Finding 1228106 (2026-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2026
Accepted
2026-08-27
Audit: 409938
Organization: Charter Township of Clinton (MI)

AI Summary

  • Core Issue: The Township failed to maintain proper documentation for pre-rehabilitation inspections, which is a repeat finding.
  • Impacted Requirements: Compliance with 24 CFR 570.506(b)(9)(ii) regarding the preparation of inspection reports before contract approval.
  • Recommended Follow-Up: Implement controls for formal inspection reports prior to contract approval and conduct monthly reviews of ongoing rehabilitation projects.

Finding Text

Assistance Listing, Federal Agency, and Program Name - ALN 14.218, U.S. Department of Housing and Urban Development, CDBG Entitlement Grants Cluster Community Development Block Grant Federal Award Identification Number and Year - B-20-MC-26-0033, B-21-MC-26-0033, B-22-MC-26-0033, B-23-MC-26-0033, B-24-MC-26-0033, B-25-MC-26 0033 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes (2025-001) Criteria - 24 CFR 570.506(b)(9)(ii) requires the Township to prepare and maintain a prerehabilitation inspection report describing the deficiencies to be rehabilitated for residential properties. Condition - We noted no formal evidence that the stated control to ensure performance of required inspections prior to contract approval had been implemented effectively in one instance. Questioned Costs - N/A If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - During testing of eleven rehabilitation projects, we noted that management was unable to provide evidence that a review took place over the preinspection for one project. However, the required inspections took place at the appropriate time as evidenced by detailed notes left by the township representative charged with carrying out rehabilitation projects. Cause and Effect - The lack of documentation of an inspection performed that identified work to be performed prior to contract approval could result in questioned costs if the need for the rehabilitation work could not be substantiated. Recommendation - We recommend the Township implement controls to ensure a formal inspection report is prepared prior to approval of all rehabilitation contracts, including contracts for deficiencies identified after the initial prerehabilitation inspection process is complete. We also recommend implementing controls to ensure a review of ongoing rehabilitation projects occurs at a minimum on a monthly basis to ensure that required inspections are performed. Views of Responsible Officials and Corrective Action Plan - Staff will review folders at various stages of the project to ensure all records of inspections at both the beginning and end of the project are in the file. Staff have already set up either biweekly or monthly meetings (depending on project activity levels) to report on the status of ongoing projects. These meetings were intended to help staff keep current projects in line with the overall project budget (i.e., not obligating funds beyond what is available). Using these same meetings to check project files for all necessary records will be an adjustment of negligible effort.

Corrective Action Plan

Condition: We noted no formal evidence that the stated control to ensure performance of required inspections prior to contract approval operated effectively in one instance. Planned Corrective Action: Staff will review folders at various stages of the project to ensure all records of inspections at both the beginning and end of the project are in the file. Staff has already set up either bi-weekly or monthly meetings (depending on project activity levels) to report on the status of ongoing projects. These meetings were intended to help staff keep current projects in line with the overall project budget (i.e. not obligating funds beyond what’s available). Using these same meetings to check project files for all necessary records will be an adjustment of negligible effort. In instances where there is a sizable gap between portions of a project (e.g. part of the project can’t be completed until spring) staff will consider closing out the completed portion of the project and completing a final inspection on the balance of the job at a later date. Contact person responsible for corrective action: Edwin Manninen, Matthew Wallace Anticipated Completion Date: Immediately

Categories

Allowable Costs / Cost Principles Material Weakness

Other Findings in this Audit

  • 1228102 2026-001
    Material Weakness Repeat
  • 1228103 2026-001
    Material Weakness Repeat
  • 1228104 2026-001
    Material Weakness Repeat
  • 1228105 2026-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $396,804
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $354,265
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $149,860
16.922 EQUITABLE SHARING PROGRAM $136,302
21.016 EQUITABLE SHARING $63,698
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $52,043
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $51,570
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $23,548
20.205 HIGHWAY PLANNING AND CONSTRUCTION $12,894
66.605 PERFORMANCE PARTNERSHIP GRANTS $4,044
97.067 HOMELAND SECURITY GRANT PROGRAM $3,822
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $725