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We audited the Virgin Islands Housing Finance Authority’s monitoring of its Community Development Block Grant Disaster Recovery (CDBG-DR)-funded activities.  We initiated the audit because of the large amount of CDBG-DR funds awarded to the U.S. Virgin Islands for the 2017 disasters and to aid in the U.S. Department of Housing and Urban Development’s (HUD) strategic objective to support effectiveness and accountability in long-term disaster recovery. 

Our objective was to determine whether the Authority effectively monitored its CDBG-DR-funded activities administered by itself and its subrecipients to ensure that the national objectives and performance measures were met.

The Authority did not effectively monitor its CDBG-DR-funded activities.  Specifically, it did not (1) assess the activities’ performance during its monitoring, (2) consistently track the status of corrective actions, (3) verify that the activities’ national objectives were or are being met, and (4) consistently monitor the activities.  These deficiencies occurred because the Authority lacked policies and detailed procedures to guide its staff on effectively monitoring and tracking corrective actions and ensure performance metrics included in subrecipient agreements were assessed.  Therefore, HUD could not be assured that activities were progressing, identified deficiencies were corrected, and funds were used for authorized purposes.

We recommend that the Deputy Assistant Secretary for Grant Programs require the Authority to develop and implement monitoring policies and detailed procedures to ensure that an activity’s performance is assessed, corrective actions in monitoring reports are tracked, and documentation supporting the national objectives is verified.  In addition, we recommend that the Authority revise subrecipient agreements to include performance metrics and milestones that are tailored to the activity.

Recommendations

Community Planning and Development

  •   2023-FW-1003-001-A

    Closed on Octubre 20, 2023

    We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement monitoring policies and detailed procedures to guide the Authority’s CMU staff in assessing activity performance to meet the subrecipient monitoring requirements and establish written performance metrics to progressively achieve the performance outcome for those activities the Authority administers.

  •   2023-FW-1003-001-B

    Closed on Octubre 20, 2023

    We recommend that the Deputy Assistant Secretary instruct the Authority to revise subrecipient agreements to include performance metrics and milestones tailored to the activity in sufficient detail to enable the Authority to collect information to effectively assess the activity’s performance.

  •   2023-FW-1003-001-C

    Closed on Octubre 20, 2023

    We recommend that the Deputy Assistant Secretary instruct the Authority to revise the monthly status report template to allow the subrecipient to report its current progress against the established performance metrics.

  •   2023-FW-1003-001-D

    Closed on Marzo 31, 2024

    We recommend that the Deputy Assistant Secretary instruct the Authority to develop a tracking process to ensure that the Authority issues monitoring reports and receives responses to these reports within the timeframe required by its policy. This process should also include a referral to management when the timeframe requirements are not met.

  •   2023-FW-1003-001-E

    Closed on Marzo 31, 2024

    We recommend that the Deputy Assistant Secretary instruct the Authority to develop detailed procedures to ensure that the corrective action tracking process is consistently followed to ensure proper resolution.

  •   2023-FW-1003-001-F

    Closed on Marzo 31, 2024

    We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement policies and detailed procedures to establish the CMU’s responsibilities related to verifying that the CDBG-DR activity meets the stated national objective.

  •   2023-FW-1003-001-G

    Closed on Marzo 31, 2024

    We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement policies and detailed procedures to identify the risk analysis process for monitoring all CDBG-DR-funded activities during the course of the activity and require that the monitoring files document the basis for why an activity is or is not monitored.

  •   2023-FW-1003-001-H

    Closed on Marzo 31, 2024

    We recommend that the Deputy Assistant Secretary instruct the Authority to train the CMU staff on the newly developed policies and procedures and obtain technical assistance from HUD as needed.