Corrective Action Plans

Finding 561001 (2023-001)

Material Weakness 2023

CA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Federal Awards Finding 2023-001: Tribal Council Leadership & Oversight Finding/Condition Those charged with oversight of the Rancheria’s financial accounting and reporting system have not adequately implemented a system to ensure that it is properly utilized for Rancheria operations. The weaknesse...

Federal Awards Finding 2023-001: Tribal Council Leadership & Oversight Finding/Condition Those charged with oversight of the Rancheria’s financial accounting and reporting system have not adequately implemented a system to ensure that it is properly utilized for Rancheria operations. The weaknesses in the system are as follows: 1. A system has not been completely developed and implemented to allow for centralized grant management, ongoing monitoring of program budgets or other tribal activities. 2. Accurate financial reporting is not being completed for the Tribal Council at regular Council meetings. Planned Corrective Action Governance and management concur with this finding, and are implementing corrective measures. Anticipated Completion Date December 31, 2024

View Audit 356634

Finding 560993 (2023-008)

Significant Deficiency 2023

Heading Home

NM

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing policies and procedures found in Section II Policy #201 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the ...

View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing policies and procedures found in Section II Policy #201 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure all invoices and funds requests are properly reviewed and approved prior to processing. All invoices and requests for funds for fiscal year 2024 will be reviewed to ensure the payment request is reasonable and necessary. The invoice or funds request will be signed and dated by the preparer, as well as by the reviewer as evidence of approval for processing the payment. All invoices and funds requests will be maintained in the cloud server in a manner that allows them to be easily retrieved when needed. The disbursements in question were reviewed and found to be to vendors regularly used by Heading Home and Heading Home firmly believes that documentation of approval existed at one point in time. However, with the complete turnover in executive personnel during 2023, and the fact that the prior administration utilized an online system for document storage that the current administration has very little access to, we were unable to locate the approvals for these payments. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.

View Audit 356632

Finding 560983 (2023-006)

None 2023

Heading Home

NM

Reporting § 200.512

View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. After years of turnover in key management positions steps have been taken to address staffing challenges and these positions have been successfully staffed with high-quality individuals...

View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. After years of turnover in key management positions steps have been taken to address staffing challenges and these positions have been successfully staffed with high-quality individuals who bring extensive knowledge and expertise to their roles. These positions include a new Chief Executive Officer, Director of Operations, Chief Financial Officer, and Director of Human Services. To address challenges in accounting and finance Heading Home has contracted with a local CPA firm specializing in nonprofit accounting and financial reporting to assist the CFO with daily accounting tasks, the monthly close, financial reporting to management and the board of directors, and to facilitate and ensure audits are completed timely each year. The new management group is committed to maintaining a skilled and competent team in key financial roles. Heading Home’s accounting team is now in the process of preparing for the 2024 audit and anticipates the audit to be completed by December 31, 2025. While this will once again result in a late filing, the new management team has made significant strides in a short amount of time and anticipates that the 2025 and all future audits will be submitted on or before the March 31st due date. Management anticipates the above corrective action plan to be fully implemented by March 30, 2026. Personnel responsible for ensuring implementation include Connie Chavez, Executive Director, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountant team lead.

View Audit 356632

Finding 560856 (2023-002)

Significant Deficiency 2023

Tnkids Nutrition

TN

Reporting

he Organization agrees with the auditor’s finding and will take actions to ensure that future documentation and reporting meets the standards required.

View Audit 356610

Finding 560844 (2023-005)

Significant Deficiency 2023

Beaufort Jasper Hampton Comprehensive Services, Inc.

SC

Cash Management Reporting Matching / Level of Effort / Earmarking

We concur with the auditor's findings. We submitted the annual financial report during the period expense reimbursement was received instead of submitting it for the budget periods that ended. We are developing and implementing a grant reporting calendar listing federal financial report (FFR) due da...

We concur with the auditor's findings. We submitted the annual financial report during the period expense reimbursement was received instead of submitting it for the budget periods that ended. We are developing and implementing a grant reporting calendar listing federal financial report (FFR) due dates for all federal grants. We will use the automated alerts from the grants management system to track and remind staff of upcoming reporting deadlines. Lastly, we will maintain audit-ready documentation of each FFR submission.

View Audit 356598

Finding 560797 (2023-005)

Material Weakness 2023

International Association of Forensic Nurses, Inc.

MD

Material Weakness Reporting

Action Taken: • We are producing a timetable and posting it to calendars of the filing dates of all key reports to the relevant authorities and are circulating it widely to all executives including the Board and Finance Committee. • This recommendation is also supported by the work undertaken on inv...

Action Taken: • We are producing a timetable and posting it to calendars of the filing dates of all key reports to the relevant authorities and are circulating it widely to all executives including the Board and Finance Committee. • This recommendation is also supported by the work undertaken on invoice approval, monthly review of financials and updates on the policy on Grants and Federal Awards. • We are also in the process of recruiting a new full-time Finance Director.

View Audit 356575

Finding 560775 (2023-009)

Significant Deficiency 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Reporting Significant Deficiency Internal Control / Segregation of Duties

U.S. Department of Housing and Urban Development Significant Deficiency in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: The Organization was unable to locate documentation related to performance and financial reporting. Recommendat...

U.S. Department of Housing and Urban Development Significant Deficiency in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: The Organization was unable to locate documentation related to performance and financial reporting. Recommendation: The Organization should review its internal controls and procedures to ensure all relevant documentation is reviewed and retained for all federal funds awarded. Implementing a standardized process for document retention and training staff on proper record-keeping practices can help mitigate this issue in the future. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization has developed a more robust contract compliance process which includes document retention and training. The organization recently reviewed and updated the document retention policy and trained staff responsible for record-keeping. The organization also began conducting internal audits to ensure documentation is reviewed and retained properly. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is December 31, 2024.

View Audit 356548

Finding 560743 (2023-007)

Material Weakness 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Allowable Costs / Cost Principles Material Weakness Reporting

U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted that 21 out of 40 transactions tested exhibited a variance in the recalculation of wages...

U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted that 21 out of 40 transactions tested exhibited a variance in the recalculation of wages charged to the program. This variance was identified when comparing the wages charged to the program with the time and effort documented on the timesheet for the respective programs. Recommendation: We recommend the time and effort documentation be regularly reviewed by appropriate personnel to ensure accuracy and completeness of personnel cost documentation is appropriately reported to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a new process for wages charged to a program to ensure accuracy. This will also be monitored regularly and tracked through the accounting software in the grant spend management module. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

View Audit 356548

Finding 560655 (2023-011)

Material Weakness 2023

Shenandoah School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-011 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, a...

FINDING 2023-011 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by the Director of Curriculum without oversight by another individual. All six of the submitted reports were selected for testing. One of the reports, ESSER II, Year 2; was not supported by the School Corporation's records. The School Corporation had expenditures of $583,415 from the ESSER II grant which was not included in this report. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Director of Curriculum will review the annual data reports together before submittal. Anticipated Completion Date: September 30, 2024􀀃

View Audit 356534

Finding 560640 (2023-007)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: Monthly reimbursement claims for breakfast and lunch meals served are prepared and submitted without documented review or approval by a second individual not involved in the preparation of the reimbursement cla...

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: Monthly reimbursement claims for breakfast and lunch meals served are prepared and submitted without documented review or approval by a second individual not involved in the preparation of the reimbursement claim. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will calculate the monthly claims to be submitted to the DOE/CNP and email this information to the Business Manager for review before submittal. Anticipated Completion Date: March 31, 2024

View Audit 356534

Finding 560586 (2023-001)

None 2023

Town of Hammond

NY

Reporting § 200.512

The auditor recommends that the Town ensure compliance with the 9 month requirements and have the audits and single audit reporting package submitted by the end of September each year. The Town plans on submitting all the outstanding years of audits upon completion of its December 31, 2023 audit, w...

The auditor recommends that the Town ensure compliance with the 9 month requirements and have the audits and single audit reporting package submitted by the end of September each year. The Town plans on submitting all the outstanding years of audits upon completion of its December 31, 2023 audit, with submission to the FAC by May 15, 2025.

View Audit 356504

Finding 560569 (2023-005)

Significant Deficiency 2023

Town of Coventry, Rhode Island

RI

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding 2023-005 – Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding For one of two reports tested related to fiscal year 2023, the report was not submitted within 30 days of the end of the quarter. Statement of Concurrence or Nonconcurrence Managemen...

Finding 2023-005 – Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding For one of two reports tested related to fiscal year 2023, the report was not submitted within 30 days of the end of the quarter. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action This late submission was the result of significant turnover in the Town’s Finance Department. All subsequent reports have been filed and will continue to be filed in a timely manner. Name of Contact Person Robert J. Civetti, CPA, Finance Director Projected Completion Date Completed and all reports timely filed since June 30, 2023

View Audit 356492

Finding 560557 (2023-002)

None 2023

Town of Bellingham, Massachusetts

MA

Reporting Internal Control / Segregation of Duties

Finding 2023-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Programs Condition: Upon review of the Town of Bellingham’s report filed with the U.S. Department of Trea...

Finding 2023-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Programs Condition: Upon review of the Town of Bellingham’s report filed with the U.S. Department of Treasury it was noted that the reports did not agree with the Town’s accounting ledgers. Criteria: Per the U.S. Department of Treasury the Town was required to submit an accurate annual Recovery Plan Performance Report. Context: The annual report submitted to the U.S. Department of Treasury reported expenditures that did not agree with the general ledger. Effect: The Town of Bellingham was not in compliance with the U.S. Department of Treasury reporting requirements. Questioned Costs: N/A Cause: During this time period, the Grant Administrator compiled manually created records to support reporting requirements. Those manual records were not properly reconciled with the General Ledger reports prior to submission to the required agencies. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: The Town of Bellingham should complete and submit all required quarterly reporting by the due date designated by the Federal Agency and ensure that it agrees with grant activity for time period reported. Responsible for Corrective Plan: Grants Administrator and CFO Estimated Completion Date: January 2024 Action Taken: The Town has trained the Grants Administrator on procedures to reconcile General Ledger reports with manually created project-based records. The Town is also implementing a procedure whereby the CFO signs each required report before submitting.

View Audit 356487

Finding 560406 (2023-003)

Significant Deficiency 2023

The Pines Housing, Inc.

OR

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Finding Reference Number: 2023-003 Condition: In September 2023, HUD suspended its HAP subsidy to the Organization due to noncompliance regarding the tenant recertifications requirements under the HAP Contract. Recommendation: We recommend that control systems are put in place to ensure there are re...

Finding Reference Number: 2023-003 Condition: In September 2023, HUD suspended its HAP subsidy to the Organization due to noncompliance regarding the tenant recertifications requirements under the HAP Contract. Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding OJF has completed all overdue tenant recertifications. To prevent future delinquent recertifications, OJF will conduct a root cause analysis by January 15, 2025 to identify gaps in the current process. Once gaps are identified, procedures will be updated to provide clear guidelines and timelines to staff. By February 15, 2025, OJF will implement a tracking system for tenant recertifications, including supervisory review of all tenant files. By March 15, 2025, relevant OJF staff will undergo training on compliance with HUD requirements. This will include the creation of a compliance calendar. OJF’s senior management team and board of directors will monitor progress towards these goals. Progress reports will be drafted no later than April 15, 2024

View Audit 356309

Finding 560404 (2023-002)

Significant Deficiency 2023

The Pines Housing, Inc.

OR

Eligibility HUD Housing Programs Reporting

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 mov...

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 move-ins and move-outs sampled out of the population (9 total move-ins and 13 total move-outs during the audit period). Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding To address this finding, OJF will take the following actions: 1. Implement regular tenant file reviews at least semi-annually beginning January 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 2. Develop a mandatory training program on compliance requirements for property management site staff to follow by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 3. Revise and distribute existing tenant file management procedures by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 4. Establish a monitoring and feedback system by March 15, 2025 for site staff to seek guidance on or report challenges of file management so that advice can be given and/or corrective action taken a. Responsible party: OJF asset management director and property management portfolio manager 5. Conduct quarterly management reviews beginning 4/15/2025 to discuss and evaluate the effectiveness of above actions a. Responsible party: OJF asset management director and property management portfolio manager

View Audit 356309

Finding 560393 (2023-004)

Material Weakness 2023

Bakersfield, American Indian Health Project INC

CA

Reporting Internal Control / Segregation of Duties

Establish and Maintain a Reporting Calendar: A comprehensive grant reporting calendar will be implemented to track all financial and performance reporting deadlines. Calendar will include due dates, responsible staff, and required supporting documentation. Assigned Clear Roles and Responsibilities:...

Establish and Maintain a Reporting Calendar: A comprehensive grant reporting calendar will be implemented to track all financial and performance reporting deadlines. Calendar will include due dates, responsible staff, and required supporting documentation. Assigned Clear Roles and Responsibilities: Each grant report will have a designated preparer and reviewer. The Controller will be responsible for ensuring that all reports reconcile to the general ledger before submission. Implemented Standardized Reporting Procedures: A written Grants Reporting and Procedure Manual will be developed outining step-by-step procedures for preparing, reviewing, and submitting reports. Reports will only be submitted after reconciliation with the accounting system and documented approval from the Finance Director or Controller. Training and Capacity Building: Staff responsible for grant reporting will receive annual training on federal compliance requirements, Uniform Guidance, and internal procedures. Training sessions will include examples of common reporting errors and reconciliation best practices. Monitoring and Internal Reviews: The Finance Director will conduct a monthly compliance check to verify timely completion and accuracy of each report. Quarterly internal audits will be conducted to assess adherence to the reporting procedures and controls.

View Audit 356287

Finding 560390 (2023-003)

Material Weakness 2023

Bakersfield, American Indian Health Project INC

CA

Reporting Internal Control / Segregation of Duties

Reporting Calendar and Schedule: A grant reporting calendar will be created and maintained, outlining all required reporting deadlines for each funding source, including due dates, responsible staff, and required documentation. The calendar will be reviewed weekly by the Finance Director to ensure u...

Reporting Calendar and Schedule: A grant reporting calendar will be created and maintained, outlining all required reporting deadlines for each funding source, including due dates, responsible staff, and required documentation. The calendar will be reviewed weekly by the Finance Director to ensure upcoming deadlines are met. Assignment of Responsibilities: Clear responsibilities will be assigned to specific personnel for each step of the reporting process, including data preparation, report drafting, internal review, and final submission. A checklist will be used for each report to document the review proceduress and ensure all elements are completed accurately and timely. Reconciliation Procedures: All reports will be reconciled to the general ledger and supporting schedules prior to submission to ensure consistency and accuracy. Supporting documentation will be attached to each report file to provide an audit trail. Internal Review Process: A second-level review by the Controller or Finance Director will be required before reports are submitted to funding agencies. Review will include verifying accuracy, completeness, and agreement with accounting system data. Training and Internal Controls: Staff responsible for report preparation will undergo annual training on grant compliance requirements, Uniform Guidance, and reporting accuracy. Internal controls will be documented in Grants Management Policy and Procedures Manual, including reporting guidelines. Monitoring and Follow-Up: Compliance with the reporting calendar and procedures will be tracked monthly. Any missed or delayed reports will be investigated, and corrective actions taken immediately.

View Audit 356287

Finding 560385 (2023-002)

Significant Deficiency 2023

Public Housing Authority of Butte

MT

HUD Housing Programs Eligibility Reporting

The Public Housing Authority of Butte will contract with the Certified Public Accounting firm to assist with timely submission of the FY 2024 unaudited Financial Data Schedule. This will provide su icient time for the audit to get completed by the audited FASSPHA deadline.

View Audit 356277

Finding 560348 (2023-002)

Material Weakness 2023

Cornerstone Whole Healthcare Organization, Inc.

ID

Reporting Material Weakness § 200.328

Plan of Action: To correct deficiencies in the preparation and submission of the SF-425 Federal Financial Report, the organization has established SOP F1.03: Submission and Recordkeeping of Federal Financial Reports (SF-425). This procedure outlines the steps for accurately completing the SF-425 usi...

Plan of Action: To correct deficiencies in the preparation and submission of the SF-425 Federal Financial Report, the organization has established SOP F1.03: Submission and Recordkeeping of Federal Financial Reports (SF-425). This procedure outlines the steps for accurately completing the SF-425 using verified financial data, submitting it through the appropriate federal systems by required deadlines, and maintaining supporting documentation in compliance with federal recordkeeping standards. It applies to all staff involved in financial reporting on federally funded grants.

View Audit 356257

Finding 560336 (2023-001)

None 2023

Near West Side Multi-Service Corporation

OH

Reporting Internal Control / Segregation of Duties

We will implement stricter adherence to deadlines and ensure that all reports are filed on time. Measures will include setting up reminder systems and providing additional training to staff on the importance of meeting these deadlines.

View Audit 356241

Finding 560335 (2023-004)

None 2023

City of Dunkirk, New York

NY

Reporting

View of Responsible Officials and Planned Corrective Action Plan—The City will update amounts and descriptions within the Department of Treasury’s reporting portal to ensure all amounts expended are properly reported.

View Audit 356234

Finding 560313 (2023-002)

Material Weakness 2023

Springboard Collaborative

PA

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Issue Corrective Actions Responsible Party Status Springboard Collaborative did not maintain adequate time and effort reports for staff salaries and fringe benefits for all employees who spent less than 100% of their time working on this major program. Implement quarterly effort report certification...

Issue Corrective Actions Responsible Party Status Springboard Collaborative did not maintain adequate time and effort reports for staff salaries and fringe benefits for all employees who spent less than 100% of their time working on this major program. Implement quarterly effort report certification process, which requires eligible employees, their managers, and the grant management staff to review and certify effort charged to grant funding during the applicable reporting period. **The effort report certification process was fully enabled and completed in response to Single Audit review during the FY23 audit process and in preparation for FY24 audit. Grant management staff (Associate Director, Fiscal Grant Management) Completed Corrective Action

View Audit 356226 Questioned Costs: $1

Finding 560310 (2023-003)

Material Weakness 2023

Windsor Housing Authority

CT

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accou...

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accountant and Auditors to make sure deadlines are realistic, coordinated and attainable. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

View Audit 356224

Finding 560309 (2023-002)

Material Weakness 2023

Windsor Housing Authority

CT

HUD Housing Programs Subrecipient Monitoring Eligibility

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for ten...

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for tenants begins 90 days prior to the recert date, but if tenants do not provide all the requested information, the recertification will be delayed until the information is provided, tenant is converted to a market rate rent, or we begin the termination process for termination of the voucher. We will continue to follow the HUD process for the management of the Housing Choice Voucher Programs/Mainstream voucher programs. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

View Audit 356224

Finding 560261 (2023-001)

Material Weakness 2023

Appalachian Community Capital Corporation

VA

Reporting

Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 105 Arbor Drive, 3rd Floor Christiansburg, VA 24073 Audit period: Decem...

Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 105 Arbor Drive, 3rd Floor Christiansburg, VA 24073 Audit period: December 31, 2023 The findings from the December 31, 2023 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2023-001: Community Development Financial Institutions Fund – Assistance Listing No. 21.024, Rapid Response Program, Restatement of Schedule of Expenditures of Federal Awards, Material Weakness Criteria and Condition: Recipients of federal funds are required to prepare a complete and accurate Schedule of Expenditures of Federal Awards. Additionally, recipients must establish and maintain effective internal controls over federal awards to provide reasonable assurance of accurate financial reporting Context: The Company restated the 2023 Schedule of Expenditures of Federal Awards by a material amount a result of misinterpretation of reporting requirements for loan loss reserves and allocations of other allowable purposes. Cause: The omission occurred due to a misinterpretation of reporting requirements involving the treatment of grant expenditures for the purpose of loan loss reserve funds, which differs in nature from general program expenditures. Management identified the issue and determined a change in reporting was needed to simplify tracking and reporting of federal grants, and to ensure compliance with the technical definition of expenditures in the guidance. Effect: Loan loss reserves allocated in the wrong period resulted in an understatement of total federal expenditures on the Schedule of Expenditures of Federal Awards. Recommendation: We recommend that the Company implement a formalized review process to ensure all applicable expenditures, including loan loss reserves, are properly recorded in the period in which assigned. Views of Responsible Officials and Planned Corrective Actions: We agree with the finding and have established a process to ensure all expenditures are properly included in the SEFA. Name of Contact Person: Donna Gambrell, President and Chief Executive Officer Signature of Contact Person:

View Audit 356165

Corrective Action Plans

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