Corrective Action Plans

Finding 517243 (2024-011)

Material Weakness 2024

OR

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

The District will improve internal controls by incorporating the involvement of a grant manager who is knowledgeable of grant requirements to approve expenditures.

View Audit 335260

Finding 517242 (2024-010)

Material Weakness 2024

Union County School District #23

OR

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

The District will improve internal controls by incorporating the involvement of a grant manager who is knowledgeable of grant requirements to approve expenditures.

View Audit 335260

Finding 517233 (2024-001)

Material Weakness 2024

Columbia Village

MN

Material Weakness Reporting Internal Control / Segregation of Duties

Management will continue to rely on their independent certified public accountant for assistance with their financial statement preparation.

View Audit 335234

Finding 517131 (2024-002)

Significant Deficiency 2024

Brevard Housing Authority

NC

Questioned Costs HUD Housing Programs Special Tests & Provisions

Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Numbers: 14.850 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Fi...

Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Numbers: 14.850 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its Admissions and Continued Occupancy Policy for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203(Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that new move-ins were selected from the wait list in an order that is in accordance with the Authority’s policy. Context: Two (2) names were selected from the new move-in list and those names were to be traced to the waiting list to verify new move-ins were chosen in an order that was in accordance with the Authority’s policy. It was determined that one (1) out of two (2) new move-ins selected could not be traced with any certainty back to the Authority's waiting list. Known Questioned Costs: $3,320 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selections from the waiting list as proper documentation for new admissions was not maintained. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Public and Indian Housing Program is in material non-compliance with the special tests and provisions type of compliance related to selections from the waiting list, as new admissions to the program could be admitted in violation of HUD roles and the Authority’s Admissions and Continued Occupancy Policy. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority has recognized the material weakness in the Public and Indian Housing Program and will implement internal control procedures that will ensure compliance with federal regulations. Rhodney Norman, Interim CEO, will be responsible to implement this corrective action by March 31, 2025.

View Audit 335003 Questioned Costs: $1

Finding 516962 (2024-002)

Material Weakness 2024

St. Clair County Housing Authority

IL

Questioned Costs HUD Housing Programs Eligibility

Finding 2024·002 - Low Rent Public Housing Tenant Files - Eligibility- Rent Calculations Noncompliance & Material Weakness Low Rent Public Housing-ALN #14.850 Corrective Action Plan: 1) SCCHA plans to engage ap industry consultant to assess its internal processes and procedures concerning eligibilit...

Finding 2024·002 - Low Rent Public Housing Tenant Files - Eligibility- Rent Calculations Noncompliance & Material Weakness Low Rent Public Housing-ALN #14.850 Corrective Action Plan: 1) SCCHA plans to engage ap industry consultant to assess its internal processes and procedures concerning eligibility and tenant rent calculations, particularly focusing on the computation of adjusted annual income, to enhance accuracy and streamline the overall process. 2) The Compliance & Integrity Coordinator will examine the audited files and conduct individual meetings with each team member to discuss any identified errors, as well as to clarify the procedures and policies that contribute to the recurrence of these mistakes. The Compliance Officer, the employee, and the Program Director will sign the documentation, which will be added to the employee's file. 3) Monthly peer-to-peer audits will be conducted, accompanied by a staff meeting to collectively review identified errors. This approach aims to facilitate continuous training and encourages active participation from all staff members, enhancing their understanding of the errors. 4) SCCHA has strengthened its disciplinary measures to identify staff members who may lack the motivation or capability to meet the requirements of the role. If a staff member fails to maintain consistently successful audits of files for three consecutive months of 80% or above, a 90-day improvement plan will be initiated. Anticipated Completion Date: June 30, 2025 1. Within six months 2. On-going. 3. On-going. 4. On-going. Persons Responsible: Vera Jones, Executive Director Meisha Kerby, Director of Asset Management Suellen Riley-Keen, Program Integrity & Compliance Coordinator

View Audit 334861 Questioned Costs: $1

Finding 516652 (2024-001)

Material Weakness 2024

Wood County Village Ii, Inc.

OH

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Wood County Village II, Inc. HUD Project No. 042-HD102 Audit Firm: GBQ Partners LLC Audit Period: 07/1/23-06/30/24 CAP Prepared by: Dustin Watkins, CEO A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2024-001 U.S. Department of Housing and Urban D...

Wood County Village II, Inc. HUD Project No. 042-HD102 Audit Firm: GBQ Partners LLC Audit Period: 07/1/23-06/30/24 CAP Prepared by: Dustin Watkins, CEO A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2024-001 U.S. Department of Housing and Urban Development Supportive Housing for Persons with Disabilities (Section 811) – CFDA 14.181; Grant period – Year ended June 30, 2024 a. Comments on the Finding and Each Recommendation. Statement of Condition: The Project did not request tenant assistance payments for the month of April. Criteria: The Regulatory Agreement requires the Project to ensure controls exist to request the appropriate funds for each tenant on a monthly basis. Cause: The Project’s controls over monthly housing assistance payments were not working properly due to lack of management oversight due to turnover during the year. Effect of Condition: The Project is not in compliance with the HUD approved Regulatory Agreement. Recommendation: We recommend that the Project’s sponsor review the design and implementation of internal control procedures and identify areas to strengthen management oversight. b. Action(s) Taken or Planned on the Finding 1. The Project’s sponsor is aware of the requirements of the HUD Regulatory Agreement and is working with new staff to ensure they receive the proper training on HUD requirements. 2. In August 2024, the April 2024 HAP requests were submitted for payment.

View Audit 334625

Finding 516538 (2024-004)

Material Weakness 2024

Housing Authority of the City of Carrollton, Missouri

MO

HUD Housing Programs Material Weakness Special Tests & Provisions

The Authority is aware of the Environmental Review requirement. However, during Covid 19, we received an email stating it was not required. Therefore, the last one was past the five-year requirement. It is procedure to conduct an Environmental Review when the Authority does its Five-Year Capital ...

The Authority is aware of the Environmental Review requirement. However, during Covid 19, we received an email stating it was not required. Therefore, the last one was past the five-year requirement. It is procedure to conduct an Environmental Review when the Authority does its Five-Year Capital Funds Plan. Therefore, the Authority will conduct a review this year for calendar years 2025-2029.

View Audit 334475

Finding 516537 (2024-003)

Material Weakness 2024

Housing Authority of the City of Carrollton, Missouri

MO

Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs

The Housing Authority of the Town of Carrollton, Missouri, is aware of the prevailing wage rate requirements. The Director was confused with the small purchase threshold and therefore did not require documentation on those contracts, but will in the future. The other contracts complied with the re...

The Housing Authority of the Town of Carrollton, Missouri, is aware of the prevailing wage rate requirements. The Director was confused with the small purchase threshold and therefore did not require documentation on those contracts, but will in the future. The other contracts complied with the requirement, but were not located on the audit date, therefore we agree with the finding. A checklist of required contract documents has been developed to assure compliance in the future.

View Audit 334475

Finding 516536 (2024-002)

Material Weakness 2024

Housing Authority of the City of Carrollton, Missouri

MO

Internal Control / Segregation of Duties Special Tests & Provisions Cash Management

The Housing Authority of the Town of Carrollton, Missouri, is a small PHA defined by HUD and lacks in segregation of duties for Internal Control. The Director has developed a spreadsheet to track obligation dates, amounts, contracts, and expenses to justify the amount obligated each month in the sy...

The Housing Authority of the Town of Carrollton, Missouri, is a small PHA defined by HUD and lacks in segregation of duties for Internal Control. The Director has developed a spreadsheet to track obligation dates, amounts, contracts, and expenses to justify the amount obligated each month in the system.

View Audit 334475

Finding 516518 (2024-002)

Material Weakness 2024

Housing Authority of the City of Fort Myers

FL

HUD Housing Programs Eligibility Material Weakness

Eligibility Public and Indian Housing Program - AL No. 14.850 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 621 tenants, a total of 44 tenant files were selected for testing and the following deficiencies were noted:  Eleven files had an...

Eligibility Public and Indian Housing Program - AL No. 14.850 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 621 tenants, a total of 44 tenant files were selected for testing and the following deficiencies were noted:  Eleven files had an annual recertification completed over 12 months after the previous recertification,  Twenty files were missing inspections,  One file was missing a photo identification for one adult tenant,  Three files were missing the flat rent option sheet,  Two files did not have 9886 release of information from within 15 months of the annual recertification, and  Two files were missing all supporting documents. Auditor Recommendations: The Authority should continue to train staff on the established procedures and controls in place to ensure full compliance in regard to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: To ensure that assisted tenants pay rents commensurate with their ability to pay, HUD requires that owners conduct a recertification of family income and composition at least annually. Owners must then recompute the tenants' rent and assistance payments if applicable, based on the information gathered. The folowing procedure is put in place to prevent the above conditions found during composition for families in the Public Housing Program. Property Managers will be required to complete the following courses in 2024: 1. Public Housing Management (PHM) or 2. Multifamily Housing Specialist depending on property program criteria Property clerks and Leasing Specialist will be required to complete Rent Calculation courses that correlate to their property program types. HACFM is actively working on creating operationprocedures and process manuals. The procedure manual will include the following requirements to ensure program compliance: Annual recertification packets will be sent to the resident 120 days from the household's annual effective date. Submission of required documentation from resident will be enforced according to the lease agreement. A certification review checklist (attached) to support staff in esuring all documentation is in file and all required signatures are present. The checklist will ensure that the submitter is verifying the file, the property manager has certified the file prior to finalizing the review in the tennat software program and uploading the file to records. The property Manager is required to conduct 5% audit of files monthly and correct any deficiencies found. An audit checklist will be created to support this required task.

View Audit 334427

Finding 516517 (2024-001)

Material Weakness 2024

Housing Authority of the City of Fort Myers

FL

HUD Housing Programs Eligibility Material Weakness

Eligibility Section 8 Housing Choice Vouchers Program - AL No. 14.871 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 2,256 tenants, a total of 39 tenant files were selected for testing and the following deficiencies were noted:  Five file...

Eligibility Section 8 Housing Choice Vouchers Program - AL No. 14.871 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 2,256 tenants, a total of 39 tenant files were selected for testing and the following deficiencies were noted:  Five files had an annual recertification completed over 12 months after the previous recertification,  Six files did not have a valid 9886 release of information from within 15 months of the annual recertification,  Eight files had the incorrect payment standard used,  One file contained an income calculation error,  One file had missing income support,  One file was missing photo identification for one adult tenant,  One file had 214 forms missing for 3 tenants, and  One file had a missing rent reasonableness form. Auditor Recommendations: The Authority should continue to train staff on the established procedures and controls in place to ensure full compliance in regard to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: HCV Department will implement the recommendations as presented. The department does recognize that this is a repeat finding and leadership adjustments have been made, appointing a new program director. Transition to paperless function resulted in an adjustment to regular quality checks. A few of the functions to enhance performance during the next fiscal year will be; 1. establish and enforce Standard Operating Purchases 2. Reestablish 120-day Recertification protocols and enforce compliance 3. Streamline elderly and disabled customers based on initial HOTMA 3 yr interval 4. Quantitative metrics added to performance evaluation for all staff, including error-rate 5. Periodic one-on-one check-ins from supervisors 6. Enforce mandatory, individual staff, QC forms to ensure files are maintained in order 7. Weekly staff meetings to review and discuss regulations, administrative policies, PIC issues, QC errors, and required protocols 8. Enforce internal QC procedures at a minimum of 10% annually 9. Enforce electronic files for every customer 10. In an effort to exceed expectations staff will attend trainings to update and teach staff requirements and protocols on pending HACFM changes to include PBV, HOTMA, NSPIRE, and HCV Specialist training for newer staff

View Audit 334427

Finding 516478 (2024-001)

Material Weakness 2024

Wallace Stegner Academy

UT

Material Weakness Reporting Internal Control / Segregation of Duties

Finding Summary: Wallace Stegner Academy is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER f...

Finding Summary: Wallace Stegner Academy is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER funds and criteria used and number of full-time equivalent positions for all GEER & ESSER funds received from the USBE during the period of July 1, 2022 to June 30, 2023. Wallace Stegner Academy did not properly report the correct amount of ESSER expenditures by specific positions supported with GEER and ESSER funds and the number of full-time equivalent positions for all GEER and ESSER funds. Responsible Individuals: Accountant and Executive Director Corrective Action Plan: Management will provide the USBE with the correct amount of ESSER expenditures by specific positions supported with GEER and ESSER funds and the number of full-time equivalent positions for all GEER & ESSER funds. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management will ensure all necessary corrective action plan items are in place by the end of the next reporting period.

View Audit 334387

Finding 516389 (2024-003)

Material Weakness 2024

McMurry University

TX

Student Financial Aid Material Weakness Reporting

R2T4 Finding Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268, 84.063 and 84.007 Finding Summary: Errors in return to Title IV calculations: Calculations for five students included various errors. Errors included one late determin...

R2T4 Finding Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268, 84.063 and 84.007 Finding Summary: Errors in return to Title IV calculations: Calculations for five students included various errors. Errors included one late determination of withdrawal date (more than 30 days after the end of the period of enrollment), three returns completed more than 45 days after the withdrawal date, two incorrect percentage of aid earned calculations, and one overpayment to the Department of Education. Responsible Individuals: Tim Sechrist, Director of Financial Aid Corrective Action Plan: We agree with the auditors’ findings and recommendations. Financial Aid Office staff that will deal with withdrawals and returns will complete the FSA Training Webinar Videos for R2T4. These include the R2T4 Essentials and R2T4 Modules webinars available online. We will implement a second review of calculations with an additional staff member added to the process. We will have the Financial Aid Counselor review withdrawals as they are received and complete the preliminary calculation. The Counselor will pass the preliminary calculation to the Director of Financial Aid for review prior to processing the returns. We will work with the Online Learning Office to report and retain academic activity for distance education students. Anticipated Completion Date: December 31, 2024

View Audit 334328

Finding 516320 (2024-001)

Material Weakness 2024

Davinci Academy of Science and the Arts

UT

Material Weakness Reporting Internal Control / Segregation of Duties

Finding Summary: DaVinci Academy of Science and the Arts is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of ...

Finding Summary: DaVinci Academy of Science and the Arts is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER funds and criteria used and number of full-time equivalent positions for all GEER & ESSER funds received from the USBE during the period of July 1, 2022 to June 30, 2023. DaVinci Academy of Science and the Arts did not properly report the correct amount of all ESSER funds expended. Responsible Individuals: Business Manager and Executive Director Corrective Action Plan: Management will provide the USBE with the correct the amount of all ESSER funds expended. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management will ensure all necessary corrective action plan items are in place by the end of the next reporting period.

View Audit 334150

Finding 516274 (2024-002)

Material Weakness 2024

Western Oregon University

OR

Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Each month, the Common Origination and Disbursement (COD) system provides institutions...

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Each month, the Common Origination and Disbursement (COD) system provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution’s financial records. As a result of implementing a new Student Information System, the SAS reconciliations were not completed during the current year. Responsible Individuals: Kella Helyer, Director of Financial Aid Corrective Action Plan: Management agrees with this finding. Compliance on this finding was resolved by the end of the award year with reconciliation being completed by the end of June 2024. Financial aid implemented a new Financial Aid Management System (FAMS) starting with the 2023-24 year which caused delays in processes; however, the office is caught up with reconciliations, and going forward this compliance area is not an issue. Anticipated Completion Date: Completed June 2024

View Audit 334105

Finding 516243 (2024-004)

Material Weakness 2024

School District of Cadott Community

WI

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Material Weakness

The District acknowledges this finding. Invoices are reviewed by the Administration and Board of Education monthly. Additional reviews by administration will be put into place. The Board of Education shall approve the pay rates annually and appropriate documentation kept.

View Audit 334049

Finding 516242 (2024-003)

Material Weakness 2024

School District of Cadott Community

WI

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment § 200.326

The District is in the process of developing a procurement policy, including prevailing wage rate requirements and will ensure that subcontractors meet the requirements.

View Audit 334049 Questioned Costs: $1

Finding 515856 (2024-002)

Material Weakness 2024

Housing Authority of the City of Raleigh

NC

HUD Housing Programs Subrecipient Monitoring Material Weakness

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

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

View Audit 333725

Finding 515855 (2024-001)

Material Weakness 2024

Housing Authority of the City of Raleigh

NC

HUD Housing Programs Eligibility Material Weakness

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

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

View Audit 333725

Finding 515781 (2024-007)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

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

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

View Audit 333618

Finding 515780 (2024-006)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

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

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

View Audit 333618

Finding 515778 (2024-004)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

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

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

View Audit 333618

Finding 515777 (2024-003)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Eligibility Material Weakness

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

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

View Audit 333618

Finding 515771 (2024-001)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

Questioned Costs HUD Housing Programs Material Weakness

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

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

View Audit 333618 Questioned Costs: $1

Finding 515682 (2024-003)

Material Weakness 2024

School District of Marathon City

WI

Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking § 200.326

The District will implement a process to obtain, review and retain certified payrolls if ever using federal funds on future construction contracts in excess of $2,000. The District will work with the contractor to obtain and review the certified payrolls to determine the contractor is in compliance.

View Audit 333509

Corrective Action Plans

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