FAC Explorer

Finding 1177 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2023-11-03
Audit: 2251
Organization: City of Scottsdale, Arizona (AZ)
Auditor: Heinfeld Meech & CO PC

AI Summary

  • Core Issue: The City failed to obtain a HUD-approved request for release of funds (RROF) for a project, leading to noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 24 CFR §58.22, which mandates HUD approval before spending CDBG grant funds.
  • Recommended Follow-Up: Allocate resources to the Community Assistance Office to improve training and ensure proper maintenance of compliance documents.

Finding Text

Finding Number: 2023‐002 Repeat Finding: No Program Name/Assistance Listing Title: CDBG‐Entitlement Grants Cluster Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Federal Award Number: B‐20‐MC‐04‐0503 Pass‐Through Agency: N/A Questioned Costs: $255,750 Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions Criteria 24 CFR §58.22 requires Housing and Urban Development (HUD) to approve a request for release of funds (RROF) before the City can obligate or expend CDBG grant funds. Condition The City could not provide a HUD‐approved RROF for one project funded with Program Year 2020 monies. Cause The Community Assistance Office experienced turnover and vacancies in key positions responsible for reporting during fiscal year 2021. Training was needed for program employees to fully understand reporting responsibilities for the City. In some cases information was not retained and required recreation. Effect The City was not in compliance with 24 CFR §58.22. Context HUD approval of the RROF for the Piute Splashpad project in fiscal year 2019‐20 was not retained. The City was, therefore, required to remit to HUD the $255,750 expended on the project. The funds were returned in June and July 2023. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The City should dedicate time and resources to the Community Assistance Office to ensure that key compliance documents are maintained for the program. Views of Responsible Officials See Corrective Action Plan.

Corrective Action Plan

The Community Assistance Office completed a Housing and Urban Development (HUD) Environmental Review audit on February 14, 2023, resulting in a Corrective Action Plan to pay back funding for a statutory and regulatory violation of failure to retain an Authority to Use Grant Funds. A Corrective Action Plan was submitted to HUD on March 10, 2023, that included the following most notable items: 1) Update environmental review policies to ensure compliance with 24CFR 58.22 with financial controls, retention, and the funding process, 2) Repayment of $255,750 to the CDBG line of credit and ensure no future CDBG funds are used for this purpose and 3) Staff training and development. Community Development Block Grant staff, including the supervisor and manager complete a webbased instruction system for environmental reviews through the HUD Exchange as recommended by October 31, 2023. In September 2023 two staff members attended an in person Environmental Review Training in San Francisco, CA through the Office of Environment and Energy. The $255,750 was repaid to the line of credit in two installments in June 2023 and August 2023. These funds will be re‐programmed for future eligible CDBG funding activities in the Annual Action Plan for FY 2024‐2025. Community Assistance Policies for financial controls, retention and the funding process will be updated and completed by January 1, 2024.

Categories

Questioned Costs Special Tests & Provisions HUD Housing Programs Reporting Significant Deficiency

Other Findings in this Audit

  • 1176 2023-001
    Significant Deficiency
  • 1178 2023-003
    Significant Deficiency
  • 1179 2023-004
    Significant Deficiency
  • 1180 2023-005
    Significant Deficiency
  • 1181 2023-006
    Significant Deficiency
  • 1182 2023-001
    Significant Deficiency
  • 577618 2023-001
    Significant Deficiency
  • 577619 2023-002
    Significant Deficiency
  • 577620 2023-003
    Significant Deficiency
  • 577621 2023-004
    Significant Deficiency
  • 577622 2023-005
    Significant Deficiency
  • 577623 2023-006
    Significant Deficiency
  • 577624 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $14.62M
14.871 Section 8 Housing Choice Vouchers $6.73M
20.106 Airport Improvement Program $3.95M
14.218 Community Development Block Grants/entitlement Grants $1.21M
21.016 Equitable Sharing $1.07M
20.507 Covid-19 - Federal Transit_formula Grants $775,517
15.514 Reclamation States Emergency Drought Relief $649,042
20.205 Highway Planning and Construction $634,972
97.044 Assistance to Firefighters Grant $570,231
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $478,888
21.023 Covid-19 - Emergency Rental Assistance Program $379,317
20.507 Federal Transit_formula Grants $211,160
16.741 Dna Backlog Reduction Program $205,961
10.697 State & Private Forestry Hazardous Fuel Reduction Program $150,615
14.896 Family Self-Sufficiency Program $86,597
97.106 Securing the Cities Program $73,847
93.568 Low-Income Home Energy Assistance $73,376
97.083 Staffing for Adequate Fire and Emergency Response (safer) $49,050
20.600 State and Community Highway Safety $47,931
93.569 Community Services Block Grant $25,000
10.665 Schools and Roads - Grants to States $20,000
97.067 Homeland Security Grant Program $9,703
20.616 National Priority Safety Programs $8,000
45.310 Covid-19 - Grants to States $4,774
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $4,467
45.310 Grants to States $4,000
14.239 Home Investment Partnerships Program $1,345
16.738 Edward Byrne Memorial Justice Assistance Grant Program $64