EIN: 463510845
UEI: HPDGL935X2R6
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (41 days from today).
What is a management decision? →The Organization failed to timely make all of its required deposits to its reserve for replacement account during the year ended September 30, 2024. In accordance with the Organization's regulatory agreement, the Organization is required to make all deposits on a monthly basis. Cause: Due to cashflow constraints the Organization did not generate sufficient cash flow to pay it's monthly operating expenses and fund the required reserve for replacement in a timely fashion. Effect: The Organization failed to make the October 2023 through March 2024 reserve for replacement required deposits in a timely manner (amount was subsequently deposited in September 2024). In addition, the reserve for replacement required deposits for April 2024 to September 2024 were not made prior to September 2024. Questioned costs: $ 20,994 Context: All of the required monthly reserve for replacement deposits were not made in a timely manner. Recommendation: The Organization should establish procedures to ensure all required reserve for replacement amounts are deposited in a timely fashion. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The Organization has made a corrective deposit to the reserve for replacement for the months of October 2023 to March 2024 before September 30, 2024. The Organization has made catch-up deposits to the reserve for replacement account for all of the monthly deposits required for the year ended September 30, 2024, subsequent to the year-end.
Show full finding ▾Hide full finding ▴Federal agency: U.S. Department of Housing and Urban Development Federal program title: Supportive Housing for the Elderly Section 202 Assistance Listing Number: 14.157 Award Period: Year Ended September 30, 2024 Type of Finding: · Other Matters Criteria or specific requirement: Failure to make all required reserve for replacement deposits. Condition: The Organization failed to timely make all of its required deposits to its reserve for replacement account during the year ended September 30, 2024. In accordance with the Organization's regulatory agreement, the Organization is required to make all deposits on a monthly basis. Cause: Due to cashflow constraints the Organization did not generate sufficient cash flow to pay it's monthly operating expenses and fund the required reserve for replacement in a timely fashion. Effect: The Organization failed to make the October 2023 through March 2024 reserve for replacement required deposits in a timely manner (amount was subsequently deposited in September 2024). In addition, the reserve for replacement required deposits for April 2024 to September 2024 were not made prior to September 2024. Questioned costs: $ 20,994 Context: All of the required monthly reserve for replacement deposits were not made in a timely manner. Recommendation: The Organization should establish procedures to ensure all required reserve for replacement amounts are deposited in a timely fashion. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The Organization has made a corrective deposit to the reserve for replacement for the months of October 2023 to March 2024 before September 30, 2024. The Organization has made catch-up deposits to the reserve for replacement account for all of the monthly deposits required for the year ended September 30, 2024, subsequent to the year-end.
There is no disagreement with this audit finding. Management is in the process of communicating with the proper HUD representatives regarding the procedures required to catch up the funding of the replacement for reserve erroneously omitted during the year ended September 30, 2024. NDC Asset Management LLC has taken several steps to increase the cash flow of the property to allow for sufficient funds to meet the operating and reserve for replacement requirements of the property. Procedures taken include filing property tax appeals; applying for increases in rent subsidies; and establishing and monitoring the property's budget to control spending.
2023-001
FAC accepted this audit on July 1, 2024 — management decision was due January 1, 2025.
The Organization failed to timely make all of its required deposits to its reserve for replacement account during the year ended September 30, 2023. In accordance with the Organization's regulatory agreement, the Organization is required to make all deposits on a monthly basis. Cause: The Organization failed to make the December 2022 reserve for replacement required deposit in a timely manner (amount was subsequently deposited in January 2023). In addition, the reserve for replacement required deposits for March 2023 to September 2023 were not made prior to September 2023. Effect: All required monthly deposits were not made to the reserve for replacement account in accordance with the Organization's regulatory agreement with HUD. Questioned costs: $ 13,712 Context: Two required reserve for replacement deposits were not made in a timely manner. Recommendation: The Organization should establish procedures to ensure all required reserve for replacement amounts are deposited in a timely fashion. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The Organization has made a corrective deposit to the reserve for replacement for the month of December 2022. The Organization will make a catch-up deposit to the reserve for replacement account for all of the monthly deposits previously not made.
Show full finding ▾Hide full finding ▴Federal agency: U.S. Department of Housing and Urban Development Federal program title: Supportive Housing for the Elderly Section 202 Assistance Listing Number: 14.157 Award Period: Year Ended September 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Failure to make all required reserve for replacement deposits. Condition: The Organization failed to timely make all of its required deposits to its reserve for replacement account during the year ended September 30, 2023. In accordance with the Organization's regulatory agreement, the Organization is required to make all deposits on a monthly basis. Cause: The Organization failed to make the December 2022 reserve for replacement required deposit in a timely manner (amount was subsequently deposited in January 2023). In addition, the reserve for replacement required deposits for March 2023 to September 2023 were not made prior to September 2023. Effect: All required monthly deposits were not made to the reserve for replacement account in accordance with the Organization's regulatory agreement with HUD. Questioned costs: $ 13,712 Context: Two required reserve for replacement deposits were not made in a timely manner. Recommendation: The Organization should establish procedures to ensure all required reserve for replacement amounts are deposited in a timely fashion. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The Organization has made a corrective deposit to the reserve for replacement for the month of December 2022. The Organization will make a catch-up deposit to the reserve for replacement account for all of the monthly deposits previously not made.
Re: Corrective Action Plan (CAP) for Primrose Apartments, Inc. Name of Auditee: Primrose Apartments, Inc HUD Project No.: 033-EE147 Period Covered by Audit: Year Ended September 30, 2023 CAP Prepared by: Kristiann Keller Property Controlller NDC Asset Management LLC 412-578-7833 Current Finding on Schedule of Findings and Questioned Costs Views of Responsible Officials and Planned Corrective Action: Finding 2023-001 There is no disagreement with this audit finding. Management is in the process of communicating with the proper HUD representatives regarding the procedures required to catch up the funding of the replacement for reserve erroneously omitted during the year ended September 30, 2023. NDC Asset Management LLC will implement procedures to be followed any time a new property comes under management to ensure that any reserve for replacement required deposits are funded in a timely manner.
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
The Organization failed to timely make all of its required deposits to its reserve for replacement account during the year ended September 30, 2022. In accordance with the Organization's regulatory agreement, the Organization is required to make all deposits on a monthly basis. Cause: The Organization failed to make the July 2022 and August 2022 deposits to reserve for replacement account within a timely manner. Effect: All required monthly deposits were not made to the reserve for replacement in accordance with the Organization's regulatory agreement with HUD. Questioned costs: $ 3,428 Context: Two required reserve for replacement deposits were not made in a timely manner. Recommendation: The Organization should establish procedures to ensure all reserve for replacement amounts are deposited in a timely fashion. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The Organization has made corrective deposits to the reserve for replacement account in the months following the missed deposits prior to the year ended September 30, 2022.
Show full finding ▾Hide full finding ▴Federal agency: U.S. Department of Housing and Urban Development Federal program title: Supportive Housing for the Elderly Section 202 CFDA Number: 14.157 Award Period: Year Ended September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Failure to make all required reserve for replacement deposits. Condition: The Organization failed to timely make all of its required deposits to its reserve for replacement account during the year ended September 30, 2022. In accordance with the Organization's regulatory agreement, the Organization is required to make all deposits on a monthly basis. Cause: The Organization failed to make the July 2022 and August 2022 deposits to reserve for replacement account within a timely manner. Effect: All required monthly deposits were not made to the reserve for replacement in accordance with the Organization's regulatory agreement with HUD. Questioned costs: $ 3,428 Context: Two required reserve for replacement deposits were not made in a timely manner. Recommendation: The Organization should establish procedures to ensure all reserve for replacement amounts are deposited in a timely fashion. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The Organization has made corrective deposits to the reserve for replacement account in the months following the missed deposits prior to the year ended September 30, 2022.
View of Responsible Officials and Planned Corrective Action This finding relates to the late deposit of the required amount to the Replacement for Reserve as required by HUD. The late deposits were due to the timing of cash flows and the deficiency of cash available to make the deposit. The property manager is in the process of working with HUD to increase rents and make the property more financially self-sufficient. The late deposits were made to the Replacement for Reserve before the end of the Organization’s year end, September 30, 2022. Therefore, no further corrective action plan is deemed necessary at this time.
FAC accepted this audit on February 2, 2022 — management decision was due August 2, 2022.
Management fees paid for the year ended September 30, 2021 were greater than the per unit per month (PUPM) calculation plus $ 1.50 special fee for not-forprofit entities per form HUD-9839-B dated June 2016. Cause: Management fees are not being calculated in accordance with the signed HUD agreement. Effect: The Organization paid management fees in excess of the amount allowable per the management agreement, thus incurring nonallowable costs. Questioned costs: $ 4,531 Context: The management agent did not implement effective internal controls over payment of management fees. Recommendation: The Organization should establish procedures to ensure monthly management fees are calculated in accordance with HUD regulations and the management agreement. Views of Responsible Officials and Planned Corrective Actions: Management agrees, see separate corrective action plan.
Show full finding ▾Hide full finding ▴SECTION III - FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL PROGRAMS Finding 2021-001: Federal agency: U.S. Department of Housing and Urban Development Federal program title: Supportive Housing for the Elderly Section 202 CFDA Number: 14.157 Award Period: Year Ended September 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: In accordance with the HUD Regulatory Agreement related to the Section 202 Capital Advance Program, Assistance Listing No. 14.157, management fees are to be paid in accordance with the Project Owner's/Management Agent's Certification (form HUD-9839-B). Condition: Management fees paid for the year ended September 30, 2021 were greater than the per unit per month (PUPM) calculation plus $ 1.50 special fee for not-forprofit entities per form HUD-9839-B dated June 2016. Cause: Management fees are not being calculated in accordance with the signed HUD agreement. Effect: The Organization paid management fees in excess of the amount allowable per the management agreement, thus incurring nonallowable costs. Questioned costs: $ 4,531 Context: The management agent did not implement effective internal controls over payment of management fees. Recommendation: The Organization should establish procedures to ensure monthly management fees are calculated in accordance with HUD regulations and the management agreement. Views of Responsible Officials and Planned Corrective Actions: Management agrees, see separate corrective action plan.
Community Action Partnership of Mercer County (CAPMC) has reviewed the Findings and Questioned Costs for Primrose Apartments and are in agreement with your assessment. While the Management agent, Action Housing-SHMS has provided documentation from Maria Sandor, HUD Account Executive stating that the maximum PUPM fee for the state of Pennsylvania is $58.00, and provided other supporting documentation, this amount does not comply with Project Owner?s Management Agents Certification for Multifamily Housing Projects which was signed in 2016. According to the above-mentioned certification, the amount of management fees that could be collected by the Management Agent was 8% of residential rent collected and special fees which included non-profit fee of $1.50 PUPM, no miscellaneous fees could be utilized for the calculation of Management fees. Based on the audit conducted by your firm the Management Agent included miscellaneous income which was laundry fees as part of the calculation. The Management Agent took action without authorization by utilizing the laundry fees as part of the management fee calculation. Corrective Action: ? Community Action Partnership of Mercer County (CAPMC) will inform the Management Agent of their unauthorized use of laundry fees as part of the calculation of Management Fees.? CAPMC will inform the Management Agent (Action Housing ? SMHS) of the funds that are due back to the project as an overcharge of management fees and will collect such fees and request that they cease this practice until approval can be acquired from HUD. ? CAPMC will comply with paragraph 10 of the Project Owners/Management Agent Certification and submit a new Project Owners/Management Certification to HUD that will include the miscellaneous fees.
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