We audited Hamilton County’s subrecipient agreement with People Working Cooperatively, Inc. (corporation), for a Community Development Block Grant-funded housing repair services program based on a request from the U.S. Department of Housing and Urban Development’s (HUD) Columbus Office of Community Planning and Development concerning information the Office received regarding the program, which it did not have the resources to review. The audit was part of the activities in our fiscal year 2018 annual audit plan. Our objective was to determine whether the County and corporation complied with HUD’s requirements in the use of Block Grant funds for the program.
The County and corporation did not always comply with HUD’s requirements in the use of Block Grant funds for the program. Specifically, the County did not ensure that (1) it required the corporation to submit source documentation before providing it with Block Grant funds for housing repair services, (2) it provided the corporation Block Grant funds for eligible program expenses, (3) two households were eligible for assistance under the program, (4) it properly documented compliance with HUD’s environmental review procedures, (5) the corporation notified the County before completing a third emergency repair job for households within a grant year, (6) a member of a household associated with an accessibility modification was disabled, and (7) the corporation reduced all of the program income it received from its invoices for housing repair services. As a result, more than $10,000 in Block Grant funds was not available for eligible expenses of the program, and HUD and the County lacked assurance that nearly $13,000 in Block Grant funds was used in accordance with HUD’s requirements.
We recommend that the Director of HUD’s Columbus Office of Community Planning and Development require the County to (1) reimburse its Block Grant program from non-Federal funds for inappropriate expenses, (2) support or reimburse its Block Grant program from non-Federal funds for expenses for which the corporation lacked sufficient documentation to support, and (3) implement adequate procedures and controls to address the weaknesses cited in this audit report.
Recommendations
Community Planning and Development
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Status2018-CH-1008-001-AOpenClosedClosed on March 26, 2020
Implement adequate procedures and controls to ensure that it obtains and reviews source documentation, such as invoices and time sheets, to support that expenses are eligible before providing Block Grant funds to the corporation for housing repair services.
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Status2018-CH-1008-001-BOpenClosed$5,810.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on April 08, 2019Reimburse its Block Grant program from non-Federal funds for the $5,810 it provided to the corporation for labor that exceeded actual labor costs (more than $4,800) and indirect costs associated with the excessive labor costs (nearly $1,000).
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Status2018-CH-1008-001-COpenClosed$338,904.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on May 04, 2021Review the labor costs associated with the remaining 1,645 (1,668 - 23 reviewed) jobs that we did not review to determine whether the Block Grant funds it provided the corporation for labor exceeded the actual labor costs for each job. If the labor exceeded the actual labor cost for a job, the County should reimburse its Block Grant program from non-Federal funds for the excessive labor costs and the indirect costs associated with the excessive labor costs that the County provided to the corporation.
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Status2018-CH-1008-001-DOpenClosedClosed on March 26, 2020
Implement adequate procedures and controls to ensure that it does not provide the corporation Block Grant funds for excessive labor costs.
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Status2018-CH-1008-001-EOpenClosedClosed on March 26, 2020
Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that the cost of materials and services acquired for the program is reasonable.
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Status2018-CH-1008-001-FOpenClosed$182.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on April 08, 2019Reimburse its Block Grant program from non-Federal funds for the $182 it provided to the corporation for a 4 percent surcharge that was inappropriately included on all materials.
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Status2018-CH-1008-001-GOpenClosed$6,140.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on April 08, 2019Support or reimburse its Block Grant program from non-Federal funds for the $6,140 it provided to the corporation for indirect costs for which the corporation lacked sufficient documentation to support whether the indirect costs included lobbying-related expenses.
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Status2018-CH-1008-001-HOpenClosed$1,541.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on April 08, 2019Support or reimburse its Block Grant program from non-Federal funds for the $1,541 it provided to the corporation for jobs for which the corporation lacked sufficient income documentation to support that the households were eligible for assistance.
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Status2018-CH-1008-001-IOpenClosedClosed on March 26, 2020
Implement adequate procedures and controls to ensure that sufficient income documentation is maintained to ensure that households are eligible for assistance under the program and income is verified in accordance with HUD’s requirements and the subrecipient agreement.
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Status2018-CH-1008-001-JOpenClosedClosed on March 26, 2020
Implement adequate procedures and controls to ensure that it properly documents compliance with HUD’s environmental review procedures before the start of each job.
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Status2018-CH-1008-001-KOpenClosedClosed on March 26, 2020
Implement adequate procedures and controls to ensure that third emergency repairs are documented in writing and reported to the County before completion of assistance in accordance with the subrecipient agreement.
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Status2018-CH-1008-001-LOpenClosed$4,953.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on April 08, 2019Support or reimburse its Block Grant program from non-Federal funds for the $4,953 it provided to the corporation for one job for which the corporation lacked sufficient documentation to support that a member of the household was physically disabled.
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Status2018-CH-1008-001-MOpenClosedClosed on March 26, 2020
Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that accessibility modifications are provided only to households with at least one member who is physically disabled.
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Status2018-CH-1008-001-NOpenClosed$4,127.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on April 08, 2019Reimburse its Block Grant program from non-Federal funds for the $4,127 it inappropriately provided to the corporation due to not ensuring that the corporation reduced all of its program income from its invoices for housing repair services.
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Status2018-CH-1008-001-OOpenClosed$107.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on April 08, 2019Support or reimburse its Block Grant program from non-Federal funds for the $107 it provided to the corporation for the January 2016 invoice that the corporation generally could not explain.
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Status2018-CH-1008-001-POpenClosedClosed on March 26, 2020
Implement adequate procedures and controls to ensure that the corporation reduces program income from its invoices for housing repair services.