Corrective Action Plans

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CORRECTIVE ACTION PLAN -For FY 2025 Audit Finding FINDING: 2025-001-ALN 14.871 & 14.879: U.S. Department of Housing and Urban Development’s (HUD’s) Section 8 Housing Choice Voucher (HCV) Program & Housing Quality Standards Inspection/HQS Enforcement CRITERIA: 24 CFR 982.405 & 983.103 require units l...
CORRECTIVE ACTION PLAN -For FY 2025 Audit Finding FINDING: 2025-001-ALN 14.871 & 14.879: U.S. Department of Housing and Urban Development’s (HUD’s) Section 8 Housing Choice Voucher (HCV) Program & Housing Quality Standards Inspection/HQS Enforcement CRITERIA: 24 CFR 982.405 & 983.103 require units leased, under the HCV Program, to be inspected at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. CONDITION: During the audit, three (3) failed HQS inspections, with life threatening issues as defined by the WVHA’s Administrative Plan, was found that did not receive a pass in conformance with the Criteria noted above and no HAP abatement process was enforced. Additionally, two (2) HCV units were found to have not been inspected at least biennially. PLAN FOR CORRECTION: Inspection Protocols- With the limitation of time imposed by the 24-hour remedy period, staff were calling and/or emailing the landlords as soon as they noted a Life, Health & Safety deficiency. Inspection staff have been informed that all Life Health and Safety deficiencies will immediately trigger a letter to the landlord (with a copy to the HCV caseworker) stating that Housing Assistance Payments will be placed in abatement and the HCV caseworkers will perform such abatement action as soon as the 24-hour period has elapsed (unless informed by the inspector that the property has subsequently corrected the deficiencies). Documentation- Physical inspection records will be provided to each HCV caseworker and be added to the tenant household’s HCV file within 24 hours of the inspection. HCV caseworkers are required to ensure all inspection documentation is properly located within each HCV file and such documentation is in accordance with the program’s rules and regulations. CONTACTS FOR PLAN: Cheryl Slagle – Housing Programs Manager Ph. (503) 623-8387 Ext. 328 cslagle@wvpha.org Christian Edelblute - Executive Director Ph. (503) 623-8387 Ext. 314 cedelblute@wvpha.org
1. Termination of responsible parties
1. Termination of responsible parties
• The Employee responsible for overriding the internal controls and improperly authorizing disbursements without sufficient documentation was terminated from employment by the board of directors on April 2, 2026.
• The Employee responsible for overriding the internal controls and improperly authorizing disbursements without sufficient documentation was terminated from employment by the board of directors on April 2, 2026.
2. Mandatory Disclosures
2. Mandatory Disclosures
• In accordance with 2 CFR 200.13 on April 2, 2026, the organization notified its Federal Awarding Agency in writing of the audit finding and on April 6, 2026 a “Grant or Contract Fraud Complaint” was file with the U.S. Department of Health and Human Services Office of Inspector General.
• In accordance with 2 CFR 200.13 on April 2, 2026, the organization notified its Federal Awarding Agency in writing of the audit finding and on April 6, 2026 a “Grant or Contract Fraud Complaint” was file with the U.S. Department of Health and Human Services Office of Inspector General.
3. Strengthening Documentation Requirements
3. Strengthening Documentation Requirements
• Implement standardized documentation checklists for all disbursements
• Implement standardized documentation checklists for all disbursements
• Require complete supporting documentation prior to payment approval
• Require complete supporting documentation prior to payment approval
4. Enhanced Review and Approval Process
4. Enhanced Review and Approval Process
• Establish formal pre-payment approval workflows
• Establish formal pre-payment approval workflows
• Require documented supervisory approval for all expenditures
• Require documented supervisory approval for all expenditures
• Implement secondary review for federally funded transactions
• Implement secondary review for federally funded transactions
5. Segregation of Duties
5. Segregation of Duties
• Reassign roles to separate authorization, processing, and reconciliation functions
• Reassign roles to separate authorization, processing, and reconciliation functions
• Implement compensating controls where staffing limitations exist
• Implement compensating controls where staffing limitations exist
6. Staff Training and Compliance Education
6. Staff Training and Compliance Education
• Provide mandatory training on Uniform Guidance (2 CFR Part 200)
• Provide mandatory training on Uniform Guidance (2 CFR Part 200)
• Conduct annual refresher training for all relevant staff
• Conduct annual refresher training for all relevant staff
7. Review of Questioned Costs
7. Review of Questioned Costs
• Conduct a detailed review of all identified transactions
• Conduct a detailed review of all identified transactions
• Determine allowability in accordance with federal requirements
• Determine allowability in accordance with federal requirements
• Reimburse the federal program for any unallowable costs
• Reimburse the federal program for any unallowable costs
8. Monitoring and Oversight
8. Monitoring and Oversight
• Implement periodic internal audits of disbursement activity
• Implement periodic internal audits of disbursement activity
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