Management’s Response/Corrective Action Plan: The Administrative conditions related to this issue include a delay in entitlement award which caused the City to not complete any IDIS Drawdowns until December 2024. However, during that time, program income was received, and the CDO understands that th...
Management’s Response/Corrective Action Plan: The Administrative conditions related to this issue include a delay in entitlement award which caused the City to not complete any IDIS Drawdowns until December 2024. However, during that time, program income was received, and the CDO understands that the report should have been filed to reflect COH at the deadline. The Community Development Officer consulted with staff from the Auditing firm in July 2023 to inquire about the relevance of FFATA and was told that these reports were not required because the City did not award CDBG funds to Subrecipients. However, several key awards made prior to 2022 were made pursuant to an executed Subrecipient Agreement and would be subject to this requirement. The CDO received clarification on this issue in the Fall of 2024 from HUD during a regional training of all CDBG entitlement communities. It is further understood that all CDBG funds, excluding that provided to income eligible beneficiaries is a Subrecipient for the purpose of FFATA. Pursuant to these findings, the Community Development Officer began revising the CDBG Policies and Procedures to implement these reporting obligations, including: 1. Monthly reports submitted on the FFATA website for any award made to an entity not expressly deemed an eligible beneficiary. This includes nonprofit and for-profit entities completing an approved activity which provides a benefit to low- and moderate-income residents of Bangor. This does not include payments made to or on behalf of LMI individuals in the Homeowner Rehab or Down Payment Assistance programs, but may include all other grants or loans made over $30,000. This will be accomplished by additional training on the use of the online portal and the integration of City software into the project award and reporting process. 2. The CDO continues to review the Cash On Hand reporting process to implement changes which will prevent further delays in reporting. The CDO recently implemented a quarterly desk audit of all CDBG Financials and continues to improve Department efficiency in this area. In addition, staff will be cross-trained to complete this procedure to ensure that personnel changes do not impact the report filing. This will be accomplished by requiring that the Cash on Hand report be entered monthly and updated until the report is submitted at the end of the Quarter.