Corrective Action Plans

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Re: Home Investment Partnerships Program (HOME), Federal Assistance Listing #14.239 County Department Department of Planning and Development (DPD) Finding 2025 001 Cause: Post Pandemic allocations to the County included several housing related fundings and initiatives, including Emergency Rental Ass...
Re: Home Investment Partnerships Program (HOME), Federal Assistance Listing #14.239 County Department Department of Planning and Development (DPD) Finding 2025 001 Cause: Post Pandemic allocations to the County included several housing related fundings and initiatives, including Emergency Rental Assistance I & II (ERA I& II), Homeless Sheltering, Homeless and Transitional Sheltering Physical Site Acquisition and Development, HOME ARPA (HUD Allocation), and HOME, CDBG CV development delays that challenged the Housing teams provision of services and compliance requirement. While HUD had extended post-pandemic compliance moratoriums into fiscal year 2024, Housing team hiring, training and implementation of compliance activities were unable to activate fully in the subject fiscal year to meet compliance. Team initial compliance training was implemented in FY 2025. DPD hired three additional staffers for a total of five to support compliance investigations moving forward. Corrective Action Plan: Special Test on Housing Quality Standards 1. Compliance training activities will continue to be coordinated by the Bureau's Compliance Management Team to strengthen program oversight and compliance efforts. As part of this initiative, 100% of Housing Team staff and management will receive compliance training, be qualified to perform compliance-related functions, and be assigned appropriate compliance responsibilities. a. All Housing Team staff and management will complete compliance training through HUD-sponsored virtual training or HUD-approved in-person training by November 30, 2026. b. Five of eight staffers will have hands-on site qualifications demonstrated by task and verified by management by November 30, 2026. 2. Required compliance planning for HOME programs will be completed by September 30, 2026. a. Plan will be reviewed and approved by Deputy Director and submitted to the Director by September 30, 2026. b. Initial site inspection appointments will be completed by October 31, 2026 c. Initial site physical inspections will commence by November 30, 2026. 3. Deputy Director will ensure that compliance site investigations and on-site file review will be completed by May 31, 2027. a. All reporting for respective site investigations shall be filed by above date b. All required communication to developer/owner teams shall be completed, mail and confirmation receipt by above date. Subrecipient Monitoring The department classified costs as subrecipient expenditures but should have classified as developer costs. Developer costs are not subject to subrecipient monitoring requirements under the Uniform Guidance. Therefore, the corrective action will be to assign a unique account code to address the finding where subrecipient monitoring will no longer apply. Grants Finance Manager will work with the Bureau of Finance to assign a unique account code by July 31, 2026. Endorsed By: Susan M. Campbell, Director
Material Weakness in Internal Control Over Financial Reporting The Agency’s year-end financial reporting controls did not detect and correct a material misstatement related to client assistance pass-through funding prior to the commencement of audit procedures. The misstatement related, in part, to ...
Material Weakness in Internal Control Over Financial Reporting The Agency’s year-end financial reporting controls did not detect and correct a material misstatement related to client assistance pass-through funding prior to the commencement of audit procedures. The misstatement related, in part, to the year-end confirmation and reconciliation process with State pass-through agencies. As a result, a material audit adjustment was required to properly state the financial statements in accordance with accounting principles generally accepted in the United States of America (GAAP). Management concurs with the finding. CAANH terminated its fiduciary services contract with NOI in 2025 and engaged CohnReznick with a start date of October 1, 2025, as its new fiduciary services provider. Management will continue to ensure that all year-end financial reporting, account reconciliations, and confirmation processes are completed in a timely manner. In addition, management will verify that all financial transactions are accurately recorded and reviewed prior to the commencement of the annual audit to support complete, accurate, and timely financial reporting. Amos Smith, President & CEO Will be in operation for all future audit periods.
Identify a new Auditing firm with proven experience working with FQHCs and their unique compliance requirements and revenue sources. Hire consultant to oversee the Audit process Engage Hough Consults to serve as the Interim CFO in response to the resignation of previous finance consultant. This cons...
Identify a new Auditing firm with proven experience working with FQHCs and their unique compliance requirements and revenue sources. Hire consultant to oversee the Audit process Engage Hough Consults to serve as the Interim CFO in response to the resignation of previous finance consultant. This consultant will review and address finance/Grants compliance gaps, review policies, create audit compliant month end workflows, oversee hiring of financial team. Hough Consults to train new finance team which includes the permanent CFO, accounts payable staff and NH executive team on new policies and procedures. Audit, Tax filing and Grant deadlines to be tracked by the VP/CFO
The Housing Authority has addressed the staffing levels for the program and is working with HUD to secure reimbursements for under funded HAP remittances. Additionally, the Authority is working with HUD to utilize reserve funds to alleviate the issue.
The Housing Authority has addressed the staffing levels for the program and is working with HUD to secure reimbursements for under funded HAP remittances. Additionally, the Authority is working with HUD to utilize reserve funds to alleviate the issue.
Finding 1222774 (2025-003)
Material Weakness 2025
Material Audit Adjustments
Material Audit Adjustments
Finding 1222774 (2025-003)
Material Weakness 2025
Recommendation: We recommend the City review its year-end close procedures to make sure that all balance sheet accounts are reviewed for the correct balance before final numbers are presented.
Recommendation: We recommend the City review its year-end close procedures to make sure that all balance sheet accounts are reviewed for the correct balance before final numbers are presented.
Finding 1222774 (2025-003)
Material Weakness 2025
Management’s Response and Actions Planned: The City will review its year-end close procedures to insure all balance sheet accounts have been reviewed and reconciled to the trial balance.
Management’s Response and Actions Planned: The City will review its year-end close procedures to insure all balance sheet accounts have been reviewed and reconciled to the trial balance.
Finding 1222773 (2025-002)
Material Weakness 2025
Preparation of Financial Statements and Related Footnotes
Preparation of Financial Statements and Related Footnotes
Finding 1222773 (2025-002)
Material Weakness 2025
Recommendation: This control deficiency is not unusual in a small city. However, it is the responsibility of management and the Council to decide whether to accept the degree of risk associated with this condition based on the cost of correction and other considerations.
Recommendation: This control deficiency is not unusual in a small city. However, it is the responsibility of management and the Council to decide whether to accept the degree of risk associated with this condition based on the cost of correction and other considerations.
Finding 1222773 (2025-002)
Material Weakness 2025
Management’s Response and Actions Planned: The City’s management is aware of this significant deficiency. Management reviews and approves the draft annual audited financial statements and distributes them to the users. For entities of this size, it generally is not practical to obtain the internal e...
Management’s Response and Actions Planned: The City’s management is aware of this significant deficiency. Management reviews and approves the draft annual audited financial statements and distributes them to the users. For entities of this size, it generally is not practical to obtain the internal expertise needed to handle all aspects of the external financial reporting. Management recognizes this and feels it is effectively handling its reporting responsibilities with the procedures described above.
Finding 1222772 (2025-001)
Material Weakness 2025
Segregation of Duties
Segregation of Duties
Finding 1222772 (2025-001)
Material Weakness 2025
Recommendation: While we recognize the City’s office staff is not large enough to permit an adequate segregation of duties in all respects for an effective internal control structure, it is important that the City be aware of this condition and look for opportunities to improve segregation of duties...
Recommendation: While we recognize the City’s office staff is not large enough to permit an adequate segregation of duties in all respects for an effective internal control structure, it is important that the City be aware of this condition and look for opportunities to improve segregation of duties or add mitigating controls to prevent material misstatement of the financial statements.
Finding 1222772 (2025-001)
Material Weakness 2025
Management’s Response and Actions Planned: The City’s management is aware of this condition and believes that it is not economically feasible to attain the ideal segregation of duties. Management attempts to mitigate the associated risks by doing the following:
Management’s Response and Actions Planned: The City’s management is aware of this condition and believes that it is not economically feasible to attain the ideal segregation of duties. Management attempts to mitigate the associated risks by doing the following:
Finding 1222772 (2025-001)
Material Weakness 2025
1. Identifies areas where the lack of segregation of duties exists and where there are higher risks of errors or fraud occurring.
1. Identifies areas where the lack of segregation of duties exists and where there are higher risks of errors or fraud occurring.
Finding 1222772 (2025-001)
Material Weakness 2025
2. Implements limited segregation to the extent possible to reduce risks without impairing efficiency.
2. Implements limited segregation to the extent possible to reduce risks without impairing efficiency.
Finding 1222772 (2025-001)
Material Weakness 2025
3. Uses the knowledge that management and the Board of Directors have of operations by having them review certain accounting records and reports.
3. Uses the knowledge that management and the Board of Directors have of operations by having them review certain accounting records and reports.
Finding 1222772 (2025-001)
Material Weakness 2025
Monitors the effectiveness of the above actions and makes changes as considered appropriate.
Monitors the effectiveness of the above actions and makes changes as considered appropriate.
2025-001 Finding SDSI Housing Corporation, Inc. (SDSI Housing) received reimbursement from the reserve for replacements of $135,824 for roof repairs that were previously funded with insurance proceeds. The reserve for replacements is under funded by $135,824 due to the reimbursement of ineligible it...
2025-001 Finding SDSI Housing Corporation, Inc. (SDSI Housing) received reimbursement from the reserve for replacements of $135,824 for roof repairs that were previously funded with insurance proceeds. The reserve for replacements is under funded by $135,824 due to the reimbursement of ineligible items. A reimbursement request was submitted for major roof repairs which are traditionally contemplated as eligible for draws under HUD Occupancy Handbook 4350.3 REV-1. However, management did not consider the fact that such repairs had already been funded by insurance proceeds, so the major roof repairs resulted in no cost to the Project. Comments on Finding and Recommendations Management agrees with the finding and recomendations. Actions Taken Management returned ineligible funds of $135,824 to reserve for replacements on April 16, 2026.
Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2025. Planned Corrective Action – The Agency will take all reasonable measures to work with the new auditors to complete the audit process and submit the data coll...
Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2025. Planned Corrective Action – The Agency will take all reasonable measures to work with the new auditors to complete the audit process and submit the data collection report within the required time period. Anticipated Date of Correction – The 2026 data collection form for the year ended June 30, 2026, will be issued to GSA within the required deadline of the earlier of thirty days after issuance of the 2026 audit or prior to March 31, 2027. Point of Contact: James Williams, Fiscal Officer/Program Director
The City will review procedures for federal procurements to ensure procurement policy is followed starting on September 1, 2026.
The City will review procedures for federal procurements to ensure procurement policy is followed starting on September 1, 2026.
A policy and procedure will be established to ensure the City documents independent review on future reports starting on September 1, 2026.
A policy and procedure will be established to ensure the City documents independent review on future reports starting on September 1, 2026.
We will review procedures and attempt to make the necessary changes by September 1, 2026 to improve internal control.
We will review procedures and attempt to make the necessary changes by September 1, 2026 to improve internal control.
1. Proposed Corrective Action: Our agency will migrate all time sheets to digital, which will be input and tracked by the employee and submitted each payroll. That timesheet will then be reviewed and approved by the Director of Operations before payroll is disbursed. Digital timesheets will be avail...
1. Proposed Corrective Action: Our agency will migrate all time sheets to digital, which will be input and tracked by the employee and submitted each payroll. That timesheet will then be reviewed and approved by the Director of Operations before payroll is disbursed. Digital timesheets will be available on demand going forward. 2. Timeline for Implementation: This process has already been completed.
Tyler Luce, Executive Vice President & CFO, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Ste 1 Lansing, MI 48912 Audit period: October 1, 2024 –...
Tyler Luce, Executive Vice President & CFO, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Ste 1 Lansing, MI 48912 Audit period: October 1, 2024 – September 30, 2025 The findings from the September 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2025-001 Recommendation: The entity should design and implement stronger internal controls over project funds, including enhanced segregation of duties, documented procurement procedures, conflict-of-interest monitoring, and periodic independent review of project expenditures to ensure compliance with Uniform Guidance. Management Comments: We agree with the facts and circumstances of this finding. Management has taken corrective action in response to this finding. The employees involved are no longer employed in connection with the project, and the matter was reported to the HUD Office of Inspector General. Management has reviewed and strengthened the project's controls over conflict-of-interest monitoring and enforcement of existing time-clock policies. In addition, we have and will continue to perform independent reviews of project expenditures to ensure compliance with Uniform Guidance.
SCRANTON PRIMARY HEALTH CARE CENTER INC IN FUTURE FILINGS OF THE DATA COLLECTION FORM AND REPORTING PACKAGE WILL OBTAIN AND COMPILE ON A TIMELY BASIS TO ALLOW THE REPORT TO BE FILED NO LATER THAN NINE MONTHS AFTER THE END OF THE AUDIT PERIOD OR EXTENDED PERIOD ALLOWED BY THE OFFICE OF MANAGEMENT AND...
SCRANTON PRIMARY HEALTH CARE CENTER INC IN FUTURE FILINGS OF THE DATA COLLECTION FORM AND REPORTING PACKAGE WILL OBTAIN AND COMPILE ON A TIMELY BASIS TO ALLOW THE REPORT TO BE FILED NO LATER THAN NINE MONTHS AFTER THE END OF THE AUDIT PERIOD OR EXTENDED PERIOD ALLOWED BY THE OFFICE OF MANAGEMENT AND BUDGET.
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