Corrective Action Plans

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Reference Number: 2025-004 No secondary review of meal claim reimbursements prior to submission Corrective Action Plan: The District will implement procedures that incorporate a second review of meal reimbursement claims before the request is submitted for reimbursement during the monthly processing...
Reference Number: 2025-004 No secondary review of meal claim reimbursements prior to submission Corrective Action Plan: The District will implement procedures that incorporate a second review of meal reimbursement claims before the request is submitted for reimbursement during the monthly processing. Contact Person: Cristina Campbell Implementation Time Frame: August 31, 2026
Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College is in agreement with the finding. At the time of noncompliance in this area the college was transitioning to a new software system for the college. The ...
Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College is in agreement with the finding. At the time of noncompliance in this area the college was transitioning to a new software system for the college. The software was required to “go dark” for a period time and during this time no processing could be completed. Because of other issues with the system, the R2T4 timeline for returning the funds was not calculated correctly and the deadline was missed by a few days. Administration did not realize the error until after the deadline had passed. As soon as the error was found, the process was completed immediately. We do not expect to have this issue in the future. The R2T4 process for review has always been that one person in the financial aid office is responsible for completing the process and another person reviews the documents once the process is complete. We will continue this process and look for other procedures to implement to ensure an accurate R2T4 process is completed.
Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. The college realizes this is a repeat finding and we have struggled with compliance in this area due to the inadequacy of the s...
Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. The college realizes this is a repeat finding and we have struggled with compliance in this area due to the inadequacy of the system we were using and turnover in the financial aid office and the registrar’s office. With the new system, and the more seasoned personnel in each of the departments, we strive to make improvements in the enrollment reporting process. We are still actively running monthly processes to review enrollment reporting data to ensure the accuracy of our reporting. The new system will aid us in doing these processes better and continued training with personnel will be prioritized. We will continue to review policy and procedures and look for ways to make this process better.
Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of this noncompliance the College was implementing a new financial aid system (JFA). The financi...
Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of this noncompliance the College was implementing a new financial aid system (JFA). The financial aid system went live in July 2024. The business office module did not go live until November 2024. The college’s IT implemented a bridge to connect the two systems while we waited for the business office module to go live. There were issues with the bridge between the two systems which caused the aid posting process to work inaccurately. We immediately contacted IT to help with the situation, but they took longer than expected to find a solution. Because we knew time was of the essence and our system would be “going dark” (unable to process anything for a period of time), we manually started processing aid in order to post aid to student accounts so that students could receive their refunds. The financial aid system had disbursement dates already set up and all of those dates had to be manually updated. Unfortunately, the College missed updating one date for the student that was found during audit, and the date that was reported to COD was the original disbursement date instead of the actual disbursement date. The system no longer requires the bridge, and we have not experienced any issues since all systems came on board. Now that the system is working properly, there is a process that looks at the disbursement date on the student account and compares it to what the financial aid system has in place. If the dates do not match, the system automatically updates the disbursement date in the financial aid system and there is a file that is generated to send an update to COD automatically. We do not expect to have this issue in the future but have implemented processes to review disbursement dates through the reconciliation process in the new system.
Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of noncompliance the college was transitioning to a new financial aid system. The compliance eng...
Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of noncompliance the college was transitioning to a new financial aid system. The compliance engine of the new system was set up but there was a gap in the compliance which allowed aid for students who were not enrolled to post without warning. The issue was found by the financial aid administrators and corrected as soon as it was discovered. Upon finding the issues, the financial aid administrators reached out to the IT department for more training on the compliance portion of the software and have worked diligently to update the system and put in place processes that will ensure that aid is canceled for students that are not enrolled. The system also has compliance setup to ensure checks and balances are in place to look for students who are eligible to receive aid and will not post aid for students who are not enrolled even if the aid has not been canceled before the official disbursement date.
Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-002 - Procur...
Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-002 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6, 2 H80CS00646-24-01, 1 H8LCS51923-01-00 for 2024 and 2025, 1 H8NCS54043-01- 00 for 2025 - (Significant Deficiency) During our audit, we noted that certain employees have no record of an exclusion search conducted during 2025. There were also certain employees for whom an exclusion search was not consistently conducted on a monthly basis. Recommendation We recommend that the Center train its personnel in relation to the exclusion screening and proper documentation thereof and that the Center conduct regular reviews to ensure the completeness of exclusion search documentation. Action Taken Management agrees with the finding and will be conducting training for its personnel to help ensure the accuracy, completeness and timeliness of exclusion searches. Effectivity Date: June 30, 2026
Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-001 - Specia...
Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-001 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6, 2 H80CS00646-24-01, 1 H8LCS51923-01-00 for 2024 and 2025, 1 H8NCS54043-01- 00 for 2025 - (Significant Deficiency) During our audit, we noted that the Center did not properly determine the sliding fee discount for one eligible patient, based on information provided during the patient registration process. Recommendation We recommend that the Center provide training to all personnel involved in determining patients’ sliding fee discounts. In addition, we recommend that an internal audit of a sample of patient charts be conducted periodically to verify that sliding fee scale discounts or categories are properly and accurately determined based on the information provided by patients. Finally, we recommend that the results of such internal audits be formally documented. Action Taken Management agrees with the finding and will be establishing policies and procedures and conducting training for all personnel involved in determining patients' sliding fee discounts to help ensure the accuracy of the process. Management will also implement an internal audit of a sample of patient charts and will ensure that such audits are properly documented. Effectivity Date: June 30, 2026
2025-001 Monitoring of Subrecipients Agency: National Aeronautics & Space Administration Program Titles: Surviving a mass extinction: Lessons from the post K-Pg fern spike Grant Numbers: 80NSSC23K1013 Contact Person: Emily Schwarz, Chief Financial Officer (718) 817-8730 Corrective Action: Subsequent...
2025-001 Monitoring of Subrecipients Agency: National Aeronautics & Space Administration Program Titles: Surviving a mass extinction: Lessons from the post K-Pg fern spike Grant Numbers: 80NSSC23K1013 Contact Person: Emily Schwarz, Chief Financial Officer (718) 817-8730 Corrective Action: Subsequent to year end, the Garden obtained and reviewed Single Audit filings for all its Subrecipients from the Federal Audit Clearinghouse. In the Garden’s review of the Subrecipient Single Audit Reports, it did not note any findings related to its Federal programs. The Garden has implemented a control to continue to obtain and review the Single Audit filings for its Subrecipients on an annual basis. Anticipated Completion Date: Plan implemented immediately, and then continues on an ongoing basis.
To the Department of Housing and Urban Development, During the audit of the Housing Authority’s fiscal year ended June 30, 2025 financial statements, it was determined that the unaudited financial data schedule that is utilized as the Housing Authority’s underlying financial statements were not prop...
To the Department of Housing and Urban Development, During the audit of the Housing Authority’s fiscal year ended June 30, 2025 financial statements, it was determined that the unaudited financial data schedule that is utilized as the Housing Authority’s underlying financial statements were not properly stated. Significant errors existed regarding grant receivables, the allowance for doubtful accounts - tenants, capital assets, accounts payable, grant revenues and bad debt expense. Also, a desk review was performed by HUD and it was determined that the Housing Authority had not properly documented its calculation of monthly voucher leased amounts and it understated its Housing Assistance Payment expenses in its VMS reporting. The Housing Authority’s Executive Director, Ashiya Hawkins, is responsible for implementing the corrective action plan. Finding 2025-002 - VMS Reporting Deficiencies We concur with the recommendation and we will establish standard operating procedures that ensure that the HAP amounts and number of vouchers stated on the VMS report are both accurate and properly documented. We are working with our software provider to ensure that VMS reporting software is being fully and correctly utilized. We are also planning on additional training for HCV employees to make sure they are qualified to meet VMS reporting and documentation requirements.
Sliding Fee Discount Supporting Documentation - Significant Deficiency 2025-002 Valley Healthcare System, Inc. acknowledges that supporting documentation used to determine sliding fee discounts should be consistenly maintained. Valley Healthcare System, Inc. will implement procedures and controls to...
Sliding Fee Discount Supporting Documentation - Significant Deficiency 2025-002 Valley Healthcare System, Inc. acknowledges that supporting documentation used to determine sliding fee discounts should be consistenly maintained. Valley Healthcare System, Inc. will implement procedures and controls to ensure that documentation is consistently maintained.
3/20/2026 Community Action Team, Inc. respectfully submits the following corrective action plan for the year ending June 30, 2025. Kern & Thompson, LLC: Audit period: July 1, 2024 to June 30, 2025 The finding from the schedule of findings are discussed below. FINANCIAL STATEMENT FINDINGS 2025-001 Fe...
3/20/2026 Community Action Team, Inc. respectfully submits the following corrective action plan for the year ending June 30, 2025. Kern & Thompson, LLC: Audit period: July 1, 2024 to June 30, 2025 The finding from the schedule of findings are discussed below. FINANCIAL STATEMENT FINDINGS 2025-001 Federal Award Special Reporting Federal Funding Accountability and Transparency Act (FFATA) Material Non-Compliance and Material Weakness in Internal Controls over Compliance (Repeat of finding 2023-003, 2024-002) Recommendation: The Organization should establish written policies and procedures regarding review of grant agreements for compliance requirements along with written policies and procedures for first-tier subawards including tracking and proper internal control procedures. Action Taken: Management concurs with the finding and has defined corrective action to address it. We understand a material weakness is identified in the internal control over special reporting. We have identified gaps in our reporting processes and worked to implement changes to ensure compliance with special reporting requirements. The responsibility for reporting under the Federal Funding Accountability and Transparency Act (FFATA) will be within the Fiscal Department. Policies and procedures will be updated regarding special reporting requirements. The Fiscal department will also be responsible for reviewing all contracts to identify all compliance requirements. Tracking procedures will be implemented to ensure reports are filed timely. The above identified corrective action was implemented in July 2024 and subsequent filing for 2025 and 2026 are compliant. Stacey Wilson, Fiscal Director, has implemented a tracking system for the FFATA. Should you have any questions regarding this plan, please contact me at 503-366-6563. Sincerely, Daniel Brown Executive Director
Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...
Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing
Finding Number: 2025-003 – Untimely Submission of Federal Financial Report (SF-425) Planned Corrective Action: American Rivers hired a Grants Director in January 2026, and the required SF-425 reporting will be the director’s responsibility to ensure compliance with all required reporting. Anticipate...
Finding Number: 2025-003 – Untimely Submission of Federal Financial Report (SF-425) Planned Corrective Action: American Rivers hired a Grants Director in January 2026, and the required SF-425 reporting will be the director’s responsibility to ensure compliance with all required reporting. Anticipated Completion Date: 02/28/2026 Responsible Contact Person: Vickie Barrow-Klein, Chief Financial Officer
Finding Number: 2025-002 – Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting Not Performed Planned Corrective Action: American Rivers hired a Grants Director in January 2026 and the FFATA reporting will be the director’s responsibility to ensure compliance with all FFATA...
Finding Number: 2025-002 – Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting Not Performed Planned Corrective Action: American Rivers hired a Grants Director in January 2026 and the FFATA reporting will be the director’s responsibility to ensure compliance with all FFATA and other required reporting. Anticipated Completion Date: 02/28/2026 Responsible Contact Person: Vickie Barrow-Klein, Chief Financial Officer
2025-001 Certified Payroll Reporting Federal Assistance Listing Number: 84.041 Program: Impact Aid Federal Agency: U.S. Department of Education Pass-Through Number: N/A Compliance Requirement: N. Special Tests and Provisions Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Noncompliance (...
2025-001 Certified Payroll Reporting Federal Assistance Listing Number: 84.041 Program: Impact Aid Federal Agency: U.S. Department of Education Pass-Through Number: N/A Compliance Requirement: N. Special Tests and Provisions Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: $-0- Repeat Finding: Similar to finding 2024-002. Condition/Context: The District did not retain documentation sufficient to determine the Davis-Bacon compliance clause was included in advertised specifications for construction projects paid with federal Impact Aid monies. In addition, for nine of 10 vendors selected weekly certified payrolls were not collected and maintained for any relevant weeks during the fiscal year. Corrective Action: The District will implement monitoring procedures over the procurement process to ensure provisions of the Davis-Bacon Act are implemented into contracts and that certified payrolls are obtained, when necessary. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Lori Wilson, Business Manager
It is the goal of the Corporation to maintain compliance with regulatory requirements. Where hardships are encountered, the Corporation remains in ongoing communication with respective regulatory agencies to promote transparency and mitigate risk of loss in funding or default.
It is the goal of the Corporation to maintain compliance with regulatory requirements. Where hardships are encountered, the Corporation remains in ongoing communication with respective regulatory agencies to promote transparency and mitigate risk of loss in funding or default.
Finding #2025-002: #84.184X – Wisconsin Well Be’s School-Based Mental Health Consortium Federal Grantor Agency: U.S. Department of Education Compliance Requirement: Cash Management Condition: During our audit procedures, it was determined that there was miscommunication between the grant manager and...
Finding #2025-002: #84.184X – Wisconsin Well Be’s School-Based Mental Health Consortium Federal Grantor Agency: U.S. Department of Education Compliance Requirement: Cash Management Condition: During our audit procedures, it was determined that there was miscommunication between the grant manager and the business manager. Therefore, an additional claim was made which resulted in the District receiving federal funds in excess of immediate needs. Effect: The District received federal funds in excess of immediate needs and before disbursement for allowable program costs. Cause: The District’s internal controls failed to identify a duplicate claim submitted for federal funds. Criteria: It is necessary under U.S. Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called "Uniform Guidance") and under most federal grant agreements that the recipient must implement financial management system that provide proper fund control, which ensures funds used in a timely fashion. Recommendation: We recommend that the District implement a pre-submission check to verify that invoices have not been previously claimed. Response: The funds were fully used up in the following fiscal year as expenditures were incurred. The grant funding has been cut as of December 31, 2025. This finding has been resolved.
Finding #2025-001: #84.184X – Wisconsin Well Be’s School-Based Mental Health Consortium Federal Grantor Agency: U.S. Department of Education Compliance Requirement: Subrecipient Monitoring Condition: During our audit procedures, it was determined that the District did not review supporting documenta...
Finding #2025-001: #84.184X – Wisconsin Well Be’s School-Based Mental Health Consortium Federal Grantor Agency: U.S. Department of Education Compliance Requirement: Subrecipient Monitoring Condition: During our audit procedures, it was determined that the District did not review supporting documentation such as invoices or pay records from subrecipient schools claiming funds. Although there is a Google shared document that summarizes expenditures claimed, subrecipient schools did not submit invoices to the grant manager for review and approval. Additionally, there was no formal written agreement between the District and the subrecipient to document the terms and conditions of the subrecipient awards. Effect: The District’s system of monitoring is not sufficient, formal, or uniform which could result in unallowable expenditures and misunderstandings between the District and the subrecipients. Cause: The District does not have adequate review and approval processes and formal written agreements for the subrecipients. Criteria: It is necessary under U.S. Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called "Uniform Guidance") and under most federal grant agreements that any federal funds passed through to a subrecipient be appropriately monitored and that the subrecipient is properly informed of the grant requirements. Recommendation: We recommend that the District review invoices from the subrecipient schools and have written agreements signed by all parties that fully explain the federal grant requirements and include other appropriate language to protect the District and to further document the District’s compliance regarding subrecipient monitoring. Response: The grant funding has been cut as of December 31, 2025. The District did not implement the recommended procedures above as there are currently no other subrecipient relationships.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the Academy implemented a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Explanation of disagreement with audit finding: T...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the Academy implemented a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Coordinators have been instructed to run the credit balance report more frequently after aid has been posted to identify students with a credit balance. Also, once a request has been made to rectify the credit balance, it will become top priority to ensure its completion is within 10 days. Name(s) of the contact person(s) responsible for corrective action: Rachael Farnell Planned completion date for corrective action plan: 07/01/2025 If the Department of Education has questions regarding this plan, please call Rachael Farnell at (612-278-5271)
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy reevaluate its policies around accurate R2T4 calculations as well as timely return of funds to COD. Explanation of disagreement with audit finding: There is no disagreement with the audit f...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy reevaluate its policies around accurate R2T4 calculations as well as timely return of funds to COD. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: R2T4 calculations will now be handled by the Financial Aid Manager & to ensure timely refunds; the Financial Aid Manager will process R2T4’s every two weeks to ensure the timeliness of any refunds. Name(s) of the contact person(s) responsible for corrective action: Rachael Farnell Planned completion date for corrective action plan: 07/01/2025
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy implement a process to ensure student is being properly awarded based on their SAI and enrollment status. Explanation of disagreement with audit finding: There is no disagreement with the a...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy implement a process to ensure student is being properly awarded based on their SAI and enrollment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Coordinators now have a corrected calculator to use when determining the student’s Pell eligibility based on their SAI. The Financial Aid Manager will also look over the award to ensure proper funding has been put into place. Name(s) of the contact person(s) responsible for corrective action: Rachael Farnell Planned completion date for corrective action plan: 07/01/2025
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit find...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Per finding 2025-002, Summit Academy has been completing the control piece when processing Title IV aid. To further the control of this process, the Financial Aid Manager will provide initials to show evidence of review. Name(s) of the contact person(s) responsible for corrective action: Rachael Farnell Planned completion date for corrective action plan: 07/01/2025
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explana...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Manager will run reports every thirty days and students will be certified in NSLDS every 30 days to ensure their enrollment status is reported in a timely manner. The Financial Aid Manager is also tracking the NSLDS changes on a spreadsheet. Name(s) of the contact person(s) responsible for corrective action: Rachael Farnell Planned completion date for corrective action plan: 07/01/2025
Federal Single Audit Finding: 2025-001 Reporting - Significant Deficiency in Internal Control over Compliance Name of Contact Person: Adrienne Gaines, Executive Director Corrective Action: WISH will reinforce existing policies requiring documented evidence of review and approval for all key reports....
Federal Single Audit Finding: 2025-001 Reporting - Significant Deficiency in Internal Control over Compliance Name of Contact Person: Adrienne Gaines, Executive Director Corrective Action: WISH will reinforce existing policies requiring documented evidence of review and approval for all key reports. These controls will ensure approval via physical signature or electronic approval via email correspondence of each key report. Periodic monitoring will be performed to ensure compliance with documentation requirements. Proposed Completion Date: June 30, 2026
CORRECTIVE ACTION PLAN March 18, 2026 Housing for Rockdale Elders, Inc. respectfully submits the following corrective action plans for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: Nove...
CORRECTIVE ACTION PLAN March 18, 2026 Housing for Rockdale Elders, Inc. respectfully submits the following corrective action plans for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The findings from the October 31, 2025 schedule of findings and questioned costs is discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2025-003 - Eligibility - Material Weakness Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Action Taken: Management agrees with the finding and is in the process of revising internal controls to address this issue.
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