Concern No. 5: The contract file checklist used by staff erroneously states that an A-133 audit is required, “if the contractor receives more than a total of $500,000.” The correct A-133 requirement is if an agency “expends” more than $500,000. Staff using the checklist aren’t considering the correct criteria for A-133 audits.

Recommended Action: Please correct the error and ensure staff are advised of the correct A-133 threshold requirement. We would appreciate a copy of the revised document.

BHCD Response Concern No. 5:

The changes have been made to the contract file checklist template. Please see attachment.

Concern No. 3: The city’s guidance uses the terms “date of completion and termination” which are less definitive than “closeout” as stated in the CFRs. As a result HUD does not have adequate assurance records are being maintained as required.

Recommended Action: Upon being advised of the weakness, staff immediately revised the BHCD procedures to be consistent with the language of 24 CFR 85.42. Please ensure contractual language is also amended and advise our office when that is completed.

BHCD Response Concern No. 3:

Please see the attached documents.  Supportive Housing Program General Terms & Conditions and BHCD’s Archiving Policy