Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements:
Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting.
(a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead.
(b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports.
(c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.
(d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient.
Section § 200.303 Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
(b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context:
For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline:
Report Type Award Number Period Date Due Date Submitted
SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024
SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024
Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline.
Cause:
During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report.
Effect:
Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements:
Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting.
(a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead.
(b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports.
(c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.
(d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient.
Section § 200.303 Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
(b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context:
For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline:
Report Type Award Number Period Date Due Date Submitted
SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024
SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024
Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline.
Cause:
During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report.
Effect:
Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements:
Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting.
(a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead.
(b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports.
(c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.
(d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient.
Section § 200.303 Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
(b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context:
For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline:
Report Type Award Number Period Date Due Date Submitted
SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024
SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024
Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline.
Cause:
During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report.
Effect:
Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements:
Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting.
(a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead.
(b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports.
(c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.
(d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient.
Section § 200.303 Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
(b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context:
For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline:
Report Type Award Number Period Date Due Date Submitted
SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024
SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024
Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline.
Cause:
During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report.
Effect:
Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared.
Condition and Context:
The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements.
The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample.
The Planning Department experienced turnover and vacancies in key positions responsible for performing the environmental reviews and determination of exception as required by the grant for the fiscal year 2024. The required HUD document ‘Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5’ was not completed until March 2025 for all CDBG Projects with expenditures during the grant year. The document and related supporting documentation were not retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program.
Effect:
The City was not in compliance with 24 CFR §58.1, 58.22, 58.34, 58.35, and 570.604.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
The City should dedicate time and resources to the Planning Department to ensure that key compliance documents are prepared and maintained as required by the program.
Management’s View and Corrective Action Plan:
The City concurs with the auditors’ finding. The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project.
Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared.
Condition and Context:
The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements.
The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample.
The Planning Department experienced turnover and vacancies in key positions responsible for performing the environmental reviews and determination of exception as required by the grant for the fiscal year 2024. The required HUD document ‘Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5’ was not completed until March 2025 for all CDBG Projects with expenditures during the grant year. The document and related supporting documentation were not retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program.
Effect:
The City was not in compliance with 24 CFR §58.1, 58.22, 58.34, 58.35, and 570.604.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
The City should dedicate time and resources to the Planning Department to ensure that key compliance documents are prepared and maintained as required by the program.
Management’s View and Corrective Action Plan:
The City concurs with the auditors’ finding. The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project.
Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared.
Condition and Context:
The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements.
The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample.
The Planning Department experienced turnover and vacancies in key positions responsible for performing the environmental reviews and determination of exception as required by the grant for the fiscal year 2024. The required HUD document ‘Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5’ was not completed until March 2025 for all CDBG Projects with expenditures during the grant year. The document and related supporting documentation were not retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program.
Effect:
The City was not in compliance with 24 CFR §58.1, 58.22, 58.34, 58.35, and 570.604.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
The City should dedicate time and resources to the Planning Department to ensure that key compliance documents are prepared and maintained as required by the program.
Management’s View and Corrective Action Plan:
The City concurs with the auditors’ finding. The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project.
Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared.
Condition and Context:
The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements.
The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample.
The Planning Department experienced turnover and vacancies in key positions responsible for performing the environmental reviews and determination of exception as required by the grant for the fiscal year 2024. The required HUD document ‘Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5’ was not completed until March 2025 for all CDBG Projects with expenditures during the grant year. The document and related supporting documentation were not retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program.
Effect:
The City was not in compliance with 24 CFR §58.1, 58.22, 58.34, 58.35, and 570.604.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
The City should dedicate time and resources to the Planning Department to ensure that key compliance documents are prepared and maintained as required by the program.
Management’s View and Corrective Action Plan:
The City concurs with the auditors’ finding. The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements:
Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting.
(a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead.
(b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports.
(c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.
(d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient.
Section § 200.303 Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
(b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context:
For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline:
Report Type Award Number Period Date Due Date Submitted
SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024
SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024
Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline.
Cause:
During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report.
Effect:
Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements:
Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting.
(a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead.
(b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports.
(c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.
(d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient.
Section § 200.303 Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
(b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context:
For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline:
Report Type Award Number Period Date Due Date Submitted
SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024
SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024
Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline.
Cause:
During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report.
Effect:
Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements:
Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting.
(a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead.
(b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports.
(c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.
(d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient.
Section § 200.303 Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
(b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context:
For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline:
Report Type Award Number Period Date Due Date Submitted
SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024
SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024
Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline.
Cause:
During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report.
Effect:
Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements:
Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting.
(a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead.
(b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports.
(c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.
(d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient.
Section § 200.303 Internal Controls
The recipient and subrecipient must:
(a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
(b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context:
For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline:
Report Type Award Number Period Date Due Date Submitted
SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024
SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024
Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline.
Cause:
During the audit period, the City did not possess the operational processes/procedures necessary to guarantee timely submission of the SF-425 report.
Effect:
Failure to submit the SF-425 reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City agrees with this finding. The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports.
Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared.
Condition and Context:
The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements.
The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample.
The Planning Department experienced turnover and vacancies in key positions responsible for performing the environmental reviews and determination of exception as required by the grant for the fiscal year 2024. The required HUD document ‘Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5’ was not completed until March 2025 for all CDBG Projects with expenditures during the grant year. The document and related supporting documentation were not retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program.
Effect:
The City was not in compliance with 24 CFR §58.1, 58.22, 58.34, 58.35, and 570.604.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
The City should dedicate time and resources to the Planning Department to ensure that key compliance documents are prepared and maintained as required by the program.
Management’s View and Corrective Action Plan:
The City concurs with the auditors’ finding. The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project.
Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared.
Condition and Context:
The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements.
The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample.
The Planning Department experienced turnover and vacancies in key positions responsible for performing the environmental reviews and determination of exception as required by the grant for the fiscal year 2024. The required HUD document ‘Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5’ was not completed until March 2025 for all CDBG Projects with expenditures during the grant year. The document and related supporting documentation were not retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program.
Effect:
The City was not in compliance with 24 CFR §58.1, 58.22, 58.34, 58.35, and 570.604.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
The City should dedicate time and resources to the Planning Department to ensure that key compliance documents are prepared and maintained as required by the program.
Management’s View and Corrective Action Plan:
The City concurs with the auditors’ finding. The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project.
Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared.
Condition and Context:
The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements.
The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample.
The Planning Department experienced turnover and vacancies in key positions responsible for performing the environmental reviews and determination of exception as required by the grant for the fiscal year 2024. The required HUD document ‘Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5’ was not completed until March 2025 for all CDBG Projects with expenditures during the grant year. The document and related supporting documentation were not retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program.
Effect:
The City was not in compliance with 24 CFR §58.1, 58.22, 58.34, 58.35, and 570.604.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
The City should dedicate time and resources to the Planning Department to ensure that key compliance documents are prepared and maintained as required by the program.
Management’s View and Corrective Action Plan:
The City concurs with the auditors’ finding. The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project.
Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 14.218
Federal Program Name: CDBG‐Entitlement Grants Cluster
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: N/A
Federal Award Number and Award Year: B-20-MW-06-0053 – FY20-21
B-21-MC-06-0053 – FY21-22
B-22-MC-06-0053 – FY22-23
B-23-MC-06-0053 – FY23-24
Criteria:
Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared.
Condition and Context:
The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements.
The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample.
The Planning Department experienced turnover and vacancies in key positions responsible for performing the environmental reviews and determination of exception as required by the grant for the fiscal year 2024. The required HUD document ‘Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5’ was not completed until March 2025 for all CDBG Projects with expenditures during the grant year. The document and related supporting documentation were not retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program.
Effect:
The City was not in compliance with 24 CFR §58.1, 58.22, 58.34, 58.35, and 570.604.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
No.
Recommendation:
The City should dedicate time and resources to the Planning Department to ensure that key compliance documents are prepared and maintained as required by the program.
Management’s View and Corrective Action Plan:
The City concurs with the auditors’ finding. The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project.