Corrective Action Plans

Finding 574006 (2024-003)

Significant Deficiency 2024

Community Housing Ii, Inc. the Maples II Apartments

OR

Questioned Costs HUD Housing Programs Matching / Level of Effort / Earmarking

Federal Award Findings and Questioned Costs Item 2024-003 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons with Disabilities (Section 811) Program Federal Assistance Listing: Number 14.157 Recommendation: Management shoul...

Federal Award Findings and Questioned Costs Item 2024-003 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons with Disabilities (Section 811) Program Federal Assistance Listing: Number 14.157 Recommendation: Management should immediately reimburse the amount due to the property and establish procedures to ensure payments of this nature are not made in the future. Action Taken: REACH has policies in place to ensure that costs are allocated to the appropriate property. In 2024, costs from an adjacent property, Community Housing I, were accidentally paid by Community Housing II. These funds were repaid to the Community Housing II in 2025. Completion Date: June 30, 2025

View Audit 364592 Questioned Costs: $1

Finding 574003 (2024-003)

Significant Deficiency 2024

Community Housing, Inc.

OR

HUD Housing Programs Special Tests & Provisions Eligibility

Federal Award Findings and Questioned Costs Item 2024-003 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Home Investment Partnership Program Federal Assistance Listing: Number 14.239 Recommendation: Management should establish procedures and monitor c...

Federal Award Findings and Questioned Costs Item 2024-003 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Home Investment Partnership Program Federal Assistance Listing: Number 14.239 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to ensure that HQS inspections are done in a timely manner. Staffing shortages at the property had an impact on the completion of HQS inspections in 2024. As new staff are brought onboard training is provided and management will continue to coordinate and provide assistance to on-site staff to ensure that the inspections are being completed and properties are in compliance.

View Audit 364591

Finding 573824 (2024-012)

Material Weakness 2024

Caddo County

OK

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.

View Audit 364483

Finding 573782 (2024-001)

Significant Deficiency 2024

Commonwealth Institute of Funeral Service

TX

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Education, Student Financial Assistance Programs Cluster, Assistance Listing #84.063, Federal Pell Grant Program, Assistance Listing #84.268, Federal Direct Student Loans, Contracts #...

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Education, Student Financial Assistance Programs Cluster, Assistance Listing #84.063, Federal Pell Grant Program, Assistance Listing #84.268, Federal Direct Student Loans, Contracts #003556 and G03556, Contract years: 05/05/21 – 12/31/26. Recommendation: Emphasize the importance of accurately reporting enrollment status. Planned corrective action: Management agrees with audit finding #2024-001. The Financial Aid Coordinator is responsible for reporting enrollment status changes, certifying enrollment every 60 days, and responding to NSLDS Roster files within 15 days, all through the NSLDSFAP website. To enhance the accuracy of these enrollment reports, the Institute is implementing a new double-check process. Henceforth, the Financial Aid Coordinator will print all enrollment status changes or enrollment report rosters prior to making any online updates or certifications. These printed reports will then be given to the Director of Operations for verification. Only after this verification will the Financial Aid Coordinator proceed with the necessary changes or certifications on the NSLDSFAP website. All printed reports will be retained by the Financial Aid Coordinator for documentation. Responsible officer: Cody Lopasky, President. Estimated completion date: June 1, 2025.

View Audit 364456

Finding 573777 (2024-001)

Significant Deficiency 2024

Pilgrim Towers, Inc.

CT

HUD Housing Programs Cash Management Reporting

We will continue to follow up with our HUD fuekd representative to determine the next steps for determining the repayment of the Flexible Subsidy Loan.

View Audit 364442

Finding 573762 (2024-002)

Significant Deficiency 2024

City of Thornton, Colorado

CO

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Federal Awards Finding 2024-002: Suspension and Debarment Finding: The City receives State and Local Fiscal Recovery Funds (SLFRF) from the U.S. Treasury as outlined in the American Rescue Plan Act (ARPA). In 2024, the City originally planned to utilize the ‘revenue replacement’ provision in ARP...

Federal Awards Finding 2024-002: Suspension and Debarment Finding: The City receives State and Local Fiscal Recovery Funds (SLFRF) from the U.S. Treasury as outlined in the American Rescue Plan Act (ARPA). In 2024, the City originally planned to utilize the ‘revenue replacement’ provision in ARPA and did not interpret the guidance at that time to require the check for suspension and debarment but rather thought that revenue replacement provision would require the City only to conduct “business as usual” regarding purchasing, acquisitions and contracts. However, after the first single audit was completed and new guidance was released by the treasury, it was determined that this requirement was needed and as all the contracts and purchases had been entered into or were at a stage where they could not be checked prior to award it was determined that prior to submitting any expenses to the treasury, each quarter that suspension and debarment checks would be done on any vendors/contracts with a purchase or contract greater than $25,000. Corrective Actions Taken or Planned: As there is no opportunity to correct this since all contracts are already in place for the ARPA SLFRF, we will continue to check for suspension and debarment each quarter before submitting the expenses to the Treasury and will not submit any expenses related to vendors or contractors that are suspended or debarred. We will implement a review by the controller to make sure that the suspension and debarment check is being done quarterly and will document such review. All other contracts and awards related to federal funds will continue to have the suspension and debarment check performed by the contracts and purchasing department before issuance of the contract or award. Anticipated Date of Implementation/Completion: July 31, 2025 Name of contact person responsible for correction action: Doug Farmen, Controller

View Audit 364417

Finding 573761 (2024-003)

Significant Deficiency 2024

City of Thornton, Colorado

CO

Reporting Subrecipient Monitoring HUD Housing Programs § 200.303

Federal Awards Finding 2024-003: Reporting Finding: The City receives Community Development Block Grant (CDBG) funding through the U.S. Department of Housing and Urban Development (HUD). During the year, the Cash on Hand & FFATA reporting did not have proper approval and review documentation. C...

Federal Awards Finding 2024-003: Reporting Finding: The City receives Community Development Block Grant (CDBG) funding through the U.S. Department of Housing and Urban Development (HUD). During the year, the Cash on Hand & FFATA reporting did not have proper approval and review documentation. Corrective Actions Taken or Planned: The Senior Accountant works with the Grant and Housing Supervisor to manage these funds. They will work together so that one employee completes the Cash on Hand or FFATA report and the other reviews, approves, and documents the approval. Anticipated Date of Implementation/Completion: July 31, 2025 Name of contact person responsible for correction action: Pam Goodwin, Senior Accountant

View Audit 364417

Finding 573696 (2024-001)

Significant Deficiency 2024

New Community Urban Renewal Corporation

NJ

HUD Housing Programs Matching / Level of Effort / Earmarking

New Community Urban Renewal Corporation (“NCURC”, “the Corporation” or “the Project”) agreed to a HUD proposal for repayment of the funds and adopted a resolution by the Board indicating such acceptance which was submitted to HUD and includes the following: 1. An acknowledgement of the obligations s...

New Community Urban Renewal Corporation (“NCURC”, “the Corporation” or “the Project”) agreed to a HUD proposal for repayment of the funds and adopted a resolution by the Board indicating such acceptance which was submitted to HUD and includes the following: 1. An acknowledgement of the obligations set forth in the Regulatory Agreement with HUD dated April 11, 1984 and the intention to fully comply with the provisions therein going forward. 2. NCURC’s affiliates, New Community Corporation (“NCC”) and New Community Healthcare, Inc.’s (“NCHC”) intention to make full restitution of the outstanding balances due to the Corporation. Annual payments will not be less than $150,000 for the next ten years beginning in 2015 through 2024. NCURC is currently in communication with HUD regarding the new repayment proposal. Until such time as the parties agree to new terms, NCURC’s intention is to continue making payments of not less than $150,000. 3. One year prior to the expiration of the 10-year repayment period (2023), a new repayment proposal will be provided to HUD requiring payments not less than $250,000 per year. NCURC is currently in communication with HUD regarding the new repayment proposal. 4. No Project funds or other HUD funds will be used as a source for repayment. 5. An accounting system must be maintained to track restitution payments acceptable to HUD. 6. Management is required to provide to HUD responses to any management letters received in connection with the annual audits. 7. Certain monthly financial reports and other program specific reports are required to be submitted to HUD. 8. The Boards of NCC / the Corporation are required to conduct quarterly compliance briefings with the minutes of such meetings sent to HUD.

View Audit 364332

Finding 573667 (2024-004)

Significant Deficiency 2024

Trilogy, Inc.

IL

Internal Control / Segregation of Duties Cash Management Significant Deficiency § 200.303

Action taken in response to finding: Trilogy will be conducting a comprehensive review of payroll records and timesheets for all employees whose salaries are charged to the grant. This includes verifying that the pay periods align with the grant’s allowable cost period and that supporting documentat...

Action taken in response to finding: Trilogy will be conducting a comprehensive review of payroll records and timesheets for all employees whose salaries are charged to the grant. This includes verifying that the pay periods align with the grant’s allowable cost period and that supporting documentation is complete and accurate. This will ensure that personnel costs are consistently reconciled with grant pay periods before charges are submitted for reimbursement. Relevant staff members will receive refresher training on grant compliance requirements, specifically focusing on documentation standards for personnel costs and the importance of aligning pay periods with grant terms. Trilogy will implement periodic internal audits to monitor compliance and ensure continued accuracy in personnel cost allocations. Name(s) of the contact person(s) responsible for corrective action: Shunita Rhodes & Hagar Buster Planned completion date for corrective action plan: July 2025

View Audit 364306

Finding 573666 (2024-003)

Significant Deficiency 2024

Trilogy, Inc.

IL

Questioned Costs Internal Control / Segregation of Duties Cash Management § 200.403

Action taken in response to finding: Trilogy will revise our monthly invoicing procedures to include a standardized step for verifying the indirect cost calculation. This will include recalculation of the indirect cost rate using actual monthly expenditures reflected in the grant invoices submitted...

Action taken in response to finding: Trilogy will revise our monthly invoicing procedures to include a standardized step for verifying the indirect cost calculation. This will include recalculation of the indirect cost rate using actual monthly expenditures reflected in the grant invoices submitted for reimbursement. This recalculation will ensure that indirect costs are proportionate and accurately reflect the approved rate and allowable base. Relevant staff members will receive training on proper indirect cost calculation methods, and how to apply the rate to the correct base and reconcile with monthly expenditures. We will implement a quarterly review of indirect cost charges to ensure continued accuracy and compliance. Any discrepancies will be addressed promptly and adjusted as needed. Name(s) of the contact person(s) responsible for corrective action: Shunita Rhodes & Hagar Buster Planned completion date for corrective action plan: July 2025

View Audit 364306 Questioned Costs: $1

Finding 573664 (2024-001)

Material Weakness 2024

Trilogy, Inc.

IL

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Action taken in response to finding: Trilogy has recently implemented a new payroll system UKG in January 2024 that includes enhanced functionality for tracking staff allocations across multiple grants and programs. This system also allows employees to self-report hours worked on specific grants or ...

Action taken in response to finding: Trilogy has recently implemented a new payroll system UKG in January 2024 that includes enhanced functionality for tracking staff allocations across multiple grants and programs. This system also allows employees to self-report hours worked on specific grants or non-grant activities if the varies from primary allocations ensuring that payroll costs are distributed based on actual effort. Allocations are reviewed monthly with program staff and updated as needed based, which improves the accuracy of cost distribution and ensures that payroll charges reflect current work assignments. Timecard hours are reviewed and approved by supervisors to maintain oversight. Staff involved in time reporting with grant management received training on the new system, allocation procedures, and federal requirements for payroll cost documentation. We are updating our timekeeping and payroll allocation policies to reflect the new system’s capabilities and to reinforce compliance with Uniform Guidance (2 CFR §200.430). These policies will include clear guidance on documenting effort and allocating wages across cost objectives. Name(s) of the contact person(s) responsible for corrective action: Shunita Rhodes and Hagar Buster Planned completion date for corrective action plan: January 2024

View Audit 364306 Questioned Costs: $1

Finding 573543 (2024-001)

Significant Deficiency 2024

Friendly Temple Apartments Ii, INC

MO

Questioned Costs HUD Housing Programs Significant Deficiency

Management agrees with this finding and the overpayment was corrected in March 2024. Management will review internal controls and implement a review process to only pay expenses already incurred to avoid future overpayments.

View Audit 364277 Questioned Costs: $1

Finding 573542 (2024-001)

Significant Deficiency 2024

West End Elderly Housing Corporation

MO

Questioned Costs HUD Housing Programs Significant Deficiency

Management agrees with this finding and the overpayment will be corrected. Management will review internal controls and implement a review process to only pay expenses already incmTed to avoid future overpayments.

View Audit 364276 Questioned Costs: $1

Finding 573510 (2024-003)

Material Weakness 2024

Engineers Without Borders USA

CO

Questioned Costs Allowable Costs / Cost Principles Cash Management

Corrective Action: 1. Review and revise existing policies and procedures for the application of indirect rates with the appropriate oversight by the Finance/Accounting department across federal grants to ensure accuracy and compliance with relevant regulations. 2. Review the allowable indirect rate ...

Corrective Action: 1. Review and revise existing policies and procedures for the application of indirect rates with the appropriate oversight by the Finance/Accounting department across federal grants to ensure accuracy and compliance with relevant regulations. 2. Review the allowable indirect rate methodologies to ensure the method used is based upon an equitable distribution across federal and non-federal programs. 3. Provide training to relevant staff on the revised policies, procedures to ensure the proper application of the indirect rate and calculation of indirect costs.

View Audit 364224 Questioned Costs: $1

Finding 573490 (2024-002)

Material Weakness 2024

Evangeline Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs HUD Housing Programs Reporting

2. Finding 2024-002 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding North TX A/C will repay the amount to the property and we will implement procedures to ensur...

2. Finding 2024-002 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding North TX A/C will repay the amount to the property and we will implement procedures to ensure that cash is not inadvertently sent to another company's bank account. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Year Findings, Questioned Costs and Recommendations None

View Audit 364210 Questioned Costs: $1

Finding 573484 (2024-007)

Material Weakness 2024

City of Lodi

CA

Reporting Allowable Costs / Cost Principles Material Weakness

Reference Number: 2024-007 – Delays in Financial Reporting Name of Contact Person: Chia Lor, Accounting Manager Corrective Action: Management agrees with the finding. The City has filled all of its vacant positions in Accounting and anticipates a timely completion of the 2024/25 Audit. Proposed...

Reference Number: 2024-007 – Delays in Financial Reporting Name of Contact Person: Chia Lor, Accounting Manager Corrective Action: Management agrees with the finding. The City has filled all of its vacant positions in Accounting and anticipates a timely completion of the 2024/25 Audit. Proposed Completion Date: December 31, 2025

View Audit 364209

Finding 573474 (2024-004)

Material Weakness 2024

Catherine Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs HUD Housing Programs Reporting

4. Finding 2024-004 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding This is related to the deposit error in 2024-002. North TX A/C repaid one deposit on Septemb...

4. Finding 2024-004 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding This is related to the deposit error in 2024-002. North TX A/C repaid one deposit on September 30, 2024 and will repay the remaining one-month deposit to the property. These funds will be correctly deposited into the replacement reserve account going forward. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Audit Findings, Questioned Costs and Recommendations 1. Finding 2023-001 In process. See finding 2024-003.

View Audit 364206 Questioned Costs: $1

Finding 573473 (2024-003)

Material Weakness 2024

Catherine Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs HUD Housing Programs Reporting

3. Finding 2024-003 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding 2 HUD approved the $75,000 repaid as a response to a 2022 finding. HUD has not reached out t...

3. Finding 2024-003 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding 2 HUD approved the $75,000 repaid as a response to a 2022 finding. HUD has not reached out to management for repayment of the $23,000, however, management will seek evidence of HUD approval for the remaining $23,000 repaid.

View Audit 364206 Questioned Costs: $1

Finding 573467 (2024-003)

Material Weakness 2024

Bibb County Board of Education

AL

Questioned Costs Matching / Level of Effort / Earmarking Special Tests & Provisions

We are award of the Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "David-Bacon Act") when using COVID-19 Education Stabilizaiton Funds to fund construction contracts in excess of $2,000. We will ensure the Davis-Bacon Act ...

We are award of the Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "David-Bacon Act") when using COVID-19 Education Stabilizaiton Funds to fund construction contracts in excess of $2,000. We will ensure the Davis-Bacon Act wage rate is included in all construction contracts over $2,000.

View Audit 364195 Questioned Costs: $1

Finding 573383 (2024-003)

Material Weakness 2024

County of Sutter

CA

Reporting Allowable Costs / Cost Principles Material Weakness

Name of Contact Person Nathan Black, Auditor-Controller Management's Response and Corrective Action The County agrees with the finding. Due to extenuating circumstances resulting in delays from the ERP implementation, the County made efforts to inform the cognizant agencies and requested a filing...

Name of Contact Person Nathan Black, Auditor-Controller Management's Response and Corrective Action The County agrees with the finding. Due to extenuating circumstances resulting in delays from the ERP implementation, the County made efforts to inform the cognizant agencies and requested a filing extension. Unfortunately, the extension request was denied. The County does not anticipate these delays will affect future reporting periods as they were one-time occurrences due to system conversion and post go-live difficulties. The County has been compliant with Single Audit submission deadline for at least the 9 prior years. Proposed Completion Date 08/08/2025

View Audit 364158

Finding 573382 (2024-004)

Significant Deficiency 2024

County of Sutter

CA

Significant Deficiency Matching / Level of Effort / Earmarking

Name of Contact Person Nathan Black, Auditor-Controller Management's Response and Corrective Action The County agrees with the finding. Development Services sent certified letters to loan recipients and retained certified or returned mail. In some cases, the department sent up to 4 letters and ph...

Name of Contact Person Nathan Black, Auditor-Controller Management's Response and Corrective Action The County agrees with the finding. Development Services sent certified letters to loan recipients and retained certified or returned mail. In some cases, the department sent up to 4 letters and physically verified the houses are still occupied. Code Enforcement staff also hand delivered letters to some of the non-responsive loan recipients. Moreover, the Department has secured the services of an outside consultant, Adams Ashby Group, to review and assist in efforts to comply with the loan requirements and provide their outside opinion on best practice in handling loans. Lastly, the Department is working with County Administrator's Office, Treasurer-Tax Collector's Office, and County Counsel on proper and legal way to handle sold properties, delinquent taxes, or simply not responding to the County's correspondence and requests. Proposed Completion Date Ongoing process.

View Audit 364158

Finding 573352 (2024-007)

Significant Deficiency 2024

Leech Lake Tribal College

AZ

Student Financial Aid Reporting Significant Deficiency § 200.328

The Department has ramped up recruiting efforts by advertising positions on external websites such as indeed. The accounting department has recently increased the wages of existing staff and the starting wages of all positions in an effort to attract and retain qualified staff.

View Audit 364132

Finding 573347 (2024-006)

Significant Deficiency 2024

Leech Lake Tribal College

AZ

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.328

The Department has ramped up recruiting efforts by advertising positions on external websites such as indeed. The accounting department has recently increased the wages of existing staff and the starting wages of all positions in an effort to attract and retain qualified staff.

View Audit 364132

Finding 573315 (2024-003)

Material Weakness 2024

Ouachita Parish Police Jury

LA

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.328

Management acknowledges the need for compliance with reporting requirements for COVID-19 State and Local Fiscal Recovery Funds. We will follow the auditors’ recommendation to review our policies and procedures to ensure that internal controls are properly designed, implemented and maintained to ensu...

Management acknowledges the need for compliance with reporting requirements for COVID-19 State and Local Fiscal Recovery Funds. We will follow the auditors’ recommendation to review our policies and procedures to ensure that internal controls are properly designed, implemented and maintained to ensure accurate and timely financial close and reporting.

View Audit 364114

Finding 573274 (2024-003)

Significant Deficiency 2024

Sunrise Residential, Inc.

IL

HUD Housing Programs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding Reference Number: 2024-03 View of Responsible Officials and Corrective Actions: Management agrees with the finding. Management will establish procedures and monitor compliance with those procedures to ensure cash disbursements of project funds are limited to project operating costs. Expens...

Finding Reference Number: 2024-03 View of Responsible Officials and Corrective Actions: Management agrees with the finding. Management will establish procedures and monitor compliance with those procedures to ensure cash disbursements of project funds are limited to project operating costs. Expense paid from project funds for an affiliated project will be reimbursed to the project. Contact Persons Responsible: Dr. Sharrone Ward, President and Chief Executive Officer Kim Shelton-Mamon, Vice President of Finance Billie Williams, President of Active Real Estate Management Completion Date: Open

View Audit 364065

Corrective Action Plans

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