Finding 1073845 (2024-001)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-09-20
Audit: 320150
Organization: Charter Township of Clinton (MI)

AI Summary

  • Core Issue: The Township failed to document required inspections before and after rehabilitation work, which is a serious compliance gap.
  • Impacted Requirements: This finding violates 24 CFR 570.506(b)(9)(ii), which mandates formal inspection reports for residential property rehabilitation.
  • Recommended Follow-Up: Implement controls for formal inspection reports before contract approval and upon project completion, and conduct monthly reviews of ongoing rehabilitation projects.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, U.S. Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant Federal Award Identification Number and Year - B-18-MC-26-0033, B-19-MC-26-0033, B-20-MC-26-0033, B-21-MC-26-0033, B-22-MC-26-0033, B-23-MC-26-0033 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - 24 CFR 570.506(b)(9)(ii) requires the Township to prepare and maintain a prerehabilitation inspection report describing the deficiencies to be rehabilitated for residential properties. The Township is also required to inspect the rehabilitation work upon completion to assure that it is carried out in accordance with rehabilitation standards. Condition - We noted no formal evidence that required inspections were performed prior to contract approval in one instance. We also noted no formal evidenced that inspections were performed upon project completion to ensure that work was carried out in accordance with contract specifications in one instance. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - No formal evidence existed where deficiencies were identified after the prerehabilitation and postrehabilitation inspection processes had been completed. Cause and Effect - The lack of documentation of an inspection performed that identified work to be performed prior to contract approval could result in questioned costs if the need for the rehabilitation work could not be substantiated. Recommendation - We recommend the Township implement controls to ensure a formal inspection report is prepared prior to approval of all rehabilitation contracts, including contracts for deficiencies identified after the initial prerehabilitation inspection process is complete. We also recomment implementing controls to ensure a formal inspection report is prepared upon completion of rehabilitation work to ensure that work was carried out in accordance with contract specifications. Additionally, we recomment implementing controls to ensure a review of ongoing rehabilitation projects occurs at a minimum on a monthly basis to ensure that prerehabilitation and postrehabilitation inspections are being performed. Views of Responsible Officials and Corrective Action Plan - After the inspector has done the initial walk through to identify required repairs, a full comprehensive write-up and cost is established for all rehabilitation projects that document additional repairs to be completed that are more preventive in nature. Any additional items discovered during the project or requested by the homeowner will be added to the write-up. For any emergency repairs, a memorandum will be added to the file. To ensure that prerehabilitation and postrehabilitation inspections are taking place, the assistant planning director will review a list of ongoing rehabilitation projects at a minimum on a monthly basis.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Other Findings in this Audit

  • 497401 2024-001
    Material Weakness
  • 497402 2024-001
    Material Weakness
  • 497403 2024-001
    Material Weakness
  • 497404 2024-001
    Material Weakness
  • 497405 2024-001
    Material Weakness
  • 497406 2024-001
    Material Weakness
  • 1073843 2024-001
    Material Weakness
  • 1073844 2024-001
    Material Weakness
  • 1073846 2024-001
    Material Weakness
  • 1073847 2024-001
    Material Weakness
  • 1073848 2024-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $296,717
16.922 Equitable Sharing Program $200,000
97.044 Assistance to Firefighters Grant $65,505
16.738 Edward Byrne Memorial Justice Assistance Grant Program $28,362
97.042 Emergency Management Performance Grants $11,396
10.730 Community Project Funds $8,847
97.067 Homeland Security Grant Program $4,764
16.607 Bulletproof Vest Partnership Program $960
20.600 State and Community Highway Safety $324