Finding 1148921 (2024-005)

Compliance Monitoring Criteria – The City entered into an agreement with East Central Intergovernmental Association (ECIA) to administer the Lead-Based Paint Hazard Control in Privately-Owned Housing grant (LBA). The agreement requires ECIA identify applicable federal and state laws and regulations and assist in complying with federal and state requirements. The agreement also requires ECIA monitor and evaluate the project progress to facilitate compliance with applicable federal and state laws and regulations. Condition – As the primary recipient of the LBA grant, the City is responsible to ensure compliance with the requirements of the Uniform Guidance. ECIA monitored the LBA grant to ensure compliance with the requirements of the Uniform Guidance. However, the City did not maintain documentation indicating eligibility, procurement and allowable payroll cost requirements were met. Cause – Although the City contracted with ECIA to administer the grant, the City is the grant recipient and, accordingly, is responsible for ensuring compliance. The City was unaware it retained this responsibility. Effect – The City is not properly monitoring ECIA to ensure compliance with the requirements of the Uniform Guidance. Noncompliance with the requirements of the Uniform Guidance could result in the loss and refunding of grant funds. Recommendation – The City should maintain and review documentation to ensure applicable compliance requirements have been met. The review should be evidenced by the initials or signature of the reviewer and the date of the review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. In addition to those supporting documents, the City is already requesting ECIA’s yearly audit report but will implement a procedure to sign off that it was reviewed. Conclusion – Response accepted.