Finding 1240166 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-10-08
Audit: 414736
Organization: Noble County (OH)

AI Summary

  • Core Issue: The County failed to establish necessary policies and procedures for complying with Section 3 of the Housing and Urban Development Act, leading to incomplete reporting of Section 3 accomplishments.
  • Impacted Requirements: Non-compliance with 24 CFR § 75.25 reporting requirements may result in actions from the grantor due to insufficient controls and lack of monitoring.
  • Recommended Follow-Up: Implement robust policies and procedures to ensure adherence to Section 3 guidelines and accurate reporting in the Disaster Recovery Grant Reporting System (DRGR).

Finding Text

24 CFR § 75.1 establishes the requirements to be followed to ensure the objectives of Section 3 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701u) (Section 3) are met. The purpose of Section 3 is to ensure that economic opportunities, most importantly employment, generated by certain HUD financial assistance shall be directed to low- and very low-income persons, particularly those who are recipients of government assistance for housing or residents of the community in which the Federal assistance is spent. 24 CFR § 75.3(a)(2)(i) further states that Section 3 projects means housing rehabilitation, housing construction, and other public construction projects assisted under HUD programs that provide housing and community development financial assistance when the total amount of assistance to the project exceeds a threshold of $200,000. 24 CFR § 75.9(A)(1) states that, consistent with existing Federal, state, and local laws and regulations, PHAs and other recipients of public housing financial assistance, and their contractors and subcontractors must make their best efforts to award contracts and subcontracts to business concerns that provide economic opportunities to Section 3 workers. 24 CFR § 75.25(a) Reporting of labor hours. 1) For Section 3 projects, recipients must report in a manner prescribed by HUD: i. The total number of labor hours worked; ii. The total number of labor hours worked by Section 3 workers; and iii. The total number of labor hours worked by Targeted Section 3 workers. 2) Section 3 workers' and Targeted Section 3 workers' labor hours may be counted for five years from when their status as a Section 3 worker or Targeted Section 3 worker is established pursuant to § 75.31. 3) The labor hours reported under paragraph (a)(1) of this section must include the total number of labor hours worked on a Section 3 project, including labor hours worked by any subrecipients, contractors and subcontractors that the recipient is required, or elects pursuant to paragraph (a)(4) of this section, to report. 4) Recipients reporting under this section, as well as subrecipients, contractors and subcontractors who report to recipients, may report labor hours by Section 3 workers, under paragraph (a)(1)(ii) of this section, and labor hours by Targeted Section 3 workers, under paragraph (a)(1)(iii) of this section, from professional services without including labor hours from professional services in the total number of labor hours worked under paragraph (a)(1)(i) of this section. If a contract covers both professional services and other work and the recipient or contractor or subcontractor chooses not to report labor hours from professional services, the labor hours under the contract that are not from professional services must still be reported. 5) Recipients may report their own labor hours or that of a subrecipient, contractor, or subcontractor based on the employer's good faith assessment of the labor hours of a full-time or part-time employee informed by the employer's existing salary or time and attendance-based payroll systems, unless the project or activity is otherwise subject to requirements specifying time and attendance reporting. Grant Agreement No. B-22-CP-OH-0725 Article IV General Federal Requirements (M) states the grantee must comply with Section 3 of the Housing and Urban Development Act of 1968 (Section 3), 12 USC 1701u, and HUD's regulations at 24 CFR part 75 as applicable, including reporting requirements in 24 CFR 75.25. This section further states grantees that are not exempt from Section 3 must submit annual reports of Section 3 accomplishment performance measure in DRGR in January of the calendar year which reflects Section 3 accomplishments of the previous year. The County did not establish any policies/procedures related to Section 3. Further, the County did not include Section 3 accomplishments in their semi-annual performance reports submitted in the Disaster Recovery Grant Reporting System (DRGR). The failure to submit Section 3 accomplishments on semi-annual performance reports was due to insufficient controls and could result in action taken by the grantor. Further, the County did not have adequate policies and procedures in place to monitor the reporting of Section 3 requirements. Additional controls should be implemented to help ensure the County is adhering to Section 3 guidelines and submitting the required Section 3 accomplishments in their semi-annual performance reports submitted in DRGR. Further, the County should implement policies and procedures to ensure Section 3 requirements are met.

Corrective Action Plan

The County Commissioners and Auditor will monitor this internally.

Categories

HUD Housing Programs

Other Findings in this Audit

  • 1240165 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $2.24M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $396,456
23.001 APPALACHIAN REGIONAL DEVELOPMENT (SEE INDIVIDUAL APPALACHIAN PROGRAMS) $368,032
93.778 GRANTS TO STATES FOR MEDICAID $114,915
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $101,147
17.259 WIOA YOUTH ACTIVITIES $88,871
17.258 WIOA ADULT PROGRAM $88,846
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $62,659
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $51,410
16.554 NATIONAL CRIMINAL HISTORY IMPROVEMENT PROGRAM (NCHIP) $46,710
93.563 CHILD SUPPORT SERVICES $45,267
93.658 FOSTER CARE TITLE IV-E $37,960
93.659 ADOPTION ASSISTANCE $37,960
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $33,013
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $32,247
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $16,670
20.205 HIGHWAY PLANNING AND CONSTRUCTION $15,480
97.047 BRIC: BUILDING RESILIENT INFRASTRUCTURE AND COMMUNITIES $15,250
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $6,666
16.575 CRIME VICTIM ASSISTANCE $4,208
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $3,554
93.667 SOCIAL SERVICES BLOCK GRANT $3,137
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $2,919
15.226 PAYMENTS IN LIEU OF TAXES $1,484
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $1,339
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $340
10.665 SCHOOLS AND ROADS - GRANTS TO STATES $282
15.438 NATIONAL FOREST ACQUIRED LANDS $266