Finding 35165 (2022-004)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-09-12
Audit: 29946
Organization: City of Woonsocket (RI)

AI Summary

  • Core Issue: The City failed to obtain necessary certifications and HUD approvals before spending funds, leading to potential compliance violations.
  • Impacted Requirements: CDBG funds cannot be spent without HUD's approval of a Request for Release of Funds and environmental certification.
  • Recommended Follow-Up: Implement stronger controls to ensure all expenditures receive the required certifications and approvals before funds are obligated.

Finding Text

Special Tests ? Required Certifications and HUD Approvals (Significant Deficiency ? Special Tests) Condition: During performing procedures and testing over compliance with Special Tests ? Required Certifications and HUD Approvals, we noted the City did not obtain the required certifications or approvals before obligating or expending funds. Criteria: The Uniform Guidance states that ?CDBG funds (and local funds to be reimbursed with CDBG funds) cannot be obligated or expended before receipt of HUD?s approval of a Request for Release of Funds (RROF) and environmental certification?. Cause: The design and operation of controls appear to be ineffective regarding ensuring proper certification and approval for CDBG expenditures. Effect: Potential unallowable costs being charged to the grant and noncompliance with HUD regulations. Isolated Instance or Systematic Problem: Systematic problem. Repeat of Finding in the Immediately Prior Audit (with Prior Year Audit Finding Number (where applicable)): Yes ? 2021-003 Recommendation: We recommend the City ensure that expenditures are approved only after obtaining proper certifications and approvals.

Corrective Action Plan

Name of Contact Person: Alyssa McDermott Corrective Action Plan: In the past year, the City has worked to develop an updated set of policies and procedures for the CDBG program and has engaged in substantial Environmental Review training. For all Environmental Reviews that are Exempt or Categorically Excluded Not Subject to Section 58.5, no Request for Release of Funds is necessary. For Environmental Reviews that are Categorically Excluded, Subject to Section 58.5, the review is conducted to determine if there are any circumstances which require compliance with any of the federal laws and authorities cited at ?58.5. If not, funds may be committed and drawn down without the need to submit a Request for Release of Funds. In the event that a project is Categorically Excluded, Subject to Section 58.5, and there are circumstances which require compliance with one or more federal laws and authorities cited at ?58.5, the City completes all required consultation and mitigation protocol requirements, publishes the Notice of Intent to Request Release of Funds, and obtains the required ?Authority to Use Grant Funds? (HUD 7015.16) per Section 58.70 and 58.71 before committing or drawing down any funds. Similarly, all Environmental Assessments are subject to the RROF process, based on whether there is a Finding of No Significant Impact or a Finding of Significant Impact. City staff is following all specific requirements of 24 CFR Part 58. Proposed Completion Date: 6/30/23

Categories

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 35164 2022-003
    Significant Deficiency
  • 35166 2022-005
    Significant Deficiency
  • 35167 2022-006
    Significant Deficiency
  • 35168 2022-003
    Significant Deficiency
  • 35169 2022-004
    Significant Deficiency
  • 35170 2022-005
    Significant Deficiency
  • 35171 2022-006
    Significant Deficiency
  • 35172 2022-002
    Material Weakness
  • 35173 2022-007
    Material Weakness
  • 35174 2022-008
    Significant Deficiency
  • 611606 2022-003
    Significant Deficiency
  • 611607 2022-004
    Significant Deficiency
  • 611608 2022-005
    Significant Deficiency
  • 611609 2022-006
    Significant Deficiency
  • 611610 2022-003
    Significant Deficiency
  • 611611 2022-004
    Significant Deficiency
  • 611612 2022-005
    Significant Deficiency
  • 611613 2022-006
    Significant Deficiency
  • 611614 2022-002
    Material Weakness
  • 611615 2022-007
    Material Weakness
  • 611616 2022-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $10.13M
84.010 Title I Grants to Local Educational Agencies $4.56M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.91M
84.027 Special Education_grants to States $1.82M
10.555 National School Lunch Program $1.61M
14.239 Home Investment Partnerships Program $1.58M
10.559 Summer Food Service Program for Children $1.12M
10.553 School Breakfast Program $969,111
84.287 Twenty-First Century Community Learning Centers $910,968
84.367 Improving Teacher Quality State Grants $629,713
97.044 Assistance to Firefighters Grant $525,205
84.371 Striving Readers $426,163
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $367,804
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $367,030
14.218 Community Development Block Grants/entitlement Grants $265,504
14.905 Lead Hazard Reduction Demonstration Grant Program $260,737
84.048 Career and Technical Education -- Basic Grants to States $221,382
84.365 English Language Acquisition State Grants $137,405
84.196 Education for Homeless Children and Youth $63,526
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $62,211
84.173 Special Education_preschool Grants $46,069
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $43,762
16.738 Edward Byrne Memorial Justice Assistance Grant Program $35,683
14.231 Emergency Solutions Grant Program $30,627
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $22,049
93.434 Every Student Succeeds Act/preschool Development Grants $21,691
97.067 Homeland Security Grant Program $11,025
84.424 Student Support and Academic Enrichment Program $9,260