EIN: 264498990
UEI: EE7DAAJWYST1
Audited by: WithumSmith+Brown P.C.
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 11, 2025. 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 June 11, 2026 (90 days ago).
What is a management decision? →Finding No.: 2024-002: Failure to Make the Required Replacement Reserve Deposits Information on the Federal Program: U.S. Housing of Urban Development (HUD) -14.157 Supportive Housing for Elderly. Finding Type: Significant Deficiency and Non Compliance Criteria: The Organization, in accordance with the Regulatory Agreement, is required to maintain a reserve for replacements. The required minimum monthly deposit into this account is $2,440 for the year ended December 31, 2024. Condition and Context: For the year ended December 31, 2024, a total of $82.033 ($52,753 pertaining to prior years and $29,280 pertaining to 2024) was to be deposited into the replacement reserve account. However, only $24,128 was deposited. Cause: Due to turnover in the accounting department staff, the required monthly deposits were not made in a timely fashion. Effect or Potential Effect: The Organization did not make the deposits into the replacement reserve account as required by the Regulatory Agreement. Questioned Costs: None Recommendation: The Organization should have procedures in place to ensure all required monthly deposits are made to the reserve for replacements. Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorporate the recommendations above. Planned Implementation Date of Corrective Action: December 2025 Person Responsible for Corrective Action: David Fazio, Director of Finance
Show full finding ▾Hide full finding ▴Finding No.: 2024-002: Failure to Make the Required Replacement Reserve Deposits Information on the Federal Program: U.S. Housing of Urban Development (HUD) -14.157 Supportive Housing for Elderly. Finding Type: Significant Deficiency and Non Compliance Criteria: The Organization, in accordance with the Regulatory Agreement, is required to maintain a reserve for replacements. The required minimum monthly deposit into this account is $2,440 for the year ended December 31, 2024. Condition and Context: For the year ended December 31, 2024, a total of $82.033 ($52,753 pertaining to prior years and $29,280 pertaining to 2024) was to be deposited into the replacement reserve account. However, only $24,128 was deposited. Cause: Due to turnover in the accounting department staff, the required monthly deposits were not made in a timely fashion. Effect or Potential Effect: The Organization did not make the deposits into the replacement reserve account as required by the Regulatory Agreement. Questioned Costs: None Recommendation: The Organization should have procedures in place to ensure all required monthly deposits are made to the reserve for replacements. Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorporate the recommendations above. Planned Implementation Date of Corrective Action: December 2025 Person Responsible for Corrective Action: David Fazio, Director of Finance
Management’s Response: Management agrees with the finding above. Both the CEO and Director of Finance have been replaced by a new transitional CEO and Director of Finance and they will review the existing accounting policies and procedures and implement appropriate procedures and controls to incorporate the recommendations above.
2023-001
Finding No.: 2024-003: Special Tests and Provisions – Project Funds Information on the Federal Program: U.S. Housing of Urban Development (HUD) -14.157 Supportive Housing for Elderly. Finding Type: Significant Deficiency Criteria: In accordance with 24 CFR 891.400(e), a separate interest-bearing project fund account shall be maintained in a depository or depositories which are members of the Federal Deposit Insurance Corporation or National Credit Union Share Insurance Fund and all tenant payments, charges, income and revenues arising from project operation or ownership shall be deposited to this account. Condition and Context: During our testing, we noted that the project fund account used by the Organization was not an interest-bearing account. Cause: Subsequent to the initial rental assistance contract, changes to HUD regulations resulted in the requirement that the project fund account be an interest-bearing account. This change was an oversight by the Organization’s management. Effect or Potential Effect: Project funds would not earn interest in accordance with HUD requirements. Questioned Costs: None Recommendation: We recommend that the Organization utilize an interest-bearing account for project funds in accordance with HUD requirements. Management’s Response: Although the Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action. Planned Implementation Date of Corrective Action: December 2025 Person Responsible for Corrective Action: David Fazio, Director of Finance
Show full finding ▾Hide full finding ▴Finding No.: 2024-003: Special Tests and Provisions – Project Funds Information on the Federal Program: U.S. Housing of Urban Development (HUD) -14.157 Supportive Housing for Elderly. Finding Type: Significant Deficiency Criteria: In accordance with 24 CFR 891.400(e), a separate interest-bearing project fund account shall be maintained in a depository or depositories which are members of the Federal Deposit Insurance Corporation or National Credit Union Share Insurance Fund and all tenant payments, charges, income and revenues arising from project operation or ownership shall be deposited to this account. Condition and Context: During our testing, we noted that the project fund account used by the Organization was not an interest-bearing account. Cause: Subsequent to the initial rental assistance contract, changes to HUD regulations resulted in the requirement that the project fund account be an interest-bearing account. This change was an oversight by the Organization’s management. Effect or Potential Effect: Project funds would not earn interest in accordance with HUD requirements. Questioned Costs: None Recommendation: We recommend that the Organization utilize an interest-bearing account for project funds in accordance with HUD requirements. Management’s Response: Although the Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action. Planned Implementation Date of Corrective Action: December 2025 Person Responsible for Corrective Action: David Fazio, Director of Finance
Management’s Response: Although the Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.
FAC accepted this audit on July 24, 2024 — management decision was due January 24, 2025.
2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CFDA #14.157 Supportive Housing for the Elderly Type of Finding: Noncompliance/significant deficiency in internal control over compliance Criteria The Corporation, in accordance with the Regulatory Agreement, is required to maintain a reserve for replacements. The required minimum monthly deposit into this account is $2,439 through November 2023 and $2,562 for December 2023. Condition For the year ended December 31, 2023, a total of $29,399 was to be deposited into the replacement reserve account. However, no amounts were deposited. Additionally, there was replacement reserve amounts of $23,353 from fiscal 2022 and 2021 which have not been deposited to date. Questioned Costs None Cause Due to turnover in the accounting department staff, the required monthly deposits were not made in a timely fashion. Effect The Corporation did not make the deposits into the replacement reserve account as required by the Regulatory Agreement. Recommendation The Corporation should have procedures in place to ensure all required monthly deposits are made to the reserve for replacements. Views of Responsible Officials and Planned Corrective Action See accompanying Corrective Action Plan.
Show full finding ▾Hide full finding ▴2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CFDA #14.157 Supportive Housing for the Elderly Type of Finding: Noncompliance/significant deficiency in internal control over compliance Criteria The Corporation, in accordance with the Regulatory Agreement, is required to maintain a reserve for replacements. The required minimum monthly deposit into this account is $2,439 through November 2023 and $2,562 for December 2023. Condition For the year ended December 31, 2023, a total of $29,399 was to be deposited into the replacement reserve account. However, no amounts were deposited. Additionally, there was replacement reserve amounts of $23,353 from fiscal 2022 and 2021 which have not been deposited to date. Questioned Costs None Cause Due to turnover in the accounting department staff, the required monthly deposits were not made in a timely fashion. Effect The Corporation did not make the deposits into the replacement reserve account as required by the Regulatory Agreement. Recommendation The Corporation should have procedures in place to ensure all required monthly deposits are made to the reserve for replacements. Views of Responsible Officials and Planned Corrective Action See accompanying Corrective Action Plan.
Management has prepared an outstanding Replacement Reserve Deposit worksheet and this tool will be used to track monthly deposits into the Replacement Reserve Account. Deposits will begin in June 2024 and older outstanding balances will be paid first. On a go forward basis, St. Cat's will make at least one monthly deposit into the Replacement Reserve, and depending on cash flow will strive to make additional monthly deposits to lower the total amount outstanding.
2022-002
FAC accepted this audit on September 29, 2023 — management decision was due March 29, 2024.
2022-02 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CFDA #14.157 ? Supportive Housing for the Elderly Type of Finding: Noncompliance\ significant deficiency in internal control over compliance Criteria The Corporation, in accordance with the Regulatory Agreement, is required to maintain a reserve for replacements. The required minimum monthly deposit into this account is $2,326 through November 2022 and $2,440 for December 2022. Condition For the year ended December 31, 2022, a total of $28,026 was to be deposited into the replacement reserve account. However, only $4,652 was deposited, representing two monthly payments. Questioned Costs None Cause Due to turnover in the accounting department staff, the required monthly deposits were not made in a timely fashion. Effect The Corporation did not make the deposits into the replacement reserve account as required by the Regulatory Agreement. Recommendation The Corporation should have procedures in place to ensure all required monthly deposits are made to the reserve for replacements. Views of Responsible Officials and Planned Corrective Action See accompanying Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-02 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CFDA #14.157 ? Supportive Housing for the Elderly Type of Finding: Noncompliance\ significant deficiency in internal control over compliance Criteria The Corporation, in accordance with the Regulatory Agreement, is required to maintain a reserve for replacements. The required minimum monthly deposit into this account is $2,326 through November 2022 and $2,440 for December 2022. Condition For the year ended December 31, 2022, a total of $28,026 was to be deposited into the replacement reserve account. However, only $4,652 was deposited, representing two monthly payments. Questioned Costs None Cause Due to turnover in the accounting department staff, the required monthly deposits were not made in a timely fashion. Effect The Corporation did not make the deposits into the replacement reserve account as required by the Regulatory Agreement. Recommendation The Corporation should have procedures in place to ensure all required monthly deposits are made to the reserve for replacements. Views of Responsible Officials and Planned Corrective Action See accompanying Corrective Action Plan.
2022-02 Audit Finding
2021-001
FAC accepted this audit on September 20, 2022 — management decision was due March 20, 2023.
2021-01 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CFDA #14.157 ? Supportive Housing for the Elderly Type of Finding: Noncompliance\ significant deficiency in internal control over compliance Criteria The Corporation, in accordance with the Regulatory Agreement, is required to maintain a reserve for replacements. The required minimum monthly deposit into this account is $2,326. Condition For the year ended December 31, 2021, a total of $27,912 was to be deposited into the replacement reserve account. However, only $4,652 was deposited, representing two monthly payments. The remaining payment was made to the replacement reserve account subsequent to year end. Questioned Costs None Cause Due to turnover in the accounting department staff, the required monthly deposits were not made in a timely fashion. Effect The Corporation did not make the deposits into the replacement reserve account as required by the Regulatory Agreement. Recommendation The Corporation should have procedures in place to ensure all required monthly deposits are made to the reserve for replacements. Views of Responsible Officials and Planned Corrective Action See accompanying Corrective Action Plan.
Show full finding ▾Hide full finding ▴2021-01 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CFDA #14.157 ? Supportive Housing for the Elderly Type of Finding: Noncompliance\ significant deficiency in internal control over compliance Criteria The Corporation, in accordance with the Regulatory Agreement, is required to maintain a reserve for replacements. The required minimum monthly deposit into this account is $2,326. Condition For the year ended December 31, 2021, a total of $27,912 was to be deposited into the replacement reserve account. However, only $4,652 was deposited, representing two monthly payments. The remaining payment was made to the replacement reserve account subsequent to year end. Questioned Costs None Cause Due to turnover in the accounting department staff, the required monthly deposits were not made in a timely fashion. Effect The Corporation did not make the deposits into the replacement reserve account as required by the Regulatory Agreement. Recommendation The Corporation should have procedures in place to ensure all required monthly deposits are made to the reserve for replacements. Views of Responsible Officials and Planned Corrective Action See accompanying Corrective Action Plan.
2021 Audit Finding Finding 2021-01: Delinquent deposits into the Replacement Reserve Account Management Position: We agree with the 2021 Audit Finding regarding payments being made to the Replacement Reserve Account. Due to turnover in accounting staff, the required deposits were not made on a monthly basis consistently throughout the year. This was identified and the required deposits were made to the Replacement Reserve Account in July 2022. Contact Person: Frank Unger Controller Holy Family Senior Living, Inc. 610-865-5595 Corrective Action Planned: Management will implement a control which will require staff to track and make required deposits on a timely basis. This control will be reviewed by the Corporate Controller or other appropriate member of management to ensure compliance with the deposit requirement. Completion Date: The control identified in the corrective action plan for Finding 2021-001 is in the process of being implemented as of September 2022 and will include a retroactive review of previous months in 2022.
FAC accepted this audit on April 13, 2021 — management decision was due October 13, 2021.
FAC accepted this audit on April 20, 2020 — management decision was due October 20, 2020.
FAC accepted this audit on April 15, 2019 — management decision was due October 15, 2019.
FAC accepted this audit on April 19, 2018 — management decision was due October 19, 2018.
FAC accepted this audit on April 24, 2017 — management decision was due October 24, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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