Corrective Action Plans

Name of Contact Person: Sherry Joyner, Executive Director. We will implement proper internal control procedures for the Section 8 New Construction program eligibility requirements. Immediately.

We have requested HUD approval to delay reimbursement of the reserves pending receipt of Budget Based Rent increase. We anticipate that this will be approved.

Finding 2024-002: Significant Deficiency and Noncompliance Finding, Reporting-Annual Program: Lead-Based Paint Hazard Reduction Grant Program Finding: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2022, to June 30, 2023, by January 10, 2024. Based on our testing of the required quarterly and annual reports we determined the annual report was not submitted as required. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy has been implemented with centralized tracking to monitor grant reporting deadlines and prevent missed submissions. 2. The Office of Management, Policy, and Grants is establishing a Grant Management Team to conduct a secondary review of all reporting-related entries and ensure timely submissions. These actions will be implemented by the end of the next fiscal year, with all policy updates and training completed by October 31, 2025. 3. Health Department: The Health Department and the City’s Internal Auditor are creating Standard Operation Procedures and will train staff by December 31, 2025. 4. Contacts: Shannon McCue, Director of Management, Policy, and Grants; Maritza Bond, Health Director, Anticipated Completion Date: January 2026

The Consortium is in the processes of performing these unit inspections and will ensure those inspections are properly documented in the participant’s files. Name of Contact Person Responsible for Corrective Action: Kyle Lyskawa, CFO, (315) 424-1821. Anticipated Completion Date: January 2025

2024-010 - ALN 14.850 - Public Housing Operating Fund - Special Tests and Provisions - Declaration of Trust Planned Corrective Action: The Executive Director acknowledges the finding and is following the auditor's recommendation as presented in the Audit Report. Issues are a result of prior management, and a corrective action plan is in place to address these weaknesses and deficiencies. Person Responsible for Correction of Finding: Christy Amacher, Executive Director Anticipated Completion Date: September 30, 2025

2024-009 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions - Depository Agreements Planned Corrective Action: The Executive Director acknowledges the finding and is following the auditor’s recommendation as presented in the Audit Report. Issues are a result of prior management, and a corrective action plan is in place to address these weaknesses and deficiencies. Person Responsible for Correction of Finding: Christy Amacher, Executive Director Anticipated Completion Date: September 30, 2025

2024-008 – ALN 14.872 – Public Housing Capital Fund Program – Reporting Planned Corrective Action: The Executive Director acknowledges the finding and is following the auditor’s recommendation as presented in the Audit Report. Issues are a result of prior management, and a corrective action plan is in place to address these weaknesses and deficiencies. Person Responsible for Correction of Finding: Christy Amacher, Executive Director Anticipated Completion Date: September 30, 2025

Planned Corrective Action: The Executive Director acknowledges the finding and is following the auditor’s recommendation as presented in the Audit Report. Issues are a result of prior management, and a corrective action plan is in place to address these weaknesses and deficiencies. Person Responsible for Correction of Finding: Christy Amacher, Executive Director Anticipated Completion Date: September 30, 2025

Name of Contact Person: Lynn Alligood, Executive Director Corrective Action: We will implement proper internal control procedures for the Public and Indian Housing program eligibility requirements. Immediately.

Name of Contact Person: Lynn Alligood, Executive Director Corrective Action: We will implement proper internal control procedures for the Section 8 New Construction program eligibility requirements. Immediately.

Finding 2024-002 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Passed through Hearth Connections and Passed through Dakota County, Continuum of Care. Assistance Listing Number: Federal Financial Assistance Listing #14.267 Program Name: Continuum of Care Program Finding Summary: Guild’s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Corrective Action Plan: This clinical program is now under new leadership and is enhancing its controls and oversight. In addition to requiring a monthly rent checklist to be reviewed and signed off by the responsible official, an additional layer of control will be implemented by involving Finance in verifying that proper documentation is in place before rent checks are issued. The program, in collaboration with Finance, will also continue enhancing the approach to standardized documentation. Responsible Individuals: Keith Rachey - Chief Financial Officer, Tiffany Yang – Controller, Diana Harris – Director of Clinical Services Anticipated Completion Date: Completed by September 2025

2024-002 – REPORTING Auditee’s Response and Planned Corrective Action The Executive Director will work with the Fee Accountant in order to review and enhance year end close processes to ensure accuracy and timeliness of reporting. Planned Implementation Date of Corrective Action: June 30, 2025 Person Responsible for Corrective Action: Anne Marie Burns, Executive Director

2024-009. SEMAP Supporting Documentation Corrective action planned: Revised control procedures and checklist system for future SEMAP submissions with backup file requirements. Updated ADMIN plan to enforce Quality Assurance procedure, to be performed quarterly. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipated completion date: May 31, 2025/ Ongoing Monitoring

2024-008 Tenant Files – Housing Choice Vouchers Corrective action planned: Staff retrained on HUD requirements. Standard audit process implemented for incoming and annual recertifications. Quarterly file reviews and a new checklist for income verification implemented. Contact person: Candice Ivory, Executive Director / Deputy Director Anticipated completion date: July 31, 2025/ Ongoing Monitoring

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425U, 84.425W Recommendation: CLA recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases, along with adding controls to ensure that the item purchased was received by the District. CLA also recommends the District review its payroll process and identify payroll tasks that could be reassigned to other district personnel or consider implementing additional review procedures specifically focused on payroll and related fringe benefit costs claimed on federal and state grants. CLA also recommends the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting including special reports. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: District staff will accumulate as much of the information required for federal and state awards as we can and reconcile the revenue and expenditures information to the general ledger for these awards. Name(s) of the contact person(s) responsible for corrective action: Adrian Foster, Brooke Rosemeyer Planned completion date for corrective action plan: Ongoing.

Recommendation: The Commission should consider reviewing its current policy regarding rent certifications. The Commission should ensure all persons involved in the certification process are properly trained and understand regulations in order to accurately identify errors. Additionally, the Commission should implement a thorough second party review of annual certifications to verify accuracy. Action Taken: Management will implement stronger controls over tenant files including a more thorough second party review. Anticipated Completion Date of Action: August 31, 2025.

Management concurs with the auditor’s findings and recommendations. The Management Agent has been in the process of working with the bank to move these funds into interest-bearing accounts for the past two years, however based on interest rates during this time the bank fees would have exceeded the interest earned on these accounts and it was not prudent of the project to move the accounts. The Management Agent will continue to monitor the accounts going forward and will move the accounts into interest-bearing accounts when it makes financial sense to do so.

Management concurs with the auditor’s findings and recommendations. Based on communications between the Management Agent and the HUD account executive, the Management Agent believes that HUD intends for these funds to be spent on the Project in future years and does not believe that remittance of these funds is required at this time.

Contact Person Larissa Deedrich, Executive Director Corrective Action Plan Management has reviewed control processes and assigned staff to perform necessary controls over the reconciliation of HAP expenses. Planned Completion Date for CAP September 30, 2025

Contact Person Larissa Deedrich, Executive Director Corrective Action Plan Management has reviewed control processes and assigned staff to perform necessary controls over the reconciliation of HAP expenses. Planned Completion Date for CAP September 30, 2025

Contact Person Larissa Deedrich, Executive Director Corrective Action Plan Management has begun the process of creating a quality control plan to ensure that all HQS inspections and abatements are monitored. Staff have been trained on when to properly abate a payment and how to properly document abatements. Planned Completion Date for CAP September 30, 2025

Contact Person Larissa Deedrich, Executive Director Corrective Action Plan Management has begun the process of creating a quality control plan to ensure that all files are accurate and follow all local, state and federal compliance guidelines. Planned Completion Date for CAP September 30, 2025

2024-004 Housing Choice Voucher Waiting List: Special Tests and Provisions Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Statement of Condition: Out of a total population of approximately 258 applicants, 25 applicants were selected for testing, and the following errors were discovered. • 1 applicant file had the following error: o The applicant was incorrectly awarded local preference points. Removing these points would drop their waiting list rank from #54 to #258. However, this issue would have likely been identified and corrected during the routine verification of preference points, which occurs when an applicant is pulled from the waiting list. • 1 applicant file had the following error: o The applicant was incorrectly awarded working preference points. Removing these points would drop their waiting list rank from #64 to #245. However, this issue would have likely been identified and corrected during the routine verification of preference points, which occurs when an applicant is pulled from the waiting list. • 1 applicant file had the following error: o The applicant selected the local preference point, but was not awarded the local preference point. Correcting this issue would change the applicant’s ranking on the waiting list from #114 to #6. Nonetheless, it’s likely that the applicant would have been pulled from the waiting list at the correct time regardless of whether the applicant is ranked #114 or #6, since the Authority selects a large pool of applicants. • 1 tenant file had the following error: o The applicant selected the victim of domestic violence preference point, but was not awarded the preference point. Correcting this issue would change the applicant’s ranking on the waiting list from #124 to #2. Nonetheless, it’s likely that the applicant would have been pulled from the waiting list at the correct time regardless of whether the applicant is ranked #124 or #2, since the Authority selects a large pool of applicants. • 1 tenant file had the following error: o The applicant selected the local preference point, but was not awarded the local preference point. Correcting this issue would change the applicant’s ranking on the waiting list from #174 to #10. Nonetheless, it’s likely that the applicant would have been pulled from the waiting list at the correct time regardless of whether the applicant is ranked #174 or #10, since the Authority selects a large pool of applicants. Recommendation: The Authority should provide ongoing staff training on accurate data entry and documentation requirements for preference points assigned to applicants on the waiting list. In addition, the Authority should implement a quality control review process to ensure preference points are appropriately assigned. This could involve a second staff member reviewing a sample of applicant entries for accuracy of preference point awarded. Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants. The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being sent to the Compliance Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the Counselor handling specialty vouchers, will attend Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam during the next 24 months, as budget permits. Effective Date: June 19, 2025 Contact Information Gwendolyn B. Dawson, CEO Ocala Housing Authority 1629 NW 4th Street Ocala, Florida 34475 (352) 369-2636

2024-003 Housing Choice Voucher Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters This is a repeat finding of 2023-002 from September 30, 2023 (Originally reported as Material non-compliance and Material Weakness in Internal Control over Compliance under finding 2019-001 from September 30, 2019) Statement of Condition: Out of a total tenant population of approximately 1,118 vouchers, 25 files were selected for testing, and the following errors were discovered. • 2 tenant files had the following error: o The HAP contract in the tenants’ file was not signed by a representative of Ocala Housing Authority. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will decrease the Housing Assistance Payment by $4. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $23. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $7. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates for a 1-bedroom unit. The 2024 utility allowance rates for a 2-bedroom unit should have been used. Correcting this error will increase the Housing Assistance Payment by $20. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants. The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being sent to the Compliance Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the Counselor handling specialty vouchers, will attend Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam during the next 24 months, as budget permits.

2024-002 Public Housing Tenant Files: Eligibility Program: U.S. Department of HUD: Public and Indian Housing Program (ALN #14.850) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Statement of Condition: We tested 19 out of approximately 181 tenant files and discovered the following errors: • 1 tenant file had the following error: o A dependent of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the dependent’s birth certificate, the dependent is a U.S. citizen. • 1 tenant file had the following error: o The tenant’s childcare income was calculated and reported incorrectly on the 50058 form in the amount of $2,472. Correcting the tenant’s childcare income to $2,237 would decrease the tenant’s rent by $6. • 1 tenant file had the following error: o Support for the tenant’s wage income could not be located. It’s unknown as to whether the tenant’s wage income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly. • 1 tenant file had the following error: o The tenant’s social security income was carried forward from the prior year in the amount of $11,172. Correcting the tenant’s social security income to $12,144 for the annual recertification period tested, would increase the tenant’s rent by $25. • 1 tenant file had the following error: o The tenant’s social security income was carried forward from the prior year in the amount of $12,456. Correcting the tenant’s social security income to $13,548 for the annual recertification period tested, would increase the tenant’s rent by $27. • 1 tenant file had the following error: o The tenant’s other source income of $720 was carried forward from the prior year. The tenant’s income was not updated for the annual recertification and it’s unknown as to whether the tenant’s other source income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and a PH Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. Management will monitor and review counselor’s strength and weaknesses and determine if additional training and/or monitoring is needed.