Housing Authority of The City of ConwayLocal Government

2025-002 Payroll Significant Deficiency in Internal Control (Repeated from prior year, Finding No. 2024-002) Condition: During our audit of payroll expenditures, the Authority was unable to provide adequate supporting documentation and as a result we were unable to verify that employees were paid at the properly approved rates for the periods tested and that internal controls were operating effectively. Auditor’s Recommendations: The Authority should implement internal controls over payroll and human resources to ensure complete and accurate personnel files are maintained on an ongoing basis for all employees. The Authority should review all current employee payroll files to ensure their files are up to date and include documentation supporting their approved pay rates and all subsequent compensation changes. Management Response: Management acknowledges the findings and the significant deficiency in internal control. We accept responsibility for the deficiencies in internal control over payroll reporting and are committed to implementing corrective actions as follows to ensure a robust control environment that ensures payroll transactions are verified against authorized documentation. Action(s) Taken: • Comprehensive File Reviews: • Immediately initiated a full review of all current employee payroll files to confirm completeness. • Acknowledge that some documentation predating the implementation of Paycom may remain incomplete; however, CHA is making every effort to ensure files are as complete as possible. • Documentation Verification: • Began verifying that each employee file contains proper documentation, including: • initial pay rates, • compensation changes, and • job descriptions and offer letters, where applicable. • Implemented a checks-and-balances review process to ensure that: • time is entered accurately, • timesheets are reviewed and signed by both the employee and the employee's supervisor, and • Authority leadership conducts a pre-payroll audit prior to processing. • Internal Controls: • The Authority utilizes a third-party provider, Paycom, for payroll administration and recordkeeping. • Timesheets are submitted, reviewed, and approved electronically within the system. • Pre-payroll audits are performed by the Executive Director prior to final payroll approval. • All payroll records are securely stored, easily searchable, and fully traceable through the electronic system. • Final payroll approval by the Executive Director through an approval memo to the HR Director before payments are allowed to be made. • Ongoing Compliance: • The HR Director will conduct semi-annual internal audits of a sample of employee files to verify and document ongoing compliance. • Staff responsible for inputting and reviewing payroll will receive ongoing compliance training. • A standardized file documentation checklist will be used to support consistent and complete recordkeeping. Name of Responsible Person(s): Jackie Otto, Executive Director, Sherdana Wade, Director of Operations, and Natalie Hawks, HR Director Projected Completion Date: Some of the corrective activities are underway. We anticipate full compliance ahead of the June 30, 2027 audited submission.

2024-002

2025-003 Procurement Material Weakness in Internal Control (Repeated in part from prior year, Finding No. 2024-003) Condition: For two of the four contracts tested, the contracts were not solicited in accordance with the Authority’s procurement policy. The contracts did not go through a formal solicitation process, and instead three informal bids were received. Additionally, none of the contracts tested contained quality control documentation to support internal controls. Auditor’s Recommendations: The Authority should strengthen their internal controls over procurement by implementing standardized procurement procedures, including documentation checklists and supervisory review processes to ensure compliance with procurement requirements. The Authority should also provide training to staff involved in the process to ensure they are aware of the requirements and processes. Management Response: Management acknowledges the findings and the material weakness in internal control and material noncompliance in procurement. We accept responsibility for the deficiencies in internal control over procurement and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Implement Standardized Procurement Procedures: Update and implement a formal, written procurement policy that clearly outlines the procedures for sealed bids, proposals, and small purchases. • CHA has established and uses a procurement register to manage the lifecycle of acquired goods and services to ensure payment status and contract compliance. • Mandatory Documentation Checklist: Create a procurement file checklist for every contract to ensure all required documents—such as the independent cost estimate, advertisement, bidder list, evaluations, and justification for award—are included in the procurement file. • Supervisory Review Process: A supervisor will review and sign off on the procurement file document before the good or service is purchased. • Staff Training: Provide comprehensive training to all staff involved in procurement to ensure they understand HUD’s procurement standards, including requirements for full and open competition and proper record-keeping. o CHA is scheduled to have a reputable HUD procurement trainer give a one-and-a-half-day procurement training to staff and a half day board procurement training to help improve compliance and staff knowledge. • CHA is in the process of having a professional third-party vendor update its procurement and disposition policies. • Maintain Records: Ensure that all documentation for the full procurement cycle is maintained, including evidence that contractors are not debarred or suspended. Name of Responsible Person(s): Jackie Otto, Executive Director, Sherdana Wade, Director of Operations, and Natalie Hawks, Procurement Director Projected Completion Date: Some of the corrective activities are underway. We anticipate full compliance ahead of the June 30, 2027 audited submission.

2024-003

2025-004 Eligibility Housing Voucher Cluster Material Weakness in Internal Control Other matter required to be reported in accordance with Uniform Guidance (Repeated in part from prior year, Finding No. 2024-004) Condition: Out of a population of 377 Housing Voucher Cluster tenants, we selected 40 tenants for testing and the following deficiencies were noted: • 6 files had incorrect income calculations, 5 of which impacted the HAP received; • 2 files were missing signatures on their 9886 form; • 2 files were missing 214 declarations for members of the household; • 1 file was missing identification for adults and dependents in the household; • 1 file had the incorrect utility allowance applied; • 1 file was delayed in receiving an annual recertification (13-month recertification); and, • 1 file did not have an annual recertification performed when due, and not able to be provided for testing. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Management Response: Management acknowledges the findings and the material weakness in internal control for eligibility. We accept responsibility for the deficiencies in internal control over eligibility and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • CHA will perform a 100% review of all remaining Housing Choice Voucher participant files not included in the audit sample to determine whether the deficiencies identified are isolated or systemic. Any additional errors or missing documentation discovered during that review will be corrected promptly, and any financial impact will be evaluated. • Correct utility allowances are being applied. • CHA has begun to review and correct all deficiencies identified in the auditor’s sampled files. This includes obtaining missing documents where possible, completing or correcting forms, verifying income, utility allowances, payment standards, inspections, rent reasonableness, identification documents, and 50058 submissions. Any unsupported payments or eligibility determinations will be recalculated and resolved. • CHA uses a mandatory file documentation checklist for all new admissions, interim recertifications, annual recertifications, moves, and contract rent changes. • No file will be finalized and no HAP action processed until a supervisor or designated reviewer verifies completeness, accuracy, and compliance with HUD requirements. This review will be documented and retained in the file. • With the implementation of new housing software in the late summer of 2026, CHA will implement a software-based tickler system to monitor annual recertification due dates, interim actions, inspection due dates, and expiring documents. The system will provide advanced reminders to staff to ensure recertifications and related actions are completed within required timeframes. In addition, the same system will be used to improve inspection monitoring/tracking. • All Housing Choice Voucher staff involved in eligibility, recertifications, inspections, file maintenance, and payment processing will continue to receive training on HUD eligibility requirements, documentation standards, file retention, rent calculations, utility allowances, payment standards, rent reasonableness, and 50058 reporting. • Management will conduct periodic internal quality control reviews of tenant files throughout the year to test compliance and identify issues before year-end. Results of these reviews will be documented, discussed with staff, and used to provide additional coaching or corrective action where needed. Name of Responsible Person(s): Jackie Otto, Executive Director, Sherdana Wade, Director of Operations, and Daporsha Abernathy, HCVP Director Projected Completion Date: Some of the corrective activities are underway. We anticipate full compliance ahead of the June 30, 2027 audited submission.

2024-004

2025-005 Allowability – Interprogram Activity Public Housing Operating Fund ALN 14.850 Significant Deficiency in Internal Control Other matter required to be reported in accordance with Uniform Guidance Condition: The Authority maintains a material interprogram receivable balance in the asset management program (“AMP”), which is due from other programs of the Authority. This interprogram receivable increased by $373,091 from the September 30, 2024 balance of $433,981, for a total receivable balance of $807,072 as of September 30, 2025. Auditor Recommendations: We recommend that the Authority immediately discontinue using Public Housing Operating Fund resources to fund costs or cash shortfalls of other programs or component units. The Authority should prepare a detailed reconciliation of all interprogram receivable and payable balances by program and implement a repayment plan to restore the Public Housing Operating Fund. We further recommend that the Authority implement written cash management and interprogram accounting procedures to prevent future unauthorized advances. These procedures should include monthly reconciliation of all interprogram balances, supervisory review, and approval of interprogram activity. Management Response: Management acknowledges and accepts responsibility for the deficiencies in internal control over allowability and eligibility and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. Reconcile intercompany balances • CHA is currently working with its fee accountant to complete this process Cease Additional Borrowing • Effective immediately, CHA will discontinue the practice of increasing interprogram borrowings from AMP 1 except where expressly authorized by HUD regulations. Implementing a Repayment Plan • CHA will implement a repayment plan to prioritize repayment from unrestricted or otherwise eligible funding sources in compliance with HUD requirements. Monthly Interprogram Reconciliation • Finance staff and fee accountant will reconcile all interprogram receivable and payable balances monthly. • Any new interprogram activity will be reviewed by the Executive Director and Fee Accountant to ensure allowability before recording. Strengthen Budget Monitoring • Management will perform monthly budget-to-actual reviews for every program to identify operating deficits before they require interprogram borrowing. • Programs experiencing budget shortfalls will implement corrective spending measures or identify alternative eligible funding sources. Improve Cash Flow Management • With the assistance of the fee accountant, CHA will prepare monthly cash flow projections for each program to monitor liquidity and prevent the use of restricted Public Housing Operating Funds for other programs. Implement Internal Control Procedures • Written procedures governing interprogram transactions will be incorporated into the Authority's financial policies. • All interprogram transactions will require documentation supporting the purpose, funding source, and regulatory allowability. Oversight by Fee Accountant • The Authority's Fee Accountant will review interprogram balances during monthly financial statement preparation and report unusual activity or growing receivable balances to management. Board Oversight • The Board of Commissioners will receive monthly financial reports that include interprogram receivable and payable balances to provide ongoing oversight of repayment progress and compliance. Monitoring • The Executive Director and Finance Department will monitor compliance with this corrective action plan monthly and adjust operating budgets as necessary to eliminate future interprogram borrowing. Name of Responsible Person(s): Jackie Otto, Executive Director, Sherdana Wade, Director of Operations, Michelle Guidry, Finance Director Projected Completion Date: Some of the corrective activities are underway. We anticipate full compliance ahead of the June 30, 2027 audited submission.

Action Taken: Management acknowledges the findings and the significant deficiency in internal control. We accept responsibility for the deficiencies in internal control over payroll reporting and are committed to implementing corrective actions as follows to ensure a robust control environment that ensures payroll transactions are verified against authorized documentation. • Comprehensive File Reviews: We have immediately begun reviewing all current employee payroll files to confirm that they are complete. • Verify Documentation: We have immediately begun ensuring each employee file contains proper documentation for initial pay rates, compensation changes, and job descriptions and offer letters, where applicable. The Authority has implemented a checks and balances review process to ensure that time is entered accurately, reviewed and signed on by the employee and the employee's supervisor, and then Authority leadership also conducts a pre-payroll audit. • Internal Controls: The Authority currently uses a third-party, Paycom, to manage its payroll functions and for recordkeeping purposes. Timesheets are entered and approved electronically in the system. Pre-payroll audits are conducted by the CEO and COO, prior to payroll being approved for payment. With the current electronic record keeping system, payroll documents are securely stored, easily searchable, and traceable. • Ongoing Compliance: The HR Directorwill conduct semi-annual internal audits of a sample of employee files to confirm and document ongoing compliance. In addition, staff who input and review payroll will receive ongoing compliance training and file documentation. Name of Responsible Person: Catherine Lamberg, CEO and Jackie Otto COO, and Natalie Hawks. HR Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by March 1, 2026.

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in procurement. We accept responsibility for the deficiencies in internal control over procurement and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Implement Standardized Procurement Procedures: Update and implement a forma', written procurement policy that clearly outlines the procedures for sealed bids, proposals, and small purchases. • Mandatory Documentation Checklist: Create a procurement file checklist for every contract to ensure all required documents—such as the independent cost estimate, advertisement, bidder list, evaluations, and justification for award—are included in the procurement file. • Supervisory Review Process: A supervisor will review and sign off on the procurement file checklist before a contract is executed. • Staff Training: Provide comprehensive training to all staff involved in procurement to ensure they understand H U D's procurement standards, including requirements forf ull and open competition and proper record-keeping. • Maintain Records: Ensure that all documentation for the full procurement cycle is maintained, including evidence that contractors are not debarred or suspended. Name of Responsible Person: Catherine Lamberg, CEO and Jackie Otto, COO, and Natalie Hawks, Procurement Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by May 1, 2026.

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in allowability and eligibility. We accept responsibility for the deficiencies in internal control over allowability and eligibility and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Immediate File Correction & Review: Correct all identified deficiencies in the sampled files. Furthermore, a 100% review of the remaining -335 files must be conducted to identify if these errors are systematic [1.1]. • Repayment and Re-calculation: For files with incorrect income, utility allowance, or payment standards, the Authority must recalculate the Housing Assistance Payments (HAP) and determine if repayments to HUD are necessary. • Strengthen Internal Controls: • Implement a File Checklist: Require a mandatory, signed checklist for all new admissions and annual recertifications to ensure all 214 forms, 9886 forms, income verifications, and ID documentation are present. • Supervisory Review: Implement a mandatory, independent supervisory review of a percentage of files before HAP payments are authorized. • Inspection Tracking System: Utilize automated tools to track HQS inspection dates to prevent late or missed inspections. • Training: Provide staff training on HUD eligibility, income verification, and rent calculation procedures, specifically focusing on the requirements in 24 CFR Part 5. Name of Responsible Person: Catherine Lamberg, CEO, and Jackie Otto, COO, and Daporsha Abernathy, HCVP Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by June 1, 2026.

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in its waiting list management. We accept responsibility for the deficiencies in internal control over the waiting list and are committed to implementing corrective actions that address missing documentation and lack of transparency in following the Authority's Administrative Plan and HUD guidelines when selecting applicants from its waiting list. Immediate corrective actions include: • Only using the electronic records of applicants from the Authority's housing software and not creating external waiting lists. • Reconcile and Reconstruct: Immediately reconcile the waiting list and reconstruct missing documentation for voucher issuance. • Cleanup Waiting List: The Authority's waiting list is closed, and staff are currently working to purge it. • Update Procedures: Ensure staff know and are trained on waiting list procedures to ensure compliance with HUD regulations and the Authority's Administrative Plan. • Implement Controls: Establish a periodic supervisory review to verify document completeness during the voucher issuance process. • Training: Provide staff with ongoing training on proper, consistent, and compliant wailing list administration. • Retention: Ensure all records are maintained according to federal retention requirements. Name of Responsible Person: Catherine Lamberg, CEO, and Jackie Otto, COO, and Daporsha Abernathy, HCVP Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by June 1, 2026.

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in SEMAP reporting. We accept responsibility for the deficiencies in internal control over SEMAP reporting and are committed to implementing corrective actions that address missing self-certification documentalion to ensure compliance. The Authority must take immediate steps to remediate these deficiencies by establishing a robust, auditable documentation process: • Strengthen Internal Controls: Develop procedures to ensure complete and accurate documentation is maintained for all 14 SEMAP indicators, including detailed sampling methodologies. • Pre-Certification Review: Implement a mandatory management review process for all SEMAP documentation before final certification is submitted to HUD. • Ensure Proper Retention: Enforce document retention policies that align with HUD regulations, ensuring records are accessible for audit purposes. • Staff Training: Provide training to staff regarding SEMAP indicator requirements and the necessity of maintaining supporting evidence. • Utilize PIG Reports: Ensure all tenant data is properly reported in PlC, as this is the basis for several indicators. Name of Responsible Person: Catherine Lamberg, CEO, and Jackie Otto, COO, and Daporsha Abernathy, HCVP Director Projected Completion Date: Most of the corrective activities are completed. We anticipate completing the balance of activities by May 1, 2026.

Housing Authority of the City of Conway respectfully submits the following corrective action plan for the year ended September 30, 2023. Responsible Official: Catherine Lamberg, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Audit period: Year ended September 30, 2023 Oversight Agency: U.S. Department of Housing and Urban Development The findings from the September 30, 2023, audit are discussed below. The findings are numbered to correspond to the auditing findings disclosed in the Schedule of Findings and Questioned Costs. MATERIAL WEAKNESSES Finding 2023-001 – Material Misclassifications • Criteria: A control deficiency exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions to prevent or detect misstatements of the financial statements on a timely basis. AU-C Section 265 Communication Internal Control Related Matters Identified in an Audit, identifies deficiencies in controls over the period-end financial reporting process, including controls over procedures used to enter transactions and journal entries into the general ledger and to record recurring and nonrecurring adjustments to the financial statements that was not initially identified by the entity’s internal controls even if management subsequently corrects the misstatement. • Condition: Material misclassifications in the financial statements under audit. Multiple accounts were not reconciled on a regular basis. In addition, deposits were not recorded on a timely basis resulting in material errors on the financial data schedule that was submitted to REAC. • Context: Several items were discovered that were misclassified. More specifically, assets, liabilities, revenues and expenses were not able to be verified or reconciled. • Effect: The financial statements of Housing Authority of the City of Conway were not materially correct. • Recommendation: Review procedures for proper classification of expenditures and reconcile accounts on a regular basis. • Planned Corrective Actions: We are working with our accountant to resolve the issue. During the current fiscal year, our accountant was not able to access our financial records on a timely basis which resulted in multiple items not being recorded or reconciled. We anticipate these issues being resolved prior to completion of the next audit.