CITY OF PITTSBURGH

Finding 2024-001: Subrecipient Monitoring Federal Agency: U.S. Department of Housing and Urban Development Frogram Name: COVID 19 — HOME Investment Partnerships Program and HOME Investment Partnerships Program (HOME) - ALN 14.239; Award Identification Number: MC420501 Criteria of Specific Requirement: Per 2 CFR 200.332, a pass-through entity must monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Condition: During our testing of subrecipient monitoring, we noted that the City did not perform required monitoring procedures during the year. Questioned Costs: Unknown Cause: The City did not have adequate internal controls in place to ensure compliance with subrecipient monitoring requirements, and staffing turnover contributed to the lack of oversight. Effect: The City was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is not a repeat finding from the prior audit. Recommendation: We recommend the City implement controls to ensure compliance with subrecipient monitoring, documenting monitoring activities performed and following up on any identified deficiencies in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see corrective action plan below. History The City initiated monitoring of the HOME program in March 2023, and the local office of the Department of Housing and Urban Development (HUD) initiated its own monitoring in June 2023. To avoid duplicative work, the City shifted its approach and reviewed closed programs while HUD monitored open programs. These monitoring efforts resulted in significant updates to program policies and procedures. The City's monitoring was completed in October 2023 and HUD's monitoring was finalized in October 2024. Correction Action Plan Since October 2024, the City has collaborated with its subrecipient, the Urban Redevelopment Authority (URA), to implement a streamlined, informal quarterly review process. While formal HOME monitoring has not occurred since the end of the HUD monitoring, the City will initiate a review before the end of 2025 to return to compliance. Monitoring will occur annually moving forward.

Finding 2023-001: Reporting - Federal Funding Accountability and Transparency Act Program Name: COVID-19 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants and Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants (CDBG), AL Number: 14.218 (Grant No. MC420103) Criteria of Specific Requirement: Federal Funding Accountability and Transparency Act (FFATA) (as codified in 2 CFR parts 170) requires direct recipients of grants and cooperative agreements to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: The City's did not comply with FFATA reporting requirements. Questioned Costs: None Cause: The Department responsible for this grant did not complete the reports as required under FFATA. Effect: The City was not in compliance with reporting requirements under FFATA. Identification as a Repeat Finding: This is not a repeat finding from the prior audit. Recommendation: The City should implement procedures to ensure all required reporting is completed. The City's corrective action follows. Action Taken: The City will report all missing 2023 obligations before the end of October 2024.The City has established an internal process to ensure compliance with FFATA moving forward. Members of the Community Development leadership team will conduct monthly recurring meetings to review which newly-executed contracts in the prior period exceed the $30,000.00 threshold. Once determined, the appropriate information will be entered into the FFATA system by the established deadlines. In addition to monthly meetings on individual electronic calendars, monthly reminders have been clearly marked on a large calendar in a shared workspace. If you have any, questions, I can be reached at 412-255-2640. Jake Pawlak

The City?s corrective action follows. Action Taken: The City has developed an internal process to ensure compliance with contracting deadlines. The Community Development leadership team now conducts monthly contract check-in meetings with Program Coordinators. During these meetings, contract execution timelines are discussed. If a subrecipient has not submitted contract documentation 90 days before the appropriate deadline, the Program Coordinator will contact the subrecipient to better understand why the contract documents were not submitted. The Program Coordinator will continue to contact the subrecipient, via email and telephone, each week until all materials are submitted and the agreement is executed. Additionally, all deadlines are clearly marked on a large calendar in a shared workspace as well as on individual electronic calendars. If you have any questions, I can be reached at 412-255-2640. Sincerely, Jake Pawlak Director, Office of Management & Budget

2019-001 ? Emergency Solutions Grant Program (ESG) ? Obligation Requirements Questioned Costs: $0 Statement of Condition: The City of Pittsburgh (City) received a monitoring report, dated November 4, 2019, regarding the City?s ESG funds (2017 ESG funding) from the HUD Pittsburgh Field Office. The report indicates that the City?s ESG sub-recipient contracts were not signed within 180 days of HUD?s grant agreement with the City as prescribed in the ESG single audit compliance supplement and 24 CFR 576.203(a)(2). Current year testing found one of four contracts selected was signed after the 180 days of the City?s signed agreement with HUD. Action Taken: The City of Pittsburgh has drafted amendments to the ?Emergency Solutions Grant (ESG) Program Policies and Procedures Manual.? The amendments include a reference to HUD?s requirement of sub-recipient contract execution within 180 days of the execution of the grant agreement as prescribed in 24 CFR 576.203(a)(2). Additionally, the updated policies and procedures manual includes a new policy that sub-recipients who do not return their contracts executed within 60 days of receipt are subject to having their funds re-allocated to another program. These updates will be submitted to HUD for review by 09.30.20. The Office of Management and Budget has also added internal controls to help meet this requirement. These include a tracker for all program contracts that records when the City?s grant agreement with HUD is executed, and when each sub-recipient grant agreement is executed, and a formula that counts down to the 180 day deadline. OMB staff can filter the spreadsheet to review the grant agreements that still need to be executed so we can focus efforts on getting those agreements signed. OMB has also set up monthly recurring meetings with fiscal team members and the Law department. Each meeting includes a review of the outstanding contracts and a strategy discussion for getting them executed.

2019-002 ? Emergency Solutions Grant Program (ESG) and Housing Opportunities for Persons with AIDS (HOPWA) ? Contract Requirements U.S. Department of Housing and Urban Development (HUD) ? CFDA #14.231; Grant #MC420103 and CFDA #14.241; Grant #MC420501 Questioned Costs: $0 Statement of Condition: The City of Pittsburgh (City) received a monitoring report, dated November 4, 2019, regarding the City?s ESG funds (2017 ESG funding) from the HUD Pittsburgh Field Office. The report indicates that the City?s ESG sub-recipient contracts did not include all the requirements of 2 CFR 200.331 Federal Award Identification. Current year testing for both the ESG program and the HOPWA program indicated the same condition continues in which some but not all requirements noted above are included within the contracts. Action Taken: The City of Pittsburgh has begun drafting the 2020 Emergency Solutions Grant contracts to reflect the below language from 2 CFR 200.331 Federal Award Identification. OMB also added this information as part of the aforementioned amendments to the ?Emergency Solutions Grant (ESG) Program Policies and Procedures Manual.? (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see ? 200.39 Federal award date) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (vii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current obligation; (viii) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (x) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xi) CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; (xii) Identification of whether the award is R&D; and (xiii) Indirect cost rate for the Federal award (including if the de minimis rate is charged per ? 200.414 Indirect (F&A) costs).

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