Finding Text
Finding Reference Number: SA 2021-005 Duplication of Benefits Compliance Documentation
AL Number: 14.218
Assistance Listing Title: COVID-19 - Community Development Block Grants/Entitlement Grants (CDBG)
Federal Agency: Department of Housing and Urban Development
Federal Award Identification Number: B-14-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037
Criteria: All CDBG-CV grantees are required to establish and maintain adequate procedures to prevent any duplication of benefits for assisted activities (as discussed in Section III.B.9. of the CDBG-CV Notice). To demonstrate that no financial assistance has been received or is available to pay costs charged to a CDBG-CV grant, a grantee may demonstrate that no other funds are available for an activity by maintaining records of compliance with mandatory duplication of benefits requirements described in Section III.B.9.
Condition: It appears the City did develop a policy to address duplication of benefits per our review of the City's Duplication of Benefits Policy & Procedures document that includes a certification form to be used for applicable projects. We requested a copy of the certification for the Davis Emergency Shelter project funded by the CDBG-CV funding and City staff was unable to locate the certification.
Effect: The City is not in compliance with the duplication of benefits documentation requirements to ensure no financial assistance has been received or is available to pay costs charged to a CDBG-CV grant.
Cause: We understand that City staff in charge of the project are no longer with the City, so current City staff are unable to determine whether the duplication of benefits certification required by the City’s policy was completed.
Recommendation: City staff should develop procedures to ensure that CDBG-CV grant-funded projects documentation includes the duplication of benefits certification.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.