Working with Local OHHLHC Grant Funded Agencies

Working with Local OHHLHC Grant Funded Agencies August 8, 2013 Barb Kimmel City of Lansing 517-483-4053 barb.kimmel@lansingmi.gov

Or What 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 Monitoring OHHLHC 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 Review Scrutinized 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 Visits Viewed 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 Visits Proper 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 Visits Verified 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!

Working with Local OHHLHC Grant Funded Agencies