additionally, beginning in March 2026, the agency initiated comprehensive refresher trainings for all Housing Specialist (HS) staff, covering core program functions and requirements. These trainings are scheduled for completion by the end of July 2026. September 30, 2026 Program Manager, Christi Champ The file identified as missing required rent reasonableness documentation will be reviewed, and any deficiencies will be corrected as appropriate. Based on internal review, this case may be associated with a Project-Based Voucher (PBV) unit, where prior rent increases were appropriately completed but not consistently retained within the tenant file. In Spring 2026, the agency identified this documentation gap and implemented process improvements, including updates to internal policies to ensure that all rent reasonableness determinations are consistently documented and maintained September 30, 2026 Program Manager, Christi Champ in the tenant file. These updates will be effective July 2026. All required rent reasonableness documentation will be added to the applicable tenant file
Eligibility Housing Voucher Cluster Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of an approximate population of approximately 600 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Four files did not have an inspection perfor...
Eligibility Housing Voucher Cluster Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of an approximate population of approximately 600 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Four files did not have an inspection performed during the required period, ▪ Two files did not have an up to date 9886 form on file ▪ One file did not have ID for an adult tenant in the household, and ▪ One file had the incorrect income calculated, which did not impact the HAP received. Auditor Recommendations: The Authority should re-evaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: Action Due Date Responsible Person Conduct a review of cases associated with inspectionrelated findings to verify the accuracy of the determinations and implement corrections as necessary. In certain cases, inspections may align with approved biennial inspection schedules, or delays may have occurred due to inability to access the unit or tenant non-compliance. In such instances, cases may currently be progressing through the ineligibility process, which requires additional time to resolve in accordance with program requirements. Additionally, the agency identified system-related reporting issues within Yardi that may have impacted the September 30, 2026 Program Manager, Nat Dybens accuracy of inspection tracking reports. The agency has been actively collaborating with system coordinators to address and resolve these issues. Files identified as lacking an upto-date Form HUD-9886 will be reviewed to confirm the accuracy of the finding, and all required documentation will be obtained and maintained in the tenant file to ensure compliance. Form HUD-9886-A [24 CFR 5.230(b)(1), b(2), (c)(4), and (c)(5)]; Notice PIH 2023-27 All adult applicants and participants sign form HUD-9886- A, Authorization for Release of Information. All adult family members (and the head and spouse/cohead, regardless of age) are required to sign the Form HUD9886-A at admission. Participants, prior to January 1, 2024, signed and submitted Form HUD9886 at each annual reexamination. HOTMA eliminated this requirement and instead required that the Form HUD-9886-A be signed only once. On or after January 1, 2024 (regardless of the PHA’s HOTMA compliance date), current program participants must sign and submit a new Form HUD-9886-A at their next interim or annual reexamination. This form will only be signed once. Another Form HUD-9886-A will not be submitted to the PHA except under the following circumstances: • When any person 18 years or older becomes a member of the family; • When a current member of the family turns 18; or • As required by HUD or the PHA in administrative instructions. September 30, 2026 Program Manager, Christi Champ The PHA has the discretion to establish policies around when family members must sign consent forms when they turn 18. PHAs must establish these policies stating when family members will be required to sign consent forms at intervals other than at reexamination. PHA To address areas of identified findings, the agency will reinforce expectations through staff reminders and provide additional training as needed. Additionally, beginning in March 2026, the agency initiated comprehensive refresher trainings for all Housing Specialist (HS) staff, covering core program functions and requirements. These trainings are scheduled for completion by the end of July 2026. Continued throughout the year. Program Manager, Christi Champ and Program Manager, Nat Dybens The file identified as missing required identification documentation for an adult household member will be reviewed to verify the accuracy of the finding, and all necessary documentation will be obtained and updated as appropriate. The agency recognizes that there are multiple acceptable methods for verifying adult identity and will ensure that documentation on file meets HUD requirements and is properly maintained. Additionally, a recertification checklist was implemented in October 2025 to support staff in verifying the presence of all required permanent documentation, including identification, during case file reviews. This control strengthens ongoing compliance and reduces September 30, 2026 Program Manager, Christi Champ the likelihood of similar deficiencies.
Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers program to ensure that established internal control policies are being followed on a timely basis. HHA has immed...
Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers program to ensure that established internal control policies are being followed on a timely basis. HHA has immediately instituted steps to properly abate rents should a unit fail after the 30-day compliance period. Marc A. Recko, Executive Director was designated to be responsible for implementing this corrective action by September 30, 2026.
Authority's Response and Planned Corrective Action: The Authority acknowledges the deficiencies identified in the Section 8 Housing Choice Vouchers program and has implemented internal control procedures to ensure compliance with federal regulations. The Auditor selected two files out of 17 leased u...
Authority's Response and Planned Corrective Action: The Authority acknowledges the deficiencies identified in the Section 8 Housing Choice Vouchers program and has implemented internal control procedures to ensure compliance with federal regulations. The Auditor selected two files out of 17 leased units in the Audit period. In one, the Rent Reasonableness verification documentation was missing. HHA staff will review all 17 newly leased units from the Audit period to assure compliance. In addition, HHA has implemented a system for all new lease ups to assure full compliance with Rent Reasonableness documentation. This includes the Assistant Director of Management reviewing all files before a unit is leased. Marc A. Recko, Executive Director was designated to be responsible for implementing this corrective action by September 30, 2026.
Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers program to ensure that established internal control policies are being followed on a timely basis. To that end, ...
Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers program to ensure that established internal control policies are being followed on a timely basis. To that end, in October of 2025, the month after the current Audit period, HHA brought on an outside firm (Nan McKay and Associates) to assure the completeness and correctness of all new admissions and recertification and regulatory file requirements. Our new system includes a quality control review after Nan McKay provides HHA with a completed new admission or recertification file. Marc A. Recko, Executive Director was designated to be responsible for implementing this corrective action by September 30, 2026.
2025-001 ALN 14.871 – Housing Choice Voucher Program – Eligibility The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Responses. Person Responsible for Correction of Finding: Franklin Scott Jr., Executive Director P...
2025-001 ALN 14.871 – Housing Choice Voucher Program – Eligibility The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Responses. Person Responsible for Correction of Finding: Franklin Scott Jr., Executive Director Projected Completion Date: September 30, 2026
Finding 2025-005 Plan: Please see below the new process regarding hiring additional staff and turnover at Community Action Program Belknap-Merrimack Counties Inc. Due to lack of management, it is understood the importance of having staff training on a regular basis to ensure management and complianc...
Finding 2025-005 Plan: Please see below the new process regarding hiring additional staff and turnover at Community Action Program Belknap-Merrimack Counties Inc. Due to lack of management, it is understood the importance of having staff training on a regular basis to ensure management and compliance duties can be performed adequately. Community Action Program Belknap-Merrimack Counties Inc. plans to improve the standards of employee training and will be hosting quarterly trainings on employee responsibilities, performance, and areas for improvement. This includes HUD trainings and keeping up to date on any new HUD policies and procedures. We understand the importance of a well-trained staff. We are committed to our performance and adhering to HUD standards while implementing policies to follow for continuous improvement. Please see below the new process regarding filling vacancies and completing management duties in a timely manner: 1. Immediate Focus on Vacancies: We are prioritizing the filling of vacant units by having two staff members complete move ins at the same time. 2. Streamlined Recertification Process: We have updated our process to ensure all tenants are recertified in a timely manner. There has been a new system in place to monitor deadlines and improve efficiency. 3. Staffing and Training: We are actively recruiting and training additional staff to ensure these tasks are handled promptly, preventing future delays. These steps will address the backlog of management duties and ensure that all tasks, such as filling vacancies and completing tenant recertifications, are handled in a timely and efficient manner. Completion Date: 11/1/2026 Contact: Jackie Oliveira-Director of Affordable Housing
Finding 2025-004 Plan: Management acknowledges this finding. The surplus cash deposit was not made within the required 90-day timeframe following fiscal year-end because an Owner-Certified REAC submission was filed while awaiting completion of the audited financial statements. Management incorrectly...
Finding 2025-004 Plan: Management acknowledges this finding. The surplus cash deposit was not made within the required 90-day timeframe following fiscal year-end because an Owner-Certified REAC submission was filed while awaiting completion of the audited financial statements. Management incorrectly believed the surplus cash calculation and deposit could be deferred until the audited REAC was submitted. To prevent this from occurring in the future, management has implemented a procedure requiring surplus cash to be calculated immediately following fiscal year-end, regardless of whether an Owner-Certified REAC or Audited REAC is submitted. Management will estimate and deposit any required surplus cash into the Residual Receipts Account within HUD's required 90-day timeframe and make any necessary adjustments after the audited financial statements are completed. Management has reviewed HUD requirements with applicable staff and will monitor future year-end submissions to ensure compliance with all surplus cash deposit requirements. Contact: Jackie Oliveira-Director of Affordable Housing Completion Date: 03/31/2026
Management agrees with the finding. Policies and procedures as described above will be established and implemented during the current year.
Management agrees with the finding. Policies and procedures as described above will be established and implemented during the current year.
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.155 The Project is required to make a deposit into the residual receipts account within 90 days after year end in the amount of any surplus cash. Recommendation: We recommend management ensure they have the controls and processes in place t...
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.155 The Project is required to make a deposit into the residual receipts account within 90 days after year end in the amount of any surplus cash. Recommendation: We recommend management ensure they have the controls and processes in place to make the residual receipts deposit timely. Action taken in response to finding: Management will review procedures to ensure they have the process in place to ensure timely deposit going forward. Name of the contact person responsible for corrective action: Thomas Krolak Planned completion date for corrective action plan: April 2026
Section 202 HUD-Insured Mortgage– Assistance Listing No. 14.157 The Project is required to make a deposit into the residual receipts account within 90 days after year end in the amount of any surplus cash. Recommendation: We recommend management ensure they have the controls and processes in place t...
Section 202 HUD-Insured Mortgage– Assistance Listing No. 14.157 The Project is required to make a deposit into the residual receipts account within 90 days after year end in the amount of any surplus cash. Recommendation: We recommend management ensure they have the controls and processes in place to make the residual receipts deposit timely. Action taken in response to finding: Management will review procedures to ensure they have the process in place to ensure timely deposit going forward. Name of the contact person responsible for corrective action: Thomas Krolak Planned completion date for corrective action plan: October 2025
Finding 1219022 (2025-002)
Material Weakness 2025
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.157 Management is responsible for maintaining required monthly deposits into the Replacement Reserve account in accordance with the form HUD-9250. Recommendation: The Project should establish and follow a consistent monthly review process t...
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.157 Management is responsible for maintaining required monthly deposits into the Replacement Reserve account in accordance with the form HUD-9250. Recommendation: The Project should establish and follow a consistent monthly review process to ensure all deposits are made on a timely basis. Action taken in response to finding: Management continues to review and establish processes related to review and approval to ensure monthly replacement reserve deposits are made. The missed July payment was made April of 2026. The Project currently does not have the funds to make the deposit and is working with HUD to resolve. Name of the contact person responsible for corrective action: Thomas Krolak Planned completion date for corrective action plan: December 31, 2026
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.155 The security deposit liability needs to be funded by a security deposit asset equal to or greater than the liability. Recommendation: We recommend management ensure they have controls and processes in place to ensure the security deposi...
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.155 The security deposit liability needs to be funded by a security deposit asset equal to or greater than the liability. Recommendation: We recommend management ensure they have controls and processes in place to ensure the security deposit liability account is properly funded at all times. Action taken in response to finding: The property sold on November 30, 2025, and the security deposit cash was transferred to the new owners at that point. The $342 shortage in cash was considered in the sale but was not transferred from operating to the security deposit cash before the sale took place. Name of the contact person responsible for corrective action: Thomas Krolak Planned completion date for corrective action plan: November 30, 2025
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.155 The Project is required to make a deposit into the residual receipts account within 90 days after year end in the amount of any surplus cash. Recommendation: We recommend management ensure they have the controls and processes in place t...
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.155 The Project is required to make a deposit into the residual receipts account within 90 days after year end in the amount of any surplus cash. Recommendation: We recommend management ensure they have the controls and processes in place to make the residual receipts deposit timely. Action taken in response to finding: Management has made all required deposits to the residual receipts account as of May 2025 and the cash account was whole before the sale that took place on November 30, 2025. Name of the contact person responsible for corrective action: Thomas Krolak Planned completion date for corrective action plan: May 31, 2025
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Distributions and payments on surplus cash notes must be within amounts permitted based upon semi-annual surplus cash calculations. Recommendation: Recommend that management account for surplus cash note payments when determining how mu...
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Distributions and payments on surplus cash notes must be within amounts permitted based upon semi-annual surplus cash calculations. Recommendation: Recommend that management account for surplus cash note payments when determining how much cash is available for distribution in accordance with the semi-annual surplus cash calculations and review those calculations for accuracy prior to distributions being made. There is no disagreement with the audit finding. Action taken in response to finding: We have surplus cash remaining at December 31, 2025, subsequent to the distributions being made, therefore the finding has corrected itself. Future distributions and payments on surplus cash notes will be monitored closely to ensure they are limited to amounts permitted. Name of the contact person responsible for corrective action: Doug Harrison Planned completion date for corrective action plan: December 31, 2026
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to retain the HUD approved management agreement to ensure payments made are in accordance with HUD requirements. The Project does not have a HUD approved management agreement. Recommendation: Recommend that manage...
Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to retain the HUD approved management agreement to ensure payments made are in accordance with HUD requirements. The Project does not have a HUD approved management agreement. Recommendation: Recommend that management work with HUD to have the current management agreement approved. There is no disagreement with the audit finding. Action taken in response to finding: We have contacted HUD to obtain an approved management agreement. Name of the contact person responsible for corrective action: Doug Harrison Planned completion date for corrective action plan: December 31, 2026
2025-002 - Eligibility: Public Housing Operating Fund (FALN #14.850) Criteria HUD regulations of Annual Income (24 CFR § 5.609), Eligible Family Status (24 CFR § 5.403), Citizenship and Eligible Immigrant Status (24 CFR § 5.506) and Disclosure of Social Security Numbers (24 CFR § 5.216) require the ...
2025-002 - Eligibility: Public Housing Operating Fund (FALN #14.850) Criteria HUD regulations of Annual Income (24 CFR § 5.609), Eligible Family Status (24 CFR § 5.403), Citizenship and Eligible Immigrant Status (24 CFR § 5.506) and Disclosure of Social Security Numbers (24 CFR § 5.216) require the collection and retention of certain tenant information to document the eligibility determination for each recipient. Condition The results of our testing indicated that certain items were not completed in a timely matter as follows: • In fifteen instances, the income verification form was not found in the file or not performed timely. Questioned Costs Not determinable. Context We selected a sample of 60 files for review. Our sample was a statistically valid sample. Effect or Possible Effect The tenant income verification form was not performed timely. Cause The cause is unknown. Identification as a Repeat Finding This finding is a repeat finding (see prior year finding number: 2024-002). Recommendation We recommend that Park City continue to improve its internal processes to ensure tenant income verification is performed timely. Park City's Response A Compliance Manager has been hired to randomly review resident files to make sure all documentation is maintained. An email reminder is sent monthly to managers to insure that EIV for move-ins is done on a timely basis. Contact: Jillian Baldwin Email & Phone Number : jbaldwin@oarkcitycommunities.org (203) 337-8900
2025-001 – Eligibility and Special Tests and Provisions: Housing Voucher Cluster (FALN #14.871) Criteria HUD regulations of Annual Income (24 CFR § 5.609), Eligible Family Status (24 CFR § 5.403), Citizenship and Eligible Immigrant Status (24 CFR § 5.506) and Disclosure of Social Security Numbers (2...
2025-001 – Eligibility and Special Tests and Provisions: Housing Voucher Cluster (FALN #14.871) Criteria HUD regulations of Annual Income (24 CFR § 5.609), Eligible Family Status (24 CFR § 5.403), Citizenship and Eligible Immigrant Status (24 CFR § 5.506) and Disclosure of Social Security Numbers (24 CFR § 5.216) require the collection and retention of certain tenant information to document the eligibility determination for each recipient. Condition The results of our testing indicated that certain items were unable to be located in the file, as follows: • In five instances, supporting documentation (Form HUD-52580) was not available to verify that HQS inspections were completed and passed • In five instances, social security verification was missing from the tenant file. • In six instances, income verification form was missing from the tenant file or performed timely. • In fourteen instances, signed HAP contracts were not maintained in the tenant file for review. • In one instance, income was incorrectly calculated on Form HUD-50058. Questioned Costs Not determinable. Context We selected a sample of 60 files for review. Our sample was a statistically valid sample. Effect or Possible Effect The tenant file documentation was incomplete and tenant income verification was not performed timely. Cause The cause is unknown. Identification as a Repeat Finding This finding is a repeat finding (see prior year finding number: 2024-001). Recommendation We recommend that Park City continue to improve its internal processes to ensure tenant files contain the required documentation and tenant income verification is performed timely. Park City's Response Income verification: PCC has implemented software tracking of income verification attempts. Inspections: An SOP was issued to staff to review/compare lines 5I and 5H on the 50058 to inspection result history, to confirm dates populating are accurate. HAP Contracts and Social Security Card Documentation: Implemented internal tracking review of ongoing executions are in place and monitored. HAP payments are not released until HAP contract is executed by both parties. Automated process to perform a review of electronically indexed files will be put into place to identify active units that may not display an indexed document relevant to HAP contract. A request for submission of the documents will be made. Contact: Jillian Baldwin Email & Phone Number : jbaldwin@oarkcitycommunities.org (203) 337-8900
– HUD Comprehensive Compliance Monitoring Review, Public Housing Program –14.850, Housing Choice Vouchers – 14.871, Resident Opportunities and Supportive Services -14.870 Family Self-Sufficiency Program – 14.896; Grant Period – year ended September 30, 2025. Corrective Action: The Authority has comp...
– HUD Comprehensive Compliance Monitoring Review, Public Housing Program –14.850, Housing Choice Vouchers – 14.871, Resident Opportunities and Supportive Services -14.870 Family Self-Sufficiency Program – 14.896; Grant Period – year ended September 30, 2025. Corrective Action: The Authority has completed all corrective actions submitted to HUD on March 24, 2025. The Authority received the official close out letter that all findings have been closed on March 12, 2026. Responsible Party: Darold Sterling, Executive Director, (256)329-2201. Anticipated Completion Date: September 30, 2026.
Authority Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor and has initiated corrective actions to strengthen compliance with Housing Quality Standards (HQS) inspection requirements and related abatement procedures. Management identified that staff...
Authority Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor and has initiated corrective actions to strengthen compliance with Housing Quality Standards (HQS) inspection requirements and related abatement procedures. Management identified that staffing turnover and transition-related training gaps contributed to delays in the timely processing and enforcement of failed inspection reinspections and landlord abatements during the audit period. In response, the Authority has implemented enhanced monitoring and supervisory review procedures over failed inspections and reinspection timelines to ensure compliance with HUD requirements. Management has reinforced staff training related to HQS enforcement, reinspection tracking, and Housing Assistance Payment (HAP) abatement procedures. In addition, the Authority is utilizing system generated tracking reports and management oversight tools to identify failed inspections approaching required corrective action deadlines and to ensure timely follow-up and enforcement actions are completed. The Authority believes these corrective measures will strengthen internal controls over compliance and help ensure continued adherence to HUD Housing Quality Standards requirements and related special tests and provisions compliance requirements. Isaiah Norris, Vice President of the Housing Choice Vouchers Program, is responsible for ensuring the deficiencies have been rectified by September 30, 2026.
Authority's Response and Planned Corrective Plan: The Authority accepts the auditor’s recommendation. Management acknowledges the importance of maintaining complete and readily available tenant file documentation to support eligibility determinations and ongoing program compliance for the Housing Vo...
Authority's Response and Planned Corrective Plan: The Authority accepts the auditor’s recommendation. Management acknowledges the importance of maintaining complete and readily available tenant file documentation to support eligibility determinations and ongoing program compliance for the Housing Voucher Cluster. The documents noted as unavailable during the audit relate to file maintenance and documentation retention. Management does not believe the exceptions indicate that the sampled households were ineligible for assistance; however, the Authority recognizes that required documentation must be consistently maintained and available for audit review. In response, the Authority will implement a corrective action plan that includes increased supervisory review of tenant files, enhanced file completion checklists, periodic internal quality control reviews, and additional staff training on required eligibility documentation, including consent forms, lead-based paint documentation, HAP contracts, and tenancy addenda. The Authority will also strengthen monitoring procedures to ensure missing or incomplete documents are identified and corrected timely. Management will assign responsibility for periodic file review to Housing Choice Voucher leadership and will document follow-up actions taken. These procedures are intended to improve internal controls over tenant file maintenance and ensure continued compliance with HUD requirements, Uniform Guidance, and the applicable compliance supplement. Isaiah Norris, Vice President of the Housing Choice Vouchers Program, is responsible for ensuring the deficiencies have been rectified by September 30, 2026.
Finding 2025-001 - Section 8 Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance & Material Weakness Management Response and Corrective Action Plan The Southern Nevada Regional Housing Authority (SNRHA) agrees with the audit finding and recommendation. During the audit per...
Finding 2025-001 - Section 8 Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance & Material Weakness Management Response and Corrective Action Plan The Southern Nevada Regional Housing Authority (SNRHA) agrees with the audit finding and recommendation. During the audit period, the Agency was finalizing its transition from paper files to electronic records while simultaneously establishing a dedicated Quality Control (QC) Unit. These organizational and process changes contributed to inconsistencies in file documentation, income verification procedures, and compliance monitoring. Management notes that compliance improved during the audit period, with the overall tenant file error rate decreasing from 32% in 2024 to 28.3% in 2025 and income-related errors decreasing from 21% to 11.7%. While these improvements demonstrate significant progress, SNRHA recognizes the need to further strengthen internal controls to ensure full compliance with HUD requirements and reduce the risk of future errors. The Housing Authority respectfully submits this Corrective Action Plan (CAP) in response to Finding 2025-001 concerning deficiencies in Section 8 tenant file eligibility determinations and internal controls over tenant files, identified as both noncompliance and a material weakness. Corrective Action Plan: Staffing Enhancements • One (1) Housing Programs Supervisor (Compliance) to oversee quality control, audit readiness, policy implementation, and compliance monitoring. • Two (2) Senior Occupancy Specialists (SOS) to assist with file reviews, staff mentoring, and compliance guidance. • One (1) Office Assistant (OA) to support administrative processes, document management, and workflow efficiency. These staffing enhancements will improve internal controls through increased supervision, workload distribution, and technical assistance. Target Completion Date: September 30, 2026. Quality Control (QC) Procedures • 100% QC review of all provisional (new-hires) staff files. • 100% QC review of all new admissions, lease-ups, and contract executions. • 25% monthly QC review of files processed by non-provisional staff. • Quarterly SEMAP review for overall key performance indicators • Use standardized QC checklists aligned with HUD regulations, HOTMA requirements, SEMAP indicators, and annual audit standards. • Track eligibility transactions, QC findings, corrective actions, and retraining efforts through a centralized Smartsheet system. • Issue monthly individual and departmental compliance scorecards. • Provide coaching and retraining for staff exceeding a 5% monthly error rate. Target Completion Date: Implemented and ongoing. Training and Professional Development The Authority will strengthen staff competency through structured training initiatives: • Eighteen (18) staff members will complete the Nan McKay HCV Rent Calculation Training with HOTMA requirements in July 2026 • Updated Standard Operating Procedures (SOPs) will be finalized and staff trained on: o Annual and interim reexaminations o Portability o Terminations o Moves and contracts • Staff will receive training on: o Accurate system data entry and validation procedures • The entire department will complete monthly assigned ASPIRE trainings, aligned with: o Eligibility requirements o QC findings and trends o SEMAP indicators and audit findings. • Senior Occupancy Specialists (SOS) will provide ongoing one-on-one technical assistance and timely follow-up on error corrections. Internal Controls and Process Improvements The Authority will enhance internal controls through: • Standardized workflows aligned with updated SOPs • Increased supervisory oversight of eligibility determinations • Integration of QC findings into continuous process improvements • Strengthened documentation practices to ensure audit compliance • Improved segregation of duties where applicable • Mandatory verification that EIV reports are generated, reviewed, and retained in tenant files prior to certification completion. • Verification of utility allowance calculations using the Authority's Board-approved Utility Allowance Schedule. • Monitoring inspection due dates through Yardi and management dashboards. • Reestablishment of inspection due dates within Yardi and monthly monitoring of inspection batching reports Target Completion Date: September 30, 2026 Monitoring and Oversight The Compliance Supervisor will oversee the implementation of this plan and: • Monitor QC processes and staff performance. • Analyze trends in error rates and compliance deficiencies. • Report progress to Compliance & Training Administrator. Monthly reviews of QC data will be conducted to identify systemic issues and adjust training and procedures as needed to sustain compliance. Person(s) Responsible: Rosa Elaine Garcia, Director of Housing Programs, in assistance with Compliance & Training Administrator, Housing Programs Supervisor (Compliance) and Training and Development Specialist
Non-compliance with Cash Management Requirements of the Capital Fund Program Corrective Action With the exception of Capital Fund Program grant authorizations budged for Public Housing Program operating assistance, the Authority will expend the unexpended Capital Fund Program grant proceeds held pri...
Non-compliance with Cash Management Requirements of the Capital Fund Program Corrective Action With the exception of Capital Fund Program grant authorizations budged for Public Housing Program operating assistance, the Authority will expend the unexpended Capital Fund Program grant proceeds held prior to drawing down additional funding from Capital Fund Program grants. Jebidiah Jackson, Executive Director, has assumed the responsibility of executing this corrective action as of August 1, 2026.
Insufficient Cash and Deficit of Unrestricted Net Position Corrective Action The Authority will analyze and evaluate charges and allocations to the Section 8 Housing Choice Voucher Program and budget administrative and applicable operating expenses of the Program within HUD’s administrative funding ...
Insufficient Cash and Deficit of Unrestricted Net Position Corrective Action The Authority will analyze and evaluate charges and allocations to the Section 8 Housing Choice Voucher Program and budget administrative and applicable operating expenses of the Program within HUD’s administrative funding limits. Additionally, the Authority will abstain from advancing Public Housing Program assets to the Section 8 Housing Choice Voucher Program. Jebidiah Jackson, Executive Director, has assumed the responsibility of executing this corrective action as of August 1, 2026.
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