HOUSING CORPORATION OF ARLINGTONNon-Profit

Criteria: Tenant files are required to be maintained and tenant eligibility determined in accordance with 24 CFR, section 92.203 and 92.508 of the Office of Management and Budget's Uniform Guidance. Condition and Context: For 7 of the 8 tenants selected for testing, recertifications were not completed in accordance with 24 CFR, section 92.203 and 92.508 of the Office of Management and Budget's Uniform Guidance. Cause: Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with 24 CFR, section 92.203 and 92.508 of the Office of Management and Budget's Uniform Guidance were not consistently followed. Effect or Potential Effect: The procedures for determining tenant recertification eligibility and maintaining tenant lease files were not consistently applied in accordance with 24 CFR, section 92.203 and 92.508 of the Office of Management and Budget's Uniform Guidance. This could result in units being rented to ineligible tenants or errors in the rent subsidies. Questioned Costs: None Repeat Finding: No Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that recertifications are performed timely, tenant eligibility is correctly determined, and that tenant lease file are properly maintained in accordance with the requirements of 24 CFR, section 92.203 and 92.508 of the Office of Management and Budget's Uniform Guidance. Views of Responsible Officials: The Agency will implement controls and procedures to ensure applicable compliance requirements are completed timely and accurately.

Criteria: Tenant files are required to be maintained and special tests, including unit inspections, determined in accordance with 24 CFR sections 92.209(i), 92.251(f), and 92.504(d) of the Office of Management and Budget's Uniform Guidance. Condition and Context: For 7 of the 8 tenants selected for testing, inspections were not completed in accordance with 24 CFR sections 92.209(i), 92.251(f), and 92.504(d) of the Office of Management and Budget's Uniform Guidance. Cause: Management's policies with respect to recertifications and the maintenance of tenant lease files, specifically unit inspections, in accordance with 24 CFR sections 92.209(i), 92.251(f), and 92.504(d) of the Office of Management and Budget's Uniform Guidance were not consistently followed. Effect or Potential Effect: The procedures for unit inspections, were not consistently applied in accordance with 24 CFR sections 92.209(i), 92.251(f), and 92.504(d) of the Office of Management and Budget's Uniform Guidance. This could result in unhabitable units being rented to tenants. Questioned Costs: None Repeat Finding: No Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that inspections are performed on a timely basis in accordance with the requirements of 24 CFR sections 92.209(i), 92.251(f), and 92.504(d) of the Office of Management and Budget's Uniform Guidance. Views of Responsible Officials: The Agency will implement controls and procedures to ensure applicable compliance requirements are completed timely and accurately.

Criteria: The Office of Management and Budget (OMB) has issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called "Uniform Guidance"), which requires institutions of higher education and nonprofit institutions that expend $750,000 or more in federal funds to annually conduct a detailed, organization-wide audit that complies with the established criteria. Additionally, the Uniform Guidance reporting package and the data collection form are required to be submitted to the Federal Audit Clearinghouse the earlier of 30 days after the receipt of the auditors reports or nine months after the end of the audit period, unless a longer period of time was agreed to in advance by the cognizant or oversight agency for the audit. Condition and Context: A detailed, organization-wide audit that complies with Uniform Guidance established criteria was not timely completed and submitted to OMB. Cause: Management did not have internal controls in place to allow for a timely audit which resulted in delays in timely submitting the report to OMB. Effect: A detailed, organization-wide audit that complies with the established criteria was not timely completed resulting in the Agency not being in compliance with Uniform Guidance requirements. Questioned Costs: None Repeat Finding: No Recommendation: Management should ensure timely completion of a Uniform Guidance audit, as required. Views of Responsible Officials: HCA's executive and property management transitions that occurred in 2021, combined with the findings listed above and the additional research and preparation they required, resulted in a severely delayed 2020 audit. We are finalizing the final draft of the 2020 audit now and have started preparing for our 2021 and 2022 audits. We have the internal capacity to prioritize and move quickly to get all audits up to date. A system has been put in place to ensure smooth and timely completion of HCA's audits and required reporting to OMB going forward.