Issue Date
July 9, 2009
Audit Report Number
2009-PH-0002
TO: Nadab O. Bynum, Director, Office of Community Planning and Development,
Philadelphia Regional Office, 3AD
Charles E. Halm, Director, Office of Community Planning and Development,
Baltimore Field Office, 3BD
FROM: John P. Buck, Regional Inspector General for Audit, Philadelphia Region, 3AGA
SUBJECT: The Philadelphia, Pennsylvania, and Baltimore, Maryland, CPD Offices
Did Not Adequately Document Their Monitoring of CDBG Program Grantees
HIGHLIGHTS
What We Audited and Why
We audited the U.S. Department of Housing and Urban Development’s (HUD)
monitoring of its Community Development Block Grant (CDBG) program
grantees under the jurisdiction of the Philadelphia, Pennsylvania, and Baltimore,
Maryland, Community Planning and Development (CPD) field offices as part of
our annual audit plan. Our audit objective was to determine whether those offices
adequately monitored their CDBG program grantees to ensure that they used their
grant funds to assist low- and moderate-income families through eligible activities
according to HUD requirements.
What We Found
The Philadelphia and Baltimore CPD field offices did not adequately document
their monitoring of CDBG program grantees. Specifically, the field offices did
not always maintain documentation to demonstrate that their monitoring was
complete and did not always notify grantees of the findings and concerns
identified during on-site monitoring within the required time limit.
What We Recommend
We recommend that the Directors of HUD’s Philadelphia and Baltimore CPD
field offices reemphasize to their staffs the importance of following established
monitoring procedures, specifically to ensure that all correspondence,
documentation, and work papers relating to the monitoring and conclusions are
maintained in the official monitoring files; monitoring officials use the required
monitoring exhibits; monitoring officials answer all of the questions and fill in all
of the text boxes in the monitoring exhibits; and staffs prepare and send
notification of the monitoring results to the grantees within the required 45-day
time limit.
In addition, we recommend that the Directors of HUD’s Philadelphia and
Baltimore CPD field offices develop and implement a written quality assurance
procedure and/or mechanism to ensure that monitoring conclusions are
appropriately supported by complete documentation and that monitoring letters
are submitted to grantees within the 45-day requirement.
For each recommendation without a management decision, please respond and
provide status reports in accordance with HUD Handbook 2000.06, REV-3.
Please furnish us copies of any correspondence or directives issued because of the
audit.
Auditee’s Response
We discussed the report with the Philadelphia and Baltimore CPD field offices
during the audit and at exit conferences on June 11 and June 15, 2009,
respectively. The Philadelphia field office provided written comments to our
draft report on June 19, 2009. The Baltimore field office chose not to provide
written comments. The field offices agreed with the recommendations in the
report. The complete text of Philadelphia field office’s response can be found in
appendix D of this report.
2
TABLE OF CONTENTS
Background and Objective 4
Results of Audit
Finding: The Philadelphia and Baltimore CPD Field Offices Did Not 5
Adequately Document Their Monitoring of CDBG Program Grantees
Scope and Methodology 12
Internal Controls 13
Appendixes
A. Grantees Reviewed 15
B. Schedule of Deficiencies 16
C. Findings and Concerns Not Reported within 45 Days
17
D. Auditee Comments
18
3
BACKGROUND AND OBJECTIVE
The Community Development Block Grant (CDBG) program is authorized under Title I of the
Housing and Community Development Act of 1974 (Act), as amended, and governed by 24 CFR
[Code of Federal Regulations] Part 570. The administrative office is the Assistant Secretary for
Community Planning and Development, U.S. Department of Housing and Urban Development
(HUD), Washington, DC. The CDBG program is a flexible program that provides communities
with resources to address a wide range of unique community development needs. The CDBG
entitlement program allocates annual grants to larger cities and urban counties, on a
noncompetitive basis, to develop viable communities by providing decent housing, a suitable
living environment, and opportunities to expand economic opportunities, principally for low- and
moderate-income persons. The entitlement program receives 70 percent of the annual funding
allocation. Cities and counties that do not meet the criteria to receive funds as entitlement
grantees participate in the CDBG program on a competitive basis through the state in which they
are located. The nonentitlement program receives 30 percent of the annual funding allocation.
There are five Community Planning and Development (CPD) field offices within Region III.
They are Philadelphia (covers eastern Pennsylvania and all of Delaware), Pittsburgh (covers
western Pennsylvania and all of West Virginia), Baltimore (covers Maryland), Richmond (covers
Virginia), and Washington, DC (covers Washington, DC). HUD provided CDBG funds totaling
nearly $797 million to 107 grantees in Region III on an entitlement basis in fiscal years 2007 and
2008. The following chart provides details.
Fiscal year 2007 Fiscal year 2008
Field office funding funding Two-year total
Philadelphia1 $174,523,428 $168,639,007 $343,162,435
Pittsburgh $ 82,474,328 $ 79,614,601 $162,088,929
Baltimore1 $ 56,098,857 $ 76,938,015 $133,036,872
Richmond $ 61,989,899 $ 59,840,783 $121,830,682
Washington, DC $ 18,767,297 $ 18,033,221 $ 36,800,518
Total $393,853,809 $403,065,627 $796,919,436
The field offices are responsible for their jurisdictions and operate independently of each other
within the guidelines provided. Each field office performs an annual risk assessment for the
CDBG entitlement program grantees to identify candidates for monitoring using risk analysis
factors such as financial, physical, management, satisfaction, and services. In addition,
subfactors such as dollar value, complexity of programs, number of programs administered, and
compliance issues are critical in determining those grantees defined as high risk.
Our audit objective was to determine whether the Philadelphia and Baltimore field offices
adequately monitored their CDBG program grantees to ensure that they used their grant funds to
assist low- and moderate-income families through eligible activities according to HUD
requirements.
1
We performed our work at the Philadelphia and Baltimore offices.
4
RESULTS OF AUDIT
Finding: The Philadelphia and Baltimore CPD Field Offices Did Not
Adequately Document Their Monitoring of CDBG Program Grantees
The Philadelphia and Baltimore CPD field offices did not properly maintain documentation to
demonstrate that their monitoring was complete and did not notify grantees of findings and
concerns identified during on-site monitoring within the required time limit. These conditions
occurred because monitoring officials did not follow established monitoring policy and
procedures to document monitoring reviews completely and notify grantees of monitoring results
within the required time limit. The cost of not adequately documenting monitoring can be
substantial and potentially embarrassing, especially when HUD seeks to take enforcement
actions that are challenged by the grantee. When HUD does not inform grantees of its
monitoring findings and concerns in a timely manner, it runs the risk of having the grantee
expend funds inappropriately. Further, proper monitoring will become even more critical as a
result of the significant increase in grantee funding provided under the Neighborhood
Stabilization program and the American Recovery and Reinvestment Act of 2009 (Recovery
Act).
Monitoring Was Properly
Based on Risk Assessments
The Philadelphia and Baltimore field offices based their monitoring on risk
assessments performed on 51 grantees for fiscal years 2007 and 2008 as required.
The field offices created annual work plans and an individual monitoring strategy
for each grantee selected for monitoring. Our review of the monitoring files for
13 grantees that received $67.9 million (appendix A) showed that the monitoring
teams identified findings and concerns during their on-site monitoring visits at
eight of the 13 grantees. In addition, for all 13 grantees, we found at least some
documentation to show that the field offices performed a review to determine the
grantees’ compliance with timely funds expenditure requirements and that the
field offices properly followed up on recommended corrective action to address
findings and concerns, which they communicated to the grantee in their
monitoring letters.
Monitoring is the principal means by which HUD ensures that programs and
technical areas are carried out efficiently, effectively, and in compliance with
applicable laws and regulations; assists program grantees in improving their
performance, developing or increasing capacity, and augmenting their
management and technical skills; and stays abreast of the efficacy of CPD-
administered programs and technical areas within the communities that these
5
programs serve. Regulations at 24 CFR 570.900(a)(1) require HUD to at least
annually conduct reviews and audits to determine whether recipients have carried
out their activities in a timely manner, have carried out those activities and their
certifications in accordance with the requirements and the primary objectives of
the Act and other applicable laws, and have continued capacity to carry out those
activities in a timely manner.
Monitoring Conclusions Were
Not Always Supported by
Proper Documentation
Monitoring officials did not always maintain appropriate documentation to
support their conclusions. HUD Handbook 6509.2, REV-5, chapter 2-14(C)5,
requires each CPD field office to document its monitoring of grantees by
obtaining and completing monitoring exhibits, which are similar to checklist
questionnaires, with any supporting documentation obtained during the
monitoring such as but not limited to contracts, budget forms, grantee policies,
and work write-ups to be attached to the appropriate exhibit and clearly labeled,
indicating what they are and what part of the monitoring they support. Chapter 2-
14(A) of the handbook also requires all monitoring conclusions to be supported
and all correspondence, documentation, and working papers relating to the
monitoring and conclusions to be maintained in the official field office files. For
the CDBG program, there are about 40 different monitoring exhibits used to
monitor various program requirements. The combination of exhibits needed to
monitor a grantee depends on the mix of activities in that grantee’s action plan.
However, in the monitoring files for 7 of the 13 grantees (54 percent) reviewed,
there were instances in which answers to some exhibit questions were not
supported by documentation copied or reviewed by the monitoring official during
the monitoring review when they should have been. For example, below are
questions from monitoring exhibits that required documentation to support the
monitoring official’s conclusions.
6
The monitoring officials did not obtain appropriate documentation to support the
conclusions drawn. The exhibit questions shown above required the monitoring
official to perform an analysis to determine whether costs were reasonable and
whether ineligible activities were funded. Thus, an independent analysis should
be performed by the monitoring official to demonstrate whether the grantee is
carrying out its activities in accordance with HUD requirements. However, it
appears as though the monitoring officials relied on explanations provided by the
grantee rather than determining whether the grantee maintained the
documentation necessary to demonstrate that the costs were reasonable and
whether ineligible activities were assisted. Monitoring officials need to obtain
and maintain documentation to support their conclusions as required.
Documentation preserves valuable results, both positive and negative. The cost to
HUD of not maintaining such documentation is substantial and potentially
embarrassing, especially when HUD seeks to take enforcement actions that are
challenged by the grantee.
Monitoring Officials Did Not
Answer All Questions and Did
Not Use Required Forms
Monitoring officials did not always provide answers to monitoring questions and
did not use required forms to document summary information. HUD Handbook
6509.2, REV-5, chapter 1-7, requires that exhibits in the handbook be used. All
monitoring conclusions and exhibit questions must be clearly answered, to which
includes providing answers to all “Yes/No/N/A” boxes and the “basis for
conclusion” text box to prevent confusion regarding the determinations made by
the monitoring official. However, in the monitoring files for 7 of 13 grantees
reviewed (54 percent), the monitoring official did not answer all of the questions
or include summary information regarding the monitoring that was needed to
complete the exhibit (see appendix B). The following are examples from
monitoring exhibits in which the monitoring official did not answer the question
or provide the basis for conclusion:
7
Further, none of the monitoring files for all 13 grantees reviewed (100 percent)
contained evidence that the monitoring officials used the required monitoring
summary form. The form is used to document the exit conference including key
information such as the names and titles of the attendees, the grantee’s
agreement/disagreement with the monitoring results, and the basis of any
objections to the results.
The Field Offices Did Not
Inform Grantees of Monitoring
Results within the Required
Timeframe
In 10 of 13 monitoring reviews (77 percent), the field offices did not send the
monitoring letters to the grantee within the required time period (see appendixes
B and C). HUD Handbook 6509.2, REV-5, chapter 2-10, requires the field
offices to send a monitoring letter to the grantee within 45 days after completion
of monitoring. The purpose of the monitoring letter is to communicate the
monitoring results, in sufficient detail, to clearly describe the areas that were
covered during the monitoring review, the basis for the conclusions drawn, and
provide opportunities for the grantee to demonstrate that it has complied with
8
requirements within the time prescribed by the field office. For the 10 instances
noted, the number of elapsed days before the monitoring letter was sent to the
grantee ranged from 66 to 213 days after the on-site monitoring was completed.
On average, the monitoring letters were sent 128 days, or more than four months,
after the on-site monitoring was completed. The following paragraphs describe
examples of findings and concerns that the field offices did not communicate to
the grantee in a timely manner:
The Philadelphia field office sent a monitoring letter to a grantee 186 days
after it completed the on-site monitoring. In the letter, the field office
presented three findings concerning the grantee’s lack of documentation to
demonstrate that it complied with eligibility and national objective
requirements for three activities.
The Baltimore field office sent a monitoring letter to a grantee 213 days
after it completed the on-site monitoring. In the letter, the field office
informed the grantee that it had cleared a finding concerning the timing of
income eligibility determination based on a letter that it received from the
grantee stating the corrective actions that it planned to take. In the letter,
the field office also notified the grantee of concerns regarding its (1) lack
of grievance procedures for beneficiary dispute resolution for its housing
rehabilitation program, (2) need to update its systems and procedures
manual, and (3) lack of consistency in prevailing rate calculations.
Field Offices Need to Follow
Established Procedures
The field offices did not adequately document their monitoring because the
monitoring officials did not follow established monitoring policy and procedures
detailed in HUD’s Community Planning and Development Monitoring Handbook
(Handbook 6509.2, REV-5), and they lacked a quality assurance control to ensure
compliance. The handbook contains adequate policy and procedures for
monitoring a grantee’s performance. Monitoring officials should be aware of the
monitoring requirements in the handbook. A lack of a quality assurance control
also contributed to this condition. Neither field office had developed and
implemented an internal quality control procedure to ensure that monitoring
conclusions were supported by documentation, all monitoring questions were
answered, and the monitoring results were communicated to grantees within
established timeframes. The Philadelphia CPD Director stated that his office’s
ability to complete monitoring timely was affected by challenges such as
voluminous workload, decrease in staff and the associated loss of institutional
knowledge, competing priorities, and the complexity of the grant programs which
require consultation with headquarters regarding programmatic issues. The
Baltimore CPD Director stated that the primary reason for the lateness of the
letters was a lack of supervisory emphasis on completing the task. In addition,
9
this Director also stated that using the monitoring exhibit checklists had made
monitoring a much more time-consuming practice with very little payoff in terms
of staff performance.
The field office Directors need to reemphasize to their staffs the importance of
following established monitoring procedures in HUD Handbook 6509.2, REV-5,
and develop and implement a quality assurance control to ensure that staff
performs the monitoring according to the handbook. Monitoring is the principal
means by which HUD ensures that programs are carried out efficiently,
effectively, and in compliance with applicable laws and regulations.
The Field Offices Took Some
Action to Improve Their
Monitoring
The field office Directors acknowledged that their monitoring could be improved
and informed us of some actions that they took to improve it. The Philadelphia
field office held a four-hour on-site training session for the staff in September
2008 to discuss the policies and procedures of HUD Handbook 6509.2, REV-5.
A senior management analyst from the Office of the Assistant Secretary for
Community Planning and Development conducted the training and provided
feedback on 17 monitoring letters and reports and 81 exhibits that the office had
uploaded into the monitoring database. The feedback addressed process and
technical improvements including examples and suggestions to sufficiently
document the monitoring of grantee performance. During the audit, the Baltimore
field office Director revised a locally-developed report that the office used as a
tool to track annual monitoring. The field office Director added a column to the
report listing the date by which the office needed to send the monitoring letter to
the grantee to comply with the 45-day requirement.
Effective Monitoring Will Be
More Critical in the Future
The results presented in this audit report raise concern over the field offices’
ability to effectively monitor their CPD programs going forward, given the
significant increase in workload that will occur due to the infusion of funds into
CPD programs resulting from the Neighborhood Stabilization program and the
Recovery Act. States, cities, and counties in Region III are scheduled to receive
more than $531 million under the Neighborhood Stabilization program and the
Recovery Act. HUD is providing funds under these initiatives to acquire and
redevelop foreclosed properties that might otherwise become sources of
abandonment and blight within their communities, stabilize and revive local
neighborhoods and housing markets with heavy concentrations of foreclosed
properties, and assist vulnerable families who are on the brink of homelessness or
10
have recently become homeless. The field office staffs will be engaged
simultaneously with implementing and managing larger CPD programs and
monitoring grantees for compliance with more stringent obligation, expenditure,
and reporting requirements in addition to compliance with other program
regulations.
Conclusion
The Philadelphia and Baltimore CPD field offices did not properly maintain
documentation to demonstrate that their monitoring was complete and did not
notify grantees of findings and concerns identified during on-site monitoring
within the required time limit. This occurred because field offices did not
adequately follow established HUD monitoring policy and procedures, and lacked
a quality assurance control to ensure compliance. The cost of not adequately
documenting monitoring can be substantial and potentially embarrassing,
especially when HUD seeks to take enforcement actions that are challenged by
the grantee. When HUD does not inform grantees of its monitoring findings and
concerns in a timely manner, it runs the risk of having the grantee expend funds
inappropriately. Proper monitoring will become even more critical in the future
due to the significant increase in funds that HUD will provide to grantees under
the Neighborhood Stabilization program and the Recovery Act.
Recommendations
We recommend that the Philadelphia and Baltimore CPD field office Directors
1A. Reemphasize to their staffs the importance of following established
monitoring procedures to ensure that
All correspondence, documentation, and work papers relating to the
monitoring and conclusions are maintained in the official monitoring
files;
Monitoring officials use the required monitoring exhibits;
Monitoring officials answer all of the questions and fill in all of the text
boxes in the monitoring exhibits; and
Staffs prepare and send notification of the monitoring results to the
grantees within the required 45-day time limit.
1B. Develop and implement a written quality assurance procedure and/or
mechanism to ensure that monitoring conclusions are appropriately
supported by complete documentation and that monitoring letters are
submitted to grantees within the 45-day requirement.
11
SCOPE AND METHODOLOGY
We performed our audit at the HUD Philadelphia, Pennsylvania, and Baltimore, Maryland, CPD
field offices from September 2008 through April 2009. The audit covered the field offices’
monitoring activities during the period October 2006 through September 2008. We expanded the
scope of the audit as necessary. We included tests of internal controls that we considered
necessary. We used computer-processed data only in conjuction with other supporting
documents to reach our conclusions, and we determined that the data were sufficiently reliable
for our purposes. We traced hard-copy records back to data contained in HUD’s computer
databases, and nothing came to our attention to suggest that the computer-processed data were
materially inaccurate or misleading.
To determine whether the Philadelphia and Baltimore field offices adequately monitored their
CDBG program grantees to ensure that they used their grant funds to assist low- and moderate-
income families through eligible activities according to HUD requirements, we
Reviewed regulations pertaining to the CDBG program, including 24 CFR 570; HUD
Handbook 6509.2, REV-5; and CPD Notice 07-07.
Conducted interviews with the Philadelphia and Baltimore field office Directors and
staff.
Obtained and reviewed listings of the Philadelphia and Baltimore entitlement grantees
and the CDBG funding they received during the audit period.
Obtained and reviewed risk assessments, desk reviews, and/or on-site monitoring reviews
performed by the Philadelphia and Baltimore field offices during the audit period.
Reviewed the files for the 13 CDBG entitlement grantees monitored by the Philadelphia
and Baltimore field offices between October 2006 and September 2008. We selected the
Philadelphia and Baltimore field offices for review because during fiscal years 2007 and
2008, 51 entitlement grantees within their jurisdiction received CDBG funds totaling
$476.2 million. This amount represented 60 percent of the total CDBG funding allocated
within Region III for the period. We reviewed the completed monitoring files for all 13
grantees for which the Philadelphia and Baltimore field offices performed on-site
monitoring during fiscal years 2007 and 2008. Those 13 grantees received $67.9 million
of the $476.2 million (14 percent) in CDBG funds allocated within the jurisdiction of the
field offices.
We conducted the audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objective. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.
12
INTERNAL CONTROLS
Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following controls are achieved:
Program operations,
Relevance and reliability of information,
Compliance with applicable laws and regulations, and
Safeguarding of assets and resources.
Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. They include the processes and procedures for planning,
organizing, directing, and controlling program operations as well as the systems for measuring,
reporting, and monitoring program performance.
Relevant Internal Controls
We determined that the following internal controls were relevant to our audit
objective:
Policies and procedures that management implemented to reasonably ensure
that CDBG program monitoring complied with HUD requirements.
Policies and procedures that management implemented to ensure that risk
assessments identified activities that represented the greatest vulnerability to
fraud, waste, and mismanagement.
Policies and procedures that management implemented to ensure that
grantees used their grant funds to assist low- and moderate-income
families through eligible activities.
We assessed the relevant controls identified above.
A significant weakness exists if management controls do not provide reasonable
assurance that the process for planning, organizing, directing, and controlling
program operations will meet the organization’s objectives.
Significant Weakness
Based on our review, we believe that the following item is a significant weakness:
13
The Philadelphia and Baltimore field offices did not have controls to
ensure that CDBG program monitoring complied with HUD requirements
and that the intended objectives were met.
14
APPENDIXES
Appendix A
GRANTEES REVIEWED
CDBG funding
Date of on-site Responsible for fiscal years
Grantee monitoring review field office 2007 and 2008
Philadelphia, PA March 10-14, 2008 Philadelphia $51,734,740
Lancaster County, PA September 17-21, 2007 Philadelphia $ 3,328,250
New Castle County, DE March 26-30, 2007 Philadelphia $ 2,447,599
Anne Arundel County, MD March 12-14, 2007 Baltimore $ 2,175,387
Dauphin County, PA May 12-16, 2008 Philadelphia $ 1,495,700
Cumberland County, PA June 2-4, 2008 Philadelphia $ 1,345,344
Howard County, MD June 27-July 3, 2008 Baltimore $ 1,158,318
Harford County, MD July 18-20, 2007 Baltimore $ 1,089,692
Hagerstown, MD February 20-23, 2007 Baltimore $ 962,490
Lebanon, PA June 9-12, 2008 Philadelphia $ 830,442
Bristol Township, PA August 26-29, 2008 Philadelphia $ 661,294
Annapolis, MD March 4-6, 2008 Baltimore $ 339,698
Salisbury, MD August 26-28, 2008 Baltimore $ 298,632
Total $67,867,586
15
Appendix B
SCHEDULE OF DEFICIENCIES
Number of
Was Did CPD
days Did CPD Did CPD
monitoring maintain
between completely use the
letter documentation
Grantee monitoring fill out the monitoring
provided to support
and monitoring summary
within 45 monitoring
monitoring exhibits? form?
days? conclusions?
letter
HUD HUD
HUD
Handbook Handbook HUD
Handbook
6509.2, 6509.2, Handbook
Reference 6509.2, REV-
REV-5, REV-5, 6509.2, REV-5,
5, section 2-
section 2-10 section 2- section 2-7C3
7C3
7D
Hagerstown, MD N 213 N N Y
Annapolis, MD N 203 N N N
Anne Arundel County,
N 197 N N Y
MD
Cumberland County, PA N 188 Y N Y
Philadelphia, PA N 186 Y N N
New Castle County, DE N 178 N N Y
Lebanon, PA N 154 Y N Y
Howard County, MD N 88 N N N
Bristol Township, PA N 70 Y N Y
Harford County, MD N 66 N N N
Dauphin County, PA Y 44 Y N N
Lancaster County, PA Y 43 Y N N
Salisbury, MD Y 32 N N N
Total “no” answers 10 of 13 7 of 13 13 of 13 7 of 13
77% 54% 100% 54%
Average number of 128
days
16
Appendix C
FINDINGS AND CONCERNS NOT REPORTED
WITHIN 45 DAYS
Cumberland County, PA
New Castle County, DE
Anne Arundel County,
Bristol Township, PA
Harford County, MD
Howard County, MD
Hagerstown, MD
Philadelphia, PA
Annapolis, MD
Lebanon, PA
Grantee
MD
Number of days 213 203 197 188 186 178 154 88 70 66
Lack of documentation for eligibility X,X X
Lack of documentation for national objectives X X,X
Notice not provided to owners before acquisition of their
X
properties
Incomplete eligibility documentation X X X
Grantee did not submit SF 2722 to HUD X
Grantee not following federal procurement
X
requirements
Grantee not maintaining race and ethnicity data X X
Lack of loan servicing procedures X
Lack of a cost allocation plan X
Lack of time records for staff working multiple
X
programs
Lack of documentation to demonstrate monitoring of X
subrecipient
Lack of procedures for housing rehabilitation program X X
Systems and procedures manual outdated X
Lack of consistency in prevailing rate calculations X
Subrecipient provided notices that were confusing X
Lack of organizational chart X
Financial information inaccurately reported in IDIS 3 X
Lack of documentation for national objectives X
Grantee does not have a pool of licensed and qualified
X
rehabilitation contractors
Lack of evidence to demonstrate monitoring of
X
subrecipient
Findings4 Concerns4
2
SF 272 - Federal Cash Transactions Report.
3
IDIS - Integrated Disbursement and Information System. IDIS is a real-time, mainframe-based computer
application that enables grantees to draw down program funds and report on their activities.
4
According to HUD Handbook 6509.2, REV-5, chapter 2-10, findings must include condition, criteria, cause, effect,
and required corrective action. Concerns should include condition, cause, and effect. Corrective actions are not
required for concerns.
17
Appendix D
AUDITEE COMMENTS
18
19
The Philadelphia, Pennsylvania, and Baltimore, Maryland, CPD Offices Did Not Adequately Document Their Monitoring of CDBG Program Grantees
Published by the Department of Housing and Urban Development, Office of Inspector General on 2009-07-09.
Below is a raw (and likely hideous) rendition of the original report. (PDF)