Corrective Action Plans

Finding 1156642 (2024-002)

Material Weakness 2024

Highmark Health

PA

Student Financial Aid

Management’s Views and Corrective Action Plan 2024-002 – Non-compliance with Disbursements to or on behalf of students Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant...

Management’s Views and Corrective Action Plan 2024-002 – Non-compliance with Disbursements to or on behalf of students Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Year: 1/1/2024 - 12/31/2024 Award Number: Not applicable Assistance Listing Numbers: 84.007, 84.063 and 84.268 Management’s Response Management has sent disbursement notifications to students and tracked aspects of the notifications via the AHN Schools of Nursing’s (the “Schools”) student portal. Each notification was sent by email to the student, and an activity was logged in the student’s audit log and activity tracking with the student portal. From this process, management agrees that the Schools were unable to extract the exact disbursement details that were sent via the disbursement email. Additionally, the Schools could not replicate the disbursement email that is sent to the student. To ensure all reporting requirements are met, the Schools have ensured that a copy of the disbursement email will be sent to both the student and the institution. The Schools have already modified the disbursement notification process by adding a secondary email address to the disbursement notifications. A copy of each notification will be sent to campuscafesuperuser@ahn.org to ensure a copy of the notifications will be available for future audits. Management agrees that there was no receipt of affirmative confirmation for one student and no available signed attestation to verify voluntary consent to participate in electronic transactions for one student. The lack of receipt and documentation was due to a human clerical error. Management has communicated reminders of the related requirements, as well as the Schools policies and procedures to the personnel. In addition, management is in process of recruiting an additional Financial Aid Officer, who will act as an additional layer of review and cross-checks to ensure documentation is retained appropriately. Anticipated Completion Date As of the date of this report the above noted process has been updated and is current procedure. Management is actively recruiting for an additional Financial Aid Officer and is working to fill the open position as soon as possible. Responsible Parties • Amy Stoker, Director of AHN Schools of Nursing • Sarah Loomis, Director of Financial Aid of AHN Schools of Nursing • Rosanna Sarantinoudis, Student Accounts Associate and Registrar of West Penn Hospital School of Nursing • Natalia Wassel, Student Accounts Associate and Registrar of West Penn Hospital School of Nursing

View Audit 368997

Finding 1156641 (2024-001)

Material Weakness 2024

Highmark Health

PA

Student Financial Aid Reporting

Management’s Views and Corrective Action Plan 2024-001 – Non-compliance with Enrollment Reporting Requirements Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Year: 1/1/2024 - 12/3...

Management’s Views and Corrective Action Plan 2024-001 – Non-compliance with Enrollment Reporting Requirements Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Year: 1/1/2024 - 12/31/2024 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Management’s Response Management agrees with the finding as it relates to the improper reporting to NSLDS of enrollment reporting for one student. The improper reporting was due to a human clerical error. As of the date of this report, management notes that the identified student’s enrollment status has been updated to NSLDS. Currently all financial aid aspects of the AHN Schools of Nursing are completed by one personnel. Management has communicated reminders of the student enrollment change requirements, as well as the AHN Schools of Nursing policies and procedures to the personnel to ensure that changes are reported accurately and timely. In addition, management is in process of recruiting an additional Financial Aid Officer, who will act as an additional layer of review and cross-checks to ensure that data is being reported for enrollments accurately and timely. Anticipated Completion Date As of the date of this report, the noted student’s enrollment status has been updated. Management is actively recruiting for an additional Financial Aid Officer and is working to fill the open position as soon as possible. Responsible Parties • Amy Stoker, Director of AHN Schools of Nursing • Sarah Loomis, Director of Financial Aid of AHN Schools of Nursing

View Audit 368997

Finding 1156637 (2024-001)

Material Weakness 2024

Chamber of Commerce of the Borough of Queens, Inc.

NY

Procurement, Suspension & Debarment § 200.318 § 200.319 § 200.320

As stated in the Management Letter issued by SAX regarding the Organizations procurement policy, 2024 was the first year the Organization received federal funding and therefore was not aware of the specific language required by the Uniform Guidance (2 CFR §200.317-.327) needed in the procurement pol...

As stated in the Management Letter issued by SAX regarding the Organizations procurement policy, 2024 was the first year the Organization received federal funding and therefore was not aware of the specific language required by the Uniform Guidance (2 CFR §200.317-.327) needed in the procurement policy. The Organization has worked with SAX to add policies to procurement policies to ensure that any future procurements required by federal funding received will include procedures required under the Uniform Guidance (2 CFR §200.317-.327).

View Audit 368984

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 1156633 (2024-005)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

HUD Housing Programs Special Tests & Provisions

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure the HAP agrees between the HUD-50058, HAP contract, and HAP register. Explanation of disagreement with audit finding: There is no disagreement with the audit ...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure the HAP agrees between the HUD-50058, HAP contract, and HAP register. 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 the HUD-50058 matches the HAP contract and the HAP register by reviewing the accuracy of HAP amount, coordinate general HAP processing controls, (segregating duties to mitigate the threat of fraud or theft), and monitoring files on a monthly basis. 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: 3/31/2026

View Audit 368975

Finding 1156630 (2024-004)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: Th...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will conduct Quality Control on 20% of failed inspections on a biweekly basis to ensure abatements are not missed before the cutoff date of the 27th of each month. 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: 1/31/2026

View Audit 368975

Finding 1156627 (2024-003)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

HUD Housing Programs Special Tests & Provisions Material Weakness

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Explanation of disagreement with audit finding: There is no disagre...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will audit files for the correct methodology used in determining rents and ensure rents are reasonable on a monthly basis. In addition, HAKC has contracted a QC audit to review 100% of the files. 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: 12/31/2026

View Audit 368975

Finding 1156624 (2024-002)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

HUD Housing Programs Material Weakness Reporting

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will monitor the monthly SEMAP Indicator report and monitor the PIC dashboard to ensure all 50058 errors are corrected and uploaded in a timely manner. HAKC will also pull the ADHOC from PIC to verify the records. HAKC will continue working with the HUD PIC coach monthly to correct all errors. 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: 4/30/2026

View Audit 368975

Finding 1156621 (2024-001)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

Eligibility Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Explanation of disagreement with audit finding: There is no disagreem...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC has moved to mass annual recertification appointments to address the program delinquency and inspect files for required documentation; the recertifications will be completed and processed ensuring all documentation has been received in the file. HAKC will perform a QC sample on a monthly basis to address the files and ensure proper documentation. In addition to QC samples, the HAKC has awarded a QC contract to audit 100% of the files. 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: 12/31/2026

View Audit 368975

Finding 1156618 (2024-004)

Material Weakness 2024

Hendricks County

IN

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2024-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of ...

FINDING 2024-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of Responsible O􀆯icials: We concur with the findings. Description of Corrective Action Plan: The Grant Administrator will monitor all claims that will be used for the quarter and send them to the reporting agent to report after the quarter ends. She will be diligent to track any claims coming in outside of that quarter so that reporting is accurate. She will provide the reporting agent with all claims relevant to that quarter’s report. Anticipated Completion Date: This will be done quarterly starting with the quarter ending on September 30th, 2025. The Grant Administrator will submit these claims to the reporting agent one week after the quarter ends. The Financial Administrator will sign o􀆯 on the LOW report to verify the claims match.

View Audit 368974

Finding 1156617 (2024-003)

Material Weakness 2024

Hendricks County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

FINDING 2024-003 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / asta...

FINDING 2024-003 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of Responsible O􀆯icials: We concur with the findings. Description of Corrective Action Plan: To prevent future mishaps, the Grant Assistant will email department heads educating them on the procedures and expectations for suspension and debarment assessment. The email will be a step-by-step process for those responsible for checking suspension and debarment. This will prevent subrecipients from being missed. She will also check for suspension/debarment for each contractor/subrecipient through the County within a month of receiving a signed contract. This will ensure all contracts with the County are complying. Anticipated Completion Date: The Grant Assistant will begin this corrective action plan on October 1st, 2025.

View Audit 368974

Finding 1156616 (2024-001)

Material Weakness 2024

Independent Communities, Inc.

GA

Management agrees with the finding and will implement procedures to ensure the financial statements are filed timely.

View Audit 368972

Finding 1156613 (2024-002)

Material Weakness 2024

The Affordable Housing Conservancy

NY

Allowable Costs / Cost Principles § 200.400

Finding 2024-002: Allowable Costs Condition: The Organization did not allocate shared costs appropriately between program and non-program related activities, resulting in approximately $15,078.56 in costs charged incorrectly to the Weatherization Assistance Program. Corrective Action: Management has...

Finding 2024-002: Allowable Costs Condition: The Organization did not allocate shared costs appropriately between program and non-program related activities, resulting in approximately $15,078.56 in costs charged incorrectly to the Weatherization Assistance Program. Corrective Action: Management has developed and implemented a cost allocation methodology consistent with 2 CFR 200.400. Beginning in 2025, costs will be allocated between programs (Weatherization Assistance Program and others) based on employee time distribution. This allocation policy will be documented and reviewed annually. Staff involved will be trained to ensure consistent application of cost allocation procedures. Responsible Party: Program/Fiscal Director

View Audit 368962

Finding 1156612 (2024-001)

Material Weakness 2024

The Affordable Housing Conservancy

NY

Procurement, Suspension & Debarment § 200.214

Finding 2024-001: Suspension and Disbarment Condition: The Organization did not research all vendors for potential suspension or disbarment, and documentation of this research was not maintained. Corrective Action: Management’s understanding of the regulations is that only purchases from vendors equ...

Finding 2024-001: Suspension and Disbarment Condition: The Organization did not research all vendors for potential suspension or disbarment, and documentation of this research was not maintained. Corrective Action: Management’s understanding of the regulations is that only purchases from vendors equal to or greater than $25,000 must be researched for potential suspension or disbarment. Management will implement a policy that any subcontracts or purchases expected or known to be equal to or greater than $25,000 will be checked against SAM.gov for potential suspension or disbarment. Documentation of the research, such as a screenshot, will be maintained. Responsible Party: Program/Fiscal Director

View Audit 368962

Finding 1156611 (2024-004)

Material Weakness 2024

New York City Housing Authority

NY

Questioned Costs HUD Housing Programs

Finding Number 2024-004 SPECIAL PERFORMANCE – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.871– SECTION 8 HOUSING CHOICE VOUCHERS Contract # N/A Criteria Special Reporting - HUD-50058, Family Report (OMB No. 2577-0083) - The PHA ...

Finding Number 2024-004 SPECIAL PERFORMANCE – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.871– SECTION 8 HOUSING CHOICE VOUCHERS Contract # N/A Criteria Special Reporting - HUD-50058, Family Report (OMB No. 2577-0083) - The PHA is required to submit this form electronically to HUD each time the PHA completes an issuance, admission, annual reexamination, interim reexamination, portability move-in, expiration, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA's jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Key Line items - The following line items contain critical information Line 2a - Type of Action Line 2b - Effective Date of Action Line 3b, 3c – Names Line 3e - Date of Birth Line 3n - Social Security Numbers Line 5a - Unit Address Line 5h, 5i - Unit inspection Dates Line 7i - Total Annual income Lines 2k and 17a - Family's Participation in the Family Self Sufficiency (FSS) Program Line 17k (2) - FSS Account Balance Condition/Context The Authority received funding from the HUD. The Authority is required to submit HUD-50058 each time the PHA completes an issuance, admission, annual reexamination, interim .reexamination, portability move-in, expiration, or other change of unit for a family. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (Special reporting forms as noted in the Criteria section above) were requested to be provided: • Eight documents related to HUD-50058 forms were not provided (One missing verification of Names; Three missing verification of Date of Birth; and Four missing Verification of Social Security. These forms are considered critical information for HUD -50058 forms. This documents are required documentation to be maintained in the case files to support HUD-50058 form for Section 8 Housing Choice Voucher Program. Therefore, we were not able to determine if the critical information in HUD-50058 form are supported by supporting documentation. Recommendation We recommend the Authority strengthen its controls over the Section 8 Housing Choice Voucher Program HUD-50058 form to ensure that all supporting documentation for HUD-50058 form are received, reviewed, and maintained to support HUD -50058 form. Corrective Action Plan There are some missing documentations pertaining to eligibility and admission in files for households admitted prior to 2011. Such documentation, which includes the application, vital documents, lease, and request for tenancy approval, is aged beyond 20 years for some cases and is not retrievable as part of a 2010 backfile conversion. This was noted as a condition in a previous Single Audit. Part III of the Schedule of Findings and Questioned Costs for Federal Awards year ending December 31, 2010, cited the condition as “For two of our selections, the Authority was not able to locate the tenant file containing the required documentation that the authority had obtained to verify income eligibility. Because the tenant file was not available, the authority was not able to provide all of the documents needed to test eligibility such as tenant applications, third party income verifications, or lease agreements.” NYCHA's response to that audit conveyed our confidence in the business improvement initiatives completed to streamline the document management process. As NYCHA noted in response to the 2010 audit: the backfile conversion process was part of a large-scale, multi-year implementation of a new computer system that went live in 2011, during which over 15 million documents were converted to electronic files. New system improvements included forms tracking using the Intelligent Forms Processing (IFP) scanning technology. The IFP technology associates and saves scanned documents and documents completed by tenants electronically directly to the tenant case files in Siebel. The Siebel Customer Relationship Manager (CRM) System provides process standardization and solutions for document retention needs. In the current audit, there are 30 files that are reflective of our improved document management and retention; NYCHA has continued to make such improvements since 2011 and NYCHA remains committed to making our best efforts to ensure that all eligibility and admission documentation is maintained in the system of record. Action Date September 10, 2025 Final Implementation September 10, 2025 Name And Phone Number Of Person Responsible for Implementation Lakesha Miller Executive Vice President for Leased Housing Office of the Chief Executive Officer +1-212-306-8818

View Audit 368960 Questioned Costs: $1

Finding 1156608 (2024-003)

Material Weakness 2024

New York City Housing Authority

NY

Questioned Costs HUD Housing Programs

Finding Number 2024-003 ELIGIBILITY – SIGNIFICANT DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.871– SECTION 8 HOUSING CHOICE VOUCHERS Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application fo...

Finding Number 2024-003 ELIGIBILITY – SIGNIFICANT DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.871– SECTION 8 HOUSING CHOICE VOUCHERS Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: • As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). • For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income- based rent (24 CFRsection 982.516). Condition/Context The Authority received funding from the HUD. The Section 8 Housing Choice Voucher Program provides rental assistance to help very low- income families afford decent, safe, and sanitary rental housing. The Mainstream Voucher program enables families for whom the head, spouse, or co-head is a person with disabilities to lease affordable private housing of their choice. Of the sixty (60) case files selected for testing in which 600 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: • Thirty-three eligibility forms related to five cases, were not provided (Thirty-two missing application forms, and one missing third -party verification of reported family annual income form). These forms are required documentation to be maintained in the case files to support eligibility for Section 8 Housing Choice Voucher Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Section 8 Housing Choice Voucher Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan There are some missing documentations pertaining to eligibility and admission in files for households admitted prior to 2011. Such documentation, which includes the application, vital documents, lease, and request for tenancy approval, is aged beyond 20 years for some cases and is not retrievable as part of a 2010 backfile conversion. This was noted as a condition in a previous Single Audit. Part III of the Schedule of Findings and Questioned Costs for Federal Awards year ending December 31, 2010, cited the condition as “For two of our selections, the Authority was not able to locate the tenant file containing the required documentation that the authority had obtained to verify income eligibility. Because the tenant file was not available, the authority was not able to provide all of the documents needed to test eligibility such as tenant applications, third party income verifications, or lease agreements.” NYCHA's response to that audit conveyed our confidence in the business improvement initiatives completed to streamline the document management process. As NYCHA noted in response to the 2010 audit: the backfile conversion process was part of a large-scale, multi-year implementation of a new computer system that went live in 2011, during which over 15 million documents were converted to electronic files. New system improvements included forms tracking using the Intelligent Forms Processing (IFP) scanning technology. The IFP technology associates and saves scanned documents and documents completed by tenants electronically directly to the tenant case files in Siebel. The Siebel Customer Relationship Manager (CRM) System provides process standardization and solutions for document retention needs. In the current audit, there are 30 files that are reflective of our improved document management and retention; NYCHA has continued to make such improvements since 2011 and NYCHA remains committed to making our best efforts to ensure that all eligibility and admission documentation is maintained in the system of record. Action Date September 10, 2025 Final Implementation September 10, 2025 Name And Phone Number Of Person Responsible for Implementation Lakesha Miller Executive Vice President for Leased Housing Office of the Chief Executive Officer +1-212-306-8818

View Audit 368960 Questioned Costs: $1

Finding 1156605 (2024-002)

Material Weakness 2024

New York City Housing Authority

NY

Questioned Costs HUD Housing Programs Eligibility

Finding Number 2024-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled...

Finding Number 2024-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). Condition/Context The Authority received funding from the HUD. The Public and Indian Housing Program is to provide and operate cost effective, decent, safe, and affordable dwellings for lower income families through an authorized local PHA. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: • Ten eligibility forms were not provided (Three missing application forms, two missing Federally prescribed general release form for employment information; two missing verification of income; two missing calculation of rent forms and one missing reexamine family income). These forms are required documentation to be maintained in the case files to support eligibility for Public and Indian Housing Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan In January 2011, NYCHA implemented the Siebel Customer Relationship Management (CRM) system, which included digital file storage and an online application process, which replaced our previous paper application process. Any applications in process from that date onward were subject to document scanning and documentation was stored digitally. Any applications processed prior to this date were kept in a paper format and stored at the development, where the applicant was certified or where the tenant resides. If a tenant family transferred to another development, the physical tenant folder and documents were sent to their new location. In June 2020, NYCHA sought to digitize all tenant folders; however, the cost of the project was determined to be prohibitive so the goal of digitizing the tenant folders was not realized. Any documents damaged or lost prior to 2011 cannot be recovered, including those impacted by Hurricane Sandy. Action Date September 12, 2025 Final Implementation September 12, 2025 Name And Phone Number Of Person Responsible for Implementation Sylvia Aude Senior Vice president Office of the Senior Vice President for Public Housing Operations Tenancy Administration +1-212-306-3921

View Audit 368960 Questioned Costs: $1

Finding 1156604 (2024-001)

Material Weakness 2024

New York City Housing Authority

NY

HUD Housing Programs Special Tests & Provisions

Finding Number 2024-001 SPECIAL TESTS AND PROVISIONS- ENVIRONMENTAL CONTAMINANTS TESTING AND REMEDIATION – MATERIAL WEAKNESS Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Special Tests and Provision...

Finding Number 2024-001 SPECIAL TESTS AND PROVISIONS- ENVIRONMENTAL CONTAMINANTS TESTING AND REMEDIATION – MATERIAL WEAKNESS Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Special Tests and Provisions - Environmental Contaminants Testing and Remediation As stated in the May 2024 Compliance Supplement, Public Housing must be decent, safe, sanitary, and in good repair. Public Housing Authority’s (PHA) must maintain such housing in a manner that meets the physical condition standards set forth in 24 CFR section 5.703 in order to be considered decent, safe, sanitary, and in good repair. Those standards address the major areas of the public housing: the site; the building exterior; the building systems; the dwelling units; the common areas; and health and safety considerations. Health and safety considerations require that all areas and components of the housing must be free of health and safety hazards. These areas include, but are not limited to, air quality, electrical hazards, elevators, emergency/fire exits, flammable materials, garbage and debris, handrail hazards, infestation, and lead-based paint. The housing must have no evidence of infestation by rats, mice, or other vermin, or of garbage and debris. The housing must have no evidence of electrical hazards, natural hazards, or fire hazards. The dwelling units and common areas must have proper ventilation and be free of mold, odor (e.g., propane, natural gas, methane gas), or other indoor air hazards such as radon. The housing must comply with all requirements related to the evaluation and reduction of lead-based paint hazards and have available proper certifications of such (see 24 CFR Part 35). For the period under audit, the PHA is required to test for and remediate environmental contaminates including but not limited to lead-based paint, radon gas, and mold to ensure that public housing met the physical condition standards for health and safety considerations set forth in 24 CFR section 5.703. Condition/Context The New York City Housing Authority (the “Authority”) performs environmental contaminates testing and remediation including but not limited to Lead-based paint, Mold, Pest Control, Elevators, Heating and Annual Apartment Inspections. To track compliance with the Agreement executed on January 31, 2019 by and among the Authority, the U.S. Department of Housing and Urban Development (“HUD”) and the U.S. Attorney’s Office for the Southern District of New York (SDNY) and The City Of New York (the “HUD Agreement”), the Authority maintains monthly inspection reports for the various inspections performed and provides that information to HUD, the SDNY and the Federal Monitor appointed under the HUD Agreement. Deloitte obtained the bi-annual lead- based paint compliance reports from the Authority and for the Period from January 1, 2024 through July 31, 2024. we read extermination, heat outage, mold inspections, annual apartment inspections, and elevator outage reports for the months of February 2024; April 2024; July 2024; September 2024 and November 2024. During our audit, we noted that the Authority did not complete all corrective actions in the 2024 audit period and is in the process of addressing these issues. Recommendation We recommend that the Authority continue to ensure that all environmental contaminates are properly remediated during the audit period through the HUD Agreement. Corrective Action Plan In January 2019, the Authority entered into the HUD Agreement to address building conditions, including conditions related to lead-based paint, mold, pests, elevators, and heating. Among other things, the HUD Agreement appointed a federal Monitor and established three new Departments – Compliance, Environmental Health & Safety, and Quality Assurance. It also required the promulgation of action plans around these health and safety issues and other items. These action plans are publicly available https://www1.nyc.gov/site/nycha/about/reports.page, along with other reports on health and safety issues, which detail the Authority’s efforts to inspect for and correct deficiencies associated with environmental contaminants like lead-based paint and mold. The Authority plans to continue to work to address these health and safety issues, and to work towards meeting the multi-year obligations laid out in the HUD agreement in addition to the action plans. NYCHA has recorded $4,930,190,000 of pollution remediation obligations as of December 31, 2024, which relates to costs to inspect for, and correct deficiencies associated with environmental contaminants. Action Date Ongoing milestones through January 31, 2039 Final Implementation The latest in time obligation under the HUD Agreement is the Authority’s obligation to abate 100% of the apartment units that contain lead-based paint, and the interior common areas that contain lead-based paint in the same building as those units, by January 31, 2039 Name And Phone Number Of Person Responsible For Implementation Cassiah (Cassie) M.Ward Chief Compliance Officer +1-212-306-8484

View Audit 368960

Finding 1156603 (2024-001)

Material Weakness 2024

Bebashi - Transition to Hope

PA

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329

On behalf of Bebashi – Transition to Hope, I am submitting this corrective action plan in response to the material weakness finding identified in our recent federal audit. The finding noted a lack of effective internal controls over the maintenance of accurate accounting records, including the trial...

On behalf of Bebashi – Transition to Hope, I am submitting this corrective action plan in response to the material weakness finding identified in our recent federal audit. The finding noted a lack of effective internal controls over the maintenance of accurate accounting records, including the trial balance, general ledger, and the Schedule of Expenditures of Federal Awards (SEFA) and state financial assistance. These deficiencies resulted in material audit adjustments to the current year’s financial statements, multiple versions of the trial balance due to reconciling issues, and audit delays related to unreconciled supporting documentation. We take these findings with the utmost seriousness. As stewards of federal funds, it is our fiduciary duty to maintain strict compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), as well as applicable state financial requirements. Corrective Action Plan 1. Strengthening Internal Controls o We are implementing enhanced internal control procedures to ensure timely reconciliation of the trial balance and general ledger. o Monthly reconciliations will now be prepared by the Finance Department, reviewed by the Chief Operating Officer, and formally approved by the President & Chief Executive Officer prior to closing. o Quarterly oversight reporting will also be provided to the Bebashi Board of Directors. 2. Accounting System Improvements o We will establish a standardized process to ensure one official version of the trial balance is maintained, with all adjustments tracked and documented in accordance with Generally Accepted Accounting Principles (GAAP). o We are upgrading our financial reporting system to include automated reconciliation checks, audit trails, and controls that will minimize the risk of discrepancies. 3. Staff Training and Accountability o Finance staff will undergo mandatory annual training on federal compliance, SEFA preparation, and reconciliation best practices. o Roles and responsibilities will be clearly defined, with a segregation of duties to prevent misstatements and errors. 4. Audit Readiness and Documentation o A comprehensive audit binder will be prepared and maintained to ensure that supporting documentation reconciles with the trial balance prior to submission. o A compliance calendar will be developed to track critical deadlines, reconciliation reviews, and reporting requirements. 5. Board and Executive Oversight o The Bebashi Board of Directors, through its Finance and Audit Committees, along with the President & CEO, will provide governance oversight of this corrective action plan. o Quarterly progress reports will be submitted to the Board, and the CEO and Board will formally document oversight in meeting minutes to ensure accountability and compliance. Responsible Party: The Finance Director, in collaboration with the Chief Operating Officer and with final accountability to the President & CEO as well as the Bebashi Board of Directors, will be responsible for implementing and monitoring this corrective action plan. Anticipated Completion Date: All corrective measures will be completed within ninety (90) days of the date of this letter, with ongoing monitoring and governance oversight by the CEO and Board of Directors to ensure sustainability. We regret the deficiencies that led to this finding and are committed to taking the corrective actions necessary to strengthen our financial management systems. Bebashi – Transition to Hope is dedicated to full compliance with federal and state requirements and to safeguarding the integrity of public funds entrusted to us. Respectfully submitted, Sincerely, Sebrina Tate President & Chief Executive Officer Bebashi – Transition to Hope On behalf of the Bebashi Board of Directors

View Audit 368952

Finding 1156598 (2024-001)

Material Weakness 2024

Educate Maine

ME

Reporting Subrecipient Monitoring

Management agrees with the finding and is working on submission of the federal reporting package for the year ended December 31, 2023. The submission of the December 31,2024 federal reporting package will be completed prior to its due date.

View Audit 368944

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 1156587 (2024-003)

Material Weakness 2024

Saint Charles County, Missouri

MO

Procurement, Suspension & Debarment

Action taken in response to finding: The County will continue to ensure that suspension and debarment assessments are performed.

View Audit 368939

Finding 1156586 (2024-002)

Material Weakness 2024

Saint Charles County, Missouri

MO

Subrecipient Monitoring Cash Management § 200.332

Action taken in response to finding: The County will review the subrecipient monitoring requirements and work with the County Auditor to develop a formal policy that includes internal controls, monitoring procedures, and documentation requirements.

View Audit 368939

Corrective Action Plans

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