1. Implementation of Formal Written Policy MCHA implemented a comprehensive Tenant File Review Policy and Procedure in November 2025. The policy: • Establishes mandatory monthly file review requirements • Defines standardized file selection methodology • Requires consistent documentation of all reviews • Assigns clear roles and responsibilities for oversight and implementation • Requires reviews to be completed monthly without exception, regardless of workload or competing priorities 2. Review Frequency and File Selection • A minimum of 14 tenant files per month are reviewed: o 7 files from the prior month (retrospective review) o 7 files from the upcoming/proactive review group • Files are selected through a randomized process within Compliance Manager, ensuring: o Representation across annual reexaminations, interim reexaminations, and new admissions o A consistent and unbiased sampling of program activity 3. Standardized Review Procedures All file reviews are conducted using a uniform, HOTMA-compliant audit checklist, requiring verification of: • Income and asset calculations • Third-party verification documentation • Required HUD forms and signatures • Accuracy of subsidy determinations (TTP, HAP, utility allowance) • Proper application of payment standards and program requirements 4. Documentation and Internal Control Measures MCHA established a centralized internal tracking system (Excel-based) to document and monitor all file reviews and corrections. • The tracking log: o Is accessible to Case Managers for visibility o Has restricted editing access limited to the Compliance Manager and HCV Program Manager • The log includes: o File selected and review date o Identified deficiencies o Date file is submitted for audit o Date file is returned for correction o Date corrections are completed and formally signed off This process ensures: • A complete audit trail of all reviews and corrections • Separation of duties • Data integrity and accountability 5. Correction and Verification Process • All identified deficiencies must be corrected within established timeframes • Corrections may include: o File documentation updates o Participant or owner follow-up • No file is closed until: o Corrections are verified o Compliance is confirmed by management o Final sign-off is documented 6. Oversight and Accountability • The Program Manager is responsible for: o Overall oversight of the policy and procedures o Ensuring monthly compliance with review requirements o Confirming all deficiencies are resolved prior to closure • The Compliance Manager is responsible for: o Execution and implementation of the review process o Conducting detailed file audits o Maintaining and controlling the tracking log o Monitoring and documenting all correction activity This structure ensures clear segregation of duties, accountability, and consistent oversight. 7. Staff Training and Acknowledgment • All Case Managers received formal training in November 2025 • Each staff member signed a written acknowledgment confirming: o Receipt of the policy o Understanding of requirements • Documentation has been: o Provided to the auditors o Retained for compliance verification Status of Corrective Action Corrective actions were fully implemented in November 2025 and are currently in effect. Planned Completion Date Completed – November 2025 Responsible Officials • HCV Program Manager – Oversight and compliance monitoring • Compliance Manager – Implementation and audit execution Conclusion MCHA believes the corrective actions implemented fully address the identified deficiency. The Authority has established formal written policies, strengthened internal controls, and implemented a structured and sustainable monitoring process. These measures ensure: • Consistent and timely tenant file reviews • Documented tracking and accountability of corrections • Ongoing compliance with HUD program requirements MCHA is confident that these controls prevent recurrence of the issues identified in this finding.