THE ARC ORANGE APARTMENTS

Supportive Housing for Persons with Disabilities (Section 811), ALN 14.181 Criteria: Under HUD regulations, recipients are required to maintain and make available all records necessary to demonstrate compliance with program requirements. HUD requires documentation of tenant eligibility, income verification, and rent determination. The Uniform Guidance requires recipients to maintain records that adequately identify the source and application of funds. Statement of Condition: We reviewed 10% of the total population of tenant files. During our review, we noted that documentation to support tenant eligibility determination was missing or incomplete. We consider this condition to be a significant deficiency. Cause: The deficiencies occurred due to inconsistent file management practices and ineffective internal review procedures to ensure that all required eligibility documentation is obtained and retained. Effect: Missing or incomplete files increase the risk of improper eligibility determinations, inaccurate rent calculations, questioned costs, and HUD noncompliance. Recommendation: We recommend that management strengthen internal controls over tenant file documentation by conducting periodic supervisory reviews of files to ensure that all required documentation is present and complete and by providing staff training on HUD eligibility and documentation requirements. Views of Responsible Officials: We agree with the auditor’s finding. The issue was primarily due to staff turnover of nearly 90% since August 2024, with new staff receiving little to no training on HUD requirements and The Arc’s Standard Operating Procedures, continued use of a failed software system through a five-year contract that ended May 31, 2025, and failed management practices prior to March 2025. Corrective procedures are now in place, and we believe these steps will resolve the matter going forward. Supervisors will initiate corrective actions to strengthen tenant file documentation and compliance with HUD requirements. Staff have received refresher training on eligibility and documentation procedures and will receive ongoing training and mentoring as needed. A thorough review of all properties has been conducted and supervisory reviews of tenant files will be conducted on a periodic basis going forward. Missing or incomplete documentation in existing files will be addressed where feasible. These measures are expected to resolve the deficiency and prevent recurrence in future audits.

To address the noted deficiencies in tenant file documentation, management has changed management of the organization in March 2025, established new and experienced supervisors in April 2025, reviewed Standard Operating Procedures and implemented anew, reviewed all properties and prioritized needed corrections in May and June 2025, transitioned from MRI software to Yardi software as of June 2025, sent Occupancy Specialists to a 2 ½ day Quadel training to review all the basic requirements of HUD in July 2025, and we continue to provide internal training and process orientation to Occupancy Specialists. In addition, we will continue to ensure all Standard Operating Procedures are followed. This oversight will be provided by all supervisors, re-establish the regular reviews of new tenant files outlined in the SOP “OCC-05 Occupancy File Reviews,” and continue internal training for staff as needed.

Supportive Housing for Persons with Disabilities (Section 811), ALN 14.181 Criteria: In accordance with HUD regulations and the Uniform Guidance, recipients are required to submit audited financial statements to HUD and to submit the Single Audit reporting package to the Federal Audit Clearinghouse (FAC) within nine months after fiscal year end. Statement of Condition: The Organization did not submit its audited financial statements to HUD or its Single Audit reporting package to the FAC by the required due date. Cause: The delays in completing the audit resulted from the Organization’s difficulty completing year-end closing of the books due to issues from a change to new software and staff turnover during the year. Additional delays resulted from the Organization’s difficulty locating occupancy records requested by the auditor. Effect: Failure to submit required reports by the established deadlines places the Organization in noncompliance with federal requirements and may result in sanctions or restrictions on program funding. Recommendation: We recommend that management implement procedures to ensure that financial reconciliations are completed timely and that software issues are promptly identified and resolved. We also recommend that management strengthen recordkeeping procedures to ensure that occupancy records are maintained, organized, and provided timely to auditors. Views of Responsible Officials: We agree with the auditor’s finding. The issue was primarily due to staff turnover of nearly 90% since August 2024, with new staff receiving little to no training on HUD requirements and The Arc’s Standard Operating Procedures, continued use of a failed software system through a five-year contract that ended May 31, 2025, and failed management practices prior to March 2025. Corrective procedures are now in place, and we believe these steps will resolve the matter going forward. Supervisors will initiate corrective actions to strengthen tenant file documentation and compliance with HUD requirements. Staff have received refresher training on eligibility and documentation procedures and will receive ongoing training and mentoring as needed. A thorough review of all properties has been conducted and supervisory reviews of tenant files will be conducted on a periodic basis going forward. Missing or incomplete documentation in existing files will be addressed where feasible. These measures are expected to resolve the deficiency and prevent recurrence in future audits.

To address the noted deficiencies in the late submissions to HUD and the FAC, management has changed management of the organization in March 2025, established new and experienced supervisors in April 2025, reviewed Standard Operating Procedures and implemented anew, reviewed all properties and prioritized needed corrections in May and June 2025, transitioned from MRI software to Yardi software as of June 2025, sent Occupancy Specialists to a 2 ½ day Quadel training to review all the basic requirements of HUD in July 2025, and we continue to provide internal training and process orientation to Occupancy Specialists. In addition, we will continue to ensure all Standard Operating Procedures are followed. This oversight will be provided by all supervisors, re-establish the regular reviews of new tenant files outlined in the SOP “OCC-05 Occupancy File Reviews,” and continue internal training for staff as needed.