Corrective Action Plans

For the Rockford Supportive Housing Facility - FINDING 2024-002: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 TENANT FILE CONTAINED MATHEMATICAL ERROR IN COMPUTING HOUSEHOLD INCOME Recommendation: The Project should recompute the HUD subsidy and tenant rent for this tenant and adjust a future monthly billing. Project managers should be aware of the importance of computing the tenant's household income correctly. Action Taken: The Project agrees with the finding. Tenant rent was recomputed in January 2025 and will be corrected on a future HAP voucher.

For the OTR - Arboretum West Apartments Facility FINDING 2024-004: SECTION 223(f), ASSISTANCE LISTING NUMBER 14.155 PAID THE EXPENSE OF ANOTHER PROJECT UNDER COMMON MANAGEMENT Recommendation: The Project should carefully review invoices before payment to make sure it pays the correct amount. Action Taken: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment.

Over the Rainbow Association and Subsidiaries respectfully submits the following corrective action plans for the year ended December 31, 2024. Name and address of independent public accounting firm: Baker Meinz & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit period: December 31, 2024. The findings from the December 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT - NONE; FINDINGS - FEDERAL AWARD PROGRAMS AUDIT - DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT; For the Hill Housing Facility - FINDING 2024-001: SECTION 8, ASSISTANCE LISTING NUMBER 14.195 SPONSOR LOAN PAYMENT WITHOUT HUD APPROVAL Recommendation: The Sponsor should obtain HUD approval for the repayment of the sponsor loan. Action Taken: The Sponsor will contact HUD to obtain HUD permission to retain the unauthorized sponsor loan payments.

The Organization will continue efforts to obtain written confirmation from the Department of Commerce, compile all available email correspondence and notes from verbal conversations, and prepare a detailed timeline of authorization requests and responses. Further, the Organization will submit a formal response to the Department of Commerce regarding questioned costs, provide documentation supporting the allowability of expenses, and request a formal resolution of questioned costs. Person Responsible: Steve Sanders, Grant Manager, Tel: 207-249-8578 Estimated completion: December 2025

Name of Contact Person: Grace Leatherman – Executive Director Contact Information: 410-440-9066 Corrective Action Plan: Finding 2024 – 002 Management is in agreement with the findings and will remind staff to include supporting calculations when submitting for reimbursement per Organization policies. Senior staff will review payroll data to ensure calculations are being made and reported. Expected Completion Date: The Organization expects all findings to be resolved by December 31, 2025

Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879 & 14.EHV Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Financial Statements: No Significant deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its HCVP administrative plan 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: Twenty-five (25) 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 twenty-five (25) new move-ins selected could not be traced with any certainty back to the Authority's waiting list. Known Questioned Costs: $9,231 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to selections from the waiting list. 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 Housing Voucher Cluster programs are in non-compliance with the special tests and provisions type of compliance related to selections from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the significant deficiency in the Housing Voucher Cluster programs and will implement internal control procedures that will ensure compliance with federal regulations. Nicole Alexander, HCV Program Director, is responsible for implementing this corrective action by December 31, 2025.

Finding 2024-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879, & 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were failed inspections that did not pass reinspection within 30 days without penalty. Context: There are approximately 405 units with failed inspections. Of a sample size of twenty-five (25) failed inspections, two (2) failed inspections did not pass reinspection within 30 days. HAP was not abated nor was the tenant evicted. Our sample size is statistically valid. Known Questioned Costs: $330 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly performed HQS inspections in compliance with program requirements following the expiration of HUD waivers as a result of insufficient staffing. Effect: The Housing Voucher Cluster programs are in non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor, and will design and implement internal controls over compliance in order to ensure all necessary failed HQS inspections with life threatening deficiencies are addressed within 24 hours and all other deficiencies are addressed within 30 days. Nicole Alexander, HCV Program Director, is responsible for implementing this corrective action by December 31, 2025.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Department of Social Services (DSS) – MO HealthNet Division (MHD) and Family Support Division (FSD) Audit Finding Number: 2024-002 - Medicaid and CHIP Participant Eligibility Terminations Name of the contact person responsible for corrective action: Stacy Kaylor Anticipated completion date for corrective action: September 1, 2025 Recommendation: The DSS through the MHD and the FSD continue to review, strengthen, and enforce internal controls to ensure ineligible participant cases are closed when necessary and resume the DHSS vital records death match in the MEDES. DSS Response: The DSS partially agrees with this finding. DSS has controls in place to close coverage when a customer requests closure; however, the procedures were not followed. During the audit period, the FSD Call Center had processes in place to accept calls for applications, renewals, change in circumstance, enter evidence and inquiries. However, contracted staff are unable to authorize any action that results in a case closing and that authorization must be completed by a DSS employee. There were procedures in place for contracted staff to submit a form that will create a task for DSS staff to finalize the actions. For the case cited in the finding, the task was not created, resulting in DSS staff not receiving the request to voluntarily close the case. Although call center staff noted in the electronic case file the purpose of the call, there are not systematic controls in place to take action or create tasks for DSS employees from the case notes. Currently, a death match with Department of Health and Senior Services (DHSS) vital records is functional in the Family Assistance Management Information System (FAMIS) eligibility system currently used for Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), and MO HealthNet for Aged, Blind, and Disabled (MHABD) individuals. When the match is received into FAMIS from DHSS, that information is included on the eligibility file submitted to the Medicaid Management Information System (MMIS) to ensure that the death date is captured in MMIS to prohibit any payments after the death of the individual. This control ensures that no improper payments are made on a beneficiary’s behalf after the date of death. DSS has processes in place to close eligibility when death information is received from family members and providers during the certification period. Additionally, in compliance with 42 CFR 435.949, DSS administers an electronic verification match with the federal hub at application and during the annual review process to inquire about death. DSS is continuing to evaluate necessary steps to reinstate the death match with DHSS vital records, but do not have an anticipated completion date. Regarding the questioned costs, eligibility errors are governed by section 1903(u) of the Social Security Act. Therefore, questioned costs identified in the single statewide audit should not be subject to recoupment. Corrective action planned is as follows: DSS is strengthening controls by revising the procedures of the contracted FSD Call Center to ensure case actions are completed timely. DSS will use a system action to close cases with out of state address evidence in the Missouri Eligibility and Enrollment System (MEDES).

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Department of Elementary and Secondary Education (DESE) Audit Finding Number: 2424-013 - Child Care Payments Name of the contact person responsible for corrective action: Shelley Woods Anticipated completion date for corrective action: 12/31/2025 Corrective action planned is as follows: DESE agrees with the auditor's finding. DESE is working on strengthening internal controls within the Child Care Data System (CCDS) to prevent duplicate payments and overpayments due to absences and attendance and ensure sliding fees for each child are correct. DESE has worked with the Administration for Children and Families on the specific requirements related to correcting overpayments. DESE has paid the providers with underpayments.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Department of Health and Senior Services (DHSS) Audit Finding Number: 2024-009 - CACFP Subrecipient Monitoring Name of the contact person responsible for corrective action: Sarah Walker, Bureau Chief Anticipated completion date for corrective action: Corrective action planned is as follows: The agency does not agree with the audit findings and therefore no corrective action is required. Explanation and specific reasons are as follows: DHSS disagrees with this finding. While the USDA partially sustained the previous finding in the FY2023 SWSA, the corrective action plan and supporting documentation submitted by DHSS was accepted by USDA and deemed adequate. On April 17, 2025, the USDA recommended final action to close the FY2023 audit finding.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Department of Health and Senior Services (DHSS) Audit Finding Number: 2024-008 - CACFP Subrecipient Reimbursements Name of the contact person responsible for corrective action: Sarah Walker, Bureau Chief Anticipated completion date for corrective action: Corrective action planned is as follows: The agency does not agree with the audit findings and therefore no corrective action is required. Explanation and specific reasons are as follows: Department of Health and Senior Services (DHSS) disagrees with this finding because the previous audit finding in the FY2023 SWSA was not sustained by the federal funding agency, therefore no finding or corrective action is required.

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871, 14.879, 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions. Criteria: HQS Inspections. Per the Authority's HCV Admin Plan, the PHA must inspect the unit leased to a family biennially in order to determine if the unit meets HQS standards, and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management there were inspection reports that were unavailable for examination at the time of audit. Context: Of a sample size of thirty-six (36) units, three (3) units did not have biennial HQS inspections performed timely. Our sample size is statistically valid. Known Questioned Costs: $75,684 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. 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 Housing Choice Vouchers Programs are in material non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures over HQS inspections that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Emergency Housing Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Kathleen Wyatt, Director of Housing Operations, will be responsible to implement this corrective action by December 31, 2025.

Financial Statement Findings Findings 2024-001 and 2024-002 listed below are also financial statement findings which are required to be reported in accordance with Government Auditing Standards. Federal Award Findings and Questioned Costs Finding 2024-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871, 14.879, 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,533 units. Of a sample size of thirty-six (36) tenant files, the following was noted: • Verification of income was unable to be recalculated in 4 files • Verification of assets was unable to be provided in 1 file • HUD 50058 annual recertification was not filed timely in 2 files • Citizen Declaration Section 214 form was unable to be provided in 9 files Our sample size is statistically valid. Known Questioned Costs: $84,235 Cause: There is a material weakness in the Housing Voucher Cluster in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. 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 Housing Voucher Cluster Programs are in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures over the maintenance of tenant files that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Kathleen Wyatt, Director of Housing Operations, will be responsible to implement this corrective action by December 31, 2025.

AUDITEE’S CORRECTIVE ACTION PLAN As required by 2CFR Section 200.511 of the Uniform Guidance, Mississippi Public Health Institute has prepared and hereby submits the following corrective action plan for the findings included in the Schedule of Findings and Questions Costs for the year ended December 31, 2024: Federal Award Findings and Questioned Costs 2024-002 Unallowable Costs Criteria - The Uniform Guidance states that any federal share of allowable costs must be refunded to the government. During our audit, we noticed an instance of duplicate expenditures being recorded. Reimbursement was requested and received for these costs from the Racial and Ethnic Approaches to Community Health program under ALN 93.304. This occurred through a single vendor, for which it was noted that the vendor had sent duplicate invoices, and MSPHI recorded both invoices. Recommendation - We recommend the implementation of IT controls to prevent duplicate invoice numbers to be recorded. Corrective Action Plan - Mississippi Public Health Institute will increase oversight of grant expenditures and drawdowns to improve reconciliation accuracy. Position of Responsible Official – John Davis, Chief Financial Officer Anticipated Completion Date – Completed after brought to client’s attention. August 31st, 2025.

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Public Housing Authority (PHA) has designated the Owner Services Supervisor to oversee the inspection This role ensures that all inspections are completed in a timely and consistent manner. The supervisor is also responsible for verifying that Housing Assistance Payments (HAP) are only released for units that fully meet Housing Quality Standards (HQS) requirements. These measures strengthen oversight, improve accountability, and ensure compliance with federal regulations. Name(s) of the contact person(s) responsible for corrective action: MaryLiz Paulson, Director, Housing Choice Vouchers

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879 Recommendation: We recommend that management should implement a quality control review over a sampling of tenant files recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify 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: We would like to provide additional context. The challenge is not due to a lack of monitoring efforts, but rather staffing constraints that have impacted our ability to meet recertification timelines. Specifically, the Agency is currently operating with an insufficient number of staff to manage the full caseload effectively. Additionally, a significant portion of the team responsible for processing recertifications consists of new hires who are still in training and not yet able to carry a full workload, which has temporarily reduced the overall output of the team. In response, we are actively working to streamline internal processes, prioritize core functions, and improve overall operational efficiency. These efforts are intended to increase the number of timely recertifications completed and ensure compliance with HUD requirements moving forward. Name(s) of the contact person(s) responsible for corrective action: MaryLiz Paulson, Director, Housing Choice Vouchers Planned completion date for corrective action plan:: December 31, 2025

Management understands that CFR 200.430 requires compensation for personnel services to be based on records that accurately reflect the work performed, and costs must be properly allocated to benefiting programs or cost objectives. The HR/Payroll Administrator has implemented a review process to ensure that all payroll changes are properly reviewed, verified, and approved prior to final payroll processing and the Cooperative does not believe this should be in an issue going forward.

Management agrees and will develop review procedures to respond to the findings.

Management agrees and will reimburse the employee for the amounts due for hours worked more than 40 hours in a work week during the fiscal year. Management will develop review procedures to respond to this finding.

Management agrees and will develop review procedures to respond to the findings.

Management agrees with the finding and will work with the City of San Antonio to correct the issue, and develop review procedures to respond to the finding.

Belmont County Department of Job and Family Services reviews employee’s job duties routinely to determine the most appropriate and accurate cost pool they should be assigned. The essential job duties and how they align with the program area determine cost pool assignment based on the agency’s interpretation. As a result of this finding, BCDJFS will reassign the FCFC Coordinator to the shared cost pool and reimburse the shared cost pool from the applicable FCFC allocations through a MOU signed between the council and BCDJFS

Finding 2024-003- Allowable Activities and Allowable Cost Finding Subject : Covid-19. Coronavirus State and Local Fiscal Recovery Funds- Activities allowed or unallowed and allowable cost/cost principles. Contact Person Responsible for Corrective Action : Ashley Huffman Contact Phone Number and Email Address: 765-521-6803 nccityclerk@gmail.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Claims for ARPA monies will be reviewed to confirm it is allowable. Anticipated Completion Date: Immediately

Finding Number 2024-004 SPECIAL PERFORMANCE – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.871– SECTION 8 HOUSING CHOICE VOUCHERS Contract # N/A Criteria Special Reporting - HUD-50058, Family Report (OMB No. 2577-0083) - The PHA is required to submit this form electronically to HUD each time the PHA completes an issuance, admission, annual reexamination, interim reexamination, portability move-in, expiration, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA's jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Key Line items - The following line items contain critical information Line 2a - Type of Action Line 2b - Effective Date of Action Line 3b, 3c – Names Line 3e - Date of Birth Line 3n - Social Security Numbers Line 5a - Unit Address Line 5h, 5i - Unit inspection Dates Line 7i - Total Annual income Lines 2k and 17a - Family's Participation in the Family Self Sufficiency (FSS) Program Line 17k (2) - FSS Account Balance Condition/Context The Authority received funding from the HUD. The Authority is required to submit HUD-50058 each time the PHA completes an issuance, admission, annual reexamination, interim .reexamination, portability move-in, expiration, or other change of unit for a family. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (Special reporting forms as noted in the Criteria section above) were requested to be provided: • Eight documents related to HUD-50058 forms were not provided (One missing verification of Names; Three missing verification of Date of Birth; and Four missing Verification of Social Security. These forms are considered critical information for HUD -50058 forms. This documents are required documentation to be maintained in the case files to support HUD-50058 form for Section 8 Housing Choice Voucher Program. Therefore, we were not able to determine if the critical information in HUD-50058 form are supported by supporting documentation. Recommendation We recommend the Authority strengthen its controls over the Section 8 Housing Choice Voucher Program HUD-50058 form to ensure that all supporting documentation for HUD-50058 form are received, reviewed, and maintained to support HUD -50058 form. Corrective Action Plan There are some missing documentations pertaining to eligibility and admission in files for households admitted prior to 2011. Such documentation, which includes the application, vital documents, lease, and request for tenancy approval, is aged beyond 20 years for some cases and is not retrievable as part of a 2010 backfile conversion. This was noted as a condition in a previous Single Audit. Part III of the Schedule of Findings and Questioned Costs for Federal Awards year ending December 31, 2010, cited the condition as “For two of our selections, the Authority was not able to locate the tenant file containing the required documentation that the authority had obtained to verify income eligibility. Because the tenant file was not available, the authority was not able to provide all of the documents needed to test eligibility such as tenant applications, third party income verifications, or lease agreements.” NYCHA's response to that audit conveyed our confidence in the business improvement initiatives completed to streamline the document management process. As NYCHA noted in response to the 2010 audit: the backfile conversion process was part of a large-scale, multi-year implementation of a new computer system that went live in 2011, during which over 15 million documents were converted to electronic files. New system improvements included forms tracking using the Intelligent Forms Processing (IFP) scanning technology. The IFP technology associates and saves scanned documents and documents completed by tenants electronically directly to the tenant case files in Siebel. The Siebel Customer Relationship Manager (CRM) System provides process standardization and solutions for document retention needs. In the current audit, there are 30 files that are reflective of our improved document management and retention; NYCHA has continued to make such improvements since 2011 and NYCHA remains committed to making our best efforts to ensure that all eligibility and admission documentation is maintained in the system of record. Action Date September 10, 2025 Final Implementation September 10, 2025 Name And Phone Number Of Person Responsible for Implementation Lakesha Miller Executive Vice President for Leased Housing Office of the Chief Executive Officer +1-212-306-8818

Finding Number 2024-003 ELIGIBILITY – SIGNIFICANT DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.871– SECTION 8 HOUSING CHOICE VOUCHERS Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: • As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). • For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income- based rent (24 CFRsection 982.516). Condition/Context The Authority received funding from the HUD. The Section 8 Housing Choice Voucher Program provides rental assistance to help very low- income families afford decent, safe, and sanitary rental housing. The Mainstream Voucher program enables families for whom the head, spouse, or co-head is a person with disabilities to lease affordable private housing of their choice. Of the sixty (60) case files selected for testing in which 600 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: • Thirty-three eligibility forms related to five cases, were not provided (Thirty-two missing application forms, and one missing third -party verification of reported family annual income form). These forms are required documentation to be maintained in the case files to support eligibility for Section 8 Housing Choice Voucher Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Section 8 Housing Choice Voucher Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan There are some missing documentations pertaining to eligibility and admission in files for households admitted prior to 2011. Such documentation, which includes the application, vital documents, lease, and request for tenancy approval, is aged beyond 20 years for some cases and is not retrievable as part of a 2010 backfile conversion. This was noted as a condition in a previous Single Audit. Part III of the Schedule of Findings and Questioned Costs for Federal Awards year ending December 31, 2010, cited the condition as “For two of our selections, the Authority was not able to locate the tenant file containing the required documentation that the authority had obtained to verify income eligibility. Because the tenant file was not available, the authority was not able to provide all of the documents needed to test eligibility such as tenant applications, third party income verifications, or lease agreements.” NYCHA's response to that audit conveyed our confidence in the business improvement initiatives completed to streamline the document management process. As NYCHA noted in response to the 2010 audit: the backfile conversion process was part of a large-scale, multi-year implementation of a new computer system that went live in 2011, during which over 15 million documents were converted to electronic files. New system improvements included forms tracking using the Intelligent Forms Processing (IFP) scanning technology. The IFP technology associates and saves scanned documents and documents completed by tenants electronically directly to the tenant case files in Siebel. The Siebel Customer Relationship Manager (CRM) System provides process standardization and solutions for document retention needs. In the current audit, there are 30 files that are reflective of our improved document management and retention; NYCHA has continued to make such improvements since 2011 and NYCHA remains committed to making our best efforts to ensure that all eligibility and admission documentation is maintained in the system of record. Action Date September 10, 2025 Final Implementation September 10, 2025 Name And Phone Number Of Person Responsible for Implementation Lakesha Miller Executive Vice President for Leased Housing Office of the Chief Executive Officer +1-212-306-8818