Finding 1215376 (2025-001)

Responsible Official Nichelle Brown, Senior Vice President of Property and Asset Management Plan Detail Management concurs with the audit finding related to the inability to locate certain tenant files. Management acknowledges that one of the eight tenant files selected for audit testing was not available and concurs with the disclosure that nine of the forty tenant files for the program could not currently be located. Management has evaluated the circumstances contributing to the missing files and determined that existing record retention and file management procedures did not sufficiently ensure that all tenant documentation was safeguarded and readily retrievable. Management recognizes that the absence of tenant files limits the ability to demonstrate compliance with federal award requirements and to support costs charged to the program. To address this issue, management has initiated corrective actions to strengthen document retention and file management controls. These actions include implementing enhanced tracking and reconciliation processes for tenant files, improving secure storage and retention practices, and reinforcing staff responsibilities for maintaining complete and accessible tenant records. Management also plans to conduct periodic internal reviews to confirm that tenant files are properly maintained and available for monitoring and audit purposes. Specifically we plan to: 1. All physical resident files are stored in locked cabinets or secured file rooms with access limited to authorized personnel, including Property Managers, Assistant Property Managers, Compliance Specialists, and designated corporate staff. 2. Access to records will be restricted based on job function and necessity 3. There will be a formal file transfer and chain-of-custody process with required signatures 4. File transfers between properties will be by locked file transport boxes marked as confidential. 5. Employees will be required to maintain direct control of files during transport. 6. All files will be maintained during required retention periods. Management believes that these corrective actions will improve compliance with record retention requirements and reduce the risk of missing documentation in the future. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in fiscal year 2026.