FAC Explorer

Finding 1205174 (2025-004)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-03-31
Audit: 396826
Organization: Louisville/jefferson County Metro Government (KY)
Auditor: LBMC

AI Summary

  • Core Issue: Metro Government is not drawing down CDBG funds in a timely manner, exceeding the 1.5 times annual grant limit for the third consecutive time.
  • Impacted Requirements: Compliance with HUD's cash management criteria, specifically 24 CFR 570.902(a)(1), which mandates timely fund disbursement.
  • Recommended Follow-Up: Develop and implement a Timeliness Workout Plan to ensure compliance by the next assessment on May 2, 2026.

Finding Text

Finding 2025-004: Community Development Block Grant (“CDBG”) Draws Are Not Always Timely Federal Program: ALN 14.218 Community Development Block Grants/Entitlement Grants Name of Federal Agency: U.S. Department of Housing and Urban Development (“HUD”) Award Identification Number and Year: B-21-MC-21-0008, B-22-MC-21-0008, B-20-MC-21-0008, B-18-MC-0008, B-23-MC-21-0008, and B-24-MC-211-008 Name of pass-through entity: N/A COVID Identification: No Amount of Questioned Costs: N/A Compliance Requirement: Cash Management Criteria: 24 CFR 570.902(a)(1) states, “HUD will consider an entitlement recipient ….to be failing to carry out its CDBG activities in a timely manner if: (i) Sixty days prior to the end of the grantee’s current program year, the amount of entitlement grants funds available to the recipient under grant agreements but undisbursed by the U.S. Treasury is more than 1.5 times the entitlement grant amount for its current program year; and (ii) The grantee fails to demonstrate to HUD’s satisfaction that the lack of timeliness has resulted in factors beyond the grantee’s reasonable control.” Per HUD, “A grantee is considered to be in compliance if, 60 days prior to the end of its program year, there is no more than 1.5 times its annual grant remaining in the line of credit.” Condition: Metro Government received an email from HUD on May 22, 2025 stating that HUD reviewed their compliance with requirements for carrying out a CDBG program in a timely manner and that Metro Government was in noncompliance with the timeliness standard for the third consecutive time. Metro Government has a July 1st program start date. HUD conducted the 60 day test on May 2, 2025. It was calculated that Metro Government had a balance in its line of credit 2.21 times its annual grant. HUD required Metro Government to prepare a Timeliness Workout Plan to provide detail on the category of the CDBG funds. Per the CDBG Timeliness Progress Report on August 26, 2025, there was a total remaining balance of $37.4 million of CDBG funds to be drawn down. The largest categories of these funds were “slow but active project spending” of $18.8 million and “uncommitted funds” of $16.8 million. On January 15, 2026, the total remaining balance was $30.6 million. The two largest categories were “spending on time” of $9.2 million and “activities to be funded” of $9.1 million. Effect: HUD could impose sanctions for grant reductions. Cause: Reasons for this issue are projects are not moving forward as quickly as planned, focus of projects has changed and project will not move forward, and project has had expenditures but the reimbursement for the expenditures have not been drawn down. Recommendation: We recommend Metro Government reach the 1.5 timeliness standard by the next HUD timeliness standard assessment on May 2, 2026.

Corrective Action Plan

Management’s response: Management concurs with the auditors’ finding and recommendation and will continue to implement the timeliness backlog remediation steps outlined in the CDBG Timeliness Workout Plan revised on September 9, 2025.

Categories

Cash Management Subrecipient Monitoring HUD Housing Programs Period of Performance

Other Findings in this Audit

  • 1205161 2025-002
    Material Weakness Repeat
  • 1205162 2025-003
    Material Weakness Repeat
  • 1205163 2025-004
    Material Weakness Repeat
  • 1205164 2025-005
    Material Weakness Repeat
  • 1205165 2025-006
    Material Weakness Repeat
  • 1205166 2025-004
    Material Weakness Repeat
  • 1205167 2025-005
    Material Weakness Repeat
  • 1205168 2025-004
    Material Weakness Repeat
  • 1205169 2025-005
    Material Weakness Repeat
  • 1205170 2025-004
    Material Weakness Repeat
  • 1205171 2025-005
    Material Weakness Repeat
  • 1205172 2025-004
    Material Weakness Repeat
  • 1205173 2025-005
    Material Weakness Repeat
  • 1205175 2025-005
    Material Weakness Repeat
  • 1205176 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $93.72M
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $7.73M
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $6.61M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $3.96M
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $3.59M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $2.96M
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $2.86M
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $2.84M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $2.66M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $2.34M
16.922 EQUITABLE SHARING PROGRAM $2.03M
14.900 LEAD HAZARD REDUCTION GRANT PROGRAM $1.65M
20.933 NATIONAL INFRASTRUCTURE INVESTMENTS $1.30M
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $1.18M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $906,754
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $903,939
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $756,023
66.001 AIR POLLUTION CONTROL PROGRAM SUPPORT $731,005
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $690,339
20.939 SAFE STREETS AND ROADS FOR ALL $670,517
21.016 EQUITABLE SHARING $606,130
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $539,017
97.067 HOMELAND SECURITY GRANT PROGRAM $475,267
93.788 OPIOID STR $444,220
97.039 HAZARD MITIGATION GRANT $439,285
94.011 AMERICORPS SENIORS FOSTER GRANDPARENT PROGRAM (FGP) 94.011 $419,880
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $370,561
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $296,677
16.838 COMPREHENSIVE OPIOID, STIMULANT, AND OTHER SUBSTANCES USE PROGRAM $262,455
20.941 STRENGTHENING MOBILITY AND REVOLUTIONIZING TRANSPORTATION (SMART) GRANTS PROGRAM $253,292
93.235 TITLE V STATE SEXUAL RISK AVOIDANCE EDUCATION (TITLE V STATE SRAE) PROGRAM $248,313
93.926 HEALTHY START INITIATIVE $233,013
16.045 COMMUNITY-BASED VIOLENCE INTERVENTION AND PREVENTION INITIATIVE $218,509
66.312 ENVIRONMENTAL JUSTICE GOVERNMENT-TO-GOVERNMENT (EJG2G) PROGRAM $217,151
66.046 CLIMATE POLLUTION REDUCTION GRANTS $214,663
20.205 HIGHWAY PLANNING AND CONSTRUCTION $196,183
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $155,392
16.548 DELINQUENCY PREVENTION PROGRAM $150,042
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $137,309
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $126,798
45.024 PROMOTION OF THE ARTS GRANTS TO ORGANIZATIONS AND INDIVIDUALS $120,000
14.889 CHOICE NEIGHBORHOODS IMPLEMENTATION GRANTS $119,748
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $117,334
94.002 AMERICORPS SENIORS RETIRED AND SENIOR VOLUNTEER PROGRAM (RSVP) 94.002 $107,099
16.833 NATIONAL SEXUAL ASSAULT KIT INITIATIVE $102,236
97.056 PORT SECURITY GRANT PROGRAM $86,666
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $78,408
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $77,734
97.137 STATE AND LOCAL CYBERSECURITY GRANT PROGRAM TRIBAL CYBERSECURITY GRANT PROGRAM $77,465
93.070 ENVIRONMENTAL PUBLIC HEALTH AND EMERGENCY RESPONSE $75,000
14.401 FAIR HOUSING ASSISTANCE PROGRAM $71,612
93.217 FAMILY PLANNING SERVICES $70,567
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $69,881
14.267 CONTINUUM OF CARE PROGRAM $55,592
93.778 MEDICAL ASSISTANCE PROGRAM $45,802
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $45,694
93.917 HIV CARE FORMULA GRANTS $45,375
16.606 STATE CRIMINAL ALIEN ASSISTANCE PROGRAM $45,098
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $39,753
16.609 PROJECT SAFE NEIGHBORHOODS $36,184
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $28,986
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $28,321
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $26,056
66.034 SURVEYS, STUDIES, RESEARCH, INVESTIGATIONS, DEMONSTRATIONS, AND SPECIAL PURPOSE ACTIVITIES RELATING TO THE CLEAN AIR ACT $25,611
93.048 SPECIAL PROGRAMS FOR THE AGING, TITLE IV, AND TITLE II, DISCRETIONARY PROJECTS $23,779
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $20,964
93.103 FOOD AND DRUG ADMINISTRATION RESEARCH $19,000
66.306 ENVIRONMENTAL JUSTICE COLLABORATIVE PROBLEM-SOLVING COOPERATIVE AGREEMENT PROGRAM $14,461
93.008 MEDICAL RESERVE CORPS SMALL GRANT PROGRAM $13,111
10.699 PARTNERSHIP AGREEMENTS $12,747
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $11,179
20.218 MOTOR CARRIER SAFETY ASSISTANCE $10,229
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $5,238
93.569 COMMUNITY SERVICES BLOCK GRANT $2,763
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $2,726
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $853
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $829
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $172