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We audited Clark County, NV’s Community Development Block Grant (CDBG) program.  We selected Clark County for review due to its large grant size and the U.S. Department of Housing and Urban Development’s (HUD) risk assessment.  The reporting objective of the audit was to determine whether Clark County followed procurement requirements, ensured that CDBG projects met CDBG national objectives, and spent CDBG funds on eligible expenses.

Clark County did not have appropriate controls to ensure that it used CDBG funds in accordance with HUD requirements.  Specifically, it (1) did not ensure that it followed HUD procurement requirements, (2) did not ensure that one project met a CDBG national objective, and (3) spent CDBG funds on general government expenses.  This condition occurred because Clark County (1) did not have adequate controls and its controls were not always effective or implemented as written, (2)  was not aware that one project did not exclusively serve severely disabled adults, and (3) was not aware of all CDBG requirements.  As a result, it used CDBG funds for $119,720 in ineligible costs and $4.8 million in unsupported costs and budgeted an additional $33,603 for an ineligible CDBG activity.

We recommend that the Acting Director of HUD’s San Francisco Office of Community Planning and Development require Clark County to (1) repay the program $119,720 for ineligible costs, (2) support the eligibility of $4.8 million, (3) reallocate $33,603 to an eligible CBDG activity, (4) provide proof that the Americans with Disabilities Act (ADA) pool project meets ADA requirements through a third party or make the pool ADA compliant, (5) update its policies and procedures for monitoring procurement and contracting, and (6) provide training to its staff on program requirements.

Recommendation Status Date Issued Summary
2017-LA-1001-001-A Cerrado Abril 13, 2017 Support the reasonableness of the amount paid for the food facility consolidation and expansion project or repay the program $1,663,758 from non-Federal funds.
2017-LA-1001-001-B Cerrado Abril 13, 2017 Correct any citations from the Southern Nevada Health District at the Pettiti public pool before May 2017 using non-Federal funds or repay the entire project cost of $596,126 from non-Federal funds and support the reasonableness of the change orders for the Pettiti pool project or repay the program from non-Federal funds.
2017-LA-1001-001-C Cerrado Abril 13, 2017 Support the cost reasonableness of $2,809 in change orders for the ADA pool improvement project or repay the program from non-Federal funds.
2017-LA-1001-001-D Cerrado Abril 13, 2017 Provide supporting documentation for $4,955 in unsupported costs or repay the program from non-Federal funds.
2017-LA-1001-001-E Cerrado Abril 13, 2017 Provide support showing that the ADA pool improvement project allows equal and independent access for people with disabilities through a third party or correct the access issue.
2017-LA-1001-001-F Cerrado Abril 13, 2017 Develop and implement procurement policies and procedures for monitoring subrecipients to ensure that the scope of work developed by its subrecipients is sufficiently detailed to allow contractors to submit informed bids, reducing the number of change orders after the contract, and that its subrecipients do an independent cost analysis before all procurement transactions, including change orders, to ensure that it receives a reasonable price and allows for full and open competition.
2017-LA-1001-001-G Cerrado Abril 13, 2017 Develop and implement policies and procedures that ensure labor wage interviews are completed and documented.
2017-LA-1001-001-H Cerrado Abril 13, 2017 Provide training to its staff on CDBG program rules and requirements to ensure that its staff adequately implements policies and procedures.
2017-LA-1001-002-A Cerrado Abril 13, 2017 Identify the national objective met for the park project or repay the program $2,000,000 from non-Federal funds.
2017-LA-1001-002-B Cerrado Abril 13, 2017 Develop monitoring practices to ensure that all projects that use limited clientele criteria exclusively serve the specific population claimed.
2017-LA-1001-003-A Cerrado Abril 13, 2017 Repay $48,323 to the program from non-Federal funds for non-program-related payroll costs.
2017-LA-1001-003-B Cerrado Abril 13, 2017 Determine the allocable amount of CDBG payroll costs for the employees who worked on CDBG and non-CDBG activities and adjust the funding amount as necessary or repay the program $573,064 from non-Federal funds.
2017-LA-1001-003-C Cerrado Abril 13, 2017 Repay $71,397 to the program from non-Federal funds for the use of CDBG funds for code enforcement costs related to general government expenses.
2017-LA-1001-003-D Cerrado Abril 13, 2017 Revise its code enforcement program to meet CDBG requirements for the remaining $33,603 budgeted or amend the use of the funding to another CDBG-eligible activity.
2017-LA-1001-003-E Cerrado Abril 13, 2017 Determine the CDBG proportional benefit of the $329 charged for indirect automotive costs and repay the program any unsupported charges using non-Federal funds.
2017-LA-1001-003-F Cerrado Abril 13, 2017 Obtain training or technical assistance from HUD concerning CDBG code enforcement, allocation of payroll, and indirect administrative costs.