Finding 401660 (2023-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-06-24
Audit: 309614
Organization: City of Livonia, Michigan (MI)

AI Summary

  • Core Issue: Environmental reviews for emergency and minor home rehabilitation activities were incomplete, violating HUD regulations.
  • Impacted Requirements: 24 CFR Part 58 mandates that all applicable activities undergo proper environmental review procedures.
  • Recommended Follow-Up: Implement internal controls and provide staff training to ensure timely completion of environmental reviews and compliance with HUD regulations.

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.

Categories

Subrecipient Monitoring HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 401659 2023-002
    Material Weakness
  • 978101 2023-002
    Material Weakness
  • 978102 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $279,280
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $173,832
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $52,590
10.569 Emergency Food Assistance Program (food Commodities) $44,712
97.042 Emergency Management Performance Grants $34,878
20.507 Federal Transit_formula Grants $32,691
14.239 Home Investment Partnerships Program $31,903
16.U02 Federal Bureau of Investigation - Detroit Major Crimes Task Force $18,392
20.600 State and Community Highway Safety $14,485
16.U01 U.s. Marshals - Detroit Fugitive Apprehension Task Force $13,204
16.738 Edward Byrne Memorial Justice Assistance Grant Program $12,191
16.922 Equitable Sharing Program $960