Finding Text
2022-004 FAL # 14.218 Community Development Block Grants ? Detailed Time Sheets Condition: A prior year Community Development Block Grant (CDBG grant) was monitored by HUD. As a result of the monitoring, the client was made aware that additional detail may be needed to better support the payroll related expenditures charged to housing rehab and affordable housing allowance activities. Detailed time is not being kept of the amount of time spent on each specific activity, providing a description of the activity assisted, including its location (address). Criteria: Per 24 CFR 570.506 (a) Grantee shall establish and maintain sufficient records to enable the Secretary to determine whether the recipient has met the requirements of this part. At a minimum, the following records are needed: (a) records providing a full description of each activity assisted (or being assisted) with CDBG funds, including its location (if the activity has a geographical locus). Cause of Condition: Time allocated to the housing rehab and affordable housing function is documented on time sheets submitted to the Finance Department. However, the detail of the time charged to the specific activities is not being retained in a distinct orderly fashion that can be reconciled to the time charged per the time sheet. Effect: Administrative costs under the CDBG grant have a 20% cap. Amounts could be erroneously charged to an activity thereby reducing the amount charged to administrative costs. Administrative costs if they had been reported correctly could exceed the cap resulting in unallowed costs. Recommendation: Detail time of all housing rehabilitation, affordable housing and any other activities charged with payroll costs should be retained. The records of the time should include a full description of the activity assisted including its location (if the activity has a geographical locus). The detail time retained should be easily traceable to the time charged to each activity per the time sheets submitted to the Finance Department. Views of Responsible Officials and Planned Corrective Actions: The City has hired a consultant to assist staff with administration of the Community Development Block Grants program. If necessary, the Community Development Director will work with the consultant to develop a detailed timekeeping system to report time and activity spent on the programs and a retention policy.