Finding Text
Assistance Listing, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
Federal Award Identification Number and Year - B-22-MC-26-0008/B-23-MC-26-0008
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - 24 CFR Part 58 requires enivronmental review procedures for entities assuming HUD environmental responsibilities.
Condition - Tiered environmental reviews were not completed for the City’s emergency and minor home rehabilitation activities. The environmental review for major rehabilitation activities was incomplete and was not submitted in HEROS.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During a monitoring visit by HUD in March 2023, it was noted that environmental reviews were incomplete or not completed. These findings related to program year 2022. The environmental reviews were subsequently completed and the finding was closed out by HUD in March 2024.
Cause and Effect - Certain activities did not have environmental reviews conducted or the reviews were incomplete. Federal funds were spent prior to ensuring that the activity did not cause an adverse effect on the environment.
Recommendation - Internal controls should be implemented to ensure environmental reviews are completed for all applicable activities.
Views of Responsible Officials and Corrective Action Plan - This finding was partly due to the staff members' need for more training. HUD mandated that staff undergo training on HEROS as part of the resolution. The extra training enabled staff to revisit and finalize previous environmental reviews, ensuring compliance with environmental review regulations. After a follow up with HUD, the agency considers the issue resolved. Going forward, environmental reviews will be conducted once every five years, which is in compliance with HUD regulations. Tiered reviews will be added as projects are completed. Our rehab specialist will be responsible for entries in HEROS, and the division director will be responsible for public notices and hearings.