Corrective Action Plans

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MATERIAL WEAKNESS 2024-002: Section 202, Assistance Listing No. 14.157 One tenant file was selected for testing and the following findings were noted: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not updated for the year tested • Move-in...
MATERIAL WEAKNESS 2024-002: Section 202, Assistance Listing No. 14.157 One tenant file was selected for testing and the following findings were noted: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not updated for the year tested • Move-in/move-out inspection form was not provided • Lease was not provided • Annual recertification of income by a third party was not provided Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
View Audit 374024 Questioned Costs: $1
2024-002: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and signatures, as required by HUD regulations, were missing from Form HUD-50059, Owner’s Certification of Compliance. Additionally, our testing indicated that the required deposits to the replacement res...
2024-002: Section 202, Assistance Listing No. 14.157 Two tenant files were selected for testing and signatures, as required by HUD regulations, were missing from Form HUD-50059, Owner’s Certification of Compliance. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
2024-002: Section 811, Assistance Listing No. 14.181 One tenant file was selected for testing and the following items were noted: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not signed • Move-in/move-out inspection form was not provided...
2024-002: Section 811, Assistance Listing No. 14.181 One tenant file was selected for testing and the following items were noted: • Form HUD-50059, Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent Procedures was not signed • Move-in/move-out inspection form was not provided • Lease was not signed Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
2024-002: Section 202, Assistance Listing No. 14.157 One tenant file was selected for testing, and none of the required documentation to determine eligibility, as required by the HUD regulations, was provided. Additionally, our testing indicated that the required deposits to the replacement reserve ...
2024-002: Section 202, Assistance Listing No. 14.157 One tenant file was selected for testing, and none of the required documentation to determine eligibility, as required by the HUD regulations, was provided. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness.
View Audit 374016 Questioned Costs: $1
2024-002: Section 811, Assistance Listing No. 14.181 Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • One of the files was missing Form HUD-50059, Owner’s Certification of Comp...
2024-002: Section 811, Assistance Listing No. 14.181 Three tenant files were selected for testing and the required documentation to determine eligibility, as required by the HUD regulations, could not be located as follows: • One of the files was missing Form HUD-50059, Owner’s Certification of Compliance. • One of the files was missing verification of income by a third party. • All three of the files were missing signed move-in/move-out inspection forms. Additionally, our testing indicated that the required deposits to the replacement reserve account had not been made for the last quarter of the Corporation’s fiscal year for any tenants. Recommendation: We recommend the Corporation establish procedures and internal controls to ensure that all required documentation is maintained, and all required reserve deposits are made timely, in accordance with HUD requirements. Action Taken: Management concurs with this recommendation. Since assuming property management on June 1, 2025, ULREDC has conducted a tenant file audit. All property management staff have been properly trained to ensure compliance with certification, documentation, and inspection requirements. Missing documentation, including Form HUD-50059, income verifications, and leasing inspections, is being corrected. Replacement reserve deposits were delayed because properties were not cash flowing. As leasing stabilizes, deposits will resume and be verified once RealPage is fully active. RealPage will serve as the compliance and record-retention platform. Quarterly internal compliance reviews will be instituted to confirm file accuracy and documentation completeness. We are committed to compliance and accuracy as required by the U.S. Department of Housing and Urban Development. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Dr. Hawkins at shawkins@ulr.org.
The construction projects originated from an initial bid awarded in 2022, which was approved in multiple phases. The original 2022 bid specifications did not include Davis-Bacon Act requirements; consequently, the 2023-2024 projects tested during the audit period did not comply with the applicable w...
The construction projects originated from an initial bid awarded in 2022, which was approved in multiple phases. The original 2022 bid specifications did not include Davis-Bacon Act requirements; consequently, the 2023-2024 projects tested during the audit period did not comply with the applicable wage provisions. Going forward, the Board will ensure that all construction projects, either wholly or in part, being paid with federal dollars will include the Davis-Bacon Act provisions and all related federal compliance requirements in accordance with Title 29.
View Audit 373937 Questioned Costs: $1
The increase in federal funding that now positions the organization to implement single audits through the State required incrased in-house capacity. This capacity building transition also contributed to the delay in filing. The Organization has acquired additional support through an external accoun...
The increase in federal funding that now positions the organization to implement single audits through the State required incrased in-house capacity. This capacity building transition also contributed to the delay in filing. The Organization has acquired additional support through an external accounting firm. Timely audit filings will occur going forward.
2024-003 Internal Controls System Over Allowable Costs and Allowed Activities. – U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, audit...
2024-003 Internal Controls System Over Allowable Costs and Allowed Activities. – U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award. Funds utilized under the Housing Opportunities for Persons with AIDS program are required to be expended on costs consistent with those outlined in 2 CRF 200 Subpart E – Cost Principles, and within the core service categories outlined in the grant agreement. Condition: For one pay period selected for testing, two employees charged to the grant did not have an approved grant time sheet which assigns the appropriate time worked by employees to be allocated to the grant. Cause: Internal controls over payroll allocations was not performed consistently to ensure all payroll allocations and related expenses were properly reviewed. Context: Management failed to design and implement consistent internal controls to address the risk of improper payroll amounts being allocated to the grant. Effect: Failure to design and implement controls over the approved payroll allocations could result in the grant being overcharged. Repeat Finding: No Recommendation: We recommend management design and implement a system of internal controls whereby a review of costs and activities and the related supporting schedules being submitted for reimbursement are reviewed on a consistent basis and management ensures proper documentation of this review is maintained to support the performance of the control. Views of Responsible Officials and Planned Corrective Actions: For one of the pay periods selected for testing, two employees charged to the grant did not have an approved grant time sheet which assigns the appropriate time worked by employees to be allocated to the grant. Internal controls over payroll allocations were not performed consistently to ensure all payroll allocations and related expenses were properly reviewed. Management failed to design and implement consistent internal controls to address the risk of improper payroll amounts being allocated to the grant. Failure to design and implement controls over the approved payroll allocations could result in the grant being overcharged. Management intends to put in place additional training for case managers to identify eligibility of clients and ensure proper backup is submitted. Supervisors will ensure all proper backup and supporting documents are included in the case file before submitting.
Recommendation: We recommend that the County implement a procedure by which a monthly review of the activities billed by providers to the CLTS Third Party Administration is performed with special attention on any authorized changes in services that occurred during the month. Explanation of disagreem...
Recommendation: We recommend that the County implement a procedure by which a monthly review of the activities billed by providers to the CLTS Third Party Administration is performed with special attention on any authorized changes in services that occurred during the month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County acknowledges the recommendation to implement a procedure for monthly review of provider-billed activities submitted to the CLTS Third Party Administration (TPA). It is our understanding that the activity subject to testing in the future for CLTS will be case management and other services directly provided by Taylor County personnel. The County will evaluate current processes to make sure they are complying. Name(s) of the contact person(s) responsible for corrective action: Tracy Hartwig, Finance Director Planned completion date for corrective action plan: December 31, 2025
View Audit 373865 Questioned Costs: $1
Finding No. 2024-007 HUD Low Income Housing Preservation and Resident Homeownership Act of 1990 Federal Assistance Listing Number #99.999 Statement of Condition The owner was unable to provide support that they ensured passing HQS inspections were performed during 2024. Corrective Action Plan REACH ...
Finding No. 2024-007 HUD Low Income Housing Preservation and Resident Homeownership Act of 1990 Federal Assistance Listing Number #99.999 Statement of Condition The owner was unable to provide support that they ensured passing HQS inspections were performed during 2024. Corrective Action Plan REACH has policies in place for annual HQS inspections. During the audit, we were informed that the inspection form did not include inspection, work orders, and re-inspection. As a result of the 2024 audit, Management implemented using a new form in 2025 to capture inspection, work orders, and re-inspection.
Finding No. 2024-006 Housing Trust Fund Program Federal Assistance Listing Number #14.275 Statement of Condition In connection with our lease file review, we noted two instances of four tenants tested where management did not provide support that they performed a 3rd party income verification in acc...
Finding No. 2024-006 Housing Trust Fund Program Federal Assistance Listing Number #14.275 Statement of Condition In connection with our lease file review, we noted two instances of four tenants tested where management did not provide support that they performed a 3rd party income verification in accordance with policy. Corrective Action Plan As a result of the 2024 audit, a new process is set up to ensure that new employees receive HUD annual training. Management will continue to ensure that 3rd party income verification is performed in accordance with policy.
Finding No. 2024-005 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner was unable to provide a listing that detailed the available to HOME tenants the contracted number and type of HOME units and therefore we were unable to test the H...
Finding No. 2024-005 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner was unable to provide a listing that detailed the available to HOME tenants the contracted number and type of HOME units and therefore we were unable to test the HOME program compliance for the audit year. Corrective Action Plan REACH utilizes a 3rd party property management company to manage the two properties located in Washougal, Washington. Management is setting up a new process to ensure that the 3rd party property management company can provide all required information.
Finding No. 2024-004 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. This is considered a temporary noncompliance as follows: "Next Available Unit"...
Finding No. 2024-004 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. This is considered a temporary noncompliance as follows: "Next Available Unit" rule: The owner must rent the next comparable or smaller unit that becomes vacant to a low-income household. Temporary noncompliance: The unit is temporarily out of compliance with HOME requirements, but the property can regain compliance by following the "next available unit" rule. Unit conversion: If the owner fails to comply and rents a comparable vacant unit to a non-low-income tenant, the over-income unit loses its low-income status and the building's compliance is reduced. A two bedroom unit did become available in 2024 and this tenant was not relocated. Corrective Action Plan A new review process is in placed to review the HOME units that will be re-classified the next time there is a vacant unit of the corresponding size/type.
Finding No. 2024-003 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. Corrective Action Plan A new process is in placed to review HOME unit count wh...
Finding No. 2024-003 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not make available to HOME tenants the contracted number and type of HOME units. Corrective Action Plan A new process is in placed to review HOME unit count when a unit becomes available.
Finding No. 2024-002 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition In connection with our lease file review, we noted six instances of eight tenants tested where management did not provide support that they performed a 3rd party income veri...
Finding No. 2024-002 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition In connection with our lease file review, we noted six instances of eight tenants tested where management did not provide support that they performed a 3rd party income verification in accordance with policy. Corrective Action Plan As a result of the 2024 audit, a new process is set up to ensure that new employees receive HUD annual training. Management will continue to ensure that 3rd party income verification is performed in accordance with policy.
Finding No. 2024-001 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not ensure passing HQS inspections were performed during 2024. Corrective Action Plan REACH has policies in place for annual HQS inspections, and in 2023 retur...
Finding No. 2024-001 HUD HOME Investment Partnerships Program Federal Assistance Listing Number #14.239 Statement of Condition The owner did not ensure passing HQS inspections were performed during 2024. Corrective Action Plan REACH has policies in place for annual HQS inspections, and in 2023 returned to performing these inspections after suspending this activity during prior years impacted by COVID-era policies. Though inspections were performed according to requirements, during the audit we were informed that our inspection form did not include details related to inspection follow-up, work orders and re-inspection. As a result of the 2024 audit, Management implemented the use of a new form in 2025 to capture this additional information related to inspections, work orders and re-inspection
Management of the Organization concurs with the audit finding and will immediately implement the auditors’ recommendations. Management will remediate by immediately filing the September 30, 2024 financials and timely file the September 30, 2025 year end financials.
Management of the Organization concurs with the audit finding and will immediately implement the auditors’ recommendations. Management will remediate by immediately filing the September 30, 2024 financials and timely file the September 30, 2025 year end financials.
Adjusting Journal Entries, Required Disclosures and Draft Financial Statements - Auditor’s Recommendation: Although auditors may continue to provide such assistance both now and, in the future, under the pronouncement, the Borough should continue to review and accept both proposed adjusting journal ...
Adjusting Journal Entries, Required Disclosures and Draft Financial Statements - Auditor’s Recommendation: Although auditors may continue to provide such assistance both now and, in the future, under the pronouncement, the Borough should continue to review and accept both proposed adjusting journal entries and footnote disclosures, along with the draft financial statements. Borough’s Response: The Borough has received, reviewed and accepted all journal entries, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information in future years. Further, the Borough believes it has a thorough understanding of these financial statements and the ability to make informed judgments based on these financial statements. Lastly, the Borough considers such assistance provided by the auditors to be the most cost-effective manner to prepare such information. The Borough will also ensure that in the future all transactions will be properly reflected in the accounting software.
Segregation of Duties - Auditor’s recommendation: We recognize the Borough has attempted to segregate duties to the best of its ability. The Borough should continue to seek opportunities to segregate duties including involvement from Council Members. Borough’s Response: Because of the limited number...
Segregation of Duties - Auditor’s recommendation: We recognize the Borough has attempted to segregate duties to the best of its ability. The Borough should continue to seek opportunities to segregate duties including involvement from Council Members. Borough’s Response: Because of the limited number of personnel in the office, the Borough recognizes the limitations with regards to segregation of duties and therefore will consider mitigating controls. The Borough will continue to seek involvement from the Borough Council in terms of reviewing financial information.
Untimely Single Audit Filing - Auditor’s Recommendations: The Borough should establish a system to closely monitor Single Audit deadlines, designate clear responsibilities for the audit process, and proactively communicate with the auditor to ensure timely completion and submission of the report. Bo...
Untimely Single Audit Filing - Auditor’s Recommendations: The Borough should establish a system to closely monitor Single Audit deadlines, designate clear responsibilities for the audit process, and proactively communicate with the auditor to ensure timely completion and submission of the report. Borough’s Response: Eldred Borough was unable to contract a CPA to perform the single audit. This process included months of phone calls and emails to over 30 CPA and Accounting Firms across the State of Pennsylvania. The Borough has since contracted with a CPA firm to perform the 2025 single audit and do not anticipate it being delayed in submission.
Camillus House acknowledges the need to strengthen its allocation of OTPS costs charged to the SLFRF program and is implementing a formal, documented cost allocation plan that identifies objective and consistently applied allocation bases supported by contemporaneous records. Management is enhancing...
Camillus House acknowledges the need to strengthen its allocation of OTPS costs charged to the SLFRF program and is implementing a formal, documented cost allocation plan that identifies objective and consistently applied allocation bases supported by contemporaneous records. Management is enhancing internal controls by requiring measurable documentation for all OTPS charges, performing periodic reconciliations to ensure allocations reflect actual usage, and updating procedures to reinforce federal compliance standards. Staff training and ongoing monitoring have been established to ensure adherence to the revised allocation methodology, with oversight by Finance leadership and full implementation expected by June, 2026.
View Audit 373839 Questioned Costs: $1
Camillus House recognizes the need to ensure that payroll costs charged to the SLFRF program are based on actual time and effort rather than budgeted estimates and is implementing a formal reporting process supported by supervisor-approved documentation for all personnel charged to federal awards. T...
Camillus House recognizes the need to ensure that payroll costs charged to the SLFRF program are based on actual time and effort rather than budgeted estimates and is implementing a formal reporting process supported by supervisor-approved documentation for all personnel charged to federal awards. The organization is strengthening its payroll allocation procedures in Paylocity, updating relevant policies to align with Uniform Guidance, and providing targeted training to program and finance staff to reinforce compliance expectations. Management will conduct regular internal reviews to verify the accuracy of payroll charges and promptly address any discrepancies. These corrective actions, overseen by the Finance Department under the Chief Financial Officer, are expected to be fully implemented by June, 2026.
View Audit 373839 Questioned Costs: $1
Camillus House will be implementing enhanced procedures to ensure full compliance with HUD rent reasonableness requirements, including establishing standardized documentation protocols, instituting supervisory review prior to payment approval, providing staff training on rent reasonableness standard...
Camillus House will be implementing enhanced procedures to ensure full compliance with HUD rent reasonableness requirements, including establishing standardized documentation protocols, instituting supervisory review prior to payment approval, providing staff training on rent reasonableness standards, and conducting ongoing quarterly monitoring to verify compliance. These corrective actions are designed to ensure that all rental payments under the Continuum of Care Program are properly supported, reviewed, and retained in accordance with federal regulations by June, 2026.
Processes and controls have been implemented so that the accounting staff prepares the grant reimbursement requests which are reviewed and approved by the CEO for submission.
Processes and controls have been implemented so that the accounting staff prepares the grant reimbursement requests which are reviewed and approved by the CEO for submission.
Processes and controls have been implemented so that the accounting staff prepares the justification and expense support of the grant reimbursement requests which are reviewed and approved by the CEO for submission.
Processes and controls have been implemented so that the accounting staff prepares the justification and expense support of the grant reimbursement requests which are reviewed and approved by the CEO for submission.
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