Finding No. 2023-001 - Uniform Guidance Compliance Requirement Code: N-Special Tests and Provisions - Significant Deficiency
HUD HOME Investment Partnerships Program
Federal Assistance Listing Number #14.239
HOME Investment Partnership Program Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau:
Allen Freemont 3110013 2015 1
Passed-through State of Washington:
Cascadia Village - HUD 02-40420-008 2002 1
Addy Street - HUD 09-47104-001 2009 1
Passed-through Clark County:
Covington Commons - HUD 2011-HOME-11H01 2011 2
Addy Street - HUD 2008-HOME-08H15 2008 1
McCallister Village (Fruit Valley) 2010-HOME-0H0 2010 1
Passed-through City of Vancouver:
McCallister Village (Fruit Valley) 2010-HOME-601002 2010 1
Total instances 8
Criteria
During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)).
Condition
The owner did not ensure passing HQS inspections were performed during 2023.
Cause
Management did not have in place proper procedures and controls to ensure that HQS inspections were performed during the year ended December 31, 2023.
Effect or Potential Effect
Housing units may be out of compliance with HUD Quality Standards.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to tenant file testing there were 8 instances of the 8 files tested where the passing HQS inspections were not performed during the year ended December 31, 2023.
Repeat Finding: Yes - Finding 2022-001
Recommendation
Management should ensure that all units are inspected timely, that they meet the HUD Housing Quality Standards and that the responses to any findings are cleared timely.
Views of Responsible Officials
REACH did return to doing HQS Inspections in 2023. With staffing shortages, it is possible that not every unit was inspected in 2023. REACH continued to reestablish our annual unit inspection process post COVID in 2024. For the finding related to Addy St. This property is managed by a third party management company, REACH's Asset Management team will work with the management company to ensure all inspections are happening.
Finding No. 2023-002 - Uniform Guidance Compliance Requirement Code: E-Eligibility - Significant Deficiency
HUD HOME Investment Partnerships Program
Federal Assistance Listing Number #14.239
HOME Investment Partnership Program Entity Identifying Number Initial year Finding instances
Passed-through State of Washington:
Cascadia Village - HUD 02-40420-008 2002 1
Passed-through Clark County:
Covington Commons - HUD 2011-HOME-11H01 2011 1
McCallister Village (Fruit Valley) 2010-HOME-0H0 2010 1
Passed-through City of Vancouver:
McCallister Village (Fruit Valley) 2010-HOME-601002 2010 1
Total instances 4
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual.
Condition
In connection with our lease file review, we noted four instances of eight tenants tested where management did not provide support that they performed a 3rd party income verification in accordance with policy.
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual were not consistently followed.
Effect or Potential Effect
This could result in units being rented to ineligible tenants.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to our HOME units testing, four of the eight tenants tested did not have a 3rd party income verification performed in accordance with policy.
Repeat Finding: Yes - Finding 2022-002
Recommendation
Management should establish procedures and monitor compliance with those procedures to ensure that recertifications and correct income verification procedures are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual.
Views of Responsible Officials
For the properties in Washington, they have several sources of HOME funds based on the issuing jurisdiction State, County or City that adds a layer of complexity to the recertification process and due to staffing turnover, both at the properties and REACH main office some of the HOME third party income verifications were missed at recertification. Management has established policies and procedures for complying with the HOME program which includes a centralized tracker for HOME certifications.
Finding No. 2023-003 - Uniform Guidance Compliance Requirement Code: E-Eligibility - Significant Deficiency
HUD HOME Investment Partnerships Program
Federal Assistance Listing Number #14.239
HOME Investment Partnership Program Entity Identifying Number Initial year Finding instances
Passed-through Clark County:
Covington Commons - HUD 2011-HOME-11H01 2011 1
Criteria
Each owner must comply with the requirements set forth in 24 CFR Part 92 regulations as outlined in the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD which requires the property to maintain the contracted number of HOME units as well as the designated splits in bedroom size and High Home/Low Home unit ratios.
Condition
The owner did not make available to HOME tenants the contracted number and type of HOME units.
Cause
Management's policies with respect to maintaining the number and split of contracted HOME units were not consistently followed.
Effect or Potential Effect
The procedures for determining and maintaining the correct HOME units within the property were not applied. This could result in ineligible tenants occupying HOME designated units.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to our HOME units testing, one of the five properties tested did not meet the contracted HOME units size portfolio (there should be four 3-bedroom units (there are 5); and there should be three 4-bedroom units (there are 2)).
Repeat Finding: Yes - Finding 2022-003
Recommendation
Management should follow procedures in place to ensure consistent application and adherence to the requirements in accordance with the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD.
Views of Responsible Officials
A unit will be re-classified the next time there is a vacant unit of the corresponding size/type.
Finding No. 2023-004 - Uniform Guidance Compliance Requirement Code: N- Special Tests and Provisions - Significant Deficiency
HUD Low Income Housing Preservation and Resident Homeownership Act of 1990
Federal Assistance Listing Number #99.999
Low Income Housing Preserve & Resident Homeownership Act of 1990 Capital Grant Entity Identifying Number Initial year Finding instances
Beacon 126-35062 1996 2
Taylor 126-55017 1996 1
Total Instances 3
Criteria
In accordance with the Use Agreement, Housing Quality Standards require that the Owner shall maintain the property in good repair and condition.
Condition
The owner did not ensure passing HQS inspections were performed during 2023.
Cause
Management did not have in place proper procedures and controls to ensure that HQS inspections were performed during the year ended December 31, 2023.
Effect or Potential Effect
Housing units may be out of compliance with HUD Quality Standards.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to tenant file testing there were 3 instances of the 3 files tested where the passing HQS inspections were not performed during the year ended December 31, 2023.
Repeat Finding: No
Recommendation
Management should ensure that all units are inspected timely, that they meet the HUD Housing Quality Standards and that the responses to any findings are cleared timely.
Views of Responsible Officials
REACH did return to doing HQS Inspections in 2023, with staffing shortages it is possible that not every unit was inspected in 2023. Specifically, around the 3 instances of the 3 files tested after the finding were provided to REACH we provided the annual inspection for unit #11 at Beacon. For unit #5 at Beacon the annual inspection was not in the current resident file that was tested because the unit was vacant at the time of 2023 annual inspection. The annual inspection for the last file at Taylor this inspection was missed due to staffing changes at the time. REACH continued to reestablish our annual unit inspection process post COVID in 2024.
Finding No. 2023-005 - Uniform Guidance Compliance Requirement Code: N- Special Tests and Provisions - Significant Deficiency
CDBG Entitlement Grants Cluster
Federal Assistance Listing Number #14.218
Community Development Block Grants - Entitlement Grants Cluster Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau::
Allen Fremont 3110013 2015 2
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Clark County Community Services CDBG Procedures Manual and grant documents.
Condition
In connection with our lease file review, we noted two instances of seven tenants tested where management was unable to locate tenant files.
Cause
Management's policies with respect to eligibility and the maintenance of tenant lease files in accordance with Compliance in Clark County Community Services CDBG Procedures Manual and grant documents were not consistently followed.
Effect or Potential Effect
This could result in units being rented to ineligible tenants.
Questioned Costs: N/A.
Context
In connection with the procedures applied to our CDBG units testing, two of the seven tenants tested did have lease files available.
Repeat Finding: No
Recommendation
Management should establish procedures and monitor compliance with those procedures to ensure that correct income verification procedures are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of Clark County Community Services CDBG Procedures Manual and grant documents.
Views of Responsible Officials
The Compliance Specialist discovered missing files at a property while pulling files for the audit. The Compliance team worked to contact residents and rebuild the files with the missing documents. Compliance management investigated and determined the cause of the missing documents was due to a prior site manager not scanning and filing the appropriate documents, along with high staff turnover during this time. The Compliance team is finalizing a new procedure, in addition to the existing, to audit Yardi Voyager for uploaded completed files after move-in and recertification: the goal of this is to catch missing files and documents timely and hold site teams accountable for following the required procedures.
Finding No. 2023-006 - Uniform Guidance Compliance Requirement Code: A-Allowable Costs - Significant Deficiency
CDBG Entitlement Grants Cluster
Federal Assistance Listing Number #14.218
Community Development Block Grants - Entitlement Grants Cluster Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau::
Community Develoment Block Grants/Entitlement Grants 32002765 2022 1
Criteria
Owners must use CDBG funded portion of programs to fund minor rehabilitation services to approved recipients /address' in accordance with the Rehabilitation and Preservation Activities (570.202(b)(2) and/or (11)).
Condition
The owner paid 1 vendor invoice of 79 tested, that were not listed on the CDBG Address List as reported to Portland Housing Bureau ("PHB") and charged through to and was reimbursed by PHB under their CDBG Grant.
Cause
REACH's Community Builders Program Manager did not ensure that the invoices were for an approved CDBG property.
Effect or Potential Effect
CDBG funds may be spent inappropriately potentially resulting in REACH having to repay the grants or a possible loss of future grants.
Questioned Costs: $40.
Context
In connection with the procedures applied to compliance testing, there was 1 vendor invoice of 79 tested that was not for an approved CDBG property.
Repeat Finding: Yes - Finding 2022-007
Recommendation
REACH Community Builders Program Manager should follow procedures to match each vendor invoice to the approved CDBG property listing prior to coding to CDBG and passing through for reimbursement from this grant.
Views of Responsible Officials
This instance was $40 that was in fact allocated incorrectly and the $40 spent was paid back to PHB in October 2024.
Finding No. 2023-007 Uniform Guidance Compliance Requirement Code: A-Allowable Costs - Significant Deficiency
CDBG Entitlement Grants Cluster
Federal Assistance Listing Number #14.218
Community Development Block Grants - Entitlement Grants Cluster Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau::
Community Develoment Block Grants/Entitlement Grants 32003236 2023 1
Criteria
Owners must use CDBG funded portion of programs to fund minor rehabilitation services to approved recipients /address' in accordance with the Rehabilitation and Preservation Activities (570.202(b)(2) and/or (11)) during the grant period.
Condition
The owner paid 1 vendor invoice of 79 tested, that was not incurred during the grant period which was charged to and reimbursed by PHB under their CDBG Grant.
Cause
Management did not ensure that the invoices were for the appropriate grant period.
Effect or Potential Effect
CDBG funds may be spent inappropriately potentially resulting in REACH having to repay the grants or a possible loss of future grants.
Questioned Costs: $35.
Context
In connection with the procedures applied to compliance testing, there was 1 vendor invoice of 79 tested that was not for cost incurred during the grant period.
Repeat Finding: No
Recommendation
Management should follow procedures to ensure each vendor invoice is incurred during the grant period.
Views of Responsible Officials
Community Builders Program cell phone billing is part of the larger REACH billing system and this does create some challenges in approving billing as our IT department approves this billing. We are putting systems in place for the Community Builders Program Manager will work closer with the finance team to ensure all billing involves are for the correct time periods.
Finding No. 2023-001 - Uniform Guidance Compliance Requirement Code: N-Special Tests and Provisions - Significant Deficiency
HUD HOME Investment Partnerships Program
Federal Assistance Listing Number #14.239
HOME Investment Partnership Program Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau:
Allen Freemont 3110013 2015 1
Passed-through State of Washington:
Cascadia Village - HUD 02-40420-008 2002 1
Addy Street - HUD 09-47104-001 2009 1
Passed-through Clark County:
Covington Commons - HUD 2011-HOME-11H01 2011 2
Addy Street - HUD 2008-HOME-08H15 2008 1
McCallister Village (Fruit Valley) 2010-HOME-0H0 2010 1
Passed-through City of Vancouver:
McCallister Village (Fruit Valley) 2010-HOME-601002 2010 1
Total instances 8
Criteria
During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)).
Condition
The owner did not ensure passing HQS inspections were performed during 2023.
Cause
Management did not have in place proper procedures and controls to ensure that HQS inspections were performed during the year ended December 31, 2023.
Effect or Potential Effect
Housing units may be out of compliance with HUD Quality Standards.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to tenant file testing there were 8 instances of the 8 files tested where the passing HQS inspections were not performed during the year ended December 31, 2023.
Repeat Finding: Yes - Finding 2022-001
Recommendation
Management should ensure that all units are inspected timely, that they meet the HUD Housing Quality Standards and that the responses to any findings are cleared timely.
Views of Responsible Officials
REACH did return to doing HQS Inspections in 2023. With staffing shortages, it is possible that not every unit was inspected in 2023. REACH continued to reestablish our annual unit inspection process post COVID in 2024. For the finding related to Addy St. This property is managed by a third party management company, REACH's Asset Management team will work with the management company to ensure all inspections are happening.
Finding No. 2023-002 - Uniform Guidance Compliance Requirement Code: E-Eligibility - Significant Deficiency
HUD HOME Investment Partnerships Program
Federal Assistance Listing Number #14.239
HOME Investment Partnership Program Entity Identifying Number Initial year Finding instances
Passed-through State of Washington:
Cascadia Village - HUD 02-40420-008 2002 1
Passed-through Clark County:
Covington Commons - HUD 2011-HOME-11H01 2011 1
McCallister Village (Fruit Valley) 2010-HOME-0H0 2010 1
Passed-through City of Vancouver:
McCallister Village (Fruit Valley) 2010-HOME-601002 2010 1
Total instances 4
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual.
Condition
In connection with our lease file review, we noted four instances of eight tenants tested where management did not provide support that they performed a 3rd party income verification in accordance with policy.
Cause
Management's policies with respect to recertifications and eligibility and the maintenance of tenant lease files in accordance with Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual were not consistently followed.
Effect or Potential Effect
This could result in units being rented to ineligible tenants.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to our HOME units testing, four of the eight tenants tested did not have a 3rd party income verification performed in accordance with policy.
Repeat Finding: Yes - Finding 2022-002
Recommendation
Management should establish procedures and monitor compliance with those procedures to ensure that recertifications and correct income verification procedures are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of Compliance in State of Oregon Housing and Community Services HOME Program Compliance Manual.
Views of Responsible Officials
For the properties in Washington, they have several sources of HOME funds based on the issuing jurisdiction State, County or City that adds a layer of complexity to the recertification process and due to staffing turnover, both at the properties and REACH main office some of the HOME third party income verifications were missed at recertification. Management has established policies and procedures for complying with the HOME program which includes a centralized tracker for HOME certifications.
Finding No. 2023-003 - Uniform Guidance Compliance Requirement Code: E-Eligibility - Significant Deficiency
HUD HOME Investment Partnerships Program
Federal Assistance Listing Number #14.239
HOME Investment Partnership Program Entity Identifying Number Initial year Finding instances
Passed-through Clark County:
Covington Commons - HUD 2011-HOME-11H01 2011 1
Criteria
Each owner must comply with the requirements set forth in 24 CFR Part 92 regulations as outlined in the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD which requires the property to maintain the contracted number of HOME units as well as the designated splits in bedroom size and High Home/Low Home unit ratios.
Condition
The owner did not make available to HOME tenants the contracted number and type of HOME units.
Cause
Management's policies with respect to maintaining the number and split of contracted HOME units were not consistently followed.
Effect or Potential Effect
The procedures for determining and maintaining the correct HOME units within the property were not applied. This could result in ineligible tenants occupying HOME designated units.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to our HOME units testing, one of the five properties tested did not meet the contracted HOME units size portfolio (there should be four 3-bedroom units (there are 5); and there should be three 4-bedroom units (there are 2)).
Repeat Finding: Yes - Finding 2022-003
Recommendation
Management should follow procedures in place to ensure consistent application and adherence to the requirements in accordance with the "Compliance in HOME Rental Projects: A Guide for Property Owners" published by HUD.
Views of Responsible Officials
A unit will be re-classified the next time there is a vacant unit of the corresponding size/type.
Finding No. 2023-004 - Uniform Guidance Compliance Requirement Code: N- Special Tests and Provisions - Significant Deficiency
HUD Low Income Housing Preservation and Resident Homeownership Act of 1990
Federal Assistance Listing Number #99.999
Low Income Housing Preserve & Resident Homeownership Act of 1990 Capital Grant Entity Identifying Number Initial year Finding instances
Beacon 126-35062 1996 2
Taylor 126-55017 1996 1
Total Instances 3
Criteria
In accordance with the Use Agreement, Housing Quality Standards require that the Owner shall maintain the property in good repair and condition.
Condition
The owner did not ensure passing HQS inspections were performed during 2023.
Cause
Management did not have in place proper procedures and controls to ensure that HQS inspections were performed during the year ended December 31, 2023.
Effect or Potential Effect
Housing units may be out of compliance with HUD Quality Standards.
Questioned Costs: Not applicable.
Context
In connection with the procedures applied to tenant file testing there were 3 instances of the 3 files tested where the passing HQS inspections were not performed during the year ended December 31, 2023.
Repeat Finding: No
Recommendation
Management should ensure that all units are inspected timely, that they meet the HUD Housing Quality Standards and that the responses to any findings are cleared timely.
Views of Responsible Officials
REACH did return to doing HQS Inspections in 2023, with staffing shortages it is possible that not every unit was inspected in 2023. Specifically, around the 3 instances of the 3 files tested after the finding were provided to REACH we provided the annual inspection for unit #11 at Beacon. For unit #5 at Beacon the annual inspection was not in the current resident file that was tested because the unit was vacant at the time of 2023 annual inspection. The annual inspection for the last file at Taylor this inspection was missed due to staffing changes at the time. REACH continued to reestablish our annual unit inspection process post COVID in 2024.
Finding No. 2023-005 - Uniform Guidance Compliance Requirement Code: N- Special Tests and Provisions - Significant Deficiency
CDBG Entitlement Grants Cluster
Federal Assistance Listing Number #14.218
Community Development Block Grants - Entitlement Grants Cluster Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau::
Allen Fremont 3110013 2015 2
Criteria
Tenant lease files are required to be maintained and tenant eligibility determined in accordance with the Clark County Community Services CDBG Procedures Manual and grant documents.
Condition
In connection with our lease file review, we noted two instances of seven tenants tested where management was unable to locate tenant files.
Cause
Management's policies with respect to eligibility and the maintenance of tenant lease files in accordance with Compliance in Clark County Community Services CDBG Procedures Manual and grant documents were not consistently followed.
Effect or Potential Effect
This could result in units being rented to ineligible tenants.
Questioned Costs: N/A.
Context
In connection with the procedures applied to our CDBG units testing, two of the seven tenants tested did have lease files available.
Repeat Finding: No
Recommendation
Management should establish procedures and monitor compliance with those procedures to ensure that correct income verification procedures are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of Clark County Community Services CDBG Procedures Manual and grant documents.
Views of Responsible Officials
The Compliance Specialist discovered missing files at a property while pulling files for the audit. The Compliance team worked to contact residents and rebuild the files with the missing documents. Compliance management investigated and determined the cause of the missing documents was due to a prior site manager not scanning and filing the appropriate documents, along with high staff turnover during this time. The Compliance team is finalizing a new procedure, in addition to the existing, to audit Yardi Voyager for uploaded completed files after move-in and recertification: the goal of this is to catch missing files and documents timely and hold site teams accountable for following the required procedures.
Finding No. 2023-006 - Uniform Guidance Compliance Requirement Code: A-Allowable Costs - Significant Deficiency
CDBG Entitlement Grants Cluster
Federal Assistance Listing Number #14.218
Community Development Block Grants - Entitlement Grants Cluster Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau::
Community Develoment Block Grants/Entitlement Grants 32002765 2022 1
Criteria
Owners must use CDBG funded portion of programs to fund minor rehabilitation services to approved recipients /address' in accordance with the Rehabilitation and Preservation Activities (570.202(b)(2) and/or (11)).
Condition
The owner paid 1 vendor invoice of 79 tested, that were not listed on the CDBG Address List as reported to Portland Housing Bureau ("PHB") and charged through to and was reimbursed by PHB under their CDBG Grant.
Cause
REACH's Community Builders Program Manager did not ensure that the invoices were for an approved CDBG property.
Effect or Potential Effect
CDBG funds may be spent inappropriately potentially resulting in REACH having to repay the grants or a possible loss of future grants.
Questioned Costs: $40.
Context
In connection with the procedures applied to compliance testing, there was 1 vendor invoice of 79 tested that was not for an approved CDBG property.
Repeat Finding: Yes - Finding 2022-007
Recommendation
REACH Community Builders Program Manager should follow procedures to match each vendor invoice to the approved CDBG property listing prior to coding to CDBG and passing through for reimbursement from this grant.
Views of Responsible Officials
This instance was $40 that was in fact allocated incorrectly and the $40 spent was paid back to PHB in October 2024.
Finding No. 2023-007 Uniform Guidance Compliance Requirement Code: A-Allowable Costs - Significant Deficiency
CDBG Entitlement Grants Cluster
Federal Assistance Listing Number #14.218
Community Development Block Grants - Entitlement Grants Cluster Entity Identifying Number Initial year Finding instances
Passed-through City of Portland, Portland Housing Bureau::
Community Develoment Block Grants/Entitlement Grants 32003236 2023 1
Criteria
Owners must use CDBG funded portion of programs to fund minor rehabilitation services to approved recipients /address' in accordance with the Rehabilitation and Preservation Activities (570.202(b)(2) and/or (11)) during the grant period.
Condition
The owner paid 1 vendor invoice of 79 tested, that was not incurred during the grant period which was charged to and reimbursed by PHB under their CDBG Grant.
Cause
Management did not ensure that the invoices were for the appropriate grant period.
Effect or Potential Effect
CDBG funds may be spent inappropriately potentially resulting in REACH having to repay the grants or a possible loss of future grants.
Questioned Costs: $35.
Context
In connection with the procedures applied to compliance testing, there was 1 vendor invoice of 79 tested that was not for cost incurred during the grant period.
Repeat Finding: No
Recommendation
Management should follow procedures to ensure each vendor invoice is incurred during the grant period.
Views of Responsible Officials
Community Builders Program cell phone billing is part of the larger REACH billing system and this does create some challenges in approving billing as our IT department approves this billing. We are putting systems in place for the Community Builders Program Manager will work closer with the finance team to ensure all billing involves are for the correct time periods.