Corrective Action Plans

Tenant Files

Move-ins:

1.     In one (1) instance out of nine (9) tenant files tested, the “Verification of Handicapped/Disable Status” form was not maintained in the tenant’s file.

2.     In one (1) instance out of nine (9) tenant files tested, the Student Certification form was not signed and dated by the tenant.

3.     In one (1) instance out of nine (9) tenant files tested, the security deposit amount per the lease agreement, did not agree to the amount stated on the security deposit agreement.

4.     In three (3) instances out of nine (9) tenant files tested, the date on the Form HUD-50059 did not agree to the date on the lease agreement.

5.     In one (1) instance out of nine (9) tenant files tested, the “Race and Ethnic Data” form was not maintained in the tenant’s file.

6.     In three (3) instances out of nine (9) tenant files tested, the “Citizenship Declaration” form was not maintained in the tenant’s file.

Recertification:

1.     There was one (1) instance, whereby the annual recertification was not performed for the 2023 calendar year.

2.     In eight (8) instances out of eighteen (18) tenant files tested, the “Student Certification” form did not indicate, whether the tenant was a student at an institution of higher education.

3.     In four (4) instances out of eighteen (18) tenant files tested, the “Certification/Recertification Questionnaire” form was not maintained in the tenant’s file.

4.     In two (2) instances out of eighteen (18) tenant files tested, the “Lease Amendment” was not signed by the Management Agent.

5.     In one (1) instance out of eighteen (18) tenant files tested, the “Notice of Rent Increase” form, was not signed by the Property Manager.

6.     In one (1) instance out of eighteen (18) tenant files tested, verification of the Pension income in the amount of $14,543 was not maintained in the tenant’s file.

Move-out:

1.     In one (1) instance out of three (3) tenant files tested, the security deposit disposition notice was not maintained in the tenant’s file.

(1)   Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor’s recommendation that Alpha Tower process applicants and tenants, including recertification of tenants in accordance with guidelines established by the Department of Housing and Urban Development prior to the tenant occupying the unit. By performing these procedures, the risk of incurring questioned costs will be significantly reduced.

(2)   Actions Taken on the Finding.

There was a change in staff.

There was a change in supervisor.

Remind staff to follow tenant procedure manual to sure all document’s are included.

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Procurement and Suspension and Debarment Summary of Finding: (copied from SBOA Findings document provided) The Allen County Department of Health (Department of Health), a department within Allen County, was awarded the Health Issues and Challenges grant through the Indiana Department of Health financed through the American Rescue Plan Act (ARPA) for the purpose of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. The Health Issues and Challenges grant is a reimbursable grant, whereby the County received reimbursement on a percase basis at a stated rate for Case Management and Environmental Investigation activities performed. The Department of Health received federal receipts related to the grant in the amount of $130,479 during 2023. As part of sound management of the Federal award, the Department of Health was responsible for implementing a system of internal control that would ensure compliance with the applicable requirements. The Department of Health did not properly design or implement such a system. Receipts of the program were adequately identified through the use of an account number within the County Health Fund (285) in the Allen County's ledger (ledger) which was unique to the Health Issues and Challenges grant receipts. However, the ledger did not adequately identify the expenditures of the grant program within the County Health Fund. Through inquiry with the Department of Health employees and review of unitprepared support of grant expenditures, we determined expenditures were made with grant funds during the audit period, however, we were unable to distinguish between the expenditures of the Health Issues and Challenges grant and all other activities of the Department of Health in the County Health Fund. Due to the lack of separate identification of expenditures in the financial records, we were not able to establish a population from which to audit the Health Issues and Challenges grant for compliance with the following compliance requirements of the program: 􀁸 Activities Allowed or Unallowed 􀁸 Allowable Costs/Cost Principles 􀁸 Period of Performance 􀁸 Procurement and Suspension and Debarment As such, the full award amount of $130,479, as reported on the Schedule of Expenditures of Federal Awards, was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Recommendation: We recommend that management of the Health Department establish a system of internal controls to ensure that grant award funds are adequately accounted for and tracked in such a manner as to determine the activity, receipts and disbursement, associated with the grant. ………………………… Contact Person Responsible for Corrective Action: JENNIFER MILLER (Finance Director) Contact Phone Number and Email Address: 260-449-7358 (Jennifer.miller@allencounty.us) Views of Responsible Officials: We concur with the finding Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: When we were informed of the outcomes of the SBOA audit and the subsequent needs for a corrective action plan (CAP) relative to their findings, we moved quickly to begin the development of the CAP. We feel this finding/issue could be easily remedied by following our normal procedure for grants, whereby we develop a new fund, craft a Fund Ordinance for approval by the Allen County Commissioners to establish said new fund, and then subsequently track all expenditures and reimbursements in the separate fund vs. utilizing a line item for deposits in the main Health Fund as was done with this grant (which lacked the ability to denote exact salary expenditures and such next to each payment as it was all done within the larger fund for all staff and expenses. We were not aware of this need. THE PLAN (which will be added as a new “Grants” section in our existing Finance Internal Controls policies): For all grants (reimbursable or deliverables-based), once a contract is near completion or upon execution, a separate fund will be created through development and approval of a local fund ordinance. All expenditures allowed by said grant and all reimbursements received by the grant funder will be tracked solely and only within the separate grant fund that is tied to the signed contract from the funder. If there are staff payments for salaries or benefits being reimbursed by a grant, we will ensure that: (1) the hours/minutes per staff member per pay period for all work associated with these grant duties are tracked appropriately so as to ensure we are invoicing the grant funder for the exact and accurate work hours (regardless of whether or not the grant contract specifies this be tracked or reimbursed per minute/hour, as most do not require this); and (2) these amounts will be noted alongside the expenditures in the grant fund for clarity upon invoicing or auditing. Anticipated Completion Date: We will follow this practice for any new grants accepted by the Allen County Department of Health effective 9/17/2024. This is the standard practice for most grants we have accepted, and therefore, we will not vary from this practice in the future even if given permission to do so.

2023-001 - HQS Enforcements and Annual HQS Inspections Housing Voucher Cluster - Assistance Listing No. 14.871 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In response to the HOS enforcement and annual inspections finding for the Housing Authority of the City of Key West, FL 12-31-2023 audit, management has completed the following items in order to address the issue: • Hired a new HCV Program Manager, • Procured a new outside HCV inspection contractor, • Provided current staff training on HCV program HOS requirements, • Adopted the recommendation from our independent auditors to have the Assistant to the Director of Housing sample 10% of the HCV recertification files monthly to ensure compliance with federal regulations and housing quality standards - files that are found to be out of compliance will be reported to the Director of Housing & Executive Director. In addition, the following items will be done: • Consider changing the administrative plan to prohibit time extensions beyond 30 days, thereby requiring abatement of HAP effective the 31st day in all cases, • Update the job description of the Assistant to the Director of Housing & change the title of the position to Assistant to the Director of Housing/Compliance Specialist. Name(s) of the contact person(s) responsible for corrective action: Randy Sterling, Executive Director Planned completion date for corrective action plan: October 31, 2024.

1)The duplicate invoice for $92,880.00 was removed from the Tracker worksheet which was submitted in 11/27/2023. 2)The duplicate invoice for $91,511.66 will be removed from the FEMA Project 140215 Tracker worksheet which will be submitted by the end of September 2024. 3)The discounts taken for early payment of contract labor invoices for a certain vendor will be corrected on the FEMA Project 140215 Tracker worksheet which will be submitted by the end of September 2024.