Corrective Action Plans

Finding 1154984 (2024-004)

Material Weakness 2024

American Indian Council on Alcoholism Inc.

WI

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.318

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional procurement policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person:...

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional procurement policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025

View Audit 367335 Questioned Costs: $1

Finding 1154943 (2024-001)

Material Weakness 2024

Bronx Community Health Network, Inc.

NY

Reporting Subrecipient Monitoring HUD Housing Programs § 200.303

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-001 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) Description of Finding: Th...

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-001 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) Description of Finding: The FFATA subawards were not submitted timely to the Federal Funding Accountability and Transparency Act Subaward Reporting System (“FSRS”). The review and approval occurred after the FFATA subaward was submitted to the FSRS. Statement of Concurrence: We concur with the finding above. Corrective Action: BCHN has created a policy regarding the FFATA reporting process. In this process the Electronic Handbook (EHB) is reviewed weekly to ensure that if new awarded funding is released, BCHN is alerted to the need to complete the FFATA report. BCHN has created a spreadsheet to track all the awarded funding and due dates for FFATA reports. Every month, at the board meeting, the spreadsheet is presented to the board with any new awarded funding and when the FFATA report is completed. BCHN has begun a process where the FFATA report is put together by the Finance Manager and reviewed and signed off by the CFO before submitting the report. Completion Date: October 2024. Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer

View Audit 367254

Finding 1154942 (2024-004)

Material Weakness 2024

Bronx Community Health Network, Inc.

NY

Allowable Costs / Cost Principles HUD Housing Programs Period of Performance § 200.303

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-004 – Period of Performance Description of Finding: There was no evidence, such as a signature, evidencin...

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-004 – Period of Performance Description of Finding: There was no evidence, such as a signature, evidencing review and approval by a direct supervisor of the timesheets. Time and effort reports were not done. Statement of Concurrence: We concur with the finding above. Corrective Action: BCHN has put together a training program for employees to ensure that timecards are reviewed and approved by both the employee and the supervisor on a bi-weekly basis. Before payroll is processed, approvals by employees and supervisors will be checked. HR will provide a monthly time and effort report to the finance team. This report will provide total number of hours worked by each employee for each assigned cost center. Completion Date: October 2024. Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer

View Audit 367254

Finding 1154861 (2024-003)

Material Weakness 2024

Housing Authority of Trempealeau County

WI

Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking Eligibility § 200.303

Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. We agree that implementing an independent review process will strengthen accuracy and compliance with Rural Development requirements. Actions taken or planned The organization will as...

Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. We agree that implementing an independent review process will strengthen accuracy and compliance with Rural Development requirements. Actions taken or planned The organization will assign preparation and review of RD Form 3560-8 and HUD Form 50058 to different staff members. Anticipated completion date September 30, 2025

View Audit 367201

Finding 1154851 (2024-001)

Material Weakness 2024

Hawaii Good Food Alliance

HI

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.430

Effective January 1, 2025, employees are required to complete a monthly Personnel Activity Report (PAR) where the employees document the percentage of time they spent for each grant/program during the month with a brief description of the work performed for each project. The completed form is signed...

Effective January 1, 2025, employees are required to complete a monthly Personnel Activity Report (PAR) where the employees document the percentage of time they spent for each grant/program during the month with a brief description of the work performed for each project. The completed form is signed by the employee and their supervisor, then retained for our records. Effective September 1, 2025, monthly PARs will include contemporaneous certification by the employee that the distribution of hours worked is correct.

View Audit 367196

Finding 1154850 (2024-001)

Material Weakness 2024

City of Cheney

WA

Questioned Costs Reporting Matching / Level of Effort / Earmarking

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Cheney January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 20...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Cheney January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported 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: 2024-001 Finding caption: The City did not have adequate internal controls for ensuring compliance with federal allowable costs, matching and reporting requirements, and it did not comply with federal allowable costs and matching requirements. Name, address, and telephone of City contact person: Cindy Niemeier, Finance Director 609 2nd Street Cheney, WA 99004 509-498-9215 Corrective action the auditee plans to take in response to the finding: The City of Cheney recognizes the error in classifying a grant received from the Washington State Department of Commerce as a state grant rather than a federal pass through grant, which makes this funding source ineligible as matching funds in the funding awarded from the Department of Reclamation. The City has contacted the Department of Reclamation federal program to disclose the error and determine the required corrective action. The City of Cheney has proposed replacing the submitted reimbursement requests with City expenses as allowable matching expenses. The City is currently waiting on the Department of Reclamation for direction. The 2024 reporting error was corrected in 2025. Future projects with multiple funding sources will continue to be managed by the individual departments. The additional internal control will require the departments to meet quarterly with Finance to conduct internal audits of the reimbursement requests and completed reporting. Anticipated date to complete the corrective action: December 31, 2025

View Audit 367195 Questioned Costs: $1

Finding 1154809 (2024-001)

Material Weakness 2024

Housing Authority of the City of Decatur, Georgia

GA

HUD Housing Programs Eligibility Material Weakness

CORRECTIVE ACTION PLAN August28, 2025 Cognizant oversight agency: U.S. Department of Housing and Urban Development The Housing Authority of the City of Decatur, Georgia respectfully submits the following corrective action plan for the year ended December 31 , 2024. Audit Firm: CohnReznick LLP 3560 L...

CORRECTIVE ACTION PLAN August28, 2025 Cognizant oversight agency: U.S. Department of Housing and Urban Development The Housing Authority of the City of Decatur, Georgia respectfully submits the following corrective action plan for the year ended December 31 , 2024. Audit Firm: CohnReznick LLP 3560 Lenox Road, Suite 2900 Atlanta, Georgia 30326 Audit period: for the year ended December 31, 2024 The finding from the December 31 , 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING-FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2024-001 Housing Voucher Cluster -AL Nos. 14.871 , 14.879 Recommendation: the Authority reviews its internal controls to reduce the risk of unauthorized access to and/or misuse of PII contained within the EIV reports in the future to ensure compliance with eligibility requirements. Action Taken: As part of the Authority's standard internal controls, all HCV employees with access to EIV are required to sign the Rules of Behavior and complete HUD's annual cybersecurity training. In addition, the Authority maintains physical security measures and general IT controls onsite to reduce risks associated with unauthorized access. Since the incident occurred, the Authority has implemented several additional measures to strengthen data protection practices. Specifically: •Issued a new Information Protection Policy and Confidentiality Agreement, which all employees are required to review and sign. ·Conducted an all-staff training session to review the new policy in detail and reinforce best practices for safeguarding participant information. •The Chief Executive Officer reiterated the Authority's commitment to data security and emphasized that any violation of information protection policies will result in disciplinary action, up to and including termination of employment, as well as potential legal prosecution. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Larry H. Padilla, CEO at 404-270-2101. Larry H. Padilla CEO/Executive Director

View Audit 367171

Finding 1154798 (2024-003)

Material Weakness 2024

Samuel Merritt University

CA

Matching / Level of Effort / Earmarking

Planned Corrective Action The University recognizes the deficiencies in maintaining proper documentation related to exit interviews for the Nursing Student Loan program. In response, the University is updating its policies and procedures to ensure full compliance with 42 CFR Part 57 § 57.310 (b), in...

Planned Corrective Action The University recognizes the deficiencies in maintaining proper documentation related to exit interviews for the Nursing Student Loan program. In response, the University is updating its policies and procedures to ensure full compliance with 42 CFR Part 57 § 57.310 (b), including: -Requiring signed Truth in Lending Statements for all borrowers -Maintaining evidence of mailings in cases where borrowers fail to attend in-person exit interviews or failed to return the mailing -Implementing a checklist and file audit process to ensure all required documentation is consistently retained Staff involved in loan processing and management will be retrained to ensure awareness of the regulatory documentation requirements. Implementation Date -Policy & Procedure Update: December 31, 2025 -Staff Training Completion: October 31, 2025 Responsible Personnel Tony Baraghimian Deputy CFO & Controller

View Audit 367160

Finding 1154235 (2024-001)

Material Weakness 2024

People Acting in Community Endeavors, Inc.

MA

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Reporting

Management strives to operate within a model of continuous improvement and will review and improve processes appropriately to provide for timely reporting on a go-forward basis.

View Audit 367150

Finding 1154225 (2024-001)

Material Weakness 2024

County of Milwaukee

WI

Allowable Costs / Cost Principles Student Financial Aid Reporting § 200.303 § 200.430

Condition In two instances, the amounts recorded in the General Ledger (GL) did not match the corresponding amounts recorded in the payroll system. Corrective Action Plan Corrective Action Planned: Efforts were taken to verify Dayforce is configured to allocate salary expenses to an employee’s home ...

Condition In two instances, the amounts recorded in the General Ledger (GL) did not match the corresponding amounts recorded in the payroll system. Corrective Action Plan Corrective Action Planned: Efforts were taken to verify Dayforce is configured to allocate salary expenses to an employee’s home agency and department, regardless of where the employee assigns their hours in the timekeeping system. While the timesheet programmatic reflects the agency and department where hours and dollars are functionally charged, the payroll register aligns with the General Ledger based on home agency coding. As a result, the Payroll Register and General Ledger will reconcile with each other but may not align with programmatic reports, which are based on timesheet-level allocations. This system behavior is consistent with current configuration and financial reporting practices. The Payroll Department and the DHHS will meet in Q3 2025 to ensure grant/expense tracking activities are working as intended. Name(s) of Contact Person(s) Responsible for Corrective Action: Sue Drummond, Director Payroll & HRIS Interface Anticipated Completion Date: Completed January 2025.

View Audit 367148

Finding 1154183 (2024-004)

Material Weakness 2024

Lawrence County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

August 20, 2025 FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Martha L. Arnold-Turner Contact Phone Number and Email Address: 812-275-3111, mturner@...

August 20, 2025 FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Martha L. Arnold-Turner Contact Phone Number and Email Address: 812-275-3111, mturner@lawrencecounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The county corrective action plan will be designed to implement a proper system of internal controls that will ensure compliance with the Reporting requirements of the grant. - The County will implement internal controls that will prevent or correct noncompliance. For all Federal grants that require reports, after one person prepares the report, another person will review the report for accuracy and completeness prior to it being submitted. Anticipated Completion Date: 12/31/2025

View Audit 367099

Finding 1154182 (2024-003)

Material Weakness 2024

Lawrence County

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

August 20, 2025 FINDING 2024-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Lead Reduction Grant - Reporting Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Paula Kern-Edwards Contact Phone Number and Email Address: 812-275-3234, pedwa...

August 20, 2025 FINDING 2024-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Lead Reduction Grant - Reporting Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Paula Kern-Edwards Contact Phone Number and Email Address: 812-275-3234, pedwards@lawrencecounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The county corrective action plan will be designed to implement a proper system of internal controls that will ensure compliance with the Reporting requirements of the grant. - The County Health Department will implement internal controls that will prevent or correct noncompliance. The Health Department Director will review all reports related to Federal Grants prior to submission, after they have been prepared by another employee. Anticipated Completion Date: 12/31/2025

View Audit 367099

Finding 1154178 (2024-004)

Material Weakness 2024

Evangeline Booth Residence, Inc., A Florida Corporation

FL

Questioned Costs Special Tests & Provisions HUD Housing Programs

Finding 2024-004 Comments on the Finding and Each Recommendation The auditee agrees that retained replacement reserve withdrawal forms did not include HUD signature, though HUD did approve the withdrawals. Action(s) Taken or Planned on the Finding Management will reach out to HUD to obtain evidence ...

Finding 2024-004 Comments on the Finding and Each Recommendation The auditee agrees that retained replacement reserve withdrawal forms did not include HUD signature, though HUD did approve the withdrawals. Action(s) Taken or Planned on the Finding Management will reach out to HUD to obtain evidence of approval of the specific withdrawal in question. Management will implement procedures to request from HUD and retain a copy of each signed 9250 going forward.

View Audit 367098 Questioned Costs: $1

Finding 1154177 (2024-003)

Material Weakness 2024

Evangeline Booth Residence, Inc., A Florida Corporation

FL

Questioned Costs Special Tests & Provisions HUD Housing Programs

Project Legal Name: Evangeline Booth Residence, Inc., A Florida Corporation HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2023 – 9/30/2024 Corrective Action Plan prepared by: Name: Lee Auvenshine Position: Territorial Legal Director-General Counsel (THQ...

Project Legal Name: Evangeline Booth Residence, Inc., A Florida Corporation HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2023 – 9/30/2024 Corrective Action Plan prepared by: Name: Lee Auvenshine Position: Territorial Legal Director-General Counsel (THQ legal) Telephone Number: 404-728-6700 Finding 2024-003 Comments on the Finding and Each Recommendation The auditee agrees that replacement reserve deposits were not made. This was a result of significant delays in PRAC funding that severely affected cash flows. Action(s) Taken or Planned on the Finding Once the PRAC issues were corrected our cash flows have improved to allow us to make past due deposits. We will also reach out to our HUD account executive to discuss possible waiving of past due deposits.

View Audit 367098 Questioned Costs: $1

Finding 1154163 (2024-002)

Material Weakness 2024

Housing Authority of the City of Dothan

AL

Questioned Costs Cash Management HUD Housing Programs

2024-002 – ALN 14.881 – Moving to Work Demonstration Program – Allowable Activities Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Samuel Crawford, Chief Execu...

2024-002 – ALN 14.881 – Moving to Work Demonstration Program – Allowable Activities Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Samuel Crawford, Chief Executive Officer Projected Completion Date: Ongoing work in progress. No completion date can currently be determined.

View Audit 367072 Questioned Costs: $1

Finding 1154162 (2024-004)

Material Weakness 2024

Grant County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2024-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Angela Jarvis, County Auditor Contact Phone Number and Email Address: 765-668-6552 ajarvis@grantcounty.in.gov Views of Responsible Officials: W...

FINDING 2024-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Angela Jarvis, County Auditor Contact Phone Number and Email Address: 765-668-6552 ajarvis@grantcounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal Controls, although in place, will require additional signatures when completing the online reporting of the required quarterly reports. Anticipated Completion Date: This will be completed by September 9, 2025.

View Audit 367070

Finding 1154120 (2024-003)

Material Weakness 2024

Santa Fe Community Housing Trust

NM

Reporting Allowable Costs / Cost Principles Cash Management

View of Responsible Official The Housing Trust acknowledges the finding. Prior staffing and system limitations created gaps in tracking recycled funds and aligning general ledger data to SEFA. Since then: - A dedicated Finance Manager now oversees all financial activities. - A grant-specific chart o...

View of Responsible Official The Housing Trust acknowledges the finding. Prior staffing and system limitations created gaps in tracking recycled funds and aligning general ledger data to SEFA. Since then: - A dedicated Finance Manager now oversees all financial activities. - A grant-specific chart of accounts structure has been created in QBO. - Each grant now has a dedicated class and project for transaction tracking. - Recycled funds are being tracked separately from new funds in both QBO and the reimbursement log. - SEFA schedules will be reconciled monthly and reviewed with each billing cycle. Corrective Action Plan Timeline - Finalize and adopt new Grant Management Policies: by September 2025 - Implement monthly SEFA reconciliations: by September 2025 - Complete staff training on program income and federal grant tracking: by September 2025 Designated Employee Responsible for Corrective Action - Finance Manager - Assets Specialist Assistant - Accounting Technician

View Audit 367044

Finding 1154089 (2024-002)

Material Weakness 2024

The Carle Foundation

IL

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending accurate file submissions t...

The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending accurate file submissions to NSC in June 2024. Files generated and submitted under the College’s new processes are taking roughly one week to process from initial submission, through error correction, and finalization.

View Audit 366981

Finding 1153873 (2024-005)

Material Weakness 2024

Chicago Housing Authority

IL

HUD Housing Programs Special Tests & Provisions Reporting § 200.303

Finding 2024-005 N. Special Tests and Provisions: N1. Wage Rate Requirements – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. A review of the process was completed, and the procedure will be updated to include language that no...

Finding 2024-005 N. Special Tests and Provisions: N1. Wage Rate Requirements – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. A review of the process was completed, and the procedure will be updated to include language that notes until all documents are received, the contract file should be notated and remain open. The checklist will be updated as well. A review of the pending invoice payments will be completed by Internal Audit of the User Groups to ensure timely close out of projects can be completed. Contact Person: Shelia Johnson, Deputy Chief Procurement Anticipated Completion Date: End of 4th Qtr. 2025

View Audit 366932

Finding 1153872 (2024-004)

Material Weakness 2024

Chicago Housing Authority

IL

HUD Housing Programs Special Tests & Provisions Matching / Level of Effort / Earmarking § 200.303

Finding 2024-004 N. Special Tests and Provisions: N4. NSPIRE/Housing Quality Standards (HQS) Inspections – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The inspections identified as findings during the audit were part of HQS Inspections compliance controls enacted ...

Finding 2024-004 N. Special Tests and Provisions: N4. NSPIRE/Housing Quality Standards (HQS) Inspections – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The inspections identified as findings during the audit were part of HQS Inspections compliance controls enacted in accordance with direction from HUD to ensure inspections missed due to COVID-19 waivers were completed. CHA will continue to monitor HQS inspections scheduling program-wide via Yardi reporting and Power BI dashboards to ensure compliance with HUD mandated timelines. Contact Person: Cheryl Burns, Chief HCV Officer Anticipated Completion Date: End of 3rd Qtr. 2025

View Audit 366932

Finding 1153871 (2024-003)

Material Weakness 2024

Chicago Housing Authority

IL

HUD Housing Programs Special Tests & Provisions Internal Control / Segregation of Duties § 200.303

Finding 2024-003 N. Special Tests and Provisions: N3. Utility Allowance Schedule – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The Authority acknowledges the finding regarding the retention of supporting documentation for the utility allowance schedule analysis an...

Finding 2024-003 N. Special Tests and Provisions: N3. Utility Allowance Schedule – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The Authority acknowledges the finding regarding the retention of supporting documentation for the utility allowance schedule analysis and related approvals. To address this, the CHA has established a Compliance Team to oversee documentation retention and review processes. In 2025, CHA has instituted procedures to ensure all supporting documentation is retained, including: • Inputs from the third-party vendor’s analysis of utility allowance schedule changes; • Evidence of management’s review and approval of the annual utility allowance schedule; • Signed and dated utility allowance notice with effective date instructions and copies of the new schedules. • The final report is maintained in a central location by the user group, ensuring accessibility for reference and audit purposes. Timeline • Implementation began Quarter 3 2025 and is ongoing. Contact Person: Leonard Langston, Jr., Interim Chief Property Officer Anticipated Completion Date: End of 3rd Qtr. 2026

View Audit 366932

Finding 1153870 (2024-002)

Material Weakness 2024

Chicago Housing Authority

IL

HUD Housing Programs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Finding 2024-002 N. Special Tests and Provisions: N17. Environmental Contaminants Testing and Remediation – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Under the recent Property and Asset Management (PAM) reorganization and CHA’s Year of Renewal, the Healthy Homes...

Finding 2024-002 N. Special Tests and Provisions: N17. Environmental Contaminants Testing and Remediation – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Under the recent Property and Asset Management (PAM) reorganization and CHA’s Year of Renewal, the Healthy Homes Division was established to identify and address historic indoor environmental health hazards and proactively engage CHA programs in primary prevention strategies. In addition to regulatory lead and asbestos compliance, the Healthy Homes team will engage on mold, pest/pesticides, indoor air quality, and other indoor environmental concerns. Strategies include, but are not limited to: • Establish a compliance assurance protocol and tracking system and engage appropriate regulatory agencies (HUD, Illinois Department of Public Health, U.S. Environmental Protection Agency, Chicago Department of Public Health) • Establish records management schedule related to inspections, abatement or remediation, and clearance testing • Draft Quality Assurance Performance Plan and Scientific Integrity Policy • Track, route, and review applicable healthy homes-related work orders • Create screening and assessment criteria (for inspection schedules) • Provide basic environmental health training to CHA staff and media-specific training to appropriate programs (for instance, mold cleanup for Property Operations Managers) • Coordinate training and review certification/license of CHA contractors (construction vendors and property management firms) • Establish policies, procedures, and best practices guidance Timeline: Spring/Summer 2025: - Healthy Homes Team (within PAM) established and full team build out begins. Team hiring will be complete by September 2025. o Healthy Homes Director (1) o Environmental Health and Safety Managers (2) o Environmental Health and Safety Analysts (2) o Quality Assurance/Quality Control Analyst (1) - Coordinated renovation, repair, and painting (RRP) training for construction vendors, inhouse construction project management, and Property Management firms (16 courses, 20 participants each, between June and October). RRP is a federal regulation that requires lead-safe work practices in targeted housing. Established CHA’s RRP Policy that requires all construction and maintenance staff and vendors to be RRP certified by November 2025. All maintenance, repair, renovation, rehabilitation, or construction work will be done under RRP, in both target and non-target housing. Current and ongoing into 2026: - Drafting policies, procedures, and best practices guidance for construction and property operations, including but not limited to life-cycle abatement manual, lead safe work practices, safe mold clean-up and best practices, and lead abatement during unit turns - Creating a data management system which includes relevant unit inventory and recurrent inspection schedules. Contact Person: Leonard Langston, Jr., Interim Chief Property Officer Anticipated Completion Date: Q1 2026

View Audit 366932

Finding 1153869 (2024-001)

Material Weakness 2024

Chicago Housing Authority

IL

HUD Housing Programs Eligibility Special Tests & Provisions § 200.303

Finding 2024-001 E. Eligibility, L. Reporting (Form HUD-50058 MTW), and N. Special Tests and Provisions – N1. Waiting List, N2. Reasonable Rent, N3. Utility Allowance Schedule, N6. Housing Assistance Payment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Since Janu...

Finding 2024-001 E. Eligibility, L. Reporting (Form HUD-50058 MTW), and N. Special Tests and Provisions – N1. Waiting List, N2. Reasonable Rent, N3. Utility Allowance Schedule, N6. Housing Assistance Payment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Since January 2025, CHA’s Property and Asset Management Division has been engaged in an extensive reorganization to expand resources that will improve compliance and increase controls around program compliance. With this restructuring, precise policies, procedures, and internal controls are being implemented as outlined below. Timeline: February 2025 • Added additional Property Operations Managers to allow for more oversight of day-to-day site activity April 2025 • Creation of a new Compliance team, who will function as a hub on both regulatory and contract compliance for Public Housing and RAD programs. Part of this team was created to focus specifically on program eligibility—either directly or through oversight of third-party management firms—and is staffed accordingly: o Director of Compliance o Senior Manager of Compliance o Compliance Specialist June 2025 • Worked to finalize solicitation for third party firm to perform monthly tenant file reviews, provide comprehensive reporting on general findings, patterns, training needs, and gross compliance concerns. CHA staff will implement trainings and contract enforcement as necessary to ensure compliance standards are raised, and controls are being adhered to. These monthly tenant file reviews are expected to continue in addition to the routine file audits conducted by Property Operations Managers. October 2025 • Updated manuals for Property Operations will be completed, distributed, and trained on to ensure site operations meet compliance standards and controls are being adhered to. Initiated and ongoing actions • Frequent business meetings with third party firms to discuss performance and expectations • Trainings required as necessary • Contract enforcement, up to and including contract termination, when chronic disregard for or misapplication of policies and/or procedures are noted Contact Person: Leonard Langston, Jr, Interim Chief Property Officer Anticipated Completion Date: Q4 2025 Response/Planned Actions: The CHA will review quality control procedures currently in place by Housing Choice Voucher (HCV) program administration to ensure processes are sound and efficient and proper prevent controls are in place. All quality control processes in place must effectively ensure accuracy and timeliness of completed recertifications, including submission of Form HUD-50058s to the U.S. Department of Housing and Urban Development’s (HUD’s) PIH Information Center (PIC) system. CHA will also develop internal detect control reports to monitor the timelines for recertification scheduling and tracking. CHA conducts monthly follow-up to ensure corrections are made to records identified as “fails” during the monthly quality control review. All “fails” items are tracked and monitored until resolution for final determination has been achieved. Contact Person: Cheryl Burns, Chief HCV Officer Anticipated Completion Date: End of 3rd Qtr. 2025

View Audit 366932

Finding 1153856 (2024-009)

Material Weakness 2024

Florida Crown Workforce Board, INC

FL

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

2024-009 WIOA Cluster Matching Noncompliance Criteria: According to the Compliance Supplement, 2 CFR PART 200, APPENDIX XI, published by the Office of Management and Budget (OMB) for the WIOA Cluster, Local Areas: "(1) A local area may expend no more than 10 percent of the Adult, Dislocated Worker, ...

2024-009 WIOA Cluster Matching Noncompliance Criteria: According to the Compliance Supplement, 2 CFR PART 200, APPENDIX XI, published by the Office of Management and Budget (OMB) for the WIOA Cluster, Local Areas: "(1) A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations." Condition: In the current year, the Organization failed to expend no more than 10% in administrative costs in the WIOA cluster, expending 13.31%. Cause: The Organization did not properly monitor administrative expenses for the WIOA Cluster to ensure that the overall percentage allocated to administrative expenses was no more than 10%. Effect: The Organization was not in compliance with the Matching requirements under the WIOA cluster. Recommendation: We recommend that the Organization ensure that expenses - and specifically administrative expenses - be properly tracked to ensure compliance with WIOA cluster grant requirements. Response: Management concurs with the finding and recommendation. Due to the termination of awards effective June 28, 2024, FL Crown did not have the ability to reclassify administrative costs to subsequent program year awards. The new consolidated entity, LWDB 26, monitors the 10% cap with each monthly cash draw and benefits from having an interlocal agreement with Alachua County to provide administrative support services at a capped rate of 3.5% of formula awards.

View Audit 366929 Questioned Costs: $1

Finding 1153829 (2024-003)

Material Weakness 2024

Trinity Acres Housing Corporation

IL

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

The Corporation will register the PPP loan with the SBA to determine the course of action that can be taken.

View Audit 366918

Corrective Action Plans

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