Finding 1205175 (2025-005)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-03-31
Audit: 396826
Auditor: LBMC

AI Summary

  • Core Issue: OHCD's monitoring of subrecipients was inadequate, lacking formal risk assessments and site visits.
  • Impacted Requirements: Compliance with federal guidelines (2 CFR 200.332) for evaluating subrecipient risk and ensuring proper fund usage was not met.
  • Recommended Follow-Up: OHCD should implement OSS's monitoring procedures, including formal risk assessments and regular site visits.

Finding Text

Finding 2025-005: CDBG Subrecipient Monitoring At Metro Government’s Office of Housing and Community Development (“OHCD”) Needs Improvement Federal Program: ALN 14.218 Community Development Block/Entitlement Grants Name of Federal Agency: U.S. Department of Housing and Urban Development 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: Subrecipient monitoring Criteria:The Metro Government Subrecipient Management Policy Manual states, “Title 2 CFR 200.332 requires all pass-through entities to evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward to determine the appropriate monitoring needed to ensure Federal funds are used properly. Passthrough entities are not required to complete a risk assessment on contractors. Metro agencies must complete risk assessments on all subrecipients no less than annually.” 2 CFR 200.332(c) states, “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also received Federal awards directly from the Federal agency).” Condition: During FY 2025, a total of $9,780,961 in CDBG funds were distributed to 21 subrecipients by Metro Government. Monitoring these subrecipients was conducted by two offices. The Office of Social Services (“OSS”) monitored 11 subrecipients totaling $5,306,082. The Office of Housing and Community Development (“OHCD”) was responsible for monitoring 10 subrecipients totaling $4,474,879. OSS is responsible for monitoring the subrecipients that have subawards for CDBG operating and service projects. OSS completes the following procedures when monitoring their subrecipients: completing a risk assessment spreadsheet, maintaining a historic log documenting the dates of when each subrecipient was monitored, and desk reviews and/or site visits. High risk subrecipients are monitored more frequently compared to those assessed at a lower risk. Subrecipients are required to be monitored at least once every three years. The OHCD is responsible for monitoring subrecipients that have subawards for CDBG capital projects. OHCD conducts informal, undocumented risk assessments of subrecipients. No site visits were conducted in fiscal year 2025. Effect: The OHCD did not adequately monitor its subrecipients during fiscal year 2025. Cause: The OHCD did not have a designated individual responsible for subrecipient monitoring during fiscal year 2025. Recommendation: We recommend the OHCD adopt the procedures and documentation practices established by OSS. Specifically, this includes conducting site visits, assessing each subrecipient’s risk of noncompliance, performing desk reviews and site visits, and maintaining comprehensive documentation of risk assessment and monitoring activities.

Corrective Action Plan

Management’s Response: Management concurs with the auditors’ finding and recommendation. OHCD has hired a full-time staff person who will work to implement a subrecipient monitoring process for OHCD subrecipients.

Categories

Subrecipient Monitoring

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
  • 1205174 2025-004
    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