Management’s Response/Corrective Action Plan: The City of Bangor’s Community Development Block Grant program receives direct oversight by the Community Development Officer, responsible for ensuring compliance with Federal regulations, including the determination of eligibility, allowability, and all...
Management’s Response/Corrective Action Plan: The City of Bangor’s Community Development Block Grant program receives direct oversight by the Community Development Officer, responsible for ensuring compliance with Federal regulations, including the determination of eligibility, allowability, and allocability of all financial expenditures. Previously, the City’s practice concerning CDBG funds provided to other departments allowed those project managers to directly charge the CDBG account through payroll, requisition or direct charges which are not first reviewed and approved by the Community Development Officer. The Community Development Officer has implemented the following procedural changes: 1. Executing Interdepartmental Subrecipient Agreements. This document establishes certain standards and expectations for CDBG-funded programs. In 2025-26, Agreements will create new procedural safeguards including submitting requisitions for all expenditures not contained in the approved budget, and to submit receipts or invoices to the Community Development office directly to back up all approved expenses. 2. The Community Development Officer must review and sign off on all expenses charged to the CDBG account by Community and Economic Development Staff, including “OK To Pay” charges, and requisitions. The Community Development Officer recommends the following changes: 1. The issuance of a separate credit card to be used exclusively for CDBG expenditures. The reconciliation process is very tedious and involves sifting through unrelated expenses, and some expenses which are allocated to CDBG which have not been initiated by the Community Development Division and were deemed ineligible by the Community Development Officer. This creates some challenges finding another account to charge to, often a month or more after the expense occurred. The CDBG program does a monthly drawdown for administrative costs, which requires the CDO to make adjustments for expenses that are discovered during the reconciliation process. 2. Eliminating the practice of providing CDBG account numbers to individual departments to directly charge expenses. This leaves the program particularly vulnerable, as when a department charged nearly $435,000 to the CDBG account, requiring reversal of charges that were not eligible. The CDO believes that this change should be initiated by the Finance department with cooperation by the CED. 3. Establishing a review process for personnel expense outside of Salary and Fringe Benefit. Many charges in SunGard related to 701 charges are not viewable as they are deemed privileged expenses. However, some charges for personnel expenses have required review and reversal, and in one case a charge for “travel” was discovered for a program that does not involve this activity. The Finance Department might consider a change to include review if necessary.