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untanglingwebs
El Supremo
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This report was sent to Dayne Walling on December 22, 2010 and yet no council person has said they have seen it. It focuses on Community development Block Grants and HOME funding.
Subrecipients are the agencies the city contracts with HUD dollars to perform services for Flint.
HUD
"City needs to improve its subrecipient management in both programs, have better control over how the City documents its administrative charges to the programs, and needs to have improved written procedures in its City Wide Emergency Rehabilitation Program."
The report also stated the City has not corrected the IDIS used to draw down HUD funds that were cited in earlier monitoring reports.
City is not making sufficient progress in completing it's HOME Projects.
City Wide Emergency Rehabilitation
This section focused on rehabiltaion compliance and cited 24 CFR 570.202
Site visits by HUD revealed repairs that had excessive costs and some that did not appear to be emergency repairs. The procedures established by the City required a visit by a Program Enforcement Manager for all repairs over $10,000 so the City could decide how to proceed.
HUD found no evidence this procedure was followed and the projects did not meet the City definitions of an emergency.
The Department of Community and Economic Development stopped using nonprofit partners, with the exception of HOME CHDO (Community Housing Development organizations) and placed all housing activities under the direct administration of the DCED.
HUD noted the current staff is not experienced in administering a housing rehab program and "strongly suggested City establish a detailed, comprehensive, written set of rehabilitation policies and procedures."
CDBG
The rules for governance, 24 CFR 570.504, says the city must execute witten agreements with subrecipients.
In three consecutive visits by HUD the City did the bulk of their subrecipient monitoring just prior to HUD;s visit. Thus HUD was unable to see the responses from the agencies after the City monitoring visit.
There were no overall summary of conclusions for the entire year:
*Did subgrantees regularly submit the required monthy reports timely with draw requests?
* Was training needed to improve the subgrantees performance?
* Recommendations concerning the capacity of subgrantees to carry out the requirements of the agreements.?
HUD said there was confusion as to what constituted a finding versus a concern or comment.
The DCED Complince Officer was to work with the monitors to produce a consistency in reporting.
Administartive Expenditues
There were numerous unsupported charges to the CDBG and the HOME programs, especially by the business manager. Most staff said they had little to do with the HOME program. Yet there were timesheets with reported charges to HOME for "assisted client with general information", "researched GCCARD information" (when GCCARD had no active HOME contract), "completed second resolution re: MSHDA grant", 'managers meeting", "NSP1". "FAEC" and others.
DCED was required to perform city tasks that were not eligible for HUD CPD funding. Historically thes tasks were performed using general fund dollars, but DCED informed HUD the council withdrew all city funding from DCED. Yet, the most common cause of the misbilling was a confusion over what were the proper charges.
HUD
"IMPROPER CHARGES COULD LEAD TO DISALLOWED COSTS AND REPAYMENTS TO HUD FROM THE CITYS GENERAL FUND".
HUD wants to be informed how the city has or will educate staff as to the proper charging of time.
They also want to know if DCED will get general fund money or if staff will be prohibited from doing the tasks previously funded by the city and not eligible for HUD CPD funding. |
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Tue Jan 25, 2011 7:26 pm |
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untanglingwebs
El Supremo
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| If you can read between the lines, it appears that HUD is saying the department doesn't know what they are doing. |
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Sun Jan 30, 2011 6:16 pm |
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