Report 2009-119.3 Recommendation 2 Responses

Report 2009-119.3: Department of Housing and Community Development: Despite Being Mostly Prepared, It Must Take Additional Steps to Better Ensure Proper Implementation of the Recovery Act's Homelessness Prevention Program (Release Date: February 2010)

Recommendation #2 To: Housing and Community Development, Department of

The department should finalize and implement those policies that are currently in draft form. Specifically, the department should finalize and implement its draft guidelines for monitoring subrecipients, including its plans to conduct quarterly surveys of subrecipients and to perform risk assessments of the subrecipients. These guidelines should ensure that subrecipients comply with the following:
- Costs incurred are for only those services allowed by law.
- The time period between receiving and spending federal funds is minimized, which has the effect of limiting the federal cash balances that subrecipients maintain.
- Federal cash balances are maintained in interest-bearing accounts.
- Households receiving services are eligible to participate.
- Eligible households are not charged fees to participate.
- The two- and three-year spending deadlines are met.
- Administrative costs stay within applicable limits.
- Reports submitted to the department contain accurate and complete information.
- The 11 requirements identified in the March 2009 notice issued by the U.S. Department of Housing and Urban Development are met, including habitability standards for housing units, nondiscrimination and equal opportunity requirements, and requirements involving lead-based paint.
- Registration in the federal Central Contractor Register is maintained.

6-Month Agency Response

The department finalized and implemented its guidelines for monitoring subrecipients, including guidelines for reviewing quarterly expenditure reports to ensure subrecipients expended program funds on only those services allowed by law, and a quarterly subrecipient questionnaire to solicit contract management information and identify possible red flags. Additionally, to help ensure that subrecipients meet spending deadlines, the guidelines also include a policy and procedure for monitoring subrecipients no later than 120 days before the deadlines. The guidelines also include procedures to review information included in quarterly expenditure reports to ensure accuracy and completeness, as well as procedures for performing site monitoring and desk audits of subrecipients that incorporate the requirements identified in federal guidance. (See 2011-406 p. 206)

California State Auditor's Assessment of 6-Month Status: Fully Implemented

All Recommendations in 2009-119.3

Agency responses received after June 2013 are posted verbatim.