Corrective Action Plans

Finding 569335 (2024-002)

Material Weakness 2024

SC

Questioned Costs Cash Management Eligibility § 200.302 § 200.305

Mov ing to Work Demonstra tion Program - Capital Fund ProgramALN: 14.881 Description: During testing of the Mov ing to Work Demonstration Program - Capital Fund Progra m, we selected a sample of eight elOCCS drawdown vouchers for rev iew. Of these, the Authority was unable to provide sufficient supp...

Mov ing to Work Demonstra tion Program - Capital Fund ProgramALN: 14.881 Description: During testing of the Mov ing to Work Demonstration Program - Capital Fund Progra m, we selected a sample of eight elOCCS drawdown vouchers for rev iew. Of these, the Authority was unable to provide sufficient supporting documentation to substantia te the eligibility, timing, or purpose of the draw d owns for four v ouchers. For another v oucher, the Authority could only partially support the a mount dra wn. These issues reflect a lack of a dequate documentation necessary to substantiate the allowability and propriety of the expenditure charged to the CFP grants. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility and "just-in-time" requirements prior to the Executive Director signing the request.

View Audit 360844 Questioned Costs: $1

Finding 569322 (2024-005)

Material Weakness 2024

Housing Authority of Florence

AL

Questioned Costs HUD Housing Programs Subrecipient Monitoring § 200.302 § 200.303

Title: Inadequate Tenant File Documentation and Inconsistencies in MTW Housing Assistance and Public Housing Records Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: During tenant file testing for both the Housing Choice Voucher (HCV) and Public Housing (PH) components ...

Title: Inadequate Tenant File Documentation and Inconsistencies in MTW Housing Assistance and Public Housing Records Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: During tenant file testing for both the Housing Choice Voucher (HCV) and Public Housing (PH) components of the Moving to Work (MTW) Demonstration Program, we identified multiple deficiencies in the Authority's documentation and reporting practices: 1. For the MTW HAP (HCV) sample, the Authority did not properly complete the "Summary Decision on the Unit" section of the HUD Form 52580-A, which documents the final pass or fail outcome of the Housing Quality Standards {HQS) inspection. As a result, it could not be confirmed whether the unit met HQS requirements at the time of assistance. 2. In six out of twenty-three HCV tenant files tested, housing assistance payments did not agree with the amounts reported on HUD Form 50058, and no reconciliations or explanations were provided. 3. For one out of twenty-three HCV tenants, the Authority was unable to provide a Form 50058 covering the period for which the HAP payment was selected, leaving the payment unsupported. 4. In the MTW Public Housing sample, five out of seventeen tenant files contained discrepancies between tenant receipts or rent register balances and the amounts reported on HUD Form 50058, without adequate explanation or reconciliation. 5. For one out of seventeen Public Housing tenants, the Authority was unable to provide any support for either the receipt from or payment to the tenant for the period tested. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a (a) process to ensure that Hud Form 52580-A is fully completed for all HQS inspections, documenting pass or fail outcomes, (b) establish procedures for reconciling housing assistance payments (HAP) and tenant rent payments with amounts reported on HUD Form 50058, documenting any

View Audit 360842 Questioned Costs: $1

Finding 569321 (2024-004)

Material Weakness 2024

Housing Authority of Florence

AL

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.302 § 200.334

Title: Missing Required Moving to Work (MTW) Demonstration Program Documentation Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide two critical documents required to...

Title: Missing Required Moving to Work (MTW) Demonstration Program Documentation Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide two critical documents required to support its eligibility and compliance under the MTW framework: he Authority did not provide a copy of its Annual Contributions Contract (ACC), which serves as the foundational agreement between the Authority and HUD for the receipt and use of federal funds. 2. The Authority also failed to provide a signed MTW Certification of Compliance for the most recent fiscal year, which affirms board approval of the MTW Plan and Report and verifies the Authority's adherence to MTW statutory objectives and HUD program requirements.Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to locate and archive the ACC and to complete an MTW Certification of Compliance.

View Audit 360842

Finding 569320 (2024-003)

Material Weakness 2024

Housing Authority of Florence

AL

Questioned Costs HUD Housing Programs Subrecipient Monitoring § 200.302 § 200.305

Title: Incomplete Support for Capital Fund Program (CFP) Drawdown Sample Program Name: Capital Fund Program ALN: 14.872 Description: As part of the testing of the Capital Fund Program (CFP) major program, a sample of six drawdown vouchers were selected for review. The Authority was unable to prov...

Title: Incomplete Support for Capital Fund Program (CFP) Drawdown Sample Program Name: Capital Fund Program ALN: 14.872 Description: As part of the testing of the Capital Fund Program (CFP) major program, a sample of six drawdown vouchers were selected for review. The Authority was unable to provide adequate supporting documentation for one voucher in the sample. The missing documentation prevented verification of the eligibility, timing, and allowability of the associated expenditures. Planned Corrective Action: Fiscal Vear 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility, timing, and allowability of the associated expenditures.

View Audit 360842 Questioned Costs: $1

Finding 569319 (2024-002)

Material Weakness 2024

Housing Authority of Florence

AL

Questioned Costs Cash Management § 200.302 § 200.305

Title: Unsupported MTW Capital Fund Program (CFP) Drawdowns Program Name: Moving to Work Demonstration Program - Capital Fund Program ALN: 14.881 Description: During testing of the Moving to Work Demonstration Program - Capital Fund Program, we selected a sample of eight eLOCCS drawdown vouchers ...

Title: Unsupported MTW Capital Fund Program (CFP) Drawdowns Program Name: Moving to Work Demonstration Program - Capital Fund Program ALN: 14.881 Description: During testing of the Moving to Work Demonstration Program - Capital Fund Program, we selected a sample of eight eLOCCS drawdown vouchers for review. Of these, the Authority was unable to provide sufficient supporting documentation to substantiate the eligibility, timing, or purpose of the drawdowns for two vouchers. In addition, for one voucher, the Authority did not provide evidence of immediate obligations or expenditures to support the drawdown, indicating a potential violation of the federal "just-in-time" funding requirement. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility and "just-in-time" requirements prior to the Executive Director signing the request.

View Audit 360842 Questioned Costs: $1

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

24 CFR 1000.128(b) income verification – income recertification for

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

continued occupancy and rent determination not consistently documented per policy

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

The Housing Authority’s internal policy provides for periodic income recertification for continued

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

occupancy and rent determination

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

Contact Person Sharon Vogel, Executive Director

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

Anticipated Completion Date; 9/30/2025

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

Action Plan: In 2024-2025 Cheyenne River Housing Authority conducted a major review of 100%

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

of its policies and procedures, including the Occupancy and Management Policy. The review consisted

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

of additions, deletions, and amendments, etc to ensure CRHA’s policies were updated, current and a

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

reflection of our management operations. The Board of Commissioners gave the final approval for the

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

policies. The issue of recertifications is addressed in our Occupancy and Management Policy.

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

Correction: CRHA will provide an orientation to the Occupancy staff on the procedures on how to

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

process annual recertifications for all tenants. Cheyenne River Housing Authority will conduct

View Audit 360837

Finding 569318 (2024-001)

Significant Deficiency 2024

Cheyenne River Housing Authority

SD

quarterly file audits of no more than ten percent of audit files to identify compliance.

View Audit 360837

Finding 569314 (2024-001)

None 2024

Pact, Inc.

DC

Subrecipient Monitoring Procurement, Suspension & Debarment

Corrective Action Plan: At the time of the misuse of the company vehicle (USAID Contract No. 72061123C00003), Pact had—and continues to have—effective internal controls in place for any project with approval to purchase vehicles. These include policies and procedures that comply with all applicable ...

Corrective Action Plan: At the time of the misuse of the company vehicle (USAID Contract No. 72061123C00003), Pact had—and continues to have—effective internal controls in place for any project with approval to purchase vehicles. These include policies and procedures that comply with all applicable laws and regulations and Pact policies, including the organization’s internal Code of Conduct, while aligning with the objectives and scope of work for the project. Pact’s guidelines specify roles and responsibilities and role assignments; identify authorized places to obtain fuel; where to store vehicle keys; where to park vehicles; and require individuals to enter detailed records regarding the use of the vehicle into a log. Pact controls enabled the employee to detect and promptly report the misuse of the vehicle, allowing the issue to be resolved with no financial impact to Pact or the USG. In alignment with Pact’s core principle of continuous quality improvement, and following the substantiation of the misuse, Pact developed and implemented a corrective action plan. This plan included a comprehensive quality review of existing controls to identify and address any policy or procedural gaps. In addition to maintaining and reinforcing the internal controls already in place, the plan introduced several additional measures: • Approval Limitation: Vehicle usage approval was restricted to no more than two individuals—one designated as the fleet manager and the other authorized to approve vehicle use. • Key Access Restriction: Access to vehicle keys stored in the secure storage box was limited exclusively to the fleet manager and the authorized approver. • Clarified Approval Procedures: Project-specific procedures were updated to require separate approvals for each instance of vehicle use, even if multiple uses occurred within the same day. • Mandatory Refresher Training: Employees were required to complete refresher training on the revised project-specific guidelines, office procedures for proper vehicle use, and applicable regulations, including any agency-specific requirement.

View Audit 360835

Finding 569307 (2024-037)

Significant Deficiency 2024

Government of the District of Columbia

DC

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

The Homeland Security and Emergency Management Agency (HSEMA) concurs that the subaward reporting required by FFATA is not currently complete and up to date in sam.gov website. Due to the transition to sam.gov and the FSRS system being terminated, the record of prior FFATA reports submitted that enc...

The Homeland Security and Emergency Management Agency (HSEMA) concurs that the subaward reporting required by FFATA is not currently complete and up to date in sam.gov website. Due to the transition to sam.gov and the FSRS system being terminated, the record of prior FFATA reports submitted that encountered errors and were left in partially complete status is no longer retrievable from the FSRS system to demonstrate that the report had been submitted. HSEMA is already in the process of updating processes and procedures to gather and submit the FFATA report in the new sam.gov system. HSEMA has already developed and tested a new approach to directly updating sam.gov through its API portal. We had previously noted the gaps in the data brought over from FSRS to sam.gov and understood that these gaps required corrective action. HSEMA will compare the sam.gov data to our current subawards lists and will update sam.gov in addition to reporting on new subawards as they are issued. We will also review sam.gov data for older closed grants to see if any of those need to be updated as well. Contact: Charles Madden, Grants Bureau Chief Estimated Completion Date: September 30, 2025 or earlier See Corrective Action Plan for chart/table

View Audit 360834

Finding 569306 (2024-036)

Significant Deficiency 2024

Government of the District of Columbia

DC

Reporting § 200.302 § 200.303

The Department of Behavioral Health (DBH) Office of the Chief Financial Officer (OCFO) concurs with this finding. Prior to the submission of the SEFA, the grant expenditures will be reviewed with the Accounting Officer, the AFO, and the Grants program manager for a detailed review of the SEFA to co...

The Department of Behavioral Health (DBH) Office of the Chief Financial Officer (OCFO) concurs with this finding. Prior to the submission of the SEFA, the grant expenditures will be reviewed with the Accounting Officer, the AFO, and the Grants program manager for a detailed review of the SEFA to confirm expenditures are correctly categorized by fund and grant, reconciles to the financial system and reflects the amount expended for subrecipients. Contact: Barbara S. Roberson, Accounting Officer, Human Support Services Cluster Estimated Completion Date: September 2025 See Corrective Action Plan for chart/table

View Audit 360834

Finding 569305 (2024-035)

Material Weakness 2024

Government of the District of Columbia

DC

Matching / Level of Effort / Earmarking § 200.303

The Department of Behavioral Health (DBH) concurs with this finding. In previous years the block grant budgets were allocated by set-asides/earmarks which made the expenditures easily trackable and verifiable. For fiscal year 2024, the DIFS budget was not structured in the system in the same manner...

The Department of Behavioral Health (DBH) concurs with this finding. In previous years the block grant budgets were allocated by set-asides/earmarks which made the expenditures easily trackable and verifiable. For fiscal year 2024, the DIFS budget was not structured in the system in the same manner. Beginning fiscal year 2026, DBH will create subtasks for each of the earmarks/set-asides within budgets to better segregate expenditures for these set-asides. Contact: Michael Neff, DBH Chief Operating Officer Adran Reid, Agency Fiscal Officer, Department of Behavioral Health & Deputy Mayor for Health and Human Services Ryelle Roddey, Deputy Chief Operating Officer Anthony Baffour, Director of Financial Services Renee Evans Jackman, Director of Grants Management Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

View Audit 360834

Finding 569304 (2024-034)

Material Weakness 2024

Government of the District of Columbia

DC

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

The Department of Behavioral Health (DBH) agrees with the findings and will put controls in place to resolve the issue. To ensure documentation of employees who are paid in full or in part with federal grant funds, DBH will enact a time and effort certification standard operating procedure (SOP) in...

The Department of Behavioral Health (DBH) agrees with the findings and will put controls in place to resolve the issue. To ensure documentation of employees who are paid in full or in part with federal grant funds, DBH will enact a time and effort certification standard operating procedure (SOP) in conjunction with the Agency Operations Administration and Office of the Chief Financial Officer. The SOP will direct the supervisor to review a payroll report generated by the OCFO providing each employee’s percentage of time charged to the assigned fund source. A form will allow supervisors to certify the employee has performed the duties that align with the funding source. The certification will be required at least quarterly for employee’s funded 100% and at least monthly for employee’s funded by more than one funding source. Creation, execution and monitoring of SOP: Draft SOP, September 1, 2025 Contact: Michael Neff, DBH Chief Operating Officer Virtual training to all affected employees, September 15, 2025 Contact: Adran Reid, Agency Fiscal Officer, Department of Behavioral Health & Deputy Mayor for Health and Human Services Contact: Ryelle Roddey, Deputy Chief Operating Officer Anthony Baffour, Director of Financial Services Renee Evans Jackman, Director of Grants Management Estimated Completion Date: Operationalize, October 1, 2025 See Corrective Action Plan for chart/table

View Audit 360834 Questioned Costs: $1

Finding 569303 (2024-033)

Material Weakness 2024

Government of the District of Columbia

DC

Matching / Level of Effort / Earmarking § 200.303

The Department of Health (DC Health) concurs with the finding. While DC Health reported match and level of effort expenditures in total, there was not sufficient documentation to distinguish 100% of the components of the match and LOE required. This detail included account-types/classifications, acc...

The Department of Health (DC Health) concurs with the finding. While DC Health reported match and level of effort expenditures in total, there was not sufficient documentation to distinguish 100% of the components of the match and LOE required. This detail included account-types/classifications, account numbers, allocation amounts and service areas needed to total the match and LOE requirements. DC Health will conduct a root cause analysis to determine factors contributing to the deficiency issues found in this finding. The results should minimally direct DC Health on the development of an internal protocol to: (1) create a match and level of effort (LOE) plan ensuring sign-off by the program manager, budget responsible manager in HAHSTA and the OCFO; (2) conduct a quarterly review and certification of match and LOE spending to ensure program expenditure details align with the reports of the financial system, and the agency is meeting the required thresholds, and (3) ensure that all match and LOE support documents are stored properly and accessible by program and fiscal managers for reconciliation and for reporting purposes. Brenda Ramsey-Boone, Deputy Director of Operations (HAHSTA) Contact: Clara Ann McLaughlin, Chief – Office of Grants Management Estimated Completion Date: October 31, 2025 See Corrective Action Plan for chart/table

View Audit 360834

Corrective Action Plans

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