Corrective Action Plans

Finding 52054 (2022-004)

Significant Deficiency 2022

PA

Student Financial Aid Reporting Significant Deficiency

Corrective Action Plan Monday, February 20, 2023 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the June 30, 2022 audit report dated February 20, 2023 schedule of findings and questioned cost are disc...

Corrective Action Plan Monday, February 20, 2023 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the June 30, 2022 audit report dated February 20, 2023 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding) U.S. Department of Education Audit Period: July 1, 2021 ? June 30, 2022 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants 804 Wayne Avenue Chambersburg, Pennsylvania Finding Type: (per Finding) Student Financial Aid Cluster: Significant Deficiency in Internal Control over Compliance and NonCompliance Internal Control Type: (please choose the type per the finding) o Material Weakness(es) ? Significant Deficiencies Audit Finding No.: 2022-004 Federal Program: (per Finding) Student Financial Aid Cluster Compliance Requirement: (per Finding) Reporting Audit Finding Title/Statement of Condition: (copy from audit findings documentation) Significant Deficiency in Internal Control over Compliance and NonCompliance Institutions are required to report enrollment information under the Pell grant and direct loan programs via the National Student Loan Data System (NSLDS). Auditor Recommendation: (copy from audit findings documentation) We recommend that the College contact the student to obtain a copy of their social security card to confirm the name and number to correct this situation. The College should also review its internal procedures to ensure controls are in place to timely identify reporting discrepancies and make corrections as necessary Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). ? The College contacted the student (via email) on Jan. 16, 2023, to verify their information. The student did not respond. ? The College sent a follow up communication on Feb. 13, 2023. ? If the student does not respond by close of business this week (Friday, Feb. 24, 2023), then a member of the Registration and Records unit will contact the student via phone. ? If the student does not respond, a hold will be placed on the student account. The student will not be able to perform any transition until the requirement is met. *The case in question is a unique situation in which the College does not know if the student provided the wrong SSN to HACC or the previous institution, and there is no way that the College would have known that information prior to the reject from the National Student Clearinghouse. At this point the College does not know if the student provided the wrong information to HACC or their prior institution because the student has not responded to the College?s outreach. Moving forward, the College plans to contact students immediately AND place a hold on their accounts (immediately). In most cases, the holds prompt students into action that they would not otherwise take. Anticipated Completion Date: In process Name(s) and Title(s) of contact person(s) responsible for correction action: Dawn K Mull Director, Financial Accounting & Reporting Harrisburg Area Community College dkmull@hacc.edu

View Audit 51968

Finding 52050 (2022-005)

Material Weakness 2022

Cci Health & Wellness Services and Affiliate

MD

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Finding No. 2022-005: Lack of Documentation of Management Review over Salary Certifications ? Material Weakness in Internal Control Over Financial Reporting ...

Finding No. 2022-005: Lack of Documentation of Management Review over Salary Certifications ? Material Weakness in Internal Control Over Financial Reporting U.S. Department of Health and Human Services, Family Planning Services, ALN 93.217; Prevention and Health Promotion Administration--Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 Condition: Time charges to federal awards are based upon estimates established by CCI through the grant budgeting process. There is no evidence that salaries charged to the federal programs were subsequently reviewed by program managers for propriety and adjusted as deemed necessary. Recommendation: Marcum recommends that management adhere to its policy requiring the Finance and Grants Manager to meet after each pay period to review the time and labor charges to federal awards, noting any changes that need to be made. Marcum also recommend that this meeting, review and any amendments made be documented and evidenced by signatures or initials of the employees involved in the process and the date the meeting occurred. Action Taken: CCI will implement a grants management software that will tie to the payroll software. Changes made in one system, will be reflected in the other. Each system will have an advanced audit trail?complete with an approvals process. Anticipated Completion/Implementation Date: End of calendar year 2023.

View Audit 52323

Finding 52049 (2022-001)

Material Weakness 2022

Cedar County Memorial Hospital

MO

Allowable Costs / Cost Principles Material Weakness Reporting

FINDINGS? FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL PROGRAMS DEPARTMENT OF HEALTH AND HUMAN SERVICES 2022 ? 001 COVID-19 Provider Relief Funding Recommendation: We recommend the Hospital design controls to ensure documentation is completed timely and sufficiently on how costs are necessary to r...

FINDINGS? FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL PROGRAMS DEPARTMENT OF HEALTH AND HUMAN SERVICES 2022 ? 001 COVID-19 Provider Relief Funding Recommendation: We recommend the Hospital design controls to ensure documentation is completed timely and sufficiently on how costs are necessary to respond to Covid-19. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management did not believe it was necessary to document how contracted emergency room physician costs were necessary to prepare, prevent and respond to Covid-19. Name of the contact person responsible for corrective action: Carla Gilbert, CFO. Planned completion date for corrective action plan: January 31, 2023 If the Department of Health and Human Services has questions regarding this plan, please call Carla Gilbert, CFO at (417) 876-3097.

View Audit 52320

Finding 52037 (2022-002)

Material Weakness 2022

Ashland University

OH

Questioned Costs Special Tests & Provisions Student Financial Aid

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-002 Audit Finding: As part of the audit for the 2021- 2022 Federal award year, Schneider Downs determined that the University used the same determ...

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-002 Audit Finding: As part of the audit for the 2021- 2022 Federal award year, Schneider Downs determined that the University used the same determination for the payment period for those students who had been awarded Pell grants that it had been using in the periods for which the U.S. Department of Education (ED) conducted the Focused Program Review (FPR). In addition to the population of students who are participating the Second Chance Pell program, the University also identified additional students, that when using ED?s interpretation of the Code of Federal Regulations (CFR), the University used a payment period that did not reflect enrollment in a nonstandard instructional term program. Corrective Actions Taken or Planned: Management does not concur with the criteria of this finding due to a disagreement with the interpretation of the regulations included in ED?s Final Program Review Determination (FPRD) and has appealed the finding as stated in the following paragraphs. Management followed the direction received from the ED Reviewers during the FPR exit interview on September 24, 2021, stating the University should not change its practice for the Second Chance Pell students enrolled in their respective instructional program nor the calculation using Formula 1 for the payment period until the Program Review Report (PRR) is received. The PRR was received on January 3, 2022, which was after the summer and fall 2021 semesters and just weeks prior to the start of the spring 2022 semester. Moreover, pursuant to the Higher Education Act ?498A(b), the University was entitled to an opportunity to review the PRR and within 60 days of receipt, submit a response for ED?s review prior to their preparing a final determination. The University submitted its response to the PRR on March 11, 2022. The University disagrees with the determinations in the FPRD and is vigorously defending itself against the ED interpretation of the regulations, the findings and the proposed financial assessments. The University filed an appeal of the findings and the associated financial assessments contained in the FPRD on October 24, 2022, and submitted a brief in support of the appeal on January 22, 2023, to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act ? 487(b)(2) and U.S.C. ? 1094(b)(2). Effective with the fall 2022 semester term and each fall and spring terms thereafter, the Second Chance Pell students enrolled in their respective instructional programs have a fifteen (15) week standard instructional term and the payment period qualifies for calculations utilizing Pell Formula 1.

View Audit 50813 Questioned Costs: $1

Finding 52026 (2022-001)

Material Weakness 2022

The Salvation Army Residence Inc., A Florida Corporation

FL

HUD Housing Programs Reporting Special Tests & Provisions

1 CORRECTIVE ACTION PLAN Project Legal Name: William Booth Towers Orlando, FL (A Project of The Salvation Army Residences, Inc., a Florida Corporation) HUD Project No.: 067-11269 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-9/30/2022 Corrective Action Plan prepared by: Name: Sr...

1 CORRECTIVE ACTION PLAN Project Legal Name: William Booth Towers Orlando, FL (A Project of The Salvation Army Residences, Inc., a Florida Corporation) HUD Project No.: 067-11269 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2021-9/30/2022 Corrective Action Plan prepared by: Name: Sriparna Mitra Position: HUD Specialist, THQ (Legal) Telephone Number: 404-728-6700 A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation Management is working to get the audit done in a more timely manner so that the calculation for residual receipts can be completed in time to make any necessary deposits within the required deadline. The intent is to begin the FY 23 audit prior to fiscal year end to allow for customary preliminary audit work. b. Action(s) Taken or Planned on the Finding On February 11, 2022 the Project remitted the residual receipts funds to HUD for the fiscal year ended Sep 30, 2021. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Year Findings, Questioned Costs and Recommendations 1. Finding 2021-001 Cleared. 2. Finding 2021-002 Cleared.

View Audit 49453

Finding 52016 (2022-001)

Significant Deficiency 2022

Ucr of Marion, Ohio Inc. D/b/a Brownstone Terrace

OH

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

1. Comments on Findings and Recommendation Management acknowledges failure to comply with timely EIV Master File Reports required to be completed as part of tenant move in certification process and EIV Master File process. 2. Actions Taken or Planned The Corporation will regularly monitor and recon...

1. Comments on Findings and Recommendation Management acknowledges failure to comply with timely EIV Master File Reports required to be completed as part of tenant move in certification process and EIV Master File process. 2. Actions Taken or Planned The Corporation will regularly monitor and reconcile the creation and retention of background checks and Income reports as part of the move in process. Additional training was provided and corrective action was taken. Management is reviewing and revising the EIV policy. 3. Status of Corrective Actions on Prior Findings The Corporation did not remediate the prior year finding for failure to comply with timely EIV Income Reports.

View Audit 47883

Finding 52015 (2022-001)

Significant Deficiency 2022

Ucc Xvii, Inc. D/b/a Biimaadiiziiwiin

OH

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

Corrective Action Plan Finding Number: 2022-001 Condition: HUD guidelines regarding the EIV system were not followed and the EIV system reports were not utilized timely during 2022. Planned Corrective Action: Management has implemented guidelines and trainings surrounding the use of the EIV system....

Corrective Action Plan Finding Number: 2022-001 Condition: HUD guidelines regarding the EIV system were not followed and the EIV system reports were not utilized timely during 2022. Planned Corrective Action: Management has implemented guidelines and trainings surrounding the use of the EIV system. Management will continue to monitor the appropriate use of the EIV system. Contact person responsible for corrective action: Julie Reed, Housing Accounting Manager Anticipated Completion Date: December 31, 2023

View Audit 47574

Finding 52010 (2022-002)

Material Weakness 2022

Salem Lodge of B'nai B'rith Housing Corporation 034-44814-Np

PA

Special Tests & Provisions Allowable Costs / Cost Principles HUD Housing Programs

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS: Internal control over compliance / compliance Finding number 2022-002 Section 207 pursuant to Section 223(f) loan: Federal Agency: U.S. Department of Housing and Urban Development Pass-through entity: None HUD Project number: 034-44814 NP Condi...

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS: Internal control over compliance / compliance Finding number 2022-002 Section 207 pursuant to Section 223(f) loan: Federal Agency: U.S. Department of Housing and Urban Development Pass-through entity: None HUD Project number: 034-44814 NP Condition and criteria: As required by the Section 207 pursuant to Section 223(f) HUD insured loan, the Corporation is required to keep funds collected as a security deposit in the name of the project, in an account separate and apart from all other funds of the project, with the amount of this account at all times equal to or exceeding the aggregate of all outstanding security deposits. All disbursements from the security deposit account must be only for refunds to tenants and for payment of expenses incurred by or on behalf of the tenant. The contracted management company had transferred funds out of the security deposit account to the operating account to cover operations during the fiscal year ended October 31, 2022, leaving insufficient funds in the security deposit account to cover outstanding security deposits. Cause: For the fiscal year ended October 31, 2022, the Corporation did not have adequate internal controls over compliance in place for the area of special tests and provisions to ensure that the security deposit account funds were properly always separated from other funds of the Corporation. Effect: As a result of unallowable disbursements from the security deposit account, the Corporation and management company will not be in compliance with the special tests and provisions compliance requirement, may not have sufficient funds to cover the security deposit liability, and could be restricted from entering into any new business with HUD. Recommendation: The Corporation, along with the contracted management company, should develop effective internal control procedures to ensure that the security deposit account always have sufficient funds to cover the security deposit liability and that no unallowable disbursements from the account occur. The Corporation?s and contracted management company?s response / corrective action: The contracted management company took the appropriate steps to set up controls over the security deposit account to ensure only allowable disbursements occur, and that the account funds are always sufficiently separated to cover the security deposit liability. Sincerely, ____________________________________ Jody Dimpsey, Management Agent Salem Lodge of B?nai B?rith Housing Corporation

View Audit 45379

Finding 52009 (2022-001)

Significant Deficiency 2022

Salem Lodge of B'nai B'rith Housing Corporation 034-44814-Np

PA

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

January 30, 2023 U.S. Department of Housing and Urban Development Salem Lodge of B?nai B?rith Housing Corporation (the Corporation) respectfully submits the following corrective action plan for the year ended October 31, 2022. Name and address of independent accounting firm: Brown Schultz Sherid...

January 30, 2023 U.S. Department of Housing and Urban Development Salem Lodge of B?nai B?rith Housing Corporation (the Corporation) respectfully submits the following corrective action plan for the year ended October 31, 2022. Name and address of independent accounting firm: Brown Schultz Sheridan & Fritz 210 Grandview Avenue Camp Hill, PA 17011 Audit period: November 1, 2021 ? October 31, 2022 Findings #2022-001 and #2022-002 from the schedule of findings and questioned costs for the year ended October 31, 2022 are discussed on the following page. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS: Internal control over compliance / compliance Finding number 2022-001 Section 207 pursuant to Section 223(f) loan: Federal Agency: U.S. Department of Housing and Urban Development Pass-through entity: None HUD Project number: 034-44814 NP Condition and criteria: As required by the Section 207 pursuant to Section 223(f) HUD insured loan, the Corporation is required to prepare and submit monthly reports of excess income (Form HUD-93094) in accordance with HUD instructions and in a timely manner. The contracted management company, on behalf of the Corporation, had failed to timely submit one of the monthly reports of excess income for the fiscal year ended October 31, 2022. Cause: For the fiscal year ended October 31, 2022, the Corporation did not have adequate internal controls over compliance in place for the area of reporting to ensure all required financial reporting was filed timely. Effect: As a result of failing to properly submit required financial reporting in a timely manner, the Corporation and management company will not be in compliance with the reporting compliance requirement, and could have been restricted from entering into any new business with HUD. Recommendation: The Corporation, along with the contracted management company, should develop effective internal control procedures to ensure all required financial reporting is filed timely. The Corporation?s and contracted management company?s response / corrective action: The contracted management company took the appropriate steps to set up automatic reporting for property managers each month. Sincerely, ____________________________________ Jody Dimpsey, Management Agent Salem Lodge of B?nai B?rith Housing Corporation

View Audit 45379

Finding 52008 (2022-001)

Significant Deficiency 2022

Deborah's Place

IL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Federal Agency: U.S. Department of Housing and Urban Development Program: Continuum of Care Program Assistance Listing #: 14.267 Condition: Incorrect payroll percentages were used to allocate payroll costs to the grant, resulting in an incorrect amount being charged to the program. Views of Responsi...

Federal Agency: U.S. Department of Housing and Urban Development Program: Continuum of Care Program Assistance Listing #: 14.267 Condition: Incorrect payroll percentages were used to allocate payroll costs to the grant, resulting in an incorrect amount being charged to the program. Views of Responsible Officials and Planned Corrective Actions: Finance department will implement automated interface from Payroll system to General Ledger to accurately capture payroll allocation activity. Deborah?s Place expects to complete implementation of the payroll interface by end of first quarter, 2023. Accounting Coordinator will complete an extensive review of the time and labor entries per employee per pay period. This activity has already been completed from beginning of current fiscal year (7/1/22) to present and will continue going forward. CFO will continue to review monthly utilization of agency grant dollars to confirm accuracy of staff allocation percentages.

View Audit 43222

Finding 52002 (2022-010)

Significant Deficiency 2022

City of Amsterdam, New York

NY

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

2022-010 ? Community Block Grant-State Administered Small Cities Program Recovery Fund The City has been relying on guidance from previous auditors who determined that Community Development Block Grants are awarded to the City, not the URA, and are therefore recorded on the City?s financial stateme...

2022-010 ? Community Block Grant-State Administered Small Cities Program Recovery Fund The City has been relying on guidance from previous auditors who determined that Community Development Block Grants are awarded to the City, not the URA, and are therefore recorded on the City?s financial statements. The URA is only serving as a pass-through entity. As a result of this guidance, it has been the City?s understanding that the URA would not be required to report these grants on the PARIS report.

View Audit 53246

Finding 51990 (2022-002)

Material Weakness 2022

Pioneer Regional School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance L...

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: We noted that for one claim in a sample of four, the Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will verify that each claim has been reviewed by a secondary person for accuracy. Responsible Party and Timeline for Completion: Loretta Kimbrell, Immediately

View Audit 52912

Finding 51989 (2022-001)

Significant Deficiency 2022

Sarah Lawrence College

NY

Special Tests & Provisions Reporting Significant Deficiency

Corrective action: The College is aware of its responsibilities to prepare and post quarterly filings for the Higher Education Emergency Relief Fund (HEERF) awards. In addition to filing future quarterly reports and continuing to file annual reports in a timely manner, the College is currently retro...

Corrective action: The College is aware of its responsibilities to prepare and post quarterly filings for the Higher Education Emergency Relief Fund (HEERF) awards. In addition to filing future quarterly reports and continuing to file annual reports in a timely manner, the College is currently retroactively preparing missed prior quarterly reports for posting. Due to the short time frame between the extended submission date of the 2021 Uniform Guidance report and submission of the 2022 Uniform Guidance report and additional staffing transitions at the College, there was a delay in the College?s proposed completion date in the 2021 report. The College is continuing to review its staffing and administrative structure with a goal of improving grants management, reporting and compliance. Proposed Completion Date: June 30, 2023

View Audit 52910

Finding 51982 (2022-001)

Significant Deficiency 2022

Unified School District No. 466

KS

Subrecipient Monitoring Internal Control / Segregation of Duties

Finding 2022-001 - Lack of Segregation of Duties The District understands that this is a significant deficiency but feels it is not cost-effective at this time to hire additional employees to properly segregate duties. We feel that the oversight performed by the Superintendent and Board of Educati...

Finding 2022-001 - Lack of Segregation of Duties The District understands that this is a significant deficiency but feels it is not cost-effective at this time to hire additional employees to properly segregate duties. We feel that the oversight performed by the Superintendent and Board of Education over the financial statement activity and reports of the District is adequate to help mitigate the lack of segregation of duties. We believe it would be inefficient and cost prohibitive to hire the additional employees needed to properly segregate duties so at this time we do not plan on making any changes. However, we will continue to monitor this situation and periodically determine if it is cost-effective for us to properly segregate duties.

View Audit 52138

Finding 51969 (2022-004)

Significant Deficiency 2022

Howard County Housing Commission

MD

Questioned Costs HUD Housing Programs Significant Deficiency

2022-004 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated. Explanation of disagreement with audit finding: There is no disagreement with the audit fi...

2022-004 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The following actions are currently taking place to ensure abatement procedures are met when required due to failed inspections: ? The HCHC will ensure that its third-party HQS inspectors provide data on all fails that require abatement. To achieve this, the third-party inspection company has created a working document that will be updated twice a week with units that have failed twice and are recommended for abatement. The document will be shared with the Commission after each update. ? The assigned HCV Specialist will notify the landlord and tenant of the failed inspection and specific deficiencies that must be corrected. ? The assigned HCV Specialist will ensure that the third-party inspection company re-inspects to verify that the repairs have been completed and meet HQS standards. ? If the landlord fails to make the repairs by the established deadline, the HCHC will initiate abatement procedures by withholding or reducing housing assistance payments (HAP) once the unit passes inspection. The Director and Program Manager will review the inspection reports and initiate abatement. ? The assigned HCVP Specialist will provide the tenant with information and assistance to find alternative housing, such as issuing a new voucher, extending the search time, or offering relocation expenses. ? The HCHC will terminate the HAP contract with the landlord if the unit remains abated for more than 180 days or if the landlord fails to comply with other contractual obligations. The Director of Rental Assistance and the Program manager will review all recommended abatements monthly to determine who will be terminated from the HCV program. We will review all Yardi reports and the recommended abatement spreadsheet from the third-party inspector. Name(s) of the contact person(s) responsible for corrective action: Paul Diggs, Director of HCVP Planned completion date for corrective action plan: December 31, 2023

View Audit 49580 Questioned Costs: $1

Finding 51968 (2022-003)

Material Weakness 2022

Howard County Housing Commission

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022-003 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend the Commission review their HQS inspection policies and procedures, and discuss these standards with the third party inspection company that is utilized for these inspections to ensure all inspections are performe...

2022-003 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend the Commission review their HQS inspection policies and procedures, and discuss these standards with the third party inspection company that is utilized for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC has hired a third-party inspector to conduct all inspections. The third party is also responsible for determining rent reasonableness for agency-owned properties. The following actions have been implemented to ensure the integrity of HQS inspections: ? Established a clear communication channel and reporting format with the third-party inspection company. ? Defined the inspection scope, frequency, and criteria to meet the quality standards. ? Conduct regular audits and reviews of the inspection results and reports to ensure accuracy and constancy. The reviews will be conducted monthly by a newly created Quality Control staff member and the Director of Rental Assistance. The monitoring process will consist of a review of (1) 50058 action type 13 submissions in PIC, (2) all failed inspections, and (3) the timeliness and abatement status of the third-party vendor. ? Provide regular feedback and recommendations to the third-party inspection company to improve their quality and efficiency. An established monthly meeting is currently in place; however, additional meetings will be setup if necessary. ? Ensure that the third-party company utilizes real-time data tools to communicate with the HCHC Yardi Software. Yardi has a mobile inspection app that the third-party inspector will begin using. In addition, the Commission will evaluate the existing third-party inspection company to decide if its contract will be renewed or terminated based on performance. If the contract is terminated, the Commission will solicit for a new inspection company. Name(s) of the contact person(s) responsible for corrective action: Paul Diggs, Director of HCVP Planned completion date for corrective action plan: December 31, 2023

View Audit 49580

Finding 51967 (2022-002)

Material Weakness 2022

Howard County Housing Commission

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022-002 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend that the Commission review their policies and ensure that rent reasonableness is determined and documented for all rent changes. Explanation of disagreement with audit finding: There is no disagreement with the au...

2022-002 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend that the Commission review their policies and ensure that rent reasonableness is determined and documented for all rent changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rent Reasonableness is an essential requirement for the HCV program, as it ensures that the rents paid by the program participants are fair and comparable to the market rates. The following actions have been implemented to ensure rent reasonableness calculations are being made and properly applied: ? Staff uses an automated system called ?RentEllect?, that captures data of unassisted units in the Howard County market area and uses it to determine rent reasonableness. ? Staff documents the rent reasonableness determination for each program unit using clear and concise language. The documentation includes the source of information, the comparison units, the method of calculation, and the final rent decision. The documentation is maintained electronically and is attached to the tenant file in HCHC?s Yardi Database. The HCHC uses Yardi Software to manage all HCV program transactions. ? The HCV department trained staff on the rent reasonableness process and procedures and provided appropriate tools, including ?RentEllect,? to ensure accurate data. ? Supervisory staff will review the rent reasonableness determinations periodically and update the procedures as needed, especially when there are changes in the Fair Market Rents (FMRs), the rent to the owner, or the unit condition. Name(s) of the contact person(s) responsible for corrective action: Paul Diggs, Director of HCVP Planned completion date for corrective action plan: December 1, 2023

View Audit 49580

Finding 51966 (2022-001)

Significant Deficiency 2022

Howard County Housing Commission

MD

HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

2022-001 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend that management review their procedures for uploads to PIC to confirm the information is uploaded without error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Act...

2022-001 Housing Choice Voucher Program ? FALN No. 14.871 Recommendation: We recommend that management review their procedures for uploads to PIC to confirm the information is uploaded without error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HUD PIC errors occurred because data submitted for the FY 2022 Audit Period was not properly reviewed, and errors were not identified and corrected. During the audit period, the HCHC experienced a transition of personnel that included a period during which a third-party contractor led the program. Staff with the responsibility to ensure data integrity also transitioned. Since August 29, 2022, the HCHC has had stable leadership, the PIC submissions process has been changed, and PIC submissions are being reviewed. The following actions have been implemented to help mitigate PIC errors: ? The HCHC uses the HUD Pic Error Dashboard to identify and monitor PIC errors. The PIC Error Dashboard shows a summary view of PIC Fatal errors the HCHC receives when inputting the Form 50058s with reexaminations over 14 months overdue. The reports within the dashboard are updated weekly, and staff has been submitting PIC files every Friday to minimize the number of errors and ensure timely submissions of the 50058s. ? Staff also use the PIC Error Correction Guidebook for the HCV program, which guides identifying and correcting PIC errors and step-by-step instructions on common PIC errors. Name(s) of the contact person(s) responsible for corrective action: Paul Diggs, Director of HCVP Planned completion date for corrective action plan: The new procedures for monitoring and correcting PIC errors are in place. Correcting errors, however, is an ongoing process as the HCHC submits 50058 records weekly. The HCV department started corrective measures in October 2022 to identify and correct outstanding PIC submissions.

View Audit 49580

Finding 51955 (2022-002)

Material Weakness 2022

Garrett-Evangelical Theological Seminary

IL

Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding Number: 2022-002 Condition: During our review of internal controls and testing procedures, it was noted that no reconciliations could be provided. In addition, the Seminary does not have a quality...

Finding Number: 2022-002 Condition: During our review of internal controls and testing procedures, it was noted that no reconciliations could be provided. In addition, the Seminary does not have a quality assurance system in place. Planned Corrective Action: The Financial Aid Director will implement an efficient procedure for monthly reconciliation using the new JFA system and COD. First disbursement for 23-24 is planned for September, so beginning October 1, 2023, a new, efficient process will occur at the beginning of each month to reconcile federal funds. Financial Aid will maintain copies of data to support the monthly reconciliation. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 07/31/2024 (to be completed throughout 23-24 academic year)

View Audit 41785

Finding 51943 (2022-003)

Significant Deficiency 2022

Dupage Housing Authority

IL

Special Tests & Provisions HUD Housing Programs Significant Deficiency

Finding 2022-03: Missing Rent Reasonableness (Significant Deficiency) Corrective Action Plan: In April 2023, management retained Nan McKay and Associates (NMA) to review the current roles and responsibilities of its HCV support positions. DHA has completed the restructuring of its Program Specialist...

Finding 2022-03: Missing Rent Reasonableness (Significant Deficiency) Corrective Action Plan: In April 2023, management retained Nan McKay and Associates (NMA) to review the current roles and responsibilities of its HCV support positions. DHA has completed the restructuring of its Program Specialist staff and will continue to restructure additional roles and responsibilities to drive better organizational effectiveness, while addressing missing rent reasonableness deficiencies with the following changes: ? Implement Rent Reasonableness software integration with Yardi to eliminate the timeconsuming data entry). ? Separate duties and Inspectors from creating RFTAs and creating new vendors. ? Move creating units in Yardi to the Occupancy (new Program Office) department. Furthermore, DuPage Housing Authority has created a Procurement Department to retain an electronic filing system vendor. DHA currently utilizes physical file storage space within its DHA and KHA offices and an offsite storage unit. Employees have historically destroyed critical documents without authorized legal signoff. Name of Responsible Person: Cheron Corbett, Executive Director Projected Completion Date: December 31, 2023

View Audit 45321

Finding 51942 (2022-002)

Significant Deficiency 2022

Dupage Housing Authority

IL

HUD Housing Programs Reporting Significant Deficiency § 200.512

Finding 2022-02: Late Submission of Financial Statements to FAC and REAC (Significant Deficiency) Corrective Action Plan: DuPage Housing Authority (DHA) has existing controls in place, however, DHA had to seek an emergency authorization for a 60-day waiver extension for 2 CFR ? 200.512(a)(1) Report ...

Finding 2022-02: Late Submission of Financial Statements to FAC and REAC (Significant Deficiency) Corrective Action Plan: DuPage Housing Authority (DHA) has existing controls in place, however, DHA had to seek an emergency authorization for a 60-day waiver extension for 2 CFR ? 200.512(a)(1) Report Submission and the Financial Reporting Requirements per 24 CFR ? 902.33(b) for the FY2022 audit. Regulatory waivers provide relief from HUD requirements upon a finding of good cause, subject to statutory limitations, per 24 CFR 5.110. The DHA IL101 general audit submission date is March 31, 2023. DHA expected to have the financial audit submitted by April 30, 2023, as a result of the following reasons: ? Due to the abrupt quitting of the previously procured audit service provider, on February 7, 2023. DHA had to enter into an emergency Intergovernmental Agreement authorizing DuPage Housing Authority (DHA) to share the RFP process for independent audit service provider, Rubino and Company on February 27, 2023. The DHA IL101 HUD audit report submission per 2 CFR ? 200.512(a)(1) audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. The current DHA IL101 audit report submission was due March 31, 2023. ? The 60-Day Waiver extension was submitted to HUD for 2 CFR ? 200.512(a)(1) Report Submission and the Financial Reporting Requirements per 24 CFR ? 902.33(b) for the FY2022 audit will allow DHA an opportunity to avoid adverse effects including but not limited to: o Noncompliance of the audited financial data to HUD on an annual basis o Noncompliance of the annual audit being prepared in accordance with Generally Accepted Accounting Principles (GAAP), as further defined by HUD in supplementary guidance. o Noncompliance of the audited financial data being submitted electronically in the format prescribed by HUD using the Financial Data Schedule (FDS). ? HUD?s National Headquarters went through a recent organizational change; thus, delaying the approval process for the 60-dayextension waiver for 2 CFR ? 200.512(a)(1) Report Submission and the Financial Reporting Requirements per 24 CFR ? 902.33(b) for the FY2022 audit. ? DHA received official verbal approval from HUD?s Waiver Team on May 2, 2023, but the 60- day waiver extension for 2 CFR ? 200.512(a)(1) Report Submission and the Financial Reporting Requirements per 24 CFR ? 902.33(b) for the FY2022 audit is still awaiting final signature from the new HUD Deputy Assistant Secretary. Name of Responsible Person: Cheron Corbett, Executive Director Projected Completion Date: December 31, 2023

View Audit 45321

Finding 51939 (2022-001)

Material Weakness 2022

Crosspurpose

CO

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.413

Finding: 2022-001 Material Weakness in Internal Control over Financial Reporting and Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: During our testing, we noted reimbursement requests were ...

Finding: 2022-001 Material Weakness in Internal Control over Financial Reporting and Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: During our testing, we noted reimbursement requests were prepared using grant budgets rather than direct costs incurred. Management was unable to determine direct costs related to general and payroll disbursements. As a result, proper revenue recognition could not be determined for financial reporting purposes. Corrective Action Plan: The Organization will use the jobs and classes functions within their accounting software to track expenses related to grants. The Organization hired a Grant Coordinator to oversee the review, tracking, and reporting for all grants. The Organization will train and work with all applicable staff to create timesheets for grants requiring such documentation. The Organization will prepare a Schedule of Expenditures of Federal Awards (SEFA) which will be used in conjunction with the accounting software to track grant costs.

View Audit 45317

Finding 51933 (2022-003)

Significant Deficiency 2022

Prairie Inn Corporation

ND

Cash Management HUD Housing Programs Significant Deficiency

Finding 2022-003 - Special Provisions and Testing - Residual Receipts Account Federal Agency Name: US Department of Housing and Urban Development Program Name: Supportive Housing for Persons with Disabilities CFDA #: 14.181 Finding Summary: The corporation did not deposit project funds in a feder...

Finding 2022-003 - Special Provisions and Testing - Residual Receipts Account Federal Agency Name: US Department of Housing and Urban Development Program Name: Supportive Housing for Persons with Disabilities CFDA #: 14.181 Finding Summary: The corporation did not deposit project funds in a federally insured account within 60 days of fiscal year end. Responsible Individuals: Mary Simonson, Executive Director Corrective Action Plan: Management agrees with the finding and will review their internal control over compliance related to the program's residual receipts amount to ensure the excess operating funds be deposited in the fund account within 60 days following the end of the fiscal year. Anticipated Completion Date: Fiscal year 2023

View Audit 48726

Finding 51931 (2022-001)

None 2022

Sheridan Hill House Corporation

NY

Internal Control / Segregation of Duties

Sponsor is preparing.

View Audit 48722

Finding 51907 (2022-002)

Significant Deficiency 2022

Hospital District No 1 of Crawford County

KS

Questioned Costs HUD Housing Programs Reporting

Finding 2022-002: Corrective Action Plan: As new opportunities, applications, and reporting documents are prepared for Provider Relief Fund or other COVID-19 related funding, a second reviewer of the documentation prepared will be instituted requiring an approval prior to submission. Anticipated Com...

Finding 2022-002: Corrective Action Plan: As new opportunities, applications, and reporting documents are prepared for Provider Relief Fund or other COVID-19 related funding, a second reviewer of the documentation prepared will be instituted requiring an approval prior to submission. Anticipated Completion Date: We will implement any applicable corrective actions in 2023 for any new grant opportunities related to Provider Relief funds or other COVID-19 related grants.

View Audit 50821 Questioned Costs: $1

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