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Lessons Learned and Key Considerations From Prior Audits and Evaluations of the CDBG Disaster Recovery Program

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act made available $5 billion in supplemental CDBG funding for grants to prevent, prepare for, and respond to the coronavirus pandemic (CDBG-CV grants).  Because of similarities, we reviewed 132 CDBG-DR program audits and evaluations issued from May 2002 to March 2020 to summarize the common CDBG-DR program weaknesses and risks for CPD to consider to help its CDBG-CV grantees effectively and efficiently manage their CDBG-CV program operations.

We found that grantees had common areas of weaknesses and risks in the administration of their CDBG-DR programs.  More than 44 percent of grantees reviewed (32 of 72) did not follow program requirements, resulting in questioned costs totaling more than $1.7 billion.  Generally, grantees (1) did not follow general program and administrative requirements, including duplication of benefits requirements, Federal cost principles, and procurement requirements; (2) could not support the eligibility of applicant awards; (3) did not adequately monitor their program; and (4) did not follow grant requirements or did not ensure that subrecipients or contractors followed agreements or requirements.  These conditions occurred because the grantees (1) lacked controls or were unfamiliar with the program requirements; (2) had weak policies or did not implement controls; (3) relied on or did not monitor their subrecipients or contractors; and (4) lacked adequate staff or capacity to administer the program.

As of September 11, 2020, CPD had awarded the CDBG-CV grant funds to 1,265 formula and joint grantees to respond to the pandemic, and 1,195 grantees, or about 94 percent, lacked experience with CDBG-DR activities.  Most CDBG-DR grantees that incurred questioned costs were unfamiliar with the program requirements and did not implement adequate policies and internal controls.  The lack of familiarity with program rules, the creation of new programs, and the ability of States to directly administer a program are also likely to be issues for CDBG-CV grantees without disaster experience. 

To ensure program integrity and timeliness of CDBG-CV activities and to mitigate the risk of financial loss, CPD should 

  • Provide grantees with training or other technical assistance to help familiarize them with program requirements.
  • Ensure that grantee coronavirus activities are allowed and are needed to prevent, prepare for, and respond to the coronavirus pandemic.
  • Ensure that grantees without disaster experience become familiar with the program rules and have the capacity to directly administer the coronavirus funding if they choose to directly administer the funds instead of passing the funds through to units of general local government.
  • Ensure that grantees are aware of the requirements to prevent duplication of benefits issues related to other agencies and entities providing coronavirus relief to the same applicants.
  • Ensure that grantees become familiar with Federal procurement requirements, cost principles, and other administrative requirements.