Finding Text
Finding Reference 2025-004 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agency: P.R. Department of Housing Program: Community Development Block Grant/State’s Program and Non-Entitlement Grants in Hawaii (Assistance Listing No. 14.228) Compliance Requirement: Activities Allowed – Housekeepers activity (A) Type of Finding: Significant Deficiency (SD), Instance of Noncompliance (NC) Statement of Condition: We examined four (4) files of housekeeper program participants and found the following exceptions: a) The Program staff did not visit at least twice per month the participant’s housing unit to ensure the quality of services, according to the activity procedures guide. b) The monthly evaluation of the work carried out by the housekeeper was not carried out. Criteria: 24 CFR, Section 570.484 states that the Municipality must ensure that the program funds benefit very low, low and moderate-income persons and retain documentation justifying its certification. Also, the Municipality has an operational guide approved by its pass-through agency, P.R. Housing Department where it is established all procedures and program requirements for housekeeper activities. Cause of Condition: The Municipality’s controls and procedures failed to ensure that the participant’s files include all the required documents to comply with the Program requirements. Effect of Condition: The Municipality is not in compliance with the Code of Federal Regulations 24, Section 570.484 and with the operational guide. Recommendation: We recommend management follow the procedures established by the P.R. Department of Housing in the procedures manual, including the use of the forms included in it. Questioned Cost: None. Prior Year Finding: This finding is similar to prior year finding 2023-005 and 2024-004. Views of Responsible Officials and Planned Corrective Action: We acknowledge and accept the observation noted during the Single Audit regarding the frequency of monitoring visits and the completion of monthly evaluations for participants in the Housekeeper Program. We understand that, according to the program’s activity procedures guide, staff are expected to conduct at least two visits per month to each participant’s housing unit and to complete a monthly evaluation of the services provided. However, we would like to provide additional context regarding the operational realities of the program. The assigned Program Coordinator is responsible for overseeing approximately 20 program participants, which would require a minimum of 40 home visits per month to fully comply with the two-visits-per-month requirement. Considering that there are, on average, 20 working days per month, this expectation represents a significant workload within the available time. In addition to conducting home visits and preparing the corresponding reports, the coordinator performs a wide range of essential duties. These include supervising and addressing situations involving approximately 20 housekeeper aides, coordinating services and referrals with external agencies to meet participants’ social needs, organizing meetings, managing administrative responsibilities such as procurement of supplies used by the aides, and participating in program-related administrative meetings. We can attest that the coordinator consistently demonstrates a high level of commitment and diligence in fulfilling these responsibilities. Priority is given to participants with more complex or urgent needs, and in such cases, visits may occur more than once per month. However, meeting the requirement of two visits per month for every participant presents a significant challenge given the scope of responsibilities assigned. We remain committed to evaluating our processes and identifying opportunities to strengthen compliance while ensuring the continued quality and effectiveness of services provided to program participants. Notwithstanding these challenges, we will continue making every effort to comply with the requirements established in the CDBG guidelines. Implementation Date: March 31, 2027 Responsible Person: Mr. Hector R. Sanjurjo Rodríguez Federal Programs Director