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Compliance

TDA's Compliance Unit ensures that grant recipients are in compliance with federal, state and TxCDBG Program requirements. Compliance also provides oversight for administration of the TxCDBG Program. Compliance is composed of three sections: Monitoring, Audit, and Environmental Review & Labor Standards Compliance.


Compliance Monitoring

The Monitoring section is responsible for conducting reviews of grant recipients' local records in order to assess comprehensive compliance with TxCDBG project implementation policies. Monitoring is conducted through three methods, which TDA determines through risk analysis.  Generally, low risk contracts may be conducted through a certified self-monitoring review, medium risk contracts are monitored by desk review, and high risk contracts require on-site monitoring.  At least 10% of low risk contracts are randomly selected for desk reviews.  Key compliance areas include Financial Management, Procurement, Environmental Review, Labor Standards, Civil Rights & Fair Housing, Force Account, and Acquisition of Real Property. Additionally, monitors are charged with examining a grant recipient's Project Completion Report prior to determining administrative completion of a TxCDBG contract.

Program Monitoring Objectives:

- Review Grant Recipients' overall compliance with TxCDBG Project Program requirements.
- Identify necessary corrective actions.
- Identify technical assistance needs.
- Provide programmatic oversight.
- Provide quality assurance for project completion data (financial, beneficiaries and quantitative project completion accomplishments) reported to HUD.
- Examine grant recipient financial documents in order to determine proper expenditure of TxCDBG grant funds.
- Determine whether adequate internal controls are in place for responsible management of TxCDBG grant funds.
- Detect and prevent fraud and abuse.


Compliance Audit

The Audit section is responsible for tracking and enforcing grant recipients’ compliance with Single Audit reporting requirements in accordance with the Single Audit Act (1984), 2 CFR Part 200 Subpart F (formerly the United States Office of Management and Budget (OMB) Circular-A-133), and/or the Uniform Grant Management Standards -Texas Single Audit Circular.

Compliance Audit Objectives:

- Collect financial information via the submission of the Audit Certification Form (ACF) and the Single Audit Report (SA).
- Provide technical assistance in the completion and submission of the ACF and SA report.
- Track ACF and SA report submissions and notifying communities of their status.
- Perform audit desk reviews on ACFs and SA reports.
- Identify non-compliance issues and obtain from recipient a corresponding response and planned corrective actions.

Grant recipients including Local Governments (cities and counties) or nonprofits must submit an annual ACF when the grant recipient has open TDA contracts. Grant recipients that expend $750,000 or more per year in total federal or total state awards must complete and submit a Single Audit or a Program Specific Audit. Compliance Audit staff perform audit desk reviews of both the ACF and SA reports submitted. The audit desk review is a process used to assess a grant recipient's financial capacity. Through the audit desk review of a SA report, Compliance Audit will verify whether or not the grant recipient has the financial capacity to properly safeguard grant funds and related assets, to manage and administer contractual performance requirements, comply with state and federal regulatory requirements and report financial information timely and accurately.

Access the Online Audit Certification Form.

Environmental Review and Labor Standards Specialist:

The Environmental Review and Labor Standards Specialist serves a dual function to ensure 1) that grant recipients comply with requirements under the National Environmental Policy Act (1969) and HUD provisions under 24 CFR Part 58 and related regulations and 2) ensure compliance with federal and programmatic labor standards polices related to prevailing wage requirements under the Davis Bacon Act.

Environmental & Labor Standards Specialist Objectives:

Environmental Review
- Review certifications of Exempt and Categorically Excluded project activities and certifications of completed Environmental Assessments (EA).
- Issue Authorizations to Use Grant Funds.

- Perform desk reviews and on-site monitoring of Environmental Review Records (ERR) to ensure that environmental reviews are conducted properly.
- Provide technical assistance and training.

Labor Standards
- Review Labor Standards Records reports, Certificates of Construction Completion, and Final Wage Compliance Reports for completeness and accuracy.
- Approve Grant Recipients’ 10-Day Confirmation of wages decisions issued by the U.S. Department of Labor (DOL) for construction projects subject to the Davis-Bacon Act.
- Process requests for additional worker classifications and wage rates administered by DOL.
- Provide technical assistance and training.


 

Additional Links

Uniform Grant Management Standards

Government Auditing Standards

2 CFR Part 200, Subpart F – Audit Requirements

OMB Circulars including Audit Requirements and Cost Principles

OMB Circulars A-133 Compliance Supplement