Finding 540441 (2024-002)

Significant Deficiency Repeat Finding
Requirement
H
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 350255
Organization: City and County of Honolulu (HI)
Auditor: Kmh LLP

AI Summary

  • Core Issue: The City failed to meet the 60-day timeliness test, with a line-of-credit balance of 1.71 times its annual grant.
  • Impacted Requirements: This is the third consecutive year of noncompliance with 24 CFR section 570.902, risking sanctions and future grant reductions.
  • Recommended Follow-Up: The City should follow the submitted workout plan to ensure compliance by May 2, 2025.

Finding Text

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. Condition: The Department of Housing and Urban Development (the “HUD”) notified the City, in a letter dated June 4, 2024, that the City was not in compliance with the 60-day timeliness test conducted May 2, 2024, as the City had a line-of-credit balance of 1.71 times its annual grant. Context: According to the HUD letter dated June 4, 2024, this is the third consecutive year that the City was not noncompliant with 24 CFR section 570.902. The HUD required the City to develop a workout plan describing the steps the City will take to ensure compliance by May 2, 2025. The City submitted a workplan to the HUD in a letter dated June 10, 2024 . HUD granted the City an exception to the timely expenditure requirements for the 2024 grant year due to factors beyond the City’s reasonable control. Cause: Based on our discussions with City management, the failure to meet the timely expenditure requirement was primarily due to capital projects delays and supply chain issues , which were beyond the program’s control. Effect: Failure to meet the timeliness standard results in noncompliance with the period of performance requirement and could result in sanctions and reduction in future grant funds. Questioned Costs: None Identification as a Repeat Finding, if applicable: See finding 2023-003 included in the Summary Schedule of Prior Audit Findings. Recommendation: We recommend the City adhere to the workout plan submitted to HUD to comply with the CDBG timely expenditure requirements. Views of Responsible Officials: Client agrees with finding, and the unabridged version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the City.

Corrective Action Plan

Finding No. 2024-002: Period of Performance (Significant Deficiency – Federal Awards) Federal Award: 14.218 - CDBG – Entitlement Grants Cluster Audit Recommendation: We recommend the City adhere to the workout plan submitted to HUD to comply with the CDBG timely expenditure requirements. Administration’s Comments: The City will adhere to procedures to comply with the CDBG timeliness standard specified. Anticipated Completion Date: June 30, 2025 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

  • 540442 2024-002
    Significant Deficiency Repeat
  • 540443 2024-003
    Material Weakness
  • 540444 2024-003
    Material Weakness
  • 1116883 2024-002
    Significant Deficiency Repeat
  • 1116884 2024-002
    Significant Deficiency Repeat
  • 1116885 2024-003
    Material Weakness
  • 1116886 2024-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
20.500 Federal Transit Capital Investment Grants $188.75M
21.027 Coronavirus State and Local Fiscal Recovery Funds $73.61M
20.507 Federal Transit Formula Grants $58.88M
66.458 Clean Water State Revolving Fund $22.45M
14.218 Community Development Block Grants/entitlement Grants $9.83M
14.871 Section 8 Housing Choice Vouchers $7.15M
14.239 Home Investment Partnerships Program $4.42M
97.067 Homeland Security Grant Program $3.78M
14.879 Mainstream Vouchers $1.68M
95.001 High Intensity Drug Trafficking Areas Program $1.44M
16.575 Crime Victim Assistance $1.42M
17.258 Wioa Adult Program $1.08M
17.259 Wioa Youth Activities $1.02M
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $975,445
20.205 Highway Planning and Construction $968,620
14.231 Emergency Solutions Grant Program $933,457
93.558 Temporary Assistance for Needy Families $930,457
17.278 Wioa Dislocated Worker Formula Grants $573,592
14.241 Housing Opportunities for Persons with Aids $534,659
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $522,740
97.044 Assistance to Firefighters Grant $510,374
20.616 National Priority Safety Programs $471,631
97.045 Cooperating Technical Partners $462,468
20.600 State and Community Highway Safety $419,322
16.741 Dna Backlog Reduction Program $394,320
93.053 Nutrition Services Incentive Program $362,236
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $335,385
97.042 Emergency Management Performance Grants $334,555
10.559 Summer Food Service Program for Children $290,005
20.607 Alcohol Open Container Requirements $282,404
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $222,907
14.896 Family Self-Sufficiency Program $222,595
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $208,382
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $166,958
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $166,685
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $152,380
97.039 Hazard Mitigation Grant $151,808
16.922 Equitable Sharing Program $147,611
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $147,202
16.710 Public Safety Partnership and Community Policing Grants $133,173
93.136 Injury Prevention and Control Research and State and Community Based Programs $127,231
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $124,183
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $121,737
10.723 Community Project Funds - Congressionally Directed Spending $116,250
16.738 Edward Byrne Memorial Justice Assistance Grant Program $106,002
93.052 National Family Caregiver Support, Title Iii, Part E $89,981
10.935 Urban Agriculture and Innovative Production $80,000
16.588 Violence Against Women Formula Grants $78,015
17.274 Youthbuild $75,848
16.825 Smart Prosecution Initiative $70,000
16.320 Services for Trafficking Victims $51,686
66.046 Climate Pollution Reduction Grants $33,693
84.287 Twenty-First Century Community Learning Centers $32,189
21.023 Emergency Rental Assistance Program $28,288
16.034 Coronavirus Emergency Supplemental Funding Program $27,496
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $22,995
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $6,552
21.016 Equitable Sharing $5,215
10.575 Farm to School Grant Program $3,261