Finding 391231 (2023-003)

Significant Deficiency Repeat Finding
Requirement
H
Questioned Costs
-
Year
2023
Accepted
2024-04-01
Audit: 301866
Organization: City and County of Honolulu (HI)
Auditor: Accuity LLP

AI Summary

  • Core Issue: The City is out of compliance with HUD's 60-day timeliness test, having a line-of-credit balance 1.66 times its annual grant.
  • Impacted Requirements: This violates 24 CFR Section 570.902, which allows no more than 1.5 times the annual grant in the line of credit 60 days before the program year ends.
  • Recommended Follow-Up: The City should implement procedures to meet CDBG timeliness standards and adhere to the workout plan submitted to HUD.

Finding Text

Condition The Department of Housing and Urban Development (“HUD”) notified the City, via letter dated May 31, 2023, that the City was not in compliance with the 60 day timeliness test conducted May 2, 2023, as the City had a line-of-credit balance 1.66 times its annual grant. Criteria 24 CFR Section 570.902 of the CDBG regulations states that a grantee is in compliance with timely expenditure requirements if, 60 days prior to the end of its program year, there is no more than 1.5 times its annual grant remaining in the line of credit, including any program income on hand. Effect Failure to meet the timeliness standard results in noncompliance with the period of performance requirement and could result in sanctions and reduction of future grant funds. However, HUD granted the City an exception to the timeliness requirements for the FY2023 grant year due to the lingering impacts of the COVID 19 pandemic. Cause The failure to meet the timeliness requirement was primarily due to the impact of the COVID‐19 pandemic compounded by supply chain issues. Recommendation We recommend that the City establish procedures to ensure that it complies with the CDBG timeliness standard specified in 24 CFR Section 570.902. In addition, we recommend that the City ensures that it adheres to the workout plan it submitted to HUD.

Corrective Action Plan

Finding No. 2023-003: Period of Performance (Significant Deficiency - Internal Control Over Compliance) Federal Award: 14.218 - CDBG – Entitlement Grants Cluster Audit Recommendation: We recommend that the City establish procedures to ensure that it complies with the CDBG timeliness standard specified in 24 CFR Section 570.902. In addition, we recommend that the City ensures that it adheres to the workout plan it submitted to HUD. Administration’s Comment: The City will adhere to procedures to comply with the CDBG timeliness standard specified in 24 CFR 570.902. Anticipated Completion Date: May 2024 Contact Person(s): Holly Kawano, Department of Budget and Fiscal Services, Federal Grants Coordinator

Categories

HUD Housing Programs Period of Performance Program Income

Other Findings in this Audit

  • 391232 2023-003
    Significant Deficiency Repeat
  • 391233 2023-004
    Material Weakness
  • 391234 2023-004
    Material Weakness
  • 391235 2023-005
    Significant Deficiency
  • 391236 2023-005
    Significant Deficiency
  • 391237 2023-005
    Significant Deficiency
  • 391238 2023-006
    Material Weakness
  • 391239 2023-007
    Significant Deficiency
  • 391240 2023-008
    Significant Deficiency
  • 967673 2023-003
    Significant Deficiency Repeat
  • 967674 2023-003
    Significant Deficiency Repeat
  • 967675 2023-004
    Material Weakness
  • 967676 2023-004
    Material Weakness
  • 967677 2023-005
    Significant Deficiency
  • 967678 2023-005
    Significant Deficiency
  • 967679 2023-005
    Significant Deficiency
  • 967680 2023-006
    Material Weakness
  • 967681 2023-007
    Significant Deficiency
  • 967682 2023-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $130.81M
14.871 Section 8 Housing Choice Vouchers $70.62M
21.023 Emergency Rental Assistance Program $40.12M
14.218 Community Development Block Grants/entitlement Grants $13.40M
66.458 Capitalization Grants for Clean Water State Revolving Funds $12.31M
20.507 Federal Transit_formula Grants $10.08M
14.239 Home Investment Partnerships Program $3.07M
14.879 Mainstream Vouchers $1.68M
16.575 Crime Victim Assistance $1.46M
20.205 Highway Planning and Construction $1.45M
95.001 High Intensity Drug Trafficking Areas Program $1.34M
17.259 Wia Youth Activities $757,469
17.258 Wia Adult Program $714,256
20.600 State and Community Highway Safety $658,274
14.241 Housing Opportunities for Persons with Aids $656,796
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $648,704
14.231 Emergency Solutions Grant Program $639,968
16.741 Dna Backlog Reduction Program $624,346
16.034 Coronavirus Emergency Supplemental Funding Program $616,606
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $592,873
97.042 Emergency Management Performance Grants $577,806
17.278 Wia Dislocated Worker Formula Grants $544,444
20.607 Alcohol Open Container Requirements $500,057
16.922 Equitable Sharing Program $414,981
17.274 Youthbuild $399,431
10.559 Summer Food Service Program $396,563
97.067 Homeland Security Grant Program $325,516
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $278,803
93.053 Nutrition Services Incentive Program $265,618
20.616 National Priority Safety Programs $258,885
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $234,408
14.896 Family Self-Sufficiency Program $205,095
93.052 National Family Caregiver Support, Title Iii, Part E $184,533
16.738 Edward Byrne Memorial Justice Assistance Grant Program $171,478
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $153,836
21.019 Coronavirus Relief Fund $143,000
97.045 Cooperating Technical Partners $142,763
97.039 Hazard Mitigation Grant $116,242
16.588 Violence Against Women Formula Grants $113,120
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $104,843
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $87,667
94.002 Retired and Senior Volunteer Program $76,762
16.320 Services for Trafficking Victims $74,564
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $73,867
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $32,000
93.136 Injury Prevention and Control Research and State and Community Based Programs $31,099
16.710 Public Safety Partnership and Community Policing Grants $25,960
84.287 Twenty-First Century Community Learning Centers $13,088
10.935 Urban Agriculture and Innovative Production $10,000
59.075 Shuttered Venue Operators Grant Program $8,984
21.016 Equitable Sharing $1,984
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $147