Corrective Action Plans

Finding 384386 (2023-002)

Significant Deficiency 2023

Lutheran Family Services in the Carolinas and Affiliates

NC

Allowable Costs / Cost Principles Significant Deficiency

Finding 2023-002 Name of contact person: Kirby Nickerson Corrective action: Management agrees with the finding and will take corrective action to update policies and procedures to ensure that the accounting for nonroutine transactions comply with generally accepted accounting principles. Proposed...

Finding 2023-002 Name of contact person: Kirby Nickerson Corrective action: Management agrees with the finding and will take corrective action to update policies and procedures to ensure that the accounting for nonroutine transactions comply with generally accepted accounting principles. Proposed completion date: March 31, 2024

View Audit 297490

Finding 384369 (2023-001)

Significant Deficiency 2023

The New Reidsville Housing Authority

NC

HUD Housing Programs Eligibility Significant Deficiency

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Noncompliance & Significant Deficiency – Housing Choice Voucher Program – ALN 14.871 The New Reidsville Housing Authority suffered a tremendous loss with the passing of the Housing Choice Voucher (HCV) and Public Housing Special...

Finding 2023-001 – Housing Choice Voucher Tenant Files – Eligibility – Noncompliance & Significant Deficiency – Housing Choice Voucher Program – ALN 14.871 The New Reidsville Housing Authority suffered a tremendous loss with the passing of the Housing Choice Voucher (HCV) and Public Housing Specialists within weeks of one another and immediately before the start of the fiscal year. As a small housing authority, the deaths of two of the five office employees who had a combined 33 years of Authority experience left a significant void in knowledge and experience. Although the two employees were cross trained on each other’s jobs, no remaining employees were fully trained or capable of assuming those positions or responsibilities. In the immediate months after the passing of the employees, temporary and consultant labor was utilized until the Authority filled the vacant positions. Unfortunately, employee turnover among the new hires created further voids in HCV personnel during and after the fiscal year. Although a comprehensive review of all tenant and participant files to ensure completeness and compliance had begun prior to the audit, the sudden declining health and subsequent passing of the Executive Director hindered efforts even further. All new and existing housing personnel have received and continue to receive housing-related training and cross training on both the Public and Housing Choice Voucher programs. Comprehensive file review, written documentation of all tasks, and an office-wide evaluation of processes will continue as the employees become accustomed to their new positions. Corrective Action Plan: We concur with this finding. We are emphasizing the importance of accurate and complete tenant file information with our staff and within their new positions. We are confident these errors and oversights will not occur in the future. An extensive tenant file review was underway but was not completed at the time of the audit. All staff are being trained in their positions, and future cross-training and peer review processes are currently being put into practice to execute an added layer of review for all tenant files. Person Responsible: Samantha Shumaker, Interim Director Anticipated Completion Date: June 30, 2024

View Audit 297483

Finding 384368 (2023-002)

Significant Deficiency 2023

The New Reidsville Housing Authority

NC

Questioned Costs HUD Housing Programs Eligibility

Finding 2023-002 – Low Income Public Housing Tenant Files – Eligibility – Noncompliance & Significant Deficiency – Public and Indian Housing – ALN 14.850 The New Reidsville Housing Authority suffered a tremendous loss with the passing of the Housing Choice Voucher and Public Housing Specialists wi...

Finding 2023-002 – Low Income Public Housing Tenant Files – Eligibility – Noncompliance & Significant Deficiency – Public and Indian Housing – ALN 14.850 The New Reidsville Housing Authority suffered a tremendous loss with the passing of the Housing Choice Voucher and Public Housing Specialists within weeks of one another and immediately before the start of the fiscal year. As a small housing authority, the deaths of two of the five office employees who had a combined 33 years of Authority experience left a significant void in knowledge and experience. Although the two employees were cross trained on each other’s jobs, no remaining employees were fully trained or capable of assuming those positions or responsibilities. In the months after the passing of the PH Specialist, temporary labor was utilized until such time as the position was filled on a permanent basis. Although a comprehensive review of all tenant and participant files to ensure completeness and compliance had begun prior to the audit, the sudden declining health and subsequent passing of the Executive Director hindered efforts even further. All new and existing housing personnel have received and continue to receive housing-related software-specific training and cross training on both the Public and Housing Choice Voucher programs. Comprehensive file review, written documentation of all tasks, and an office-wide evaluation of processes will continue as the employees become accustomed to their new positions. Corrective Action Plan: We concur with this finding. We are emphasizing the importance of accurate tenant file information, data entry, and calculations with our staff in their new positions. We are confident these errors and oversights will not occur in the future. An extensive tenant file review was underway but was not completed at the time of the audit. A thorough tenant file audit to detect and correct any misstatements will begin as well. All staff are being trained in their positions, and future cross-training and peer review processes are currently being put into practice to execute an added layer of review for all tenant files. Person Responsible: Samantha Shumaker, Interim Director Anticipated Completion Date: June 30, 2024

View Audit 297483 Questioned Costs: $1

Finding 384366 (2023-001)

Significant Deficiency 2023

The Rodney Scheel House Foundation, Ltd.

WI

HUD Housing Programs Cash Management

Finding 2023-001 – Replacement and Residual Reserve Submissions Corrective Action Plan The Rodney Scheel House Foundation, Ltd. will review their policies and procedures surrounding replacement reserve and residual receipts reserve cash remittances to the reserve bank accounts within the required HU...

Finding 2023-001 – Replacement and Residual Reserve Submissions Corrective Action Plan The Rodney Scheel House Foundation, Ltd. will review their policies and procedures surrounding replacement reserve and residual receipts reserve cash remittances to the reserve bank accounts within the required HUD timeframes. The Foundation will discuss requirements with the property management company and establish the properly timeline to ensure the deposits are made within the required timeframes. Person(s) Responsible: Kendra Eppler, Nicole Solheim, Curt Peerenboom Timing for Implementation: Immediate

View Audit 297478

Finding 384365 (2023-003)

None 2023

Eastern University

PA

Questioned Costs Eligibility Internal Control / Segregation of Duties

Incorrect Pell Calculations Planned Corrective Action: All of our undergraduate programs now follow a similar calendar pattern and enrollment requirements which will prevent issues when a student switches from one type of program to another. Person Responsible for Corrective Action Plan: Andrea Rut...

Incorrect Pell Calculations Planned Corrective Action: All of our undergraduate programs now follow a similar calendar pattern and enrollment requirements which will prevent issues when a student switches from one type of program to another. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: Completed

View Audit 297474 Questioned Costs: $1

Finding 384359 (2023-002)

Significant Deficiency 2023

Eastern University

PA

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University concurs with the audit finding of partial compliance and recognizes the need to fully comply with GLBA regulations. The University has updated its written risk assessment. The University is working on improving safeg...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University concurs with the audit finding of partial compliance and recognizes the need to fully comply with GLBA regulations. The University has updated its written risk assessment. The University is working on improving safeguards, improving continuous monitoring provided from a vendor, implementing procedures for staff training which will be required for all employees, implementing procedures for assessing service providers, documenting an incident response plan, and completing a written annual status report to the board. Person Responsible for Corrective Action Plan: Eric McCloy, CIO Anticipated Date of Completion: April 30, 2024. Board report will be June 30, 2024.

View Audit 297474

Finding 384358 (2023-001)

Material Weakness 2023

Eastern University

PA

Student Financial Aid Material Weakness Reporting

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and deter...

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and determined that we made the proper adjustments for 21-22, a complete and detailed review for 22-23 to correct any incorrect R2T4’s was completed. This resulted in untimely returns but has since been resolved. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: August 2023

View Audit 297474

Finding 384354 (2023-001)

Significant Deficiency 2023

University of Denver

CO

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated fed...

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: As of January 2024, the University implemented a monthly process for the coordinated review of stale-dated checks. After the close of each month, the Accountant II and Business Analyst in the Controller’s Office prepares a report of stale-dated checks and sends the report to the Assistant Director of Student Accounts and the Student Accounts Business Analyst in University Financial Services. These staff members identify federal funds to be returned to the Department of Education. The Office of Student Accounts works with the Office of Financial Aid to ensure funds are returned. This process has addressed any backlog of checks, and the monthly process keeps the University current in processing stale-dated checks and returning funds in a timely manner. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Effective immediately.

View Audit 297469 Questioned Costs: $1

Finding 384353 (2023-002)

Significant Deficiency 2023

University of Denver

CO

Student Financial Aid Matching / Level of Effort / Earmarking

Condition: During our testing, we noted two of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University determined th...

Condition: During our testing, we noted two of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University determined there are a total of 39 Perkins loans with missing MPNs. Of these, 6 loans are with 3rd party collection agencies, 19 are paid in full and 14 are in repayment. For these 39 loans, the University determined that alternative documentation such as exit counseling and repayment records has been retained. The Perkins Assignment and Liquidation Guide (p.4), ED tells schools to collect alternative documentation, explain the reason the note is missing and affirm the school has searched all records for each loan missing documentation. Due to the discontinuance of the Perkins loan program, no new MPNs will be issued. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Corrective action plan completed in August 2023.

View Audit 297469

Finding 384352 (2023-003)

Significant Deficiency 2023

University of Denver

CO

Subrecipient Monitoring Reporting Special Tests & Provisions

Condition: During testing to determine if the required quarterly reports were both timely and accurate/supported by the University’s books and records, we noted that quarterly reports were not being filed timely. Of the report ultimately submitted, confirmation of the submission was not maintained,...

Condition: During testing to determine if the required quarterly reports were both timely and accurate/supported by the University’s books and records, we noted that quarterly reports were not being filed timely. Of the report ultimately submitted, confirmation of the submission was not maintained, and we could not test the accuracy of the submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: When new grants and awards are received, the University should designate ownership of compliance, including reporting requirements. Processes and controls should be implemented to ensure accurate and timely reporting occurs as required by grant requirements. In addition, reports and supporting documentation should be retained for audit and review purposes. The Office of Research and Sponsored Programs (ORSP) has identified an employee in the Morgridge College of Education who will be responsible for preparing and submitting the quarterly reports due on January 5, 2024, April 5, 2024, and July 5, 2024, after which the program will be complete and subsequently, the July 5, 2024, quarterly report will be final. The department will be required to submit a copy of the quarterly reports to ORSP to be stored in our Electronic Research Administration system (InfoEd). Name of the contact person responsible for corrective action: Julie Cunningham, Senior Director of Sponsored Programs Administration. Planned completion date for corrective action plan: Effective immediately.

View Audit 297469

Finding 384346 (2023-003)

Material Weakness 2023

Southeast Dubois County School Corporation

IN

Equipment & Real Property Management Procurement, Suspension & Debarment Material Weakness § 200.303 § 200.313

FINDING 2023-003 Finding Subject: COVID-19 Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation maintained a detailed listing of capital assets; however, the asset records provided for audit did not include two capitalized expenditures in t...

FINDING 2023-003 Finding Subject: COVID-19 Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation maintained a detailed listing of capital assets; however, the asset records provided for audit did not include two capitalized expenditures in the amounts of $70,000 and $26,440 related to the replacement of rooftop air conditioning units. Additionally, the capital asset listing provided did not identify which assets were purchased with federal dollars nor did the assets have an assigned serial number or other identification number. Contact Person Responsible for Corrective Action: Tracy Troesch Contact Phone Number and Email Address: 812-817-0900; tracy.troesch@sedubois.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager has added the two assets referenced above to the asset records. Additionally, the Business Manager has reviewed the capital asset records and noted all capital assets that were purchased with federal funds. The School Corporation will determine a way to assign identification numbers to the assets listed on the record. Anticipated Completion Date: September 2024

View Audit 297465

Finding 384342 (2023-002)

Material Weakness 2023

Southeast Dubois County School Corporation

IN

Procurement, Suspension & Debarment § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2023-002 Finding Subject: Child Nutrition Cluster -Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective...

FINDING 2023-002 Finding Subject: Child Nutrition Cluster -Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance with Procurement, Suspension and Debarment. The School Corporation entered into more than $50,000 of like/kind transactions with a single vendor during FY2022 and FY2023 without entering into a contract or properly verifying that the vendor was not suspended or debarred. Contact Person Responsible for Corrective Action: Tracy Troesch Contact Phone Number and Email Address: 812-817-0900; tracy.troesch@sedubois.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager will review the vendors related to covered transactions and determine if like/kind transactions with any vendor are approaching or are expected to exceed $50,000. For vendors that meet the criteria of requiring a contract, the Business manager will obtain a contract, which will be reviewed and approved by the school board. The Business Manager will upload the purchase order and quote or other documentation of any purchase over $50,000 on Indiana Gateway for Government Units (Gateway) after board approval. Southeast Dubois County School Corporation followed the corrective action that was issued during the prior audit for Suspension and Debarment. During the current audit, the State Board of Accounts indicated that the corrective action and steps that were taken to verify compliance that the School Corporation was instructed to do were not adequate. Going forward, the Business Manager will run monthly vendor reports to determine if any vendors are close to the $25,000 to get a Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion form from the IN Department of Education needs to be issued to a vendor. If a vendor is close to the $25,000 mark, the Business Manager will send the Certification to be returned prior to future payment. Anticipated Completion Date: September 2024

View Audit 297465

Finding 384341 (2023-001)

Significant Deficiency 2023

Chatham County Partnership for Children

NC

Cash Management Reporting

a. Comments on the Finding and Each Recommendation The finding is due to circumstances of the lead employee for the task, the Finance Assistant. This staff member was taken ill during the holiday and did not notify the Executive Director. The notification from the bank of the deposit of funds was ov...

a. Comments on the Finding and Each Recommendation The finding is due to circumstances of the lead employee for the task, the Finance Assistant. This staff member was taken ill during the holiday and did not notify the Executive Director. The notification from the bank of the deposit of funds was overlooked by other staff who were on vacation with family for the Christmas holiday. As soon as the oversight was detected by the Food Program Manager, the payment was initiated and transferred within 7 days of receipt, 2 days longer than it should have been. b. Action(s) Taken or Planned on the Finding A communication process was initiated so that the 3 staff involved in the payment process (the ED, Finance Assistant, and the Food Program Manager), coordinate their time off so that one is designated to be on the lookout for bank notifications. Also, there is better communication with the NEW Finance Assistant about illness and time off so that alternate coverage for bank notification and payment processing can be put in place.

View Audit 297458

Finding 384339 (2023-001)

Significant Deficiency 2023

Chestnut Health Systems, INC

IL

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.430

An automated reporting process of salaries through our payroll provider (ADP) has been established to eliminate the manual data entry of payroll amounts. This will eliminate the opportunity for errors in manual salary entries.

View Audit 297454 Questioned Costs: $1

Finding 384323 (2023-002)

Material Weakness 2023

Northern Nevada International Center

NV

Questioned Costs Allowable Costs / Cost Principles Cash Management

2023-002 Compliance and Internal Control Systems Over Allowable Costs/Cost Principles and Cash Management - U.S. Department of Health & Human Services, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Assistance Listing Number 93.566 Criteria: As defined in 45 CFR 75...

2023-002 Compliance and Internal Control Systems Over Allowable Costs/Cost Principles and Cash Management - U.S. Department of Health & Human Services, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Assistance Listing Number 93.566 Criteria: As defined in 45 CFR 75, the auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award, including all allowable indirect and fringe cost rates. Condition: The Center requested indirect costs in excess of expenses incurred. Cause: The Center utilized a historical process to calculate and request indirect costs for reimbursement that was not updated to account for the increase in federal grant awards during the fiscal year. Effect: Reimbursement requests related to indirect costs not incurred resulted in the Center receiving federal award funding in excess of what was allowable. Known Questioned Costs: Requests for reimbursement of indirect costs exceeded indirect costs incurred by $51,980 for this federal award program. Repeat Finding: No Recommendation: We recommend that management design and implement a system whereby only incurred and allowable indirect expenses are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Center experienced significant growth in its federal awards during the fiscal year that were not commensurate with the growth in its overhead and indirect costs. As a result, the processes used in prior years to capture and request indirect costs for reimbursement were no longer effective. The Center will reconcile the accounting class utilized in its general ledger system at least quarterly to ensure indirect costs incurred are equal to or exceed the indirect costs requested for reimbursement under federal grant awards. Carina A. Black, Ph.D. Executive Director cblack@unr.edu/775.250.5454

View Audit 297448 Questioned Costs: $1

Finding 384322 (2023-003)

Significant Deficiency 2023

Erikson Institute

IL

Cash Management Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than ...

Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than one percent of total prior year drawdowns, were not returned within a seven day tolerance period. Corrective Action Plan A Student Bursar was hired in November 2022 and onboarding included comprehensive federal funds cash management training with an outside consultant. A review of cash management policies in place was conducted at that time and monitoring procedures and reconciliations were enhanced to eliminate excess cash. Contact Person Christine Frankhauser Controller cfrankhauser@erikson.edu Anticipated Completion Date January 2023

View Audit 297439

Finding 384321 (2023-002)

Significant Deficiency 2023

Erikson Institute

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Reg...

Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Registration, & Records, who oversees the Registration & Records office has taken steps to ensure timely and accurate reporting moving forward. In summer 2023, a new full-time Registrar was hired to oversee the office. Additionally, Erikson has updated the functioning of its student information system in ways that are compatible with timely and accurate reporting. Changes to the system have been tested and implemented. Lastly, Erikson created a new Business Analyst position and is in the process of hiring to oversee administration and maintenance of the student information system in ways that will continue to facilitate timely reporting and data integrity. Contact Person Leanne Beaudoin Ryan, PhD Director of Research, Registration, & Records lbeaudoinryan@erikson.edu Anticipated Completion Date Updates to processes and procedures were completed in September 2023. Transition from outsourced staffing to the newly-created position is expected by May 2024.

View Audit 297439

Finding 384318 (2023-001)

Significant Deficiency 2023

Erikson Institute

IL

Internal Control / Segregation of Duties Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding 2023-001: Gramm-Leach Bliley Act—Student Information Security While the Institute does have various policies addressing information security, the Institute did not have written policies to address the required safeguards for the eight required elements under the Gramm-Leach Bliley Act (GL...

Finding 2023-001: Gramm-Leach Bliley Act—Student Information Security While the Institute does have various policies addressing information security, the Institute did not have written policies to address the required safeguards for the eight required elements under the Gramm-Leach Bliley Act (GLBA) by June 9, 2023, the required date of compliance. Of the eight required elements under the GLBA, the Institute did have six written and formally documented safeguards, one is not applicable (assess apps developed by institution) and one had safeguards designed (dispose of customer information securely) but not a written policy in place. Corrective Action Plan A comprehensive formal Information Security Policy that addresses all required safeguards under the GLBA has been drafted, and as of March 2024 is in its final institutional review with approval expected in April 2024. Contact Person Ed Baker IT Director ebaker@erikson.edu Anticipated Completion Date April 2024

View Audit 297439

Finding 384307 (2023-002)

Significant Deficiency 2023

Desert Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS w...

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS website.

View Audit 297438

Finding 384306 (2023-001)

Significant Deficiency 2023

Desert Community College District

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

The District concurs with the finding. The District will establish procedures such as monthly reconciliation for return to Title IV calculations to identify the funds that need to be returned and ensure that funds are returned within 45 days.

View Audit 297438

Finding 384303 (2023-002)

Significant Deficiency 2023

National Association of Criminal Defence Lawyers, Inc.

DC

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213

Views of Responsible Officials: Management acknowledges the comment and has subsequently established policies and procedures to ensure suspension and debarment checks of vendors, supplies, contractors, and sub-contractors/grantees are done in accordance with the recommended threshold.

View Audit 297433

Finding 384302 (2023-001)

Significant Deficiency 2023

National Association of Criminal Defence Lawyers, Inc.

DC

Procurement, Suspension & Debarment § 200.318

Views of Responsible Officials: Management acknowledges the comment and subsequent to fiscal year end; has implemented internal procedures to ensure procurement is performed and documented for purchases in excess of our purchase threshold.

View Audit 297433

Finding 384299 (2023-004)

Material Weakness 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Material Weakness

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over HQS failed inspections to ensure they are following up timely on correction or properly abating HAP for the unit until correction. Explanation of disagr...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over HQS failed inspections to ensure they are following up timely on correction or properly abating HAP for the unit until correction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As noted above, the Authority has contracted the services of a third-party vendor and hired a Senior Quality Control Inspector to assist with the completion of inspections. As part of the Quality Control Plan the Authority tracks failed inspections. In addition to monitoring failed inspections, The Authority has required trainings or HCVP Department staff and partner agency staff, including HQS standards and HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE). Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Finding 384296 (2023-003)

Significant Deficiency 2023

Virginia Housing Development Authority

VA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their processes over annual and quality-control inspections to ensure they are completed timely and in compliance with HUD’s requirements. Explanation of disagreement with...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their processes over annual and quality-control inspections to ensure they are completed timely and in compliance with HUD’s requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has contracted the services of a third-party vendor to assist with completing overdue inspections. The Authority has also hired a Senior Quality Control Inspector to assist with the completion of overdue inspections. The Senior Quality Control Inspector will develop a Quality Control Plan by [date]. The Authority is currently making software upgrades to align with HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE). In addition, the Authority is assessing technology needs of inspectors and considering possible technological improvements. Currently, The Authority PCOs have begun to monitor late inspections monthly. PCOs work with the LHAs to develop a plan to address late inspections and include a due date. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024.

View Audit 297428

Finding 384293 (2023-002)

Material Weakness 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Material Weakness

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over reasonable rent determination to ensure that it is done timely, and that the approved rent is properly carried forward to the HUD-50058 and HAP Contract/...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over reasonable rent determination to ensure that it is done timely, and that the approved rent is properly carried forward to the HUD-50058 and HAP Contract/HAP Contract Amendment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has developed a checklist system for each step in the process for determining and documenting rent reasonableness. The checklist includes each step of the process, along with due dates, and responsible entities. As part of the development and implementation of the quality control process for the HAP process, noted above, the Authority will also include a process for ensuring approved rent reasonableness match contract rents on all supporting documentation. The Authority will implement monthly reviews of HUD-50058 forms, HAP contracts and rent reasonableness documentation by the Housing Choice Voucher Program Compliance Manager. The Authority PCOs and/or HCVP’s accounting staff will work closely together, coordinate and follow the procedures for correcting any issues identified during the reviews. The Authority will also develop and implement a monitoring plan to ensure Local Housing Agencies (LHAs) are correctly following all the Authority established policies and procedures and adhering to Federal Regulations. The monitoring plan will outline how The Authority will conducts a risk analysis to target monitoring resources to the highest risk LHAs. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Corrective Action Plans

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