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We audited the City of Orlando’s HOME Investment Partnerships Program because it had more than $1 million that it needed to commit approximately 1 month before its deadline compliance date. Our objective was to determine whether the City accurately entered commitments and project completion data into the U.S. Department of Housing and Urban Development’s (HUD) Integrated Disbursement and Information System for HOME-funded activities.

The City entered more than $706,900 for invalid ($407,000) and inadequately supported ($299,900) commitments into the information system, and it charged the HOME program more than $18,200 for ineligible costs for a terminated activity. These conditions occurred because the City’s HOME program managers had not established and implemented adequate controls and procedures and because they disregarded HUD requirements which they should have known that prohibit charges to the HOME program for terminated activities. The invalid commitments concealed a commitment shortfall of more than $407,000 that is subject to recapture by HUD. The invalid and inadequately supported commitments undermined the integrity of the information system and jeopardized the accuracy and support of reports that HUD generates from the system to monitor the City’s compliance with the 24-month statutory commitment requirement and to compile national program statistics. The City entered accurate completion data into the information system.

We recommend that the Director of HUD’s Jacksonville Office of Community Planning and Development require the City to (1) reduce commitments in the information system to the amounts supported by written agreements, (2) recapture $407,006 in HOME funds that was not supported by valid commitments, (3) require the City to reimburse the program $18,248 spent for a terminated activity, (4) implement controls to ensure compliance with commitment requirements, and (5) ensure that its managers and staff are properly trained concerning the validity and support for commitments entered into the information system. We recommend that the Associate General Counsel for Program Enforcement pursue civil or other appropriate administrative action against the City for the invalid and inadequately supported commitment entries which its staff made to the information system.