Audit 406687

Federal Program Name: HOME Investment Partnerships Program Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing Number: 14.239 Criteria Per 2 CFR 200.332, pass-through entities are required to evaluate each subrecipient’s risk of noncompliance to determine the appropriate level and type of monitoring, monitor the activities of the subrecipient to ensure compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and ensure subrecipients meet applicable program requirements, including financial and performance reporting and taking corrective action when issues are identified. Condition The City of Lafayette did not have formal, documented subrecipient monitoring policies in place during 2025, resulting in a lack of a consistent and structured monitoring framework. While the City performed several compensating controls (e.g., desk reviews, pre-disbursement reviews, and training), these activities were not formally defined or applied uniformly to ensure full compliance with Uniform Guidance. Cause The City has an agreement with Lafayette Housing Authority to administer and monitor the HOME program. Due to staff transitions during the year, the Authority relied on informal oversight procedures rather than implementing a structured monitoring plan, including risk-based assessments and documented monitoring activities. Effect The lack of formal subrecipient monitoring increases the risk that noncompliance with HOME program requirements may not be identified or corrected in a timely manner. Recommendation We recommend the Authority implement formal subrecipient monitoring procedures for the HOME program, including: • Performing and documenting annual risk assessments to determine the appropriate level of monitoring; • Conducting and documenting monitoring procedures (e.g., desk reviews and/or on-site reviews); and • Maintaining evidence of supervisory review and follow-up on any identified issues. Views of Responsible Officials and Planned Corrective Actions: For the views of responsible officials, refer to the Corrective Action Plan

Federal Program Name: HOME Investment Partnerships Program Federal Agency: U.S. Department of Housing and Urban Development Assistance Listing Number: 14.239 Criteria Per 24 CFR § 92.209(i), § 92.251(f) & § 92.504(d), participating jurisdictions are required to ensure that HOME-assisted rental units meet Housing Quality Standards (HQS) and to perform ongoing inspections during the period of affordability to confirm continued compliance. Condition The City has established procedures to ensure initial compliance with HQS, including reliance on certificates of occupancy for newly constructed and rehabilitated properties and inspections performed by the Lafayette Housing Authority for tenant-based rental assistance prior to lease-up. However, the City has fallen behind in conducting required ongoing inspections of HOME-assisted properties after occupancy and does not currently have a fully implemented inspection schedule covering the affordability period. Cause The delay in completing ongoing inspections appears to be due to the absence of a formalized and consistently implemented inspection schedule to track and monitor properties throughout the affordability period. Effect Without timely ongoing inspections, the City cannot ensure that HOME-assisted units continue to meet HQS requirements. This increases the risk that assisted properties may fall out of compliance with federal standards, potentially impacting the health and safety of occupants and resulting in noncompliance with HOME program regulations. Recommendation We recommend that the City finalize and implement a comprehensive inspection schedule to ensure all HOME-assisted properties are inspected at required intervals throughout the affordability period. Additionally, the City should establish monitoring controls (e.g., tracking logs or software) to ensure inspections are performed timely and documented appropriately to demonstrate compliance with HQS requirements. Views of Responsible Officials and Planned Corrective Actions: For the views of responsible officials, refer to the Corrective Action Plan