OIG AUDIT A GRANTEE S PERSPECTIVE
FLOOD SUMMER OF 2011 CDBG-DR ALLOCATION $67 MILLION 2012 CDBG-DR ALLOCATION $35 MILLION 2013 NOT AN ENTITLEMENT CITY BUT TREATED AS ONE
THE LETTER OIG AUDIT NOTIFICATION LETTER GRANTEE IS PROVIDED LIST OF INFORMATION REQUESTED IN ADVANCE OF THE OIG ARRIVAL REVIEW FILES AND PROJECTS INFORM OTHER CITY STAFF AND ADMINISTRATIVE CONSULTANT OIG ENTRANCE CONFERENCE ON-SITE REVIEW EXIT CONFERENCE DRAFT REPORT ISSUED OPPORTUNITY TO RESPOND WITH WRITTEN COMMENTS OIG ISSUES A FINAL REPORT WITH OUR COMMENTS AND THE OIG REBUTTAL
INITIAL DATA REQUEST CURRENT ORGANIZATION CHART CAFR ACTION PLAN(S) GRANT AGREEMENTS WAIVERS POLICIES AND PROCEDURES LOCAL PROCUREMENT GUIDANCE
DATA REQUEST FOR FIELD WORK ALL RECORDS RELATED TO THE OBLIGATION AND EXPENDITURE OF CDBG DISASTER RECOVERY GRANT FUNDS ALL ACCOUNTING RECORDS, PROGRAM FILES, AND MONITORING FILES RELATED TO CDBG DISASTER RECOVERY GRANT FUNDS CITY COUNCIL BOARD MINUTES INCLUDING RESOLUTIONS RELATED TO CDBG DISASTER RECOVERY ENVIRONMENTAL REVIEWS
DATA REQUEST FOR FIELD WORK ALL RECORDS RELATED TO THE OBLIGATION AND EXPENDITURE OF CDBG DISASTER RECOVERY GRANT FUNDS ALL ACCOUNTING RECORDS, PROGRAM FILES, AND MONITORING FILES RELATED TO CDBG DISASTER RECOVERY GRANT FUNDS ENVIRONMENTAL REVIEWS INVOICES AND CHECK VOUCHERS AND CONTRACTS, SUCH AS THOSE FOR DEVELOPERS, GRANT ADMINISTRATORS, AND CONSULTANTS CITY COUNCIL BOARD MINUTES INCLUDING RESOLUTIONS RELATED TO CDBG DISASTER RECOVERY
OIG AUDIT FINDINGS CITY DID NOT FULL COMPLY WITH FEDERAL AND LOCAL PROCUREMENT REQUIREMENTS THE CITY SIGNED TWO CONTRACT AMENDMENTS BEFORE CITY COUNCIL APPROVAL THE CITY DID NOT ALWAYS PREPARE INDEPENDENT COST ESTIMATES THE CITY DID NOT PERFORM DEBARMENT CHECKS BEFORE AWARDING THREE CONTRACTS
CITY S RESPONSE THE CITY DID NOT ALWAYS PREPARE INDEPENDENT COST ESTIMATES IN ACCORDANCE WITH 24 CFR 85.36(B) THROUGH (I) A COST ANALYSIS WILL BE NECESSARY WHEN ADEQUATE PRICE COMPETITION IS LACKING, AND FOR SOLE SOURCE PROCUREMENTS, INCLUDING CONTRACT MODIFICATIONS OR CHANGE ORDERS PER HUD GUIDELINES: CONTRACT MODIFICATIONS. IF YOU ARE NEGOTIATING A MODIFICATION (INCLUDING CHANGE ORDERS) TO ANY CONTRACT (EVEN IF THE BASIC CONTRACT WAS AWARDED COMPETITIVELY THROUGH SEALED BIDDING) THAT CHANGES THE SCOPE OF THE WORK PREVIOUSLY AUTHORIZED AND IMPACTS THE PRICE OR ESTIMATED COST, YOU MUST USE COST ANALYSIS TO ARRIVE AT A REASONABLE COST. THE ONLY EXCEPTION TO THIS RULE IS A CONTRACT MODIFICATION BASED ON PRICING TERMS ALREADY ESTABLISHED IN THE CONTRACT DOCUMENT....:
CITY S RESPONSE THE CITY DID NOT PERFORM DEBARMENT CHECKS BEFORE AWARDING THREE CONTRACTS THE CITY COMPLETED DEBARMENT CHECKS ON 50 CONTRACTORS AND SUB-CONTRACTORS FOR EACH AND EVERY PROJECT FOR WHICH THE CITY HAS UTILIZED HUD CDBG FUNDS. THE THREE DEBARMENT CHECKS IDENTIFIED IN THE OIG AUDIT AS NOT HAVING OCCURRED PRIOR TO CONTRACT AWARD WERE COMPLETED SHORTLY AFTER BID AWARD AND THE CONTRACTOR AND SUB-CONTRACTORS WERE FOUND TO HAVE NO ISSUES.
CITY S RESPONSE THE CITY SIGNED TWO CONTRACT AMENDMENTS BEFORE CITY COUNCIL APPROVAL THE CITY FULLY DISAGREED WITH THE FINDING. THE DATE THE OIG AUDITORS REFERENCED WAS THE DATE THE DOCUMENT WAS WRITTEN VERSUS THE DATE THE DOCUMENT WAS SIGNED.
OIG AUDIT FINDINGS & CITY RESPONSE THE CITY LACKED DETAILED OPERATION PROCEDURES AND CHECKLISTS THE CITY DEVELOPED A NEW PROCUREMENT CHECKLIST TO STRENGTH CONTROLS AND REVISED OUR PROCUREMENT POLICY
AFTER THEY ARE GONE GRANTEE AND HUD REGIONAL OFFICE DETERMINE WHAT ACTION, IF ANY, IS REQUIRED HUD REGIONAL OFFICE DRAFTS A MANAGEMENT DECISION OUTLINING ANY CORRECTIVE ACTIONS NECESSARY OIG AGREES OR DISAGREES HUD REGIONAL OFFICE WORKS WITH THE GRANTEE TO SATISFY THE CORRECTIVE ACTIONS
LESSONS LEARNED PERFORM ANALYSIS ON ALL CHANGE ORDERS VERIFY DEBARMENT CHECKS ARE DONE PRIOR ENSURE ALL CITY STAFF ARE AWARE OF THE PROCUREMENT REGULATIONS AND GUIDELINES DUE DILIGENCE ON DATES KEEP CITY MANAGER AND ELECTED OFFICIALS UP TO DATE ON THE ENTIRE PROCESS CHECK AND DOUBLE CHECK EVERYTHING AND DOCUMENT, DOCUMENT!