City of High Point, NC
Lead Based Paint Hazard Control Grants
Office of Audit, Region 4 Audit Report Number: 2015-AT-1005
Atlanta, GA July 9, 2015
To: Eric Hornbuckle, Director of Programs Division, Office of Healthy Homes and
Lead Hazard Control, L
//signed//
From: Nikita N. Irons, Regional Inspector General for Audit, 4AGA
Subject: The City of High Point Did Not Properly Administer Its Lead-Based Paint Hazard
Control Grants in Compliance With Federal Requirements
Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our review of the City of High Point’s lead-based paint hazard
control grants.
HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on
recommended corrective actions. For each recommendation without a management decision,
please respond and provide status reports in accordance with the HUD Handbook. Please furnish
us copies of any correspondence or directives issued because of the audit.
The Inspector General Act, Title 5 United States Code, section 8M, requires that OIG post its
publicly available reports on the OIG Web site. Accordingly, this report will be posted at
http://www.hudoig.gov.
If you have any questions or comments about this report, please do not hesitate to call me at
404-331-3369.
Audit Report Number: 2015-AT-1005
Date: July 9, 2015
The City of High Point Did Not Properly Administer Its Lead-Based Paint
Hazard Control Grants in Compliance With Federal Requirements
Highlights
What We Audited and Why
We audited the City of High Point’s lead-based paint procurement and eligibility operations.
This audit was a result of a referral from the U.S. Department of Housing and Urban
Development’s (HUD) Office of Healthy Homes and Lead Hazard Control. Our audit objective
was to determine whether the City administered its lead-based paint hazard control grants in
accordance with HUD’s regulations and grant requirements for procurement of contracted
services and expense eligibility.
What We Found
The City did not properly manage its procurement activities in accordance with HUD’s
requirements. Specifically, it continued using an expired contract to pay for environmental
services from November 1, 2009, to July 15, 2013. Also, it did not consistently select the lowest
bidder, retain required documentation, and perform cost analyses on change orders. As a result
of the City’s noncompliance, HUD funds were used to pay more than $1 million for ineligible
and unsupported procurement costs.
The City improperly used its grant funds for expenses that did not contain lead-based paint and
for ineligible lead-based paint expenses. As a result, HUD funds were used to pay more than
$9,000 for ineligible costs, which the City was not able to use for other projects.
What We Recommend
We recommend that the Director of the Office of Healthy Homes and Lead Hazard Control
require the City to (1) reimburse $207,097 in ineligible costs from non-Federal funds, (2) support
or reimburse $874,241 in unsupported costs from non-Federal funds, and (3) implement internal
controls to ensure that regulations and procedures are followed. We also recommend that the
Director continue the zero threshold process by reviewing the eligibility of the projects for approval
under the 2011 grant until the grant is completed.
Table of Contents
Background and Objective......................................................................................3
Results of Audit ........................................................................................................4
Finding 1: The City Did Not Comply With Procurement Requirements ................... 4
Finding 2: The City Used HUD Funds for Ineligible Costs ......................................... 7
Scope and Methodology ...........................................................................................9
Internal Controls ....................................................................................................11
Appendixes ..............................................................................................................12
A. Schedule of Questioned Costs .................................................................................. 12
B. Auditee Comments and OIG’s Evaluation ............................................................. 13
C. Procurement Deficiencies ......................................................................................... 20
2
Background and Objective
The City of High Point, Community Development and Housing Department, administers the
City’s Lead Safe High Point program. The program is federally funded by the U.S. Department
of the Housing and Urban Development (HUD). The purpose of the program is to identify and
control lead-based paint hazards in eligible privately owned rental or owner-occupied housing.
HUD awarded the City lead-based paint hazard control grants of $5.5 million for grant years
2008 and 2011. As of March 17, 2015, the City had used its entire 2008 grant of more than $2.9
million and more than $755,000 of its more than $2.4 million 2011 grant.
HUD’s Office of Healthy Homes and Lead Hazard Control conducted a review of the City in
May 2013 and identified that the City used grant funds for nonlead components, did not
consistently follow procurement policy and regulations, and had inadequate record keeping.
HUD reviewed the City’s 2008 and 2011 grant and questioned $107,407 of the $588,206 (18
percent) reviewed. Since the review, HUD had placed the City on a zero threshold for approval
of projects under the 2011 grant but had not reviewed later spending for eligibility.
The HUD Office of Healthy Homes and Lead Hazard Control is responsible for overseeing the
City’s program.
Our audit objective was to determine whether the City administered its lead-based paint hazard
control grants in accordance with HUD’s regulations and grant requirements for the procurement
of contracted services and expense eligibility.
3
Results of Audit
Finding 1: The City Did Not Comply With Procurement
Requirements
The City did not properly manage its procurement activities in accordance with HUD’s
requirements. Specifically, it continued using an expired contract to pay for environmental
services from November 1, 2009, to July 15, 2013. Also, it did not consistently select the lowest
bidder, retain required documentation, and perform cost analyses on change orders. These
conditions occurred because the City lacked internal controls over its lead-based paint hazard
control grant and did not ensure that its staff followed HUD’s procurement regulations during
personnel changes. As a result of the City’s noncompliance, HUD funds were used to pay more
than $1 million for ineligible and unsupported procurement costs.
Expired Contract
The City entered into an environmental contract in April 2009 for services rendered from April 1
through October 31, 2009. This contract had expired and was not renewed; therefore, as of
November 1, 2009, the contract was no longer valid. However, the City continued to pay the
contractor under the expired contract through July 31, 2013, which resulted in more than
$197,000 1 (see appendix C) in unallowable costs. The City’s affordable housing manager stated
that the contract was expired when he started working for the City.
Failure To Follow Procurement Requirements
We reviewed a statistical sample of 14 of 287 lead-based paint hazard control grant projects from
the City’s 2008 and 2011 lead-based paint hazard control grants. The City did not adequately
procure the contracts for the 14 projects reviewed totaling more than $877,000 for procurement
activities. In addition, the City did not follow its 2008 and 2011 grant work plans and 24 CFR
(Code of Federal Regulations) 85.36.
• The City did not select the lowest bidder. The City would determine the cost
estimate amount and the 15 percent margin above and below this amount. It
would open the bids after it determined the range. For any bids outside the 15
percent range, the City would consider the contractor to be nonresponsive. As a
result, it did not select the lowest bidder for 5 of the 14 (36 percent) project bids
(see appendix C). Regulations at 24 CFR 85.36(d)(2)(ii) state that the lowest
bidder must be selected for sealed bids. The HUD Director of Community
Planning and Development was aware that the City used a 15 percent margin to
disallow offers outside the margin; however, this practice did not comply with
1
This amount includes $151,699 from the 2008 grant year and $45,740 from the 2011 grant year.
4
HUD regulations. The City’s community development director stated that this
practice was used when he worked for another North Carolina city and it was the
practice when he started at the City of High Point.
• The City did not retain all procurement documentation, such as signed contracts,
notices to proceed, requests for bids and documents, and cost estimates for change
orders as required by the City’s work plans. In addition, 24 CFR 85.36(b)(9)
states that grantees must provide sufficient procurement history. Also, 24 CFR
85.36(f)(1) states that the grantee must perform a cost estimate for every
procurement action. All of the 14 projects reviewed lacked at least 2 types of
procurement documentation. Upon request, the City could not provide the
required documentation for the 14 projects totaling more than $877,000 2 (see
appendix C).
• The City did not prepare cost analyses on change orders for 6 of the 14 (43
percent) projects totaling more than $784,000 as required by 24 CFR 85.36(f) 3
(see appendix C). As a result, it did not support the reasonableness of the costs.
The affordable housing manager stated that City staff performed cost analyses
informally but had not documented them.
Lack of Internal Controls
Although the City had a HUD-approved work plan, the director of the Community Development
and Housing Department did not ensure that City staff followed the requirements. The director
stated that during times of staff turnover and workload increases, staff focused on completing the
work and did not follow the requirements. Between December 2008 and August 2014, the City
had two different affordable housing managers, and the position was vacant from November 17,
2011, to August 13, 2012.
The City’s affordable housing manager stated that as a result of HUD’s May 2013 review, the
City had developed new standard operating procedures for the lead grant program, which
addressed the 15 percent margin issues identified. However, as of March 12, 2015, the newly
developed standard operating procedures had not been dated, signed, or implemented. The
director stated he verbally approved the procedures. The affordable housing manager stated that
some of the staff had been involved in writing the procedures and thought that would be
sufficient to implement the new procedures. The new standard operating procedures no longer
allowed the 15 percent margin as the reason for removing a bid. They also required that the
project manager review the bid with each contractor as if the bid were outside the 15 percent
margin to confirm whether the contractor could perform the work for the price of the bid.
Although City staff could access the standard operating procedures on the City’s shared drive,
the City had not trained its staff on the new procedures.
2
This amount is comprised of $460,397 from the 2008 grant and $416,914 from the 2011 grant.
3
Regulations at 24 CFR 85.36(f) require that grantees and subgrantees must perform a cost or price analysis in
connection with every procurement action, including contract modifications.
5
Conclusion
The deficiencies discussed above occurred because the City failed to comply with HUD’s
procurement regulations or its own policies to ensure that HUD funds were used for eligible
services and procurements were adequately supported.
Recommendations
We recommend that the Director of the Office of Healthy Homes and Lead Hazard Control
require the City to
1A. Reimburse the U.S. Treasury from non-Federal funds $151,699 from the 2008
grant for ineligible procurement activities using the expired environmental
contract.
1B. Repay the program $45,740 from non-Federal funds from the 2011 grant for
ineligible procurement activities using the expired environmental contract.
1C. Provide adequate support or reimburse the U.S. Treasury from non-Federal funds
for procurement activities from the 2008 grant totaling $457,327. 4
1D. Provide adequate support or repay the program from non-Federal funds for
procurement activities from the 2011 grant totaling $416,914.
1E. Develop and implement internal controls to ensure that it complies with HUD
procurement regulations and its policies and procedures so that only eligible costs
are paid using the grant funds and the costs are properly supported.
1F. Ensure that City staff is trained on the policies and procedures for HUD
procurement regulations to ensure that the staff no longer uses the 15 percent cost
estimate margin.
4
The actual amount unsupported was $460,397. To avoid double counting, the amount was reduced by $3,070,
which is accounted for in the eligibility section.
6
Finding 2: The City Used HUD Funds for Ineligible Costs
The City improperly used its grant funds for expenses that did not contain lead-based paint and
for ineligible lead-based paint expenses. These conditions occurred because City staff did not
understand HUD’s requirements or the City’s work plan. As a result, HUD funds were used to
pay more than $9,000 for ineligible costs, which the City was not able to use for other projects.
Ineligible Use of Funds
The City did not properly administer its 2008 grant for work items and expenses for 6 of the 14
(43 percent) projects. The City paid more than $8,000 in lead-based paint expenditures for six
projects that did not comply with the 2008 notice of funding availability 5 (see table). The City’s
project managers stated that during HUD training, they received conflicting information
regarding what was considered an eligible expense. However, they were unable to confirm in
which training they received the conflicting information.
Ineligible use of funds
Project
name Items and issue Amount
Patch ceiling sheetrock
- The item was not
519 North listed as a lead paint
Centennial hazard. $ 400
Interior door -The item did
201 Edgeworth not test positive for lead. $ 700
Remediate siding and trim
- The items were not tested
415 Welch for lead. $3,552
Rear door and bathroom
610 Clover exhaust fan - The items $850
Drive were not tested for lead. $250
Doors - The doors were not
1005 Barbee tested for lead. $2,275
Miniblinds - The item was
1912 Wickham not tested for lead. $70
Total $8,097
The City also spent $1,063 for moving expenses that would not be needed according to the
City’s work plan because the contractor would move the furniture to the center of the room and
cover it while completing the work. However, the City paid the moving expenses for one unit.
5
Notice of Funding Availability 2008 (III C 2a (4))
7
City staff stated that it was not aware of the work plans. 6 In addition, the City miscoded the cost
of a hot water heater for $498, using lead-based paint funds instead of a community planning and
development grant.
Conclusion
The deficiencies discussed above occurred because the City failed to comply with HUD’s
regulations and its own policies to ensure that HUD funds were used for eligible services.
Specifically the City did not implement internal controls over its lead-based paint grant because
its staff and management did not understand HUD’s requirements and the City’s work plan.
Therefore, HUD’s continuous oversight of the remaining 2011 project grant funds would ensure
the required procedures are implemented.
Recommendations
We recommend that the Director of the Office of Healthy Homes and Lead Hazard Control
require the City to
2A. Reimburse the U.S. Treasury $9,658 from non-Federal funds for the 2008 grant
payments made for ineligible expenses.
2B. Develop and implement internal controls to ensure that it complies with HUD
regulations and its work plans so that only eligible costs are paid using grant
funds.
We also recommend that the Director of the Office of Healthy Homes and Lead Hazard Control
2C. Continue the zero threshold process by reviewing the eligibility of the projects for
approval under the 2011 grant until the grant is completed.
6
The 2008 work plan refers to the grantee’s plan for implementing the specific, reasonable, time-phase objectives
for each major program activity in the grant.
8
Scope and Methodology
We performed our audit from September 2014 and May 2015 at the City’s office located in High
Point, NC, and the HUD Office of Inspector General’s (OIG) Greensboro and Atlanta regional
offices.
To accomplish our objective, we
• Interviewed City staff to obtain an understanding of the controls significant to the audit
objective and assist in our review of City records.
• Interviewed HUD staff to obtain background information on the grantee.
• Reviewed applicable criteria, including Public Law 102-550, Residential Lead-Based
Paint Hazard Reduction Act of 1992; 24 CFR Part 35, Lead Base Paint in Residential
Structures; 24 CFR 85.36, Federal Procurement Regulations; 2008 Lead-Based Paint
Notice of Funding Availability; 2011 Lead-Based Paint Grant Notice of Funding
Availability; 2008 City grant agreement, and 2011 City lead-based paint hazard control
grant.
• Reviewed 14 lead-based paint hazard control project files for compliance with
procurement and eligibility requirements.
The City received $2,808,897 and selected 335 projects to complete using the lead-based paint
hazard control grant funds during our audit period. Since HUD performed a review of the City’s
grants, we removed the 45 projects HUD reviewed from the 335 audit universe. We also
removed an additional three projects; two had zero dollars spent and one had two entries. Our
remaining universe was 287 projects for the City’s 2008 and 2011 grants. From the universe of
287, we develop a statistical sample of 75. We reviewed a statistical sample of 14 projects
totaling $206,455 7, charged to the 2008 and 2011 lead-based paint grants, from 287 projects
completed totaling $2,808,496 for the audit period December 1, 2008, through August 31, 2014,
which was expanded as determined necessary. Of the 14 projects, 12 were from the 2008 grant,
and 2 were from the 2011 grant. Since we reviewed only 14 the 75 sampled projects, the results
of the audit apply only to items selected for review and cannot be projected to the universe or
population. The statistical sample amount is unit based. From the sample of 14 projects, 4
projects were for the same multi-family complex, Oakwood Apartments, and are presented in
Appendix C as one project. Appendix C also contains a line for the environmental contract.
This contract was not included in the total 14 projects selected. This contract was for
environmental reviews completed on each of the lead-based paint projects.
7
The statistical sample amount is unit based. The unsupported and ineligible procurement costs determined include
the costs on a per project basis and are higher than the sample amount.
9
We relied in part on computer-processed data contained in the City’s systems to achieve our
audit objective. Although we did not perform detailed assessments of the reliability of the data,
we performed minimal levels of testing and found the data to be adequately reliable for our
purposes. The tests for reliability included but were not limited to comparing computer-
processed data to invoices, project files, and other supporting documentation.
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(s). We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.
10
Internal Controls
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the achievement of the organization’s mission,
goals, and objectives with regard to
• Effectiveness and efficiency of operations,
• Reliability of financial reporting, and
• Compliance with applicable laws and regulations.
Internal controls comprise the plans, policies, methods, and procedures used to meet the
organization’s mission, goals, and objectives. Internal controls 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:
• Program operations - Policies and procedures that the management has implemented to
reasonably ensure that a program meets its objectives, while considering cost effectiveness
and efficiency.
• Relevance and reliability of information - Policies and procedures that management has
implemented to reasonably ensure that operational and financial information used for
decision making and reporting externally is relevant, reliable, and fairly disclosed in reports.
• Compliance with laws and regulations - Policies and procedures that management has
implemented to reasonably ensure that program implementation is consistent with laws and
regulations.
We assessed the relevant controls identified above.
A deficiency in internal control exists when the design or operation of a control does not allow
management or employees, in the normal course of performing their assigned functions, the
reasonable opportunity to prevent, detect, or correct (1) impairments to effectiveness or
efficiency of operations, (2) misstatements in financial or performance information, or (3)
violations of laws and regulations on a timely basis.
Significant Deficiency
Based on our review, we believe that the following item is a significant deficiency:
• The City did not properly administer its lead-based paint program (see findings 1 and 2).
11
Appendixes
Appendix A
Schedule of Questioned Costs
Recommendation
Ineligible 1/ Unsupported 2/
number
1A $151,699
1B $45,740
1C $457,327
1D $416,914
2A $9,658 ________
Totals $207,097 $874,241
1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity
that the auditor believes are not allowable by law; contract; or Federal, State, or local
policies or regulations.
2/ Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
or activity when we cannot determine eligibility at the time of the audit. Unsupported
costs require a decision by HUD program officials. This decision, in addition to
obtaining supporting documentation, might involve a legal interpretation or clarification
of departmental policies and procedures.
12
Appendix B
Auditee Comments and OIG’s Evaluation
Ref to OIG Auditee Comments
Evaluation
Comment 1
13
Ref to OIG Auditee Comments
Evaluation
Comment 2
Comment 3
Comment 4
Comment 5
Comment 6
Comment 7
14
Ref to OIG Auditee Comments
Evaluation
Comment 8
Comment 9
Comment 10
15
Ref to OIG Auditee Comments
Evaluation
16
OIG Evaluation of Auditee Comments
Comment 1 The City stated that the agreement between the City and Matrix Health & Safety
L.L.C was not extended in writing, that paragraph C of the agreement allowed the
City to renew it unilaterally on an annual basis through December 2011, and such
extensions were not required by the agreement to be in writing. The City also
stated that for all periods between 2009 and 2013, both the City and Matrix
performed under the same terms and conditions provided for in the original
written agreement. The City was operating under the assumption that the
Agreement was extended by virtue of the past performance of the parties which at
all times was consistent with the written terms of the agreement and the fact that
neither party had given notice to the other that the agreement had been terminated.
A contract extension based on past performance may be enforced under North
Carolina law and the City obtained written confirmation from Matrix that the
agreement was so extended. The City provided a legal opinion as to the
enforceability of the contract extension and the execution of the contract overall.
However, paragraph C of the original 2008 contract states that the agreement is
for services rendered beginning April 1, 2009 through October 31, 2009, and the
City reserves the right to renew subsequent contracts, on an annual basis in the
best interest of the City, through December 2011. The City did not provide any
documentation of the contactors performance for renewal or document the
renewal of the contract. The contract extension provided by the City is dated June
9, 2015, which is 2 years after the work was completed. The legal opinion states
that the agreement itself did not address renewals past December 2011. The City
continued to pay the contractor under the expired contract through July 31, 2013,
which resulted in more than $197,000 being expended. The City continued to use
Matrix until July 31, 2013.
Comment 2 The City stated North Carolina general statutes allow units of government to
consider quality as a consideration for bid awards. The City also stated the +/-15
percent bid range was used by the City’s Community Development and Housing
Department to help ensure the quality of the work that a “responsible” bidder
would provide.
We spoke with a State of North Carolina purchasing Officer and she stated that
she was not aware of this common practice and stated the North Carolina General
Statute, NC GS 143 Article 8, Public Contracts is the State regulation the City
should follow. The statute states, the contract shall be awarded to the lowest
responsible, responsive bidder, taking into consideration quality, performance,
and the time specified in the bids for the performance of the contract.
Comment 3 The City stated due to concerns expressed during the initial site visit from the
HUD Lead Office, it discontinued using the +/- 15 percent bid range. In addition,
the Department has further revised its procurement process by utilizing the City’s
17
Purchasing Department in securing contractors for rehabilitation work as of
November 25, 2014.
We acknowledge the City’s efforts to discontinue using the +/- 15 percent bid
range and revising its procurement process. However, as of March 12, 2015, the
newly developed standard operating procedures had not been dated, signed, or
implemented. Although the City staff had access to the standard operating
procedures on the City’s share drive, the City had not trained its staff on the new
procedures. The City should ensure that the staff is trained on the policies and
procedures for HUD procurement regulations so that the staff no longer uses the
15 percent cost estimate margin. The Office of Healthy Homes and Lead Hazard
Control will be responsible for reviewing the staff training on the policies and
procedures.
Comment 4 The City stated that it located one of the executed contracts (519 N. Centennial)
and forwarded it to the auditors in an email dated March 13, 2015. The executed
contract for the other project (521 Ashburn) could not be located. However, all
other documents associated with this project are located in the project file.
We obtained the executed contract for 519 N. Centennial; therefore, we revised
appendix C. The City agreed that the executed contract for 521 Ashburn could
not be located. However, we disagree with the statement that the file contained
all other documentation as noted in appendix C.
Comment 5 The City stated that in both grant applications, language was included stating that
the City staff will notify contractors and owners of successful bids and a notice-
to-proceed will be issued as a part of the bid acceptance process. However, the
application does not specify the method or form that would be used in a “notice-
to-proceed.” The executed contract between the homeowner and the contractor
served as a de facto “notice-to-proceed” for all parties involved.
As the City stated in both grant applications, language was included stating that
the City staff will notify contractors and owners of successful bids and a notice-
to-proceed will be issued as a part of the bid acceptance process. In addition, the
City’s 2008 and 2011 work plans stated that the contractor and owner must sign
the lead hazard control work agreement and then a notice-to-proceed will be
issued. The contract and notice-to-proceed are two separate documents that are
required to be executed.
Comment 6 The City stated that its staff was able to locate one of the requests for bid (610
Clover) and forwarded it to the auditors in an email dated March 13, 2015. The
request for bid for 415 Welch could not be located. However, all other documents
associated with the completion of the work at 415 Welch are located in the project
file.
18
We obtained the requests for bids for 610 Clover; therefore, we revised appendix
C. The City agreed that the request for bid for 415 Welch could not be located.
However, we disagree with the statement that the file contained all other
documentation as noted in appendix C.
Comment 7 The City stated that the deficiency primarily consisted of missing signatures;
however, bid documents could not be located for one of the projects (1912
Wickham). All other documents associated with the completion of the work at
1912 Wickham are located in the project file.
The City agrees that the bid documents could not be located for 1912 Wickham.
However, we disagree with the statement that the file contained all other
documentation as noted in appendix C.
Comment 8 The City stated that the change orders in question constituted less than 7 percent
of the total contract value. It strongly believes that it is unreasonable to invalidate
the entire contract based on such a small amount.
The City was required by 24 CFR 85.35(f)1 to provide documentation of cost
estimates for change orders. The City was not able to provide any documentation
of change orders for six contracts. We disagree with the statement that it is
unreasonable to invalidate the entire contract based on such a small amount. The
six contracts in question had at least one additional deficiency, associated with the
contract as noted in appendix C.
Comment 9 We acknowledge the City’s steps to submit HUD documentation (1) of internal
controls to ensure compliance with HUD procurement regulations and policies &
procedures so that only eligible costs are paid and costs are properly supported
and (2) stating the staff members are aware of and trained on Department policies
and procedures, especially as it related to HUD procurement regulations on or
before a mutually agreed upon date. The City stated is has already taken steps to
improve internal controls overall. The Office of Healthy Homes and Lead Hazard
Control will be responsible for reviewing verifying whether the actions for
recommendations 1E and 1F are addressed sufficiently.
Comment 10 We acknowledge the City’s comment to reimburse the U.S. Treasury $9,658 from
non-Federal funds for the 2008 grant payments made from ineligible expenses.
The Office of Healthy Homes and Lead Hazard Control will be responsible for
verifying whether the actions for recommendations 2A and 2B are addressed
sufficiently.
19
Appendix C
Procurement Deficiencies
No cost Lack
estimate Lowest of
Lack of Incomplete for bidder request Lack of
Unsupported Ineligible notice to bid change not for executed Expired
Project name amount amount proceed documents order chosen bids contract contract
Lexington
Apartments $408,364 X X X
Oakwood
Apartment (4
files reviewed) $345,330 X X X X
519 North
Centennial $30,950 X X
201 Edgeworth $23,575 X X X X
1115 Anderson $23,300 X X
1805 Arden $16,515 X X
415 Welch $13,307 X X
521 Ashburn $8,550 X X X
610 Clover $3,695 X X X
1005 Barbee $2,225 X X
1912 Wickham $750 X X X
Environmental
8
contract $197,439 X X
Total $876,561 $197,439 12 6 6 5 1 1 1
8
This contractor performed the lead testing for all the projects reviewed.
20
The City of High Point Did Not Properly Administer Its Lead-Based Paint Hazard Control Grants in Compliance With Federal Requirements
Published by the Department of Housing and Urban Development, Office of Inspector General on 2015-07-09.
Below is a raw (and likely hideous) rendition of the original report. (PDF)