EIN: 946000311
UEI: FZXEQ4KUYKE7
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 12, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 12, 2022 (1413 days ago).
What is a management decision? →During our audit of the CDBG - Entitlement Grants Cluster, we noted six out of six rehabilitation samples selected for testing were missing required information needed to determine if the rehabilitation work is properly completed. Six out of the six samples were missing the rehabilitation contract used to determine that the deficiencies noted in the pre-rehabilitation inspection were included in the work to be completed. Five out of the six samples were missing the final inspection documenting that the grantee inspected the rehabilitation work upon completion to assure that it is carried out in accordance with contract specifications. Cause: The City did not keep adequate files with one or more of the documents missing that are being requested; i.e. pre-rehabilitation inspection or scope of work write ups noting deficiencies to be corrected, rehabilitation contracts that incorporated the deficiencies to be corrected, and final inspection reports. Effect or Potential Effect: Without proper documentation, the auditor was unable to determine if the rehabilitation work was properly completed. Questioned Costs: None. Context: We selected six out of 36 rehabilitation projects for the CDBG - Entitlement Grants Cluster for testing. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend the City enhance the internal control procedures to ensure the required Rehabilitation records are maintained to determine if the rehabilitation work was properly completed. View of Responsible Officials: The City concurs with the auditor?s finding. The City?s Finance Department has implemented procedures to maintain proper record keeping for the program. There is a new Housing Program Manager at the City and the files and record keeping are currently administered in strict adherence to CDBG and HUD program regulations and follows the general sequence below: 1. City manages an interest list and accepts rehabilitation applications when funding is available, on a first- come-first-served basis. 2. City staff reviews application for eligibility and forwards accepted applications to construction inspector (in this case it was Habitat for Humanity) for inspection and work write up. 3. Dependent on the inspection, construction inspector may recommend applicant for funding, or identify applicants that are not qualified due to scope of work being ineligible. 4. City staff, construction inspector, and homeowner review, approve and sign Scope of Work for file. 5. City works with applicant to obtain bids. 6. Applicant advises City which contractor they are selecting. 7. City drafts Rehabilitation Contract between City and Applicant, forwards to Applicant for signatures, signs and submits to construction inspector and to file. 8. Construction inspector and applicant oversee construction work. 9. After completion, construction inspector and applicant have a final inspection of finished work, and both sign off on Certification of Final Inspection and Statement of Satisfaction (for file). Or a punch list is prepared if additional work is needed. 10. City administers all invoicing and payments. 11. File is closed, construction inspector provides closed file, including pictures and correspondence, to City for records retention.
Show full finding ▾Hide full finding ▴Finding 2021-001 Special Tests and Provisions ? Internal Control and Compliance over Rehabilitation Information on the Federal Program: Federal Catalog Number: 14.218 Federal Program Name: CDBG - Entitlement Grants Cluster Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Number and Award Year: B-14-MC-06-0062 ? FY 14-15; B-15-MC-06-0062 ? FY 15-16 B-16-MC-06-0062 ? FY 16-17; B-17-MC-06-0062 ? FY 17-18 B-18-MC-06-0062 ? FY 18-19; B-19-MC-06-0062 ? FY 19-20 B-19-MW-06-0062 ? FY 19-20; B-20-MC-06-0062 ? FY 20-21 B-20-MW-06-0062 ? FY 20-21 Criteria: Per the 2021 OMB Compliance Supplement, Part 4 - CDBG - Entitlement Grants Cluster, Special Tests and Provisions ? Rehabilitation, ?When CDBG funds are used for rehabilitation, the grantee must ensure that the work is properly completed (24 CFR section 570.506).? 2 CFR section 570.506 Records to be maintained, states ?Each recipient shall establish and maintain sufficient records to enable the Secretary to determine whether the recipient has met the requirements of this part. At a minimum, the following records are needed: (h) Financial records, in accordance with the applicable requirements listed in ? 570.502, including source documentation for entities not subject to 2 CFR part 200. Grantees shall maintain evidence to support how the CDBG funds provided to such entities are expended. Such documentation must include, to the extent applicable, invoices, schedules containing comparisons of budgeted amounts and actual expenditures, construction progress schedules signed by appropriate parties (e.g., general contractor and/or a project architect), and/or other documentation appropriate to the nature of the activity. Grantee records pertaining to obligations, expenditures, and drawdowns must be able to relate financial transactions to either a specific origin year grant or to program income received during a specific program year. Condition: During our audit of the CDBG - Entitlement Grants Cluster, we noted six out of six rehabilitation samples selected for testing were missing required information needed to determine if the rehabilitation work is properly completed. Six out of the six samples were missing the rehabilitation contract used to determine that the deficiencies noted in the pre-rehabilitation inspection were included in the work to be completed. Five out of the six samples were missing the final inspection documenting that the grantee inspected the rehabilitation work upon completion to assure that it is carried out in accordance with contract specifications. Cause: The City did not keep adequate files with one or more of the documents missing that are being requested; i.e. pre-rehabilitation inspection or scope of work write ups noting deficiencies to be corrected, rehabilitation contracts that incorporated the deficiencies to be corrected, and final inspection reports. Effect or Potential Effect: Without proper documentation, the auditor was unable to determine if the rehabilitation work was properly completed. Questioned Costs: None. Context: We selected six out of 36 rehabilitation projects for the CDBG - Entitlement Grants Cluster for testing. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend the City enhance the internal control procedures to ensure the required Rehabilitation records are maintained to determine if the rehabilitation work was properly completed. View of Responsible Officials: The City concurs with the auditor?s finding. The City?s Finance Department has implemented procedures to maintain proper record keeping for the program. There is a new Housing Program Manager at the City and the files and record keeping are currently administered in strict adherence to CDBG and HUD program regulations and follows the general sequence below: 1. City manages an interest list and accepts rehabilitation applications when funding is available, on a first- come-first-served basis. 2. City staff reviews application for eligibility and forwards accepted applications to construction inspector (in this case it was Habitat for Humanity) for inspection and work write up. 3. Dependent on the inspection, construction inspector may recommend applicant for funding, or identify applicants that are not qualified due to scope of work being ineligible. 4. City staff, construction inspector, and homeowner review, approve and sign Scope of Work for file. 5. City works with applicant to obtain bids. 6. Applicant advises City which contractor they are selecting. 7. City drafts Rehabilitation Contract between City and Applicant, forwards to Applicant for signatures, signs and submits to construction inspector and to file. 8. Construction inspector and applicant oversee construction work. 9. After completion, construction inspector and applicant have a final inspection of finished work, and both sign off on Certification of Final Inspection and Statement of Satisfaction (for file). Or a punch list is prepared if additional work is needed. 10. City administers all invoicing and payments. 11. File is closed, construction inspector provides closed file, including pictures and correspondence, to City for records retention.
In relation to the City of Clovis? annual financial statement audit and the single audit for the year ended June 30, 2021, the City hereby submits a corrective action plan, as required by Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 511 Audit findings follow-up. Corrective Action Plan SECTION III ? FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS Finding 2021-001 Special Tests and Provisions ? Internal Control and Compliance over Rehabilitation Condition: During our audit of the CDBG - Entitlement Grants Cluster, we noted six out of six rehabilitation samples selected for testing were missing required information needed to determine if the rehabilitation work is properly completed. Six out of the six samples were missing the rehabilitation contract used to determine that the deficiencies noted in the pre-rehabilitation inspection were included in the work to be completed. Five out of the six samples were missing the final inspection documenting that the grantee inspected the rehabilitation work upon completion to assure that it is carried out in accordance with contract specifications. City?s Corrective Action Plan: The City concurs with the auditor?s finding. The City?s Finance Department has implemented procedures to maintain proper record keeping for the program. There is a new Housing Program Manager at the City and the files and record keeping are currently administered in strict adherence to CDBG and HUD program regulations and follows the general sequence below: 1. City manages an interest list and accepts rehabilitation applications when funding is available, on a first come, first served basis. 2. City staff reviews application for eligibility and forwards accepted applications to construction inspector (in the year audited, it was Habitat for Humanity) to perform an initial inspection and to draft the scope of work. 3. Dependent on the inspection findings and costs associated with the scope of work, the construction inspector may recommend applicant to City for funding or identify applicants that are not qualified due to scope of work being ineligible. 4. City staff, construction inspector, and homeowner review, approve and sign Scope of Work for Rehabilitation Contract, bidding purposes and for file. 5. City drafts Rehabilitation Contract (Homeowner Agreement) between City and Applicant, forwards to Applicant for signatures, and routes for internal signatures. Contract is submitted to construction inspector and kept in file. 6. Construction inspector works with applicant to obtain bids. 7. Qualifying bids are provided to applicant for Applicant selection. 8. Bid is awarded, Applicant signs contract with Contractor, and construction inspector issues Notice to Proceed to Contractor. 9. Construction inspector and applicant oversee construction work. 10. After completion, construction inspector and applicant conduct a final inspection of finished work, and both sign off on Certification of Final Inspection and Statement of Satisfaction (for file). If needed, a punch list is prepared. 11. Once signed Final Inspection and Statement of Satisfaction is provided to the City, City staff processes all invoicing and payments. 12. Construction inspector provides file documentation, including any original documents, pictures and correspondence, to City for records retention. City staff closes the file and updates any programmatic data as necessary. Contact person responsible for corrective action: Jay Schengel, Finance Director Anticipated completion date: Fiscal year ending June 30, 2022
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