Retired Steelworkers Housing and Health Development Corporation

EIN: 231923419

UEI: J5FMVR8LENF5

Data as of August 24, 2026

Retired Steelworkers Housing and Health Development Corporation10 audit years12 findings4 repeat
10
Audit Years
12
Total Findings
4
Repeat Findings

FY 2025-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on August 12, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 12, 2027 (172 days from today).

What is a management decision? →
2025-001
Special Tests & Provisions

The Project underfunded the account by $604. Cause: The Project did not implement a funding increase in a timely manner. Effect or Potential Effect: Deficiently funded reserve for replacements. Auditor Non-Compliance Code: N – Reserve for Replacements Deposits. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations will be adopted. Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Response Indicator: Agree. Completion Date: 12/31/2026 Response: We are researching the underfunding and will ensure the RR account is fully funded on a monthly basis. New procedures have been implemented to review the deposits each month to ensure amounts are proper.

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Full finding narrative

FINDING No. 2025-001: Section 236 Interest Reduction Payments, ALN 14.103 Finding Resolution Status: Unresolved. Information on Universe Population Size: All replacement reserve deposits for the year ended December 31, 2025. Sample Size Information: All replacement reserve deposits for the year ended December 31, 2025. Identification of Repeat Finding and Finding Reference Number: No. Criteria: In accordance with HUD, the required monthly deposit must be made to the Project's reserve for replacement account. Statement of Condition: The Project underfunded the account by $604. Cause: The Project did not implement a funding increase in a timely manner. Effect or Potential Effect: Deficiently funded reserve for replacements. Auditor Non-Compliance Code: N – Reserve for Replacements Deposits. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations will be adopted. Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Response Indicator: Agree. Completion Date: 12/31/2026 Response: We are researching the underfunding and will ensure the RR account is fully funded on a monthly basis. New procedures have been implemented to review the deposits each month to ensure amounts are proper.

Corrective Action Plan

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2025 through December 31, 2025 The findings from the December 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 236 Interest Reduction Payments, ALN 14.103 Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Action Taken: We are researching the underfunding and will ensure the RR account is fully funded on a monthly basis. New procedures have been implemented to review the deposits each month to ensure amounts are proper.

About Special Tests and Provisions →
2025-002
Eligibility
REPEAT

The Project did not verify income and other resident information of one of its Section 236 tenants through the EIV system. Cause: The Project did not adhere to HUD regulations for continuing eligibility and did not verify income and other resident information. Effect or Potential Effect: Untimely verification of tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R – Section 8 Program Administration. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations will be adopted. Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system. Response Indicator: Agree. Completion Date: 12/31/2026 Response: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance.

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Full finding narrative

FINDING No. 2025-002: Section 236 Interest Reduction Payments, ALN 14.103 Finding Resolution Status: Unresolved. Information on Universe Population Size: One hundred twenty-six tenants. Sample Size Information: Twenty tenants. Identification of Repeat Finding and Finding Reference Number: Yes, 2023-001 and 2024-002. Criteria: HUD regulations require timely verification and maintenance of documentation of a tenant’s income and other resident information through the Enterprise Income Verification (EIV) system that is performed within 90 days of the tenant being entered into the Tenant Rental Assistance Certification System (TRACS). Statement of Condition: The Project did not verify income and other resident information of one of its Section 236 tenants through the EIV system. Cause: The Project did not adhere to HUD regulations for continuing eligibility and did not verify income and other resident information. Effect or Potential Effect: Untimely verification of tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R – Section 8 Program Administration. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations will be adopted. Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system. Response Indicator: Agree. Completion Date: 12/31/2026 Response: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance.

Corrective Action Plan

FINDING No. 2025-002: Section 236 Interest Reduction Payments, ALN 14.103 Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

Prior Finding References

2023-001, 2024-002

About Eligibility →

FY 2024-12-31

FAC accepted this audit on August 1, 2025 — management decision was due February 1, 2026.

2024-001
Cost Allowability

A purchase was not authorized by the appropriate level of management. Cause: A transaction in the amount of $15,019 was approved by a member of management who only had authorization to approve transactions up to $1,000. Effect or Potential Effect: Potential unauthorized use of project funds. Auditor Non-Compliance Code: S – Internal control deficiencies. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendation has been adopted. Recommendation: Management should ensure adherence to and the monitoring of established controls over cash disbursements. Response Indicator: Agree. Completion Date: 10/30/2024 Response: Staff training has been provided. New manager has been advised regarding limits. This was a glitch in the OPS Spend Management system.

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FINDING No. 2024-001: Section 236 Interest Reduction Payments, ALN 14.103 Finding Resolution Status: Resolved. Information on Universe Population Size: All disbursements for the year ended December 31, 2024. Sample Size Information: Twenty-five disbursements. Identification of Repeat Finding and Finding Reference Number: No. Criteria: All purchases must be authorized by the appropriate level of management prior to disbursement. Statement of Condition: A purchase was not authorized by the appropriate level of management. Cause: A transaction in the amount of $15,019 was approved by a member of management who only had authorization to approve transactions up to $1,000. Effect or Potential Effect: Potential unauthorized use of project funds. Auditor Non-Compliance Code: S – Internal control deficiencies. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendation has been adopted. Recommendation: Management should ensure adherence to and the monitoring of established controls over cash disbursements. Response Indicator: Agree. Completion Date: 10/30/2024 Response: Staff training has been provided. New manager has been advised regarding limits. This was a glitch in the OPS Spend Management system.

Corrective Action Plan

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2024 through December 31, 2024 The findings from the December 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENT AUDITS FINDING No. 2024-001: Section 236 Interest Reduction Payments, ALN 14.103 Recommendation: Management should ensure adherence to and the monitoring of established controls over cash disbursements. Action Taken: Staff training has been provided. New manager has been advised regarding limits. This was a glitch in the OPS Spend Management system.

About Allowable Costs / Cost Principles →
2024-002
Eligibility
REPEAT

The Project verified income and other resident information of one of its Section 236 tenants subsequent to the 90 day requirement. Cause: The Project did not adhere to HUD regulations for continuing eligibility and did not verify income and other resident information within the established time frame. Effect or Potential Effect: Untimely verification of tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R – Section 8 Program Administration. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations have been adopted. Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system within the established time frame. Response Indicator: Agree. Completion Date: 07/03/2024 Response: Staff training has been provided with additional HUD training inclusive of EIV reporting.

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Full finding narrative

FINDING No. 2024-002: Section 236 Interest Reduction Payments, ALN 14.103 Finding Resolution Status: Resolved. Information on Universe Population Size: One hundred twenty-two tenants. Sample Size Information: Twenty tenants. Identification of Repeat Finding and Finding Reference Number: Yes, 2023-001. Criteria: HUD regulations require timely verification and maintenance of documentation of a tenant’s income and other resident information through the Enterprise Income Verification (EIV) system that is performed within 90 days of the tenant being entered into the Tenant Rental Assistance Certification System (TRACS). Statement of Condition: The Project verified income and other resident information of one of its Section 236 tenants subsequent to the 90 day requirement. Cause: The Project did not adhere to HUD regulations for continuing eligibility and did not verify income and other resident information within the established time frame. Effect or Potential Effect: Untimely verification of tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R – Section 8 Program Administration. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations have been adopted. Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system within the established time frame. Response Indicator: Agree. Completion Date: 07/03/2024 Response: Staff training has been provided with additional HUD training inclusive of EIV reporting.

Corrective Action Plan

FINDING No. 2024-002: Section 236 Interest Reduction Payments, ALN 14.103 Recommendation: Management should implement procedures to ensure the Project verifies tenant eligibility through the EIV system within the established time frame. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO

Prior Finding References

2023-001

About Eligibility →

FY 2023-12-31

FAC accepted this audit on August 20, 2024 — management decision was due February 20, 2025.

2023-001
Eligibility
REPEAT

The Project attempted to obtain an EIV for one tenant utilizing incorrect information resulting in an accurate report not being obtained within 90 days. Cause: The Project did not adhere to HUD regulations for initial eligibility and did not perform timely income verification. Effect or Potential Effect: Alternative income documentation was provided to verify tenant eligibility and cost of assistance; however, the accuracy of such information was not verified through the EIV system as required by HUD. Auditor Non-Compliance Code: R – Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure the Project verifies tenant eligibility through the EIV system in a timely manner. Response Indicator: Agree. Completion Date: 12/31/2024 Response: Staff training has been provided and included in monthly reporting procedures.

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Full finding narrative

FINDING No. 2023-001: Section 236 Mortgage Restructuring Note, ALN 14.103 Finding Resolution Status: Unresolved. Information on Universe Population Size: One hundred twenty tenants. Sample Size Information: Twenty tenants. Identification of Repeat Finding and Finding Reference Number: Yes, 2022-001. Criteria: HUD regulations require timely verification of tenant’s initial income through the Enterprise Income Verification (EIV) performed within 90 days of the tenant being entered into Tenant Rental Assistance Certification System (TRACS) with the corresponding documentation maintained. Statement of Condition: The Project attempted to obtain an EIV for one tenant utilizing incorrect information resulting in an accurate report not being obtained within 90 days. Cause: The Project did not adhere to HUD regulations for initial eligibility and did not perform timely income verification. Effect or Potential Effect: Alternative income documentation was provided to verify tenant eligibility and cost of assistance; however, the accuracy of such information was not verified through the EIV system as required by HUD. Auditor Non-Compliance Code: R – Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure the Project verifies tenant eligibility through the EIV system in a timely manner. Response Indicator: Agree. Completion Date: 12/31/2024 Response: Staff training has been provided and included in monthly reporting procedures.

Corrective Action Plan

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2023 through December 31, 2023 The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2023-001: Section 236 Mortgage Restructuring Note, ALN 14.103 Recommendation: The Project should implement procedures to ensure the Project verifies tenant eligibility through the EIV system in a timely manner. Action Taken: Staff training has been provided and included in monthly reporting procedures.

Prior Finding References

2022-001

About Eligibility →
2023-002
Eligibility

The Project did not refund the security deposit plus accrued interest to one tenant within the required 30 days from tenant move-out. Cause: The Project did not follow the state law and HUD regulations for refunding security deposits resulting in untimely refunds of security deposits. Effect or Potential Effect: The Project is not in compliance with HUD regulations and state laws requiring tenant security deposits to be refunded within 30 days of a tenant move out if no assessments are made against that tenant. Auditor Non-Compliance Code: M – Security Deposits. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations have been adopted. Recommendation: The Project should comply with state law and HUD regulations for refunding security deposits and ensure all refunds are made to the move-out tenants within the required period. Response Indicator: Agree. Completion Date: 10/31/2023 Response: Training has been provided to staff on state and HUD laws and the processes and procedures of refunding move-out tenants within the required period.

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Full finding narrative

FINDING No. 2023-002: Section 236 Mortgage Restructuring Note, ALN 14.103 Finding Resolution Status: Resolved. Information on Universe Population Size: Eight former tenants. Sample Size Information: Three former tenants. Identification of Repeat Finding and Finding Reference Number: No. Criteria: As required by HUD regulations, the owner must refund the full security deposit plus accrued interest and/or provide the tenant with an itemized list of any unpaid rent, damages to the unit, and an estimated cost for repair, along with a statement of the tenant’s rights under HUD regulations and state and local laws within 30 days from move-out. Statement of Condition: The Project did not refund the security deposit plus accrued interest to one tenant within the required 30 days from tenant move-out. Cause: The Project did not follow the state law and HUD regulations for refunding security deposits resulting in untimely refunds of security deposits. Effect or Potential Effect: The Project is not in compliance with HUD regulations and state laws requiring tenant security deposits to be refunded within 30 days of a tenant move out if no assessments are made against that tenant. Auditor Non-Compliance Code: M – Security Deposits. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor’s recommendations have been adopted. Recommendation: The Project should comply with state law and HUD regulations for refunding security deposits and ensure all refunds are made to the move-out tenants within the required period. Response Indicator: Agree. Completion Date: 10/31/2023 Response: Training has been provided to staff on state and HUD laws and the processes and procedures of refunding move-out tenants within the required period.

Corrective Action Plan

FINDING No. 2023-002: Section 236 Mortgage Restructuring Note, ALN 14.103 Recommendation: The Project should comply with state law and HUD regulations for refunding security deposits and ensure all refunds are made to the move-out tenants within the required period. Action Taken: Training has been provided to staff on state and HUD laws and the processes and procedures ot refunding move-out tenants within the required period. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO

About Eligibility →

FY 2022-12-31

FAC accepted this audit on April 10, 2023 — management decision was due October 10, 2023.

2022-001
Eligibility
REPEAT

The Project did not perform and/or maintain the EIV reports for three tenants. Cause: The Project did not adhere to HUD regulations for initial and continuing eligibility and did not perform timely income verification. Effect or Potential Effect: Unable to verify tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure the Project verifies tenant eligibility through the EIV system in a timely manner. Also, the Project should contact its local HUD office EIV coordinator for guidance on generating reports for tenant occupying the Project?s section 236 units. Response Indicator: Agree. Completion Date: 12/31/2023 Response: Managers have been trained that EIV income reports must be pulled timely and reviewed and action taken if needed. Alerts have been turned on in One Site to remind managers to pull EIV 90 day reports.

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FINDING No. 2022-001: Section 236 Mortgage Restructuring Note, CFDA 14.103 Finding Resolution Status: Unresolved. Information on Universe Population Size: One hundred thirty tenants. Sample Size Information: Twenty tenants. Identification of Repeat Finding and Finding Reference Number: Yes, 2021-001. Criteria: HUD regulations require timely verification of tenant?s initial income through the Enterprise Income Verification (EIV) performed within 90 days of the tenant being entered into Tenant Rental Assistance Certification System (TRACS) with the corresponding documentation maintained. Statement of Condition: The Project did not perform and/or maintain the EIV reports for three tenants. Cause: The Project did not adhere to HUD regulations for initial and continuing eligibility and did not perform timely income verification. Effect or Potential Effect: Unable to verify tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure the Project verifies tenant eligibility through the EIV system in a timely manner. Also, the Project should contact its local HUD office EIV coordinator for guidance on generating reports for tenant occupying the Project?s section 236 units. Response Indicator: Agree. Completion Date: 12/31/2023 Response: Managers have been trained that EIV income reports must be pulled timely and reviewed and action taken if needed. Alerts have been turned on in One Site to remind managers to pull EIV 90 day reports.

Corrective Action Plan

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2022 through December 31, 2022 The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III ? FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATMENT AUDITS FINDING No. 2022-001: Section 236 Mortgage Restructuring Note, CFDA 14.103 Recommendation: The Project should implement procedures to ensure the Project verifies tenant eligibility through the EIV system in a timely manner. Also, the Project should contact its local HUD office EIV coordinator for guidance on generating reports for tenant occupying the Project?s section 236 units. Action Taken: Managers have been trained that EIV income reports must be pulled timely and reviewed and action taken if needed. Alerts have been turned on in One Site to remind managers to pull EIV 90 day reports.

Prior Finding References

2021-001

About Eligibility →
2022-002
Special Tests & Provisions

The Project did not increase the required monthly deposits to the replacement reserve by the 2.67% OCAF rent increase, and the replacement reserve was underfunded by $379. Cause: An increase in funding was not implemented. Effect or Potential Effect: Deficiently funded reserve for replacement account. Auditor Non-Compliance Code: N ? Reserve for Replacements Deposits. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: Management should implement procedures to ensure that replacement reserve monthly deposits are increased at the same percentage as the authorized OCAF rental increase and that the correct amount is deposited into the replacement reserve account each month. Response Indicator: Agree. Completion Date: 12/31/2023 Response: Management has implemented a new procedure to ensure all monthly deposits are made within the current period.

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Full finding narrative

FINDING No. 2022-002: Section 236 Mortgage Restructuring Note, CFDA 14.103 Finding Resolution Status: Unresolved. Information on Universe Population Size: All replacement reserve deposits for the year ended December 31, 2022. Sample Size Information: All replacement reserve deposits for the year ended December 31, 2022. Identification of Repeat Finding and Finding Reference Number: No. Criteria: HUD regulations require OCAF rent adjusted projects to increase its monthly replacement reserve funding by the same percentage as the authorized rent increase. Statement of Condition: The Project did not increase the required monthly deposits to the replacement reserve by the 2.67% OCAF rent increase, and the replacement reserve was underfunded by $379. Cause: An increase in funding was not implemented. Effect or Potential Effect: Deficiently funded reserve for replacement account. Auditor Non-Compliance Code: N ? Reserve for Replacements Deposits. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: Management should implement procedures to ensure that replacement reserve monthly deposits are increased at the same percentage as the authorized OCAF rental increase and that the correct amount is deposited into the replacement reserve account each month. Response Indicator: Agree. Completion Date: 12/31/2023 Response: Management has implemented a new procedure to ensure all monthly deposits are made within the current period.

Corrective Action Plan

FINDING No. 2022-002: Section 236 Mortgage Restructuring Note, CFDA 14.103 Recommendation: Management should implement procedures to ensure that replacement reserve monthly deposits are increased at the same percentage as the authorized OCAF rental increase and that the correct amount is deposited into the replacement reserve account each month. Action Taken: Management has implemented a new procedure to ensure all monthly deposits are made within the current period.

About Special Tests and Provisions →
2022-003
Eligibility

Three applicants were passed over without maintaining and documenting a reason. Cause: The manager did not maintain appropriate documentation of the reasons for passing over applicants. Effect or Potential Effect: Unable to determine date and time for the receipt of applications for proper wait listing placement and subsequent selection to occupy a unit. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure appropriate documentation of the reasoning for passing over applicants. Response Indicator: Agree. Completion Date: 12/31/2023 Response: Training has been conducted with managers on proper waiting list procedures. Going forward compliance will be checking waiting lists at random to ensure appropriate documentation is entered on the waiting list if an applicant is passed over.

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Full finding narrative

FINDING No. 2022-003: Section 236 Mortgage Restructuring Note, CFDA 14.103 Finding Resolution Status: Unresolved. Information on Universe Population Size: Eleven moved-in tenants. Sample Size Information: Two moved-in tenants. Identification of Repeat Finding and Finding Reference Number: No. Criteria: HUD regulations require the maintenance of a waiting list and the selection of applicants in chronological order of application date with adequate documentation of the reasoning for an applicant being passed over for an applicant with a later application date. Statement of Condition: Three applicants were passed over without maintaining and documenting a reason. Cause: The manager did not maintain appropriate documentation of the reasons for passing over applicants. Effect or Potential Effect: Unable to determine date and time for the receipt of applications for proper wait listing placement and subsequent selection to occupy a unit. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: The Project should implement procedures to ensure appropriate documentation of the reasoning for passing over applicants. Response Indicator: Agree. Completion Date: 12/31/2023 Response: Training has been conducted with managers on proper waiting list procedures. Going forward compliance will be checking waiting lists at random to ensure appropriate documentation is entered on the waiting list if an applicant is passed over.

Corrective Action Plan

FINDING No. 2022-003: Section 236 Mortgage Restructuring Note, CFDA 14.103 Recommendation: The Project should implement procedures to ensure appropriate documentation of the reasoning for passing over applicants. Action Taken: Training has been conducted with managers on proper waiting list procedures. Going forward compliance will be checking waiting lists at random to ensure appropriate documentation is entered on the waiting list if an applicant is passed over. If the audit Oversight Agency has questions regarding these plans, please call Christine Harris at 954-835-9200. Sincerely yours, Christine Harris Accounting Manager

About Eligibility →

FY 2021-12-31

FAC accepted this audit on April 14, 2022 — management decision was due October 14, 2022.

2021-001
Eligibility

The Project did not perform and/or maintain the initial EIV for one tenant and did not maintain the signature page of the application for one tenant. Cause: The Project did not adhere to HUD regulations for initial eligibility and did not perform timely income verification. Effect or Potential Effect: Unable to verify tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations have been adopted. Recommendation: The Project should implement procedures to ensure the Project verifies initial tenant income through the EIV system in a timely manner and maintain all required tenant documentation. Response Indicator: Agree. Completion Date: 1/10/2022 Response: This was an oversight of the former community manager. Management will provide new staff with both company and HUD training inclusive of EIV reporting and tenant file maintenance.

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Full finding narrative

FINDING No. 2021-001: Section 236 Mortgage Restructuring Note, CFDA 14.103 Finding Resolution Status: Resolved. Information on Universe Population Size: One hundred thirty-two tenants. Sample Size Information: Twenty tenants. Identification of Repeat Finding and Finding Reference Number: No. Criteria: HUD regulation requires timely verification of tenant?s initial income through the use of Enterprise Verification (EIV) reports with the corresponding documentation maintained. HUD also requires tenant applications to be signed by the applicant certifying the accuracy and completeness of the information provided. Statement of Condition: The Project did not perform and/or maintain the initial EIV for one tenant and did not maintain the signature page of the application for one tenant. Cause: The Project did not adhere to HUD regulations for initial eligibility and did not perform timely income verification. Effect or Potential Effect: Unable to verify tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R ? Section 8 Program Administration Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations have been adopted. Recommendation: The Project should implement procedures to ensure the Project verifies initial tenant income through the EIV system in a timely manner and maintain all required tenant documentation. Response Indicator: Agree. Completion Date: 1/10/2022 Response: This was an oversight of the former community manager. Management will provide new staff with both company and HUD training inclusive of EIV reporting and tenant file maintenance.

Corrective Action Plan

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 2021. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2021 through December 31, 2021 The finding from the December 31, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2021-001: Section 236 Mortgage Restructuring Note, CFDA 14.103 Recommendation: The Project should implement procedures to ensure the Project verifies initial tenant income through the EIV system in a timely manner and maintain all required tenant documentation. Action Taken: This was an oversight of the former community manager. Management will provide new staff with both company and HUD training inclusive of EIV reporting and tenant file maintenance. If the Oversight Agency for Audit has questions regarding these plans, please call Christine Harris at 954- 835-9200. Sincerely yours, Christine Harris Assistant to VP of Finance and Accounting

About Eligibility →

FY 2020-12-31

FAC accepted this audit on April 5, 2021 — management decision was due October 5, 2021.

2020-001
Special Tests & Provisions

The Project underfunded the account by $276. Cause: The increase in funding was not implemented. Effect or Potential Effect: Deficiently funded reserve for replacements. Auditor Non-Compliance Code: N ? Reserve for Replacements Deposits. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendation will be adopted. Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Response Indicator: Agree. Completion Date: 12/31/2021 Response: Due to an incorrect effective date on the HUD form 9250, the lender would not adjust the funding until a corrected 9250 was received from HUD. On March 8, 2021 the corrected 9250 was received and the lender will retro the increase on the next loan statement.

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Full finding narrative

FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2020-001: Section 236 Mortgage Restructuring Note, CFDA 14.103 Finding Resolution Status: Unresolved. Information on Universe Population Size: All replacement reserve deposits for the year ended December 31, 2020. Sample Size Information: Required replacement reserve deposits for the year ended December 31, 2020. Identification of Repeat Finding and Finding Reference Number: No. Criteria: In accordance with HUD, required monthly deposits must be made to the Project?s reserve for replacement account. Statement of Condition: The Project underfunded the account by $276. Cause: The increase in funding was not implemented. Effect or Potential Effect: Deficiently funded reserve for replacements. Auditor Non-Compliance Code: N ? Reserve for Replacements Deposits. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendation will be adopted. Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Response Indicator: Agree. Completion Date: 12/31/2021 Response: Due to an incorrect effective date on the HUD form 9250, the lender would not adjust the funding until a corrected 9250 was received from HUD. On March 8, 2021 the corrected 9250 was received and the lender will retro the increase on the next loan statement.

Corrective Action Plan

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 2020. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2020 through December 31, 2020 The finding from the December 31, 2020 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2020-001: Section 236 Mortgage Restructuring Note, CFDA 14.103 Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Action Taken: Due to an incorrect effective date on the HUD form 9250, the lender would not adjust the funding until a corrected 9250 was received from HUD. On March 8, 2021 the corrected 9250 was received and the lender will retro the increase on the next loan statement. If the Oversight Agency for Audit has questions regarding these plans, please call Christine Harris at 954- 835-9200. Sincerely yours, Christine Harris Assistant to VP of Finance and Accounting

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FY 2019-12-31

FAC accepted this audit on April 1, 2020 — management decision was due October 1, 2020.

2019-001
Eligibility

Of the tenant files selected: ? 2 tenant files did not contain a current EIV report, 2 tenant files did not contain an initial EIV report, and 1 tenant file did not contain any initial income support. ? 1 tenant file did not contain an initial move-in HUD-50059. ? 1 tenant file did not contain supporting documentation for proof of disability. Cause: The Project did not perform in a timely manner nor maintain income verification, proof of disability, and 50059 certifications. Effect or Potential Effect: Unable to verify tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R ? Section 8 Program Admin. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: Implement procedures to ensure EIVs are performed and maintained in the tenant?s file. Verify eligibility by obtaining all required documents for potential tenants and adequately maintaining tenant files. Response Indicator: Agree. Completion Date: 6/1/2019 Response: Management has retrained current staff on HUD guidelines. Management has also implemented a new policy where regional directors will make periodic site visits to conduct file reviews

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FINDING No. 2019-001: Section 236 Mortgage Restructuring Note, CFDA 14.103 Finding Resolution Status: Resolved. Information on Universe Population Size: One-hundred thirty-one tenants. Sample Size Information: Twenty tenants. Identification of Repeat Finding and Finding Reference Number: No. Criteria: HUD regulation requires: ? Timely verification and retention of tenant?s current and initial Enterprise Income Verification (EIV) reports. ? Obtaining and retaining signed HUD-50059 certification forms. ? Obtaining and retaining proof of disability for tenants who are not 62 years or older at move-in. Statement of Condition: Of the tenant files selected: ? 2 tenant files did not contain a current EIV report, 2 tenant files did not contain an initial EIV report, and 1 tenant file did not contain any initial income support. ? 1 tenant file did not contain an initial move-in HUD-50059. ? 1 tenant file did not contain supporting documentation for proof of disability. Cause: The Project did not perform in a timely manner nor maintain income verification, proof of disability, and 50059 certifications. Effect or Potential Effect: Unable to verify tenant eligibility and cost of assistance and residency may be disallowed. Auditor Non-Compliance Code: R ? Section 8 Program Admin. Reporting Views of Responsible Officials: The Project agrees with the finding and the auditor?s recommendations will be adopted. Recommendation: Implement procedures to ensure EIVs are performed and maintained in the tenant?s file. Verify eligibility by obtaining all required documents for potential tenants and adequately maintaining tenant files. Response Indicator: Agree. Completion Date: 6/1/2019 Response: Management has retrained current staff on HUD guidelines. Management has also implemented a new policy where regional directors will make periodic site visits to conduct file reviews

Corrective Action Plan

Oversight Agency for Audit, Retired Steelworkers Housing and Health Development Corporation respectfully submits the following corrective action plan for the year ended December 31, 2019. Name and address of independent public accounting firm: Bellows Associates, P.A., 7890 Peters Road, Suite G-102, Plantation, Florida 33324 Audit period: January 1, 2019 through December 31, 2019 The finding from the December 31, 2019 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2019-001: Section 236 Mortgage Restructuring Note, CFDA 14.103 Recommendation: Implement procedures to ensure EIVs are performed and maintained in the tenant?s file. Verify eligibility by obtaining all required documents for potential tenants and adequately maintaining tenant files. Action Taken: Management has retrained current staff on HUD guidelines. Management has also implemented a new policy where regional directors will make periodic site visits to conduct file reviews If the Oversight Agency for Audit has questions regarding these plans, please call Christine Harris at 954- 835-9200. Sincerely yours, Christine Harris Assistant to the Vice President of Finance and Accounting

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