Corrective Action Plans

Finding 1157574 (2024-002)

Material Weakness 2024

MA

HUD Housing Programs Reporting

Name of Auditee: Newton Housing Authority EFPR Group, CP As, PLLC December 31, 2024 Name of Audit Firm: Period Covered by the Audit: CAP Prepared by: Michael Lara, Executive Director Phone: (718) 382-5332 (A)Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Fin...

Name of Auditee: Newton Housing Authority EFPR Group, CP As, PLLC December 31, 2024 Name of Audit Firm: Period Covered by the Audit: CAP Prepared by: Michael Lara, Executive Director Phone: (718) 382-5332 (A)Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action taken - The Authority will review and verify key line items (including restricted net position, unrestricted net position and cash and investments) against the general ledger prior to VMS submission. Supervisory review will be required to confirm accuracy. ( c) Planned implementation date - The Authority plans to implement procedures during the year ending December 31, 2025 to resolve the reported finding.

View Audit 369807

Finding 1157573 (2024-002)

Material Weakness 2024

Rock County

WI

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2024-002 Program ALN: 21.027 Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award Number/Year: Not applicable / 2021 Federal Agency: U.S. Department of Treasury Repeat of Finding 2023-004 Condition The County was not able to provide evidence that the suspen...

Finding 2024-002 Program ALN: 21.027 Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award Number/Year: Not applicable / 2021 Federal Agency: U.S. Department of Treasury Repeat of Finding 2023-004 Condition The County was not able to provide evidence that the suspension and debarment verification was completed for the three contractors selected for testing. The sample was not statistically valid. Corrective Action Plan Corrective Action Planned: Training has been provided to the County’s Purchasing division regarding the requirement to review and record evidence that verification is completed on vendors prior to contracting. Name(s) of Contact Person(s) Responsible for Corrective Action: Kristin Vander Kooi, Rock County Finance Director Anticipated Completion Date: September 18, 2024

View Audit 369805

Finding 1157572 (2024-010)

Material Weakness 2024

Philadelphia Legal Assistance Center, Inc.

PA

Questioned Costs Eligibility Internal Control / Segregation of Duties

Corrective Action Plan Provided by Management: Philadelphia Legal Assistance Center, Inc. (PLA) agrees with the finding. In November 2024, PLA hired a Legal Compliance Specialist whose full-time job is to review open and closed cases for compliance mistakes. The Legal Compliance Specialist did not h...

Corrective Action Plan Provided by Management: Philadelphia Legal Assistance Center, Inc. (PLA) agrees with the finding. In November 2024, PLA hired a Legal Compliance Specialist whose full-time job is to review open and closed cases for compliance mistakes. The Legal Compliance Specialist did not have time to review every case closed in 2024. However, the Legal Compliance Specialist has been reviewing cases all year in 2025 and catching issues with missing citizenship attestations, which should reduce the chances of a case being reported to LSC without the documentation required by 45 C.F.R. 1626. In the summer of 2025, we required all case handlers to watch compliance training videos and answer multiple-choice questions to test their knowledge. The videos and questions included content related to 45 C.F.R. 1626. We plan to require staff to complete a similar training process in 2026, which will include additional content related to 45 C.F.R. 1626 compliance.

View Audit 369802 Questioned Costs: $1

Finding 1157571 (2024-005)

Material Weakness 2024

Wilmington Neighborhood Conservancy Land Bank

DE

Allowable Costs / Cost Principles § 200.430

Re: Management’s Response & Corrective Action Plan to Salary Certifications Finding (2024-005) The Wilmington Land Bank charged allowable payroll expense to the SLFRF Program from October 11, 2022 through December 31, 2024. During the September 2025 audit, the Land Bank obtained certifications from ...

Re: Management’s Response & Corrective Action Plan to Salary Certifications Finding (2024-005) The Wilmington Land Bank charged allowable payroll expense to the SLFRF Program from October 11, 2022 through December 31, 2024. During the September 2025 audit, the Land Bank obtained certifications from each employee to document percentage of time dedicated to each SLFRF project. To ensure timely documentation and address this deficiency, the Land Bank’s Director of Finance & Grants will collect employee certifications on a quarterly basis going forward. Responsible Individual: Becky Vogel, Director of Finance & Grants Anticipated Completion Date: Already corrected

View Audit 369799

Finding 1157570 (2024-004)

Material Weakness 2024

Wilmington Neighborhood Conservancy Land Bank

DE

Procurement, Suspension & Debarment § 200.318 § 200.320

Re: Management’s Response & Corrective Action Plan to Procurement Policy & Procurement Action Documentation (2024-004) The Wilmington Land Bank adopted a written Procurement Policy on September 11, 2024. At one property, however, the policy was not fully followed. The Land Bank initially considered ...

Re: Management’s Response & Corrective Action Plan to Procurement Policy & Procurement Action Documentation (2024-004) The Wilmington Land Bank adopted a written Procurement Policy on September 11, 2024. At one property, however, the policy was not fully followed. The Land Bank initially considered the work a continuation of an existing project, but it was later determined that it should have been bid separately under the Procurement Policy. To strengthen compliance with the Procurement Policy going forward, the Land Bank will hold weekly internal staff meetings and weekly meetings with the City of Wilmington. These meetings will include a review of project updates and related procurement actions. Responsible Individual: Becky Vogel, Director of Finance & Grants Anticipated Completion Date: Already corrected

View Audit 369799

Finding 1157569 (2024-002)

Material Weakness 2024

Montgomery County Housing Authority

PA

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Views of Responsible Officials and Planned Corrective Action: The Authority has recognized the deficiencies in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Rossaine Ricketts, Comptroller, is responsible for implement...

Views of Responsible Officials and Planned Corrective Action: The Authority has recognized the deficiencies in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Rossaine Ricketts, Comptroller, is responsible for implementing this corrective action by December 31, 2025.

View Audit 369797

Finding 1157568 (2024-001)

Material Weakness 2024

Montgomery County Housing Authority

PA

Questioned Costs HUD Housing Programs

Views of Responsible Officials and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authorty will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Rossaine Ricketts, Com...

Views of Responsible Officials and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authorty will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Rossaine Ricketts, Comptroller, is responsible for implementing this corrective action by December 31, 2025.

View Audit 369797 Questioned Costs: $1

Finding 1157565 (2024-001)

Material Weakness 2024

Northwest Senior Housing Corporation

CT

HUD Housing Programs

Action Taken: The Project made the required 12 th replacement reserve deposit in March 2025 . The Project has also applied for a significant rent increase, effective 1/1/26, that would cure the Project' s cash issues and allow it to keep up with monthly replacement reserve deposits.

View Audit 369795

Finding 1157564 (2024-001)

Material Weakness 2024

Outreach Community Health Centers, Inc.

WI

Internal Control / Segregation of Duties

Staffing & Structure: A dedicated Patient Financial Counselor (PFC) position was created and filled on November 27, 2023. A second staff member was transitioned into a PFC role on April 7, 2024, to augment the team. Training & Education: A dedicated Patient Financial Counselor (PFC) position was cre...

Staffing & Structure: A dedicated Patient Financial Counselor (PFC) position was created and filled on November 27, 2023. A second staff member was transitioned into a PFC role on April 7, 2024, to augment the team. Training & Education: A dedicated Patient Financial Counselor (PFC) position was created and filled on November 27, 2023. A second staff member was transitioned into a PFC role on April 7, 2024, to augment the team. Process & Technology Improvements: Monthly Audits: Implement ongoing monthly audits of sliding fee applications to proactively identify and address errors. Staff will receive targeted training based on audit findings. System Enhancement: Awaiting implementation of the Epic Patient Financial Module (released August 2024) to enable real-time tracking and improve outreach to eligible patients.

View Audit 369793

Finding 1157563 (2024-002)

Material Weakness 2024

Pacific Housing Oahu Corporation - Elderly Residence

HI

Eligibility HUD Housing Programs Significant Deficiency

Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files during management transitions to ensu...

Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files during management transitions to ensure compliance with HUD requirements. Action Taken: The Company will start randomly testing a small sample of tenant files, as part of our quarterly site inspection. Additionally, Kay-Kay Realty, a third-party vendor is already engaged to review tenant move-in and recertification files, but the prior resident manager was selecting the files to review. We will now ask Kay-Kay Realty to randomly select tenant files for their review process. Contact person: Patrick Delaney; (808) 523-5681, ext. 693 Anticipated Completion Date: October 1, 2025

View Audit 369792

Finding 1157562 (2024-001)

Material Weakness 2024

Pacific Housing Oahu Corporation - Elderly Residence

HI

Eligibility HUD Housing Programs Significant Deficiency § 200.332

Ref. No. 2024-001: Missing Signatures Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files...

Ref. No. 2024-001: Missing Signatures Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files during management transitions to ensure compliance with HUD requirements. Action Taken: The Company will start randomly testing a small sample of tenant files, as part of our quarterly site inspection. Additionally, Kay-Kay Realty, a third-party vendor is already engaged to review tenant move-in and recertification files, but the prior resident manager was selecting the files to review. We will now ask Kay-Kay Realty to randomly select tenant files for their review process. Contact person: Patrick Delaney; (808) 523-5681, ext. 693 Anticipated Completion Date: October 1, 2025

View Audit 369792

Finding 1157557 (2024-001)

Material Weakness 2024

Housing Commission of Talbot

MD

HUD Housing Programs

U.S. Department of Housing and Urban Development The Housing Commission of Talbot respectfully submits the following corrective action plan for the year ended December 31, 2024 . . Audit period: January 1, 2024 through December 31, 2024 . Th~ finding from the prior audit's schedule of findings and q...

U.S. Department of Housing and Urban Development The Housing Commission of Talbot respectfully submits the following corrective action plan for the year ended December 31, 2024 . . Audit period: January 1, 2024 through December 31, 2024 . Th~ finding from the prior audit's schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the prior year. FINDINGS-FINANCIAL STATEMENT AUDIT None FINDINGS-FEDERAL AWARDS 2023-001 Missing Depository Agreements (Significant Deficiency) Condition: The Housing Commission of Talbot (the "Commission") did not set up depository agreements with its financial institutions. Status: This fin.ding is uncleared. A similar finding was noted in fiscal year 2024. The Commission has had prior communications with the Bank regarding the depository agreements requirements. The Bank would not sign due to internal policies. The Commission will coordinate discussions between our HUD local field office and the Bank to discuss the requirements for obtaining a depository agreement. U.S. Department of Housing and Urban Development · The Housing ,Commission -of Talbot- respectfully submits the following corrective action plan for the year ended December 31, 2024. Audit period: January 1, 2024 through December 31, 2024 · :. ·· The findirigs:from the schedule of findings and questioned costs is discussed below. The findings are numbered consistently with the numbers assigned in the schedule. -FINDINGS--FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2024-001 Missing Depository Agreements (Non Compliance) Recommendation: The Commission should enter into depository agreements with all financial institutions holding Federal funds for the Commission. Explanation of disagreement with audit.finding: There is no disagreement with the audit finding. Action ~aken in response to finding: The Commission has had prior communications with the Bank regarding the depository agreement requirements. The Bank would not sign due to internal policies. The Commission will continue to coordinate discussions between our HUD local field office and the Bank to discuss the requirements for obtaining a depository agreement. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2025 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Don Bibb, Executive Director

View Audit 369789

Finding 1157556 (2024-002)

Material Weakness 2024

Housing Authority of the City of New Bern

NC

HUD Housing Programs

Finding No. 2024-002: Failure to Submit CFP Reports on Time (Significant Deficiency) Corrective Action Plan: NBHA acknowledges the late submission of the AMCCs and the Annual Performance and Evaluation Report. To prevent recurrence, NBHA will create a compliance calendar with submission deadlines an...

Finding No. 2024-002: Failure to Submit CFP Reports on Time (Significant Deficiency) Corrective Action Plan: NBHA acknowledges the late submission of the AMCCs and the Annual Performance and Evaluation Report. To prevent recurrence, NBHA will create a compliance calendar with submission deadlines and designate a staff member responsible for monitoring all reporting requirements. The Executive Director will review compliance status monthly to ensure all reports are completed and submitted on time. Responsible Person: Reginal Barner, Executive Director Expected Completion Date: December 31, 2025 39

View Audit 369785

Finding 1157555 (2024-001)

Material Weakness 2024

Housing Authority of the City of New Bern

NC

HUD Housing Programs Cash Management Period of Performance

Finding No. 2024-001: Obligation Requirement for Capital Fund Program Drawdowns (Significant Deficiency Corrective Action Plan: NBHA has reviewed its internal controls regarding the obligation requirement for CFP LOCCS and will implement additional monitoring procedures to ensure timely obligation o...

Finding No. 2024-001: Obligation Requirement for Capital Fund Program Drawdowns (Significant Deficiency Corrective Action Plan: NBHA has reviewed its internal controls regarding the obligation requirement for CFP LOCCS and will implement additional monitoring procedures to ensure timely obligation of funds. This includes developing a tracking spreadsheet and assigning a staff member to review obligations quarterly. The Executive Director will receive quarterly reports to ensure compliance going forward. Responsible Person: Reginal Barner, Executive Director Expected Completion Date: December 31, 2025

View Audit 369785

Finding 1157554 (2024-002)

Material Weakness 2024

Housing Authority of Cass County

ND

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Contact Person Tawnya Taylor, Executive Director Corrective Action Plan The Authority will review its policies and procedures over program compliance requirements and continue to provide occupancy training to staff to prevent future exceptions. Planned Completion Date for CAP December 31, 2025

View Audit 369784

Finding 1157552 (2024-002)

Material Weakness 2024

Saraland Manor, Inc.

MS

Cash Management HUD Housing Programs

We agree that surplus cash deposit was not made in FY2020, and the recommendations described above. Management will deposit any surplus cash required into the residual receipts in future periods.

View Audit 369783

Finding 1157551 (2024-001)

Material Weakness 2024

Saraland Manor, Inc.

MS

Cash Management HUD Housing Programs

We agree that surplus cash deposit was not made in FY2019, and the recommendations described above. Management will deposit any surplus cash required into the residual receipts in future periods.

View Audit 369783

Finding 1157546 (2024-003)

Material Weakness 2024

Young Women's Christian Association of St Joseph Missouri

MO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318 § 200.326

2024-003 Program: Crime Victim Assistance Federal Agency: Department of Justice AL #: 16.575 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Missouri Department of Social Services Type of Compliance Finding: I - Procurement, Suspension, & Debarment Internal Cont...

2024-003 Program: Crime Victim Assistance Federal Agency: Department of Justice AL #: 16.575 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Missouri Department of Social Services Type of Compliance Finding: I - Procurement, Suspension, & Debarment Internal Control Impact: Material Weakness Finding: During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted the Organization did not follow their documented procurement procedures for approving one contractor. Corrective Action Plan: All procurement procedures will be followed as documented in YWCA St. Joseph financial policies. Person(s) Responsible for Implementation: Danielle Brown, CEO, dbrown@ywcasj.org, 816-232-4481

View Audit 369777

Finding 1157545 (2024-002)

Material Weakness 2024

Young Women's Christian Association of St Joseph Missouri

MO

Subrecipient Monitoring Eligibility Material Weakness

2024-002 Program: Crime Victim Assistance Federal Agency: Department of Justice AL #: 16.575 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Missouri Department of Social Services Type of Compliance Finding: E - Eligibility Internal Control Impact: Material Weak...

2024-002 Program: Crime Victim Assistance Federal Agency: Department of Justice AL #: 16.575 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Missouri Department of Social Services Type of Compliance Finding: E - Eligibility Internal Control Impact: Material Weakness Finding: When a participant arrives at the Shelter, the admission checklist, procedures, and forms must be completed by program staff. During our audit of the Organization’s fiscal year ended December 31, 2024 federal award program, we noted the Organization did not have necessary supporting documentation, such as admission checklists for eligibility, to evaluate twenty-one out of twenty- five participants in their files. Corrective Action Plan: All supporting documentation for client eligibility will be maintained for the period required by the grant. Person(s) Responsible for Implementation: Danielle Brown, CEO, dbrown@ywcasj.org, 816-232-4481

View Audit 369777

Finding 1157544 (2024-001)

Material Weakness 2024

Arrowhead Regional Development Commission

MN

Reporting Internal Control / Segregation of Duties

Corrective Action Taken or Planned: The Commission will adopt a policy whereby the Executive Director or a designee will review all future reports prior to submission. Contact person(s) responsible for correction action: Kristi Kane, Executive Director Anticipated Completion Date: Immediately

View Audit 369776

Finding 1157543 (2024-001)

Material Weakness 2024

Richmond Medical Center

NY

Procurement, Suspension & Debarment § 200.318

RUMC follows applicable federal grant guidelines and requirements, including adherence to the three-bid policy and related procurement standards. However, there were two factors that impacted our ability to provide complete supporting documentation during the audit period: (1) the departure of the p...

RUMC follows applicable federal grant guidelines and requirements, including adherence to the three-bid policy and related procurement standards. However, there were two factors that impacted our ability to provide complete supporting documentation during the audit period: (1) the departure of the project manager who was responsible for maintaining procurement records for the project, and (2) a cyber event in 2023 that resulted in the loss of certain files and supporting documentation. While these circumstances limited our ability to produce documentation evidencing compliance, management affirms that the required procurement steps were performed and that RUMC remains in adherence with federal grant requirements. To further strengthen compliance, RUMC has established a Construction Grant Committee to ensure full adherence to all grant requirements. This committee is responsible for reviewing procurement actions, verifying compliance with the three-bid requirement, ensuring proper documentation is retained, and monitoring procurement processes throughout the life of each project. These corrective actions will ensure that complete and verifiable records

View Audit 369773

Finding 1157542 (2024-001)

Material Weakness 2024

Coordinated Living of Southern Nevada, Inc.

NV

Internal Control / Segregation of Duties

Beneficiary Reporting - Auditor’s Recommendation: We recommend that a responsible employee review and approve all HOME Program Housing Beneficiary Reports for accuracy prior to their submission to the applicable oversite agency. The review should contain procedures to match the income amounts per th...

Beneficiary Reporting - Auditor’s Recommendation: We recommend that a responsible employee review and approve all HOME Program Housing Beneficiary Reports for accuracy prior to their submission to the applicable oversite agency. The review should contain procedures to match the income amounts per the HOME Program Housing Beneficiary Reports with the specific tenant income certification forms. We recommend that the reviewer document the date of the income certification form for each unit as well as the initials of the reviewer. Action Taken: In order to ensure the accuracy of the HOME Program Housing Beneficiary Reports, the reports are now routed to our director of Low-Income Housing Tax Credit and Compliance, who reviews each report in detail. This review will include adding the documentation of the date of the specific tenant income certification forms that were utilized to verify the proper income amounts are reported and the initials and date of the review. This documentation will be reviewed by a Board Member and then the reports will be sent to either the City of Las Vegas or Clark County, as required. These procedures will be implemented in October 2025.

View Audit 369765

Finding 1157541 (2024-004)

Material Weakness 2024

Seattle Jobs Initiative

WA

Subrecipient Monitoring Reporting Significant Deficiency

Corrective Action: Procedures will be created as part of the subaward monitoring process to ensure that subrecipient information is received in a timely manner. Deadlines will be created to ensure that the subaward information is entered as part of FFATA reporting in Sam.gov with deadlines outlined ...

Corrective Action: Procedures will be created as part of the subaward monitoring process to ensure that subrecipient information is received in a timely manner. Deadlines will be created to ensure that the subaward information is entered as part of FFATA reporting in Sam.gov with deadlines outlined in 2 CFR 170.

View Audit 369762

Finding 1157540 (2024-003)

Material Weakness 2024

Seattle Jobs Initiative

WA

Subrecipient Monitoring § 200.332

Corrective Action: The risk assessment template and list of subaward terms to be downloaded. A new subaward agreement template to be developed which encompasses all aspects of 200.332(b). Contact Persons: Laurie Olson, Controller and Kevin Osborn, Interim Executive Director Implementation Timeline: ...

Corrective Action: The risk assessment template and list of subaward terms to be downloaded. A new subaward agreement template to be developed which encompasses all aspects of 200.332(b). Contact Persons: Laurie Olson, Controller and Kevin Osborn, Interim Executive Director Implementation Timeline: The risk assessment template and subaward terms were downloaded and distributed to key stakeholders on Friday, September 19, 2025. A new subaward agreement template will be created in a multi-department collaboration and is due to be completed by December 31, 2025.

View Audit 369762

Finding 1157539 (2024-001)

Material Weakness 2024

Petersburg Redevelopment and Housing Authority

VA

HUD Housing Programs

MANAGEMENT’S RESPONSE TO FINDINGS CORRECTIVE ACTION PLAN Finding Reference 2024-001: During the performance of the 2024 audit a sample of public housing tenant files were reviewed. Three of the public housing recertifications selected were not completed during the 2024 fiscal year. Correction Action...

MANAGEMENT’S RESPONSE TO FINDINGS CORRECTIVE ACTION PLAN Finding Reference 2024-001: During the performance of the 2024 audit a sample of public housing tenant files were reviewed. Three of the public housing recertifications selected were not completed during the 2024 fiscal year. Correction Action Plan: The three late recertifications were missed due to an ineffective system for tracking the recertifications that are due each month. To correct this issue, effective immediately, the Housing Supervisor will create a recertification calendar using YARDI data to serve as a monthly listing of recertifications due within 90-120 days. The Housing Supervisor will monitor the recertification calendar and check off the recertifications as they are completed. Any missing or late recertifications identified will be communicated to the Housing Managers to ensure completion. In addition, the monthly PIC reports will also be monitored to ensure any missing, late, or rejected recertifications are completed or corrected in a timely manner. Tenants who fail to complete their recertification packets in a timely fashion will be promptly sent a 21/30 notice of non-compliance. Those who fail to comply within the required timeframe, will be subject to court action as failure to complete their recertification is a lease violation . LaTysha Carpenter, CPA Executive Director

View Audit 369758

Corrective Action Plans

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