Finding Text
2024-003: Internal Controls over Compliance for Special Tests and Provisions
(Environmental Reviews)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Community Development Block Grants (CDBG)/Entitlement Grants – ALN 14.218
Criteria: Environmental reviews should be performed on CDBG projects as required by 24 CFR
section 58.
Condition: Environmental reviews were incomplete or missing from a sample of projects tested
for compliance.
Cause: Turnover within the HRA during 2024 attributed to this condition. Existing procedures
in place to help ensure program compliance were not consistently followed by staff.
Effect: Without proper environmental reviews, there is a risk of potential negative environmental
impacts resulting from a project funded by CDBG funds or noncompliance with the National
Environmental Policy Act or other applicable federal, state, and local laws and regulations.
Questioned Costs: $0
Context: A sample of four out of 40 projects with activity during 2024 found two of the four
projects tested lacked supporting documentation to prove that environmental reviews were
completed.
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend the HRA continue to strengthen its controls over compliance
within the CDBG program, including having the HRA Administrator or HRA Assistant
Administrator verify program checklists are completed with proper supporting documentation for
all programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this
finding and is in the process of developing internal controls to ensure timely and appropriate
actions are taken on the deficiency noted. Additional details can be found in the City of
Bloomington’s Corrective Action Plan.