2024-001: Internal Controls over Compliance for Procurement Suspension & Debarment
U.S. DEPARTMENT OF TREASURY
COVID-19 Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027
Criteria: Per 2 CFR sections 200.318 through 200.327, [entities] must use their own documented
procurement procedures, which reflect applicable state and local laws and regulations, provided
that the procurements conform to applicable federal statutes and the procurement requirements
identified in 2 CFR Part 200. Further, when a non-federal entity enters into a covered transaction
with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2
CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise
excluded from participating in the transaction.
Condition: The City did not follow its Grant Standard Operating procedures for validating that a
contractor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Cause: The contract agreement was finalized without validation that all proper procurement
procedures had been followed.
Effect: By not following the City’s procedures in place, it puts the City at risk of doing business
with companies who are suspended, debarred or otherwise excluded from doing business with
the federal government.
Questioned Costs: $0
Context: The auditor tested one procurement transaction entered into during 2024 using COVID-
19 Coronavirus State and Local Fiscal Recovery Funds. The City’s Grant Standard Operating
procedures over suspension and debarment were not followed for this one procurement.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the City perform a separate individual check of contract files
to ensure the City’s Grant Standard Operating procedures are followed and documented prior to
entering into a contract agreement with covered contractors.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-002: Internal Controls over Compliance for Reporting
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Reports submitted within the Integrated Disbursement and Information System (IDIS),
including the PR26 CDBG Financial Summary Report and the PR29 CDBG Cash on Hand
Quarterly Report, should be accurate, be supported by adequate documentation, and be submitted
timely.
Condition: Adequate internal controls to ensure the accuracy of reporting were not in place over
the PR26 CDBG Financial Summary Report and the PR29 CDBG Cash on Hand Quarterly
Report. Errors were noted in the PR29 CDBG Cash on Hand Quarterly Report for the last two
quarters of 2024 due to recording program income activity within the grant funds.
Cause: Turnover within the HRA during 2024 attributed to this condition.
Effect: There is a risk that data submitted is inaccurate. For the HRA's PR29 CDBG Cash on
Hand Quarterly Report, program income received and disbursed during 2024 was understated
and grant funds activity was overstated by the same amount.
Questioned Costs: $0
Context: These IDIS system-generated reports are based on the HRA’s data inputs into the IDIS
system throughout the year. There are currently no additional procedures in place to validate the
accuracy of this data within these reports and to make corrections if errors are noted.
Additionally, we noted there are system limitations in IDIS, causing certain system-generated
errors which the HRA cannot fix.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA have a separate individual with appropriate
knowledge and experience review and approve the IDIS reports, including a review of
reconciliations from these reports to supporting financial data. Additionally, we recommend
HRA staff work with the Department of Housing and Urban Development to resolve the systemgenerated
errors in these reports.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-003: Internal Controls over Compliance for Special Tests and Provisions
(Environmental Reviews)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Environmental reviews should be performed on CDBG projects as required by 24 CFR
section 58.
Condition: Environmental reviews were incomplete or missing from a sample of projects tested
for compliance.
Cause: Turnover within the HRA during 2024 attributed to this condition. Existing procedures
in place to help ensure program compliance were not consistently followed by staff.
Effect: Without proper environmental reviews, there is a risk of potential negative environmental
impacts resulting from a project funded by CDBG funds or noncompliance with the National
Environmental Policy Act or other applicable federal, state, and local laws and regulations.
Questioned Costs: $0
Context: A sample of four out of 40 projects with activity during 2024 found two of the four
projects tested lacked supporting documentation to prove that environmental reviews were
completed.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA continue to strengthen its controls over compliance
within the CDBG program, including having the HRA Administrator or HRA Assistant
Administrator verify program checklists are completed with proper supporting documentation for
all programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-004: Internal Controls over Compliance for Eligibility
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Section 8 Housing Choice Vouchers – ALN 14.871
Criteria: Adequate internal controls should exist to ensure an entity meets program compliance
requirements over program eligibility. The HRA’s internal controls over eligibility include staff
completing tenant checklists for eligibility determinations with a separate program specialist
responsible for reviewing and signing off on the checklists.
Condition: The HRA did not complete or maintain tenant file checklists as required by its
internal controls when performing tenant eligibility procedures during 2024.
Cause: Turnover within the HRA during 2024 attributed to this condition. Existing procedures
in place to help ensure program compliance were not consistently followed by staff.
Effect: There is a risk that errors in tenant eligibility could have occurred during 2024 due to not
following the existing procedures in place.
Questioned Costs: $0
Context: Our sample of tenant files supporting 25 housing choice vouchers issued from a
population of approximately 9,800 individual housing choice vouchers noted that no tenant file
checklists were maintained in the files for activity occurring during 2024. However, no instances
of noncompliance with eligibility were noted.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA create monitoring controls to ensure its policies
relating to tenant eligibility are being followed.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-002: Internal Controls over Compliance for Reporting
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Reports submitted within the Integrated Disbursement and Information System (IDIS),
including the PR26 CDBG Financial Summary Report and the PR29 CDBG Cash on Hand
Quarterly Report, should be accurate, be supported by adequate documentation, and be submitted
timely.
Condition: Adequate internal controls to ensure the accuracy of reporting were not in place over
the PR26 CDBG Financial Summary Report and the PR29 CDBG Cash on Hand Quarterly
Report. Errors were noted in the PR29 CDBG Cash on Hand Quarterly Report for the last two
quarters of 2024 due to recording program income activity within the grant funds.
Cause: Turnover within the HRA during 2024 attributed to this condition.
Effect: There is a risk that data submitted is inaccurate. For the HRA's PR29 CDBG Cash on
Hand Quarterly Report, program income received and disbursed during 2024 was understated
and grant funds activity was overstated by the same amount.
Questioned Costs: $0
Context: These IDIS system-generated reports are based on the HRA’s data inputs into the IDIS
system throughout the year. There are currently no additional procedures in place to validate the
accuracy of this data within these reports and to make corrections if errors are noted.
Additionally, we noted there are system limitations in IDIS, causing certain system-generated
errors which the HRA cannot fix.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA have a separate individual with appropriate
knowledge and experience review and approve the IDIS reports, including a review of
reconciliations from these reports to supporting financial data. Additionally, we recommend
HRA staff work with the Department of Housing and Urban Development to resolve the systemgenerated
errors in these reports.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-003: Internal Controls over Compliance for Special Tests and Provisions
(Environmental Reviews)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Environmental reviews should be performed on CDBG projects as required by 24 CFR
section 58.
Condition: Environmental reviews were incomplete or missing from a sample of projects tested
for compliance.
Cause: Turnover within the HRA during 2024 attributed to this condition. Existing procedures
in place to help ensure program compliance were not consistently followed by staff.
Effect: Without proper environmental reviews, there is a risk of potential negative environmental
impacts resulting from a project funded by CDBG funds or noncompliance with the National
Environmental Policy Act or other applicable federal, state, and local laws and regulations.
Questioned Costs: $0
Context: A sample of four out of 40 projects with activity during 2024 found two of the four
projects tested lacked supporting documentation to prove that environmental reviews were
completed.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA continue to strengthen its controls over compliance
within the CDBG program, including having the HRA Administrator or HRA Assistant
Administrator verify program checklists are completed with proper supporting documentation for
all programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-001: Internal Controls over Compliance for Procurement Suspension & Debarment
U.S. DEPARTMENT OF TREASURY
COVID-19 Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027
Criteria: Per 2 CFR sections 200.318 through 200.327, [entities] must use their own documented
procurement procedures, which reflect applicable state and local laws and regulations, provided
that the procurements conform to applicable federal statutes and the procurement requirements
identified in 2 CFR Part 200. Further, when a non-federal entity enters into a covered transaction
with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2
CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise
excluded from participating in the transaction.
Condition: The City did not follow its Grant Standard Operating procedures for validating that a
contractor was not suspended or debarred or otherwise excluded from participating in the
transaction.
Cause: The contract agreement was finalized without validation that all proper procurement
procedures had been followed.
Effect: By not following the City’s procedures in place, it puts the City at risk of doing business
with companies who are suspended, debarred or otherwise excluded from doing business with
the federal government.
Questioned Costs: $0
Context: The auditor tested one procurement transaction entered into during 2024 using COVID-
19 Coronavirus State and Local Fiscal Recovery Funds. The City’s Grant Standard Operating
procedures over suspension and debarment were not followed for this one procurement.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the City perform a separate individual check of contract files
to ensure the City’s Grant Standard Operating procedures are followed and documented prior to
entering into a contract agreement with covered contractors.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-002: Internal Controls over Compliance for Reporting
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Reports submitted within the Integrated Disbursement and Information System (IDIS),
including the PR26 CDBG Financial Summary Report and the PR29 CDBG Cash on Hand
Quarterly Report, should be accurate, be supported by adequate documentation, and be submitted
timely.
Condition: Adequate internal controls to ensure the accuracy of reporting were not in place over
the PR26 CDBG Financial Summary Report and the PR29 CDBG Cash on Hand Quarterly
Report. Errors were noted in the PR29 CDBG Cash on Hand Quarterly Report for the last two
quarters of 2024 due to recording program income activity within the grant funds.
Cause: Turnover within the HRA during 2024 attributed to this condition.
Effect: There is a risk that data submitted is inaccurate. For the HRA's PR29 CDBG Cash on
Hand Quarterly Report, program income received and disbursed during 2024 was understated
and grant funds activity was overstated by the same amount.
Questioned Costs: $0
Context: These IDIS system-generated reports are based on the HRA’s data inputs into the IDIS
system throughout the year. There are currently no additional procedures in place to validate the
accuracy of this data within these reports and to make corrections if errors are noted.
Additionally, we noted there are system limitations in IDIS, causing certain system-generated
errors which the HRA cannot fix.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA have a separate individual with appropriate
knowledge and experience review and approve the IDIS reports, including a review of
reconciliations from these reports to supporting financial data. Additionally, we recommend
HRA staff work with the Department of Housing and Urban Development to resolve the systemgenerated
errors in these reports.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-003: Internal Controls over Compliance for Special Tests and Provisions
(Environmental Reviews)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Environmental reviews should be performed on CDBG projects as required by 24 CFR
section 58.
Condition: Environmental reviews were incomplete or missing from a sample of projects tested
for compliance.
Cause: Turnover within the HRA during 2024 attributed to this condition. Existing procedures
in place to help ensure program compliance were not consistently followed by staff.
Effect: Without proper environmental reviews, there is a risk of potential negative environmental
impacts resulting from a project funded by CDBG funds or noncompliance with the National
Environmental Policy Act or other applicable federal, state, and local laws and regulations.
Questioned Costs: $0
Context: A sample of four out of 40 projects with activity during 2024 found two of the four
projects tested lacked supporting documentation to prove that environmental reviews were
completed.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA continue to strengthen its controls over compliance
within the CDBG program, including having the HRA Administrator or HRA Assistant
Administrator verify program checklists are completed with proper supporting documentation for
all programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-004: Internal Controls over Compliance for Eligibility
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Section 8 Housing Choice Vouchers – ALN 14.871
Criteria: Adequate internal controls should exist to ensure an entity meets program compliance
requirements over program eligibility. The HRA’s internal controls over eligibility include staff
completing tenant checklists for eligibility determinations with a separate program specialist
responsible for reviewing and signing off on the checklists.
Condition: The HRA did not complete or maintain tenant file checklists as required by its
internal controls when performing tenant eligibility procedures during 2024.
Cause: Turnover within the HRA during 2024 attributed to this condition. Existing procedures
in place to help ensure program compliance were not consistently followed by staff.
Effect: There is a risk that errors in tenant eligibility could have occurred during 2024 due to not
following the existing procedures in place.
Questioned Costs: $0
Context: Our sample of tenant files supporting 25 housing choice vouchers issued from a
population of approximately 9,800 individual housing choice vouchers noted that no tenant file
checklists were maintained in the files for activity occurring during 2024. However, no instances
of noncompliance with eligibility were noted.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA create monitoring controls to ensure its policies
relating to tenant eligibility are being followed.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-002: Internal Controls over Compliance for Reporting
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Reports submitted within the Integrated Disbursement and Information System (IDIS),
including the PR26 CDBG Financial Summary Report and the PR29 CDBG Cash on Hand
Quarterly Report, should be accurate, be supported by adequate documentation, and be submitted
timely.
Condition: Adequate internal controls to ensure the accuracy of reporting were not in place over
the PR26 CDBG Financial Summary Report and the PR29 CDBG Cash on Hand Quarterly
Report. Errors were noted in the PR29 CDBG Cash on Hand Quarterly Report for the last two
quarters of 2024 due to recording program income activity within the grant funds.
Cause: Turnover within the HRA during 2024 attributed to this condition.
Effect: There is a risk that data submitted is inaccurate. For the HRA's PR29 CDBG Cash on
Hand Quarterly Report, program income received and disbursed during 2024 was understated
and grant funds activity was overstated by the same amount.
Questioned Costs: $0
Context: These IDIS system-generated reports are based on the HRA’s data inputs into the IDIS
system throughout the year. There are currently no additional procedures in place to validate the
accuracy of this data within these reports and to make corrections if errors are noted.
Additionally, we noted there are system limitations in IDIS, causing certain system-generated
errors which the HRA cannot fix.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA have a separate individual with appropriate
knowledge and experience review and approve the IDIS reports, including a review of
reconciliations from these reports to supporting financial data. Additionally, we recommend
HRA staff work with the Department of Housing and Urban Development to resolve the systemgenerated
errors in these reports.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.
2024-003: Internal Controls over Compliance for Special Tests and Provisions
(Environmental Reviews)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Environmental reviews should be performed on CDBG projects as required by 24 CFR
section 58.
Condition: Environmental reviews were incomplete or missing from a sample of projects tested
for compliance.
Cause: Turnover within the HRA during 2024 attributed to this condition. Existing procedures
in place to help ensure program compliance were not consistently followed by staff.
Effect: Without proper environmental reviews, there is a risk of potential negative environmental
impacts resulting from a project funded by CDBG funds or noncompliance with the National
Environmental Policy Act or other applicable federal, state, and local laws and regulations.
Questioned Costs: $0
Context: A sample of four out of 40 projects with activity during 2024 found two of the four
projects tested lacked supporting documentation to prove that environmental reviews were
completed.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA continue to strengthen its controls over compliance
within the CDBG program, including having the HRA Administrator or HRA Assistant
Administrator verify program checklists are completed with proper supporting documentation for
all programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.