Finding 1206533 (2025-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-04-14
Audit: 398608
Organization: City of Corpus Christi, Texas (TX)

AI Summary

  • Core Issue: The City exceeded the 20% cap on administrative and planning costs for CDBG grants, leading to questioned costs of $249,565.
  • Impacted Requirements: Compliance with 24 CFR §570.205 and §570.206 regarding allowable costs for planning activities.
  • Recommended Follow-up: Collaborate with HUD to address noncompliance and implement corrective actions for future expenditures.

Finding Text

Finding 2025-002 Information on Federal Program: Federal Program: CDBG Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development (HUD) Assistance Listing: 14.218 Compliance Requirements: Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance and Noncompliance (Questioned Costs over $25,000 for a Non-Major Federal Program) Criteria 24 CFR §570.205 and §570.206 allows costs incurred for planning activities, which consist of all costs of data gathering, studies, analysis, and preparation of plans and the identification of actions that will implement such plans, as well as program administrative costs related to the planning and execution of community development activities. These costs are capped at twenty (20) percent. Condition A HUD review of the City’s program year 2023 Consolidated Annual Performance and Evaluation Report (CAPER) and related CDBG funded activities on the CDBG Financial Summary Report showed the City expended more than twenty (20) percent in administrative and planning costs for origin years 2015, 2017, 2018 and 2020. Cause City staff did not correctly identify activities as exceeding the administrative cap under the CDBG regulations and award requirements. Effect or Potential Effect Federal funds were reimbursed for activities which has resulted in required repayment of funds from nonfederal sources. Questioned Costs $249,565 Recommendation We recommend City officials work with HUD to determine the nature of noncompliance and implement any remedial actions to ensure future administrative and planning costs are being appropriately expended under the CDBG award agreements. Views of Responsible Official(s) and Planned Corrective Action See corrective action plan

Corrective Action Plan

Finding 2025-002 Information on Federal Program: Federal Program: CDBG Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development (HUD) Assistance Listing: 14.218 Compliance Requirements: Allowable Costs/Cost Principles Corrective Action Plan The City will submit payment to HUD for the $249,565 of questioned costs. Additionally, the City will update its written program and financial policies and procedures per 24 CFR 570.200(g) which should outline how the City of Corpus Christi will monitor compliance with both of the Administrative and Planning expenditure tests and will provide HUD with a certification stating Planning and Community Development staff received training regarding the limitation on planning and administration costs for origin year grants. Person(s) Responsible Jennifer Buxton, Interim Director of Planning and Economic Development Anticipated Completion Date The City has completed all corrective actions.

Categories

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1206527 2025-002
    Material Weakness Repeat
  • 1206528 2025-002
    Material Weakness Repeat
  • 1206529 2025-002
    Material Weakness Repeat
  • 1206530 2025-002
    Material Weakness Repeat
  • 1206531 2025-002
    Material Weakness Repeat
  • 1206532 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $6.93M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $2.46M
10.557 SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $925,147
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $851,116
93.045 SPECIAL PROGRAMS FOR THE AGING_TITLE III, PART C_NUTRITION SERVICES $690,186
66.458 CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS $624,370
93.667 SOCIAL SERVICES BLOCK GRANT $597,882
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $567,441
20.106 AIRPORT IMPROVEMENT PROGRAM $492,293
94.016 SENIOR COMPANION PROGRAM $400,798
93.556 PROMOTING SAFE AND STABLE FAMILIES $396,617
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $313,846
16.575 CRIME VICTIM ASSISTANCE $291,030
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $267,487
21.016 EQUITABLE SHARING $260,463
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $225,361
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $151,520
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $119,725
16.922 EQUITABLE SHARING PROGRAM $114,726
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $84,806
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $68,183
97.067 HOMELAND SECURITY GRANT PROGRAM $63,241
94.002 RETIRED AND SENIOR VOLUNTEER PROGRAM $63,021
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $59,609
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $55,464
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $49,666
20.930 PAYMENTS FOR SMALL COMMUNITY AIR SERVICE DEVELOPMENT $45,237
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $40,593
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $38,588
93.967 CDC'S COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $34,337
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $29,358
93.940 HIV PREVENTION ACTIVITIES_HEALTH DEPARTMENT BASED $19,171
93.977 PREVENTIVE HEALTH SERVICES_SEXUALLY TRANSMITTED DISEASES CONTROL GRANTS $10,410
93.008 MEDICAL RESERVE CORPS SMALL GRANT PROGRAM $10,244
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $7,578
16.543 MISSING CHILDREN'S ASSISTANCE $4,400
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $3,722
10.558 CHILD AND ADULT CARE FOOD PROGRAM $3,183