Corrective Action Plans

SUSPENSION AND DEBAREMENT – COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: It is recommended the County ensure all departments follow their county-wide policies regarding suspension and debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will ensure all departments follow federal requirements for purchases to ensure vendors are not suspended or debarred. Name of the contact person responsible for corrective action plan: Nancy Malecha, Finance Director Planned completion date for corrective action plan: December 31, 2025

Finding: 2024-001 Condition: In accordance with Section 330(k)(3)(G) of the Public Health Services Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which the Organization’s fee schedule is discounted based on a patient’s ability to pay. In accordance with their policy, the Organization will monitor the accuracy of the discounts provided to patients by a monthly random audit of 15 visits where a sliding fee discount adjustment was received. Individual(s) Responsible for Corrective Action: Kimberly Garca, Director of Patient Accounts Planned Corrective Action: 1. Complete Q1 2025: Complete internal audit/monitoring for January, February and March. 2. Establish a Formal Monitoring Calendar: Develop and maintain a documented monitoring calendar that includes monthly deadlines and responsible personnel for completing the required audits. This calendar should be reviewed and approved by supervisory staff and integrated into regular compliance reporting. 3. Assign Backup Personnel: Designate and train at least one backup staff member to perform sliding fee discount audits during periods of high workload or staff absences. This ensures continuity and timely completion of required monitoring activities. 3. Monthly Oversight Review: Require supervisory review and sign-off on the completion of each monthly audit to verify that the monitoring activities were conducted and documented appropriately. Anticipated Completion Date: • Corrective Action #1 has been completed as of 4/28/2025. • Corrective Action #2 has been completed as of 5/5/2025. • Corrective Action #3 will be completed by August 2025.

2024-004 Housing Choice Voucher Waiting List: Special Tests and Provisions Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Statement of Condition: Out of a total population of approximately 258 applicants, 25 applicants were selected for testing, and the following errors were discovered. • 1 applicant file had the following error: o The applicant was incorrectly awarded local preference points. Removing these points would drop their waiting list rank from #54 to #258. However, this issue would have likely been identified and corrected during the routine verification of preference points, which occurs when an applicant is pulled from the waiting list. • 1 applicant file had the following error: o The applicant was incorrectly awarded working preference points. Removing these points would drop their waiting list rank from #64 to #245. However, this issue would have likely been identified and corrected during the routine verification of preference points, which occurs when an applicant is pulled from the waiting list. • 1 applicant file had the following error: o The applicant selected the local preference point, but was not awarded the local preference point. Correcting this issue would change the applicant’s ranking on the waiting list from #114 to #6. Nonetheless, it’s likely that the applicant would have been pulled from the waiting list at the correct time regardless of whether the applicant is ranked #114 or #6, since the Authority selects a large pool of applicants. • 1 tenant file had the following error: o The applicant selected the victim of domestic violence preference point, but was not awarded the preference point. Correcting this issue would change the applicant’s ranking on the waiting list from #124 to #2. Nonetheless, it’s likely that the applicant would have been pulled from the waiting list at the correct time regardless of whether the applicant is ranked #124 or #2, since the Authority selects a large pool of applicants. • 1 tenant file had the following error: o The applicant selected the local preference point, but was not awarded the local preference point. Correcting this issue would change the applicant’s ranking on the waiting list from #174 to #10. Nonetheless, it’s likely that the applicant would have been pulled from the waiting list at the correct time regardless of whether the applicant is ranked #174 or #10, since the Authority selects a large pool of applicants. Recommendation: The Authority should provide ongoing staff training on accurate data entry and documentation requirements for preference points assigned to applicants on the waiting list. In addition, the Authority should implement a quality control review process to ensure preference points are appropriately assigned. This could involve a second staff member reviewing a sample of applicant entries for accuracy of preference point awarded. Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants. The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being sent to the Compliance Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the Counselor handling specialty vouchers, will attend Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam during the next 24 months, as budget permits. Effective Date: June 19, 2025 Contact Information Gwendolyn B. Dawson, CEO Ocala Housing Authority 1629 NW 4th Street Ocala, Florida 34475 (352) 369-2636

2024-003 Housing Choice Voucher Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters This is a repeat finding of 2023-002 from September 30, 2023 (Originally reported as Material non-compliance and Material Weakness in Internal Control over Compliance under finding 2019-001 from September 30, 2019) Statement of Condition: Out of a total tenant population of approximately 1,118 vouchers, 25 files were selected for testing, and the following errors were discovered. • 2 tenant files had the following error: o The HAP contract in the tenants’ file was not signed by a representative of Ocala Housing Authority. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will decrease the Housing Assistance Payment by $4. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $23. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $7. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates for a 1-bedroom unit. The 2024 utility allowance rates for a 2-bedroom unit should have been used. Correcting this error will increase the Housing Assistance Payment by $20. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants. The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being sent to the Compliance Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the Counselor handling specialty vouchers, will attend Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam during the next 24 months, as budget permits.

2024-002 Public Housing Tenant Files: Eligibility Program: U.S. Department of HUD: Public and Indian Housing Program (ALN #14.850) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Statement of Condition: We tested 19 out of approximately 181 tenant files and discovered the following errors: • 1 tenant file had the following error: o A dependent of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the dependent’s birth certificate, the dependent is a U.S. citizen. • 1 tenant file had the following error: o The tenant’s childcare income was calculated and reported incorrectly on the 50058 form in the amount of $2,472. Correcting the tenant’s childcare income to $2,237 would decrease the tenant’s rent by $6. • 1 tenant file had the following error: o Support for the tenant’s wage income could not be located. It’s unknown as to whether the tenant’s wage income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly. • 1 tenant file had the following error: o The tenant’s social security income was carried forward from the prior year in the amount of $11,172. Correcting the tenant’s social security income to $12,144 for the annual recertification period tested, would increase the tenant’s rent by $25. • 1 tenant file had the following error: o The tenant’s social security income was carried forward from the prior year in the amount of $12,456. Correcting the tenant’s social security income to $13,548 for the annual recertification period tested, would increase the tenant’s rent by $27. • 1 tenant file had the following error: o The tenant’s other source income of $720 was carried forward from the prior year. The tenant’s income was not updated for the annual recertification and it’s unknown as to whether the tenant’s other source income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and a PH Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. Management will monitor and review counselor’s strength and weaknesses and determine if additional training and/or monitoring is needed.

The instances identified in this finding represent individuals who, in several cases, were processed in the same batches ( e.g., COD date 9/28/23, disbursement date on ledger 10/3/23, and COD date 11/3/23, disbursement date 11/8/23). CMN recognizes the importance of disbursing funds to student accounts on the date that funds are stated to be disbursed through COD. While there have been instances of funds not being available in COD in a timely manner, the financial aid coordinator and bursar will work together to ensure these disbursements are completed on the same date in order to remain compliant with stated CMN policy.

The College has identified that the dates of Return of Title IV Calculations and amounts (in one case) were out of compliance. The return calculations for all three students identified through this audit have been completed and corrected to reflect the correct return amounts, if appropriate. Student 1: After changing from an attendance-taking institution to a non-attendance taking institution, this student was identified during the audit as a student who may not have completed the term due to all F/NP grades. Calculation was completed and a return was made based on the midpoint date of the spring term. Student 2: After changing from an attendance-taking institution to a non-attendance taking institution, this student was identified during the audit as a student who may not have completed the term due to all F /NP grades. Calculation was completed and a return was made based on the midpoint date of the spring term. Student 3: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enrollment status (as noted in fmding 2024-001) and subsequent R2T4 calculation was delayed. Calculation was completed and a return was made based on the date indicated in the official withdrawal documents. Due to delayed calculations on these three students, CMN will continue to work with fmancial aid staff and the registrar's office to streamline communication on withdrawals and students who complete the term with all F/NP grades, as indicated in CMN policy. CMN has already worked with Anthology (student information system)'to provide electronic triggers to the fmancial aid office when a student status changes from active to drop/withdrawal. Additionally, Enrollment Management notifies all faculty by email at the beginning of the term and again prior to fmal grades being submitted that electronic notification must be sent by the faculty to financial aid in order to alert the fmancial aid office of the date oflast academic engagement for students who earn an For NP grade. For the current audit period, the Director of Enrollment Management and the Financial Aid Coordinator work together to review a final grade report for all students and identify those who need R2T4 calculations based on that review. Both the director and coordinator sign the working documents to indicate that it has been reviewed by both parties. We will continue with this process and will refme as necessary, but we anticipate that this will resolve the issue of calculations not having been performed on students with all F /NP grades at the end of the term.

The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (102 days and 69 days). The statuses of both students are correct with NSLDS. Student 1: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enollment status and subsequent R2T4 calculation (as noted in finding 2024-002) was delayed. Student 2: Student graduated, and status was updated with NSLDS at 69 days. Due to delayed communication and delayed reporting to NSLDS, CMN will revise institutional policy to clearly define the process and timeline for enrollment status changes. Financial aid staff will seek additional training in enrollment reporting through FSA and/or NSFAA. To further monitor compliance, CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. This electronic, automatic process will provide an additional layer of notification to the financial aid office when a student status change requires further attention.

Finding Number: 2024-001 Planned Corrective Action: City of Norton will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: June 2025 Responsible Contact Person: Pamela Keener, Finance Director

Views of the Responsible Officials and Planned Corrective Actions The Yuma County Water Users’ Association acknowledges the findings related to the nonperformance of required quarterly financial reporting under the Infrastructure Investment and Jobs Act (IIJA) loan agreements. The primary cause of this issue was the absence of necessary data—specifically, detailed actual expense information—which was not provided by the Imperial Irrigation District (IID). Without this information, the Association was unable to complete and submit the quarterly reports as required under the terms of the agreement. The Association is fully committed to resolving this issue and ensuring ongoing compliance with all provisions of the loan agreements. We are actively engaging with the relevant parties to obtain the required data and implement measures to prevent future delays in financial reporting. Corrective Actions: To address this issue, the Association will collaborate closely with both the Bureau of Reclamation and the Imperial Irrigation District (IID) to ensure timely receipt of quarterly actual expense data. Specifically: • At the end of each quarter, the Association will issue a formal request to IID for detailed expense data. • Follow-up reminders will be sent as necessary to facilitate timely submission. • This coordination will support the Association’s ability to meet quarterly financial reporting deadlines as required by the IIJA loan agreements. Timeline for Implementation: The corrective actions outlined above will be implemented immediately. Full compliance with quarterly reporting requirements is expected by the end of the second quarter.

Finding 2024-001: Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds and the Food Cluster Program. The Problem: CEO timesheets were not reviewed or approved by our Board of Directors in 2024 so proper oversight was not being done. Corrective Action: The procedure we had in place was that our Board Chairperson would review and approve our CEO timesheet entries each payroll period. This procedure was followed in prior years. In January 2024 the Chairperson changed to a new Chairperson and this person did not receive proper training on how to approve the CEO timesheet. When the auditors brought our attention to this situation in March of 2025, we immediately contacted the current and previous Board Chairs, HR Director, and Interim CEO. They worked together to train the present Board Chairperson on how to access the CEO timesheet entries, review them and approve them in a timely manner. This process is being used every pay period and our reports show that all timesheets are approved. We also printed out all timesheets going back to January and had the Board Chair review and sign those copies. Going forward we will be sure that proper training is done when there is a change in either the Board Chair or the CEO/Ed position.

Finding 2024-006 Personnel Responsible for Corrective Action: Director of Sponsored Programs- Eva Kain, Director of Title III – Dr. Neidra Butler and Grant Accountant – Charme Benson Anticipated Completion Date: June 30, 2025 Corrective Action Plan: Payroll charges to federal programs must match certified time and effort documentation. The Director of Sponsored Programs, the Director of Title III, and the Grant Accountant will jointly review allocations before payrolls are processed. Monthly reports will be generated for review by the Grant Accountant, and discrepancies must be corrected within 30 days. Management will implement a formal review and approval process to ensure that all allowable costs are verified for compliance with applicable regulations and approved by designated personnel prior to reimbursement or payment.

Finding Number 2024-001 Contact Person(s): Dionne Gordon dgordon@pnri.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Although the findings consisted primarily of a small number of late payments that were either 1 day late or late as a result of a poorly timed holiday, we fully acknowledge the accuracy of the finding and have added an additional control to account for the impact of weekends and holidays on our AP payment runs. Corrective action planned: Internal control established in AP department to keep track of sub recipients’ request reimbursement to ensure payments are disbursed within 30 calendar days after receipt of request. Anticipated completion date: March 31st 2025

Management will work to implement controls that will ensure subrecipient monitoring requirements are met.

Views of Responsible Officials and Planned Corrective Action: Global Communities experienced staff turnover in the positions responsible for FFATA reporting. Management will ensure those staff now responsible for maintaining compliance with FFATA reporting requirements have received adequate training and that supporting documentation of the review and approval of FFATA reports prior to submission are retained in our files.

Views of Responsible Officials and Planned Corrective Action: Global Communities policies and procedures did detect these instances of fraud, management of Global Communities took appropriate action ensuring that no unallowable costs were charged to Federal funds. Global Communities will continue their due diligence with respect to any items that are considered fraudulent in nature. Any high-risk areas are carefully monitored, additional training and/or resources are provided to ensure that internal controls are functioning as designed to prevent occurrences of misappropriation of assets and procurement fraud.

This is a repeat finding, so the Authority was already aware of the deficiency. There were no findings in the sample selected specifically for the HQS enforcement. These deficiencies were inspected prior to the change in process for MCHA. Since September of 2023, the Authority has revamped its HQS processes significantly. Responsibility for scheduling and tracking of inspections has been taken out of the hands of the individual inspectors and a single administrative employee has been dedicated to the job of tracking and scheduling inspections and follow-up inspections in order to ensure everything is properly documented and follow up is being done within the required time period.

2024-007 – Eligibility Housing Opportunities for Persons with Aids – Assistance Listing 14.241 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Explanation of disagreement with audit finding: There is no disagreement with the audit finding Action taken in response to finding: All current PBCHA staff responsible for eligibility determinations have received HCV rent calculation training through Nan McKay as of March 21, 2025. The PBCHA will continue to conduct training for program staff on eligibility documentation requirements and program rules to reinforce compliance standards. Through the implementation of intakes, interims and annual recertifications utilizing Yardi’s online workflows, the PBCHA expects to see increased improvement through automated application and documentation processes. The PBCHA will utilize available dashboards, internal audits and formal monitoring protocols to ensure continued compliance and to minimize the risk of recurring deficiencies. The PBCHA will continue to assess current staffing levels and evaluate the feasibility of hiring outside consultants or increasing staffing to support consistent and compliant eligibility determinations while being cognizant of current funding uncertainties. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

2024-06 – Eligibility Public Housing – Assistance Listing 14.850 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All current PBCHA staff responsible for eligibility determinations have received HCV rent calculation training through Nan McKay as of March 21, 2025. The PBCHA will continue to conduct training for program staff on eligibility documentation requirements and program rules to reinforce compliance standards. Through the implementation of intakes, interims and annual recertifications utilizing Yardi’s online workflows, the PBCHA expects to see increased improvement through automated application and documentation processes. The PBCHA will utilize available dashboards, internal audits and formal monitoring protocols to ensure continued compliance and to minimize the risk of recurring deficiencies. The PBCHA will continue to assess current staffing levels and evaluate the feasibility of hiring outside consultants or increasing staffing to support consistent and compliant eligibility determinations while being cognizant of current funding uncertainties. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

2024-005 – PIC Reporting Housing Voucher Cluster – Assistance Listing 14.781 and 14.879 Recommendation: We recommend that the Authority designate an individual to ensure the HUD-50058s are uploaded into the PIC system accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Beginning in March 2023, the PBCHA implemented that completion of all reexaminations within its Yardi resident portal. Reexaminations within Yardi provide online workflows that maximize efficiency, streamline compliance, reduce errors, and increase reporting accuracy. As such, the PBCHA has seen improvement in this area. PIC submissions are completed weekly to ensure compliance with eVMS and encourage timely correction of fatal errors. The PBCHA will utilize available dashboards and reports to improve monitoring and oversight to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

2024-004 – Selection from the Waiting List Housing Voucher Cluster – Assistance Listing 14.871 and 14.879 Recommendation: We recommend management that designates an induvial to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the wait list timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Beginning in March 2023, the PBCHA implemented the completion of all waiting lists generation/selection and intakes for eligibility within its Yardi resident portal. Intakes within Yardi automates applications, increases efficiency and ensures compliance with program requirements. Utilizing this technology, the PBCHA has seen improvement in this longstanding finding. The PBCHA will utilize available dashboards and reports to improve monitoring and oversight to ensure compliance and that correspondence with potential tenants is properly documented and tracked. Additionally, PBCHA will implement procedures to regularly monitor its waitlist tracking software to confirm that applicants are removed from the wait list in a timely and compliant manner. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

2024-003 – Rent Reasonableness Housing Voucher Cluster – Assistance Listing 14.871 and 14.879 Recommendation: We recommend management that designates an individual to review tenant filles to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the authority to hire outside consultants to assist with reasonable rent determination or increase staffing in this area. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PBCHA will continue to instruct staff members to review tenant files to ensure rent reasonableness determinations have been completed accurately and in a timely manner, in accordance with HUD requirements. With this instruction, the PBCHA has seen vast improvement in this area. The PBCHA will continue to assess current staffing levels and evaluate the feasibility of hiring outside consultants or increasing staffing to support consistent and compliant rent reasonableness determinations while being cognizant of current funding uncertainties. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: August 30, 2026

2024-002 – Annual HQS Inspection Housing Voucher Cluster – Assistance Listing 14.871 and 14.879 Recommendation: We recommend that management implement a centralized tracking system to monitor inspection due dates and follow-up timelines, ensuring all inspections are completed within HUD- mandated timeframes. Additionally, we recommend that PBCHA evaluate current staffing levels and consider hiring additional inspectors or contracting with third-party providers to meet inspection demands. Ongoing training should also be provided to staff on Housing Quality Standards (HQS) protocols and compliance expectations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA has seen vast improvement in this area. The PBCHA will continue to monitor its third-party inspection vendor to ensure continued adherence for the provision of inspection reports. The PBCHA will utilize centralized tracking systems within Yardi and other systems to improve oversight of inspection due dates and follow-up timelines, ensuring timely completion of all inspections in accordance with HUD requirements. The PBCHA will assess current staffing levels and evaluate the feasibility of hiring internal inspectors or contracting with additional third-party inspection services to meet demand while being cognizant of current funding uncertainties. Additionally, training will be provided to staff to reinforce Housing Quality Standards (HQS) protocols and compliance expectations. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: August 30, 2026

CORRECTIVE ACTION PLAN Name of the Project: Beaumont Senior Citizens Housing, Inc. FHA/CONTACT NO. 114-11227 Audit Firm: M Group, LLP Audit Period: The year ended June 30, 2024 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING #2024-001: Section 8 Housing Assistance Payments Program, Assistance Listing: 14.195 and Mortgage Insurance Section 223(f) Insured Loan, Assistance Listing: 14.155 CORRECTIVE ACTION TO BE COMPLETED: The Corporation completed and submitted the financials for audit for the years ended June 30, 2024 and 2023. The financial data was submitted into the FASSUB and FAC system. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Stewart Grounds, Chief Financial Officer.

CORRECTIVE ACTION PLAN Name and Number of the Project: INDEPENDENT LIVING PLACE, INC. No. 115-EH115 Audit Firm: M Group, LLP Audit Period: The year ended September 30, 2024 Compliance Review: A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING #2024-01: Section 202 Supportive Housing for the Disabled, Assistance Listing 14.157 and Section 8 Housing Assistance Payments Program, Assistance Listing 14.195 CORRECTIVE ACTION COMPLETED: CLEARED. The Corporation submitted the audited financials for the year ended September 30, 2023 on September 25, 2024. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Stewart Grounds, Chief Financial Officer of Arnold-Grounds Apartment Management & Affordable Housing Specialists, LLC.