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Open Recommendations by Oversight Area

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Open Recommendations by Oversight Area
Oversight Area	Priority Recommendations	Open Recommendations
Housing Assistance	75	100
Community Development	3	75
Disaster Recovery	3	82
Financial Risk and Accountability	6	130
Technology and Cybersecurity	4	88
Health and Safety	1	53
HUD's Operations	4	100
Total	96	628

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We audited Clark County, NV’s Community Development Block Grant (CDBG) program. We selected Clark County for review due to its large grant size and the U.S. Department of Housing and Urban Development’s (HUD) risk assessment. The reporting objective of the audit was to determine whether Clark…

Oversight Area: Community Improvement

Support the reasonableness of the amount paid for the food facility consolidation and expansion project or repay the program $1,663,758 from non-Federal funds.

Correct any citations from the Southern Nevada Health District at the Pettiti public pool before May 2017 using non-Federal funds or repay the entire project cost of $596,126 from non-Federal funds and support the reasonableness of the change orders for the Pettiti pool project or repay the program from non-Federal funds.

Support the cost reasonableness of $2,809 in change orders for the ADA pool improvement project or repay the program from non-Federal funds.

Provide supporting documentation for $4,955 in unsupported costs or repay the program from non-Federal funds.

Provide support showing that the ADA pool improvement project allows equal and independent access for people with disabilities through a third party or correct the access issue.

Develop and implement procurement policies and procedures for monitoring subrecipients to ensure that the scope of work developed by its subrecipients is sufficiently detailed to allow contractors to submit informed bids, reducing the number of change orders after the contract, and that its subrecipients do an independent cost analysis before all procurement transactions, including change orders, to ensure that it receives a reasonable price and allows for full and open competition.

Develop and implement policies and procedures that ensure labor wage interviews are completed and documented.

Provide training to its staff on CDBG program rules and requirements to ensure that its staff adequately implements policies and procedures.

Identify the national objective met for the park project or repay the program $2,000,000 from non-Federal funds.

Develop monitoring practices to ensure that all projects that use limited clientele criteria exclusively serve the specific population claimed.

Repay $48,323 to the program from non-Federal funds for non-program-related payroll costs.

Determine the allocable amount of CDBG payroll costs for the employees who worked on CDBG and non-CDBG activities and adjust the funding amount as necessary or repay the program $573,064 from non-Federal funds.

Repay $71,397 to the program from non-Federal funds for the use of CDBG funds for code enforcement costs related to general government expenses.

Revise its code enforcement program to meet CDBG requirements for the remaining $33,603 budgeted or amend the use of the funding to another CDBG-eligible activity.

Determine the CDBG proportional benefit of the $329 charged for indirect automotive costs and repay the program any unsupported charges using non-Federal funds.

Obtain training or technical assistance from HUD concerning CDBG code enforcement, allocation of payroll, and indirect administrative costs.

We audited the U.S. Department of Housing and Urban Development (HUD), Office of Community Planning and Development’s (CPD) Section 108 Loan Guarantees program. We conducted the audit as part of our annual audit plan. Our audit objectives were to determine whether HUD had adequate oversight of…

Oversight Area: Community Improvement

Reevaluate the feasibility of the two Section 108 activities that failed to meet a national objective and determine the eligibility of the $15,814,000 already invested. Any amount determined ineligible must be reimbursed to the program from non-Federal funds.

Require the borrowers to submit a plan for how they will proceed and use the $8,694,000 million in unused commitments to provide the intended benefits and meet program objectives.

Require the borrower to provide all supporting documentation and evaluate the allowability and eligibility of $75,000 used for the unauthorized activity. Any amount determined ineligible must be reimbursed to the program from non-Federal funds.

Develop procedures directing field offices to include the review of Section 108-funded activities when performing the annual reviews of Block Grant recipients.

Develop procedures to ensure that the information necessary to monitor program performance and compliance with program requirements is promptly provided to the field offices.

Implement procedures to ensure that borrowers comply with all loan contract provisions and that required documents are submitted, including bank agreements, monthly statements, and security documents. If a borrower does not provide evidence that it has complied with all program requirements, HUD must initiate appropriate remedial actions under paragraph 12 of the contract.

Develop and implement a tracking system for monitoring reviews of Section 108 loans.

We reviewed the Miami-Dade County Homeless Trust’s Continuum of Care Program because our office had not audited this entity. In addition, this assignment was in accordance with our annual audit plan and the U.S. Department of Housing and Urban Development’s (HUD) 2014-2018 strategic objective to…

Oversight Area: Community Improvement

Provide supporting documentation or reimburse its Program $81,654 from non-Federal funds for unsupported on-the-job training costs incurred under project FL0220L4D001407.

Provide supporting documentation or reimburse its Program $1,023 from non-Federal funds for unsupported personal cell phone costs incurred under project FL0220L4D001407.

Provide guidance to subrecipients to ensure that (1) on-the-job training hours are supported by source documents, such as signed attendance or time sheets, and (2) personal goods and services are supported by documents that show the allocation between business and personal use.

Report Program income of $31,724 for FL0199L4D001407 to HUD.

Provide supporting documentation to show that participant 87487 from FL0431L4D001403 was chronically homeless or reimburse its Program $15,756.

Perform onsite monitoring of the subrecipient that administered project FL0431L4D001403 to ensure that participants are eligible and annual income re-certifications are performed.

We audited Mental Health Systems, Inc.’s (MHS) Supportive Housing Program and Continuum of Care direct grants from the U.S. Department of Housing and Urban Development (HUD). We audited MHS as the result of requests from HUD, prompted by a media report and the County of San Diego’s review of MHS…

Oversight Area: Community Improvement

Develop and implement a written methodology for employees’ time allocations for its HUD grant programs in accordance with program requirements.

Provide training on compensation for personal services grant program requirements to employees working on HUD grants.

Support $142,181 spent on payroll allocated to HUD grants or repay the program from non-Federal funds.

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General audited HUD’s Office of Community Planning and Development’s (CPD) process for making changes to its programs, policies, and operations. We initiated the audit because of concerns we had with HUD’s disaster…

Oversight Area: Disaster Relief

Pursue departmental clearance for the July 25, 2013, guidance that did not go through required departmental clearance. For any items that cannot be appropriately cleared, HUD should take appropriate action to recall the document or policy.

Develop guidance that helps the public understand its options for assistance between CDBG-DR and SBA and how to comply with Federal requirements.

Develop improved procedures and provide training to appropriate staff regarding the departmental clearance process requirements, including • Determining which guidance is considered to be a directive, including public communications, and • Ensuring that HUD program participants have clear, instructive, and helpful information to comply with the applicable requirements and procedures for HUD programs.

We audited the City of Huntington Park’s Community Development Block Grant (CDBG) program. We selected the City based on the high risk assessment score and prior findings identified by the U.S. Department of Housing and Urban Development (HUD). The objective of the audit was to determine whether…

Oversight Area: Community Improvement

Repay the program $7,323 from non-Federal funds for ineligible code enforcement costs.

Support the $576,997 in code enforcement costs (activities 499, 512, and 531), including meeting code enforcement and cost allocation requirements, or repay the program from non-Federal funds.

Implement revised code enforcement program policies and procedures to meet CDBG requirements. This will help ensure that the remaining $328,918 budgeted for code enforcement activity 531 is put to better use.

Support the reasonableness of the $110,000 Graffiti Removal program (activities 504 and 520) cost allocations or repay the program from non-Federal funds.

Support the $31,186 After School program (activity 501) costs, including the reasonableness of the contract costs and meeting the limited clientele national objective, or repay the program from non-Federal funds.

Support the reasonableness of the $95,736 in cost allocations charged as CDBG administrative (activity 522) costs or repay the costs from non-Federal funds.

Implement additional policies and procedures to ensure that salaries and wages and cost allocations are charged in compliance with HUD requirements.

Implement additional procedures and controls to ensure that documentation is obtained to support that the limited clientele national objective was met.

Obtain training or technical assistance on CDBG program requirements.

We audited the U.S. Department of Housing and Urban Development’s (HUD) Office of Community Planning and Development’s (CPD) risk assessment and monitoring of its State Community Development Block Grant (CDBG) recipients. We started this assignment due to significant findings reported on the State…

Oversight Area: Community Improvement

We recommend that the General Deputy Assistant Secretary for Community Planning and Development develop and implement a quality review process at the headquarters level to ensure consistent compliance with its policy for risk analysis, to include but not be limited to reviewing supporting documentation for conclusions drawn.

We recommend that the General Deputy Assistant Secretary for Community Planning and Development, develop and implement a policy requiring field offices to rate grantees of at least medium risk that have not been monitored in their respective program area within the last 3 years on factors that require assessments of capacity, program complexity, and monitoring findings resulting in repayment or grant reductions.

We recommend that the General Deputy Assistant Secretary for Community Planning and Development, develop and implement guidance for field offices to maintain supporting documentation in their official files with an adequate explanation of procedures performed to verify risk scores assigned, which could include upgrading CPD’s systems to allow for the attachment of supporting documentation for risk analyses.

We recommend that the General Deputy Assistant Secretary for Community Planning and Development, develop and implement a quality control review process at the headquarters level to ensure compliance with monitoring requirements for reports and exhibits, to include but not be limited to explaining procedures performed and adequately explaining and providing supporting documentation for conclusions drawn.

We recommend that the General Deputy Assistant Secretary for Community Planning and Development, require field offices to upload referenced supporting documentation into CPD’s system for findings and concerns developed during the monitoring review.

We recommend that the General Deputy Assistant Secretary for Community Planning and Development, update exhibits to require staff to document procedures performed, provide sufficient explanation to verify procedures performed and conclusions drawn, and reference appropriate supporting documentation.

We audited the City of Atlanta, GA, and its subrecipient, the Fulton County-City of Atlanta Land Bank Authority. We began our review of the City’s administration of its Neighborhood Stabilization Programs 1 (NSP1) and 3 (NSP3) grants because it aligns with our goal in the U.S. Department of…

Oversight Area: Community Improvement

Provide adequate monitoring to the Land Bank to ensure that the subrecipient follows Federal regulations as required, including policies and procedures to help verify subrecipient compliance or address any deficiencies in need of correcting, such as annual audits, financial management systems, and file management.

Provide adequate support for expenses totaling $48,985. Any expenses that are not supported should be repaid to the appropriate NSP grant from non-Federal funds.

Ensure that the Land Bank completes and clears all outstanding annual audits for fiscal years 2012 through 2016.

Ensure that the Land Bank develops and implements adequate financial and file management policies and procedures to ensure that files are auditable and financial records adequately identify the source and application of federally sponsored activities in accordance with Federal regulations.

Reprogram the remaining NSP1 funds of $219,851 and NSP3 funds of $28,745 to another subrecipient or developer or return the funds to the U.S. Treasury.

We audited the City of Birmingham, AL’s Community Development Block Grant Disaster Recovery (CDBG-DR) grant. We selected the City for review based on concerns by the U.S. Department of Housing and Urban Development’s (HUD) Birmingham Office of Community Planning and Development in regard to the…

Oversight Area: Community Improvement

Develop and implement HUD-approved policies and procedures to ensure that the process for conducting an internal audit complies with HUD regulations and the policies and procedures are submitted and certified to HUD.

Immediately conduct an internal audit of the CDBG-DR grant funds.

Update, finalize, and implement its procurement policies to comply with 2 CFR 200.317-326.

We audited the Louisville-Jefferson County Metropolitan Government’s Housing Opportunities for Persons With AIDS (HOPWA) program. We selected Louisville Metro for review based on a management referral from the U.S. Department of Housing and Urban Development’s (HUD) Louisville, KY, Office of…

Oversight Area: Community Improvement

Adequately support or reimburse its HOPWA program $31,157 from non-Federal funds for the inappropriate disbursements.

Reimburse its HOPWA program $14,017 from non-Federal funds for the inappropriate disbursements.

Provide adequate training to staff responsible for reviewing and approving the expenditures to ensure compliance with HUD’s and Louisville Metro’s requirements for the administration of the HOPWA program, including processing program disbursements and monitoring project sponsors’ cash management.

Implement adequate procedures for sufficiently monitoring its project sponsors’ cash management.

Open Recommendations by Oversight Area

Oversight Area

Status

Priority

Clark County, NV, Did Not Always Use Community Development Block Grant Funds in Accordance With HUD Requirements

HUD’s Oversight of Section 108 Loans Was Not Adequate To Ensure Compliance With Program Requirements

The Miami-Dade County Homeless Trust Did Not Always Properly Administer Its Continuum of Care Program

Mental Health Systems Inc., San Diego, CA, Did Not Allocate Payroll Costs in Accordance With Requirements

CPD Did Not Follow the Departmental Clearance Process When It Issued the July 25, 2013, Guidance for Duplication of Benefits Requirements

The City of Huntington Park, CA, Did Not Administer Its Community Development Block Grant Program in Accordance With Requirements

HUD’s Monitoring of State CDBG

The City of Atlanta, GA, Did Not Properly Administer the Neighborhood Stabilization Program Grants for Its Subrecipient in Accordance With Requirements

The City of Birmingham, AL, Did Not Ensure That Adequate Policies and Procedures Were Implemented for Its Internal Audits and Procurement Process

Louisville Metro, Louisville, KY, Did Not Always Administer Its HOPWA Program in Accordance With HUD’s and Its Own Requirements

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