Corrective Action Plans

Finding 519917 (2023-004)

Significant Deficiency 2023

NC

Internal Control / Segregation of Duties Significant Deficiency Special Tests & Provisions

Responsible Parties: Board of Directors (Dr. Althea Riddick, Chair). Corrected. The Board Members are currently compliance. Anticipated Date of Completion: Deadline: This is an ongoing requirement.

View Audit 339360

Finding 519914 (2023-001)

Material Weakness 2023

Gateway Community Health Centers, Inc.

NC

Internal Control / Segregation of Duties Subrecipient Monitoring § 200.510

Responsible Parties: Chief Executive Officer (Rose Turner), Interim Chief Financial Officer (Dan Miles), Finance Director (Kelly Glover) Gateway’s Management will utilize the implemented Matrix duties and responsibilities Grid to help monitor the documentation of required procedures and Standard Ope...

Responsible Parties: Chief Executive Officer (Rose Turner), Interim Chief Financial Officer (Dan Miles), Finance Director (Kelly Glover) Gateway’s Management will utilize the implemented Matrix duties and responsibilities Grid to help monitor the documentation of required procedures and Standard Operating Procedures approved by the Board of Directors. The health center will use the approved Financial Policies and Procedures Manual as its Standard Operating Procedures. The Health Center’s Management employs key management staff that reflects the size and composition of a health center. Ongoing evaluations will be used to monitor the qualifications of the staff. This Audit is a late submission, however with the submission a qualified Chief Financial Officer is in place and has the qualifications needed to assess and train staff accordingly and provide recommended changes to the department. This new Chief Financial Officer will serve as a technical resource to assist with the implementation of all the resolutions to the findings of the 2022 and 2023 audits

View Audit 339360

Finding 519903 (2023-002)

None 2023

Rumford-Mexico Sewerage District

ME

Reporting Internal Control / Segregation of Duties § 200.512

Management will work with the audit firm to plan, schedule, and begin the audit process to meet the deadline set by Uniform Guidance.

View Audit 339272

Finding 519878 (2023-001)

Significant Deficiency 2023

Boothbay Harbor Sewer District

ME

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.138 § 200.318

Management will review their current procurement policies and make any necessary changes to update the policies to be compliant with 2 CFR Sections 200.138 – 300.327. We anticipate that the corrective action will be completed within 12 months.

View Audit 339201

Finding 519874 (2023-003)

Material Weakness 2023

Town of Lafontaine

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.303 § 200.313

FINDING 2023 - 003 Finding Subject: Water and Waste Disposal System for Rural Communities - Equipment Summary of Finding: Material Weakness, Other Maatters Contact Person Responsible for Corrective Action: Pamela Whitener Contact Phone Number and Email Address: 765-981-4591 clerk@lafontaine.in.gov V...

FINDING 2023 - 003 Finding Subject: Water and Waste Disposal System for Rural Communities - Equipment Summary of Finding: Material Weakness, Other Maatters Contact Person Responsible for Corrective Action: Pamela Whitener Contact Phone Number and Email Address: 765-981-4591 clerk@lafontaine.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have purchased the Silversmith Program to track Capital Assets. All equipment purchased with federal money will be listed in the program and reviewed yearly. Anticipated Completion Date: January 2025

View Audit 339193

Finding 519725 (2023-002)

Material Weakness 2023

Central Decatur Community School District

IA

Internal Control / Segregation of Duties

The District reviews this audit finding internally on an annual basis, identifying control procedures and processes that would leverage movement toward the maximum internal control possible with available staffing although this is difficult with a limited number of employees.

View Audit 338828

Finding 519721 (2023-001)

Material Weakness 2023

Eau Claire Cooperative Health Center, Inc.

SC

Reporting Internal Control / Segregation of Duties

We have reviewed the comments provided herein and are in agreement with the comments and will remediate the findings as follows: We are reviewing the staffing of our finance department in an effort to ensure that on a go forward basis we reduce turnover and have individuals with adequate training ...

We have reviewed the comments provided herein and are in agreement with the comments and will remediate the findings as follows: We are reviewing the staffing of our finance department in an effort to ensure that on a go forward basis we reduce turnover and have individuals with adequate training and subject matter knowledge to perform assigned functions in accordance with appropriate standards and expectations. We are always receptive to positive constructive criticism in our effort to improve upon compliance and financial reporting. Sincerely yours, Sonja McCausland

View Audit 338825

Finding 519714 (2023-002)

Significant Deficiency 2023

Advent House Ministries, Inc.

MI

Allowable Costs / Cost Principles Reporting Significant Deficiency

January 7, 2025 Advent House Ministries, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: The finding from the December 31, 2023 schedule of findings and ...

January 7, 2025 Advent House Ministries, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: The finding from the December 31, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Financial Statement Audit Finding 2023-001 - Significant Deficiency Recommendation: Advent House Ministries, Inc. should consider obtaining the necessary skills, knowledge, or experience to prepare and/or review the footnotes related to the financial statements of the Organization. Action Taken: We concur with the recommendation, the Organization has contracted with an accountant in 2024 with the skills, knowledge, and experience to address the above recommendation. Finding - Federal audit Finding 2023-002 - Significant Deficiency Recommendation: Advent House Ministries, Inc. currently has procedures and controls in place to effectively monitor the status of the submission of the data collection form and the reporting package to ensure that the required information is submitted in a timely manner. The cause related to this finding was not due to failure in internal controls, therefore, we have no further recommendation for the Organization at this time. Action to be Taken: The Organization concurs with the facts of this finding and has procedures in place to ensure the timely submission of the data collection form and the reporting package. Sincerely yours, Susan Cancro, Executive Director

View Audit 338820

Finding 519623 (2023-001)

Material Weakness 2023

Longview School District No. 122

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Longview School District No. 122 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of F...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Longview School District No. 122 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Joan Parsons, Lead Accountant 2715 Lilac St Longview, WA 98632 (360)575-7177 Corrective action the auditee plans to take in response to the finding: The District has now enhanced its process surrounding collection and verification of certified payroll reports to include sending a weekly inquiry to the point of contact for the prime contractor for each federally-funded construction project. The inquiry requests the prime contractor to: • disclose if the prime contractor performed any work on the project that would be subject to Davis-Bacon prevailing wage requirements and if so, supply the certified payroll reports • identify any subcontractors who performed work on the project that would be subject to Davis-Bacon prevailing wage requirements, and if so, supply the certified payroll reports This communication is sent via email, read receipt requested, and the prime contractor’s response (or lack thereof) is documented and followed up on as necessary. Anticipated date to complete the corrective action: This process was implemented June 2024.

View Audit 338730

Finding 519519 (2023-002)

Significant Deficiency 2023

Living Indepdence for Everyone, Inc. (life)

MS

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303

Compliance Requirement – Living Independence for Everyone, Inc. (LIFE) is subject to 2 CFR section 200.303 and 45 CFR section 75.303. Both require that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance tha...

Compliance Requirement – Living Independence for Everyone, Inc. (LIFE) is subject to 2 CFR section 200.303 and 45 CFR section 75.303. Both require that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Recommendation – The Organization should continue working with the assistance of ACL to correct the significant deficiencies noted by the ACL review team in order to improve internal control over compliance and meet the requirements and expectations of 2 CFR section 200.303 and 45 CFR section 75.303. Corrective Action Plan – The Organization agrees with the finding and has made substantial progress in addressing the significant deficiencies identified in their internal control over compliance. The Organization is committed to continuing to work diligently and in full cooperation with ACL to implement the corrective actions included in their compliance review report. Contact Person – Roger Bullock, Executive Director

View Audit 338528

Finding 519488 (2023-009)

Significant Deficiency 2023

Kipp Delta, Inc. D/b/a Kipp Delta Public Schools

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

Views of responsible officials and planned corrective actions: Management agrees with this finding and will ensure copies of all employee contracts are maintained. See 2023-004 for management’s detailed action plan, timeline, and the responsible parties for all Education Stabilization Fund findings.

View Audit 338456 Questioned Costs: $1

Finding 519487 (2023-008)

Significant Deficiency 2023

Kipp Delta, Inc. D/b/a Kipp Delta Public Schools

AR

Questioned Costs Internal Control / Segregation of Duties § 200.430

Views of responsible officials and planned corrective actions: Management agrees with this finding and will ensure all time certifications are signed by employees and reviewed and approved by the appropriate School personnel. See 2023-004 for management’s detailed action plan, timeline, and the resp...

Views of responsible officials and planned corrective actions: Management agrees with this finding and will ensure all time certifications are signed by employees and reviewed and approved by the appropriate School personnel. See 2023-004 for management’s detailed action plan, timeline, and the responsible parties for all Education Stabilization Fund findings.

View Audit 338456 Questioned Costs: $1

Finding 519486 (2023-007)

Significant Deficiency 2023

Kipp Delta, Inc. D/b/a Kipp Delta Public Schools

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

Views of responsible officials and planned corrective actions: Management agrees with this find and will review time certifications in comparison to salaries and wages recorded to the program. See 2023-004 for management’s detailed action plan, timeline, and the responsible parties for all Education...

Views of responsible officials and planned corrective actions: Management agrees with this find and will review time certifications in comparison to salaries and wages recorded to the program. See 2023-004 for management’s detailed action plan, timeline, and the responsible parties for all Education Stabilization Fund findings.

View Audit 338456 Questioned Costs: $1

Finding 519483 (2023-004)

Material Weakness 2023

Kipp Delta, Inc. D/b/a Kipp Delta Public Schools

AR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate supporting documentation for all transactions. Action Plan: Establish clear guidelines and training on allowable costs for federally funded program...

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate supporting documentation for all transactions. Action Plan: Establish clear guidelines and training on allowable costs for federally funded programs. Implement a compliance checklist for all federally funded expenditures to ensure alignment with Education Stabilization Fund requirements. Conduct internal audits every quarter to monitor compliance and document findings. Timeline: Immediate implementation; quarterly compliance reviews. Responsible Parties: Finance Director, APSRC, and Directors.

View Audit 338456 Questioned Costs: $1

Finding 519481 (2023-001)

Material Weakness 2023

Mental Health Resource of Texas, Inc.

TX

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles

I. VIA HOPE 2023 MANAGEMENT CORRECTIVE ACTION PLAN: ► BACKGROUND: CONTINUATION, ADDRESS MULTI-YEAR FRAUD: STRENGTHEN INTERNAL CONTROLS: Management and staff continue to work with the insurance carrier and local law enforcement agencies to restore funds and strengthen its internal controls. ► Update:...

I. VIA HOPE 2023 MANAGEMENT CORRECTIVE ACTION PLAN: ► BACKGROUND: CONTINUATION, ADDRESS MULTI-YEAR FRAUD: STRENGTHEN INTERNAL CONTROLS: Management and staff continue to work with the insurance carrier and local law enforcement agencies to restore funds and strengthen its internal controls. ► Update: History and Board Actions: In FY 2021, Via Hope experienced a significant loss of revenue due to the ending of contracts from its two primary funding streams – the Health and Human Services Commission and the Hogg Foundation for Mental Health. This loss of revenue resulted in the Board recommending and approving the reduction of staff and the departure of the CEO. In FY 2022, the Board recommended and approved the termination of its Accounts Manager and the former Board Chairman stepped in to voluntarily manage the finances until the organization could make other arrangements. The former chairman stepped down from his role and an election of officers was held to install a new Chair. By January 2022, with new revenue coming into the organization, the Board selected a new CEO and in December 2022, a new accounts manager was hired. Once the new accounts manager began reconciling the accounts, a pattern of questionable expenditures became evident with PayPal and other accounts. The CEO and staff informed the Board of what appeared to have happened and recognizing its fiduciary responsibility, the Board approved the engagement of a forensic audit by an external audit firm, The Wesley Peachtree Group (WPG) of Atlanta, Georgia. The forensic audit resulted in findings that fraudulent activity in the amount of $233,000 was likely to have occurred. As a result, the CEO was instructed to file an insurance claim with Frost Insurance. To process the claim, Frost required the involvement of law enforcement which was approved by the Board. Formal investigations were launched and remain ongoing with the Austin Police Department and the Travis County District Attorney's office. Recently, law enforcement met with the Board and provided an update on the investigation. Subsequently, the CEO was requested to follow up with the insurance carrier and state regulatory agencies to ensure the prompt receipt of its insurance claim from PayPal and other potential sources. II. FINDINGS AND RECOMMENDATIONS: Finding 2023-001 - Internal Control Deficiencies (Material Weakness) a) Time and Effort, Payroll and Human Resource Forms and Contracts - In response to the finding, Management will require monthly Time and Effort reports for each employee, develop new human resource forms, and update staff contracts at the beginning of the fiscal year. b) Drawdowns and Written Approvals - With the addition of the new Finance staff member in January 2025, management will initiate a written approval process. All payroll adjustments, drawdowns, credit card purchases, and payments will require invoices, receipts, and written approvals before payment is made. The Accounting Manager will also work with the CEO to ensure that staff provide receipts promptly and that journal entries are recorded on a monthly basis. c) Receipts, Written Approvals, PP&E Schedule - Receipts and written approvals were addressed in Response (C). While the organization maintains an equipment log, we will establish a formal Property, Plant, and Equipment Schedule (PP&E), particularly noting equipment purchased with federal funds. d) Paypal, Frost, Forte - Management continues to work with law enforcement to obtain misappropriated funds from PayPal, and other potential accounts. As indicated, investigators met with the CEO, staff, Frost Bank, and the Board to obtain information regarding these accounts. It is our understanding that they may meet with prior Via Hope executives as well. We will update the auditors when more information is provided. e) Segregation of Duties - Management has begun the process of interviewing qualified staff to segregate duties in the Finance office. This will ensure that one individual will no longer be responsible for handling funds, payments, reconciliations, and General Ledger (GL) postings. The individual will be in place by January 2025.

View Audit 338449 Questioned Costs: $1

Finding 519405 (2023-003)

Material Weakness 2023

Crawford County Board of Education

GA

Cash Management Subrecipient Monitoring Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.305

FA 2023-003 Improve Controls over Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The School District made cash drawdowns in excess of immediate cash needs for the Elementary and Secondary School Emergen...

FA 2023-003 Improve Controls over Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The School District made cash drawdowns in excess of immediate cash needs for the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The district will implement procedures to ensure all drawdowns align with expenditures. The program director or coordinator will view and sign all draw- down packets. The packets will include detailed expenditure reports for the month and year-to-date of the expenditures that are a part of the requested drawdown. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

View Audit 338350

Finding 519404 (2023-002)

Significant Deficiency 2023

Crawford County Board of Education

GA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.403 § 200.415

FA 2023-002 Strengthen Budgetary Controls over Expenditures Internal Control Impact: Significant Deficiency Compliance Impact: Activities Allowed or Unallowed Allowable Costs/Cost Principle Prior Year Finding: None Description: A review of expenditures charged to the Elementary and Secondary ...

FA 2023-002 Strengthen Budgetary Controls over Expenditures Internal Control Impact: Significant Deficiency Compliance Impact: Activities Allowed or Unallowed Allowable Costs/Cost Principle Prior Year Finding: None Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures has not been properly approved by the pass- through entity. Corrective Action Plans: the School District will work with all entities to confirm that all existing controls are adhered to by developing and implementing an improved monitoring process. This process will ensure that all expenditures comply with all applicable policies and regulations. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

View Audit 338350 Questioned Costs: $1

Finding 519402 (2023-001)

Material Weakness 2023

Crawford County Board of Education

GA

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303

FA 2023-001 Improve Controls over Financial Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The accounting procedures of the School District were insufficient to provide adequate internal controls over multipl...

FA 2023-001 Improve Controls over Financial Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The accounting procedures of the School District were insufficient to provide adequate internal controls over multiple control categories. Corrective Action Plans: Management will review, design, and implement procedures to strengthen the internal controls over the accounting functions to ensure transactions are properly processed and reported. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

View Audit 338350

Finding 519400 (2023-007)

Material Weakness 2023

Town of Seabrook

NH

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.430

Audit Finding Reference: 2023-007 Management’s Response and Planned Corrective Action: Implement a record keeping process for all rates and weighted rates for payroll. Name of Contact Person and Completion Date: Name: William Manzi

View Audit 338332 Questioned Costs: $1

Finding 519360 (2023-005)

Material Weakness 2023

Housing Authority of the County of Marin

CA

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Numbers: 14.850 Noncompliance – N. Special Tests and Provisions – Public Housing Waiting List Non Compliance Material to the Financial Statements: Yes...

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Numbers: 14.850 Noncompliance – N. Special Tests and Provisions – Public Housing Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Finding 2023-005 (continued): Criteria: Selections from the Waiting List. The PHA must have written policies in its Admissions and Continued Occupancy Policy for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203 (Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that certain new move-ins to the Public and Indian Housing Program were selected from the wait list in an order that is in accordance with the Authority’s Admissions and Continued Occupancy Policy. Context: Of a sample size of nine (9) new move-ins, nine (9) could not be determined to be housed in proper order from the Authority's waiting list. Our sample size is statistically valid. Known Questioned Costs: $89,397 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to the public housing waiting list. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Public and Indian Program is in material non-compliance with the special tests and provisions type of compliance related to selection of applicants from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight on the maintenance of the waiting list and process of housing applicants to better monitor adequacy with compliance requirements. Kim Dolan, Chief Financial officer, will be responsible to implement this corrective action by December 31, 2024.

View Audit 338241 Questioned Costs: $1

Finding 519359 (2023-004)

Material Weakness 2023

Housing Authority of the County of Marin

CA

Questioned Costs HUD Housing Programs Eligibility

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Assistance Listing Numbers: 14.850 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Comp...

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Assistance Listing Numbers: 14.850 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Finding 2023-004 (continued): Context: There are approximately 460 units. Of a sample size of seventeen (17) tenant files, the following was noted: • HUD 50058 annual recertification was not filed timely in 2 files • Original Application was missing in 1 file • Verification of income was missing in 3 files • Verification of assets was missing in 2 files Our sample size is statistically valid. Known Questioned Costs: $28,961 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Public and Indian Housing Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Public and Indian Housing Program and will implement internal control procedures that will ensure compliance with federal regulations. Elizabeth Campbell, Interim Deputy Director, will be responsible to implement this corrective action by December 31, 2024.

View Audit 338241 Questioned Costs: $1

Finding 519358 (2023-006)

Material Weakness 2023

Housing Authority of the County of Marin

CA

Questioned Costs HUD Housing Programs Eligibility

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance - N. Special Tests and Provisions - Selection from the Waiting List Non Compliance Material to the Financial Sta...

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance - N. Special Tests and Provisions - Selection from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its Section 8 Administrative Plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203 (Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that certain new move-ins to the Section 8 Housing Choice Vouchers Program were selected from the wait list in an order that is in accordance with the Authority’s Section 8 Administrative Plan. Context: Of a sample size of thirteen (13) new move-ins, seven (7) could not be determined to be housed in proper order from the Authority's waiting list. Our sample size is statistically valid. Known Questioned Costs: $181,533 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selection from the waiting list. The Authority has not properly housed applicants in compliance with program requirements. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the eligibility type of compliance related to selection from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Finding 2023-006 (continued): Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Voucher Program to ensure that established internal control policies are being followed on a timely basis. Kim Dolan, Chief Financial officer, will be responsible to implement this corrective action by December 31, 2024.

View Audit 338241 Questioned Costs: $1

Finding 519357 (2023-003)

Significant Deficiency 2023

Housing Authority of the County of Marin

CA

Questioned Costs HUD Housing Programs Significant Deficiency

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers - Mainstream Vouchers - Emergency Housing Vouchers Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – N. Special Tests and ...

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers - Mainstream Vouchers - Emergency Housing Vouchers Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussions with management, the Authority did not properly abate five (5) out of thirty-six (36) annual failed inspections selected for testing. Context: The Authority did not properly abate five (5) out of thirty-six (36) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Finding 2023-003 (continued): Known Questioned Costs: • 14.871 - Section 8 Housing Choice Vouchers - $11,067 • 14.879 - Mainstream Vouchers - $160 • 14.EHV - Emergency Housing Vouchers - $341 Cause: There is a significant deficiency in internal controls over compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers, Mainstream Vouchers, and Emergency Housing Vouchers programs are in non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the significant deficiency in the Section 8 Housing Choice Vouchers, Mainstream Vouchers, and Emergency Housing Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Kathleen Wyatt, Director of Housing Operations, will be responsible to implement this corrective action by December 31, 2024.

View Audit 338241 Questioned Costs: $1

Finding 519356 (2023-002)

Material Weakness 2023

Housing Authority of the County of Marin

CA

Questioned Costs HUD Housing Programs Material Weakness

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: - Section 8 Housing Choice Vouchers - Emergency Housing Vouchers Assistance Listing Numbers: 14.871, 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Materia...

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: - Section 8 Housing Choice Vouchers - Emergency Housing Vouchers Assistance Listing Numbers: 14.871, 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Inspections. Per the Authority's HCV Admin Plan, the PHA must inspect the unit leased to a family biennially in order to determine if the unit meets HQS standards, and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management there were inspection reports that were unavailable for examination at the time of audit. Context: Of a sample size of forty-four (44) units, twelve (12) units did not have biennial HQS inspections performed timely. Our sample size is statistically valid. Known Questioned Costs: • 14.871 - Section 8 Housing Choice Vouchers - $246,504 • 14.EHV - Emergency Housing Vouchers - $30,252 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Finding 2023-002 (continued): Effect: The Section 8 Housing Choice Vouchers and Emergency Housing Vouchers programs are in material non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Emergency Housing Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Kathleen Wyatt, Director of Housing Operations, will be responsible to implement this corrective action by December 31, 2024.

View Audit 338241 Questioned Costs: $1

Finding 519355 (2023-001)

Material Weakness 2023

Housing Authority of the County of Marin

CA

Questioned Costs HUD Housing Programs Eligibility

Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers - Mainstream Vouchers - Emergency Housing Vouchers Assistance Listing Numbers: 14.871, 14.879, 14.EHV Noncompliance – E. Eli...

Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers - Mainstream Vouchers - Emergency Housing Vouchers Assistance Listing Numbers: 14.871, 14.879, 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Housing Voucher Cluster - Section 8 Housing Choice Vouchers - Yes - Mainstream Vouchers - Yes - Emergency Housing Vouchers - No Finding 2023-001 (continued): Material Weakness and Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,434 units. Of a sample size of fifty-six (56) tenant files, the following was noted: • HUD form 9886 was unable to be provided in 4 files • Verification of income was unable to be provided in 5 files • Verification of assets was unable to be provided in 4 files • HUD 50058 annual recertification was not filed timely in 8 files • Original Application was unable to be provided in 12 files • Citizen Declaration Section 214 form was unable to be provided in 2 files • Lead based paint form was unable to be provided in 16 files • Signed lease was unable to be provided in 6 files • Our sample size is statistically valid. Known Questioned Costs: • 14.871 - Section 8 Housing Choice Vouchers - $65,025 • 14.879 - Mainstream Vouchers - $31,974 • 14.EHV - Emergency Housing Vouchers - $14,095 Cause: There is a material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and a significant deficiency in the Emergency Housing Vouchers program in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers and Mainstream Vouchers programs are in material non-compliance, and the Emergency Housing Vouchers program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Kathleen Wyatt, Director of Housing Operations, will be responsible to implement this corrective action by December 31, 2024.

View Audit 338241 Questioned Costs: $1

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