Audit 305597

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-007 – Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City could not provide evidence that the stormwater project totaling $1,783,033 for the year ended December 31, 2022 followed formal procurement procedures. The stormwater contract exceeds the Uniform Guidance formal procurement methods. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-007 – Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City could not provide evidence that the stormwater project totaling $1,783,033 for the year ended December 31, 2022 followed formal procurement procedures. The stormwater contract exceeds the Uniform Guidance formal procurement methods. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-007 – Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City could not provide evidence that the stormwater project totaling $1,783,033 for the year ended December 31, 2022 followed formal procurement procedures. The stormwater contract exceeds the Uniform Guidance formal procurement methods. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. View of Responsible Official: The City agrees. See the corrective action plan.

Finding 2022-007 – Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City could not provide evidence that the stormwater project totaling $1,783,033 for the year ended December 31, 2022 followed formal procurement procedures. The stormwater contract exceeds the Uniform Guidance formal procurement methods. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. View of Responsible Official: The City agrees. See the corrective action plan.