Finding 1166679 (2024-006)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-12-29

AI Summary

  • Core Issue: The County failed to establish policies for Section 3 compliance, impacting economic opportunities for low-income individuals.
  • Impacted Requirements: Non-compliance with 24 CFR 75 and HUD regulations, specifically regarding reporting Section 3 accomplishments in semi-annual performance reports.
  • Recommended Follow-Up: Implement additional controls to ensure adherence to Section 3 guidelines and timely submission of required accomplishments in DRGR.

Finding Text

Finding Number: 2024-006 Assistance Listing Number and Title: AL # 14.251 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Federal Award Identification Number / Year: B-22-CP-OH-0726 Federal Agency: U.S. Department Of Housing And Urban Development Compliance Requirement: Special Tests and Provisions Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Prior Audit Finding Number: N/A 24 CFR 75 establishes the requirements to be followed to ensure the objectives of Section 3 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701u) (Section 3) are met. The purpose of Section 3 is to ensure that economic opportunities, most importantly employment, generated by certain HUD financial assistance shall be directed to low- and very low-income persons, particularly those who are recipients of government assistance for housing or residents of the community in which the Federal assistance is Section 3 projects means housing rehabilitation, housing construction, and other public construction projects assisted under HUD programs that provide housing and community development financial assistance when the total amount of assistance to the project exceeds a threshold of $200,000. Consistent with existing Federal, state, and local laws and regulations, PHAs and other recipients of public housing financial assistance, and their contractors and subcontractors, must make their best efforts to award contracts and subcontracts to business concerns that provide economic opportunities to Section 3 workers. Grant Agreement No. B-22-CP-OH-0726 Article IV General Federal Requirements (M) states the grantee must comply with Section 3 of the Housing and Urban Development Act of 1968 (Section 3), 12 USC 1701u, and HUD's regulations at 24 CFR part 75 as applicable, including reporting requirements in 24 CFR 75.25. The County did not establish any policies/procedures related to Section 3. Further, The County did not include Section 3 accomplishments in their semi-annual performance reports submitted in Disaster Recovery Grant Reporting System (DRGR).The failure to submit Section 3 accomplishments on semi-annual performance reports was due to insufficient controls and could result in action taken by the grantor. Additional controls should be implemented to help ensure the County is adhering to Section 3 guidelines and submitting the required Section 3 accomplishments in their semi-annual performance reports submitted in DRGR.

Corrective Action Plan

Finding Number: 2024-006 Planned Corrective Action: The Special Projects Manager will ensure the County establishes policies/procedures related to Section 3 and includes Section 3 accomplishments in semi-annual performance reports submitted in Disaster Recovery Grant Reporting System. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: P Philip Schaffer, Special Projects Manager

Categories

HUD Housing Programs Special Tests & Provisions

Other Findings in this Audit

  • 1166677 2024-004
    Material Weakness Repeat
  • 1166678 2024-005
    Material Weakness Repeat
  • 1166680 2024-003
    Material Weakness Repeat
  • 1166681 2024-003
    Material Weakness Repeat
  • 1166682 2024-003
    Material Weakness Repeat
  • 1166683 2024-003
    Material Weakness Repeat
  • 1166684 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $2.67M
93.658 FOSTER CARE TITLE IV-E $868,124
93.778 MEDICAL ASSISTANCE PROGRAM $782,020
93.563 CHILD SUPPORT SERVICES $635,609
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $386,354
23.001 APPALACHIAN REGIONAL DEVELOPMENT (SEE INDIVIDUAL APPALACHIAN PROGRAMS) $368,000
94.006 AMERICORPS STATE AND NATIONAL 94.006 $360,986
17.258 WIOA ADULT PROGRAM $356,051
20.205 HIGHWAY PLANNING AND CONSTRUCTION $321,198
93.659 ADOPTION ASSISTANCE $301,281
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $292,126
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $285,891
17.259 WIOA YOUTH ACTIVITIES $257,707
21.032 LOCAL ASSISTANCE AND TRIBAL CONSISTENCY FUND $165,436
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $120,422
20.509 FORMULA GRANTS FOR RURAL AREAS AND TRIBAL TRANSIT PROGRAM $89,591
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $81,233
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $72,376
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $61,902
15.226 PAYMENTS IN LIEU OF TAXES $57,269
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $55,708
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $49,003
94.002 AMERICORPS SENIORS RETIRED AND SENIOR VOLUNTEER PROGRAM (RSVP) 94.002 $46,878
93.788 OPIOID STR $44,253
84.027 SPECIAL EDUCATION GRANTS TO STATES $41,294
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $40,921
10.665 SCHOOLS AND ROADS - GRANTS TO STATES $37,595
93.667 SOCIAL SERVICES BLOCK GRANT $37,084
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $32,457
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $20,665
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $20,598
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $18,641
10.553 SCHOOL BREAKFAST PROGRAM $17,908
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $14,839
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $13,877
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $11,936
15.438 NATIONAL FOREST ACQUIRED LANDS $11,337
10.555 NATIONAL SCHOOL LUNCH PROGRAM $6,851
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $3,308
16.575 CRIME VICTIM ASSISTANCE $3,040
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $2,447
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $1,339