EVALUATION OF CDBG ADMINISTRATION PROCEDURES
Coopers
& Lybrand
certifld public accountants
Suite 1500
101 E. Kennedy Boulevard
Tampa, Florida 33602-5194
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Tampa
Pinellas
(813) 229-0221
(813) 461-1580
facsimile
(813) 229-3646
January 5, 1994
Ms. Elizabeth Deptula
Interim City Manager
City of Clearwater
Post Office Box 4748
Clearwater, FI 34618
Dear Ms. Deptula:
We are pleased to have this opportunity to assist you with the evaluation of procedures used to
administer the City's Community Development Block Grant (CDBG) program (the Project).
In this letter, we have set forth our understanding of the Project background, an outline of our
approach to the Project, including a detailed work plan, and an estimate of our fees for the services
discussed. We are excited about the prospect of assisting the City with this important project and
look forward to beginning work.
PROJECT BACKGROUND
Based on review of recent monitoring reports, discussions with City staff, and the results of our
single audit procedures in prior years, we understand the City has experienced difficulties related
to the operation and administration of the CDBG program. In addressing these difficulties,
management has expended considerable time and expense to ensure compliance with applicable
laws and regulations. The difficulties experienced include:
1. Staffing of the Community Development Division
The Community Development Division Manager position has been vacant with the Assistant
Division Manager temporarily filling the role. Other staff within the division include a
Rehabilitation Specialist and two Housing Specialists. The Division Manager is responsible
for managing all U.S. Housing and Urban Development programs. Staff members are
responsible for administrative matters including processing of applications, construction
management and record keeping.
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Ms. Elizabeth Deptula
City of Clearwater
January 5, 1994
Page 2
2. Preparation of the Grantee Performance Report
The City's Grantee Performance Report (GPR) has been criticized by HUD for containing
mathematical errors, incomplete information, incorrect activity codes. There have also been
requests for more specific accomplishment information for several activities.
3. Timely Commitment of Rental Rehabilitation Program Grant Funds
The City has had a total of $88,875 of 1988 and 1989 grant funds deobligated by HUD due
to lack of commitment to qualified grant activities.
4. Reduction of Fund Utilization and Production of Single Family CDBG Funded Units
These measures of staff productivity have decreased over the past several years. We
understand that this is largely attributable to protracted disputes with several homeowners
which have taken an inordinate amount of City staff time to resolve.
5. Timeliness of the Completion of Routine Financial Record Keeping Procedures and Related
External Financial Reporting Requirements
We understand that management is interested in improving the timeliness of financial
reporting routines relating to CDBG program activities. Management cannot operate the
City's CDBG program effectively in the absence of timely financial information. In addition,
timely financial reporting is critical to ensuring that all applicable federal reporting
requirements are met.
We understand that the City has taken positive measures to address these difficulties,
including tentative filling of the vacant Community Development Manager position,
commissioning a report recommending specific alternative program management and
procedural policy improvements and obtaining technical assistance from the Community
Planning and Development Division of the Department of Housing and Urban Development.
However, in light of the amount of resources expended to address these difficulties, and the
continued significance of the CDBG program to the City's operations, you have asked us to
help by performing an evaluation of policies and procedures used in the administration of the
CDBG program. Based on our discussions with you, we believe that the evaluation should
include the following points of focus.
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Ms. Elizabeth Deptula
City of Clearwater
January 5, 1994
Page 3
.
Appropriateness of organizational structure, including elements such as definition of key
employees' responsibilities and reporting relationships.
.
The methods used in the assignment of responsibility, delegation of authority and
establishment of related policies to provide a basis for accountability and control.
.
The design of accounting and control procedures which are intended to promote adherence
to accounting, financial and administrative related compliance requirements of the CDBG
program.
.
Appropriateness of control activities designed to ensure continued adherence to established
policies, procedures, and reporting schedules.
SCOPE AND APPROACH TO THE PROJECT
This Project will entail employing additional procedures in conjunction with those already
performed as part of our single audit. These procedures will be directed to the points of focus
described previously and result in the identification of suggestions for the improvement in the
procedures used by the City to administer the CDBG program.
Based upon discussion with City personnel and our understanding of the current status of the
CDBG program, we propose that the Project consist of the following steps:
1. Meet with appropriate City management to confirm the objectives of the engagement and
scope of the procedures to be performed.
2. Update our understanding of the policies and procedures used to by management to address
both financial reporting and legal compliance requirements relating to the CDBG program.
This will be accomplished through inquiry of City staff, observation, and inspection and/or
testing of relevant documentation.
3. Update our understanding of the controls used to ensure adherence to policies and procedures
established by management to conduct the program in accordance with relevant compliance
requirements.
4. Assess the effectiveness and efficiency of existing procedures and recommend strengthening
those that are deemed ineffective and the addition of new procedures as required.
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Ms. Elizabeth Deptula
City of Clearwater
January 5, 1994
Page 4
5. Assist in the finalization of policies and procedures that will define job responsibilities and
enhance the control structure within the Community Development Division.
6. Meet with City management to discuss the results of the procedures.
The timing and completion of these procedures will be coordinated with the performance of the
Single Audit of the City's programs of federal financial assistance for fiscal year 1993 . We expect
to complete these procedures in February 1994 and finalize the project by March 11, 1994.
FEE ESTIMATE
We estimate that our fees for the Project will not exceed $9,700, including out-of-pocket expenses.
The actual amount billed will be based upon actual hours incurred at the rates stated below. Our
estimate is based on our present understanding of the scope of his project. If circumstances change
and a revision of scope is considered necessary by management, our fees would likely be affected.
We will notify you of such conditions when they are identified and obtain your approval before
we incur any additional time or billings.
Our proposed fee structure is as follows:
Staff Level
Rate
Per Hour
Partner
Manager
Senior Associate
Associate
Staff
$180
125
90
60
35
The engagement team will be headed by Wayne Burks, partner, and John Abbott, manager from
the City of Clearwater's audit team.
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Ms. Elizabeth Deptula
City of Clearwater
January 5, 1994
Page 5
CONCLUSION
In summary, we understand the importance of this Project to the City of Clearwater and are
prepared to help. If this letter is in accordance with your understanding, please countersign the
enclosed copy of this letter in the space provided below and return it to us at your earliest
convemence.
Yours truly,
(hOf<<'5 ~ l;1..-J
Name
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Date