FAC Explorer

Finding 479014 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-07-19
Audit: 315527
Organization: Arapahoe County, Colorado (CO)
Auditor: Cliftonlarsonallen

AI Summary

  • Core Issue: The County failed to conduct required inspections of HOME-assisted rental housing units in 2023.
  • Impacted Requirements: This violates 24 CFR section 92.504(d), which mandates on-site inspections during the affordability period.
  • Recommended Follow-up: Enhance training for personnel to ensure timely completion of inspections moving forward.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Program Assistance Listing Numbers: 14.239 Award Period: January 1, 2023 through December 31, 2023 Award Number: M-18-DC-08-0221, M-19-DC-08-0221, M-20-DC-08-0221, M-21-DC-08-0221, M-22-DC- 08-0221, and M-23-DC-08-0221 Compliance Requirement: Special Tests and Provisions – Housing Quality Standards Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 24 CFR section 92.504(d), during the period of affordability, the participating jurisdiction (the County) is required to perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners. Condition: The County did not conduct the required inspections of the HOME-assisted rental housing units during the year ended December 31, 2023. Questioned costs: None Context: Inspections can be required for as much as 20 years and occur at a frequency from one to three years, depending on the number of units in the building. Cause: Personnel issues led to the County not completing the inspections. Effect: HOME-assisted rental units could be out of compliance with HUD regulations which can impact tenants. Repeat Finding: No. Recommendation: We recommend the County continue to train personnel so that the inspections are completed timely. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County continue to train personnel so that the inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2023, performance issues with the administration of the HOME program were discovered, to include the absence of required inspections. With significant turnover of tenured leadership and employees within the Community Resources Department, Arapahoe County Community Resources took proactive measures in 2023 for review of the Community Development Housing and Homeless Services (CDHHS) programs by recognized consultants within the field. Community Resources has contracted with two consultants, to assist in a full review and re-development of policies and procedures (Civitas) for the CDBG and HOME programs as well as a full review of all case files (Affordable Housing Consultants). Included with this response are the contracts with both Civitas and Affordable Housing Consultants for verification purposes. The County anticipates their work to be completed and an implementation of updated policies and procedures for these programs by fall of 2024. The role of Program Administrator over the HOME program was not filled until April of 2024. This role will be responsible for all future HOME program inspections. Community Resources CDHHS employees will be taking part in a two-day training in June 2024 (June 11th and 12th, 2024) for the following:  Davis Bacon & Related Acts (Applicability, wage determinations, payroll review, interviews, common errors and how to correct)  Section 3 (Applicability, Safe Harbor benchmarks, documenting compliance, qualitative efforts)  TBRA Inspections (National Standards for the Physical Inspection of Real Estate (NSPIRE) administrative procedures)  HOME Program - Implementation and Best Practices - Arapahoe County, CO - June 12, 2024  This HOME training is an introductory course focusing on underwriting and subsidy layering requirements.  Eligible Activities (Homeowner rehab programs, Homebuyer programs, Rental housing)  Underwriting (Subsidy layering and underwriting requirements and best practices)  Community Housing Development Organization (CHDO) (Requirements, best practices, management, etc)  Long-term Compliance (HOME Match, eligible beneficiaries, income limits, subsidy layering & limits, affordability, written agreements, etc)  IDIS and Reporting Arapahoe County staff will be conducting monitoring of the two Tenant Based Rental Assistance (TBRA) programs and projects within in the affordability period (20-year span) between mid-June to mid-August of 2024. The remaining HOME program projects, within the affordability period (20-year span) will have audits completed by the end of our 2023 grant cycle, September 30th, 2024. Name of the contact person responsible for corrective action: Katherine Smith Planned completion date for corrective action plan: September 30, 2024

Categories

Special Tests & Provisions HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 478998 2023-001
    Material Weakness
  • 478999 2023-001
    Material Weakness
  • 479000 2023-001
    Material Weakness
  • 479001 2023-001
    Material Weakness
  • 479002 2023-001
    Material Weakness
  • 479003 2023-001
    Material Weakness
  • 479004 2023-001
    Material Weakness
  • 479005 2023-001
    Material Weakness
  • 479006 2023-001
    Material Weakness
  • 479007 2023-001
    Material Weakness
  • 479008 2023-001
    Material Weakness
  • 479009 2023-001
    Material Weakness
  • 479010 2023-001
    Material Weakness
  • 479011 2023-001
    Material Weakness
  • 479012 2023-001
    Material Weakness
  • 479013 2023-001
    Material Weakness
  • 479015 2023-002
    Significant Deficiency
  • 479016 2023-002
    Significant Deficiency
  • 479017 2023-002
    Significant Deficiency
  • 479018 2023-002
    Significant Deficiency
  • 479019 2023-002
    Significant Deficiency
  • 479020 2023-002
    Significant Deficiency
  • 1055440 2023-001
    Material Weakness
  • 1055441 2023-001
    Material Weakness
  • 1055442 2023-001
    Material Weakness
  • 1055443 2023-001
    Material Weakness
  • 1055444 2023-001
    Material Weakness
  • 1055445 2023-001
    Material Weakness
  • 1055446 2023-001
    Material Weakness
  • 1055447 2023-001
    Material Weakness
  • 1055448 2023-001
    Material Weakness
  • 1055449 2023-001
    Material Weakness
  • 1055450 2023-001
    Material Weakness
  • 1055451 2023-001
    Material Weakness
  • 1055452 2023-001
    Material Weakness
  • 1055453 2023-001
    Material Weakness
  • 1055454 2023-001
    Material Weakness
  • 1055455 2023-001
    Material Weakness
  • 1055456 2023-002
    Significant Deficiency
  • 1055457 2023-002
    Significant Deficiency
  • 1055458 2023-002
    Significant Deficiency
  • 1055459 2023-002
    Significant Deficiency
  • 1055460 2023-002
    Significant Deficiency
  • 1055461 2023-002
    Significant Deficiency
  • 1055462 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.575 Child Care and Development Block Grant $11.92M
93.778 Medical Assistance Program $6.06M
20.205 Highway Planning and Construction $5.28M
93.563 Child Support Enforcement $5.27M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $2.98M
21.023 Emergency Rental Assistance Program $2.70M
93.659 Adoption Assistance $2.51M
81.042 Weatherization Assistance for Low-Income Persons $1.15M
93.568 Low-Income Home Energy Assistance $1.09M
21.027 Coronavirus State and Local Fiscal Recovery Funds $940,771
17.278 Wia Dislocated Worker Formula Grants $768,908
17.207 Employment Service/wagner-Peyser Funded Activities $603,098
97.067 Homeland Security Grant Program $583,807
93.569 Community Services Block Grant $579,943
93.658 Foster Care_title IV-E $535,350
17.270 Reintegration of Ex-Offenders $454,847
93.268 Immunization Cooperative Agreements $394,586
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $380,143
93.645 Stephanie Tubbs Jones Child Welfare Services Program $315,660
17.277 Workforce Investment Act (wia) National Emergency Grants $288,571
16.606 State Criminal Alien Assistance Program $253,582
17.259 Wia Youth Activities $208,649
93.940 Hiv Prevention Activities_health Department Based $183,037
17.268 H-1b Job Training Grants $175,393
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $139,281
10.551 Supplemental Nutrition Assistance Program $124,890
93.558 Temporary Assistance for Needy Families $124,201
17.285 Apprenticeship USA Grants $122,541
93.217 Family Planning_services $119,999
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $119,618
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $117,895
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $96,434
97.042 Emergency Management Performance Grants $92,982
93.994 Maternal and Child Health Services Block Grant to the States $76,256
93.667 Social Services Block Grant $65,595
14.218 Community Development Block Grants/entitlement Grants $64,070
93.917 Hiv Care Formula Grants $58,833
93.069 Public Health Emergency Preparedness $52,836
15.437 Minerals Leasing Act $50,880
17.225 Reemployment Services and Assessment (resea) Program $45,859
93.090 Guardianship Assistance $41,705
93.556 Promoting Safe and Stable Families $41,020
95.001 High Intensity Drug Trafficking Areas Program $33,147
17.280 Workforce Investment Act (wia) Dislocated Worker National Reserve Demonstration Grants $25,735
17.258 Wia Adult Program $25,708
14.239 Home Investment Partnerships Program $25,679
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $23,909
17.245 Trade Adjustment Assistance $22,919
16.738 Edward Byrne Memorial Justice Assistance Grant Program $21,960
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $19,277
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $18,308
93.317 Emerging Infections Programs $14,153
93.747 Elder Abuse Prevention Interventions Program $12,610
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $11,707
16.607 Bulletproof Vest Partnership Program $8,633
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $8,177
17.801 Jobs for Veterans State Grants $8,006
16.543 Missing Children's Assistance $6,620
17.804 Local Veterans' Employment Representative Program $4,003
20.600 State and Community Highway Safety $2,261
93.472 Title IV-E Prevention and Family Services and Programs (a) $594