Finding 946842 (2022-003)

Documentation of Prevent Prepare and Respond Tieback Responsibilities - COVID-19 Community Development Block Grant/Entitlement Grants (AL #14.218) Criteria: Documentation should be maintained for assistance provided under the COVID-19 Community Development Block Grant/Entitlement Grants, that details how the activities prepare, prevent, and respond (PPR tieback) to coronavirus. Condition and Context: Remote monitoring by the U.S. Department of Housing and Urban Development noted that proper documentation of the PPR tieback responsibilities was not maintained. In particular, it was noted that the City did not provide a detailed and descriptive assessment that evidenced how all businesses met the PPR tieback. Cause: The City felt the assistance provided to businesses properly met the PPR tieback as it enabled retention of jobs at small businesses. Effects: The City was not in compliance with the documentation requirements. Recommendation: We recommend that the City prepare written representations that provide a full description of their assessment and conclusions that properly support their determination of allowability for each business which received assistance. We further recommend the City implement policies that require detailed written assessments and conclusions prior to approval and disbursement of funds. Auditee’s Response: As noted previously, the City’s Community Development Department is in the process of rewriting its Policies to include the CDBG-CV provisions The City’s updated policies will include the above recommendations.