Corrective Action Plans

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Finding 2023-001 – Significant Deficiency in Internal Controls over Allowable Costs (Payroll) – COVID-19 ARPA Child Care and Development Block Grant – 93.575 Recommendation: YMCA management should strengthen its controls related to the review and approval of information on employee time sheets and p...
Finding 2023-001 – Significant Deficiency in Internal Controls over Allowable Costs (Payroll) – COVID-19 ARPA Child Care and Development Block Grant – 93.575 Recommendation: YMCA management should strengthen its controls related to the review and approval of information on employee time sheets and pay rates including proper evidence is maintained of the control over compliance with allowable cost requirements, related to payroll. Corrective Action: The referenced significant deficiency was due to several factors including, but not limited to system migration from one third party payroll provider to another. For any future system migrations, the evidence of the review and approval of employee time sheets and pay rates will be retained. Person Responsible for Corrective Action: Chief Financial Officer Anticipated Completion Date for Corrective Action: The third party payroll provider has transitioned to one more well suited to the needs of the YMCA and management has begun efforts to ensure that the approval of payroll, as captured within the system at the time of processing payroll, will also be retained for future reference, should it be needed. The remaining aspects of the Corrective Action will be immediately implemented in response to the auditor's recommendation.
Corrective Action Plan and Views of Responsible Officials The Corporation will ensure that all monthly deposits to the replacement reserve are made in a timely manner.
Corrective Action Plan and Views of Responsible Officials The Corporation will ensure that all monthly deposits to the replacement reserve are made in a timely manner.
Finding 2023-001 - Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance andSignificant Deficiency Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the following by our fisca l year-...
Finding 2023-001 - Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance andSignificant Deficiency Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the following by our fisca l year-end September 30, 2024: a. Hous ing Choice Voucher tenant files will be reviewed and quality controlled each mo nth prior to initiali za tio n (25t 11- 30 111 of each month) by the Deputy Executive Director/COO. b. An action pla n has been develo ped for the Housing Choice Voucher department to ensure that all Housing Choice Voucher files are HUD and GHA compliant starting with October 1, 2023 files through the cun-e nt. c. Hous ing Choice Voucher calendar-year 2024 (October 2023-September 2024) re-exams are substantially complete, as they become effective. All tenant files will be reviewedand HUD-co mpliant by FYE2024. d. During FYE2024, the Deputy Executive Director/COO will perform 40% quality controls of the monthly re-exams processed by the Housing Specialists. e. File checklist sheets will be placed in each file upon quality control review to be signed off by the Deputy Executive Director/COO. f. Additional training has been and will be made available as necessary. g. Other interna l control measures will be implemented as deemed necessary by the Deputy Executive Director/COO, to eliminate future audit findings. Person Responsible: Shanetta Moye, Deputy Executive Director/COO Anticipated Completion Date: September 30, 2024
Finding 2023-022 Pandemic EBT Food Benefits, ALN 10.542 - Lack of Documentation for School Modality Data Reviews Management Views MDHHS disagrees that not formally documenting the review details on the log rises to the level of a material weakness and material noncompliance. MDHHS selects a sampl...
Finding 2023-022 Pandemic EBT Food Benefits, ALN 10.542 - Lack of Documentation for School Modality Data Reviews Management Views MDHHS disagrees that not formally documenting the review details on the log rises to the level of a material weakness and material noncompliance. MDHHS selects a sample of schools that submitted data and verifies the accuracy of Pandemic EBT (P-EBT) school modality data reported, documenting the schools reviewed within a log. Following the written business process, P-EBT staff first identify public information available to verify the school’s modality data such as the school’s calendar or news articles, and then reach out to school administration if public information is not available. If additional steps are required to reconcile the data, P-EBT staff document the support and results, sign off on the reconciliation, and forward to a supervisor for review. For this review period, no discrepancies were identified between what the school reported, and school websites. Since no discrepancies were noted, staff verbally communicated the review results to the manager and the log of sample items reviewed were kept within a shared drive. Planned Corrective Action MDHHS has no corrective action planned at this time as P-EBT benefit issuance ended as of May 11, 2023. No additional benefits will be issued in fiscal year 2024. Anticipated Completion Date Not applicable Responsible Individual(s) Kathy Cornell, MDHHS
Finding 2023-021 SNAP Cluster, ALN 10.551 and 10.561 - EBT Reconciliations Management Views MDHHS disagrees that a material weakness and material noncompliance exist. MDHHS federal reporting conducts a daily reconciliation of federal draws and authorizations to retailers based on vendor EBT reports...
Finding 2023-021 SNAP Cluster, ALN 10.551 and 10.561 - EBT Reconciliations Management Views MDHHS disagrees that a material weakness and material noncompliance exist. MDHHS federal reporting conducts a daily reconciliation of federal draws and authorizations to retailers based on vendor EBT reports. In addition, MDHHS conducts a monthly reconciliation between Bridges, Bridges data warehouse, and vendor EBT reports using daily data to ensure the client information in Bridges and Bridges data warehouse is accurate. The monthly reconciliation process does not impact the federal draw because the daily reconciliation of the vendor EBT report is used for this purpose. MDHHS provided detailed and accurate descriptions of MDHHS daily and monthly EBT reconciliations to the designated federal awarding agency contacts at the United States Department of Agriculture Food and Nutrition Service Agency that are familiar with MDHHS processes and received confirmation that the current reconciliation processes in place are sufficient to comply with federal regulations. Planned Corrective Action MDHHS disagrees with the finding and does not intend to take further action. Anticipated Completion Date Not applicable Responsible Individual(s) Sara Gross, MDHHS
Corrective Action Plan: The Executive Director will advise the CPA of all purchases that exceed the capitalization threshold when they occur. Copies of the check(s) and invoice(s) will be scanned into the month they are paid (into the Laserfiche electronic storage system). The CPA will review the pa...
Corrective Action Plan: The Executive Director will advise the CPA of all purchases that exceed the capitalization threshold when they occur. Copies of the check(s) and invoice(s) will be scanned into the month they are paid (into the Laserfiche electronic storage system). The CPA will review the payments scanned monthly and also scan the disbursements for any that could have been missed. At the end of the fiscal year, the disbursements that meet the capitalization requirements of HAHC and RTS will be entered into the depreciation schedule. Person(s) responsible: Executive Director- Connie Stewart CPA- Barfield and Kinkead LLC Completion Date: Fiscal year ending September 30, 2024
Management Corrective Action Plan For the Year Ended December 31, 2023 Community Roots Housing US Department of Homeland Security auditee identification number: PMDC-PJ-10-WA-2018-010 Audit Firm: Clark Nuber PS Audit Period: Year ended December 31, 2023 Finding 2023-001 – Significant deficiency in i...
Management Corrective Action Plan For the Year Ended December 31, 2023 Community Roots Housing US Department of Homeland Security auditee identification number: PMDC-PJ-10-WA-2018-010 Audit Firm: Clark Nuber PS Audit Period: Year ended December 31, 2023 Finding 2023-001 – Significant deficiency in internal controls over compliance related to special tests and provisions. Requirement: Per the requirements contained in 24 CFR Part 982, property owners must perform housing quality inspections at the time of initial occupancy and at least annually thereafter to ensure that the units are decent, safe, and sanitary. Finding: Out of 12 units selected for testing, 2 units did not have documentation supporting that a housing quality standards inspection was completed during 2023. Recommendation: CRH should implement the necessary internal controls to ensure annual inspections are performed and documented. Comments Community Roots Housing agrees with this finding and recommendation. Corrective Action Plan Community Roots Housing maintains detailed listings of annual inspection work orders, including unit numbers and when they were finished. This listing is prepared by the maintenance department. An additional control will be added to include secondary review and oversight by the Director of Property Management. This review will occur quarterly, starting in the with the second quarter of 2024, to ensure that all inspections are completed before the end of 2024, and annually thereafter. The Director of Maintenance and the Director of Property Management will be responsible for ensuring these tasks are carried out. Corrective Action Plan prepared by: Leslie Woodworth, Chief Financial Officer, 206-895-2030
2023-003 Finding - Federal Award - Significant Deficiency - Reporting US Department ofCommerceAL#11.611 Context and Cause - The Organization was not made aware by grants, CMTC or prior auditors that the final upload package of the federal reports and requests for reimbursement should have internal c...
2023-003 Finding - Federal Award - Significant Deficiency - Reporting US Department ofCommerceAL#11.611 Context and Cause - The Organization was not made aware by grants, CMTC or prior auditors that the final upload package of the federal reports and requests for reimbursement should have internal control oversight procedures and did not exercise such oversight. Only one individual was responsible for preparing and filing these final documents after such details were reviewed individually throughout the month by other individuals responsible for that review. The payroll time sheet review process was consistently followed, however, and there is not a process for the final processed payroll rep01ts to be reviewed by a second individual.Recommendation: We recommend management implement procedures to ensure the Uniform Grant Guidance and the Compliance Supplement requirements for controls over Reporting, Allowable Costs, and Cash Management are designed and performed. The month­ end checklist currently being used is a good start, and this could be enhanced by adding sections for the above items, and having specific individuals' initial and date on the checklist when the procedures are completed. A fiscal policy and procedure manual would also be a good tool. Action Taken: Manex will update fiscal Policy to include oversight on reporting to funders
Finding 402308 (2023-001)
Significant Deficiency 2023
Allowable Activities and Costs – Assistance Listing No. 93.224/93.527 Recommendation: CLA recommends that the Organization consider completing time and effort attestation forms electronically to ensure none get lost or misplaced and are returned timely. Explanation of disagreement with audit finding...
Allowable Activities and Costs – Assistance Listing No. 93.224/93.527 Recommendation: CLA recommends that the Organization consider completing time and effort attestation forms electronically to ensure none get lost or misplaced and are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Infinity Health’s current policy to support compliance with time and effort requirements is to obtain a statement from each employee with any time allocated for a grant, certifying the time spent on grant activities on a quarterly basis. Beginning 12/1/2023, Infinity Health has implemented a new electronic document management system which will improve our ability to track and monitor timely completion of time and effort statements each quarter. Name(s) of the contact person(s) responsible for corrective action: Kyle Ahlenstorf, CEO, and Michelle Leonard, CFO. Planned completion date for corrective action plan: June 30, 2024
Finding 2023 - 001: Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Material Weakness Corrective Action Plan: Training: Currently, we are having all HCV staff trained and refreshed on rent calculations through Nan McKay. Staff will also be...
Finding 2023 - 001: Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Material Weakness Corrective Action Plan: Training: Currently, we are having all HCV staff trained and refreshed on rent calculations through Nan McKay. Staff will also be trained in best practices for properly obtaining verification and following the verification hierarchy process. Also, we are hiring a Training and Development Specialist. Once filled, we will conduct monthly and quarterly training. We anticipate filling the position by July 2024. Quality Control: We conduct 100% quality control on all new hires', completed action files and 100% quality control on all contract files. Quality Control of 25% of all annuals and 25% of all interims completed monthly by all non­ provisional employees. Department Structure: The supervisors will quality-control any caseworkers with an error rate of 80% of their files. Once we fill all staff vacancies and complete the provisional period for all our new staff, we will audit up to 40% of all completed files. Anticipated Completion Date: The current staff is attending Nan McKay's rent calculations training on June 4-6, 2024. We anticipate completion of the plan by 12/31/2024. Person Responsible: Ms. Rhonda Jackson, Housing Program Manager II, and Ms. Malandria Watson, Housing Program Manager I, will review the Quality Control Report and error ratios monthly.
Policies and Procedures for Federal Awards Corrective action planned: Management will consult an advisory firm to assist with providing sample policies and procedures for tracking and usage of federal awards. Management will review and implement policies and procedures no later than 60 days to ensu...
Policies and Procedures for Federal Awards Corrective action planned: Management will consult an advisory firm to assist with providing sample policies and procedures for tracking and usage of federal awards. Management will review and implement policies and procedures no later than 60 days to ensure compliance with tracking and usage of federal awards. Anticipated completion date: June 30, 2024 Contact person responsible for corrective action: Angela St. John, CFO
As noted above, The Trust for Tomorrow continues to add compensating controls each year when possible. For example, a Director of Financial Operations was hired during the last half of the fiscal year under audit and this individual has taken over certain responsibilities, including but not limited ...
As noted above, The Trust for Tomorrow continues to add compensating controls each year when possible. For example, a Director of Financial Operations was hired during the last half of the fiscal year under audit and this individual has taken over certain responsibilities, including but not limited to general ledger coding, review and approval of invoices, processing timesheets, and handling expense reimbursement requests. Further, we will continue to review our processes to determine where duties can be segregated amongst existing staff. Additionally, the board will continue to provide close oversight of the Organization and evaluate that oversight on a consistent basis.
Corrective Action Plan For the Year Ended September 30, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Sara Potts, Executive Director Corrective Action: We concur. Management will rev...
Corrective Action Plan For the Year Ended September 30, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Sara Potts, Executive Director Corrective Action: We concur. Management will review the internal control procedures as they relate to eligiblity and will implement procedures to ensure all documents are obtained during intake. Proposed Completion Date: Immediately.
May 7, 2024 U.S. Department of Education American Academy McAllister Institute of Funeral Services, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2023. Auditors: CohnReznick 1301 Avenue of the Americas New York, NY 10019 Audit period: October 1...
May 7, 2024 U.S. Department of Education American Academy McAllister Institute of Funeral Services, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2023. Auditors: CohnReznick 1301 Avenue of the Americas New York, NY 10019 Audit period: October 1, 2022 to September 30, 2023 The findings from the fiscal year 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT SIGNIFICANT DEFICIENCY 2023-001 Federal Direct Loan Program Student Recommendation: We recommended in the prior year that the Institute review and revise its procedures to put controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to par-ticipating students. Action Plan: We agree with both the finding and the recommendation. In the Summer 2023 semester, a system was implemented to send out the required notifications regarding Federal Direct Loan Program proceeds that have been applied to a participating student's account. If the U.S. Department of Education has questions regarding this plan, please call Robert Graber at 732-547-9549.
Finding Reference Number: 2023-001 – Significant Deficiency – Lack of Documentation of Verification of Vendors Description of Finding: APA verified vendor was neither suspended nor debarred and staff confirmed as such in writing. However, they did not print and/or maintain a copy of the screenshot f...
Finding Reference Number: 2023-001 – Significant Deficiency – Lack of Documentation of Verification of Vendors Description of Finding: APA verified vendor was neither suspended nor debarred and staff confirmed as such in writing. However, they did not print and/or maintain a copy of the screenshot for files. This was inconsistent with APA written procedures. Statement of Concurrence (or Nonconcurrence): Management concurs that there was one instance wherein it did not print and maintain the verification screenshot for its files. Corrective Action: Management will review and update its procurement procedures to include a contract review checklist to be signed and dated by the preparer and approved by the contract signer (General Counsel, COO or CEO). Said checklist will include a specific reference to the date suspension and debarment were checked and will serve as primary documentary support which will be included in the vendor contract files. Contact Information: For further details or questions regarding this corrective action plan, please contact: Name: Steven Naugle
June 14th, 2024 Findings- Major Federal Award Programs Audit- Corrective Action Plan (CAP) Public Housing Capital Fund finding 2023-001 For the year ended September 30th, 2023, the audit conducted by Cherry Bekaert LLP found Significant Deficiency, Nonmaterial Noncompliance- Obligation and Expenditu...
June 14th, 2024 Findings- Major Federal Award Programs Audit- Corrective Action Plan (CAP) Public Housing Capital Fund finding 2023-001 For the year ended September 30th, 2023, the audit conducted by Cherry Bekaert LLP found Significant Deficiency, Nonmaterial Noncompliance- Obligation and Expenditure Verification for public housing capital fund grant. The recommendation to implement controls to ensure capital grants are fully obligated by contractual agreements and expended within the required deadlines will be put into procedure by management of the Housing Authority. Management understands the importance of obligating and expending capital fund grants and to remedy the above deficiency, the Housing Authority will take an approach that will implement controls within regulations. -The Charlestown Housing Authority will review 24 CFR 905.306 {a) and 24 CFR 905.306 (F), and other regulations required for compliance with capital funds. - The Charlestown Housing Authority will implement internal checks and balances when obligatlng and expending funds for grants to ensure timely contracts and expenditures. - The Housing Authority will obligate capital funds prior to the 24-month deadline and expend the funds within the 48-month deadline. Responsible Person: Leigh Bowyer Completion Date of CAP: 6/13/24
2023-001 Provider Relief Funding – Assistance Listing No. 93.498 Recommendation: We recommend that the Organization ensure there are proper procedures in place for future submissions and that a formal review occur by someone other than the preparer. Explanation of disagreement with audit finding: Th...
2023-001 Provider Relief Funding – Assistance Listing No. 93.498 Recommendation: We recommend that the Organization ensure there are proper procedures in place for future submissions and that a formal review occur by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Northern Regional Hospital will adopt a policy to review all expenditures recorded and all submissions of reporting prior to the submission being made. This review will be done by someone independent of completing the preparation and will be documented as such. Name(s) of the contact person(s) responsible for corrective action: Derek White, Director of Operational Finance Planned completion date for corrective action plan: 6/30/24 If the Department of Health and Human Services has questions regarding this plan, please call Derek White, Director of Operational Finance at 336-719-7283.
Finding 401662 (2023-001)
Significant Deficiency 2023
Corrective Action Plan The University will consistently follow established procedures used to perform Title IV refund calculations for students who withdraw after the 60 percent point that comply with Title 34 of the Code of Federal Regulations, Part 668.22. Anticipated Completion Date; June 2024 Co...
Corrective Action Plan The University will consistently follow established procedures used to perform Title IV refund calculations for students who withdraw after the 60 percent point that comply with Title 34 of the Code of Federal Regulations, Part 668.22. Anticipated Completion Date; June 2024 Contact Person(s): Alicia Bookout Associate Vice Chancellor, Financial Aid
Special Tests – Formula Income – Public and Indian Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority reviews their controls over submitting forms to HUD to ensure they contain accurate information. Explanation of disagreement with audit finding: There is no disagre...
Special Tests – Formula Income – Public and Indian Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority reviews their controls over submitting forms to HUD to ensure they contain accurate information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New CFO is preparing a Subsidy Calculation procedure so new staff will be aware of what is eligible and non-eligible transactions for preparing forms. Name(s) of the contact person(s) responsible for corrective action: Shannon Sterling and/or Carlton Brown
View Audit 309583 Questioned Costs: $1
Allowable Costs – Operating Fund – Public and Indian Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority establishes procedures to properly reconcile the revolving fund cash account to ensure that cash and interprogram accounts are properly reported at the program lev...
Allowable Costs – Operating Fund – Public and Indian Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority establishes procedures to properly reconcile the revolving fund cash account to ensure that cash and interprogram accounts are properly reported at the program level. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: There are procedures in place to settle interfunds if possible. Name(s) of the contact person(s) responsible for corrective action: J Daniels and Shannon Sterling
Reporting – PIC – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that the person assigned to submit the 50058s to PIC assures a quality control review is performed on the submissions to ensure timely and accurate reporting. Explanation of disagreement with au...
Reporting – PIC – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that the person assigned to submit the 50058s to PIC assures a quality control review is performed on the submissions to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Following CLA’s recommendation, SVP of Housing Choice will audit a random sample of 50058 submissions to PIC each month to ensure that all submissions are accurate in PIC. Additionally, the Agency is transitioning to Yardi software which should eliminate many of the submission issues caused by current enterprise software. Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023
Special Tests – Top of the Waiting List – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that the Authority reviews their standard procedures to ensure requests for informal reviews are granted and notified to the applicant within 30 days of the receipt of the ...
Special Tests – Top of the Waiting List – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that the Authority reviews their standard procedures to ensure requests for informal reviews are granted and notified to the applicant within 30 days of the receipt of the request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency hired a dedicated Hearing Officer following last year’s audit. Unfortunately, during the period in question, the Hearing Officer went on maternity leave and then subsequently left the position resulting in a delay in completing hearings and reviews. The Agency has since contracted with a 3rd party to conduct hearings and reviews in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023
Special Tests – Annual HQS and Quality Control Inspections – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that management review their controls for conducting HQS biennial and quality control re-inspections and ensure compliance standards are met. Explanatio...
Special Tests – Annual HQS and Quality Control Inspections – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that management review their controls for conducting HQS biennial and quality control re-inspections and ensure compliance standards are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previously, staff used a 90-day window to select Quality Control samples. Doing so caused some QC inspections to be completed past the regulatory time period. Going forward, staff are selecting the sample size from a 45-day window. This allows sufficient time to complete the QC inspection within the regulatory time period. Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023
In 2024 the manual component of the calculations has been eliminated and all calculations of billing units are now completed using an Excel spreadsheet.
In 2024 the manual component of the calculations has been eliminated and all calculations of billing units are now completed using an Excel spreadsheet.
View Audit 309574 Questioned Costs: $1
Finding 401511 (2023-001)
Significant Deficiency 2023
May 22, 2024 Vita Nova, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2023. Name and address of independent public accounting firm: Holyfield & Thomas, LLC, 125 Butler Street, West Palm Beach, FL 33407 Audit period: For the fiscal year ended Septembe...
May 22, 2024 Vita Nova, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2023. Name and address of independent public accounting firm: Holyfield & Thomas, LLC, 125 Butler Street, West Palm Beach, FL 33407 Audit period: For the fiscal year ended September 30, 2023. The findings from the September 30, 2023 schedule of findings and questions costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FEDERAL AWARD PROGRAM AUDITS U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD) 2023-001 Significant deficiency for the Continuum of Care Program, Youth Homeless Demonstration Program (YHDP) – Assistance Listing No. 14.267. Recommendation: We recommend that when the rent reasonableness worksheet reflects that the proposed rent is not reasonable, the lease contracts should not be approved, and negotiations should begin with the landlord to get the rent within the reasonable range. To ensure this step is taken, we recommend that the Program Director review, and initial each rent reasonableness worksheet before the lease is signed for the client tenant. Action Taken: In September 2023, Vita Nova reassigned the YHDP program to the oversight of a new Director of Housing. In late October 2023, the new Director identified the specified issue as part of a detailed file review and immediately took action to correct this error. New lease agreements were established with both tenants as of November 2, 2023, using rent reasonable rates. Vita Nova has since taken additional steps to ensure this and other similar errors do not reoccur as follows: • Housing Case Managers are not authorized to complete rent reasonableness worksheets. This procedure is completed directly by the Director of Housing. • If the requested rent is found to not be reasonable, the Director of Housing initiates negotiations with the landlord. • If rent reasonable rates are not able to be negotiated, the lease will not be signed. • The Director of Housing approves all lease contracts and related rental costs. • Peer file reviews are conducted by Housing Case Managers (HCM) on a monthly basis, and review sheets are submitted to the Director of Housing. The Director of Housing then completes a follow-up internal review and returns any comments to the respective HCM(s) with a correction date for any needed revisions within 7 days. If the U.S. Department of Housing and Urban Development (HUD) has any questions regarding this plan, please call Kelly Landrum, Chief Operating officer at (561) 517-0040. Respectfully, Kelly A. Landrum Chief Operating Officer
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