Corrective Action Plans

Finding 1164685 (2024-001)

Material Weakness 2024

Row House Community Development Corporation

TX

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Housing and Urban Development, Passed through City of Houston, HOME Investment Partnership Fund, Assistance Listing #14.239, Contract period: 08/2008 – 12/2028. Condition and context: ...

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Housing and Urban Development, Passed through City of Houston, HOME Investment Partnership Fund, Assistance Listing #14.239, Contract period: 08/2008 – 12/2028. Condition and context: We noted the rental rate for 1 out of 6 tenant agreements tested for eligible families did not agree to the actual amount paid by the tenant. The tenant agreement reflected $600 in monthly rent compared to the amount paid of $575. The lease amount paid by the tenant did comply with HUD guidelines. Recommendation: Strengthen procedures to consistently maintain rent roll and ensure lease agreements are correct based on allowable tenant rental rates. Management’s response: Management and the contract bookkeeper will verify rent rolls on a monthly basis. Responsible officer: Previn Jones, Property Manager. Estimated completion date: Immediately.

View Audit 374359

Finding 1164681 (2024-005)

Material Weakness 2024

Southwest Regional Development Commission

MN

Internal Control / Segregation of Duties Reporting Significant Deficiency

Finding Summary: There was no formal review documented over reports tested. Responsible Individuals: Jay Trusty, Executive Director Corrective Action Plan: Management has reviewed the findings and taken steps in developing an internal control review process. The Commission implemented procedures to ...

Finding Summary: There was no formal review documented over reports tested. Responsible Individuals: Jay Trusty, Executive Director Corrective Action Plan: Management has reviewed the findings and taken steps in developing an internal control review process. The Commission implemented procedures to ensure all reports have proof of review and submission, as well as working towards submitting all reports timely. Anticipated Completion Date: June 2026

View Audit 374323

Finding 1164611 (2024-001)

Material Weakness 2024

Town of Cohasset

MA

Allowable Costs / Cost Principles Reporting Significant Deficiency

Planned Corrective Action: All future ARPA reporting will be derived from trial balances generated from the accounting department staff. The trial balances will then be reviewed and entered into the reporting portal by the Town Manager by the reporting due date. Any variances or adjustments that are...

Planned Corrective Action: All future ARPA reporting will be derived from trial balances generated from the accounting department staff. The trial balances will then be reviewed and entered into the reporting portal by the Town Manager by the reporting due date. Any variances or adjustments that are necessary from the trial balance will be clearly documented for reconciliation and confirmed by the Town Accountant as accurate. Upon confirmation, the Town Manager will submit the portal. Planned Implementation Date of Corrective Action: March 2026 P&E Report (due by April 30, 2026) Person Responsible for Corrective Action: Town Accountant Town Manager

View Audit 374218

Finding 1164496 (2024-004)

Material Weakness 2024

Catholic Community Services, INC

AK

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Finding: 2024-004: Significant Deficiency in Internal Controls over Compliance – Eligibility Name of Contact Person: Tray Miller Controller Catholic Community Service 1803 Glacier Highway Juneau, AK 99801 Corrective Action: Management will ensure eligibility forms are thoroughly reviewed. Proposed C...

Finding: 2024-004: Significant Deficiency in Internal Controls over Compliance – Eligibility Name of Contact Person: Tray Miller Controller Catholic Community Service 1803 Glacier Highway Juneau, AK 99801 Corrective Action: Management will ensure eligibility forms are thoroughly reviewed. Proposed Completion Date: 6/30/25

View Audit 374065

Finding 1164490 (2024-003)

Material Weakness 2024

Catholic Housing Corporation of Mt Penn

PA

Special Tests & Provisions Cash Management HUD Housing Programs

Management’s Response: Although the Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in th...

Management’s Response: Although the Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.

View Audit 374062

Finding 1164488 (2024-002)

Material Weakness 2024

Catholic Housing Corporation of Mt Penn

PA

HUD Housing Programs Significant Deficiency

Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorpo...

Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorporate the recommendations above.

View Audit 374062

Finding 1164486 (2024-003)

Material Weakness 2024

Catholic Housing Corporation of Lansford

PA

Special Tests & Provisions Cash Management HUD Housing Programs

Management’s Response: Although the Corporation does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the...

Management’s Response: Although the Corporation does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.

View Audit 374060

Finding 1164484 (2024-002)

Material Weakness 2024

Catholic Housing Corporation of Lansford

PA

HUD Housing Programs Significant Deficiency

Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorpo...

Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorporate the recommendations above.

View Audit 374060

Finding 1164427 (2024-003)

Material Weakness 2024

Taylor County, Wi

WI

Questioned Costs Allowable Costs / Cost Principles Cash Management

Recommendation: We recommend that the County implement a procedure by which a monthly review of the activities billed by providers to the CLTS Third Party Administration is performed with special attention on any authorized changes in services that occurred during the month. Explanation of disagreem...

Recommendation: We recommend that the County implement a procedure by which a monthly review of the activities billed by providers to the CLTS Third Party Administration is performed with special attention on any authorized changes in services that occurred during the month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County acknowledges the recommendation to implement a procedure for monthly review of provider-billed activities submitted to the CLTS Third Party Administration (TPA). It is our understanding that the activity subject to testing in the future for CLTS will be case management and other services directly provided by Taylor County personnel. The County will evaluate current processes to make sure they are complying. Name(s) of the contact person(s) responsible for corrective action: Tracy Hartwig, Finance Director Planned completion date for corrective action plan: December 31, 2025

View Audit 373865 Questioned Costs: $1

Finding 1164423 (2024-007)

Material Weakness 2024

Reach Community Development, Inc.

OR

Special Tests & Provisions HUD Housing Programs Significant Deficiency

Finding No. 2024-007 HUD Low Income Housing Preservation and Resident Homeownership Act of 1990 Federal Assistance Listing Number #99.999 Statement of Condition The owner was unable to provide support that they ensured passing HQS inspections were performed during 2024. Corrective Action Plan REACH ...

Finding No. 2024-007 HUD Low Income Housing Preservation and Resident Homeownership Act of 1990 Federal Assistance Listing Number #99.999 Statement of Condition The owner was unable to provide support that they ensured passing HQS inspections were performed during 2024. Corrective Action Plan REACH has policies in place for annual HQS inspections. During the audit, we were informed that the inspection form did not include inspection, work orders, and re-inspection. As a result of the 2024 audit, Management implemented using a new form in 2025 to capture inspection, work orders, and re-inspection.

View Audit 373851

Finding 1164422 (2024-006)

Material Weakness 2024

Reach Community Development, Inc.

OR

Eligibility Significant Deficiency

Finding No. 2024-006 Housing Trust Fund Program Federal Assistance Listing Number #14.275 Statement of Condition In connection with our lease file review, we noted two instances of four tenants tested where management did not provide support that they performed a 3rd party income verification in acc...

Finding No. 2024-006 Housing Trust Fund Program Federal Assistance Listing Number #14.275 Statement of Condition In connection with our lease file review, we noted two instances of four tenants tested where management did not provide support that they performed a 3rd party income verification in accordance with policy. Corrective Action Plan As a result of the 2024 audit, a new process is set up to ensure that new employees receive HUD annual training. Management will continue to ensure that 3rd party income verification is performed in accordance with policy.

View Audit 373851

Finding 1164420 (2024-004)

Material Weakness 2024

Reach Community Development, Inc.

OR

Eligibility HUD Housing Programs Significant Deficiency

Finding No. 2024-004 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. This is considered a temporary noncompliance as follows: "Next Available Unit"...

Finding No. 2024-004 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. This is considered a temporary noncompliance as follows: "Next Available Unit" rule: The owner must rent the next comparable or smaller unit that becomes vacant to a low-income household. Temporary noncompliance: The unit is temporarily out of compliance with HOME requirements, but the property can regain compliance by following the "next available unit" rule. Unit conversion: If the owner fails to comply and rents a comparable vacant unit to a non-low-income tenant, the over-income unit loses its low-income status and the building's compliance is reduced. A two bedroom unit did become available in 2024 and this tenant was not relocated. Corrective Action Plan A new review process is in placed to review the HOME units that will be re-classified the next time there is a vacant unit of the corresponding size/type.

View Audit 373851

Finding 1164419 (2024-003)

Material Weakness 2024

Reach Community Development, Inc.

OR

Eligibility HUD Housing Programs Significant Deficiency

Finding No. 2024-003 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. Corrective Action Plan A new process is in placed to review HOME unit count wh...

Finding No. 2024-003 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. Corrective Action Plan A new process is in placed to review HOME unit count when a unit becomes available.

View Audit 373851

Finding 1164418 (2024-002)

Material Weakness 2024

Reach Community Development, Inc.

OR

Eligibility HUD Housing Programs Significant Deficiency

Finding No. 2024-002 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition In connection with our lease file review, we noted six instances of eight tenants tested where management did not provide support that they performed a 3rd party income veri...

Finding No. 2024-002 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition In connection with our lease file review, we noted six instances of eight tenants tested where management did not provide support that they performed a 3rd party income verification in accordance with policy. Corrective Action Plan As a result of the 2024 audit, a new process is set up to ensure that new employees receive HUD annual training. Management will continue to ensure that 3rd party income verification is performed in accordance with policy.

View Audit 373851

Finding 1164417 (2024-001)

Material Weakness 2024

Reach Community Development, Inc.

OR

Special Tests & Provisions HUD Housing Programs Significant Deficiency

Finding No. 2024-001 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not ensure passing HQS inspections were performed during 2024. Corrective Action Plan REACH has policies in place for annual HQS inspections, and in 2023 retur...

Finding No. 2024-001 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not ensure passing HQS inspections were performed during 2024. Corrective Action Plan REACH has policies in place for annual HQS inspections, and in 2023 returned to performing these inspections after suspending this activity during prior years impacted by COVID-era policies. Though inspections were performed according to requirements, during the audit we were informed that our inspection form did not include details related to inspection follow-up, work orders and re-inspection. As a result of the 2024 audit, Management implemented the use of a new form in 2025 to capture this additional information related to inspections, work orders and re-inspection

View Audit 373851

Finding 1164259 (2024-001)

Material Weakness 2024

Hiv Alliance INC

OR

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

U.S. Department of Health and Human Services Significant Deficiency in Internal Controls over Compliance: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidenc...

U.S. Department of Health and Human Services Significant Deficiency in Internal Controls over Compliance: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence obtained and retained by the Alliance as proof of oversight of expenditure of federal funds. Additionally, CLA recommends increased emphasis and training on the importance of consistent application of procedures and controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All reports relating to a federally funded project will be reviewed prior to being submitted to the funding agency and documentation relating to that review will be retained by HIV Alliance. Name(s) of the contact person(s) responsible for corrective action: Renee Yandel, Executive Director; Wayne Hamblin, Finance Director Planned completion date for corrective action plan: July 1, 2025

View Audit 373559

Finding 1164256 (2024-001)

Material Weakness 2024

Congregation Bais Malka Inc.

NY

Internal Control / Segregation of Duties Reporting Significant Deficiency

The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit...

The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end June 30, 2025. Mr. Benjamin Klein, executive director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-354-9500.

View Audit 373554

Finding 1164252 (2024-004)

Material Weakness 2024

Manor College

PA

Reporting Student Financial Aid Significant Deficiency § 200.303

Pending

View Audit 373530

Finding 1164249 (2024-003)

Material Weakness 2024

Manor College

PA

Student Financial Aid Reporting Significant Deficiency

Implement draft Policy & Procedures on monthly recs

View Audit 373530

Finding 1163592 (2024-002)

Material Weakness 2024

Zvago Cooperative at Long Lake

MN

Special Tests & Provisions HUD Housing Programs Significant Deficiency

The Cooperative is making required deposits to the General Operating Reserve. Management will implement a process to ensure deposits are made as required by the HUD regulatory agreement.

View Audit 373336

Finding 1163578 (2024-006)

Material Weakness 2024

Housing Authority of the City of Asheville

NC

HUD Housing Programs Special Tests & Provisions Reporting

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 – Depository Agreements Non Compliance Material to the Financial Statements: No ...

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 – Depository Agreements Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: PHAs are required to enter into general depository agreements (GDA) with their financial institutions in the form required by HUD. The agreements serve as safeguards for federal funds and provide third party rights to HUD. Among the terms in many agreements are requirements for funds to be placed in an interest-bearing account (24 CFR section 982.156). Condition: Based on inspection of files and discussions with management, it was determined that the depository agreements were signed after the reporting period. Context: The Authority did not have signed depository agreements with their financial institutions on file during the reporting period, therefore we were unable to verify the existence of depository agreements and unable to determine if the Authority met the terms of the agreements. Cause: There is a significant deficiency in internal controls over compliance for the special tests and provision type of compliance related to depository agreements. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls for their partnered management company that assures the program is in compliance. Effect: The Housing Voucher Cluster is in noncompliance with the special tests and provisions type of compliance related to depository agreements. Auditors' Recommendation: We recommend that the Authority properly file HUD-51999 forms in accordance with HUD guidelines. View of Responsible Officials and Corrective Actions: The Authority accepts the recommendation of the auditor and will properly file HUD- 51999 forms in accordance with HUD guidelines. Noelle Tackett, Director of the Housing Choice Voucher Program, will be responsible to implement this corrective action by December 31, 2025.

View Audit 373324

Finding 1163555 (2024-003)

Material Weakness 2024

Community Service Council of Greater Tulsa, Inc.

OK

Eligibility Significant Deficiency

Federal Program – Supportive Housing for Veterans (Supportive Services for Veterans Families) (SSVF) Assistance Listing Number – 64.033 Significant Deficiency Criteria: The SSVF Program Guide Section VIII, Subsection E. Documentation Required states: Grantees must use adequate financial management s...

Federal Program – Supportive Housing for Veterans (Supportive Services for Veterans Families) (SSVF) Assistance Listing Number – 64.033 Significant Deficiency Criteria: The SSVF Program Guide Section VIII, Subsection E. Documentation Required states: Grantees must use adequate financial management systems that follow generally accepted accounting principles (GAAP) and provide adequate fiscal control and account records including cost accounting records supported by documentation. Grantees must also maintain all back up documentation and invoices to support the costs paid with SSVF funds.” Condition: During the OBO review, OBO found the Organization was unable to provide a general ledger detail that separated administrative costs from general costs. Cause: Because the Organization’s SSVF administrative costs are allocated payroll expenses, management was unaware they needed to segregate the administrative costs in the general ledger. Effect: The Organization’s failure to provide a general ledger that separates administrative and general expenses increases the risk of inaccurate financial results being provided at closeout or unauthorized and ineligible expenses being charged to the award, which may result in subsequent funding shortages for other qualified expenses. Questioned Costs: None Identification as a repeat finding: This is a repeat finding. Corrective Action: As of 2/17/2025 OKVU added sub-coding to the general ledger to identify administrative labor costs under 7000 – Salaries & wages, 7100 – Fringe benefits and 7200 – Payroll taxes bases on direct allocations provided to the payroll system. This information will be provided by report from the payroll system and added via journal entry to the GL.

View Audit 373239

Finding 1163554 (2024-002)

Material Weakness 2024

Community Service Council of Greater Tulsa, Inc.

OK

Internal Control / Segregation of Duties Significant Deficiency

Federal Program – Supportive Housing for Veterans (Supportive Services for Veterans Families) (SSVF) Assistance Listing Number – 64.033 Significant Deficiency Criteria: The SSVF Program Guide (March 2021) Section VII, Subsection E. Notification to Participants, states: “To ensure that Veteran famili...

Federal Program – Supportive Housing for Veterans (Supportive Services for Veterans Families) (SSVF) Assistance Listing Number – 64.033 Significant Deficiency Criteria: The SSVF Program Guide (March 2021) Section VII, Subsection E. Notification to Participants, states: “To ensure that Veteran families receiving supportive services under the SSVF Program are receiving quality services, the grantee must give a VA-designated satisfaction survey to each participant within 30 days of the participant’s pending exit from the grantee’s program.” Condition: The Office of Business Oversight (OBO) performed a review to assess the Organization’s compliance with SSVF program and other federal requirements and regulations. During this review, OBO found 15 case files where the Organization provided the VA-designated satisfaction survey late. Cause: As a result of staff turnover, the Organization failed to develop adequate internal controls to ensure management monitored case manager development and reviewed case files for adequate documentation. Effect: The Organization’s failure to provide the VA-designated satisfaction survey within 30 days may decrease feedback to the SSVF Program, which may result in veterans not receiving appropriate assistance and quality services. Questioned Costs: None Identification as a repeat finding: This is a repeat finding. Corrective Action: As of 12/11/2024 OKVU updated the SSVF policy and procedure manual to ensure grant compliance with the VA-designated satisfaction survey and added a review requirement to the discharge file QC checklist. As of 12/11/2024 all case manager staff were provided training.

View Audit 373239

Finding 1163553 (2024-001)

Material Weakness 2024

Community Service Council of Greater Tulsa, Inc.

OK

Eligibility Significant Deficiency

Federal Program – Supportive Housing for Veterans (Supportive Services for Veterans Families) (SSVF) Assistance Listing Number – 64.033 Significant Deficiency Criteria: The SSVF Program Guide (March 2021) Section V, Subsection C. Determining Income Eligibility, provides a summary of asset inclusions...

Federal Program – Supportive Housing for Veterans (Supportive Services for Veterans Families) (SSVF) Assistance Listing Number – 64.033 Significant Deficiency Criteria: The SSVF Program Guide (March 2021) Section V, Subsection C. Determining Income Eligibility, provides a summary of asset inclusions and exclusions for use in evaluating assets. Assets must be evaluated at entry to SSVF and at recertification. Condition: The Office of Business Oversight (OBO) performed a review to assess the Organization’s compliance with SSVF program and other federal requirements and regulations. During this review, OBO found 45 case files missing evidence that the grantee evaluated assets (inclusions and exclusions) for certification of eligibility. Cause: Management misinterpreted the guidance and was not aware of the need to document asset evaluations if the veteran did not have any assets. Effect: The Organization’s failure to obtain and keep the adequate income supporting documentation in the case file may result in the Organization providing services to an ineligible veteran or household. Questioned Costs: None Identification as a repeat finding: This is a repeat finding. Corrective Action: As of 12/06/2024 OKVU implemented the addition of the Asset Calculation Worksheet to the veteran case file. To ensure compliance the requirement was also added to the discharge file QC checklist and the SSVF policy and procedure manual updated. As of 12/11/2024 all case manager staff were provided training.

View Audit 373239

Finding 1163380 (2024-007)

Material Weakness 2024

Economic Development Bank for Puerto Rico

PR

Special Tests & Provisions Subrecipient Monitoring Reporting

Management acknowledges that the Single Audit report timelines can be further strengthened. All audit processes are performed using the Recipient systems, which are designed to comply with federal requirements. Observations are considered an opportunity to improve coordination and internal monitorin...

Management acknowledges that the Single Audit report timelines can be further strengthened. All audit processes are performed using the Recipient systems, which are designed to comply with federal requirements. Observations are considered an opportunity to improve coordination and internal monitoring.

View Audit 372904

Corrective Action Plans

Filters