Finding 2022-001 - Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Significant Deficiency Corrective Action Plan: GHA will implement the following immediate and on-going actions to correct internal control over participant files in the Housing Choice Voucher program: Immediate Response: GHA is guided by seven core values. The first of which is Integrity. Upon discovery of forged documents, in March 2023 it was clearly communicated and reiterated that any actions, such as alternation, falsification, or fabrication is unacceptable and the appropriate disciplinary would be taken. A prompt and thorough investigation resulted in a team member being terminated for forging documents and a change is senior leadership. A third-party consultant was brought in immediately to complete an assessment and review of the voucher programs internal process to provide immediate process improvement along with reviewing an additional sample set of participant files. Ongoing Response: GHA will improve internal controls in the area of file review and quality control and assurance by completing multiple examinations of applicants/program participants calculations at initial move- in, interim, and re-examination anniversary. In addition to the two-prong reviews being completed by team members, a third-party compliance company may be used to review all initials, and up to twenty-five percent (25%) of all interim and re-examination of program participants' files. Internal/external training will be provided to each team member involved with the determination of rent and maintaining tenant files, as well as programmatic eligibility and administration of the housing choice voucher program in 2023. Voucher Administration leadership will continue to work closely with the Compliance Department to ensure that GHA's program files are compliant with all federal regulations, rules, HUD guidelines as well as GHA's policy and procedures. Anticipated Completion Date: The above plans will be implemented immediately and will be continuously monitored. We anticipate a completion date of December 2023. Responsible Person: Meredith Daye, Chief Operating Officer