Sneak Preview: Better Oversight Sought for Pa. Homeless Programs

February 22, 2016 | By Jerry Ashworth | Post a Comment

xsass_bookshot(The following was excerpted from a recent article in the Single Audit Information Service.) The Pennsylvania Department of Community and Economic Development (DCED) is developing formal written procedures to ensure that it enforces a special condition requiring its Emergency Solutions Grant (ESG) subrecipients comply with a 12-month expenditure requirement, and that it appropriately reallocates funds that were not spent, in response to a recent audit by the Pennsylvania Auditor General. The department also is preparing a comprehensive monitoring plan to improve its reviews of HOME Investment Partnership Program subgrantees.

The auditor general assessed DCED’s administration and oversight of the two homeless prevention and rehousing programs from July 2011 to June 2014. Through the ESG program, DCED subawards about $5 million annually to counties, cities and shelters to address housing needs for victims of domestic abuse, persons with disabilities and displaced families. DCED also receives about $15 million annually under the HOME Investment Partnership program to help local agencies expand the supply of decent, safe, sanitary and affordable housing for low-income individuals.

The auditor general’s office found several deficiencies in DCED’s oversight of the two programs. Among them, it determined that the department did not always enforce and/or document ESG subrecipients’ compliance with the state’s “midway spending requirement,” and that it failed to reallocate 2013 ESG funds that it recaptured from subrecipients that did not meet this requirement. Along with a 24-month grant period spending limit imposed by the U.S. Department of Housing and Urban Development for its ESG grant recipients, DCED also has an additional spending requirement in which ESG subrecipients must expend at least 50 percent of their allocated funds no later than 12 months after the subaward period start date (i.e., midway through the funding period). The special condition enables DCED to recapture a percentage of the grant funds from those subrecipients that fail to allocate 50 percent of their funds after 12 months. Although this requirement has been incorporated in the ESG subrecipients’ terms and conditions since 2011, DCED did not enforce the requirement during the 2011 and 2012 program years.

DCED began enforcing the requirement during the 2013 ESG program year, but the auditor general found that the department did not retain written analysis supporting this enforcement. “Decisionmaking documentation must be retained to allow an independent third party to review and evaluate the documentation to ensure it was performed accurately and that the decisions reached were reasonable,” the auditor general said.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site.)

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