Corrective Action Plans

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

Finding 515665 (2024-001)

Material Weakness 2024

Mid-South Food Bank

TN

Material Weakness Reporting Internal Control / Segregation of Duties

Compliance officer will be handling this now.

View Audit 333474

Finding 515541 (2024-004)

Material Weakness 2024

Port Edwards School District

WI

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs § 200.334

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting in...

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting including special reports and that all supporting documentation is maintained with the filed copy of the report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for grants but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing.

View Audit 333281

Finding 515538 (2024-003)

Material Weakness 2024

Port Edwards School District

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment HUD Housing Programs

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowabil...

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases when purchase orders are not required, along with adding controls to ensure that the item purchased was received by the District. We also recommend the District review its payroll process and identify payroll tasks that could be reassigned to other district personnel or consider implementing additional review procedures specifically focused on payroll and related fringe benefit costs claimed on federal and state grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for grants but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing.

View Audit 333281

Finding 515533 (2024-006)

Material Weakness 2024

Port Edwards School District

WI

Procurement, Suspension & Debarment Internal Control / Segregation of Duties HUD Housing Programs

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: Auditor recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving micro pu...

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: Auditor recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving micro purchases, along with adding controls to ensure that the item purchased was received by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for micro purchases but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing. If the oversight agencies have questions regarding this plan, please call Lisa Miller at 715-887-9000.

View Audit 333281

Finding 514569 (2024-004)

Material Weakness 2024

Clarenceville School District of Oakland and Wayne Counties

MI

Subrecipient Monitoring Cash Management Material Weakness

Condition: The School District is required to account for all revenues and expenditures of its non-profit school food service account in accordance with state and federal requirements. In order to ensure that federal reimbursement payments received monthly from the Michigan Department of Education a...

Condition: The School District is required to account for all revenues and expenditures of its non-profit school food service account in accordance with state and federal requirements. In order to ensure that federal reimbursement payments received monthly from the Michigan Department of Education are correctly credited to the school food service account, monthly bank reconciliations should be prepared and reviewed by individuals with requisite skill and experience. During the 2024 fiscal year, bank reconciliations and monthly reconciliations of food service revenues and expenditures of the school food service account were not being prepared and reviewed in a timely manner. As there was an unexpected reduction in staff resources in the business office, there were not adequate resources to perform these accounting reconciliations on a timely regular basis during the year. The absence of these timely regular reviews could lead to undiscovered errors in the school food service account and material noncompliance with federal regulations. Planned Corrective Action: The School District agrees that its internal control structure should ensure that accounting reconciliations are prepared and reviewed in a timely manner during the year. Although the School District had an intergovernmental Agreement with its Intermediate School District to provide business services, such services could not be rendered due to inability to find staffing. Near the end of the 2024 fiscal year, a Finance Director was directly hired into the business office. Monthly reconciliations of accounting records and closing of monthly books are now being performed and reviewed on a timely basis. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

View Audit 332905

Finding 514565 (2024-003)

Material Weakness 2024

Clarenceville School District of Oakland and Wayne Counties

MI

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School ...

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School District is required to have controls in place to ensure the accuracy of the request for reimbursement. The School District did not have a documented review process in place over the reimbursement requests. Meal counts entered into the Michigan Nutrition Data (MIND) system took place without a secondary review, which could result in incorrect reporting of the number of meals. The preparation of the request without a secondary review could result in incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The School District's business office performed a detailed review of all meal claim submissions for the 2023-2024 fiscal year. Claims were accurately completed as was the amount of reimbursement paid by the Michigan Department of Education. The business office has since implemented a formalized internal control procedure beginning in July 2024, whereby a formal documented review of the meal claim submission is performed. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

View Audit 332905

Finding 514419 (2024-001)

Material Weakness 2024

Arlington Baptist University

CO

Reporting Student Financial Aid Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However,...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However, the first error free report was uploaded 09/01/2024. ABU now has a schedule with set reminders from the clearinghouse to ensure timely and regular reporting. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

View Audit 332741

Finding 514372 (2024-001)

Material Weakness 2024

Danville Area Community College

IL

Procurement, Suspension & Debarment Student Financial Aid Material Weakness § 200.303

Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Explanation of disagreeme...

Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The College is in the process of developing a new procedure which will be implemented in January 2025. Name of the contact person responsible for corrective action: Jonathan Jett,Director of Financial Aid Planned completion date for corrective action plan: January 2025

View Audit 332657

Finding 514298 (2024-004)

Material Weakness 2024

Independent School District 2164

MN

School Nutrition Programs Cash Management Material Weakness

Finding 2024-004 Reporting – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance Finding Summary: The District does not have an internal control system designed to review and ensure submitted free and reduced meal counts agree to underlying records. Responsible Individuals:...

Finding 2024-004 Reporting – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance Finding Summary: The District does not have an internal control system designed to review and ensure submitted free and reduced meal counts agree to underlying records. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and submission of free and reduced meal counts to ensure they are supported and accurate. Anticipated Completion Date: June 30, 2025

View Audit 332561

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