Corrective Action Plans

Finding 1156766 (2024-003)

Material Weakness 2024

Sacramento Housing and Revelopment Agency

CA

Questioned Costs HUD Housing Programs Special Tests & Provisions

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are...

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

View Audit 369097 Questioned Costs: $1

Finding 1156753 (2024-002)

Material Weakness 2024

Plumas-Sierra Rural Electric Cooperative

CA

Internal Control / Segregation of Duties Reporting Significant Deficiency

Management understands that the Cooperative must provide data for the proper periods when filing its quarterly reports. The Controller, Steve Malay, has implemented a review process to ensure that financial reports align with the periods specified in the grant agreements whenever possible. In instan...

Management understands that the Cooperative must provide data for the proper periods when filing its quarterly reports. The Controller, Steve Malay, has implemented a review process to ensure that financial reports align with the periods specified in the grant agreements whenever possible. In instances where complete information is not available within the required reporting window (due timing of information and required deadlines), management will provide the most reliable and available data at the time of reporting. This will be clearly documented to ensure transparency with granting agencies.

View Audit 369091

Finding 1156733 (2024-001)

Material Weakness 2024

Oakland Livingston Human Service Agency

MI

Allowable Costs / Cost Principles Period of Performance Subrecipient Monitoring § 200.308 § 200.403

The Agency agrees with the finding. We will provide training to program managers who are approving program expenditures to ensure proper allocation of costs to the appropriate grant cycles. We will also update our purchasing procedures to ensure that the proper allocation of costs is reviewed prior ...

The Agency agrees with the finding. We will provide training to program managers who are approving program expenditures to ensure proper allocation of costs to the appropriate grant cycles. We will also update our purchasing procedures to ensure that the proper allocation of costs is reviewed prior to supervisor's approval of the cost.

View Audit 369077

Finding 1156636 (2024-006)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

Special Tests & Provisions Eligibility HUD Housing Programs

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure all files are maintained and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action take...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure all files are maintained and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will take the necessary steps to ensure files are placed back in the file room and are available upon request with the required documentation placed in the file. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 7/31/2026

View Audit 368975

Finding 1156596 (2024-006)

Material Weakness 2024

Meeker County

MN

Procurement, Suspension & Debarment Significant Deficiency

SUSPENSION AND DEBARMENT Recommendation: The County should implement additional procedures to ensure suspension and debarment verification procedures are followed prior to entering a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding....

SUSPENSION AND DEBARMENT Recommendation: The County should implement additional procedures to ensure suspension and debarment verification procedures are followed prior to entering a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: County personnel will review Sam.Gov website for suspension and debarment verification prior to entering a covered transaction. Name of the contact person responsible for corrective action: Andrew Letson, County Administrator. Planned completion date for corrective action plan: December 31, 2025

View Audit 368940

Finding 1156593 (2024-005)

Material Weakness 2024

Meeker County

MN

Eligibility Significant Deficiency Internal Control / Segregation of Duties § 200.303

ELIGIBILITY Recommendation: The County should implement additional procedures to ensure case file reviews are being performed on a regular basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Supervisor will sa...

ELIGIBILITY Recommendation: The County should implement additional procedures to ensure case file reviews are being performed on a regular basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Supervisor will sample and perform a quality review on a quarterly basis to ensure case workers are accurately assessing eligibility. Review will be documented. Supervisor will review at least 1 casefile for each caseworker per quarter and randomly pull additional cases from new caseworkers. Name of the contact person responsible for corrective action: Charlene Dale, Human Services Supervisor Planned completion date for corrective action plan: December 31, 2025

View Audit 368940

Finding 1156590 (2024-004)

Material Weakness 2024

Meeker County

MN

Allowable Costs / Cost Principles Cash Management Significant Deficiency

ALLOWABLE COSTS Recommendation: The County should review the listing of employees working on certain programs on a periodic basis throughout the year and document the review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response t...

ALLOWABLE COSTS Recommendation: The County should review the listing of employees working on certain programs on a periodic basis throughout the year and document the review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will review procedures and implement changes as needed to ensure reports are formally reviewed, submitted timely, and proper documentation is retained. Name of the contact person responsible for corrective action: Charlene Dale, Human Services Supervisor Planned completion date for corrective action plan: December 31, 2025

View Audit 368940

Finding 1156571 (2024-005)

Material Weakness 2024

Housing Authority of the City of Omaha

NJ

HUD Housing Programs Significant Deficiency

U.S. Department of Housing and Urban Development 2024-005 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Annual HQS Inspections Recommendation: We recommend the Authority implement controls to ensure that all units are inspected annually. We recommend the Authority hire an outs...

U.S. Department of Housing and Urban Development 2024-005 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Annual HQS Inspections Recommendation: We recommend the Authority implement controls to ensure that all units are inspected annually. We recommend the Authority hire an outside firm to perform inspections if there is not capacity internally. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. The Authority has identified an error whereby our data system isn’t identifying every unit due for an annual inspection. The Authority is implementing a new procedure to confirm every household due for an annual recertification is also pulling for an annual inspection. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Ashley Hatheway, CFO at (402) 444-6900.

View Audit 368905

Finding 1156570 (2024-004)

Material Weakness 2024

Housing Authority of the City of Omaha

NJ

Questioned Costs HUD Housing Programs Significant Deficiency

U.S. Department of Housing and Urban Development 2024-004 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Rent Reasonableness Recommendation: We recommend the Authority implement controls to ensure reasonable rent requirements are met. Explanation of disagreement with audit find...

U.S. Department of Housing and Urban Development 2024-004 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Rent Reasonableness Recommendation: We recommend the Authority implement controls to ensure reasonable rent requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. Increased effort with quality control and staff training will be focused in this area to ensure the HUD-50058 and rent determinations match and are clear on the comparable units. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

View Audit 368905 Questioned Costs: $1

Finding 1156569 (2024-003)

Material Weakness 2024

Housing Authority of the City of Omaha

NJ

HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

U.S. Department of Housing and Urban Development 2024-003 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – PIC Submissions Recommendation: We recommend the Authority to designate an individual to ensure accurate HUD-50058 information is inputted into the PIC system timely. Explan...

U.S. Department of Housing and Urban Development 2024-003 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – PIC Submissions Recommendation: We recommend the Authority to designate an individual to ensure accurate HUD-50058 information is inputted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. HUD-50058s are transmitted monthly. Some transmissions have PIC errors while other files that are submitted late due to annual recertification completion. The Authority has plans in place to ensure quality control and resubmission of any errors and to improve timely annual completion and submission. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

View Audit 368905

Finding 1156553 (2024-005)

Material Weakness 2024

Andrew County Health Department

MO

Procurement, Suspension & Debarment Significant Deficiency

Views of Responsible Officials and Planned Corrective Action: To the extent possible, monitoring of federal compliance information by management and the board of trustees will continue at ACHD. When possible with limited staff, ACHD will verify vendors are not suspended or debarred prior to engaging...

Views of Responsible Officials and Planned Corrective Action: To the extent possible, monitoring of federal compliance information by management and the board of trustees will continue at ACHD. When possible with limited staff, ACHD will verify vendors are not suspended or debarred prior to engaging in contracts.

View Audit 368888

Finding 1156551 (2024-004)

Material Weakness 2024

Andrew County Health Department

MO

Cash Management Reporting Significant Deficiency

Views of Responsible Officials and Planned Corrective Action: To the extent possible, monitoring of federal compliance information by management and the board of trustees will continue at ACHD. When possible with limited staff, ACHD will conduct a documented review of reimbursement requests and perf...

Views of Responsible Officials and Planned Corrective Action: To the extent possible, monitoring of federal compliance information by management and the board of trustees will continue at ACHD. When possible with limited staff, ACHD will conduct a documented review of reimbursement requests and performance reports.

View Audit 368888

Finding 1156543 (2024-002)

Material Weakness 2024

Samaritas and Subsidiaries

MI

Questioned Costs Eligibility Matching / Level of Effort / Earmarking § 200.303

Contact Person(s): Bridgette Zappacosta Corrective Action Planned: Management concurs with the finding. The Organization will strengthen eligibility verification procedures to ensure that only participants meeting the specific award requirements are approved for benefits. This will include: revising...

Contact Person(s): Bridgette Zappacosta Corrective Action Planned: Management concurs with the finding. The Organization will strengthen eligibility verification procedures to ensure that only participants meeting the specific award requirements are approved for benefits. This will include: revising intake and eligibility documentation protocols to require verification and supervisory sign-off that the individual meets the award’s eligibility definition and providing targeted staff training on eligibility requirements under the Refugee Admissions Program. Quarterly internal reviews of eligibility determinations will be conducted, with exceptions reported to management for corrective action. Anticipated Completion Date: December 31, 2025

View Audit 368884 Questioned Costs: $1

Finding 1156539 (2024-001)

Material Weakness 2024

Samaritas and Subsidiaries

MI

Questioned Costs Allowable Costs / Cost Principles Period of Performance

Contact Person(s): Bridgette Zappacosta, CFO Corrective Action Planned: Management concurs with the finding. We acknowledge that expenditures were charged outside of the applicable award period due to timing of invoice receipt and data entry errors. The Organization has reviewed its internal control...

Contact Person(s): Bridgette Zappacosta, CFO Corrective Action Planned: Management concurs with the finding. We acknowledge that expenditures were charged outside of the applicable award period due to timing of invoice receipt and data entry errors. The Organization has reviewed its internal controls and will strengthen procedures to ensure compliance with federal requirements. Specifically, we are revising our grant expenditure procedures, implementing new software which includes additional review controls and is specific to grant reporting, and providing targeted staff training on period of performance compliance. We will also perform quarterly monitoring of federal award expenditures to verify compliance. Anticipated Completion Date: December 31, 2025

View Audit 368884 Questioned Costs: $1

Finding 1156516 (2024-002)

Material Weakness 2024

Kama'aina Care, Inc.

HI

Subrecipient Monitoring Reporting Significant Deficiency § 200.329

Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.

View Audit 368868

Finding 1156488 (2024-002)

Material Weakness 2024

Transform 1012 N. Main Street

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties

2. In response to Finding 2024-002: Reporting – significant deficiency in internal controls over compliance Economic Development Initiative, Community Project Funding and Miscellaneous grants, please note the following: Cause of Internal Control Issue: Transform 1012’s grant reporting procedures inc...

2. In response to Finding 2024-002: Reporting – significant deficiency in internal controls over compliance Economic Development Initiative, Community Project Funding and Miscellaneous grants, please note the following: Cause of Internal Control Issue: Transform 1012’s grant reporting procedures included a verbal approval of reports and therefore, management approval could not be confirmed or reperformed. The effect of this is that bi-annual reporting was not fully documented in accordance with internal control procedures over compliance. Actions To Rectify Internal Control Issue: Management’s Response: Carlos Gonzalez-Jaime, Executive Director, will ensure his written documentation of review and approval of all grant reports is kept on file by using electronic signature to indicate review and approval and storing signed copies of the documentation. • This will be completed by October 31, 2025, for 2025 reports through October 31, 2025. Going forward, signed documentation will be stored within seven days of the report being issued.

View Audit 368849

Finding 1156467 (2024-002)

Material Weakness 2024

City of River Falls

WI

Reporting Significant Deficiency

Finding 2024-002: Internal Control Environment Condition The Federal Financial Report was submitted by the original preparer without review before submission. Corrective Action Plan Corrective Action Planned: The Finance Director will review and approve submittals of the annual grant applications an...

Finding 2024-002: Internal Control Environment Condition The Federal Financial Report was submitted by the original preparer without review before submission. Corrective Action Plan Corrective Action Planned: The Finance Director will review and approve submittals of the annual grant applications and reports, including from third-parties in the event of any pass-through grants the City facilitates. Name(s) of Contact Person(s) Responsible for Corrective Action: Josh Solinger Anticipated Completion Date: Immediate and ongoing

View Audit 368802

Finding 1156466 (2024-001)

Material Weakness 2024

Council Towers Housing Development Fund Corporation

NY

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

We are planning to close the current policy. We are opening a separate policy for Council Towers II, Council Towers III and Council Towers IV that we covered by that policy.

View Audit 368800 Questioned Costs: $1

Finding 1156459 (2024-002)

Material Weakness 2024

Southwestern Christian College

TX

Questioned Costs Reporting Significant Deficiency § 200.328 § 200.329

Emergency Relief Fund (HEERF) Programs (significant deficiency) Condition (per audit): Non-compliance noted regarding untimely filing of quarterly and annual report. SwCC’s Explanation: The HEERF department and reporting systems were closed, and Grants personnel were unable to retrieve a copy of the...

Emergency Relief Fund (HEERF) Programs (significant deficiency) Condition (per audit): Non-compliance noted regarding untimely filing of quarterly and annual report. SwCC’s Explanation: The HEERF department and reporting systems were closed, and Grants personnel were unable to retrieve a copy of the required reports from the ESF Data Collection System by the suggested deadline of May 19, 2025. Corrective Actions (overseen by the President): 1. Grant Reporting Calendar o A compliance calendar with all DOE reporting deadlines was created in August 2025. o Internal deadlines are set two weeks before federal due dates. o Responsible Official: Director of Grants 2. Dual Review & Submission Tracking o All grant quarterly and annual reports must be reviewed and signed off by the Director of Grants, President, and Comptroller before submission. o Submission confirmations will be saved in the respective grants folder of the electronic filing system. o Responsible Officials: President, Director of Grants & Comptroller 3. Centralized Filing & Audit Readiness o Grant reports (quarterly, annual, and related correspondence) will be stored in the centralized electronic filing system for continuity and audit review. o Responsible Officials: Director of Grants & Business Office 4. Quarterly Compliance Checks o The President and Director of Grants will conduct quarterly compliance reviews to confirm all required reports are submitted timely. o Responsible Officials: President & Director of Grants 5. Time and Effort Reporting in Populi o Effective August 2025, time and effort reporting for all Title IV-funded student workers and grant-funded employees will be completed in Populi, capturing descriptions of duties and percentage of time worked, aligned with payroll and funding sources. o Responsible Officials: Director of Grants & Comptroller/Business Office Completion Date: Reporting calendar implemented August 2025; all future reports will be submitted timely under this protocol. Southwestern Christian College is committed to full compliance with federal regulations and the highest standards of financial accountability. The corrective actions outlined above address both Title IV and HEERF audit findings with immediate steps, ongoing monitoring, and strengthened internal controls. With the implementation of new reconciliation processes, expanded staffing in the Business Office, centralized electronic filing, enhanced verification and reporting protocols, and a structured compliance calendar, SwCC has established sustainable safeguards to prevent recurrence of deficiencies.

View Audit 368771 Questioned Costs: $1

Finding 1156454 (2024-002)

Material Weakness 2024

Connections to Success

MO

Cash Management Reporting Significant Deficiency § 200.303

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Significant Deficiency in Internal Control Over Compliance – Cash Management and Reporting Recommendation: The Organization should update and strengthen their policies to match UG and DOL guidelines, and create...

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Significant Deficiency in Internal Control Over Compliance – Cash Management and Reporting Recommendation: The Organization should update and strengthen their policies to match UG and DOL guidelines, and create an internal control for drawdown request and report approval and review. The Organization should ensure these policies are followed for all drawdowns, reports and that documentation related to these policies are maintained. Views of Responsible Officials: Management agrees with the finding and recommendation. To address this, the Organization will update its Cash Management Policy to implement a documented, two-level review and approval process for all drawdown requests and reports, requiring both preparer and approver sign-off and develop a standard checklist to ensure each drawdown is supported by allowable, documented expenditures prior to submission. The Grants Manager will conduct quarterly internal reviews to ensure this process is being followed. Contact information for this finding: If the U.S. Department of Labor has questions regarding this schedule, please call Brandi Janke at (816) 520-4404. Completion Date: September 2025

View Audit 368768

Finding 1156450 (2024-002)

Material Weakness 2024

Lincoln Senior Housing, INC

CT

Questioned Costs HUD Housing Programs Cash Management

Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request ...

Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request a waiver if allowed. Views of Responsible Officials and Planned Corrective Actions – Management will calculate an estimated surplus cash calculation amount and deposit them into the residual receipts account within the required time frame. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – Once the funds are received.

View Audit 368750 Questioned Costs: $1

Finding 1156449 (2024-001)

Material Weakness 2024

Lincoln Senior Housing, INC

CT

Questioned Costs HUD Housing Programs Significant Deficiency

Recommendation – The reserve account was underfunded as of 12/31/24. We recommend that management discuss this issue with HUD and request approval retroactively to fund the reserve account at a lower amount until the funds due to the Project are paid in full by HUD. Views of Responsible Officials an...

Recommendation – The reserve account was underfunded as of 12/31/24. We recommend that management discuss this issue with HUD and request approval retroactively to fund the reserve account at a lower amount until the funds due to the Project are paid in full by HUD. Views of Responsible Officials and Planned Corrective Actions – Management will reach out to HUD and request approval retroactively to fund the reserve account at a lower amount. Once the approval has been granted and the remainder of the funds have been received, management will pay the reserve account in full. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – unknown

View Audit 368750 Questioned Costs: $1

Finding 1156372 (2024-002)

Material Weakness 2024

Trempealeau County

WI

Reporting Significant Deficiency

Trempealeau County, being a small county, has limited resources in personnel to accomplish a multi-verification in the reporting process. We will use additional current employees in house to do the verification to make sure the reporting is accurate before submitting. Responsible Person: Mary Martin...

Trempealeau County, being a small county, has limited resources in personnel to accomplish a multi-verification in the reporting process. We will use additional current employees in house to do the verification to make sure the reporting is accurate before submitting. Responsible Person: Mary Martin, County Clerk Anticipated Completion Date: We will attempt to begin the multiple verification process for the 2025 calendar year

View Audit 368678

Finding 1156370 (2024-001)

Material Weakness 2024

Ucc Xxiii, Inc. D/b/a Boardtown Village

OH

HUD Housing Programs Procurement, Suspension & Debarment Reporting

The security deposit was refunded to the tenant on the 78th day subsequent to their move-out. Management has taken measures to improve internal controls over compliance related to tenant security deposit refunds.

View Audit 368672

Finding 1156346 (2024-004)

Material Weakness 2024

City of Seattle

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) M...

The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) Manager to provide consistent leadership and supervision. The contract specialist receives structured management oversight and ongoing training to strengthen capacity for accurate budget monitoring. In July 2025, the FGMU updated its ESG policies and procedures to incorporate improved controls for earmarking. In addition, the Department has instituted regular training sessions for all staff responsible for federal grant management to reinforce compliance with earmarking and other federal requirements. These corrective actions are designed to strengthen internal controls, provide clearer oversight, and ensure that future expenditures remain within established budget and earmarking limits.

View Audit 368642

Corrective Action Plans

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