FAC Explorer

Finding 34658 (2022-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-06-22
Audit: 32407
Organization: Dallas County (TX)
Auditor: Deloitte & Touche LLP

AI Summary

  • Core Issue: Documentation for environmental reviews was lost, preventing verification of exempt status for CDBG projects.
  • Impacted Requirements: CDBG funds cannot be spent without HUD approval and proper environmental certification, risking noncompliance.
  • Recommended Follow-Up: Implement a reliable system for storing and backing up important documentation to prevent future losses.

Finding Text

Finding 2022-03: Special Tests ? Required Certifications and HUD Approvals and Environmental Reviews ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants (CDBG) Criteria ? CDBG funds (and local funds to be reimbursed with CDBG funds) cannot be obligated or expended before receipt of Department of Housing and Urban Development (HUD) approval of a Request for Release of Funds (RROF) and environmental certification, except for exempt activities under 24 CFR section 58.34 Projects must have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from Request for Release of Funds (RROF) and environmental certification requirements (24 CFR sections 58.1, 58.22, 58.34, 58.35, and 570.604). Accordingly, the grantee should maintain documentation if any determination not to make an environmental review was made consistent with the criteria contained in 24 CFR sections 58.34 and 58.35(b). Condition/Context ? Per discussion with grant management, the documentation substantiating the exempt status of the environmental reviews were completed, however the documentation was lost due to unforeseen circumstances and was unavailable for observation during the audit process. Per our understanding of the projects and discussions with management, the projects are effectively exempt based on 24 CFR 58.34. However, the exempt status of the projects could not be verified because the documentation was not properly retained by the County. Cause ? During the year the grant management team had to relocate, and the physical documentation got misplaced during the process. The grant manager handling the documentation of the environmental reviews experienced technology issues which further caused a loss of information. Effect ? Failure to retain or backup documentation could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for storing and backing up documentation pertaining to environmental review. Views of Responsible Officials ? See Corrective Action Plan

Categories

Cash Management HUD Housing Programs Significant Deficiency Special Tests & Provisions

Other Findings in this Audit

  • 34655 2022-004
    Significant Deficiency
  • 34656 2022-003
    Significant Deficiency
  • 34657 2022-004
    Significant Deficiency
  • 34659 2022-002
    Significant Deficiency
  • 34660 2022-002
    Significant Deficiency
  • 611097 2022-004
    Significant Deficiency
  • 611098 2022-003
    Significant Deficiency
  • 611099 2022-004
    Significant Deficiency
  • 611100 2022-003
    Significant Deficiency
  • 611101 2022-002
    Significant Deficiency
  • 611102 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $49.19M
21.023 Emergency Rental Assistance Program $26.78M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $16.90M
21.019 Coronavirus Relief Fund $15.18M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $10.53M
93.268 Immunization Cooperative Agreements $4.48M
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $2.48M
20.205 Highway Planning and Construction $2.26M
84.425 Education Stabilization Fund $2.07M
93.686 Ending the Hiv Epidemic: A Plan for America Ryan White Hiv/aids Program Parts A and B (b) $1.86M
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $1.86M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $1.72M
93.940 Hiv Prevention Activities_health Department Based $1.54M
93.566 Refugee and Entrant Assistance_state Administered Programs $1.33M
14.231 Emergency Solutions Grant Program $1.17M
14.218 Community Development Block Grants/entitlement Grants $962,221
16.606 State Criminal Alien Assistance Program $856,696
93.137 Community Programs to Improve Minority Health Grant Program $845,865
16.575 Crime Victim Assistance $830,109
16.593 Residential Substance Abuse Treatment for State Prisoners $797,619
93.778 Medical Assistance Program $762,719
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $715,757
84.010 Title I Grants to Local Educational Agencies $671,340
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $568,957
14.241 Housing Opportunities for Persons with Aids $541,865
10.555 National School Lunch Program $518,706
14.879 Mainstream Vouchers $499,971
93.568 Low-Income Home Energy Assistance $499,525
93.944 Human Immunodeficiency Virus (hiv)/acquired Immunodeficiency Virus Syndrome (aids) Surveillance $494,936
16.922 Equitable Sharing Program $390,127
81.042 Weatherization Assistance for Low-Income Persons $385,554
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $352,444
21.016 Equitable Sharing $327,365
16.588 Violence Against Women Formula Grants $290,732
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $285,843
10.553 School Breakfast Program $283,427
93.270 Adult Viral Hepatitis Prevention and Control $257,990
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $255,568
93.914 Hiv Emergency Relief Project Grants $233,573
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $232,861
96.001 Social Security_disability Insurance $213,300
97.067 Homeland Security Grant Program $201,280
16.123 Community-Based Violence Prevention Program $191,796
16.838 Comprehensive Opioid Abuse Site-Based Program $185,026
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $164,054
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $156,106
93.070 Environmental Public Health and Emergency Response $149,742
16.738 Edward Byrne Memorial Justice Assistance Grant Program $148,829
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $141,822
90.404 2018 Hava Election Security Grants $114,522
16.585 Drug Court Discretionary Grant Program $110,776
14.239 Home Investment Partnerships Program $104,341
16.833 National Sexual Assault Kit Initiative $88,953
14.896 Family Self-Sufficiency Program $74,361
93.991 Preventive Health and Health Services Block Grant $60,279
97.091 Homeland Security Biowatch Program $48,000
84.424 Student Support and Academic Enrichment Program $40,388
16.540 Juvenile Justice and Delinquency Prevention_allocation to States $29,055
95.001 High Intensity Drug Trafficking Areas Program $19,318
16.034 Coronavirus Emergency Supplemental Funding Program $18,339
84.367 Improving Teacher Quality State Grants $17,263
84.027 Special Education_grants to States $15,285
93.008 Medical Reserve Corps Small Grant Program $13,191
93.917 Hiv Care Formula Grants $10,964
21.027 Coronavirus State and Local Fiscal Recovery Funds $7,288
84.365 English Language Acquisition State Grants $3,099
84.184 Safe and Drug-Free Schools and Communities_national Programs $974
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $568