HomeMy WebLinkAbout950290.tiffSITE,
COLORADO
DIVISION OF HOUSING
Tom Hart, Director
January 27, 1995
Ms. Constance Harbert
Chairman, Weld County Commissioners
PO Box 758
Greeley, CO 80632
E'? tedatment of Local Affairs
RE: CDBG 92-743
HOME 93-043
Roy --Romer
Governor
Larry Kallenberger
Executive Director
Dear Commissioner Harbert:
On December 7, 1994, Kate Van Wyhe of our staff conducted a monitoring visit with Jim Sheehan,
Executive Director, Weld County Housing Authority, and Paul Pryor, Rehab Specialist, regarding the above -
mentioned contract. The following areas of compliance were included in the monitoring:
Application Certification and Project Start -Up
Eligibility of Activities and National Object/es
Limited Reviews of Financial Management, Environmental, Civil Rights and Labor Standards.
There were areas of concern as well as findings we need to address for this monitoring:
Concerns:
When Weld County requested a contract extension and transfer of budget funds to complete all 19
single family owner -occupied rehabs, Jim Sheehan told DOH there would be no problem in
meeting that commitment. Since only 15 rehabs were completed by the end of the project , there
should have been surplus funds in the rehab category, but all the rehab money had been
expended.
We realize that construction costs have risen markedly in the last year, which is why we were
concerned about the accuracy of the requested transfer of funds to cover the 19 rehabs. When we
were assured by Jim that he could do them for that amount, we granted the extension. The issue
here is one of overall project management. The Housing Authority needs to more accurately
estimate the number of projects they can realistically accomplish within the contract period.
The Housing Authority loans a maximum of $13,600 for the rental rehab work, which is a portion of
the total cost. The homeowner then is free to use the $13,600 as he sees fa. When the
homeowner is the general contractor, as is quite often the case, there is no federal requirement to
formally bid out any subcontracting work for the lowest bid. However, federal funds require the
following procurement procedure:
"Small purchase procedures are those relatively simple and informal procurement
methods for securing services, supplies, or other property that do not cost more than
$25,000 in the aggregate. If small purchase procurements are used, price or rate
quotations will be obtained from an adequate number of qualified sources." CFR
Part 85, Sec. 85.36(c)(4)(d)
1� If the federal funds put in the unit exceed $25,000, procurement must be by sealed bid
1 A6 (85.36(d)(2)). 950290
/) 1313 Sherman Street, Room 323, Denver, Colorado 80203 (303) 866-2033 FAX (303) 866-4485 TDD (303) 866-5300
J
January 27, 1995
Page Two
We suggest that the Housing Authority provide more oversight in the rental rehab program by:
Ensuring that the homeowner acquires at least two price quotations for the contracting work and
supplies. The homeowner needs to document an attempt to get the best dollar value when
purchasing materials. The homeowner should provide price quotes and note the
date/store/item/quoted cost for the purchase of items over $100. (In one rental rehab file, there
were invoices for items that cost $500+ and $1,000+ from Hugh M. Woods with no backup
documentation that the owner had done any comparison shopping to ensure that this was the best
price.)
The rehab specialist should make progress inspections before authorizing payment, and inspect
the finished work to ensure the house meets HQS standards and the items that were contracted for
have been completed.
Minority contractors need to be tracked for the rental rehab program, and should be reported to
DOH at the end of the contract period. No record is currently being maintained by the Housing
Authority of minority contractors used for the rental rehab work.
Findings:
Disorganized Files
In past years' monitorings, our staff has noted consistently that the files have been disorganized (letters
attached).. The condition of the files makes it difficult to locate needed information to administer the
program on a daily basis, to produce accurate and timely reports, and to monitor the contract.
The individual client files were also in disarray. There were blank change order forms bound into the file
which were irrelevant, missing environmental clearance forms, missing debarred contractor checks, no
date of inspection, and in several, no tracking of the contractor bid process.
Suggested Action: Within one month (30 days) from the date of this letter, the files mentioned
above need to be organized in such a manner so that the required paper work is readily available. DOH
will re -monitor the administrative and individual client files after one month's time for compliance before this
finding can be removed. Upon the Housing Authority's notification that the files are complete, DOH will
reschedule another visit to complete the monitoring.
At the beginning of a new contract period, the administrative files should be set up as the past years'
administrative files have been arranged after the expiration of the contract, and should contain all of the
information that complies with the grant's requirements. The client files should be kept in chronological
order so that the bid process and any procured items, change orders, etc. are clear to anyone reading the
file. The client files need to include the information on the attached checklist.
Contractor Bid Process
No formal bid process was conducted in securing contractors from August to December 1994 for the
SFOO rehab work. We understand that Weld County felt pressure to complete the rehab jobs after the
49th Street project fell through, but at no time was our office informed of this problem to see if we could
help work out a more equitable and allowable procedure for securing contractors on a timely basis.
January 27, 1995
Page Three
Suggested Action: There is no action that can be taken now to correct the lack of formal bidding that has
already occurred. However, in any future contract with DOH, proper bid procedures must be adhered to or
the expenditures will be declared ineligible and subject to repayment by the Housing Authority.
Contractor Debarred Checks
Debarred contractor checks have only been requested every six months. In some cases, the work had
already started or was completed before the contractor was checked out. This was the result of a
misunderstanding on Paul Pryor's part as to when he thought he should request the debarred check, but
logic dictates that a contractor should be checked out prior to the beginning of the project, to see if they are,
in fact, qualified to do the contracted work.
Suggested Action: All contractors must pass a debarred check before construction work begins. In any
future contract, if that does not occur, expenditures on the property will be declared an ineligible cost and
subject to repayment by the Housing Authority.
LOCCS Accountina Records
During monitoring, there were several items in the LOCCS accounting records that could not be reconciled.
For example,
Two different setup reports at $13,600 each were initiated for the same client/property. (At the time
of monitoring, the Housing Authority stated that all available HOME money had been expended.
However, since there were two duplicate setup amounts, it would appear an additional $13,600
could have been accessed for rehab purposes, had a better mmanagement and tracking system
been in place.
There were instances where final draws and completion reports were for larger amounts than the
original setup amount without a revised setup having been filed with HUD.
There were also instances where the draws reported did not match the amount in the completion
report.
Suggested Action: Before this contract can be closed out, the Housing Authority must reconcile their
LOCCS draws. The LOCCS issue should be cleared up and ready for review at the same time the
administrative and client files are reviewed.
A log system for the setup reports, draws and completion reports should be set up and used for future
contracts so the reconciliation can be tracked more accurately and easily.
I would like to thank you for the cooperation and assistance shown to Kate during her monitoring visit.
Sinperely,
KSUe Anderson
Program Administrator
cc: Jim Sheehan, Weld County Housing Authority
Bonnie Kugler
Teri Chavez
File
STATE OF COLORADO
DEPARTMENT OF LOCAL AFFAIRS
DIVISION OF HOUSING
1313 Sherman Street, Rm. 323
Denver, Colorado 80203
Phone (303) 866-2033
Fax: (303) 866-4485
June 15, 1993
The Honorable Constance L. Harbert, Chairman
Weld County Board of Commissioners
Post Office Box 758
Greeley, Colorado 80632
Re: CDBG Contract 91 -650 -Housing
Dear Chairman Harbert:
Roy Romer
Governor
Larry Kallenberger
Executive Director
Tom Hart
Director
On June 2, 1993, Donna Aguilar and Jennie Rodgers conducted a monitoring visit with Jim Sheehan, Executive
Director -Weld County Housing Authority, and Paul Pryor, Rehab Specialist -Weld County Housing Authority,
regarding the above mentioned contract. The following areas of compliance were included in the monitoring:
Application Certification and Project Start -Up
Eligibility of Activities and National Objectives
Limited Reviews of Financial Management, Environmental, Civil Rights and Labor Standards.
The monitoring was satisfactory. All financial reports have been submitted to the State in an accurate and
timely manner. The performance reports were usually late, however they were accurate.
The files and accounting records were somewhat difficult to monitor, nonetheless the files evidenced the proper
use of the CDBG funds. These same issues were noted last year, but were explained by the loss of one staff
person. This person has not been replaced and little improvement on file organization has been made. We
have determined from our experience with monitoring rehab programs statewide that organized files are a must.
The Weld program files will need to be improved prior to our next monitoring or we will have to issue a finding
on the monitoring report.
Physical inspection of the rehab performed on the Alternative Homes for Youth home in Longmont showed that
the group home had not been made accessible for disabled persons. Please contact Ms. Aguilar when
completed so that the facility can be re -inspected. Accessibility will need to be achieved prior to the close out
of this grant.
I would like to thank you for the cooperation and assistance that was shown to Donna and Jennie during their
monitoring visit. We wish you success in the continuation of your housing projects.
Sinc
KSue Anderson
Program Administrator
cc: Donna Aguilar
Jim Sheehan, Weld County Housing Authority
Bonnie Kugler
Teri Chavez
STATE OF COLORADO
DIVISION OF HOUSING
Tom Hart, Director
May 5, 1992
The Honorable Gene Brantner
Chairman, Weld County Board of Commissioners
P.O. Box 758
Greeley, Colorado 80632
Re: CDBG Contract 90-738
Dear Chairman Brantner:
Department of Local Affairs
Roy Romer
Governor
Larry Kallenberger
Executive Director
On March 11, 1992, Donna Aguilar and Linda Knopinski conducted a monitoring with the assistance
of Jim Sheehan, Executive Director, and Paul Pryor, Rehabilitation Specialist, of the Housing
Authority, regarding the above mentioned contract. The following areas of compliance were
included in the monitoring:
Application Certification and Project Start -Up
Eligibility of Activities and National Objectives
Limited Reviews of Financial Management, Environmental, Civil Rights and Labor
Standards.
The monitoring went well. The program continues to serve the housing needs of the low and
moderate income individuals and families in Weld County, despite several difficult rehabilitation
projects involving litigations and the county sheriff. The records were not as organized as they have
been in the past, however we understand that fewer personnel have been assigned to this program
due to budget restrictions. It was evident that CDBG funds were used properly. The only minor
issue discovered is explained below.
The public notice for the 1990 project did not include the required language regarding minimizing
displacement and making available past projects. This verbiage was included in the hearing notice
for the 1991 project. Please be sure this language remains in the notices published for any future
applications.
1313 Sherman Street, Room 323, Denver, Colorado 80203 (303) 866-2033 FAX (303) 866-4485 TDD (303) 866-5300
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