Corrective Action Plans

Finding 515844 (2024-001)

None 2024

NC

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Name of Responsible Individual: Mr. Brian K. Blackburn Corrective Action: As a result of Audit Finding 2023-001 the University had implemented a weekly COD Maintenance Files for Direct Loans and Pell Grants. The 2024-001 Finding is a result of an oversight in the setup of the one student record that...

Name of Responsible Individual: Mr. Brian K. Blackburn Corrective Action: As a result of Audit Finding 2023-001 the University had implemented a weekly COD Maintenance Files for Direct Loans and Pell Grants. The 2024-001 Finding is a result of an oversight in the setup of the one student record that caused the information to not be picked up and included in the weekly file. The problem has now been identified and corrected to ensure that such an oversight does not reoccur. Additionally, the University has implemented a new policy in terms of creating and updating student records. Anticipated Completion Date: December 9, 2024

View Audit 333710

Finding 515841 (2024-006)

Significant Deficiency 2024

Anson County

NC

Eligibility Reporting Significant Deficiency

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: ...

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Inaccurate Resources Entry The County met with all Adult Medicaid Staff to discuss inaccurate resource entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28 through 10/29/24 Finding: 2024-004 Corrective Actions for findings 2024-002, 2024-003, 2024-004, 2024-005, and 2024-006 also apply to the State Award findings. Finding: 2024-005 Inaccurate Information Entry The County met with All MAGI and Adult Medicaid Staff to discuss inaccurate information entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings Section IV- State Award Findings and Questioned Costs Finding: 2024-006 Untimely Review of SSI Terminations The County met with all Adult Medicaid Staff to discuss the untimely review of SSI terminations and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28/24

View Audit 333693

Finding 515840 (2024-005)

Significant Deficiency 2024

Anson County

NC

Eligibility Significant Deficiency

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: ...

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Inaccurate Resources Entry The County met with all Adult Medicaid Staff to discuss inaccurate resource entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28 through 10/29/24 Finding: 2024-004 Corrective Actions for findings 2024-002, 2024-003, 2024-004, 2024-005, and 2024-006 also apply to the State Award findings. Finding: 2024-005 Inaccurate Information Entry The County met with All MAGI and Adult Medicaid Staff to discuss inaccurate information entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings Section IV- State Award Findings and Questioned Costs Finding: 2024-006 Untimely Review of SSI Terminations The County met with all Adult Medicaid Staff to discuss the untimely review of SSI terminations and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28/24

View Audit 333693

Finding 515839 (2024-004)

Significant Deficiency 2024

Anson County

NC

Eligibility

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: ...

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Inaccurate Resources Entry The County met with all Adult Medicaid Staff to discuss inaccurate resource entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28 through 10/29/24 Finding: 2024-004 Corrective Actions for findings 2024-002, 2024-003, 2024-004, 2024-005, and 2024-006 also apply to the State Award findings. Finding: 2024-005 Inaccurate Information Entry The County met with All MAGI and Adult Medicaid Staff to discuss inaccurate information entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings Section IV- State Award Findings and Questioned Costs Finding: 2024-006 Untimely Review of SSI Terminations The County met with all Adult Medicaid Staff to discuss the untimely review of SSI terminations and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28/24

View Audit 333693

Finding 515838 (2024-003)

Significant Deficiency 2024

Anson County

NC

Eligibility Significant Deficiency

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Finding: 2024-003 IV-D Non-Cooperation The County met with All MAGI Medicaid Staff to discuss the no...

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Finding: 2024-003 IV-D Non-Cooperation The County met with All MAGI Medicaid Staff to discuss the noncooperation with child support procedures and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/29/24 Section III - Federal Award Findings and Questioned Costs Corrective Action Plan Meeting held 10/28/24 Inadequate Request for Information The County met with all Adult Medicaid Staff to discuss inadequate request for information and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Reconciliation of Records and Reporting Holly Martinez-Borja, Finance Director The County has made great efforts to achieve the timely completion of the annual audit and issuance of the financial statements. The County will ensure the appropriate year-end accounting adjustments to be properly recorded. The County has hired an experienced Finance Officer with 20 years of experience. An Assistant Finance Officer position has been added to the department to assist with the daily operations to increase capacity within the department. Board policies and procedures are implemented to increase oversight and accountability. For the Year Ended June 30, 2024 Section II - Financial Statement Findings Finding: 2024-001 Imminently.

View Audit 333693

Finding 515837 (2024-002)

Significant Deficiency 2024

Anson County

NC

Eligibility Significant Deficiency

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Finding: 2024-003 IV-D Non-Cooperation The County met with All MAGI Medicaid Staff to discuss the no...

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Finding: 2024-003 IV-D Non-Cooperation The County met with All MAGI Medicaid Staff to discuss the noncooperation with child support procedures and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/29/24 Section III - Federal Award Findings and Questioned Costs Corrective Action Plan Meeting held 10/28/24 Inadequate Request for Information The County met with all Adult Medicaid Staff to discuss inadequate request for information and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Reconciliation of Records and Reporting Holly Martinez-Borja, Finance Director The County has made great efforts to achieve the timely completion of the annual audit and issuance of the financial statements. The County will ensure the appropriate year-end accounting adjustments to be properly recorded. The County has hired an experienced Finance Officer with 20 years of experience. An Assistant Finance Officer position has been added to the department to assist with the daily operations to increase capacity within the department. Board policies and procedures are implemented to increase oversight and accountability. For the Year Ended June 30, 2024 Section II - Financial Statement Findings Finding: 2024-001 Imminently.

View Audit 333693

Finding 515828 (2024-001)

Significant Deficiency 2024

Catholic Charities of the Diocese of Tulsa, Inc.

OK

Questioned Costs Allowable Costs / Cost Principles § 200.303

Audit Finding Reference: 2024-001 Department's Response: We concur. Views of Responsible Officials and Corrective Action: There were not sufficient controls to ensure accurate payroll expenditures were submitted for reimbursement. Payroll in excess of $31,565 was charged to the grant. CCEOK has i...

Audit Finding Reference: 2024-001 Department's Response: We concur. Views of Responsible Officials and Corrective Action: There were not sufficient controls to ensure accurate payroll expenditures were submitted for reimbursement. Payroll in excess of $31,565 was charged to the grant. CCEOK has implemented a more robust review process that includes all payroll expenditures billed to the grant are traced back to supporting details. CCEOK will reimburse the overbilled amounts to the funder. Name of Contact Person: Lisa Wheeler, CPA Director of Finance Lwheeler@CCEOK.org 918-508-7118 Date of Implementation: October 2024

View Audit 333690 Questioned Costs: $1

Finding 515824 (2024-002)

Significant Deficiency 2024

Glen Oaks Community College

MI

Special Tests & Provisions Student Financial Aid Significant Deficiency

2024-002 – Return of Title IV Calculation. Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Winter 2024 semester, which resulted in the calculation being incorrect for all students who had returns in t...

2024-002 – Return of Title IV Calculation. Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Winter 2024 semester, which resulted in the calculation being incorrect for all students who had returns in the Winter 2024 semester. As a result of this condition, Return of Title IV calculations were incorrect for five students for the Winter 2024 semester, resulting in $66.52 in excess funds returned to the U.S. Department of Education. It is our understanding that on August 14, 2024, the College repaid the five students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem from arising in the future, the College has developed a review process where the Director of Financial Aid will review break day regulations in the FSA handbook and verify that the Ellucian Colleague annual set-up has accurate break days. The Director of Financial Aid will also verify accuracy as calculations are processed for students. Responsible Party. Jean Zimmerman, Director of Financial Aid. Anticipated Completion Date. August 14, 2024.

View Audit 333681

Finding 515820 (2024-001)

Significant Deficiency 2024

Glen Oaks Community College

MI

Reporting Special Tests & Provisions Student Financial Aid

2024-001 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. During our testing of thirteen students with status changes, we noted six instances of late reporting of a student's status changes. Three of these instances were winter term graduates whose status change...

2024-001 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. During our testing of thirteen students with status changes, we noted six instances of late reporting of a student's status changes. Three of these instances were winter term graduates whose status change was reported one day late. The other three of these instances were winter term graduates whose status changes had not been reported as of the date of our audit fieldwork, due to a technical glitch in the College's reporting system. Therefore, the NSLDS system is not updated with the student information timely which could lead to a student's grace period being shortened. Auditor Recommendation. We recommend that the College review its reporting procedures to ensure that students' status changes are accurately and timely reported to NSLDS as required by regulators. Corrective Action. The Director of Financial Aid will review the reporting procedures to ensure that students' status changes are accurately and timely reported to NSLDS. The Director of Financial Aid will check NSLDS to ensure timely reporting. Responsible Party. Jean Zimmerman, Director of Financial Aid, and Amy Young, Registrar. Anticipated Completion Date. First Fall 2024 NSC reporting.

View Audit 333681

Finding 515819 (2024-001)

Significant Deficiency 2024

Ashland University

OH

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

The Registrar's Office has performed a further review of its policies and procedures to continue to ensure timely, accurate, and complete submission of enrollment records. The Registrar’s Office has updated its procedures to include response schedules with internal control mechanisms for monitoring ...

The Registrar's Office has performed a further review of its policies and procedures to continue to ensure timely, accurate, and complete submission of enrollment records. The Registrar’s Office has updated its procedures to include response schedules with internal control mechanisms for monitoring compliance with the seven-day response requirement to the Provost’s Office and processing requests for additional assistance as necessary. The updated response schedule includes a goal to respond to error reports within four days of receipt, with final submission no later than six days following notice of the error report, unless the Provost has been notified that enrollment updates have been suspended by National Student Clearinghouse while files are being processed, in which case the Registrar’s Office will monitor and document the processing status until the suspension has been raised. Any response which will exceed six days requires written notice to the Provost’s Office with a plan to complete the required enrollment updates by 5:00pm ET on the seventh day, and any request for additional assistance or resources necessary to do so. Members of the Registrar’s Office also participated in additional training through National Student Clearinghouse with respect to enrollment reporting and error report codes related to enrollment effective dates. Training related to enrollment reporting will be scheduled at least annually through the Registrar’s Office. Finding 2022-005 of the Final Audit Determination (FAD) found that student enrollment status effective dates required further updates following the initial data corrections which were completed in September 2023. In addition to review of its policies and procedures and training, the Registrar’s Office engaged with its third-party servicer for enrollment reporting to review the data reporting systems and integration, as well as the data and information reported by the servicer to the National Student Loan Data System (NSLDS), during its response to Finding 2022-005. In response to the required action for this finding, the University requested an extension and the extension was granted to complete the required action with the U.S. Department of Education Office of Federal Student Aid (FSA). FSA requested regular status reporting and the University complied with the reporting requirement. The status reporting included updates as to the progress of the review and the University’s methods for reviewing and updating the enrollment reports so that FSA could ensure timely and accurate progress was being achieved throughout the University’s completion of the required action. The University completed the required corrections within the extension timeline of September 30, 2024.

View Audit 333674

Finding 515804 (2024-001)

Significant Deficiency 2024

Ashland County Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregationof duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size.

View Audit 333671

Finding 515801 (2024-001)

None 2024

Warren County School District R3

MO

Allowable Costs / Cost Principles HUD Housing Programs Reporting § 200.333

Finding #2024-001 – Inability to Produce Supporting Report to Confirms the Accuracy of the Verification Report Sample Contact for corrective action: Dr. Gregg Klinginsmith, Superintendent District’s response: Concur Anticipated completion date: December 31, 2024 Corrective Action: The District agree...

Finding #2024-001 – Inability to Produce Supporting Report to Confirms the Accuracy of the Verification Report Sample Contact for corrective action: Dr. Gregg Klinginsmith, Superintendent District’s response: Concur Anticipated completion date: December 31, 2024 Corrective Action: The District agrees with this finding and will implement the following: • Data Integrity Verification: o Implement a data review process to ensure data completeness and accuracy prior to sampling. • Staff Training: o Conduct training sessions for staff involved to ensure the accuracy of reports produced by the software used to select samples. o Obtain training from the software provider to understand how the software pulls reports, ensuring sample accuracy. • Internal Review Process o Establish periodic reviews to confirm all required documentation is retained and accurately represents the population.

View Audit 333669

Finding 515800 (2024-001)

Significant Deficiency 2024

Chapel Hill-Carrboro City Board of Education

NC

Questioned Costs Significant Deficiency Matching / Level of Effort / Earmarking

Name of Contact Person:Jonathan Scott, Chief Financial Officer, Business and Financial Services. Corrective Action Plan: Management will implement controls and procedures to ensure that staff responsible for overseeing compliance with Title I requirements understands the 12% administrative expendit...

Name of Contact Person:Jonathan Scott, Chief Financial Officer, Business and Financial Services. Corrective Action Plan: Management will implement controls and procedures to ensure that staff responsible for overseeing compliance with Title I requirements understands the 12% administrative expenditure limit. In addition, the Title I budget will be monitored by Title I staff during the year to ensure that the 12% administrative requirement is not exceeded. Proposed Completion Date: Immediately

View Audit 333668 Questioned Costs: $1

Finding 515799 (2024-003)

None 2024

Rannie Webster Foundation

NH

HUD Housing Programs Reporting

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Other Matters Recommendation: We recommend that the organization implement measures to ensure timely submission of HUD REAC reports. Explanation of...

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Other Matters Recommendation: We recommend that the organization implement measures to ensure timely submission of HUD REAC reports. Explanation of disagreement with audit finding: Management is in agreement with the finding. Action taken in response to finding: The reason for the late fiscal year 2023 submissionwas due to the affiliation with Silverstone and management transition. Managementcommunicated these circumstances with HUD and submitted a request for extension priorto the deadline. Management submitted the fiscal year 2024 REAC within the 90-day deadline. Name of the contact person responsible for corrective action: Janet Langlois, CFO Planned completion date for corrective action plan: November 30, 2024.

View Audit 333666

Finding 515798 (2024-002)

None 2024

Rannie Webster Foundation

NH

Cash Management HUD Housing Programs Internal Control / Segregation of Duties

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Other Matters Recommendation: CLA recommends the organization develops and enforces a policy requiring the independent approval of all bank reconcili...

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Other Matters Recommendation: CLA recommends the organization develops and enforces a policy requiring the independent approval of all bank reconciliations on a monthly basis. Explanation of disagreement with audit finding: Management is in agreement with the finding. Action taken in response to finding: Beginning in December 2023, Webster began implementing Silverstone Living's policy regarding bank reconciliation preparation and approval. Bank reconciliations are prepared on a monthly basis by the Business Office Manager or the Assistant Controller and reviewed by the CFO. Name of the contact person responsible for corrective action: Janet Langlois, CFO Planned completion date for corrective action plan: December 31, 2023.

View Audit 333666

Finding 515797 (2024-001)

Significant Deficiency 2024

Rannie Webster Foundation

NH

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Significant Deficiency in Internal Control over Compliance Recommendation: CLA recommends the organization develops and enforces a policy requiring t...

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Significant Deficiency in Internal Control over Compliance Recommendation: CLA recommends the organization develops and enforces a policy requiring the approval of all invoices before payment. Explanation of disagreement with audit finding: Management is in agreement with the finding. Action taken in response to finding: Starting in April 2024, Webster began implementing Silverstone Living's invoice approval policy. The authorized signers for invoices are the Executive Director, the CFO, and the department heads. Name of the contact person responsible for corrective action: Janet Langlois, CFO Planned completion date for corrective action plan: April 30, 2024.

View Audit 333666

Finding 515794 (2024-003)

Material Weakness 2024

Van Dyke Public Schools

MI

Reporting § 200.502 § 200.510

Condition: The schedule of expenditures of federal awards (SEFA) contained inaccuracies and incomplete information that was identified during the audit. Planned Corrective Action: The School District will develop a SEFA checklist to help ensure all federal expenditures are properly reported. Additio...

Condition: The schedule of expenditures of federal awards (SEFA) contained inaccuracies and incomplete information that was identified during the audit. Planned Corrective Action: The School District will develop a SEFA checklist to help ensure all federal expenditures are properly reported. Additional processes will be put in place by management to review the SEFA in advance of the annual audit to effectively meet audit report timelines and help ensure completeness, validity, and accuracy of the final SEFA reporting. Contact person responsible for corrective action: Patricia Carion/Piper Bognar Anticipated Completion Date: 07/31/2025

View Audit 333661

Finding 515793 (2024-002)

None 2024

Children's Hospital of Philadelphia

PA

Subrecipient Monitoring Eligibility

Management agrees that 2 of the 25 patient files selected did not have timely recertification of their eligibility for Ryan White services. The 2 patients did meet the criteria for eligibility however documentation of this eligibility is required on an annual basis. The Family Care Center at CHOP is...

Management agrees that 2 of the 25 patient files selected did not have timely recertification of their eligibility for Ryan White services. The 2 patients did meet the criteria for eligibility however documentation of this eligibility is required on an annual basis. The Family Care Center at CHOP is committed to full compliance with reporting requirements for all funders. We have since implemented a monthly report of patients who need updated documentation of their Ryan White eligibility (including financial, residential, and diagnostic assessments) which our medical case managers will complete in EPIC. Once they are complete in EPIC, this will be documented in CAREWare, and we will be able to pull reports to ensure we are meeting this requirement. Any questions about compliance with Ryan White eligibility can be directed to Kathryn Pultman, LCSW, Program Manager at pultmank@chop.edu.

View Audit 333649

Finding 515791 (2024-001)

None 2024

Children's Hospital of Philadelphia

PA

Procurement, Suspension & Debarment § 200.320

Management agrees with the finding that two out of five procurement selections totaling $158,000 did not include the appropriate evidence (signed competitive bid or sole source justification) and that this information was not retained in the procurement file. While the departments that selected the ...

Management agrees with the finding that two out of five procurement selections totaling $158,000 did not include the appropriate evidence (signed competitive bid or sole source justification) and that this information was not retained in the procurement file. While the departments that selected the vendors did perform sole source and vendor evaluation within their departments, formal documentation and appropriate sourcing details was not obtained by CHOP Procurement. As CHOP is committed to full compliance with reporting requirements for all external agencies, our organization has determined that putting additional controls and education into place with our staff members is the appropriate action to take. Therefore, we will be conducting formal training in November 2024 to our Purchasing and Contracting teams to ensure all established procurement processes and policies are adhered to. Additional auditing of CHOP purchases meeting the bid threshold will be conducted on a monthly basis by the CHOP Procurement Manager and AVP, Sourcing, Contracting, and Procurement. Any discrepancies will be identified and addressed following the audit. CHOP commits to an improved management and oversight of these requirements going forward. Jeffrey Raup, AVP – Sourcing, Contracting, and Procurement at CHOP, will have responsibility for this corrective action plan.

View Audit 333649

Finding 515789 (2024-001)

Significant Deficiency 2024

Peru Community School District 124

IL

Eligibility

The District will ensure personnel receive additional training regarding the verification process for the National School Lunch Program and properly complete the verification process in future years.

View Audit 333640

Finding 515782 (2024-008)

Significant Deficiency 2024

Housing Opportunities Commission of Montgomery County, MD

MD

Questioned Costs HUD Housing Programs Significant Deficiency

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action ...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will ensure that move-outs are processed promptly to prevent assistance payments from being requested for vacant units. The Regional Property Manager will oversee the completion and review of end-of-month checklists to confirm that all monthly tasks have been addressed, thereby minimizing the likelihood of this exception occuring in the future. Effective immediately, HOC’s PM Compliance Manager will ensure that move-outs are processed in a timely manner and will review monthly reports to confirm that esident terminations are handled accurately. For both HOC and Pratum, the HOC team will incorporate any open move-out and move-in actions into the monthly review of past-due certifications as part of the report. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum and HOC have immediately implemented the corrective actions as outlined above. Both discrepancies have been resolved. The HOC team will include open move-in and move-out actions within the report effective November 2024. If the U.S. Department of Housing and Urban Development has questions regarding this schedule, please call Timothy Goetzinger, Senior Vice President, Finance / Chief Financial Officer at (301) 949-4690.

View Audit 333618 Questioned Costs: $1

Finding 515781 (2024-007)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken ...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will review certifications to ensure that any necessary corrections are made so that the correct utility allowance is reflected on the HUD-50059. Management will also ensure that, going forward, site staff review the HUD-50059 utility allowance amounts for accuracy against the approved rent schedule. Additionally, Pratum will ensure that any certifications completed in advance of the Gross Rent Increase are corrected as needed to accurately reflect the correct utility allowance on the HUD-50059. HRD will review and update utility allowances currently in use, comparing them against the latest HUD-approved MOD Rehabilitation gross rent schedule. HRD and HOC Compliance team will develop or update policies and procedures to ensure that utility allowances are verified and updated as required by HUD. The training manager will conduct training sessions for relevant staff members on the utility allowance requirements and how to update them in HRD’s system of record database. As a preventive action, HRD’s management will establish a quarterly file review procedure to ensure that the utility allowances align with the HUD utility allowance approval. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC, Ali Ozair, Vice President of Property Management with HOC and Lynn Hayes, Vice President of Housing Resources Division with HOC. Planned completion date for corrective action plan: Pratum has immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. HRD has immediately implemented and will have the corrections to the impacted and future files completed by December 31, 2024.

View Audit 333618

Finding 515780 (2024-006)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in res...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will review certifications to ensure that any necessary corrections are made so that the correct contract rent is reflected on the hUD50059. Moving forward management will ensure that site staff review the HUD-50059 contract rent amounts for accuracy against the approved Rent Schedule. Additionally, Pratum will ensure that certifications are completed early, ahead of any Gross Rent Increase, and that affected certifications are corrected as needed to reflect the correct contract rents on the HUD-500-59. Pratum will also ensure that rent change letters are provided as required, with a copy retained in the resident file along with the certification. Furthermore, management will ensure that a copy of the rent change letter is uploaded to Yardi, along with the completed certification, the completed unit inspection form, and the notification letters for HQS annual inspection scheduling. Lastly, Pratum will review the reference tenant file and provide a copy of the HUD-50059 and rent change form for review. Management will ensure that these documents are retained in the resident file and uploaded to Yardi upon completion of all further certifications. The HOC compliance team will focus on conducting site visits for the Project Based Rental Assisted properties following the same guidelines used for the annual financial audit. The goal is to perform a 100% file review for properties with 25 or less units and a 50% file review for properties with more than 25 units. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. The HOC compliance team will start site visits by January 2025 and will review files from the start of the fiscal year.

View Audit 333618

Finding 515779 (2024-005)

Significant Deficiency 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Eligibility Reporting

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner Explanation of disagreement with audit finding: There is no disagre...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previously,Pratum was responsible for completing the certifications and the HOC team was responsible for transmitting the certifications through TRACS. Effective October 1 2024, Pratum assumed responsibility of ensuring that all certifications are transmitted to TRACS in alignment with the HAP reported date. The Regional Property Manager will conduct monthly reviews of HAP and TRACS submissions to ensure accuracy. HRD staff will provide weekly internal staff training to correct PIC errors and procure additional training from a third party consulting company.. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Lynn Hayes, Vice President of Housing Resources. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. The HRD team has corrected the errors and will attempt to secure training from a consultant company no later than March 31, 2024.

View Audit 333618

Finding 515778 (2024-004)

Material Weakness 2024

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreem...

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum has implemented a policy requiring annual inspections to align with annual recertifications, ensuring compliance with HUD policies. Pratum Regional Property Managers will verify that all annual inspections and their corresponding forms are completed and properly filed in each resident's file. Additionally, a copy of the completed unit inspection form will be uploaded to Yardi along with the certification acket. Pratum will also ensure that all documentation related to scheduled HQS inspections is filed in the resident file and uploaded to Yardi, along with the completed unit inspection form. HOC’s PM Division has engaged an inspection vendor, Gilson Housing Partners, to conduct all annual inspections for the HOC managed properties. The inspections will begin on December 1, 2024 with PBRA communities being the priority. They will complete approximately 150 inspections per month and utilize Yardi Maintenance IQ for record keeping. The results of each inspection will be entered into the system by Gilson and HOC’s Maintenance and PM will have the responsibility of addressing all work.This partnership will ensure that all inspections are completed on schedule and meet the necessary standards. The Compliance team will continue to conduct bi-monthly quality control reviews for the HOC managed properties, after which relevant parties will convene to discuss corrective actions and training opportunities. This interactive process aims to ensure that discrepancies are addressed and corrected effectively. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. HOC’s third party inspections vendor will begin inspecting units no later than December 1, 2024 and perform annual inspections moving forward.

View Audit 333618

Corrective Action Plans

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