Homes For Good Housing AgencyLocal Government

Eligibility Moving to Work Demonstration Program AL. No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Reported from 2024 audit (see prior year finding 2024-002) Condition: Out of an approximate population of approximately 4,800 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Two files did not have 214 documentation available for a member of the household, ▪ One file had the incorrect income calculated, which impacted the HAP received, ▪ One file had the incorrect income calculated, which did not impact the HAP received, ▪ One file received the incorrect HAP for which no subsequent correction was made, ▪ One file did not have a required rent reasonableness performed during the year, and ▪ One file did not have a quality control checklist maintained in the file. Auditor Recommendations: The Authority should re-evaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. 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. Action Due Date Responsible Person Conduct a review of cases with identified audit findings to confirm the accuracy of the determinations and implement corrections as needed. Eligibility checklists were implemented on July 31, 2024, in response to the FY23 audit findings. An additional checklist specific to annual and recertification processes was implemented in October 2025 to further strengthen compliance and quality control. Some households are on a triannual recertification cycle and have not undergone a recertification since the prior audit; these cases will be reviewed as applicable. The accuracy and effectiveness of all checklists will be reviewed and updated as needed by August 31, 2026. September 30, 2026 Program Manager, Christi Champ To address findings related to incorrect income calculations, the agency conducts monthly quality assurance reviews through random case sampling, consistent with HUD-recommended practices. Additionally, beginning in March 2026, the agency initiated comprehensive refresher trainings for all Housing Specialist (HS) staff, covering core program functions and requirements. These trainings are scheduled for completion by the end of July 2026. September 30, 2026 Program Manager, Christi Champ The file identified as missing required rent reasonableness documentation will be reviewed, and any deficiencies will be corrected as appropriate. Based on internal review, this case may be associated with a Project-Based Voucher (PBV) unit, where prior rent increases were appropriately completed but not consistently retained within the tenant file. In Spring 2026, the agency identified this documentation gap and implemented process improvements, including updates to internal policies to ensure that all rent reasonableness determinations are consistently documented and maintained September 30, 2026 Program Manager, Christi Champ in the tenant file. These updates will be effective July 2026. All required rent reasonableness documentation will be added to the applicable tenant file

2024-002

Eligibility Housing Voucher Cluster Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of an approximate population of approximately 600 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Four files did not have an inspection performed during the required period, ▪ Two files did not have an up to date 9886 form on file ▪ One file did not have ID for an adult tenant in the household, and ▪ One file had the incorrect income calculated, which did not impact the HAP received. Auditor Recommendations: The Authority should re-evaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. 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. Action Taken: Action Due Date Responsible Person Conduct a review of cases associated with inspectionrelated findings to verify the accuracy of the determinations and implement corrections as necessary. In certain cases, inspections may align with approved biennial inspection schedules, or delays may have occurred due to inability to access the unit or tenant non-compliance. In such instances, cases may currently be progressing through the ineligibility process, which requires additional time to resolve in accordance with program requirements. Additionally, the agency identified system-related reporting issues within Yardi that may have impacted the September 30, 2026 Program Manager, Nat Dybens accuracy of inspection tracking reports. The agency has been actively collaborating with system coordinators to address and resolve these issues. Files identified as lacking an upto-date Form HUD-9886 will be reviewed to confirm the accuracy of the finding, and all required documentation will be obtained and maintained in the tenant file to ensure compliance. Form HUD-9886-A [24 CFR 5.230(b)(1), b(2), (c)(4), and (c)(5)]; Notice PIH 2023-27 All adult applicants and participants sign form HUD-9886- A, Authorization for Release of Information. All adult family members (and the head and spouse/cohead, regardless of age) are required to sign the Form HUD9886-A at admission. Participants, prior to January 1, 2024, signed and submitted Form HUD9886 at each annual reexamination. HOTMA eliminated this requirement and instead required that the Form HUD-9886-A be signed only once. On or after January 1, 2024 (regardless of the PHA’s HOTMA compliance date), current program participants must sign and submit a new Form HUD-9886-A at their next interim or annual reexamination. This form will only be signed once. Another Form HUD-9886-A will not be submitted to the PHA except under the following circumstances: • When any person 18 years or older becomes a member of the family; • When a current member of the family turns 18; or • As required by HUD or the PHA in administrative instructions. September 30, 2026 Program Manager, Christi Champ The PHA has the discretion to establish policies around when family members must sign consent forms when they turn 18. PHAs must establish these policies stating when family members will be required to sign consent forms at intervals other than at reexamination. PHA To address areas of identified findings, the agency will reinforce expectations through staff reminders and provide additional training as needed. Additionally, beginning in March 2026, the agency initiated comprehensive refresher trainings for all Housing Specialist (HS) staff, covering core program functions and requirements. These trainings are scheduled for completion by the end of July 2026. Continued throughout the year. Program Manager, Christi Champ and Program Manager, Nat Dybens The file identified as missing required identification documentation for an adult household member will be reviewed to verify the accuracy of the finding, and all necessary documentation will be obtained and updated as appropriate. The agency recognizes that there are multiple acceptable methods for verifying adult identity and will ensure that documentation on file meets HUD requirements and is properly maintained. Additionally, a recertification checklist was implemented in October 2025 to support staff in verifying the presence of all required permanent documentation, including identification, during case file reviews. This control strengthens ongoing compliance and reduces September 30, 2026 Program Manager, Christi Champ the likelihood of similar deficiencies.

Cash Management Moving to Work Demonstration Program AL No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of the 66 grant drawdowns during the year, 19 drawdowns were tested and it was noted that 1 of the drawdowns was made in advance of the supporting invoices being paid to the vendors and subsequently the invoices were not paid within three business days, as required. Auditor’s Recommendations: The Agency should continue to develop and implement internal controls over grant management to coordinate capital fund draws with the timing of invoice payments. Action Taken: Action Due Date Responsible Person This finding occurred prior to the staff receiving the results of the previous audit. There have been no additional invoice payments outside of the 3-day allowable time. Staff developed and implemented an internal tracking document to ensure payments are made within three days of the draw. Complete – May 2025 Accounting Technician, Kary Smith, Lauren Hodgens and Ryan Bates

2024-003

Action: Checklists for eligibility functions were implemented 07.31.24 with the FY23 Audit Findings. The deficiencies for the FY24 Audit occurred prior to the implementation of the checklists. 01.26.24 for use of the incorrect UA and 01.18.23 for incorrect calculation of income. Due Date: July 31, 2024 Responsible Person: Program Manager, Christi Champ Action: Overdue Inspections Completed. The full portfolio of required HQS inspections were vetted following the FY23 audit, and any overdue inspections were completed. Due Date: March 31, 2025 Responsible Person: Program Manager, Nat Dybens

2023-002

Action: Set Fridays as a standard recurring day to pay invoices. Date completed: May 2025 Responsible Person: Accounting Technician, Kary Smith Action: Set Monday as the day to make capital grant drawdowns. HUD deposits the draws via ACH on Wednesdays. The PHA releases the payment on Friday Date completed: May 2025 Responsible Person: Senior Accounting Technician, Stacy Verrinder Action: At the time of the request for capital grant transfers from the Moving to Work account to the operating account, include the Accounts Payable tech in the email distribution and include information about which invoice A/P must pay by Friday Date completed: May 2025 Responsible Person: Senior Accounting Technician, Stacy Verrinder

PLAN OF ACTION RESPONSE TO FY23 FINDINGS & QUESTIONED COSTS SIGNIFICANT DEFICIENCY Action Timeframe Responsible Person Training will be provided to staff on a quality control protocol, specifically, the importance of proper calculations; obtaining necessary documentation; and the importance and process for following up on inspections July 31, 2024 Beth Ochs Rent Assistance Director Quality control by manager will be performed on all files assigned to probationary employees July 31, 2024 Beth Ochs Rent Assistance Director Establish an updated checklist for staff to follow to ensure proper documentation is obtained on each file September 30, 2024 Beth Ochs Rent Assistance Director Pull reports out of the EIV/PIC system, on a monthly basis, such as the Identity Verification Report, SSA Screening Deficiencies Report and place them in a centrally located OneNote for staff follow up. Note: This has been on pause due to the conversion to new software July 31, 2024 Beth Ochs Rent Assistance Director Establish a plan to schedule overdue inspections and complete inspections December 31, 2024 Beth Ochs Rent Assistance Director Assigned caseworker staff will correct the tenant files that were cited in the “other matter” finding in the FY 23 Audit August 30, 2024 Beth Ochs Rent Assistance Director Randomly select tenant files on a monthly basis for review. Note: This has been on pause due to the conversion to new software and will resume in July 2024 July 31, 2024 Beth Ochs Rent Assistance Director Randomly select an additional 50 HCV tenant files beyond the FY 23 audit sample of 86 and review them for the following compliance finding, to test: 1. Income calculations 2. 214 declarations for all members 3. ID documentation for all members 4. Unit inspections 5. Proof of dependents in Household August 30, 2024 Beth Ochs Rent Assistance Director

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