We reviewed the County because it received more than $19 million in NSP funds and in 2008, HUD rated the County’s HOME program as high risk. Our objectives were to determine whether the County had the capacity to effectively and efficiently administer its NSP and whether it accurately reported HOME commitments within HUD’s Integrated Disbursement and Information System (IDIS).
Based on the review, the County had the capacity to administer its NSP. The County had made substantial and effective revisions to its organization and staffing to correct many of the past performance problems identified by HUD and its own internal assessments. It had established and implemented adequate NSP procedures, followed proper procedures in the procurement of contract services, hired or was in the process of hiring an adequate number of qualified staff, and arranged for other County departments to assist with NSP workload and was progressing in carrying out its NSP.
As of October 1, 2009, the County had not entered any obligations or expenditures into the Disaster Recovery Grant Reporting (DRGR) system. We also noticed that its staff had not obtained training on the use of the system and that its policy did not address timeliness for entering and reporting obligations and expenditures in the system. In addition, the County’s DRGR policy did not define what constituted an NSP obligation and the documentation required to properly support an obligation.
The County had a past problem with making inaccurate commitment entries into IDIS. We identified more than $748,000 in incorrect commitment entries made to IDIS before the County improved its controls. The inaccurate entries subjected the County to more than $61,000 that is subject to recapture by HUD because it did not ensure that written agreements were executed before it committed activities in IDIS.
We recommend that the Director of HUD’s Jacksonville Office of Community Planning and Development require the County (1) to mandate that all staff with DRGR responsibilities complete in house and or HUD assisted training on use of the system to ensure timely and proper entry of NSP obligations, expenditures, and performance reporting, (2) amend its draft DRGR policy to include timeliness for entering and reporting NSP obligations and expenditures, defining what constitutes an NSP obligation, and describing the type of documentation to be kept to support NSP obligations, and (3) recapture $61,256 in HOME funds which the County did not commit by the 24-month statutory deadline.