Corrective Action Plans

Finding 499240 (2023-002)

Material Weakness 2023

Housing Authority of the City of Washington

GA

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

2023-002 Condition: Deficiencies Noted in Examination of New Construction Section 8 Tenant Files Steps to resolve: We will review the internal control procedures over tenant file re-certifications and documents and implement procedures which will eliminate such errors. Management has implement...

2023-002 Condition: Deficiencies Noted in Examination of New Construction Section 8 Tenant Files Steps to resolve: We will review the internal control procedures over tenant file re-certifications and documents and implement procedures which will eliminate such errors. Management has implemented procedures in order to clear this finding in FY 2024. Timeframe: By FYE December 31, 2024 Individual responsible for correction: Ms. Zena Zahran, Executive Director

View Audit 322035

Finding 499239 (2023-004)

Significant Deficiency 2023

Home Forward

OR

Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend Home Forward design controls to ensure formal documentation of approval of comparables is in the files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...

Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend Home Forward design controls to ensure formal documentation of approval of comparables is in the files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Home Forward will add clarifying language in our Shelter Plus Care (Continuum of Care) Program operating manual indicating need for staff to document who completed rent reasonableness reviews including signatures from program supervisors or department staff responsible for approving comparables when necessary as part of the rent reasonableness review. Additional staff training will be conducted during Shelter Plus Care and department team meetings. Name(s) of the contact person(s) responsible for corrective action: Ian Slingerland, Director of Homeless Initiatives and Supportive Housing Planned completion date for corrective action plan: 10/1/2024

View Audit 322033

Finding 499238 (2023-003)

Significant Deficiency 2023

Home Forward

OR

Procurement, Suspension & Debarment § 200.303

Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend Home Forward implements a process to ensure exclusion checks are done prior to the execution of a contract. This process should include a system to ensure documentation is maintained in the files evidencing the date of t...

Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend Home Forward implements a process to ensure exclusion checks are done prior to the execution of a contract. This process should include a system to ensure documentation is maintained in the files evidencing the date of the exclusion check as well as documented review and approval of the results of the exclusion check by program staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement has updated the Contract Request form to include a section for attesting yes or no for federal funds, also allowing for free form entry. After a discussion with DCR on situations where they are unsure if there will be HUD funding it was determined to treat all their Public Improvement projects as Davis Bacon projects and include all applicable steps throughout the solicitation process. We are doing a full background check on all contracts, which includes a sam.gov check. When the contracts come to the Contracts and Procurement Manager for final signature, a check will be made in the file to confirm the documents are present showing the sam.gov screen print was made and the Contracts and Procurement Manager will sign both the background check and the Contract at that time. Example attached. Name(s) of the contact person(s) responsible for corrective action: Celeste King Planned completion date for corrective action plan: June 1, 2024

View Audit 322033

Finding 499237 (2023-002)

Significant Deficiency 2023

Home Forward

OR

Eligibility HUD Housing Programs

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and income is supported. Explanation of disagreement with audit finding: There is no disagreement w...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and income is supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • We will be conducting a random audit of all LRPH files. • Training on best practice for PH and PBV reviews. This training will emphasize the importance of proper income documentation. • Sending out monthly report for reviews that are coming due. Name(s) of the contact person(s) responsible for corrective action: Suzanne Couttouw, Compliance Manager (audit and training) and Elise Anderson (monthly reporting.) Planned completion date for corrective action plan: March 30, 2025

View Audit 322033

Finding 499236 (2023-001)

Significant Deficiency 2023

Home Forward

OR

Questioned Costs Allowable Costs / Cost Principles

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that payroll transactions charged to the program are supported. Explanation of disagreement with audit finding: There is no disagreement with ...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that payroll transactions charged to the program are supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Updated settings in payroll system so timesheet codes are available for selection only by the employees who should be using them. Added additional review of timesheet totals for certain codes. Will provide reminders and additional resources to supervisors on reviewing timesheets. Name(s) of the contact person(s) responsible for corrective action: Casey Little, Assistant Controller Planned completion date for corrective action plan: 8/31/2024

View Audit 322033 Questioned Costs: $1

Finding 499235 (2023-003)

Significant Deficiency 2023

Entrepreneurship for All, Inc.

MA

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Item # 2023-003 Reconciliation of Bank Accounts (Significant Deficiency in Internal Control) Criteria: Under GAAP, bank accounts are required to be reconciled on a regular basis to ensure that they are properly stated under the accrual basis of accounting. Condition: During the year under audit, ...

Item # 2023-003 Reconciliation of Bank Accounts (Significant Deficiency in Internal Control) Criteria: Under GAAP, bank accounts are required to be reconciled on a regular basis to ensure that they are properly stated under the accrual basis of accounting. Condition: During the year under audit, the Organization did not reconcile the ending balances of all accounts held with financial institutions during the fiscal year. Cause: The Organization did not compare the balances per statements received for bank accounts from financial institutions with its own internal account balances and failed to make the necessary accrual based accounting adjustments for reconciling items. Effect: Failure to update internal controls to comply with the requirements of the GAAP could result in ineffective monitoring of costs allocated to the federal program. Recommendation: The Organization should strengthen its internal control practices by updating its policies and procedures to comply with GAAP. Views of Responsible Officials and Planned Corrective Actions: Management has been making updates to its policies and procedures throughout 2024 to be in full compliance with GAAP. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 322032

Finding 499234 (2023-002)

Material Weakness 2023

Entrepreneurship for All, Inc.

MA

Material Weakness Internal Control / Segregation of Duties

Item # 2023-002 Net Assets with Donor Restrictions (Material Weakness in Internal Control) Criteria: Under GAAP, net assets with donor restrictions should be released from restrictions when the award terms of the related grants or contributions are met. Condition: Management did not release all r...

Item # 2023-002 Net Assets with Donor Restrictions (Material Weakness in Internal Control) Criteria: Under GAAP, net assets with donor restrictions should be released from restrictions when the award terms of the related grants or contributions are met. Condition: Management did not release all restricted net assets within the proper period. Cause: Management did not examine grant and contribution agreements carefully enough to determine the nature of the applicable terms for restrictions and did not take necessary measures to ensure that net assets with donor restrictions were properly released throughout the fiscal year. Effect: Net assets with donor restrictions were overstated by $3,571,287 and net assets without donor restrictions was understated by $3,571,287. Recommendation: We recommend that management ensures that it examines grant agreements carefully to determine the nature of the applicable terms for restrictions, and to take necessary measures to ensure that net assets with donor restrictions were properly released throughout the fiscal year. Views of Responsible Officials and Planned Corrective Actions: Management has been making updates to its policies and procedures throughout 2024 to be in full compliance with GAAP. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 322032

Finding 499233 (2023-001)

Material Weakness 2023

Entrepreneurship for All, Inc.

MA

Allowable Costs / Cost Principles Material Weakness Reporting

Item # 2023-001 Conditional Grant Revenue Recognition (Material Weakness in Internal Control) Criteria: Under Generally Accepted Accounting Principles (GAAP), advances received for conditional grants for expenses not yet incurred are considered a refundable advance liability and should be recognize...

Item # 2023-001 Conditional Grant Revenue Recognition (Material Weakness in Internal Control) Criteria: Under Generally Accepted Accounting Principles (GAAP), advances received for conditional grants for expenses not yet incurred are considered a refundable advance liability and should be recognized as revenue only once the barriers are overcome, which includes incurrence of allowable costs under Office of Management and Budget Circular A-122. Condition: Management did not recognize conditional grant revenue for the full amount of the award after allowable costs were incurred. Cause: Management was unaware that conditional grant revenue was required to be deferred until allowable costs under the federal grant agreement were incurred and did not record the related revenue in the proper period. Effect: Conditional grant revenue was understated by $593,838. This is considered a material weakness in the Organization’s internal control over financial reporting. Recommendation: We recommend that management ensure that conditional grant revenue is recognized upon incurrence of allowable costs under the federal grant. We also recommend that management enroll in a professional education program that covers Uniform Guidance compliance. Views of Responsible Officials and Planned Corrective Actions: Management has been making updates to its policies and procedures throughout 2024 to be in full compliance with GAAP and the Uniform Guidance. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 322032

Finding 499232 (2023-001)

Significant Deficiency 2023

Samaritas and Subsidiaries

MI

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management

For the Year Ended December 31, 2023 Finding Number 2023-001 Contact Person(s): Cynthia Sikina, Interim CFO Wendy Perry, Director of Budget & Contracts Corrective Action Planned: Contract terms will be reviewed to ensure understanding of the billing terms and will be documented in the contract manag...

For the Year Ended December 31, 2023 Finding Number 2023-001 Contact Person(s): Cynthia Sikina, Interim CFO Wendy Perry, Director of Budget & Contracts Corrective Action Planned: Contract terms will be reviewed to ensure understanding of the billing terms and will be documented in the contract management system in accordance with the Samaritas contract approval procedure. Cash draws will be aligned with actual cash expenditures for any cost reimbursement contract/grant to limit draws to immediate cash needs in accordance with Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D – Post Federal Award Requirements, Section 200.305 Federal Payment. Anticipated Completion Date: Date completed June 30, 2023

View Audit 322026

Finding 499231 (2023-002)

Material Weakness 2023

Everett Recovery Cafe

WA

Internal Control / Segregation of Duties Subrecipient Monitoring Period of Performance

Management’s Response: Management agrees with the finding. Management plans to complete a review of resources assigned to accounting and finance departments as well as identify and implement sufficient internal controls over expenditures cutoff to ensure compliance with the period of performance com...

Management’s Response: Management agrees with the finding. Management plans to complete a review of resources assigned to accounting and finance departments as well as identify and implement sufficient internal controls over expenditures cutoff to ensure compliance with the period of performance compliance requirement.

View Audit 322025

Finding 499230 (2023-001)

Material Weakness 2023

Everett Recovery Cafe

WA

Internal Control / Segregation of Duties

Management’s Response: Management agrees with the finding. Management plans to complete a review of resources assigned to accounting and finance departments as well as identify and implement sufficient internal controls over financial reporting.

View Audit 322025

Finding 499225 (2023-001)

Material Weakness 2023

American Samoa Alliance Against Domestic and Sexual Violence INC

AS

Allowable Costs / Cost Principles Material Weakness

Views of Responsible Officials: Management agrees. Processes will be put in place to document cost savings in writing when extended travel is necessary. This cost analysis will be filed along with board approval, so it is easily accessible upon request.

View Audit 322005

Finding 499214 (2023-001)

Material Weakness 2023

Southwest Behavioral Health Services, Inc. and Subsidiaries

AZ

Subrecipient Monitoring Reporting Material Weakness § 200.303

Finding Number: 2023-001- Schedule of Expenditures of Federal Awards (SEFA) Preparation – Material Weakness Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control ...

Finding Number: 2023-001- Schedule of Expenditures of Federal Awards (SEFA) Preparation – Material Weakness Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the federal award to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. This includes properly identifying all federal awards subject to the Uniform Guidance and fairly presenting the required information in the schedule of expenditures of federal awards. Condition: Subsequent to the issuance of the Audit Report on the Consolidated Financial Statements and Supplementary Information for the year ended September 30, 2023, it was discovered that there was an omission of two federal grants with expenditures totaling $1,591,715 from the schedule of expenditures of federal awards. Cause: The Organization did not communicate with Care 1st Health Plan regarding the details of certain contracts to determine the amounts were subject to the Uniform Guidance and were to be included on the schedule of expenditures of federal awards. In addition, Care 1st Health Plan became the Regional Behavioral Health Authority for the Northern Arizona region effective October 1, 2022. Due to this transition, various changes occurred causing uncertainties with classifications of certain types of federal awards as subrecipient awards versus as contractor payments. Effect: The schedule of expenditures of federal awards was understated by $1,591,715, which resulted in the restatement of the previously issued schedule of expenditures of federal awards to correct the omission. Questioned Costs: Not applicable. Recommendation: We recommend that all funding contracts are carefully reviewed to determine whether amounts awarded should be classified as contractor payments or as subrecipient payments. If there is any uncertainty, we recommend that the Organization contact the funding source for clarification. Name of Contact Person: Mike Fett, CFO Phone Number: 602-265-8338 Anticipated Completion Date: September 30, 2024 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will establish procedures to review all contracts and to if necessary, to communicate with funding sources to ensure that receipts of federal funding are properly classified as being subrecipient versus contractor arrangements to ensure completeness of the Schedule of Expenditures of Federal Awards.

View Audit 322000

Finding 499213 (2023-009)

Significant Deficiency 2023

Shatterproof A Nonprofit Corporation

CT

Internal Control / Segregation of Duties Cash Management Significant Deficiency

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management is in the process of implementing Bill.com, which will require review and approval by a direct supervisor or higher, to ensure proper segregation of duties for approval of expendi...

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management is in the process of implementing Bill.com, which will require review and approval by a direct supervisor or higher, to ensure proper segregation of duties for approval of expenditures. Management will also reinforce the importance of employees providing the appropriate invoices or supporting documentation for all expenditures submitted for payment. Expenditures will not be paid without the appropriate supporting documentation. All approvals will be tracked through an online system. In addition, management will reinforce the importance of reviewing the timing of when expenditures are incurred, to ensure they are recorded in the appropriate fiscal year. Anticipated completion date: Implemented November 2023

View Audit 321990

Finding 499206 (2023-008)

Significant Deficiency 2023

Shatterproof A Nonprofit Corporation

CT

Internal Control / Segregation of Duties Cash Management Significant Deficiency

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management is in the process of implementing Bill.com, which will require review and approval by a direct supervisor or higher, to ensure proper segregation of duties for approval of expendi...

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management is in the process of implementing Bill.com, which will require review and approval by a direct supervisor or higher, to ensure proper segregation of duties for approval of expenditures. Management will also reinforce the importance of employees providing the appropriate invoices or supporting documentation for all expenditures submitted for payment. Expenditures will not be paid without the appropriate supporting documentation. All approvals will be tracked through an online system. In addition, management will reinforce the importance of reviewing the timing of when expenditures are incurred, to ensure they are recorded in the appropriate fiscal year. Anticipated completion date: Implemented November 2023

View Audit 321990

Finding 499205 (2023-007)

Material Weakness 2023

Shatterproof A Nonprofit Corporation

CT

Cash Management Material Weakness

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Prior to any cost reimbursement invoices submitted, the invoices will be reviewed and approved by the State Manager or a Director of State Engagement to ensure amounts requested for reimburs...

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Prior to any cost reimbursement invoices submitted, the invoices will be reviewed and approved by the State Manager or a Director of State Engagement to ensure amounts requested for reimbursement were incurred prior to the reimbursement request and are related to costs that were properly allocated to the federal program. Anticipated completion date: Implemented October 2023

View Audit 321990

Finding 499198 (2023-006)

Material Weakness 2023

Shatterproof A Nonprofit Corporation

CT

Cash Management

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Prior to any cost reimbursement invoices submitted, the invoices will be reviewed and approved by the State Manager or a Director of State Engagement to ensure amounts requested for reimburs...

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Prior to any cost reimbursement invoices submitted, the invoices will be reviewed and approved by the State Manager or a Director of State Engagement to ensure amounts requested for reimbursement were incurred prior to the reimbursement request and are related to costs that were properly allocated to the federal program. Anticipated completion date: Implemented October 2023

View Audit 321990

Finding 499197 (2023-005)

Material Weakness 2023

Shatterproof A Nonprofit Corporation

CT

Questioned Costs Allowable Costs / Cost Principles

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent...

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent. The timesheets are then reviewed and approved by the program director or a direct supervisor. Anticipated completion date: Implemented June 2024

View Audit 321990 Questioned Costs: $1

Finding 499190 (2023-004)

Material Weakness 2023

Shatterproof A Nonprofit Corporation

CT

Questioned Costs Allowable Costs / Cost Principles

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent...

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent. The timesheets are then reviewed and approved by the program director or a direct supervisor. Anticipated completion date: Implemented June 2024

View Audit 321990 Questioned Costs: $1

Finding 499188 (2023-003)

None 2023

New York City Housing Authority

NY

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding Number 2023-003 PROCUREMENT AND SUSPENSION AND DEBARMENT – 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 Procurement And Suspension and Debarment - Non-federal en...

Finding Number 2023-003 PROCUREMENT AND SUSPENSION AND DEBARMENT – 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 Procurement And Suspension and Debarment - Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Non-federal entities receiving contracts from the federal government are required to comply with the contract clause at FAR 52.209-6 before entering into a subcontract that will exceed $30,000, other than a subcontract for a commercially available off-the-shelf item. Condition/Context The Authority received funding from the Public and Indian Housing Program. The Authority has procurement and suspension and Debarment policies. Of the sixty (60) vendor files selected for testing, we noted 3 vendor’s suspension and Debarment documentation were not provided by the Authority. The Authority did review suspension and Debarment status in SAM.GOV for the samples in question, which had no documentation of suspension and Debarment and all vendors were active and no suspensions noted. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program’s suspension and Debarment policies to ensure that all vendors are not suspended or debarred. Corrective Action Plan In June 2022, NYCHA implemented the Dun & Bradstreet (D&B) Supplier Risk Management tool for development/program units to check federal debarment status of micro vendors. In addition, in February 2023, NYCHA also implemented the self-certification debarment form for micro vendors. Currently, all micro vendors who wish to be placed on the Micro Prequalification List (Micro PQL) for Responsibility to be eligible for a micro award undergo an integrity/responsibility review by a centralized vendor responsibility department prior to being placed on the Micro PQL. This review includes debarment checks among many other integrity assessments. The Micro PQL will go in effect on September 30, 2024. Given that NYCHA’s micro spend comprises less than 4% of total spend in 2021 through 2023 (and approximately 1.1% as of Q3 of 2024), concomitant with the fact that NYCHA has already implemented corrective actions to ensure all vendors are checked for debarments, NYCHA believes the risk of this deficiency to be insignificant. Action Date Already implemented Final Implementation Already implemented Name And Phone Number Of Person Responsible For Implementation Sergio Paneque Chief Procurement Officer 212-306-3528 Sergio.paneque@nycha.nyc.gov

View Audit 321980 Questioned Costs: $1

Finding 499187 (2023-002)

None 2023

New York City Housing Authority

NY

Questioned Costs HUD Housing Programs Eligibility

Finding Number 2023-002 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 th...

Finding Number 2023-002 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: Eight eligibility forms were not provided (five missing application forms, one missing certifications information provided to the PHA forms and two missing Release form). 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 6,2024 Final Implementation September 6,2024 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 321980 Questioned Costs: $1

Finding 499186 (2023-001)

Material Weakness 2023

New York City Housing Authority

NY

HUD Housing Programs Material Weakness Special Tests & Provisions

Finding Number 2023-001 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 Provisio...

Finding Number 2023-001 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 2023 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 June 16, 2023 through December 15, 2023 and December 16, 2022 through July 15, 2023, we read extermination, heat outage, mold inspections, annual apartment inspections, and elevator outage reports for the months of February 2023; April 2023; July 2023; September 2023 and November. 2023. During our audit, we noted that the Authority did not complete all corrective actions in the 2023 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 $4,392,861,000 of pollution remediation obligations as of December 31, 2023, 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 Brad Greenburg Chief Compliance Officer 212-306-4240

View Audit 321980

Finding 499185 (2023-001)

Significant Deficiency 2023

Crossroads Young Men's Christian Association, Inc.

IN

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

STARTING IN QUARTER 4, 2023, ALL METHODOLOGY FOR TRACKING AND ALLOCATING WAGES HAS BEEN MOVED TO TRACKING VIA OUR HRIS SYSTEM. INSURANCE BENEFITS ARE CODED DIRECTLY FROM THE SOURCE DOCUMENT. ONLY FICA/MEDICARE IS BEING TRACKED VIA A SPREADSHEET, WHICH IS BEING REVIEWED EACH MONTH.

View Audit 321979

Finding 499184 (2023-001)

None 2023

Operator Foundation

TX

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions Finding Reference: 2023-001 Responsible Individual: Melissa Mason Operator Foundation received a pass-through, subgrant extension from a partner organization under 19.22 Regional Democracy Program during the calendar year 2023. The subgr...

Views of Responsible Officials and Planned Corrective Actions Finding Reference: 2023-001 Responsible Individual: Melissa Mason Operator Foundation received a pass-through, subgrant extension from a partner organization under 19.22 Regional Democracy Program during the calendar year 2023. The subgrant paperwork Operator received from the partner did not include an Audit Certification form. The form was later provided and requested by the pass through entity on March 18, 2024, and Operator provided the form on the same day that the email request was received. However, passthrough recipients are required to submit a completed Audit Certification Form within 30 days of the end of each subrecipient fiscal year. Operator’s controls did not realize that the form was missing from the provided award package. Corrective Action Plan (CAP) Operator Foundation will strengthen the internal controls as it relates to submitting required reports to its granting agencies by establishing policies and procedures to ensure that reporting information is submitted timely. Operator will review each grant at inception and list out requirements related to reporting and deadlines. Operator Foundation will ensure that all reporting requirements are put on the organizational tracking system including calendars and that reminders are set to ensure timely submission. Operator will communicate any missing requirements in award packages to the funder for the purpose of strengthening compliance of all responsible parties receiving federal funds. Anticipated Completion date: 10/31/2024

View Audit 321976

Finding 499182 (2023-004)

Significant Deficiency 2023

Shiloh Home Inc.

CO

Reporting Internal Control / Segregation of Duties Significant Deficiency § 200.328

Corrective Action Plan: Management is developing a process to include a periodic review of all compliance aspects related to the grants including financial and performance reporting. This will be completed by December 31, 2024. Individual responsible for corrective action plan: Steven Ramirez

View Audit 321973

Corrective Action Plans

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