Finding 1173387 (2025-001)

Condition: The County did not perform required on-site inspections of four out of six HOME-assisted properties evaluated during FY 2025, as mandated by 24 CFR §§ 92.209(i), 92.251(f), and 92.504(d). These inspections are required every one to three years, depending on the number of units per project. Recommendation: Establish and maintain a formal inspection schedule with assigned accountability to ensure timely completion of all required HOME inspections. Implement tracking tools and cross-training to mitigate delays caused by staff turnover. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Planned in Response to Finding The County agrees with the finding and is implementing the following corrective actions to strengthen internal controls over HOME inspection compliance and ensure inspections are conducted in accordance with federal requirements. 1. Cross-Training of Inspection Staff Housing & Grants staff will conduct formal cross-training with inspectors from Environmental Health and/or the Marin Housing Authority by June 30, 2026. This training will cover HOME inspection requirements, including property standards, documentation expectations, and inspection frequency requirements. Cross-training will ensure sufficient technical expertise and backup coverage to perform and review HOME inspections in compliance with federal regulations and to maintain continuity during staffing changes.2. Implementation of Inspection Tracking Software The Community Development Agency will implement and utilize inspection tracking software by June 30, 2026 to track, schedule, and document HOME program inspections. The system will maintain inspection dates, inspection type (desk audit or physical), findings, corrective actions, and follow-up status. This tool will strengthen monitoring controls, provide management visibility, and help ensure inspections are conducted timely and consistently. 3. Conducting HOME Inspections in Accordance with HOME Regulations Housing & Grants staff will conduct HOME inspections in accordance with HOME program regulations by June 30, 2026, including both desk audits and physical inspections, as follows: • Desk Audits: Staff will review program documentation, tenant eligibility, income certifications, rent limits, and other compliance documentation using standardized desk audit procedures. • Physical Inspections: Physical property inspections will be performed in accordance with HOME property standards to assess health and safety compliance. • Monitoring and Documentation through JotForm Desk Audits: Desk audits will be documented using JotForm inspection and monitoring tools to ensure consistent documentation, clear audit trails, and management oversight of HOME compliance activities. 4. Formal Inspection Schedule and Ongoing Oversight The Community Development Agency has initiated development of a comprehensive HOME on-site inspection schedule that identifies all HOME-assisted properties, applicable inspection frequencies, and assigned staff responsibilities. The schedule will be maintained and reviewed at least quarterly by program management to ensure inspections are completed timely and any overdue inspections are promptly addressed. Responsible Officials • Leelee Thomas, Deputy Director, Community Development Agency Leelee.Thomas@marincounty.gov • Chris Miranda, Senior Program Coordinator, Community Development Agency Chris.Miranda@marincounty.gov Planned Completion Date All corrective actions described above are expected to be fully implemented by June 30, 2026.