Corrective Action Plan – December 31, 2025 Audit Findings 2025-001 Condition: Deficiencies Noted in Examination of Housing Choice Voucher Program Participant Files Auditor Recommendation: The Authority should review its internal control procedures over tenant file re-certifications and documentation. Response: The audit indicates there were egregious errors with the participants’ files. We agree. Even though 50058 were processed, for over 95% of the participants, there were two issues which made the 50058 submissions inadequate. 1. The 50058’s were submitted through Yardi MTCS files, but often records were rejected by PIC. We did not review and resolve the PIC errors in a timely manner. These errors were due to our change in operating programs, from Lindsey to Yardi. In Yardi, we complete biannual inspections and annual recertifications. However, if there were any issues with dates of submissions relative to date either transaction was processed, they often failed in the PIC submission. It takes a great deal of work and effort to go back and fix these issues, and we got very behind and finally hired a consultant to assist us with the cleanup. 2. The second issue is more concerning. Our two Section 8 analysts completed 50058 for recertifications and interims but often did not include the back up in the electronic file or the paper file for the participant. They also made many calculation issues, rule issues, and would forget to process the 50058 all the way through. Even when the system showed there might be an error of some type, they did not clear those errors before submitting. a. As background, we implemented Yardi in August 2024. It took several months to a year to clean the data that was put into the system by the Yardi implementation team. b. Our Section 8 analysts had over 15 days of on-site personal training with Yardi trainers and provided a great deal of documentation for each module/class. c. Our Section 8 analysts have both completed a Section 8 Certification course with industry leaders like Nan McKay. d. We are a four-person office, so our Section 8 analyst have access to two other people in the office as well as a contractor who has 25 years of housing experience with Fort Lauderdale Housing and Yardi implementation a year before us. The contractor is on site for 4 ½ hours on Wednesday and available via email and phone. She has provided process documents, instructions, and sometimes multiple times for the same issue. e. The workload on both Section 8 analysts has been reduced. Each analyst is responsible for approximately 235 files, interims and recertifications. The inspections are mostly outsourced, and analysts only get involved with placing abatements. f. The failure to complete the recertifications when they are incorrect relative to information and calculations, and not maintaining the backup documentation is inexcusable. g. These issues were discovered before the auditor came on site, when we started up our file audits and we shared our findings with the auditor when they came on site. The auditor came to the same opinion as us. 38 Therefore, to correct this situation, we are taking the following steps and implementing several processes to ensure the files are in line with HUD’s standards. 1. Every 50058 processed will have to be printed, and management will review the 50058, changes made, calculations, and all pertinent information including family composition, answers on recertification packages, et. The manager will sign and date and file the record. 2. The agency will continue to randomly select 15 – 25 files for spot audit each month relative to last interim and annual recertification. The sample will depend on the number of files processed for the month. 3. The Housing Authority will run recertification and inspection reports at least twice a month to ensure all recertifications and inspections due are being completed timely and not processed as late transactions. 4. The agency will continue training and retraining for all employees. This has been ongoing for several years including HOTMA, NSpire, calculating HAP, verifying eligibility, reviewing deductions, processing reasonable accommodations requests to name a few. 5. We have implemented a no override policy for any information in Yardi including dates, payment standards, etc. without Executive Director approval. 6. We have implemented that all reasonable accommodation requests must be signed by the Assistant Executive Director or the Executive Director. 7. We are looking at purchasing licensing software solutions such as Monday which helps manage daily tasks. 8. We have already documented some of the egregious transactions for each analyst and will continue to do so. If there is no improvement over time, counseling may include termination of employment. We hope these steps will reverse the errors with the files immediately. If there is time available, we plan to start a review of every file to make corrections. We are currently doing that with about forty participants who appeared in the EIV/IVT report. We have been meeting with each head of household and correcting records or executing a repayment agreement. Timeframe: By FYE December 31, 2026 Individual responsible for correction: Ms. Anne Castro, Executive Director