FAC Explorer

Finding 1227107 (2025-008)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-08-18
Audit: 409307
Organization: City of Manchester, Nh (NH)
Auditor: CLA

AI Summary

  • Core Issue: The City of Manchester failed to keep necessary documentation for environmental reviews on federal projects.
  • Impacted Requirements: Compliance with federal regulations requiring a complete Environmental Review Record (ERR) for each project.
  • Recommended Follow-Up: Strengthen internal controls to ensure all environmental review certifications are properly prepared and retained.

Finding Text

Reference Number: Prior Year Finding: 2025-008 N/A Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing Number: 14.218 Award Number and Year: B-24-MC-33-0001 (7/1/2024-6/30/2025) Compliance Requirement: Special Tests and Provisions – Environmental Reviews Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: The environmental review process consists of all the actions that a responsible entity must take to determine compliance with this part. The environmental review process includes all the compliance actions needed for other activities and projects that are not assisted by HUD but are aggregated by the responsible entity in accordance with § 58.32. (24 CFR 58.30) The responsible entity must maintain a written record of the environmental review undertaken under this part for each project. This document will be designated the “Environmental Review Record” (ERR) and shall be available for public review. The ERR must contain all environmental review documents, public notices, written determinations or environmental findings required by this part as evidence of review, decision-making, and actions pertaining to the project. The ERR must describe the project and related activities, evaluate the effects of the project or activities on the human environment, document compliance with applicable statutes and authorities, including those cited in §§ 58.5 and 58.6, and record the written determinations and other review findings required by this part. The ERR must also contain verifiable source documents and relevant base data used or cited in environmental assessments, environmental impact statements, or other project review documents. (24 CFR 58.38) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City of Manchester, New Hampshire (City) did not maintain documentation evidencing that environmental reviews were conducted for all applicable projects. Context: For one of eight projects selected for testing, the environmental review worksheet documenting that an environmental review had been conducted was not available. As such, the auditor was unable to determine if the environmental review had been performed by the City. CITY OF MANCHESTER, NEW HAMPSHIRE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED JUNE 30, 2025 (21) Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Cause: The City’s procedures and controls were not sufficient to ensure that environmental review certifications were prepared and retained as part of the environmental review process. Effect: The City was unable to ensure that the required review was performed, documented and approved prior to the expenditure of federal funds. Questioned costs: Unable to determine. Recommendation: We recommend the City strengthen procedures and internal controls to ensure that environmental review certifications are prepared and retained, evidencing that the environmental reviews were completed. Views of Responsible Officials: There is no disagreement with the finding.

Corrective Action Plan

2025-008 Community Development Block Grants/Entitlement Grants - Assistance Listing Number 14.218 Recommendation: We recommend the City strengthen procedures and internal controls to ensure that environmental review certifications are prepared and retained, evidencing that the environmental reviews were completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding:  CIP will update the Environmental Review section of the CIP Procedures Manual to ensure Environmental Reviews are completed and documentation is kept on file. Additionally a SOP will also be created for how to conduct an Environmental Review. Name(s) of the contact person(s) responsible for corrective action:  Chelcie Pinsonneault, Community Grants Manager Planned completion date for corrective action plan:  Planning and Community Development will ensure the implementation of this corrective action plan is completed by October 31, 2026

Categories

Special Tests & Provisions HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1227106 2025-007
    Material Weakness Repeat
  • 1227108 2025-009
    Material Weakness Repeat
  • 1227109 2025-009
    Material Weakness Repeat
  • 1227110 2025-009
    Material Weakness Repeat
  • 1227111 2025-009
    Material Weakness Repeat
  • 1227112 2025-009
    Material Weakness Repeat
  • 1227113 2025-009
    Material Weakness Repeat
  • 1227114 2025-009
    Material Weakness Repeat
  • 1227115 2025-009
    Material Weakness Repeat
  • 1227116 2025-009
    Material Weakness Repeat
  • 1227117 2025-009
    Material Weakness Repeat
  • 1227118 2025-009
    Material Weakness Repeat
  • 1227119 2025-009
    Material Weakness Repeat
  • 1227120 2025-009
    Material Weakness Repeat
  • 1227121 2025-010
    Material Weakness Repeat
  • 1227122 2025-011
    Material Weakness Repeat
  • 1227123 2025-012
    Material Weakness Repeat
  • 1227124 2025-013
    Material Weakness Repeat
  • 1227125 2025-010
    Material Weakness Repeat
  • 1227126 2025-011
    Material Weakness Repeat
  • 1227127 2025-012
    Material Weakness Repeat
  • 1227128 2025-013
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $2.63M
93.224 HEALTH CENTER PROGRAM $1.82M
14.905 LEAD HAZARD REDUCTION DEMONSTRATION GRANT PROGRAM $1.80M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $1.32M
20.933 NATIONAL INFRASTRUCTURE INVESTMENTS $1.01M
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $516,063
14.913 HEALTHY HOMES PRODUCTION PROGRAM $416,078
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $370,515
97.083 STAFFING FOR ADEQUATE FIRE AND EMERGENCY RESPONSE (SAFER) $349,709
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $277,315
66.458 CLEAN WATER STATE REVOLVING FUND $227,334
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $218,088
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $191,940
16.922 EQUITABLE SHARING PROGRAM $184,027
20.930 PAYMENTS FOR SMALL COMMUNITY AIR SERVICE DEVELOPMENT $182,366
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $169,830
16.839 STOP SCHOOL VIOLENCE $165,350
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $161,963
93.940 HIV PREVENTION AND SURVEILLANCE ACTIVITIES-HEALTH DEPARTMENT BASED $114,560
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $103,506
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $91,212
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $84,815
93.366 STATE ACTIONS TO IMPROVE ORAL HEALTH OUTCOMES AND PARTNER ACTIONS TO IMPROVE ORAL HEALTH OUTCOMES $77,612
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION€™S HEALTH $63,320
20.941 STRENGTHENING MOBILITY AND REVOLUTIONIZING TRANSPORTATION (SMART) GRANTS PROGRAM $58,228
16.751 EDWARD BYRNE MEMORIAL COMPETITIVE GRANT PROGRAM $55,444
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $52,116
93.197 CHILDHOOD LEAD POISONING PREVENTION PROJECTS, STATE AND LOCAL CHILDHOOD LEAD POISONING PREVENTION AND SURVEILLANCE OF BLOOD LEAD LEVELS IN CHILDREN $41,029
21.016 EQUITABLE SHARING $37,486
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $30,027
16.609 PROJECT SAFE NEIGHBORHOODS $27,958
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $26,640
66.468 DRINKING WATER STATE REVOLVING FUND $25,000
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $17,065
93.005 Project Grants for Health Status of Minority Populations $16,933
20.205 HIGHWAY PLANNING AND CONSTRUCTION $12,238
93.103 FOOD AND DRUG ADMINISTRATION RESEARCH $8,701
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $5,115
16.034 CORONAVIRUS EMERGENCY SUPPLEMENTAL FUNDING PROGRAM $1,563
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $500