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Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 In response to the finding related to non-compliance w...
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 In response to the finding related to non-compliance with procurement policies and procedures under Uniform Guidance 2 CFR §200.317 – §200.327, the Nebraska Urban Indian Health Coalition (NUIHC) is committed to ensuring full compliance with all applicable federal, state, local, and tribal procurement requirements. To address this finding and strengthen internal practices, the Coalition will implement the following corrective actions: 1. Procurement Policy Review with External Expertise: NUIHC has contracted with an external consultant with expertise in federal procurement regulations to assist in conducting a thorough review of the organization’s current procurement policies and procedures. This partnership will help ensure that all updates reflect the specific requirements of 2 CFR §200.317 – §200.327 and incorporate best practices in compliance, documentation, and oversight. 2. Update and Alignment of Procedures: With the support of the external contractor, NUIHC will update detailed procurement procedures to ensure they align with Uniform Guidance and any applicable state, local, or tribal procurement laws. Clear step-by-step procedures will be documented for each procurement method (e.g., micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals). 3. Ongoing Education and Training: NUIHC will implement a continued education and training program for all staff involved in procurement activities. In addition to the initial training on updated policies, refresher training will be offered annually and included as part of new employee onboarding. This will ensure sustained awareness of procurement responsibilities and regulatory compliance. 4. Internal Controls and Review Process: A formal internal control process will be implemented to verify compliance with updated procurement policies. This includes a procurement checklist, mandatory pre-approval protocols, and supporting documentation requirements for every procurement action. 5. Monitoring and Quarterly Compliance Checks: The Coalition will continue conducting quarterly internal audits of procurement activities to ensure adherence to policy, detect potential issues early, and implement timely corrective actions. Findings will be reported to leadership and the Board of Directors as part of ongoing compliance oversight. Timeline for Implementation: • External Consultant Engagement: Completed – May 2025 • Policy and Procedure Review: To be completed by July 31, 2025 • Initial Staff Training: To be conducted by August 15, 2025 • Internal Controls & Monitoring: To be fully implemented by August 31, 2025 • Ongoing Training and Quarterly Reviews: Begin Q3 2025 and continue thereafter Anticipated Full Compliance Date: August 31, 2025 Corrective Action Plan Finding 2024-005 – procurement Policy (Repeat Finding 2023-004) Responsible Party: Chief Financial Officer, Carlett Gregory
Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003) Condition: During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have. not collateralized cash balances more than the amounts insured by the Federal Despot Insurance Corporation. Cash balances o...
Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003) Condition: During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have. not collateralized cash balances more than the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $7,596,383 were uninsured at September 30, 2024. Unearned revenue was reported at approximately $4,434,584 which includes advance payments of Federal Funds. Corrective Action Plan – Finding 2024-004 Corrective Action: In response to the finding regarding the lack of collateralization for cash balances exceeding the amounts insured by the Federal Deposit Insurance Corporation (FDIC), the Nebraska Urban Indian Health Coalition (NUIHC) acknowledges that corrective actions were initially delayed due to the illness and eventual retirement of the former CEO. However, under new leadership, these actions have since been fully implemented. As of April 2025, NUIHC is in full compliance with the cash collateralization requirements outlined in 2 CFR §200.305(b)(7). A formal cash collateralization agreement has been executed with our financial institutions, ensuring that all cash balances—including advanced federal funds—are now either insured or properly collateralized. In addition to entering into this agreement, the following measures are in the process to strengthen ongoing compliance: 1. Updated Cash Management Policies: Policies are being reviewed and revised to reflect current federal requirements and internal procedures regarding custodial credit risk and cash handling practices. 2. Monitoring and Compliance Controls: A monitoring system is in place to routinely review cash balances and coordinate with our financial institution to ensure all funds remain protected. 3. Staff Training: Targeted training was provided to financial and accounting staff to ensure continued understanding of cash collateralization requirements and the importance of ongoing compliance. Implementation Summary: • Cash Collateralization Agreement: Completed – April 2025 • Policy Revisions and Monitoring System: In process– July 2025 • Staff Training: Completed by – August 2025 Responsible Party: Chief Financial Officer, Carlett Gregory
Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002) Condition: During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an a...
Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002) Condition: During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed. Corrective Action Plan – Finding 2024-003 Corrective Action: The Nebraska Urban Indian Health Coalition (NUIHC), in conjunction with our IT provider, has implemented a tracking system to support effective management of computer and other equipment purchased with federal funds. This includes maintaining an active equipment list and regularly updating clinic inventory on a quarterly basis for both clinic sites. Additionally, other organizational equipment is tracked using our depreciation schedule and internal records for assets that do not meet fixed asset thresholds. Inventory identification and tagging procedures are currently underway, with the goal of ensuring all equipment is properly labeled with a unique identifier and clearly marked to reflect Title V or other applicable funding sources. To further strengthen our internal controls and ensure full compliance with 2 CFR §200.313, NUIHC will take the following steps: 1. Development of Written Procedures: Comprehensive written procedures will be finalized and implemented to cover the maintenance, repair, protection, preservation, control, and accountability of all equipment purchased with federal funds. 2. Training for Staff: Additional training will be provided to all relevant staff responsible for equipment procurement, inventory tracking, and maintenance. This training will focus on the importance of proper identification, documentation, and adherence to federal equipment management standards. 3. Ongoing Monitoring: NUIHC will continue quarterly updates of clinic inventories and include periodic spot checks to verify the accuracy of records and physical inventory. Timeline for Implementation: • Finalization of written procedures: By August 31, 2025 • Completion of equipment identification and labeling: By September 30, 2025 • Staff training: Starting August 2025 and incorporated into annual compliance training Responsible Party: Chief Financial Officer, Carlett Gregory Anticipated Completion Date: September 30, 2025
Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001) Condition: During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal cont...
Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001) Condition: During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed. Corrective Action Plan: In response to the finding regarding insufficient internal controls over compliance for disbursements related to the Title V major program, the Nebraska Urban Indian Health Coalition (NUIHC) has previously taken several corrective actions to strengthen compliance, including: 1. Review and Revision of Policies and Procedures: NUIHC conducted a comprehensive review of internal control policies and procedures related to disbursements. Updates were made to ensure alignment with 2 CFR §200.313(a), and clear guidelines for review and approval processes were established. 2. Staff Training and Education: Training was provided to procurement and finance staff to ensure understanding of the revised procedures and federal compliance requirements, emphasizing the importance of proper approvals prior to disbursement. 3. Implementation of Standardized Approval Controls: A formal approval process and checklist system were implemented to ensure all disbursements are reviewed and approved by designated authorities before payment, with documentation retained for compliance. 4. Ongoing Monitoring and Internal Reviews: NUIHC began conducting quarterly internal compliance checks to verify adherence to updated procedures. Update and Continuation Plan: While these corrective actions were successfully implemented, the retirement of the former CEO temporarily stalled consistent oversight and reinforcement of these procedures. With new leadership in place, NUIHC is recommitting to the continued execution and monitoring of these corrective actions. Refresher training will be incorporated into ongoing professional development and onboarding for new staff, and quarterly internal audits will resume as scheduled. Timeline for Implementation: Corrective actions were initially implemented in 2024, and reinforcement activities—including staff refreshers and compliance monitoring—will continue a rolling basis starting July 2025. Responsible Party: Chief Financial Officer, Carlett Gregory Anticipated Completion Date: Ongoing; reinforcement begins July 2025
2024-005 – ALN 14.871 – Housing Voucher Cluster – Special Tests – HQS Enforcement Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executiv...
2024-005 – ALN 14.871 – Housing Voucher Cluster – Special Tests – HQS Enforcement Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Completion Date: September 30, 2025
2024-004 – ALN 14.871 – Housing Voucher Cluster – Reporting Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Co...
2024-004 – ALN 14.871 – Housing Voucher Cluster – Reporting Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Completion Date: September 30, 2025
2024-003 – ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected ...
2024-003 – ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Completion Date: September 30, 2025
2024-002 – ALN 14.871 – Housing Voucher Cluster – Allowable Activities Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer P...
2024-002 – ALN 14.871 – Housing Voucher Cluster – Allowable Activities Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. J. Daniels, Chief Executive Officer Projected Completion Date: September 30, 2025
USSEC was following the FAS required process of obtaining all appropriate disposal documentation prior to removing these assets from the GL and the asset list. At year-end, USSEC was waiting on a memo from the China Regional Director explaining why there was no documentation of their disposal. Until...
USSEC was following the FAS required process of obtaining all appropriate disposal documentation prior to removing these assets from the GL and the asset list. At year-end, USSEC was waiting on a memo from the China Regional Director explaining why there was no documentation of their disposal. Until that was available, USSEC did not feel they should request FAS approval to dispose and remove from our GL and asset listing. Therefore, the assets remained on USSEC’s year-end GL and asset listing. To date, that has not been received from the China office, though they are requesting it once again. FAS approval was requested May 20, 2025, and received June 5, 2025. The assets will be removed fromthe GL and assets list as of June 30, 2025.
Department of Homeland Security Federal Emergency Management Agency Disaster Grant Public Assistance – FEMA – Assistance Listing No. 97.036 Recommendation: Provide clear, updated guidance and periodic training sessions on earmarking rules and how to apply them. Conduct reviews of earmarking compli...
Department of Homeland Security Federal Emergency Management Agency Disaster Grant Public Assistance – FEMA – Assistance Listing No. 97.036 Recommendation: Provide clear, updated guidance and periodic training sessions on earmarking rules and how to apply them. Conduct reviews of earmarking compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New procedures will be implemented that strengthen internal controls to ensure that all grant revenues are recorded properly. Name(s) of the contact person(s) responsible for corrective action: Lindsey Barwick, Accounting Manager Hardee County Clerk of Courts & Lorie Ayers, General Services Director Hardee County Board of County Commissioners Planned completion date for corrective action plan: September 30, 2025
View Audit 361030 Questioned Costs: $1
Finding Reference Number: 2024-001 Description of Finding: Expenditures totaling $273,298 were incorrectly charged to the 93.464 program for a fiscal year in which the costs were not actually incurred. This misclassification resulted from recording expenses based on the purchase order date (Septemb...
Finding Reference Number: 2024-001 Description of Finding: Expenditures totaling $273,298 were incorrectly charged to the 93.464 program for a fiscal year in which the costs were not actually incurred. This misclassification resulted from recording expenses based on the purchase order date (September 30) rather than the actual service date, leading to overbilling for the grant year. Statement of Concurrence or Nonconcurrence: We concur with the audit finding regarding the misclassification of expenditures totaling $273,298 to the 93.464 program after the fiscal year-end. We acknowledge that these costs were recorded in the incorrect accounting period, resulting in an overstatement of grant expenditures for the fiscal year. Corrective Action: 1. Policy Update: CFILC will revise expense recognition policies to require that costs be recorded in the period matching the actual service date. 2. Year-End Review Process: CFILC will implement a formal review process at fiscal year-end to confirm expenses are attributed to the correct fiscal year. 3. Staff Training: CFILC will provide training for financial reporting and grant billing staff on the expense recognition policy and year-end review process. 4. Monitoring & Compliance: CFILC will establish periodic internal audits or reviews to ensure ongoing compliance with the updated procedures. 5. Finance Committee Oversight: Executive Director will report to the Finance Committee on the status of this corrective action plan by the completion date of December 31, 2025. Name of Contact Person: Kathrine Crowley, Acting Executive Director, kathrine@cfilc.org, (916) 232-1985 Projected Completion Date: December 31, 2025
Program: Section 8 Housing Choice Voucher Finding: 2024-007 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Implementation of New Software Sy...
Program: Section 8 Housing Choice Voucher Finding: 2024-007 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Implementation of New Software System: o HACLB has transitioned to the new MRI housing management software platform, which offers fully sufficient functionality and reporting capabilities compared to the prior system. o The new MRI system provides the Inspections Team with advanced tools to organize, schedule, and track Quality Control inspections efficiently and accurately. 2. Improved Reporting and Compliance: o The MRI system’s reporting functions allow HACLB to generate detailed and timely listings of all Housing Quality Control inspections. o This improvement supports HACLB’s ability to meet HUD requirements for inspection scheduling, documentation, and follow-up activities. Expected Completion Date: December 31, 2025
Program: Section 8 Housing Choice Voucher Finding: 2024-006 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Automated Data Validation and Err...
Program: Section 8 Housing Choice Voucher Finding: 2024-006 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Automated Data Validation and Error Detection: o HACLB utilizes the MRI housing management software, which syncs to the HUD’s PIC (Public and Indian Housing Information Center)requirements, ensuring data consistency and validation. o The MRI system incorporates HUD’s mandated validation standards and automatically identifies errors in participant data before submission to the PIC system. o Validation errors flagged by MRI are reviewed and corrected prior to submission to HUD, ensuring data accuracy and compliance. 2. Compliance with HUD Standards and Reporting: o Each recertification is submitted to the HUD PIC system, which further validates the data and alerts HACLB to any errors through the PIC Error Dashboard. o HACLB promptly addresses and corrects errors identified by PIC to maintain program integrity and compliance with HUD reporting standards. 3. Quality Control and Training: o HACLB conducts annual SEMAP (Section Eight Management Assessment Program) evaluations, which include quality control indicators to assess the accuracy of calculations and program administration. o Errors identified through SEMAP and system validations are used proactively as training opportunities for staff. o New Housing Specialists’ work is closely reviewed during their training period to ensure accuracy and compliance. 4. Systematic Tracking and Monitoring: o The MRI system facilitates ongoing quality control tracking, enabling Housing staff to monitor and correct errors effectively. o HACLB’s process includes regular oversight and review of participant files and related transactions to ensure timely and accurate housing assistance payments and reporting. Expected Completion Date: December 31, 2025
Program: Section 8 Housing Choice Voucher Finding: 2024-005 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Process Improvement for Reinspect...
Program: Section 8 Housing Choice Voucher Finding: 2024-005 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Process Improvement for Reinspection Scheduling: o Beginning December 2024, HACLB implemented an enhanced scheduling process to ensure all reinspections are conducted prior to the expiration of the required 30-day remediation period. o The agency has configured its housing software platform (MRI) to automatically schedule reinspections in advance of the 30-day deadline following the identification of deficiencies. This automated process minimizes the risk of delay or oversight. 2. Extension Tracking and Compliance Monitoring: o The MRI system is also configured to flag cases where an extension has been requested or approved, allowing for documented exceptions while maintaining compliance oversight. o Staff monitor reinspection dates regularly through system-generated reports to ensure adherence to HUD standards and to follow up on any outstanding cases. Expected Completion Date: December 31. 2025
Finding 569681 (2024-004)
Significant Deficiency 2024
Program: Port Security Grant Program Finding: 2024-004 Contact Person: Karen Rindone Assistant Fire Chief Long Beach Fire Department Phone: (562) 570-2544 Email: Karen.Rindone@longbeach.gov Planned Actions: The Fire Department will ensure that all grant funds are expended in compliance with grant...
Program: Port Security Grant Program Finding: 2024-004 Contact Person: Karen Rindone Assistant Fire Chief Long Beach Fire Department Phone: (562) 570-2544 Email: Karen.Rindone@longbeach.gov Planned Actions: The Fire Department will ensure that all grant funds are expended in compliance with grant guidelines, including the completion of a biennial Equipment Inventory and the submission of a certification letter verifying its accuracy to the grantor every other year. Effective June 16, 2025, the Fire Department will conduct an Equipment Inventory and submit a verification letter to the grantor confirming its completion on a biennial basis. The current Equipment Inventory will be completed by the Support Services Bureau by September 30, 2025. The Fire Department will ensure the accompanying verification letter is sent to the grantor along with the updated inventory list. This biennial requirement will be integrated into the Department’s annual calendar. Following the FY2025 inventory, the next cycle will occur in FY2027 and continue in every odd-numbered fiscal year thereafter. Expected Completion Date: 9/30/2025 Finding: 2024-004 Program: Port Security Grant Program Federal Award Number: EMW-2021-PU-00259 Contact Person: Don Kwok Assistant Director of Finance City of Long Beach Harbor Department Phone: (562) 283-7575 Email: Don.Kwok@polb.com Finding: The Harbor Department failed to properly record the disposition of a federally funded asset. The asset was still marked as “in service” within the equipment listing for FY2024. However, the item had in fact been disposed of during FY2024 after an accident. The asset had a $0 value prior to the accident which initiated the disposal. Corrective Action Plan: The Harbor Department will enhance its written procedures on equipment disposals and provide training to appropriate Finance, Security, and Maintenance Division staff in FY 2025 to ensure compliance and timeliness in following equipment disposal procedures.
Program: Section 8 Housing Choice Voucher Finding: 2024-003 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Staff Augmentation and Training: ...
Program: Section 8 Housing Choice Voucher Finding: 2024-003 Contact Person: Michelle Mel-Duch Housing Administrative and Financial Services Officer Health & Human Services Department Phone: (562) 570-5344 Email: Michelle.Mel-Duch@longbeach.gov Planned Actions: 1. Staff Augmentation and Training: o In January 2025, HACLB submitted requisitions to the Human Resources Department to recruit additional Housing Specialists to improve the management of high volume HCV program participants, documentations, processes, and to meet various requirement deadlines. o As of May 3, 2025, four new Housing Specialists have been hired and are currently undergoing training. Four additional Housing Specialists are in the onboarding process with Human Resources Department. o Several supervisory positions remain unfilled due to the need to renew the hiring list. HACLB has submitted a request to initiate the renewal process in order to recruit from a new list. o In addition, HACLB has hired a Housing Administrative and Financial Services Officer and a Housing Operations Program Officer. These roles are critical in providing oversight of operational workflows, evaluating staff productivity, and developing strategies to optimize staffing levels and resource allocation. 2. Contracted Support Services: o To address a backlog of overdue reexaminations, HACLB renewed its contract with an external agency to provide dedicated assistance in processing pending cases. This contract became effective in May 2025 and has already begun to support the reexamination workload. 3. Technology Upgrade: o HACLB has transitioned to a new housing software platform tailored to improve the tracking and processing of annual recertifications. This system upgrade enhances productivity monitoring, facilitates efficient workflow management, and supports compliance with HUD timeliness standards. Expected Completion Date: September 30, 2026
Program: HOME Investment Partnerships Program (HOME) Finding: 2024-002 Contact Person: April Apodaca Administrative & Financial Services Bureau Manager Community Development Department Phone: (562) 570-6611 Email: April.Apodaca@longbeach.gov Planned Actions: The City has increased the number of p...
Program: HOME Investment Partnerships Program (HOME) Finding: 2024-002 Contact Person: April Apodaca Administrative & Financial Services Bureau Manager Community Development Department Phone: (562) 570-6611 Email: April.Apodaca@longbeach.gov Planned Actions: The City has increased the number of properties inspected each fiscal year. For example, during the FY23 audit period, 204 inspections occurred. In the FY24 period, the number of inspections increased to 227. As of May 2025, the City has inspected 187 units and anticipates a total of 250 inspections will be completed by the end of FY25, thereby eliminating the current backlog and any late inspections. The Community Development Department implemented more proactive measures, including hiring an in-house inspector and an active master inspection log to track and target upcoming inspections. These efforts have resulted in a more streamlined, data-informed approach to HQS compliance, as evidenced by a significant reduction in the inspection backlog. The master inspection log is also being leveraged to optimize inspection scheduling and ensure that the required HOME units per property are inspected as required. To reinforce this approach, the City instituted a structured, monthly review of the log to improve data accuracy, completeness, and early identification of potential delays. The City is confident that these measures will demonstrate compliance with the HQS standards and resolve the auditor’s concerns. Expected Completion Date: 12/31/2025
Program: HOME Investment Partnerships Program (HOME) Finding: 2024-001 Contact Person: April Apodaca Administrative & Financial Services Bureau Manager Community Development Department Phone: (562) 570-6611 Email: April.Apodaca@longbeach.gov Planned Actions: The City continues to monitor HOME-ass...
Program: HOME Investment Partnerships Program (HOME) Finding: 2024-001 Contact Person: April Apodaca Administrative & Financial Services Bureau Manager Community Development Department Phone: (562) 570-6611 Email: April.Apodaca@longbeach.gov Planned Actions: The City continues to monitor HOME-assisted units to ensure eligibility with income requirements. Since the last audit period, the developer has not yet complied with multiple requests from the City to provide missing documentation; however, City staff continues outreach and has communicated shortcomings with said developer on the dates mentioned in FY 23 corrective action plan and also July 2, 2024, July 16, 2024, July 18, 2024, September 3, 2024, September 10, 2024, September 11, 2024, September 18, 2024, October 30, 2024, November 4, 2024, and December 2, 2024. The City informed the developer that continued non-compliance will result in escalation to the City Attorney, and escalation is currently underway. The City has updated procedures to add layers of review and increase frequency of communication with developers to ensure timely submission and efforts to obtain necessary documents. The City is confident that these measures will demonstrate compliance with eligibility requirements and resolve the auditor’s concerns. Expected Completion Date: 12/31/2025
Item 2024-002 (Repeat 2023-002) Reporting – Management’s Response – The Agency will implement controls to ensure proper review and approval is obtained on required grant reports prior to submission to the grantor. Anticipated Completion: September 30, 2025 Responsible Party: Jim Harnett, Execut...
Item 2024-002 (Repeat 2023-002) Reporting – Management’s Response – The Agency will implement controls to ensure proper review and approval is obtained on required grant reports prior to submission to the grantor. Anticipated Completion: September 30, 2025 Responsible Party: Jim Harnett, Executive Director
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-007: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 - Sig...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-007: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 - Significant Deficiency RECOMMENDATION The auditor recommends the Project and management review and attend training on the HUD Handbook. In addition, the auditor recommends the Project and management review its internal control policies and procedures. ACTION TAKEN Carrasquillo Management LLC acknowledges the significant deficiency noted and is committed to improving internal controls to ensure full compliance with all HUD program requirements. 1. Policy and Procedure Review Management has initiated a comprehensive review of internal control policies and procedures to identify gaps and align practices with the HUD Handbook 4350.3 and related program regulations. Updates will be made to strengthen compliance checkpoints and clearly define staff responsibilities for each stage of tenant file processing, income verification, certifications, and documentation retention. 2. Training and Capacity Building Carrasquillo Management LLC has committed to ongoing staff development by enrolling relevant personnel in HUD-compliant training programs focused on regulatory requirements, internal controls, and compliance best practices. All staff involved in leasing, recertifications, and program compliance will be required to complete refresher trainings at least annually. 3. Internal Audit and Quality Control A quarterly internal audit process has been established to monitor the effectiveness of internal controls and ensure consistent application across all major program functions. Findings from these audits will be reviewed by senior management, and corrective actions will be taken immediately when deficiencies are identified. 4. Oversight and Accountability Management will assign a dedicated compliance coordinator responsible for overseeing adherence to HUD regulations and internal policies, providing regular updates to leadership, and ensuring follow-through on all audit-related corrective actions. Carrasquillo Management LLC is committed to fostering a culture of compliance and accountability and will take all necessary steps to prevent future deficiencies and ensure the Project remains in good standing with HUD program requirements.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-006: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-006: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends the Project and management review and attend training on the HUD Handbook 4350.3 Revision 1 requirements for tenant files including eligibility and income calculations. In addition, the auditor recommends the Project obtain necessary recertification signatures timely. ACTION TAKEN Carrasquillo Management LLC acknowledges the findings and is taking the following corrective actions to ensure compliance with HUD Handbook 4350.3 requirements: 1. Enterprise Income Verification (EIV) Reports Management has implemented an internal checklist to ensure that the initial EIV reports are generated within the required 90 days for all move-ins. Staff has been retrained on EIV protocols and timelines to ensure timely compliance going forward. 2. Timely Tenant Signatures on Recertifications A new recertification specialist has been hired, who is fully trained and qualified in HUD income certifications. Carrasquillo Management LLC has implemented a new tracking system and notification schedule to ensure that all recertification documents are signed by tenants on or before the effective date. Management is also increasing tenant engagement through reminder letters and calls. 3. Bank Account Balance Calculations Staff has received additional training on income and asset calculations per HUD guidance. A verification template has been implemented to ensure all checking account balances are calculated using the six-month average, as required. 4. Security Deposit Charges The error identified regarding the incorrect security deposit has been corrected. Going forward, all move-ins will include a verification step to ensure that the correct deposit is charged in accordance with lease and program guidelines. 5. Date and Time-Stamped Applications Management has implemented a new policy requiring staff to date-and time-stamp all tenant applications upon receipt. Staff has been trained accordingly and periodic file reviews will be conducted to ensure compliance. 6. Missing Lease and Application Documents Management has begun a full file audit to identify and correct any remaining deficiencies. Procedures have been updated to ensure original leases and completed applications are filed immediately upon move-in and scanned into the electronic system as a backup. 7. Move -Inspections A revised move-in protocol has been established that includes a checklist confirming inspection completion and file documentation. A copy of the move-in inspection form is now required to be signed by both tenant and management and scanned into the file on the same day of move-in. 8. Training and Oversight Carrasquillo Management LLC will continue to provide regular staff training and compliance reviews to ensure that all HUD file requirements are met. In addition, quarterly internal audits will be conducted to verify proper documentation and adherence to timelines. We are committed to maintaining full compliance with HUD regulations and ensuring tenant file accuracy moving forward.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-005: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-005: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends ensuring all tenant’s paperwork is thoroughly reviewed and accurately used in the calculation of the tenant’s required monthly rent and HUD’s tenant assistance payments. ACTION TAKEN Carrasquillo Management LLC acknowledges the audit finding related to rent miscalculations for five tenant files during the fiscal year ended September 30, 2024. These errors resulted in both minor tenant overcharges and undercharges, as well as corresponding discrepancies in HUD’s rental assistance payments. 1. Financial Corrections ○ The Project will reimburse the two affected tenants a total of $14 to correct the overcharges. ○ The Project will submit a request to HUD to repay the $14 in overpaid rental assistance associated with these tenants. ○ For the three tenants who were undercharged a total of $826, the Project will bill the tenants for the rent differential in accordance with HUD regulations and provide HUD with reimbursement of the $826 in excess rental assistance paid. 2. File Review and Quality Control Measures Management has implemented a secondary file review process for all certifications and recertifications to ensure that income is correctly verified, entered, and calculated in accordance with HUD Handbook 4350.3 requirements. All tenant income documentation will be double-checked by the compliance team prior to finalizing certifications. 3. Staff Training All staff involved in income verification and rent calculation have been retrained on HUD rent calculation guidelines, including handling of paystubs, Social Security statements, and other income documentation. Training includes real-case scenarios and common error prevention techniques. 4. Compliance Oversight Moving forward, Carrasquillo Management LLC will conduct quarterly internal audits of a random sample of tenant files to verify the accuracy of income calculations and ensure compliance with HUD regulations. Carrasquillo Management LLC remains committed to ensuring the accuracy of tenant rent determinations and maintaining compliance with HUD’s income calculation requirements. All necessary reimbursements and corrective actions will be completed promptly and documented for HUD’s records.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-004: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-004: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends the Property receive HUD approval before withdrawing funds from its residual receipts account and repay the $163,679 to the residual receipts account. ACTION TAKEN Carrasquillo Management LLC acknowledges the finding regarding the unauthorized withdrawal of $163,679 from the Project’s residual receipts account during the fiscal year ended September 30, 2024. This withdrawal was related to surplus cash from fiscal year 2023 that had been deposited into the residual receipts account. Due to miscommunication and misunderstanding during the transition between management companies, the withdrawal was made without obtaining prior written approval from HUD, as required under HUD Handbook 4370.2 Revision 1. Corrective Actions: 1. Repayment Agreement with HUD Carrasquillo Management LLC has been in direct communication with the Project’s HUD Account Executive, Nyal McDonough, of the Northeast Region Asset Management Division. HUD has agreed to allow the Project to repay the full $163,679 through monthly installments as part of an interest-free repayment plan until the balance is fully restored to the residual receipts account. This agreement is currently being implemented and tracked in coordination with HUD. 2. Internal Compliance Controls To ensure full compliance going forward, Carrasquillo Management LLC has updated internal policies and procedures to strictly prohibit any withdrawals from the residual receipts account without explicit written authorization from HUD. All future requests for residual receipts will be submitted through HUD’s formal request channels, and no funds will be accessed without prior written approval. 3. Staff Training Relevant personnel have received training on HUD Handbook 4370.2 and HUD financial controls regarding restricted accounts. Additional safeguards are in place to ensure management and accounting teams confirm HUD approval documentation before any restricted account disbursement. 4. Monthly Monitoring and Reporting Carrasquillo Management LLC will include the residual receipts repayment schedule in its monthly financial reporting to ownership and will maintain communication with HUD to ensure full transparency throughout the repayment period. Carrasquillo Management LLC is committed to full regulatory compliance and to restoring the integrity of all project accounts in collaboration with HUD.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-003: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-003: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends management review the HUD Handbook on determining eligible income included in the management fee calculation. ACTION TAKEN Carrasquillo Management LLC acknowledges the auditor’s finding regarding the overcharged management fee of $13,884 for the fiscal year ended September 30, 2024. The overcharge occurred during the management transition in March 2024. The outgoing management company, Mount Holyoke Management LLC, issued and received a management fee payment for the full month of March despite their services ending early in the month. Carrasquillo Management LLC officially took over management of the Project on March 9, 2024, and also received the management fee for services rendered during the remainder of that month. This resulted in both management companies receiving compensation for the same period, causing the annual management fee to exceed HUD’s allowable limits. Corrective Actions: 1. Fee Review and Adjustment Carrasquillo Management LLC is working with the auditor and ownership to correct the management fee overcharge in the Project’s financial records. Any necessary adjustments or reimbursements will be made to bring the project into compliance. 2. HUD Handbook Compliance Training Management has reviewed the relevant guidance in HUD Handbook 4381.5 Revision 2 and is ensuring that all future management fee calculations strictly follow HUD’s criteria for eligible income and fee limits. 3. Transition Protocols To prevent this issue from recurring during future management transitions, Carrasquillo Management LLC has developed a formal transition protocol that includes a reconciliation of income and fees and written confirmation of responsibilities to avoid any overlapping charges. 4. Oversight and Internal Controls All future management fee calculations will be reviewed and approved by the Regional Manager and Accounting Department to verify accuracy and compliance with HUD guidelines prior to disbursement. Carrasquillo Management LLC remains committed to ensuring proper financial stewardship of HUD program funds and maintaining compliance with all applicable regulations.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-002: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 REC...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-002: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends moving some of the Project’s funds to other banks to ensure all bank account balances at each bank remain below the FDIC limit. ACTION TAKEN Carrasquillo Management LLC acknowledges the finding regarding the Project’s bank balances exceeding the Federal Deposit Insurance Corporation (FDIC) insured limit of $250,000. Carrasquillo Management LLC assumed management of the Project on March 9, 2024. At the time of transition, all existing bank accounts were already established with Westfield Bank. Management has since reviewed the account structure and balances to assess compliance with FDIC coverage requirements. Corrective Actions: 1. Risk Mitigation Plan Carrasquillo Management LLC is in the process of restructuring the Project’s banking arrangements to ensure that no single institution holds more than the FDIC-insured limit of $250,000 per ownership category. 2. Diversification of Funds The Project will open additional accounts with other FDIC-insured financial institutions and transfer excess funds accordingly. This will help safeguard assets and reduce exposure in the unlikely event of bank failure. 3. Ongoing Monitoring Management has implemented a monthly monitoring protocol to review account balances and ensure ongoing compliance with FDIC limits. This process includes scheduled reviews by the finance team to confirm that no account exceeds the insured threshold. 4. Policy Update Internal financial policies are being updated to include FDIC compliance requirements, ensuring that any future account openings or large fund deposits are properly reviewed and managed. Carrasquillo Management LLC is committed to protecting the financial assets of the Project and ensuring full compliance with HUD requirements and FDIC insurance guidelines.
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