Corrective Action Plans

Finding 516115 (2024-002)

None 2024

HI

Student Financial Aid Internal Control / Segregation of Duties

Finding No. 2024-002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $ - Responsible Individual: Davileigh Naeole, Financial Aid Director Date Action Taken: November 12, 2024 To address...

Finding No. 2024-002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $ - Responsible Individual: Davileigh Naeole, Financial Aid Director Date Action Taken: November 12, 2024 To address the auditor’s findings and ensure timely processing of unofficial withdrawals, our strategy will be to implement an internal deadline in our office of 20 days for determining withdrawal dates, ahead of the 30-day required deadline. This will provide a buffer to manage delays and ensure compliance.

View Audit 333933

Finding 516114 (2024-001)

None 2024

University of Hawaii

HI

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding No. 2024-001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $ 876 Responsible Individual: James Oshiro, Financial Aid Director Date Action Taken: August 15, 2024 This finding is...

Finding No. 2024-001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $ 876 Responsible Individual: James Oshiro, Financial Aid Director Date Action Taken: August 15, 2024 This finding is a result of a student return of Title IV funds after the R2T4 calculation was completed. At UH- West Oʻahu, student returns are returned by the university on the student’s behalf. With this finding, the student return portion of the R2T4 calculation was simply overlooked and was not returned to the federal government in a timely manner. A new staff member also took over the R2T4 duties about a year and a half ago. Once the student return was identified as not returned (nor failed to notify the student to repay the grant overpayment), the return was immediately completed and a full review of all R2T4 withdrawals for the award year was completed for any additional occurrences. There were no other student returns which was not completed. To prevent any future overlooked student returns, an R2T4 checklist was created to review the numerous steps in the R2T4 process in order to check ourselves.

View Audit 333933 Questioned Costs: $1

Finding 516073 (2024-002)

Significant Deficiency 2024

Maria L. Varisco-Rogers Charter School

NJ

Student Financial Aid Cash Management Internal Control / Segregation of Duties

In response to the indings from the Collaborative Federal Monitoring (CFM) Audit that was conducted on the Federal grants funding in FY 24, MLVR Charter school will be submitting a CFM CAP to homeroom. The CAP will address the following: ...

In response to the indings from the Collaborative Federal Monitoring (CFM) Audit that was conducted on the Federal grants funding in FY 24, MLVR Charter school will be submitting a CFM CAP to homeroom. The CAP will address the following: 1. Reimbursement requests will be submitted at a minimum quarterly otherwise every two months. 2. Accounting software is updated and reviewed to ensure budgeted amounts and carryover funds are properly recorded throughout the fiscal year.

View Audit 333875

Finding 516064 (2024-004)

Significant Deficiency 2024

Edgecombe County

NC

Eligibility Internal Control / Segregation of Duties

Finding: 2024-004 Inaccurate Information Entry Finding: 2024-005 Inaccurate Resource Calculation Finding: 2024-006 Inadequate Request for Information Corrective Action: Application checklist updated to include a list of persons in the household, a line item also added to ask if changes have been app...

Finding: 2024-004 Inaccurate Information Entry Finding: 2024-005 Inaccurate Resource Calculation Finding: 2024-006 Inadequate Request for Information Corrective Action: Application checklist updated to include a list of persons in the household, a line item also added to ask if changes have been applied in NCFAST. A line item was also added to list the children in the home and request for IV-D referral if applicable. Medicaid Supervisors and Quality Control workers will review files internally prior to approval or denial of a case to ensure that verifications match the evidence in NCFAST and changes have been applied to the cases. This will serve as a second check to catch things prior to the case being completed. MA-3300 Income training will be conducted with all workers. Corrective Action: Application checklist updated to include a line item to check to see if the bank account information in evidence matches what shows in determinations. Caseworkers will be trained to enddate old evidence and start a new evidence for a new period to show when the information has been updated. Medicaid Supervisors and Quality Control workers will review files internally to ensure verifications received and put into evidence matches information in determinations once an eligibility check has been ran. They will also ensure that changes have been applied. Proposed Completion Date: Training and implementation of additional reviews and procedures will be implemented by January 15, 2025.

View Audit 333850

Finding 516063 (2024-003)

Significant Deficiency 2024

Edgecombe County

NC

Eligibility Internal Control / Segregation of Duties

Finding: 2024-003 IV-D Non-Cooperation Edgecombe County County Administration Building 201 St. Andrew St., PO Box 10 Tarboro, NC 27886 252-641-7834 ∙ Fax 252-641-0456 www.edgecombecountync.gov For the Year Ended June 30, 2024 Corrective Action Plan Edgecombe County, NC Proposed Completion Date: June...

Finding: 2024-003 IV-D Non-Cooperation Edgecombe County County Administration Building 201 St. Andrew St., PO Box 10 Tarboro, NC 27886 252-641-7834 ∙ Fax 252-641-0456 www.edgecombecountync.gov For the Year Ended June 30, 2024 Corrective Action Plan Edgecombe County, NC Proposed Completion Date: June 30, 2024 Name of contact person: Linda Barfield, Chief Financial Officer Corrective Action: The budget variance in Debt Service stemmed from the reclassification of lease and subscription expenses originally budgeted at the departmental level. For financial reporting purposes, ease and subscription principal payments were reclassed to debt service to ensure accurate reporting. While the original departmental budgets were within approved limits, the reclassification affected the Debt Service budget after the fiscal year ended. FY24 is the first year of implementation of GASB 96 for subscriptions and the second year of GASB 87 for leases. The impacts of both these GASBs, was not fully known at the time the budget was adopted. The County will make the necessary budget amendments to FY25 budget before the end of the fiscal year to align the budget with anticipated financial reporting. Additionally, the County implemented additional review procedures to monitor such reclassifications closely and will continue to assess our budget tracking processes to prevent similar instances in future periods. Section II. Financial Statement Findings Proposed Completion Date: June 30, 2024 Name of contact person: Linda Barfield, Chief Financial Officer Corrective Action: The County initiated a rate study to assess the adequacy of our current rate structure in supporting both operating expenses and debt service obligations. The rate study analysis is still being finalized, so the impact to the rates is not yet known. The County plans to carefully consider adjustments or operational improvements based on the study’s findings to ensure compliance with bond covenants. Section III - Federal Award Findings and Question Costs Name of contact person: Brandy Dawes and Tina Radford, Medicaid Supervisors. Denise McKnight, Social Services Program Administrator Corrective Action: Application checklist updated to include line items to list all children in the household and absent parents. This list will ensure that the workers include IV-D referrals for all children when a parent is receiving benefits. Medicaid Supervisors and Quality Control workers will review files internally to ensure policy is applied to all cases and that the evidence entered into NCFAST and shows that a IV-D referral have been sent to Child Support.

View Audit 333850

Finding 515973 (2024-001)

Significant Deficiency 2024

New Mexico Land Conservancy

NM

Questioned Costs Cash Management Internal Control / Segregation of Duties

Planned Corrective Action: We agree with this finding and will create and implement additional internal controls to allow for tracking of actual payroll taxes incurred for labor charged to the award ensuring that only costs incurred are billed. Anticipated Completion Date: January 31, 2025. Res...

Planned Corrective Action: We agree with this finding and will create and implement additional internal controls to allow for tracking of actual payroll taxes incurred for labor charged to the award ensuring that only costs incurred are billed. Anticipated Completion Date: January 31, 2025. Responsible Contact Person: Megan Keller, Director of Finance and Operations

View Audit 333770 Questioned Costs: $1

Finding 515856 (2024-002)

Material Weakness 2024

Housing Authority of the City of Raleigh

NC

HUD Housing Programs Subrecipient Monitoring Material Weakness

Finding 2024-002 – Housing Choice Voucher Program – Internal Control over Waiting List – Noncompliance and Material Weakness - Housing Choice Voucher Program – ALN 14.871 Corrective Action Plan: Tenant Selection from Waiting List RHA has implemented its corrective action plan identified in the respo...

Finding 2024-002 – Housing Choice Voucher Program – Internal Control over Waiting List – Noncompliance and Material Weakness - Housing Choice Voucher Program – ALN 14.871 Corrective Action Plan: Tenant Selection from Waiting List RHA has implemented its corrective action plan identified in the response to the previous audit’s findings, including state-of-the-art YARDI waiting list management software and simplifying admissions preferences. By updating the waiting lists using the new software, the waiting lists are far more manageable now with less than 2,000 active applications. In addition, implementation of YARDI’s Application and Applicant portal have eliminated the need to use mistake-prone strategies like spreadsheets. The entire process is automated and simpler to use. Continued implementation of the software, including educating our applicants (and participants) will eliminate previous instances of noncompliance. RHA will monitor and conduct quality control measures to ensure full compliance. Anticipated Date of Completion. Implementation of all corrective actions are complete. RHA anticipates that it will be in compliance by the end of the current fiscal year—March 31, 2025. Person Responsible: Priscilla Batts, HCV Director, is principally responsible and accountable for the outcome above.

View Audit 333725

Finding 515855 (2024-001)

Material Weakness 2024

Housing Authority of the City of Raleigh

NC

HUD Housing Programs Eligibility Material Weakness

Finding 2024-001 – Housing Choice Voucher Program Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Material Weakness - Housing Choice Voucher Program – ALN 14.871 Corrective Action Plan: Timeliness of Annual Recertifications RHA has implemented all strategies ident...

Finding 2024-001 – Housing Choice Voucher Program Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Material Weakness - Housing Choice Voucher Program – ALN 14.871 Corrective Action Plan: Timeliness of Annual Recertifications RHA has implemented all strategies identified in the Corrective Action Plan in response to the previous audit’s finding regarding later annual recertifications, including, but not limited to: • Competitive compensation to attract and retain qualified employees. • Housing Choice Voucher Certification and other training to enhance RHA’s ability to comply with HUD regulations. • Reorganization of the department to implement case management to replace conveyor-belt style approach to annual recertifications to inject greater accountability for outcomes. • Improved supervisor to employee ratios to ensure that managers have reasonable supervisory loads (maximum of 1 TO 6). • Implementation of YARDI software to increase efficiency of our annual recertification processes. In addition to these corrective action strategies, RHA has also implemented state of the art information tools to track recertifications, measure timeliness and completion performance, and motivate staff and teams to perform at the highest level. The results of these efforts are in line with the expectation that was included in the previous corrective action plan: Anticipated Completion Date: These are mainly system changes that will be fully implemented in 2024, for example, new software, with significant improvements that will be evidenced by December 31, 2024. The results so far in December 2024 have exceeded expectations. For example, • As of December 1, 2024, 87% of recertifications with an effective date of January 1, 2025, had been completed. • As of December 16, 2024, 94% had been completed. • As of December 16, 2024, 73% of recertifications with a due date of January 1, 2025, and an effective date of February 1, 2025, have been completed. Our goal is to complete 90 to 95% by the due date, allowing for cases where participants are late in submitting their information. Having completed all corrective action strategies and plans, RHA expects results that will be in full compliance with completing annual recertification by their due date by July 31, 2025. Person Responsible: Priscilla Batts, HCV Director, is principally responsible and accountable for the outcome above.

View Audit 333725

Finding 515852 (2024-003)

Significant Deficiency 2024

La Habra City School District

CA

Subrecipient Monitoring Reporting Significant Deficiency

The District had new staff and reporting documentation was not compiled in order to reconcile the amounts. Moving forward all documentation will be kept by two fiscal team members. The District was never notified by the California Department of Education or the Auditors that there was an obligation...

The District had new staff and reporting documentation was not compiled in order to reconcile the amounts. Moving forward all documentation will be kept by two fiscal team members. The District was never notified by the California Department of Education or the Auditors that there was an obligation to correct prior year FTE amounts in the next reporting period and therefor this has not yet been corrected. During the next open reporting period, the District will recreate all of the FTE reports and enter new data as required by the Audit team.

View Audit 333724

Finding 515849 (2024-003)

Material Weakness 2024

Independent School District 2170

MN

Internal Control / Segregation of Duties Special Tests & Provisions

2024-003 FINDING Contact Person – Shane Tappe, Superintendent Corrective Action Plan – The District will review and update processes over wage rate requirements, to ensure all certified payrolls are reviewed to ensure wages are paid according to federal wage rates. Completion Date – December 20, 202...

2024-003 FINDING Contact Person – Shane Tappe, Superintendent Corrective Action Plan – The District will review and update processes over wage rate requirements, to ensure all certified payrolls are reviewed to ensure wages are paid according to federal wage rates. Completion Date – December 20, 2024

View Audit 333718

Finding 515847 (2024-003)

Significant Deficiency 2024

University of Mount Olive, Inc.

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Name of Responsible Individual: Ms. Terri Grice Corrective Action: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS. Anticipated Completion Date: Decem...

Name of Responsible Individual: Ms. Terri Grice Corrective Action: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS. Anticipated Completion Date: December 13, 2024

View Audit 333710

Finding 515845 (2024-002)

Significant Deficiency 2024

University of Mount Olive, Inc.

NC

Cash Management Internal Control / Segregation of Duties

Name of Responsible Individual: Mr. Jay Rebman Corrective Action: Financial Aid and the Controller's Office have implemented a bi-weekly reconciliation process to ensure that any excess funds are disbursed or returned via G5 within the 10 day window. Anticipated Completion Date: December 9, 2024

View Audit 333710

Finding 515824 (2024-002)

Significant Deficiency 2024

Glen Oaks Community College

MI

Special Tests & Provisions Student Financial Aid Significant Deficiency

2024-002 – Return of Title IV Calculation. Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Winter 2024 semester, which resulted in the calculation being incorrect for all students who had returns in t...

2024-002 – Return of Title IV Calculation. Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Winter 2024 semester, which resulted in the calculation being incorrect for all students who had returns in the Winter 2024 semester. As a result of this condition, Return of Title IV calculations were incorrect for five students for the Winter 2024 semester, resulting in $66.52 in excess funds returned to the U.S. Department of Education. It is our understanding that on August 14, 2024, the College repaid the five students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem from arising in the future, the College has developed a review process where the Director of Financial Aid will review break day regulations in the FSA handbook and verify that the Ellucian Colleague annual set-up has accurate break days. The Director of Financial Aid will also verify accuracy as calculations are processed for students. Responsible Party. Jean Zimmerman, Director of Financial Aid. Anticipated Completion Date. August 14, 2024.

View Audit 333681

Finding 515804 (2024-001)

Significant Deficiency 2024

Ashland County Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregationof duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size.

View Audit 333671

Finding 515798 (2024-002)

None 2024

Rannie Webster Foundation

NH

Cash Management HUD Housing Programs Internal Control / Segregation of Duties

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Other Matters Recommendation: CLA recommends the organization develops and enforces a policy requiring the independent approval of all bank reconcili...

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Other Matters Recommendation: CLA recommends the organization develops and enforces a policy requiring the independent approval of all bank reconciliations on a monthly basis. Explanation of disagreement with audit finding: Management is in agreement with the finding. Action taken in response to finding: Beginning in December 2023, Webster began implementing Silverstone Living's policy regarding bank reconciliation preparation and approval. Bank reconciliations are prepared on a monthly basis by the Business Office Manager or the Assistant Controller and reviewed by the CFO. Name of the contact person responsible for corrective action: Janet Langlois, CFO Planned completion date for corrective action plan: December 31, 2023.

View Audit 333666

Finding 515797 (2024-001)

Significant Deficiency 2024

Rannie Webster Foundation

NH

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Significant Deficiency in Internal Control over Compliance Recommendation: CLA recommends the organization develops and enforces a policy requiring t...

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Significant Deficiency in Internal Control over Compliance Recommendation: CLA recommends the organization develops and enforces a policy requiring the approval of all invoices before payment. Explanation of disagreement with audit finding: Management is in agreement with the finding. Action taken in response to finding: Starting in April 2024, Webster began implementing Silverstone Living's invoice approval policy. The authorized signers for invoices are the Executive Director, the CFO, and the department heads. Name of the contact person responsible for corrective action: Janet Langlois, CFO Planned completion date for corrective action plan: April 30, 2024.

View Audit 333666

Finding 515782 (2024-008)

Significant Deficiency 2024

Housing Opportunities Commission of Montgomery County, MD

MD

Questioned Costs HUD Housing Programs Significant Deficiency

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action ...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will ensure that move-outs are processed promptly to prevent assistance payments from being requested for vacant units. The Regional Property Manager will oversee the completion and review of end-of-month checklists to confirm that all monthly tasks have been addressed, thereby minimizing the likelihood of this exception occuring in the future. Effective immediately, HOC’s PM Compliance Manager will ensure that move-outs are processed in a timely manner and will review monthly reports to confirm that esident terminations are handled accurately. For both HOC and Pratum, the HOC team will incorporate any open move-out and move-in actions into the monthly review of past-due certifications as part of the report. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum and HOC have immediately implemented the corrective actions as outlined above. Both discrepancies have been resolved. The HOC team will include open move-in and move-out actions within the report effective November 2024. If the U.S. Department of Housing and Urban Development has questions regarding this schedule, please call Timothy Goetzinger, Senior Vice President, Finance / Chief Financial Officer at (301) 949-4690.

View Audit 333618 Questioned Costs: $1

Finding 515781 (2024-007)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken ...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will review certifications to ensure that any necessary corrections are made so that the correct utility allowance is reflected on the HUD-50059. Management will also ensure that, going forward, site staff review the HUD-50059 utility allowance amounts for accuracy against the approved rent schedule. Additionally, Pratum will ensure that any certifications completed in advance of the Gross Rent Increase are corrected as needed to accurately reflect the correct utility allowance on the HUD-50059. HRD will review and update utility allowances currently in use, comparing them against the latest HUD-approved MOD Rehabilitation gross rent schedule. HRD and HOC Compliance team will develop or update policies and procedures to ensure that utility allowances are verified and updated as required by HUD. The training manager will conduct training sessions for relevant staff members on the utility allowance requirements and how to update them in HRD’s system of record database. As a preventive action, HRD’s management will establish a quarterly file review procedure to ensure that the utility allowances align with the HUD utility allowance approval. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC, Ali Ozair, Vice President of Property Management with HOC and Lynn Hayes, Vice President of Housing Resources Division with HOC. Planned completion date for corrective action plan: Pratum has immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. HRD has immediately implemented and will have the corrections to the impacted and future files completed by December 31, 2024.

View Audit 333618

Finding 515780 (2024-006)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in res...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will review certifications to ensure that any necessary corrections are made so that the correct contract rent is reflected on the hUD50059. Moving forward management will ensure that site staff review the HUD-50059 contract rent amounts for accuracy against the approved Rent Schedule. Additionally, Pratum will ensure that certifications are completed early, ahead of any Gross Rent Increase, and that affected certifications are corrected as needed to reflect the correct contract rents on the HUD-500-59. Pratum will also ensure that rent change letters are provided as required, with a copy retained in the resident file along with the certification. Furthermore, management will ensure that a copy of the rent change letter is uploaded to Yardi, along with the completed certification, the completed unit inspection form, and the notification letters for HQS annual inspection scheduling. Lastly, Pratum will review the reference tenant file and provide a copy of the HUD-50059 and rent change form for review. Management will ensure that these documents are retained in the resident file and uploaded to Yardi upon completion of all further certifications. The HOC compliance team will focus on conducting site visits for the Project Based Rental Assisted properties following the same guidelines used for the annual financial audit. The goal is to perform a 100% file review for properties with 25 or less units and a 50% file review for properties with more than 25 units. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. The HOC compliance team will start site visits by January 2025 and will review files from the start of the fiscal year.

View Audit 333618

Finding 515779 (2024-005)

Significant Deficiency 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Eligibility Reporting

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner Explanation of disagreement with audit finding: There is no disagre...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previously,Pratum was responsible for completing the certifications and the HOC team was responsible for transmitting the certifications through TRACS. Effective October 1 2024, Pratum assumed responsibility of ensuring that all certifications are transmitted to TRACS in alignment with the HAP reported date. The Regional Property Manager will conduct monthly reviews of HAP and TRACS submissions to ensure accuracy. HRD staff will provide weekly internal staff training to correct PIC errors and procure additional training from a third party consulting company.. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Lynn Hayes, Vice President of Housing Resources. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. The HRD team has corrected the errors and will attempt to secure training from a consultant company no later than March 31, 2024.

View Audit 333618

Finding 515778 (2024-004)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreem...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum has implemented a policy requiring annual inspections to align with annual recertifications, ensuring compliance with HUD policies. Pratum Regional Property Managers will verify that all annual inspections and their corresponding forms are completed and properly filed in each resident's file. Additionally, a copy of the completed unit inspection form will be uploaded to Yardi along with the certification acket. Pratum will also ensure that all documentation related to scheduled HQS inspections is filed in the resident file and uploaded to Yardi, along with the completed unit inspection form. HOC’s PM Division has engaged an inspection vendor, Gilson Housing Partners, to conduct all annual inspections for the HOC managed properties. The inspections will begin on December 1, 2024 with PBRA communities being the priority. They will complete approximately 150 inspections per month and utilize Yardi Maintenance IQ for record keeping. The results of each inspection will be entered into the system by Gilson and HOC’s Maintenance and PM will have the responsibility of addressing all work.This partnership will ensure that all inspections are completed on schedule and meet the necessary standards. The Compliance team will continue to conduct bi-monthly quality control reviews for the HOC managed properties, after which relevant parties will convene to discuss corrective actions and training opportunities. This interactive process aims to ensure that discrepancies are addressed and corrected effectively. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. HOC’s third party inspections vendor will begin inspecting units no later than December 1, 2024 and perform annual inspections moving forward.

View Audit 333618

Finding 515777 (2024-003)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Eligibility Material Weakness

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There ...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC’s third-party management agent, Pratum Companies, will ensure that all site staff with access to files complete the "Intro to Affordable Housing" training hosted by Pratum Compliance within the next 60 days. Pratum will also mandate that Regional Managers conduct random quarterly reviews of move-in files and annual recertifications. Furthermore, Regional Compliance Managers will perform spot checks and file reviews throughout the year. Currently, every move-in file is reviewed by Pratum’s corporate Compliance team for program compliance, with Community Managers conducting an initial review before submission to the compliance team for final approval. Pratum will ensure that each recertification packet includes a completed application, documentation of income, assets, expenses, and an executed recertification checklist. Additionally, Pratum will generate and send reminder letters at 120, 90, 60, and 30 days to all households to minimize late annual recertifications. The Pratum Regional Managers and the Vice President of Operations will provide oversight and conduct weekly check-ins with the team to assess progress and completion of tasks. Regional Property Managers will review all corrective actions to ensure accuracy. A tracking spreadsheet will be maintained and reviewed during these weekly check-ins. This information will also be shared with the HOC compliance team during the monthly compliance and operations meetings to ensure alignment and transparency. HOC’s Property Management Division now has a Compliance Manager who has updated the internal review process to mandate that all new move-ins and annual recertifications include a completed application, documentation of income, assets, expenses, and an executed recertification checklist. The HOC compliance team will focus on conducting site visits for the Project Based Rental Assisted properties following the same guidelines used for the annual financial audit. The goal is to perform a 100% file review for properties with 25 or less units and a 50% file review for properties with more than 25 units. The Compliance team will continue to conduct bi-monthly quality control reviews for the HOC managed properties, after which relevant parties will convene to discuss corrective actions and training opportunities. This interactive process aims to ensure that discrepancies are addressed and corrected effectively. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions outlined above and is committed to correcting all specific discrepancies by March 31, 2025. The HOC compliance team will start the site visits in January 2025 and will review files from the start of the fiscal year. The PM Division has begun the updated internal review process outlined in the corrective action and has committed to correcting the discrepancies by November 30, 2024.

View Audit 333618

Finding 515772 (2024-002)

Significant Deficiency 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Eligibility Significant Deficiency

Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. Explanation of disagreement with audit finding: There is...

Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective September 2024, the HOC compliance team significantly enhanced the quality control review process to proactively identify SEMAP findings and eligibility discrepancies before the end of each fiscal year. Staff anticipates that this proactive approach will facilitate early identification of training needs on a more frequent basis, ensuring compliance standards are met while also improving overall program effectiveness. Additionally, HRD staff will identify and address systemic findings during monthly staff meetings. To further support these efforts, HOC enlisted a third-party consulting firm to provide training to new and existing staff in October 2024. Staff were trained on eligibility, portability and SEMAP requirements. Additional HOTMA training is scheduled on 11/6/24 - 11/7/24. Moreover, HOC will continue to procure recurring training based on systemic quality control findings prior to the end of the fiscal year. This comprehensive approach will ensure that staff are well-equipped to address any challenges and enhance overall compliance and effectiveness. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division and Darcel Cox, Vice President of Compliance. Planned completion date for corrective action plan: Staff training commenced October 2024 and will continue throughout the fiscal year.

View Audit 333618

Finding 515771 (2024-001)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

Questioned Costs HUD Housing Programs Material Weakness

Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with...

Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Housing Opportunities Commission (“HOC”) and Yardi, software vendor, recently identified a glitch in the system that led to the omission of several inspections. HOC met with Yardi to resolve this issue and autocorrect excluded units. HOC will generate new reports that will accurately identify all residents requiring inspections within 12 months of their last inspection. Effective immediately, staff will generate and review a monthly report of abatements to cancel any HAP contracts that have been in abatement for more than 30 days and assist clients in relocating to another unit. Tenants with units in abatement will receive a 60-day notice of the proposed termination, which will include a relocation packet to initiate the voucher re-issuance process. Staff will hold the termination in abeyance for 30 days if the landlord addresses the cited repairs. Additionally, the Program Manager will conduct a quality control review of 5% of the files for abated units. Both HRD and Gilson, a third party inspection vendor, faced strain due to the high volume of backlogged and current inspections. To mitigate this, the following actions have been implemented: -HRD and Gilson hired additional back-office staff to monitor and manage the workload. -Gilson has cross-trained staff to handle inspection caseloads in the event of staff shortages. -HRD has designated internal staff members to monitor abatements and ensure that re-inspections occur within the required timeframes. These measures aim to improve efficiency and ensure timely processing of inspections. As part of the bi-monthly quality control review, the Compliance team will include an assessment of the abatement report, identifying any units that have been in abatement for over 30 days. The Compliance team will continue to conduct bi-monthly quality control reviews, after which relevant parties will convene to discuss corrective actions and training opportunities. This interactive process aims to ensure that discrepancies are addressed and corrected effectively. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division and Darcel Cox, Vice President of Compliance. Planned completion date for corrective action plan: HRD has immediately implemented the corrective actions outlined above. The HOC compliance team will implement the additional abatement review process starting in December 2024.

View Audit 333618 Questioned Costs: $1

Finding 515763 (2024-001)

Significant Deficiency 2024

Otis College of Art and Design

CA

Questioned Costs Special Tests & Provisions Student Financial Aid

November 18, 2024 Finding 2024-001 Special Tests and Provisions - Return of Title IV: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the Return of Title IV calculation finding. This error was noticed by new financial aid staff/administration hi...

November 18, 2024 Finding 2024-001 Special Tests and Provisions - Return of Title IV: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the Return of Title IV calculation finding. This error was noticed by new financial aid staff/administration hired in late spring of 2024 after the prior administration had completed all return of Title IV calculations except for the unofficial withdrawals. The new staff noticed the error and made the adjustment going forward starting with the unofficial withdrawals for spring 2024. This error only affected the days of Spring Break. No other semesters had an error in dates used in the Return of the Title IV calculations. Responsible Office and Individual The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto (mmatsumoto@otis.edu) and Registrar Nicole Raef (nraef@otis.edu) are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan Financial Aid Management met with the Registrar's Office to ensure all future semester set up dates are correct and have been reviewed. This improvement of processes to ensure a double check of the Return of Title IV calendar setup has been implemented for 2025-2026.

View Audit 333609 Questioned Costs: $1

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