Corrective Action Plans

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Views of Responsible Officials and Planned Corrective Actions: LHCA's methodology for qualifying laboratory and affiliated organization expenses as industry in-kind contribution was developed in direct consultation with FAS program officials in June 2023. As documented in LHCA's written summary of t...
Views of Responsible Officials and Planned Corrective Actions: LHCA's methodology for qualifying laboratory and affiliated organization expenses as industry in-kind contribution was developed in direct consultation with FAS program officials in June 2023. As documented in LHCA's written summary of that meeting, transmitted to senior FAS program and operations officials including the FMD program officer and acknowledged without objection, FAS validated the eligibility of research, marketing, policy, and technical expenses funded through industry funds, focused on target markets, and connected to UES activities. LHCA was acting on direct FAS guidance, not making unsupported determinations, and that documentation is available for the auditor's review. The revenue figures that appeared in LHCA's contribution documentation served as an allocation methodology, a proportional basis for determining what share of multi-purpose expenses relates to export promotion, not as the contribution itself. The actual contribution claimed consisted of underlying expenses allocated using that methodology. LHCA acknowledges that this methodology was not clearly labeled in the documentation provided to auditors, and will revise its documentation format to clearly distinguish the allocation calculation from the contribution amount claimed, ensuring the two are not conflated in future reviews. LHCA will formalize its contribution tracking procedures with a written policy document that defines eligible activities consistent with FAS guidance, specifies the allocation methodology and its basis, and requires that all claimed contribution be supported by verifiable expense documentation consistent with the hierarchy established in FMD §1484.33(f) and the cost principles in 2 CFR Part 200 Subpart E. A documented review and approval process will be implemented to ensure contribution amounts are accurate, allowable, and properly supported prior to submission.
Views of Responsible Officials and Planned Corrective Actions: LHCA acknowledges that the 2023 Uniform Guidance audit was submitted after the nine-month deadline required under 2 CFR §200.512. We take our compliance obligations seriously and are committed to timely submission going forward. LHCA ack...
Views of Responsible Officials and Planned Corrective Actions: LHCA acknowledges that the 2023 Uniform Guidance audit was submitted after the nine-month deadline required under 2 CFR §200.512. We take our compliance obligations seriously and are committed to timely submission going forward. LHCA acknowledges that, regardless of contributing factors, the responsibility for timely submission rests with the organization under 2 CFR 200.512. To ensure timely completion in future years, LHCA has implemented the following corrective actions: A dedicated audit liaison has been designated to coordinate all auditor requests and ensure document delivery within 72 hours of any request.Moving forward, LHCA will formally engage its audit firm no later than February 1st of each subsequent audit year, allowing sufficient time for fieldwork to be completed well in advance of the September 30th submission deadline. At engagement initiation, LHCA and its audit firm will establish a shared audit timeline with agreed milestone dates for fieldwork completion, draft report delivery, management response, and final FAC submission, with September 15th as the internal target submission date to provide a two-week buffer before the regulatory deadline. Financial records and grant documentation are now organized in a standardized Google Drive structure that allows immediate retrieval of any document requested during the audit process, reducing response time, and eliminating documentation delays as a source of audit timeline risk. LHCA is confident these measures will prevent recurrence and ensure timely submission of all future Uniform Guidance audits.
Management of the Organization will restructure all classes in the functional classing system, as well as utilize the project function, and consistently apply expenditures such that system reports accurately reflect income and expenditures by program / grant.
Management of the Organization will restructure all classes in the functional classing system, as well as utilize the project function, and consistently apply expenditures such that system reports accurately reflect income and expenditures by program / grant.
Special Tests and Provisions- Gramm-Leach-Bliley Act-Student Information System The College agrees with the finding and acknowledges the need to strengthen compliance with GLBA Safeguards Rule requirements related to student information security. Although the College already maintain Information Tec...
Special Tests and Provisions- Gramm-Leach-Bliley Act-Student Information System The College agrees with the finding and acknowledges the need to strengthen compliance with GLBA Safeguards Rule requirements related to student information security. Although the College already maintain Information Technology policies addressing many of the required safeguards, a formalized written Information Security Program specifically referencing GLBA requirements had not been fully established during the audit period. To address this finding, the College is developing a formalizing a comprehensive written ISP under the College Information Technology policies and procedures, with applicable student information confidentiality provisions also incorporated into the FAO policies and procedures. The College continues to provide training and guidance to staff regarding student information security and data protection to support ongoing compliance with federal requirements.
Special Tests and Provisions – Disbursements to or on Behalf of Students The College agrees with the finding and acknowledges that, during the audit period, certain Title IV disbursement notification, credit balance disbursement, and ISIR review procedures were not consistently completed in accordan...
Special Tests and Provisions – Disbursements to or on Behalf of Students The College agrees with the finding and acknowledges that, during the audit period, certain Title IV disbursement notification, credit balance disbursement, and ISIR review procedures were not consistently completed in accordance with federal requirements. To address this issue, the College reviewed and updated its FAO policies and procedures related to award notifications, cash management, disbursement processing, and verification procedures. The College also implemented JFA system to improve the tracking and monitoring of student awards, disbursements, verification activities, and credit balance timelines. In addition, the implementation of FAFSA priority deadline prior to each semester provides additional time for staff to review files, complete packaging, finalize verification requirements, and issue timely award notifications before processing begins. The College also amended its internal verification policy to align with the US DOE’s verification requirements by verifying only students selected by US DOE as indication on the student’s ISIR. The College will continue monitoring these corrective actions to support ongoing compliance with Title IV requirements.
Cash Management The College agrees with the finding. During 2024 and continuing into FY2025-2026, the College strengthened its cash management procedures for Pell Grant drawdowns under HCM1 payment method. To address this issue, the College implemented a drawdown memorandum process, whereby supporti...
Cash Management The College agrees with the finding. During 2024 and continuing into FY2025-2026, the College strengthened its cash management procedures for Pell Grant drawdowns under HCM1 payment method. To address this issue, the College implemented a drawdown memorandum process, whereby supporting documentation and justification for the requested amount are reviewed and approved before funds are drawn down.
Reporting The College acknowledges the finding and recognizes the need to strengthen oversight of reporting requirements. To prevent recurrence, the College will enhance its monitoring processes by developing formal reporting procedures and using the Asana Project Management system to schedule, moni...
Reporting The College acknowledges the finding and recognizes the need to strengthen oversight of reporting requirements. To prevent recurrence, the College will enhance its monitoring processes by developing formal reporting procedures and using the Asana Project Management system to schedule, monitor, and provide reminders for all federal and grant- related reporting deadlines and submissions.
Cash Management The College acknowledges the finding and will enhance its cash management practices by developing formal procedures outlining responsibilities, authorization requirements, and timelines related to federal drawdown and disbursements. In addition, the College will implement routine rec...
Cash Management The College acknowledges the finding and will enhance its cash management practices by developing formal procedures outlining responsibilities, authorization requirements, and timelines related to federal drawdown and disbursements. In addition, the College will implement routine reconciliations of drawdown activity against recorded expenditures on a monthly or quarterly basis to improve monitoring and ensure compliance with federal requirements.
Period of Performance College of the Marshall Islands acknowledges that this finding, reported in 2022, was repeated in 2023. The college confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit...
Period of Performance College of the Marshall Islands acknowledges that this finding, reported in 2022, was repeated in 2023. The college confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit fieldwork. The College has since upgraded and institutionalized a cloud- based filing system and strengthened internal controls to ensure all costs are properly aligned with the funding periods stipulated in the grant awards. In addition, the College has been continuously working to improve coordination between the Business Office, Human Resources, and program personnel to ensure payroll periods and expenditure dates are properly reviewed and aligned with grant award periods.
Equipment and Real Property Management College of the Marshall Islands agrees that capital asset records and reconciliation procedures were not fully maintained in accordance with federal equipment and real property management requirements. The deficiencies were primarily due to reliance on manual r...
Equipment and Real Property Management College of the Marshall Islands agrees that capital asset records and reconciliation procedures were not fully maintained in accordance with federal equipment and real property management requirements. The deficiencies were primarily due to reliance on manual recordkeeping processes, incomplete asset documentation, and delays in updating and reconciling the fixed asset records with the general ledger. To address this finding, the College is actively working to automate and strengthen its fixed asset management process through implementation of the MIP Fixed Asset Module.
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll and non-payroll expenditures charged to federal programs were not adequately supported with sufficient documentation to clearly demonstrate allow...
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll and non-payroll expenditures charged to federal programs were not adequately supported with sufficient documentation to clearly demonstrate allowability, proper allocation, and alignment with objectives. The deficiencies resulted from weaknesses in internal control procedures, incomplete supporting documentation, and prior filing and record retention practices. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, accessible, and properly organized documentation for all grant-funded positions and expenditures. Internal controls have been strengthened to require signed employment and overload contracts, proper funding source verification, and supervisory review before any grant-related payroll costs are charged. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain compliance and oversight. Staff will continue to be trained twice a year on federal allowability and cost principles to prevent recurrence of similar issues in future audits.
2023-005 Activities Allowed and Allowable Costs Material Weakness Corrective Action: We now have staff that will complete the TEFAP and CSFP administrative cost reimbursement report and a signoff will be completed on the day of review by management level employees. Person Responsible: Stephano Blake...
2023-005 Activities Allowed and Allowable Costs Material Weakness Corrective Action: We now have staff that will complete the TEFAP and CSFP administrative cost reimbursement report and a signoff will be completed on the day of review by management level employees. Person Responsible: Stephano Blake Email: SBlake@harvesthope.org Phone: 803-636-6635
2023-004 SCDA Eligibility Material Weakness and Non-Material Noncompliance Corrective Action: We've hired competent staff that will maintain records of the 3 (Partner, Training and TEFAP) agreements that Agencies will sign annually for compliance. Person Responsible: Stephano Blake Email: SBlake@har...
2023-004 SCDA Eligibility Material Weakness and Non-Material Noncompliance Corrective Action: We've hired competent staff that will maintain records of the 3 (Partner, Training and TEFAP) agreements that Agencies will sign annually for compliance. Person Responsible: Stephano Blake Email: SBlake@harvesthope.org Phone: 803-636-6635
2023-003 SCDA Special Tests Significant Deficiency and Non-Material Noncompliance Corrective Action: We've hired competent staff that understand how to reconcile inventory to the general ledger. Person Responsible: Stephano Blake Email: S8lake@harvesthope.org Phone: 803-636-6635
2023-003 SCDA Special Tests Significant Deficiency and Non-Material Noncompliance Corrective Action: We've hired competent staff that understand how to reconcile inventory to the general ledger. Person Responsible: Stephano Blake Email: S8lake@harvesthope.org Phone: 803-636-6635
2023-002 CDBG Activities Allowed and Allowable Costs Significant Deficiency Corrective Action: We now have staff that can review invoices properly prior to payment. Invoices paid will have a final signoff prior to payment. Person Responsible: Stephano Blake Email: SBlake@harvesthope.org Phone: 803-6...
2023-002 CDBG Activities Allowed and Allowable Costs Significant Deficiency Corrective Action: We now have staff that can review invoices properly prior to payment. Invoices paid will have a final signoff prior to payment. Person Responsible: Stephano Blake Email: SBlake@harvesthope.org Phone: 803-636-6635
Condition The reporting package and data collection form for the fiscal year ended September 30, 2023 were not submitted to the Federal Audit Clearinghouse by the June 30, 2024 deadline required under 2 CFR §200.512(a). This represents a repeat finding from the prior audit period. Corrective Action ...
Condition The reporting package and data collection form for the fiscal year ended September 30, 2023 were not submitted to the Federal Audit Clearinghouse by the June 30, 2024 deadline required under 2 CFR §200.512(a). This represents a repeat finding from the prior audit period. Corrective Action Plan RJI acknowledges the delayed completion and submission of the Single Audit and has implemented corrective actions designed to strengthen financial oversight, improve audit readiness, and ensure timely completion of future federal and state reporting requirements. To address the root causes identified, RJI has implemented the following corrective measures. Strengthened Financial and Grants Infrastructure RJI has expanded organizational financial capacity through dedicated finance and grants management staffing with responsibility for grant tracking, financial reconciliation, audit preparation, and compliance monitoring. Formalized Audit Preparation and Annual Compliance Calendar RJI has established a documented year-end financial close and audit readiness calendar that includes internal deadlines for monthly reconciliations, grant closeout procedures, preparation of supporting schedules, auditor request tracking, draft review periods, and Federal Audit Clearinghouse submission timelines. Enhanced Fiscal Sponsor Coordination and Governance Procedures RJI has refined communication and workflow processes with its fiscal sponsor and external financial partners by implementing recurring financial review meetings, defined responsibility matrices, and standardized documentation requirements to ensure timely access to financial records and audit support. Established Audit Continuity and Vendor Management Procedures Recognizing prior disruptions caused by auditor transitions and capacity limitations, RJI has implemented procedures to maintain continuity of audit services including earlier auditor engagement, documented deliverables and timelines, periodic status meetings, and contingency planning for audit completion. Ongoing Monitoring and Board Oversight Financial compliance status, audit progress, and reporting deadlines will be reviewed regularly by executive leadership and reported to the Board of Directors (or Finance/Audit Committee, if applicable) until all required filings are completed and sustained. Documentation and Internal Controls Enhancement RJI has strengthened record retention, reconciliation procedures, and grant documentation practices to improve the completeness and availability of records required for annual audit testing and federal reporting Anticipated Completion Date Corrective actions began implementation in November 2025 and are expected to be fully operational and incorporated into all future annual audit and federal reporting cycles beginning with FY2026 reporting requirements. Status In Progress / Partially Implemented RJI has completed staffing and process improvements and is actively implementing monitoring procedures to ensure sustained compliance with 2 CFR §200.512(a) and timely submission of future Single Audit reporting packages. Management Statement Management believes the corrective actions implemented will ensure full compliance with federal and state reporting requirements and prevent recurrence of late audit submissions. Responsible Individual Dr. Liza Chowdhury Executive Director Date: 5/26/2026
Response: Management concurs with the finding. Corrective Action Plan: NewSpace Nexus will implement procedures to ensure subrecipients are properly documented, reported, and monitored in accordance with grant requirements. Each subaward will include a formal agreement and defined scope of work, and...
Response: Management concurs with the finding. Corrective Action Plan: NewSpace Nexus will implement procedures to ensure subrecipients are properly documented, reported, and monitored in accordance with grant requirements. Each subaward will include a formal agreement and defined scope of work, and required information will be submitted within established timelines. Documentation of submissions and monitoring activities will be maintained, and a tracking process will be used to ensure compliance. The Financial Analyst will manage subrecipient monitoring, with oversight from the Executive Director, and periodic reviews will be conducted. Designation of Employee Position Responsible for Meeting Deadline: Financial Analyst, March 31st, 2024
Response: Management concurs with the finding. Corrective Action Plan: NewSpace Nexus will maintain written financial and grants management policies to support consistent operations and compliance with Uniform Guidance (2 CFR Part 200). These policies will cover key areas including allowable costs, ...
Response: Management concurs with the finding. Corrective Action Plan: NewSpace Nexus will maintain written financial and grants management policies to support consistent operations and compliance with Uniform Guidance (2 CFR Part 200). These policies will cover key areas including allowable costs, procurement, cash management, subrecipient monitoring, reporting, record retention, and internal controls. The Financial Analyst will be responsible for maintaining and updating these policies, with oversight from the Executive Director, and policies will be reviewed at least annually and updated as needed. Designation of Employee Position Responsible for Meeting Deadline: Financial Analyst, by March 31st, 2024
Finding: 2023-010 Agency: Children & Youth Contact Person/Title: Erin Moyer. Administrator of Children & Youth Services Finding Title/Corrective Action: Special Tests and Provisions (DHS Special Tests - Subrecipient CPSL Monitoring) We are now monitoring all clearances, licenses, background checks, ...
Finding: 2023-010 Agency: Children & Youth Contact Person/Title: Erin Moyer. Administrator of Children & Youth Services Finding Title/Corrective Action: Special Tests and Provisions (DHS Special Tests - Subrecipient CPSL Monitoring) We are now monitoring all clearances, licenses, background checks, and COC’s are checked regularly. Anticipated Completion Date: January 2025
Finding: 2023-006 Agency: Children & Youth Contact Person/Title: Erin Moyer. Administrator of Children & Youth Services Finding Title/Corrective Action: Special Tests and Provisions (DHS Common Requirements – Subrecipient Monitoring) We are now monitoring in-home providers to make sure all time is a...
Finding: 2023-006 Agency: Children & Youth Contact Person/Title: Erin Moyer. Administrator of Children & Youth Services Finding Title/Corrective Action: Special Tests and Provisions (DHS Common Requirements – Subrecipient Monitoring) We are now monitoring in-home providers to make sure all time is accounted for as well as clearances, background checks and COC’s for both in-home and placement providers. Anticipated Completion Date: January 2025
Finding: 2023-004 Agency: County Commissioners Contact Person/Title: Jamie Wolgemuth, County Administrator Finding Title/Corrective Action: Special Tests and Provisions – Monitoring The County will enhance its countywide monitoring and oversight of its subrecipient funding agencies. Anticipated Comp...
Finding: 2023-004 Agency: County Commissioners Contact Person/Title: Jamie Wolgemuth, County Administrator Finding Title/Corrective Action: Special Tests and Provisions – Monitoring The County will enhance its countywide monitoring and oversight of its subrecipient funding agencies. Anticipated Completion Date: May 2026
The County has implemented a process of internal controls where expenditures are tracked in a manner that will coincide with reporting requirements for state expenditures for SEFA reporting.
The County has implemented a process of internal controls where expenditures are tracked in a manner that will coincide with reporting requirements for state expenditures for SEFA reporting.
FINDING 2023-003 - Sliding Fee Discount Program MATERIAL WEAKNESS; NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services; direct awards ALN: 93.224/93 .527, Health Center Program Cluster Compliance Requirement: Special Tests & Provisions Criteria: Section ...
FINDING 2023-003 - Sliding Fee Discount Program MATERIAL WEAKNESS; NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services; direct awards ALN: 93.224/93 .527, Health Center Program Cluster Compliance Requirement: Special Tests & Provisions Criteria: Section 330 of the Public Health Service Act and the HRSA Health Center Program Compliance Manual require health centers to maintain and operate a board-approved Sliding Fee Discount Program that adjusts patient charges based on income and family size using the current Federal Pove1ty Guidelines, applies uniformly to all patients and all in-scope services, and is supported by adequate documentation of eligibility determinations. In addition, Uniform Guidance requires nonfederal entities to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and award terms. Condition: During testing of the Sliding Fee Discount Program within the Health Center Cluster, the Center could not provide documentation of the appropriate sliding fee discounts for certain patients in accordance with federal requirements. Context: The condition was identified through testing of the Health Center Cluster as pa1i of the single audit, which included testing patient fee assessments and sliding fee discount application as a special test required under the program. Controls were determined to be ineffective in 2 of 40 test items. Noncompliance was noted in 2 of 25 test items. Statistical sampling was not utilized. Cause: The condition was caused by inadequate internal controls over the implementation and monitoring of the Sliding Fee Discount Program, including limited supervisory review to ensure all sliding fee applications are maintained, reviewed, and properly applied. Effect or Potential Effect: The Center's failure to maintain documentation surrounding sliding fee discounts in accordance with federal requirements increases the risk of noncompliance with Health Center Program requirements and may result in patients being charged amounts not aligned with their ability to pay. The condition also increases the risk of adverse findings during HRSA oversight or other federal monitoring activities. Questioned Costs: No questioned costs were identified as a result of this finding. Repeat Finding: This is not a repeat finding. Recommendation: The Center should enhance internal controls over the Sliding Fee Discount Program by ensuring consistent documentation of income and family size, timely reassessment of eligibility in accordance with policy, consistent application of the board-approved sliding fee discount schedule to all applicable in-scope services, and periodic monitoring and supervisory review to ensure ongoingcompliance. Views of Responsible Officials: Neighborhood Medical Center has implemented quarterly SFDP internal audits and training for the intake staff to improve compliance oversight and documentation accuracy. A standardized audit tracking log documenting charts are reviewed, findings identified and corrective actions completed. An annual refresher for the staff has been implemented. A quick-reference eligibility checklist has also been developed for staff use. Person Responsible for Corrective Action: Ronica Mathis and Shenika Mathews Anticipated Completion Date for Corrective Action: This practice has already been implemented.
FINDING 2023-004- Late Submission of Single Audit and FAC Data Collection Form SIGNIFICANT DEFICIENCY; NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services; direct awards ALN: 93 .011, 93.224/93.527, 93.526, and 93.918 Compliance Requirement: Reporting Cr...
FINDING 2023-004- Late Submission of Single Audit and FAC Data Collection Form SIGNIFICANT DEFICIENCY; NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services; direct awards ALN: 93 .011, 93.224/93.527, 93.526, and 93.918 Compliance Requirement: Reporting Criteria: Uniform Guidance requires nonfederal entities to submit the reporting entity's Uniform Guidance reporting package, including the audit report and completed Federal Audit Clearinghouse (F AC) Data Collection Form, to the F AC within the earlier of 30 calendar days after receipt of the auditor's rep01ts or nine months after fiscal year-end (2 CFR 200. 512( a)). Timely submission of the reporting package is required to facilitate federal oversight of award compliance. Context: The condition was identified during Single Audit testing of reporting requirements applicable to the Health Center Cluster. Sampling was not utilized. Condition: The Center did not submit its required Uniform Guidance reporting package, including the reporting entity's audit report and the FAC Data Collection Form, within the required submission timeframe. Specifically, the Uniform Guidance audit and related FAC Data Collection Form were submitted after the earlier of (1) 3 0 calendar days after receipt of the auditor's reports or (2) nine months after the end of the reporting entity's fiscal year. Cause: Due to a delay in the compiling of records related to the audit, the Center was not in compliance with the reporting requirements. Effect or Potential Effect: Failure to submit the Uniform Guidance audit and F AC Data Collection Form timely increases the risk of noncompliance with Uniform Guidance reporting requirements and may result in delayed federal oversight, increased monitoring by the awarding agency, or the imposition of additional administrative conditions. Questioned Costs: No questioned costs were identified as a result of this finding. Repeat Finding: This is a repeat finding. Recommendation: The Center should strengthen internal controls over Uniform Guidance audit reporting by ·implementing procedures to track submission deadlines, assigning responsibility for timely filing of the audit report and FAC Data Collection Form, and establishing management review processes to ensure compliance with Uniform Guidance reporting requirements. View of Responsible Officials: Neighborhood's prior auditor indicated just before time to begin the audit for FY2022; they would not be able to complete the audit because of staff sho1tages. Two RFPs were issued, and it took the center a year and a half to secure a new auditor. The 2022 and 2023 audits have been completed. Engagement contract has been issued for the 2024 audit.
Require Pre-Approval Completion of Rent Reasonableness Forms Effective immediately, rent reasonableness forms must be completed and approved before any lease is executed or renewed. No unit may be approved for occupancy until this documentation is on file. - Implement a Standardized Intake Documenta...
Require Pre-Approval Completion of Rent Reasonableness Forms Effective immediately, rent reasonableness forms must be completed and approved before any lease is executed or renewed. No unit may be approved for occupancy until this documentation is on file. - Implement a Standardized Intake Documentation A mandatory rent reasonableness form, fair market rent comparison, and supporting documentation must be maintained. Files cannot be finalized without all required items. - Centralize Documentation Storage All rent reasonableness forms will be stored in a centralized electronic repository organized by program and unit. This ensures timely retrieval for monitoring and audit purposes. - Staff Training Housing program staff will receive training on the updated procedures, including when and how rent reasonableness forms must be completed. Refresher training will be incorporated into annual compliance training. - Ongoing Monitoring and Quality Review The Director of Housing Programs will conduct quarterly reviews of tenant files to verify that rent reasonableness forms are completed prior to lease approval. Any deficiencies will be corrected immediately and reported to senior management. Management agrees with the condition noted. While all units ultimately met rent-reasonableness requirements, the Organization acknowledges that rent reasonableness forms were completed retroactively rather than at the time of lease approval, which is not consistent with our internal procedures. Completing these forms contemporaneously is essential to documenting that rents are comparable to similar units and below fair market rent prior to approving occupancy. The Organization has strengthened its intake and documentation processes to ensure rent reasonableness determinations are completed and approved before lease execution going forward.
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