Corrective Action Plans

Finding 1227866 (2024-005)

Material Weakness 2024

Grand Forks Homes Inc. - Lagrave Place 094-44019

ND

Internal Control / Segregation of Duties HUD Housing Programs

Contact Person – Matt Bakke, Executive Director Corrective Action Plan – The Project will review its policies and procedures over selection from waiting list. Completion Date – 12/31/26

View Audit 409797

Finding 1227862 (2024-003)

Material Weakness 2024

Grand Forks Homes Inc. - Lagrave Place 094-44019

ND

HUD Housing Programs Internal Control / Segregation of Duties Reporting § 200.512

Contact Person – Matt Bakke, Executive Director Corrective Action Plan – The Project will review its policies and procedures over timely reporting submissions. Completion Date – 12/31/26

View Audit 409797

Finding 1227790 (2024-002)

Material Weakness 2024

Housing Authority of the County of Mifflin

PA

HUD Housing Programs

MCHA has created policies to address this issue and staff have received training on how to follow it. The 2025 unaudited submission was filed in a timely manner.

View Audit 409755

Finding 1227789 (2024-001)

Material Weakness 2024

Housing Authority of the County of Mifflin

PA

HUD Housing Programs Allowable Costs / Cost Principles

MCHA has hired an independent HR consultant to review all personnel files and procedures and provide guidelines to ensure that supporting documentation exists for all payroll expenses. Additionally, new systems have been put into place with three layers of checks and balances to ensure that timeshee...

MCHA has hired an independent HR consultant to review all personnel files and procedures and provide guidelines to ensure that supporting documentation exists for all payroll expenses. Additionally, new systems have been put into place with three layers of checks and balances to ensure that timesheets match expenses. Policy has been set by board to ensure any bonuses or additional payments are board approved and no additional payments will be issued without board signature. MCHA has established allocation percentages for payroll and indirect costs in relation to units and/or time spent. All costs will be allocated on this basis. Allocations will be reviewed and updated annually and/or as changes are necessitated.

View Audit 409755

Finding 1227216 (2024-011)

Material Weakness 2024

St. Croix Chippewa Housing Authority

CA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management § 200.305

2024-011 Timely Grant Draws Material Weakness Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed. Action Taken: The Housing Authority agrees with this fi...

2024-011 Timely Grant Draws Material Weakness Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

View Audit 409362

Finding 1227213 (2024-008)

Material Weakness 2024

St. Croix Chippewa Housing Authority

CA

HUD Housing Programs

2024-008 Character Investigations Recommendation: Adopt and implement policies over the performance of character investigations, the filing of character investigations and the criteria to be used to preclude the hiring of individuals for certain positions. Action Taken: The Housing Authority agrees ...

2024-008 Character Investigations Recommendation: Adopt and implement policies over the performance of character investigations, the filing of character investigations and the criteria to be used to preclude the hiring of individuals for certain positions. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

View Audit 409362

Finding 1227212 (2024-007)

Material Weakness 2024

St. Croix Chippewa Housing Authority

CA

Eligibility HUD Housing Programs Material Weakness

2024-007 Tenant Eligibility Material Weakness Recommendation: In general, we continue to recommend a review of the re-certification process to determine areas of weakness. Specifically, we recommend the use of a standard checklist in the re-certification process. We further recommend that each re-ce...

2024-007 Tenant Eligibility Material Weakness Recommendation: In general, we continue to recommend a review of the re-certification process to determine areas of weakness. Specifically, we recommend the use of a standard checklist in the re-certification process. We further recommend that each re-certification clerk’s work be routinely audited. We also recommend more standardization in resident files organization of information, and procedures established to make sure all files are maintained adequately in order to be compliant. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

View Audit 409362

Finding 1227189 (2024-005)

Material Weakness 2024

Humboldt Park Health, Inc.

IL

HUD Housing Programs Subrecipient Monitoring Material Weakness § 200.303

Condition: Controls were not designed or implemented effectively to ensure: 1. Mortgage and escrow payments were made in accordance with the due dates and amounts specified in the executed mortgage note agreement. 2. Earnings are retained in the replacement reserve account 3. The organization comple...

Condition: Controls were not designed or implemented effectively to ensure: 1. Mortgage and escrow payments were made in accordance with the due dates and amounts specified in the executed mortgage note agreement. 2. Earnings are retained in the replacement reserve account 3. The organization completes the required financial reports in accordance with the applicable accounting basis, supported by underlying records representing the activity for the period reported. Planned Corrective Action: Management will design and implement internal controls to ensure compliance with mortgage escrow payments, reserve account funding, and quarterly financial reporting requirements, including a process to ensure that documentation of reviews is retained. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2026

View Audit 409357

Finding 1227188 (2024-004)

Material Weakness 2024

Humboldt Park Health, Inc.

IL

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Condition: The Organization did not submit the budget to HUD within 30 days of the start of its fiscal year. Planned Corrective Action: Management has implemented a new review and oversight process related to the process for the budget submissions in question to ensure timely submission on a go-forw...

Condition: The Organization did not submit the budget to HUD within 30 days of the start of its fiscal year. Planned Corrective Action: Management has implemented a new review and oversight process related to the process for the budget submissions in question to ensure timely submission on a go-forward basis. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2026

View Audit 409357

Finding 1226954 (2024-005)

Material Weakness 2024

Operation Hope of Fairfield, Inc.

CT

Questioned Costs Subrecipient Monitoring Eligibility

Management has updated the policies and procedures manual to address this finding. For each housing unit, we are using the Department of Housing and Urban Development (HUB) rent reasonableness form at lease signing. This form will be updated annually for each unit. We will also be following the HUD ...

Management has updated the policies and procedures manual to address this finding. For each housing unit, we are using the Department of Housing and Urban Development (HUB) rent reasonableness form at lease signing. This form will be updated annually for each unit. We will also be following the HUD fair market rent determinations.

View Audit 409144

Finding 1226907 (2024-005)

Material Weakness 2024

Oklahoma Water Resources Board

OK

Allowable Costs / Cost Principles Eligibility HUD Housing Programs

Finding Number 2024-005 Subject Heading (Financial) or AL no. and program name (Federal) 93.767 Children’s Health Insurance Program 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: We are using Azure DevOps to track the work related to the findings for the mentioned issues. The work...

Finding Number 2024-005 Subject Heading (Financial) or AL no. and program name (Federal) 93.767 Children’s Health Insurance Program 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: We are using Azure DevOps to track the work related to the findings for the mentioned issues. The work is being completed under User Story 455612 - PS2 | AFS | Notices | Update Medical Notices Language for CMS Audit Finding Corrective Action (2024-005). To ensure all required notice language updates are implemented accurately and consistently, OKDHS is currently utilizing an Azure DevOps tracking tool to conduct a thorough discovery and analysis of all aspects of this issue. Our primary focus is identifying every notice and process that may be impacted by this change. OHCA Response: Additional post-CAP audits will be conducted by Member Audits upon notification from OHS all corrective measures have been implemented, should occur after August 1, 2026. Anticipated Completion Date August 1, 2026 Responsible Contact Person Chris Dees, Eligibility and Coverage Services Technical Director; April Anonsen, Deputy State Medicaid Director; Aubrey McDonald, OKDHS Medicaid Program Administrator; Tana Parrott, OHCA Director of Member Audits; Kristin Edwards OHCA Senior Director of Program & Accountability

View Audit 409119

Finding 1226712 (2024-013)

Material Weakness 2024

Oklahoma Water Resources Board

OK

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Finding Number 2024-013 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES Planned Corrective Action OSDE acknowledges the audit finding. During the FY24 audit period, monitoring procedures for LEA Supplement Not Supplan...

Finding Number 2024-013 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES Planned Corrective Action OSDE acknowledges the audit finding. During the FY24 audit period, monitoring procedures for LEA Supplement Not Supplant (SNS) methodologies were identified as lacking adequate documentation and verification measures. On July 25, 2024, OSDE submitted corrective action plans to USDE, which included revisions to the ESEA Resource Toolkit, Title I Handbook, and GMS review protocols. As of April 11, 2025, USDE determined that the SNS requirements have been satisfied and confirmed that OSDE’s revised resources are consistent with federal guidance. OSDE has subsequently strengthened internal controls and improved monitoring procedures to ensure ongoing compliance of LEA SNS methodologies and supporting documentation. Anticipated Completion Date Apr-25 Responsible Contact Person Tammy Smith

View Audit 409119

Finding 1226203 (2024-004)

Material Weakness 2024

Inkster Housing Commission

MI

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

IHC has identified gaps in supporting documentation for credit card charges and has implemented measures to strengthen internal controls. Employees are now required to submit all receipts within two business days of the charge being processed. In addition, individuals who fail to submit proper docum...

IHC has identified gaps in supporting documentation for credit card charges and has implemented measures to strengthen internal controls. Employees are now required to submit all receipts within two business days of the charge being processed. In addition, individuals who fail to submit proper documentation may be held directly accountable for the charge. Monthly internal audits have been instituted to review all credit card transactions for compliance, and receipts ar now collected and verified according to established timelines. These measures ensure that all credit card activity is properly documented, monitored, and compliant with agency policies moving forward.

View Audit 408839

Finding 1226202 (2024-003)

Material Weakness 2024

Inkster Housing Commission

MI

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

IHC continues to strengthen its internal processes to reduce delinquent recertifications, guided by a board-approved Quality Assurance Plan that includes recurring file reviews, rent calculation checks, and completeness checklists.

View Audit 408839

Finding 1226201 (2024-002)

Material Weakness 2024

Inkster Housing Commission

MI

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

The IHC has experienced some major staffing transactions within its Finance Department which have caused delays in the processing of cash disbursements to vendors. Since that time, IHC has updated its Internal Control Policy and made changes to the process of paying vendors. IHC has also hired a Sr....

The IHC has experienced some major staffing transactions within its Finance Department which have caused delays in the processing of cash disbursements to vendors. Since that time, IHC has updated its Internal Control Policy and made changes to the process of paying vendors. IHC has also hired a Sr. Accountant and Accounts Receivable Specialist to ensure the process is followed accurately and timely. IHC's Finance Committee and Fee Accountant's will also provide an additional level of monitoring as we are in constant communication to ensure all current practices are compliant. IHC is confident these changes will correct ths finding moving forward.

View Audit 408839

Finding 1226200 (2024-001)

Material Weakness 2024

Inkster Housing Commission

MI

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

IHC has experienced significant staffing transitions within its finance department, which have comtributed to delays in processing cash receipts. In response, IHC has updated its Internal Control Policy and revised its processes. Additional support staff have been hired in the finance department to ...

IHC has experienced significant staffing transitions within its finance department, which have comtributed to delays in processing cash receipts. In response, IHC has updated its Internal Control Policy and revised its processes. Additional support staff have been hired in the finance department to ensure accurate and timely processing. Furthermore, IHC's Finance Committee and Fee Accountants provide and added layer of checks and balances, maintaining ongoing communication to ensure all practices remain compliant. IHC is confident that these measures will effectively address this issue moving forward.

View Audit 408839

Finding 1225611 (2024-002)

Material Weakness 2024

Net Treatment Services, Inc. D/b/a Net Community Care

PA

Internal Control / Segregation of Duties Student Financial Aid Cash Management

Type of Finding: Material Weakness in Internal Controls over Compliance- Cash Management Recommendation: We recommend that management ensure that all invoices are reviewed and approved before submission. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding....

Type of Finding: Material Weakness in Internal Controls over Compliance- Cash Management Recommendation: We recommend that management ensure that all invoices are reviewed and approved before submission. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a policy which requires each drawdown to be reviewed and to be based only on expenses incurred for the period, prohibiting the use of a straight-line calculation to draw down funds. Invoices are also approved by the CFO or CEO prior to submission. Name of the contact person responsible for corrective action: Regan Kelly, CEO of Net Treatment Services, Inc. dba: NET Community Care (215) 451-7000 Planned completion date for corrective action plan: December 31, 2026.

View Audit 408500

Finding 1224527 (2024-003)

Material Weakness 2024

Harvest Homes Corporation 094-Hd005-Np-Cmi

ND

HUD Housing Programs Internal Control / Segregation of Duties Questioned Costs § 200.512

Contact Person – Terry Hanson, Executive Director Corrective Action Plan – The Project will review its policies and procedures over timely reporting submissions. Completion Date – 12/31/26

View Audit 407778

Finding 1224360 (2024-001)

Material Weakness 2024

Center for Independent Living of North Florida Inc.

FL

Subrecipient Monitoring HUD Housing Programs Program Income

"Management concurs that stronger documentation surrounding the collection and monitoring of Continuum of Care program income would have strengthened internal controls and the audit trail. The finding relates to a program that has since been discontinued. Throughout the audit period, all program inc...

"Management concurs that stronger documentation surrounding the collection and monitoring of Continuum of Care program income would have strengthened internal controls and the audit trail. The finding relates to a program that has since been discontinued. Throughout the audit period, all program income that was collected was used for allowable program purposes; however, management acknowledges that documentation supporting assessment, collection, monitoring, and reconciliation procedures should have been more comprehensive. Although this activity is no longer part of the Organization's operations, Ability1st has strengthened its overall documentation standards. Should the Organization administer future programs involving program income, written policies and procedures will be implemented prior to program implementation and will include: • documented fee assessment methodology; • collection and deposit procedures; • reconciliation requirements; • supervisory review; • record retention standards; and • periodic internal monitoring. Management believes these procedures will provide an appropriate level of accountability and compliance with federal requirements should program income be collected in the future. Responsible Official: Executive Director Implementation Date: Completed for discontinued program; procedures will be implemented before any future program income activity."

View Audit 407668

Finding 1223694 (2024-002)

Material Weakness 2024

145 SO. 3RD STREET HOUSING DEVELOPMENT FUND CORPORATION

NY

HUD Housing Programs Eligibility

Management has implemented the following corrective actions to address the deficiencies noted in tenant file maintenance and eligibility determinations: A. Strengthening Recertification Compliance 1. Implementation of a Recertification Tracking System: a. A digital tracking log will be used to monit...

Management has implemented the following corrective actions to address the deficiencies noted in tenant file maintenance and eligibility determinations: A. Strengthening Recertification Compliance 1. Implementation of a Recertification Tracking System: a. A digital tracking log will be used to monitor upcoming recertifications with alerts at 90, 60, and 30 days before due dates. b. The Senior Housing Specialist will oversee timely completion and issue weekly progress reports to the Director of Asset Management. c. Non-compliant files will be flagged for immediate follow-up with tenants. d. PMCS, a third-party group, will assist with recertifications. 2. Enforcing Timely Recertifications: a. Recertifications must be completed no later than 30 days before expiration. b. Staff will receive monthly reminders, and escalation measures will be implemented for delays. 3. Quarterly Internal Audits: a. PMCS and internal staff will conduct random file audits every three months to ensure adherence. b. Deficiencies will be addressed in real-time, and corrective steps will be logged. B. Ensuring EIV System Compliance 1. Standardizing EIV Compliance Procedures: a. A formal checklist will be created for EIV report reviews, ensuring all required reports are generated before lease renewals. b. EIV data will be cross-referenced with tenant files every quarter to ensure completeness. 2. Internal Monthly EIV Reviews: a. The Senior Housing Specialist will generate and review EIV reports on the 1st of each month. b. The Director of Asset Management, Third-Party Compliance Officer (PMCS), and Senior Housing Specialist will verify compliance before reports are finalized. 3. Quarterly Compliance Reports: a. The Compliance Officer will submit a quarterly compliance report documenting completion rates and deficiencies. C. Enhancing Staff Training and Accountability 1. Mandatory Quarterly Training: a. Staff will undergo quarterly compliance training covering HUD Handbook 4350.3, recertifications, and EIV compliance. b. Training sessions will be documented, and staff performance assessed. 2. Clarification of Responsibilities: a. Staff roles will be clearly outlined in a Standard Operating Procedure (SOP) document. b. Staff will be required to acknowledge their roles in compliance processes. 3. PMCS Involvement for Training Support: a. PMCS will offer supplementary training sessions as needed. D. Documentation and Oversight Enhancements 1. Maintaining Complete and Auditable Files: a. All lease and EIV documentation will be stored both physically and digitally. b. A real-time compliance dashboard will track completion rates. 2. Routine Management Reviews: a. The Senior Housing Specialist and Director of Asset Management will conduct monthly spot checks to verify document accuracy and completion. b. Non-compliance will result in formal corrective actions.

View Audit 407198

Finding 1223693 (2024-001)

Material Weakness 2024

145 SO. 3RD STREET HOUSING DEVELOPMENT FUND CORPORATION

NY

Questioned Costs HUD Housing Programs Material Weakness

Management will immediately reimburse the property’s operating account for the unauthorized $10,000 distribution. Procedures will be implemented to ensure that all future loan repayments and cash distributions comply with HUD surplus cash requirements and the regulatory agreement. Surplus cash calcu...

Management will immediately reimburse the property’s operating account for the unauthorized $10,000 distribution. Procedures will be implemented to ensure that all future loan repayments and cash distributions comply with HUD surplus cash requirements and the regulatory agreement. Surplus cash calculations will be reviewed and approved prior to authorizing any distributions. Staff responsible for financial oversight will receive additional training on HUD surplus cash rules to prevent recurrence.

View Audit 407198

Finding 1223449 (2024-101)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Questioned Costs Special Tests & Provisions HUD Housing Programs § 200.303

The Program Integrity Unit has established SOPPs which identifies the method for identifying fraud cases, investigating cases, and developed procedures in collaborating and cooperating with legal authorities, for referring credible allegations of fraud cases to law enforcement officials.

View Audit 406809

Finding 1223447 (2024-099)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

During the audit period, the Department did not complete the required ADP Risk Analysis and System Security Review for systems supporting the Medicaid Program, and certain monitoring controls were not operating at a sufficient level of precision to ensure compliance with federal requirements. To add...

During the audit period, the Department did not complete the required ADP Risk Analysis and System Security Review for systems supporting the Medicaid Program, and certain monitoring controls were not operating at a sufficient level of precision to ensure compliance with federal requirements. To address this finding, the Department recently issued Requests for Qualifications (RFQs) to seven qualified vendors to perform comprehensive security risk assessments of the Medicaid Enterprise Systems (MES), including the VIBES Eligibility and Enrollment System, Provider Enrollment Application (PEA), Pharmacy Benefit Management (PBM) solution, and related supporting systems. Vendor responses are due within three weeks, after which the Department will evaluate submissions and proceed with the procurement process. The selected vendor will conduct the required risk assessments, identify control deficiencies and security vulnerabilities, and provide recommendations to strengthen the Department's security posture and compliance framework. The Department will work collaboratively with its technology partners, system vendors, and oversight entities to implement corrective actions identified through the assessments and enhance monitoring controls to ensure ongoing compliance with applicable federal requirements.

View Audit 406809

Finding 1223218 (2024-008)

Material Weakness 2024

Williston Basin Public School District #7

ND

Subrecipient Monitoring Procurement, Suspension & Debarment HUD Housing Programs § 200.303 § 200.317 § 200.318 § 200.327

2024-008 – CORONAVIRUS CAPITAL PROJECT FUND – LACK OF SUPPORT FOR PROCUREMENT – ALN 21.029 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain support surrounding the selection process for the construction management at-risk (CMAR) fo...

2024-008 – CORONAVIRUS CAPITAL PROJECT FUND – LACK OF SUPPORT FOR PROCUREMENT – ALN 21.029 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain support surrounding the selection process for the construction management at-risk (CMAR) for the CTE Center. Therefore, we were unable to determine if the CMAR selection was properly completed. In addition, Willison Basin Public School did not have a procurement policy. Management’s Response: We agree. The District will work to ensure that future projects are properly procured within state law and federal guidelines. Anticipated Completion Date: FY 2025

View Audit 406706

Finding 1222996 (2024-001)

Material Weakness 2024

Housing Authority of the City of Yakima

WA

HUD Housing Programs Reporting Internal Control / Segregation of Duties § 200.512

2024-001 Reporting – Late Report Submission to Federal Audit Clearinghouse and HUD Recommendation: Develop internal controls that provide month-end and year-end accounting close milestones that include deadlines that will ensure external reporting deadlines are able to be met. Explanation of disagre...

2024-001 Reporting – Late Report Submission to Federal Audit Clearinghouse and HUD Recommendation: Develop internal controls that provide month-end and year-end accounting close milestones that include deadlines that will ensure external reporting deadlines are able to be met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Authority has reviewed and updated its financial reporting and closing processes and controls for the preparation of the final trial balances and related schedules. As part of this process, the Authority has created a year-end checklist with deadlines and status meetings to monitor the progress. Name(s) of the contact person(s) responsible for corrective action: Lowel Kruger, Executive Director. Planned completion date for corrective action plan: December 31, 2024.

View Audit 406526

Corrective Action Plans

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