Re: Home Investment Partnerships Program (HOME), Federal Assistance Listing #14.239 County Department Department of Planning and Development (DPD) Finding 2025 001 Cause: Post Pandemic allocations to the County included several housing related fundings and initiatives, including Emergency Rental Ass...
Re: Home Investment Partnerships Program (HOME), Federal Assistance Listing #14.239 County Department Department of Planning and Development (DPD) Finding 2025 001 Cause: Post Pandemic allocations to the County included several housing related fundings and initiatives, including Emergency Rental Assistance I & II (ERA I& II), Homeless Sheltering, Homeless and Transitional Sheltering Physical Site Acquisition and Development, HOME ARPA (HUD Allocation), and HOME, CDBG CV development delays that challenged the Housing teams provision of services and compliance requirement. While HUD had extended post-pandemic compliance moratoriums into fiscal year 2024, Housing team hiring, training and implementation of compliance activities were unable to activate fully in the subject fiscal year to meet compliance. Team initial compliance training was implemented in FY 2025. DPD hired three additional staffers for a total of five to support compliance investigations moving forward. Corrective Action Plan: Special Test on Housing Quality Standards 1. Compliance training activities will continue to be coordinated by the Bureau's Compliance Management Team to strengthen program oversight and compliance efforts. As part of this initiative, 100% of Housing Team staff and management will receive compliance training, be qualified to perform compliance-related functions, and be assigned appropriate compliance responsibilities. a. All Housing Team staff and management will complete compliance training through HUD-sponsored virtual training or HUD-approved in-person training by November 30, 2026. b. Five of eight staffers will have hands-on site qualifications demonstrated by task and verified by management by November 30, 2026. 2. Required compliance planning for HOME programs will be completed by September 30, 2026. a. Plan will be reviewed and approved by Deputy Director and submitted to the Director by September 30, 2026. b. Initial site inspection appointments will be completed by October 31, 2026 c. Initial site physical inspections will commence by November 30, 2026. 3. Deputy Director will ensure that compliance site investigations and on-site file review will be completed by May 31, 2027. a. All reporting for respective site investigations shall be filed by above date b. All required communication to developer/owner teams shall be completed, mail and confirmation receipt by above date. Subrecipient Monitoring The department classified costs as subrecipient expenditures but should have classified as developer costs. Developer costs are not subject to subrecipient monitoring requirements under the Uniform Guidance. Therefore, the corrective action will be to assign a unique account code to address the finding where subrecipient monitoring will no longer apply. Grants Finance Manager will work with the Bureau of Finance to assign a unique account code by July 31, 2026. Endorsed By: Susan M. Campbell, Director