Corrective Action Plans

Finding 1208786 (2025-004)

Material Weakness 2025

MI

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

This finding is due to the Township not having formal written policies in place required by Uniform Guidance. The Township is now aware that these policies are required and will adopt all necessary policies. The Township does not believe that there were any actual nonallowable costs or transactions ...

This finding is due to the Township not having formal written policies in place required by Uniform Guidance. The Township is now aware that these policies are required and will adopt all necessary policies. The Township does not believe that there were any actual nonallowable costs or transactions because of the lack of written policies as required by Uniform Guidance. The Township will adopt all necessary policies to be in compliance. The person responsible for the corrective action is the Supervisor. The anticipated completion date of the corrective action plan is before the end of the 2026 fiscal year. The plan for adherence is that the Board will review all proposed policies and adopt them, the Board will also monitor any changes to policy requirements to ensure that they are in compliance in the future.

View Audit 399623

Finding 1208785 (2025-001)

Material Weakness 2025

Robbins Way Senior Housing 092-Ee129

MN

HUD Housing Programs Special Tests & Provisions Procurement, Suspension & Debarment

Corrective Action: Management agress with the finding. Due to the federal government shutdown and the temporary suspension of HUD operations, approval for one replacement reserve withdrawal could not be obtained prior to disbursement. The withdrawal was necessary to maintain essential project operat...

Corrective Action: Management agress with the finding. Due to the federal government shutdown and the temporary suspension of HUD operations, approval for one replacement reserve withdrawal could not be obtained prior to disbursement. The withdrawal was necessary to maintain essential project operations during the lapse in rental assistance payments. Management has since resumed compliance with all HUD approval requirements and will enhance documentation and contingency planning to address similar circumstances in the future. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer

View Audit 399613

Finding 1208784 (2025-001)

Material Weakness 2025

Riverview Apartments Senior Housing

MN

Eligibility HUD Housing Programs Material Weakness

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agent's procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer

View Audit 399612

Finding 1208783 (2025-002)

Material Weakness 2025

Metro Apartments, Inc. 092-Hh011-Cmi

MN

HUD Housing Programs

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer

View Audit 399609

Finding 1208782 (2025-001)

Material Weakness 2025

Metro Apartments, Inc. 092-Hh011-Cmi

MN

HUD Housing Programs Special Tests & Provisions

Corrective Action: Management agrees with the finding. Management acknowledges that the withdrawal exceeded the amount approved by HUD and is reviewing internal procedures to ensure replacement reserve withdrawals comply with HUD approval requirements. Mangement will coordinate with HUD to resolve t...

Corrective Action: Management agrees with the finding. Management acknowledges that the withdrawal exceeded the amount approved by HUD and is reviewing internal procedures to ensure replacement reserve withdrawals comply with HUD approval requirements. Mangement will coordinate with HUD to resolve the unapproved portion of the withdrawal and take corrective action as necessary. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer

View Audit 399609

Finding 1208781 (2025-001)

Material Weakness 2025

Garden Terrace Commons Senior Housing 092-Ee078

MN

Eligibility HUD Housing Programs Material Weakness

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson , Chief Financial and Operating Officer.

View Audit 399608

Finding 1208780 (2025-002)

Material Weakness 2025

Community for Affordable Senior Housing, Inc.

MN

Eligibility HUD Housing Programs Material Weakness

Corrective Action: The Organization agrees with the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party managers as of January 1, 2026. These agents have a track record of completing, documenting, and retaining certifications in acco...

Corrective Action: The Organization agrees with the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party managers as of January 1, 2026. These agents have a track record of completing, documenting, and retaining certifications in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they document and maintain tenant files in accordance with HUD and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer

View Audit 399606

Finding 1208779 (2025-001)

Material Weakness 2025

Community for Affordable Senior Housing, Inc.

MN

Eligibility HUD Housing Programs Material Weakness

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson , Chief Financial and Operating Officer.

View Audit 399606

Finding 1208778 (2025-002)

Material Weakness 2025

Bassett Creek Senior Housing 092-Ee037

MN

Eligibility HUD Housing Programs Material Weakness

Corrective Action: The Organization agrees with the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing, documenting, and retaining certification...

Corrective Action: The Organization agrees with the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing, documenting, and retaining certifications in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they document and maintain tenant files in accordance with HUD and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer

View Audit 399604

Finding 1208777 (2025-001)

Material Weakness 2025

Bassett Creek Senior Housing 092-Ee037

MN

Eligibility HUD Housing Programs Material Weakness

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...

Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agent's procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer

View Audit 399604

Finding 1208776 (2025-001)

Material Weakness 2025

Arbor Lakes Senior Housing 092-Ee059

MN

HUD Housing Programs Special Tests & Provisions Procurement, Suspension & Debarment

Corrective Action: Management agress with the finding. Due to the federal government shutdown and the temporary suspension of HUD operations, approval for one replacement reserve withdrawal could not be obtained prior to disbursement. The withdrawal was necessary to maintain essential project operat...

Corrective Action: Management agress with the finding. Due to the federal government shutdown and the temporary suspension of HUD operations, approval for one replacement reserve withdrawal could not be obtained prior to disbursement. The withdrawal was necessary to maintain essential project operations during the lapse in rental assistance payments. Management has since resumed compliance with all HUD approval requirements and will enhance documentation and contingency planning to address similar circumstances in the future. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer

View Audit 399603

Finding 1208775 (2025-001)

Material Weakness 2025

Housing and Redevelopment Authority of Brainerd

MN

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Special Provisions: Rent Reasonableness Federal Agency: Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Award Period: January 1, 2025 – December 31, 2025 Compliance Requirement Section: Special Provisions Type of ...

Special Provisions: Rent Reasonableness Federal Agency: Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Award Period: January 1, 2025 – December 31, 2025 Compliance Requirement Section: Special Provisions Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Recommendation: The agency should update its rent reasonableness procedures to ensure: • Rental comparison data is current and regularly refreshed; • Comparable non-assisted units are consistently used; and • Staff are trained on proper rent reasonableness documentation and review standards. The agency should also review a sample of recent rent reasonableness determinations to ensure corrective actions are fully implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has taken the following steps to correct the finding: • Updated and refreshed rent reasonableness software data to reflect current market rents. • Configured and are using the software to require selection of comparable non assisted units. • Revisee procedures to document software generated rent reasonableness results in tenant files. • Train staff on correct use of the rent reasonableness software and regulatory requirements. • Conduct supervisory reviews of software based determinations for compliance. Name of the contact person responsible for corrective action: Karen Young, Finance Director Planned completion date for correct action plan: The corrective action plan has already been implemented and will be corrected before December 31, 2026.

View Audit 399601

Finding 1208774 (2025-002)

Material Weakness 2025

Boys and Girls Club of New Rochelle, Inc.

NY

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Management plans to revamp procedures to ensure that the reports are filed in a timely manner in the future.

View Audit 399600

Finding 1208773 (2025-001)

Material Weakness 2025

Pepperdine University

CA

Student Financial Aid Subrecipient Monitoring

Management's Views and Corrective Action Plan: Re: Response to finding 2025-001 2025-001 - RETURN OF TITLE IV FUNDS Cluster: Student Financial Assistance Cluster Sponsoring Agency: Department of Education Award Name: Federal Direct Student Loans Program ALN Number: 84.268 Award Period: 2024-2025 Pas...

Management's Views and Corrective Action Plan: Re: Response to finding 2025-001 2025-001 - RETURN OF TITLE IV FUNDS Cluster: Student Financial Assistance Cluster Sponsoring Agency: Department of Education Award Name: Federal Direct Student Loans Program ALN Number: 84.268 Award Period: 2024-2025 Pass-through Entity: Not applicable Management concurs with the finding. To prevent future delays, we plan to stabilize staffing, increase oversight, and improve workflow efficiency: 1. Increase staffing Following the audit recommendation to maintain consistent staffing, the Graduate School of Education and Psychology’s (GSEP) Financial Aid Office will: • Prioritize hiring by expediting the recruitment and onboarding of full-time Financial Aid positions to fill existing vacancies within the GSEP Financial Aid office. • Cross-train staff and establish a backup schedule where multiple staff members are trained on the Return to Title IV (R2T4) process and can assist during peak withdrawal periods and unexpected staff vacancies. 2. Increase oversight To ensure compliance, the GSEP Financial Aid Office will improve the R2T4 log, tracking every student withdrawal and term cancelation from the date of determination and add internal oversight at the 30-day mark to ensure the 45-day deadline is met. A manager will complete a secondary review of all R2T4 calculations to ensure accuracy and compliance. 3. Improve workflow efficiency To alleviate the high volume of inquiries that contributed to processing backlogs, GSEP is exploring partnering with CollegeVine, a third-party technology solution, to implement school-specific AI agents. With CollegeVine handling routine inquiries via chat and phone, the Financial Aid staff will be able to focus on compliance-oriented tasks. IMPLEMENTATION TIMELINE Increase staffing: Clear existing R2T4 backlog. (Completion: May 1, 2026) Increase staffing: Cross-training Financial Aid staff and implement contingency plan. (Completion: June 1, 2026) Increase staffing: Fill all GSEP Financial Aid vacancies. (Estimated Completion: June 1, 2026) Increase oversight: Implement additional monitoring, reconciliation, and compliance checks. (Completion: June 1, 2026) Workflow efficiency: Implement CollegeVine AI Agents. (Estimated Completion: Undetermined- pending approval) CONCLUSION By stabilizing our workforce and leveraging additional efficiencies, GSEP will ensure that R2T4 processing is prioritized and completed within the 45-day regulatory timeframe. CONTACT FOR THIS PLAN: Jillian Doyle Robinson Director of Student Financial Services Pepperdine Graziadio Business School & Graduate School of Education and Psychology Jillian.Doyle@pepperdine.edu 310-568-5578

View Audit 399599

Finding 1208650 (2025-004)

Material Weakness 2025

Rialto Unified School District

CA

Subrecipient Monitoring

The Nutrition Services management team has established an internal schedule to ensure visits are done in a timely and compliant manner.

View Audit 399592

Finding 1208648 (2025-003)

Material Weakness 2025

Rialto Unified School District

CA

Subrecipient Monitoring Cash Management Material Weakness

The District will strengthen its internal control system to ensure that each entry within the Nutrition Services data management system meets required program criteria and is fully supported by appropriate documentation. A more robust process of review and verification will be implemented to safegua...

The District will strengthen its internal control system to ensure that each entry within the Nutrition Services data management system meets required program criteria and is fully supported by appropriate documentation. A more robust process of review and verification will be implemented to safeguard the integrity of originating data and prevent compromise. System access controls will also be reinforced to ensure that granted access is appropriate and used in accordance with established protocols. Ensuring the accuracy of meal data will support accurate revenue reporting and, in turn, reliable financial reporting. Moreover, the District will continue to foster a culture of integrity in which all allegations of fraud are taken seriously and addressed promptly. The District will also enhance the visibility and accessibility of its WeTip reporting system to ensure employees, students, and community members can report concerns.

View Audit 399592

Finding 1208639 (2025-001)

Material Weakness 2025

Nutley Senior Citizens Housing Corporation

NJ

Internal Control / Segregation of Duties HUD Housing Programs Reporting

Recommendation: Management should implement stronger internal controls to ensure surplus cash deposits are made in accordance with the required deadlines. This may include setting up automated reminders, improving oversight, or assigning clear responsibilities to ensure compliance. Views of Responsi...

Recommendation: Management should implement stronger internal controls to ensure surplus cash deposits are made in accordance with the required deadlines. This may include setting up automated reminders, improving oversight, or assigning clear responsibilities to ensure compliance. Views of Responsible Officials and Planned Corrective Actions: Management has reviewed the audit finding and acknowledges the delay in depositing surplus cash. Management has submitted a request to HUD to retain the surplus cash for future capital improvements to the property.

View Audit 399591

Finding 1208638 (2025-002)

Material Weakness 2025

Camino Real Regional Utility Authority

NM

Reporting § 200.512

Views of Responsible Officials and Planned Corrective Action CRRUA’s fiscal agent, Dona Ana County, implemented a new ERP system, along with key staff changes, that necessitated financial documentation being run several times which delayed complete financial information being provided to the audit t...

Views of Responsible Officials and Planned Corrective Action CRRUA’s fiscal agent, Dona Ana County, implemented a new ERP system, along with key staff changes, that necessitated financial documentation being run several times which delayed complete financial information being provided to the audit team. CRRUA has a new fiscal agent, the City of Sunland Park, for the upcoming fiscal year. CRRUA Board approval of fiscal agent happened in July 2026. CRRUA’s new fiscal agent, the City of Sunland Park, started providing services in FY26. Executive director and assistant director will work with the City of Sunland Park to ensure timely submission of information to the audit team. Finding resolution timeline: June 30, 2026 Designation of employee position responsible for meeting this deadline: Juan Carlos Crosby, Executive Director and David Espinoza, Assistant Director

View Audit 399589

Finding 1208608 (2025-006)

Material Weakness 2025

Legal Services Alabama, INC

AL

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Corrective Action: LSA will provide training to the appropriate departments and individuals to reinforce disbursement and purchase order policies and procedures within 30 days of the audit submission. Additionally, LSA will provide training to employees emphasizing the organizational policies requir...

Corrective Action: LSA will provide training to the appropriate departments and individuals to reinforce disbursement and purchase order policies and procedures within 30 days of the audit submission. Additionally, LSA will provide training to employees emphasizing the organizational policies requiring employee certification of their payroll timesheets. This change will be made within the next 90 days. Contact Person: George Fort, Director of Finance, (334) 223-0251; gfort@alsp.org

View Audit 399572

Finding 1208604 (2025-005)

Material Weakness 2025

Legal Services Alabama, INC

AL

Significant Deficiency

Corrective Action: LSA follows a monthly accounting checklist which includes PAI expenditures reconciliations. LSA will expand the checklist to include detailed year-end procedures and provide training that covers the expanded checklist within 30 days of the audit submission. Additionally, LSA will ...

Corrective Action: LSA follows a monthly accounting checklist which includes PAI expenditures reconciliations. LSA will expand the checklist to include detailed year-end procedures and provide training that covers the expanded checklist within 30 days of the audit submission. Additionally, LSA will provide annual accounting training to support year-end accounting activities and processes including PAI carryforward calculations and analysis. In addition, LSA will increase efforts to meet the 1614 minimum by expanding PAI training and education and evaluating activities for qualification as PAI activities. This change will be made within the next 90 days. Contact Person: George Fort, Director of Finance, (334) 223-0251; gfort@alsp.org

View Audit 399572

Finding 1208600 (2025-004)

Material Weakness 2025

Legal Services Alabama, INC

AL

Significant Deficiency

Corrective Action: Legal Services Alabama takes this finding seriously and is committed to full compliance with all case documentation and case coding requirements. We recognize the importance of maintaining complete and accurate client files, including ensuring that all required retainers, statemen...

Corrective Action: Legal Services Alabama takes this finding seriously and is committed to full compliance with all case documentation and case coding requirements. We recognize the importance of maintaining complete and accurate client files, including ensuring that all required retainers, statements of fact, signatures, and service classifications are properly entered and preserved in LegalServer. As part of Mission 2026, our statewide initiative to strengthen operations and improve consistency across all offices, leadership has been traveling throughout Alabama to meet in person with each office to reinforce expectations, improve cohesion, and emphasize compliance standards. A central component of this effort is the review of random case selections from each office, followed by written feedback identifying areas where improvement is needed, including documentation practices, case coding accuracy, and file completeness. In response to this finding, we will continue targeted training on the distinction between limited service and extended service case closures, reinforce documentation requirements for extended representation, and monitor compliance through periodic file reviews. Legal Services Alabama is fully committed to ensuring that all information maintained in LegalServer is accurate, complete, and supported by the proper documentation in every case file. This change will be made within the next 90 days. Contact Person: Michael Forton, Director of Advocacy, (256) 551-2671; mforton@alsp.org

View Audit 399572

Finding 1208596 (2025-001)

Material Weakness 2025

Sheridan Glen Housing, Inc.

CO

Management of the Partnership will ensure the audited financial statements are filed into the REAC system within 90-days after year-end.

View Audit 399569

Finding 1208584 (2025-001)

Material Weakness 2025

Universidad Teologica Del Caribe, Inc.

PR

Student Financial Aid Subrecipient Monitoring

Institutional Comments on Findings and Recommendations: The institution agrees with the auditor on this finding that there were (4) four cases where the changes to the student enrollment status were not reported. The institution also agrees with the auditor that there was (1) one case where the enro...

Institutional Comments on Findings and Recommendations: The institution agrees with the auditor on this finding that there were (4) four cases where the changes to the student enrollment status were not reported. The institution also agrees with the auditor that there was (1) one case where the enrollment status was not reported within the required 60 days' period. The institution also agrees with the auditor that there were (2) two cases where the correct student status was not reported to NSLDS. The institution has identified cases where the information was reported correctly or timely on one monthly report and in the following report some of the information is missing or identified as not reported correctly or was just eliminated from the enrollment listings. This occurred especially in the cases as notified with a status change to W (withdrawal) and G (graduated) The institution, has contacted the NDSLS Help Desk to be able to resolve such issues and others as related to the NSLDS report tools section of the revised NSLDS platform. Actions Taken or Planned: Although the institution is scheduled to report to NSLDS every 60 days, the institution would continue to submit its Enrollment Reports monthly to notify changes of student status to the Department of Education in order to do so on a timely basis. The institution has always had a personnel member designated for the compliance of the Enrollment submission process as required and has discussed the matters as related to the auditor's findings with said personnel. Following the recommendation of the auditors, the institution would proceed to document each submission and confirmation of acceptance by NSLDS of the changes submitted to the Department of Education as regards to Enrollment Reporting. Status of Corrective Actions on Prior Findings: Some of the issues related to this finding occurred in the past audit.

View Audit 399550

Finding 1208583 (2025-001)

Material Weakness 2025

Church Street Corporation

NJ

§ 200.512

Recommendation: Controls should be implemented to ensure timely filing of the audit package to the Federal Audit Clearinghouse. Views of Responsible Officials: The Organization agrees with the auditors’ recommendation.

View Audit 399548

Finding 1208580 (2025-001)

Material Weakness 2025

Golden Terrace Village Iv, Inc.

TX

The office manager will consult with HUD officials from the Fort Worth, TX servicing office and comply with their recommendations.

View Audit 399544

Corrective Action Plans

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