Finding 1223501 (2025-008)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-07-09

AI Summary

  • Core Issue: The HOME program failed to conduct final on-site inspections for 100% of new mortgages, totaling $700,750, violating HUD requirements.
  • Impacted Requirements: Noncompliance with 24 CFR 92.251, which mandates inspections to ensure construction meets property standards before project completion.
  • Recommended Follow-Up: Implement standardized checklists and reviewer controls to ensure all required documentation, especially final inspection evidence, is completed before approving HOME funds.

Finding Text

Finding No.: 2025-008 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.239 HOME Investment Partnerships (HOME) Program Federal Award No.: M17ST660202, M18ST660202 Area: Special Tests and Provisions – Housing Quality Standards Criteria or specific requirement (including statutory, regulatory or other citation): 24 CFR 92.251states: (a) New construction projects — (2) Construction progress and final inspections. The participating jurisdiction must conduct on-site progress and final inspections of construction to ensure that work is done in accordance with the applicable codes, the construction contract, and construction documents. Before completing the project in the disbursement and information system established by HUD, the participating jurisdiction must perform an on-site inspection of the project to determine that all contracted work has been completed and that the project complies with the property standards and requirements in this paragraph (a). All inspections performed by the participating jurisdiction must be conducted in accordance with the participating jurisdiction's inspection procedures. Condition: For all four (100%) new mortgages, aggregating $700,750 of $2,230,031 in total HOME subsidies, the HOME program did not perform final on-site inspections to confirm the housing meets appropriate property standards. Cause: The HOME program does not have formalized monitoring procedures, including detailed review checklists, to ensure that all required documentation is completed and adequately reviewed prior to the approval and disbursement of HOME subsidies. Finding No.: 2025-008, continued Effect or potential effect: GHURA is in noncompliance with applicable special test and provisions requirements. Questioned Costs: $700,750 Identification as a repeat finding: Not applicable. Recommendation: The HOME program should establish and implement a detailed standardized checklists with reviewer controls, to ensure that all required documentation—particularly evidence of final onsite inspections, is completed and reviewed prior to the approval and disbursement of HOME funds. Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: The condition relates to the support available for review for audit submission. We examined all new mortgagee files submitted on April 10, 2026. Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.

Corrective Action Plan

Finding #2025-008 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Houisng Quality Standards Views of Responsible Officials and Planned Corrective Action Management’s Position: #1 Management concurs with the finding and acknowledges the deficiency identified. Corrective action has been initiated. #2 Disagree, the inspection report was only requested for one of the units, submitted on March 12, 2026. Supporting documentation is available for review for the other units upon request. Explanation of Disagreement: For Item #2, GHURA completed onsite inspections for the two acquisition units reviewed. As these units required no rehabilitation, only one inspection was necessary. The remaining two units are new construction projects currently under development. GHURA has conducted ongoing progress inspections and maintained inspection reports prepared by a third-party inspector throughout the construction process. Units are scheduled to be completed 2nd quarter FY2027 at which time the final inspections will be conducted to ensure compliance with program requirements. Corrective Actions: Item #1 - Guam initiated HOME rental monitoring and technical assistance for the three rental developments currently within their compliance periods. Consistent with the schedule provided to HUD by GHURA, RPE conducted entrance meetings with the Subrecipient organization’s deputy director and key staff on June 17, 2026. The Subrecipient was notified of physical inspections scheduled for June 22, 23, and 25, 2026, to be conducted by GHURA AE. One complex, containing more than ten (10) HOME-assisted units, will also undergo financial viability monitoring. File reviews, interviews, and document collection are currently underway. Item #1 – RP&E has initiated this action and will continue as required moving forward. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Item #1 - The monitoring process will conclude within 30 days of the entrance meeting, on July 17, 2026, at which time a letter outlining the monitoring results will be issued.

Categories

Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs

Other Findings in this Audit

  • 1223495 2025-002
    Material Weakness Repeat
  • 1223496 2025-003
    Material Weakness Repeat
  • 1223497 2025-004
    Material Weakness Repeat
  • 1223498 2025-005
    Material Weakness Repeat
  • 1223499 2025-006
    Material Weakness Repeat
  • 1223500 2025-007
    Material Weakness Repeat
  • 1223502 2025-009
    Material Weakness Repeat
  • 1223503 2025-010
    Material Weakness Repeat
  • 1223504 2025-011
    Material Weakness Repeat
  • 1223505 2025-012
    Material Weakness Repeat
  • 1223506 2025-013
    Material Weakness Repeat
  • 1223507 2025-014
    Material Weakness Repeat
  • 1223508 2025-015
    Material Weakness Repeat
  • 1223509 2025-016
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $51.89M
14.248 COMMUNITY DEVELOPMENT BLOCK GRANTS SECTION 108 LOAN GUARANTEES $11.31M
14.850 PUBLIC HOUSING OPERATING FUND $7.24M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $5.62M
14.872 PUBLIC HOUSING CAPITAL FUND $4.19M
14.U01 EMERGENCY HOUSING VOUCHER $1.55M
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $1.14M
14.267 CONTINUUM OF CARE PROGRAM $1.05M
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $623,030
14.879 MAINSTREAM VOUCHERS $479,687
14.225 COMMUNITY DEVELOPMENT BLOCK GRANTS/SPECIAL PURPOSE GRANTS/INSULAR AREAS $429,662
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $245,283
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $180,272
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $79,730
14.191 MULTIFAMILY HOUSING SERVICE COORDINATORS $68,838
14.275 HOUSING TRUST FUND $33,902
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $16,106