Working with Local OHHLHC Grant Funded AgenciesAugust 8, 2013Barb KimmelCity of Lansing517-483-4053barb.kimmel@lansingmi.gov

OrWhat happens to YOU when WE get audited

And WE WILL

be audited…

What’s Driving This?OHHLHC has received findings after being audited by the Office of the Inspector General over the last several years.

What’s Driving This?In response to the findings, the OHHLHC adjusted its procedures and practices, and increased monitoring of Grantees

OHHLHC MonitoringOHHLHC Performed on-site monitoring of over 50 grantees during 2012. They identified major findings among those grantees, such as: Inadequate Risk Assessments Specifications not clearly derived from

the Risk Assessment Clearance testing not conducted per the

Guidelines

Findings (cont.) Clearance Reports not in project files Contractors were not properly certified

to perform lead hazard control work Tier II Environmental Reviews not

completed Income Eligibility not properly followed

or documented Poor file management

Findings (cont.) Poor documentation of activities Insufficient documentation and tracking

of Administrative Costs Inadequate tracking of match funds

Result:Issuance of additional Policy Guidance from OHHLHC to Grantees regarding Additional documentation from grantees

for administrative and indirect costs Match eligibility and tracking “Clarifications” of Title X and unit

eligibility related to units not occupied by children

Result: Additional testing and documentation

requirements for Risk Assessment/Paint Inspections used in OHHLHC grant program projects.

HUD’s Monitoring Focus Review of financial procedures/tracking

systems Review of Procedures and Policies In Depth File Review Site Visits

File Review:Risk Assessment/Paint Inspections: Combed through these reports to see if new 2012 HUD Guidelines were being followed. Focused on Window and component testing-they want

each window tested OR photographed to document hazards

Intact/Deteriorated vs. Good/Fair/Poor Did not like that Trough Wipes were included

and referred to but unnecessary per HUD

File ReviewScrutinized work plans to make certain that work and components specified were directly related to Risk Assessment/Paint Inspection-identified hazards. specs must be reviewed for correctness

prior to bidding All bid documents retained in file Change Orders: Estimate and photos

File Review:Must have up to date information regarding Contractors: License Insurance Lead Certifications (Worker, Supervisor,

Abatement Contractor, RRP) SAM (System for Award Management) –

Debarrment Search documentation for Contractor and all subcontractors

File Review: Unit and Income qualification

documentation-complete, accurate, accompanied by written approval

Utilization of prioritization of units for enrollment/referral/action

Clear separation of work plan items funded by LHC/LHRD from items ineligible or not funded by these funds

Site Visits Dissected Risk Assessment/Paint

Inspections and specifications to see that work was completed as specified.

Interviewed Property Owner regarding satisfaction with work, program management and customer service.

Viewed work performed to insure that quality of work was high, and work was performed to industry standards.

Site VisitsViewed jobsite for Proper containment methods in place

Site Visits Required signage in place

Site Visit Reviewed Occupant Protection Plan for

consistency with Risk Assessment and specifications

Site VisitsProper certification of contractor/workers Lead Abatement Supervisor on site Lead Abatement Supervisor/Workers

performing work RRP Training and Certification DO NOT

qualify any worker or subcontractor to perform work onsite prior to clearance.

Site VisitsVerified that Clearance was achieved

GTR’s are flagging risk assessments and demanding that funds be paid back to HUD from non-federal sources.

No municipality or health department has General Fund dollars to repay HUD

GTR’s are also holding up payments to Grantees, forcing them to fund hundreds of thousands of dollars of program costs without reimbursement in the seeable future

GTR’s visited jobsites in Michigan, and found uncertified workers performing remediation on HUD funded jobs They requested that the Enforcement

Officers visit the job and cite the company

Lessons learned: The Grantee is responsible for ensuring

program is operating within the Federal guidelines

Contractors must all be educated about their responsibilities and bring their “A Game” every time on every job.

The Grantee is responsible for ensuring that everyone is fully informed about their role, and in full compliance with the law.

Lessons Learned Program funding is jeopardized when

findings are brought forward from OHHLHC

Decrease in funding jeopardizes financial health of contractors

Contractors who know and follow the rules and care about benchmark deadlines are important partners in the process.

Last Word: Utilize only skilled, certified contractors

that follow the rules

Make certain your jobsite is in compliance and occupants and belongings are properly protected

Document, Document, Document!