The City and County of Honolulu Made Some Improper Payments in its ESG CARES Act Program (Report Number: 2026-LA-1002, March 10, 2026)
Summary
Audit Report Number 2026-LA-1002 of the Office of Audit and Evaluation, Office of Inspector General, U.S. Department of Housing and Urban Development, dated March 10, 2026, on the City and County of Honolulu's Emergency Solutions Grant (ESG) program funded under the CARES Act. The report states that the City made some improper payments because it did not always follow HUD's requirements, including 233 landlord signing bonus payments totaling $714,512, $51,235 in overpaid rent, and duplication of benefits for three program participants totaling $10,100. It also states that HUD communicated draw deadline dates inconsistent with guidance it publicly issued, causing the City to draw $1.9 million in grant funds after the deadline.
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“The City and County of Honolulu Made Some Improper Payments in its ESG CARES Act Program (Report Number: 2026-LA-1002, March 10, 2026).”
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The City and County of Honolulu
Made Some Improper Payments
in its ESG CARES Act Program
Report Number: 2026-LA-1002
March 10, 2026
Office of Audit and Evaluation | Office of Inspector General
U.S. Department of Housing and Urban Development
Highlights
The City and County of Honolulu Made Some Improper Payments in
its ESG CARES Act Program | 2026-LA-1002
What We Audited and Why
We recently issued an audit report on the City and County of Honolulu’s (City) fraud risk management
practices, which determined the grantee did not adequately develop a fraud risk management framework
for the Coronavirus Aid, Relief, and Economic Security (CARES) Act funding provided for the Emergency
Solutions Grant (ESG) program to prevent, detect, and respond to fraud. 1 This audit follows that recent
work, in which we audited the City’s ESG CARES Act program with the objective of determining if
improper payments existed.
What We Found
The City made some improper payments in its ESG CARES Act program because it did not always follow
HUD’s requirements. Specifically, the City and its subrecipients did not (1) determine that 233 landlord
signing bonus payments totaling $714,512 were reasonable and necessary, (2) prorate the rent amount
for partial months resulting in $51,235 in overpaid rent (projected to be $248,572 in overpayments based
on our statistical sample), and (3) ensure there were no duplication of benefits for three program
participants totaling $10,100. We also determined that HUD communicated draw deadline dates to
grantees that were inconsistent with guidance it publicly issued, causing the City to draw $1.9 million in
grant funds after the deadline. These conditions occurred because we determined that officials of the
City and its subrecipients were not aware of some of HUD’s requirements for the ESG CARES Act program
and did not have controls for preventing a duplication of benefits. In addition, HUD used a single draw
deadline for grantees, which conflicted with the three separate expenditure deadlines that it established,
but did not issue formal written notice so that all grantees, subrecipients, and the public would be aware
of the single deadline. These results reduced the number of participants that could have been served by
the program, intended to reduce or mitigate homelessness, and impacted the City’s ability to maintain
program and payment integrity of the ESG CARES Act program. Although the ESG CARES Act program has
concluded, the City could make some of the same types of improper payments in the annual ESG
program and other HUD-funded programs it operates, since these programs allow expenses for similar
activities.
What We Recommend
Recommendations made in this report intend to address the control deficiencies identified within the ESG
CARES Act program as well as ensure the risk of the deficiencies occurring within the annual ESG program
is mitigated. Specifically, we recommend that the Director of HUD’s Honolulu Office of Community
Planning and Development instruct the City to (1) determine whether the $714,512 paid for 233 signing
bonuses under the ESG CARES Act program were reasonable and necessary, (2) develop and implement
written policies and procedures for the ESG program to ensure that rents are prorated for the first month
1
HUD OIG audit report 2024-LA-1002 (The City and County of Honolulu Should Enhance Its Fraud Risk Management
Practices for Its ESG CARES Act Program), issued August 6, 2024.
for tenant-based rental assistance, (3) repay HUD from non-Federal funds $51,235 in overpaid rent to
landlords, (4) develop and implement written policies and procedures to prevent duplication of benefits,
and (5) review the rental assistance payments made for the ESG CARES Act program to identify other
possible duplication of benefits with other rental assistance programs that the City operates.
We also recommend that the Deputy Assistant Secretary for Grant Programs to (1) develop and
implement written policies and procedures to ensure that any changes to the expenditure and draw
deadlines for the ESG program are provided in a formal document, such as a CPD notice or memorandum
issued to all grantees, (2) ensure that ESG grantees that operate tenant-based rental assistance programs
prorate the rent amount, and (3) ensure that ESG grantees develop and implement internal controls to
prevent any duplication of benefits with other Federal rental assistance programs for ESG program
participants.
Office of Inspector General | U.S. Department of Housing and Urban Development Page | 3
451 7th Street SW, Washington, DC 20410 | P: 202-708-0430 | F: 202-401-2505 | www.hudoig.gov
Table of Contents
Background and Objectives ...................................................................................... 1
Results of Audit ............................................................................................................. 4
The City and County of Honolulu Made Some Improper Payments In Its ESG CARES Act Program ........ 4
Scope and Methodology ............................................................................................. 12
Follow-up on Prior Audits ......................................................................................... 14
Appendixes ..................................................................................................................... 15
Appendix A – Schedule of Questioned Costs and Funds to Be Put to Better Use .................................. 15
Appendix B – Management Response .................................................................................................... 16
Appendix C – Schedule of Overpaid Rent to Landlords .......................................................................... 24
Background and Objectives
The Coronavirus Aid, Relief, and Economic Security (CARES) Act, signed on March 27, 2020, provided $4
billion for the Emergency Solutions Grant (ESG) program to “prevent, prepare for, and respond to
coronavirus among individuals and families who are homeless or receiving homeless assistance and to
support additional homeless assistance and homeless prevention activities to mitigate the impacts
created by coronavirus.” The funding was provided in two rounds of funding:
• Round 1: $1 billion allocated under the ESG formula to grant recipients.
• Round 2: $2.96 billion under a formula targeted toward communities with a high incidence
of sheltered and unsheltered homeless and those at the greatest risk for
homelessness.
The requirements for the ESG program (24 CFR Part 576) applied to the use of the ESG CARES Act funds.
ESG funds may be used for five programs components: (1) street outreach, (2) emergency shelter, (3)
homelessness prevention, (4) rapid rehousing, and (5) Homeless Management Information System
(HMIS). In addition, ESG funds can be used for administrative activities.
The ESG program provides funding to states, local governments, and territories to
• Engage with homeless individuals and families living on the street,
• Improve the number and quality of emergency shelters for homeless individuals and families,
• Help operate these shelters,
• Provide essential services to shelter residents,
• Rapidly rehouse homeless individuals and families, and
• Prevent families and individuals from becoming homeless.
HUD established alternative requirements and flexibilities, as authorized by the CARES Act, through
Community Planning and Development (CPD) notices that were issued and posted on its website. For
example, HUD included landlord incentives as an eligible activity. These landlord incentives included (1)
signing bonuses of up to two months of rent, (2) security deposits of up to three months of rent, (3)
paying the costs of repair damages incurred by the program participant, and (4) paying the costs of extra
cleaning or maintenance of a program participant’s unit or appliances.
City and County of Honolulu
HUD awarded the City and County of Honolulu (City) $25.6 million in ESG CARES Act funds in three
separate allocations, as shown in Table 1. This amount represents a 3,640 percent funding increase from
its annual formula ESG grant allocation for 2020. Of the $25.6 million in funding, the City allocated most
of its funding for emergency shelters and rapid rehousing ($21.9 million in total). 2
2
Of that total of $21.9 million, $12.3 million was awarded to subrecipients for emergency shelters, and $9.6 million
was awarded to subrecipients for rapid rehousing.
Office of Audit and Evaluation | Office of Inspector General Page | 1
Table 1: ESG CARES Act Funding awarded to the City between 2020 and 2022 (as of June 4, 2025)
ESG CARES Act
Awarded Total
Allocation Contract date expenditure
amount disbursed
deadline
ESG CARES Act 1 July 07, 2020 $ 2,429,569 $ 2,429,569 September 30, 2023
ESG CARES Act 2 February 19, 2021 22,370,813 22,370,813 September 30, 2023
ESG CARES Act
September 22, 2022 849,017 3 591,572 June 30, 2024
Reallocation
Total ESG CARES
$ 25,649,399 $ 25,391,954
Act
Table 2: ESG Funding allocated to the City between 2020 and 2024
Fiscal Year Grant Amount
2020 $ 704,575
2021 706,450
2022 697,690
2023 1,155,029
2024 688,305
Total ESG $ 3,952,049
Two departments in the City administered the ESG CARES Act program. The Community Based
Development Division (CBDD) is primarily responsible for the management and oversight of the ESG
CARES Act program while the Department of Budget and Fiscal Services serves as the City’s central
finance agency responsible for the accounting transactions and monitoring reviews of the ESG CARES Act
program.
Improper Payments
Appendix C to OMB Circular A-123, Requirements for Payment Integrity Improvement, defines an
improper payment as a payment that was made in an incorrect amount under statutory, contractual,
administrative, or other legally applicable requirements. All improper payments fall into one of two
categories: (1) improper payments resulting in a monetary loss or (2) improper payments that do not
result in a monetary loss.
3
HUD deobligated $257,445 of these unused grant funds.
Office of Audit and Evaluation | Office of Inspector General Page | 2
• Monetary loss improper payments can be either intentional or unintentional. Intentional
monetary loss improper payments are referred to as financial fraud and overpayments that occur
on purpose. Unintentional monetary loss improper payments are overpayments that are
accidental in nature because at the time of the payment the program is unaware that the
payment is an overpayment and the recipient has also not purposefully falsified information for
gain.
• Non-monetary loss improper payments can be either underpayments or technically improper
payments. Technically improper payments are instances where payments were made to the right
recipient and for the right amount but the payment process did not follow all applicable statutes
and regulations.
Our audit objective was to determine if improper payments exist in the City and County of Honolulu’s ESG
CARES Act program.
Office of Audit and Evaluation | Office of Inspector General Page | 3
Results of Audit
The City and County of Honolulu Made Some Improper Payments In
Its ESG CARES Act Program
The City made some improper payments in its ESG CARES Act program because it did not always follow
HUD’s requirements. Specifically, the City and its subrecipients did not (1) determine that 233 landlord
signing bonus payments totaling $714,512 were reasonable and necessary, (2) prorate the rent amount
for partial months resulting in $51,235 in overpaid rent (projected to be $248,572 in overpayments based
on our statistical sample), and (3) ensure there were no duplication of benefits for three program
participants totaling $10,100. We also determined that HUD communicated draw deadline dates to
grantees that were inconsistent with guidance it publicly issued, causing the City to draw $1.9 million in
grant funds after the deadline. These conditions occurred because we determined that officials of the
City and its subrecipients were not aware of some of HUD’s requirements for the ESG CARES Act program
and did not have controls for preventing a duplication of benefits. In addition, HUD used a single draw
deadline for grantees, which conflicted with the three separate expenditure deadlines that it established,
but did not issue formal written notice so that all grantees, subrecipients, and the public would be aware
of the single deadline. These results reduced the number of participants that could have been served by
the program, intended to reduce or mitigate homelessness, and impacted the City’s ability to maintain
program and payment integrity of the ESG CARES Act program. Although the ESG CARES Act program has
concluded, the City could make some of the same types of improper payments in the annual ESG
program and other HUD-funded programs it operates, since these programs allow expenses for similar
activities.
Subrecipients Paid Signing Bonuses to Landlords Without Supporting
Why the Costs Were Reasonable
The City used $9.6 million of its $25.4 million (or 38 percent) ESG CARES Act grant for its rapid rehousing
program. As part of this program, two of the City’s subrecipients paid 233 signing bonuses to landlords
totaling $714,512 on behalf of program participants but did not determine that the costs paid were
reasonable and necessary as required by HUD. The subrecipients only documented the amount of the
signing bonus and ensured that it did not exceed more than two months of rent. HUD established
alternative requirements to the ESG regulations (24 CFR part 576), as authorized under the CARES Act,
which allowed recipients of ESG CARES Act funds to pay incentives to landlords. These landlord incentives
included signing bonuses, security deposits, costs of repairs not covered by the security deposit, and costs
of extra cleaning or maintenance of the participant’s unit or appliances. HUD required grantees to
support the landlord incentive costs by documenting that each cost was reasonable under the program
participant’s particular circumstances, and not more than was necessary to house the program
participant.
According to the subrecipient that was the lead agency for the City’s rapid rehousing program, there were
no written policies and procedures for the signing bonuses, including determining and documenting that
the bonuses were reasonable and necessary. According to the subrecipient, the signing bonus amounts
were initially negotiated with landlords but towards the middle of the program, the signing bonuses were
not negotiated, and all landlords were offered the maximum amount (2 months of rent) because it
believed the signing bonuses were proven to be effective in housing the program participants faster.
Office of Audit and Evaluation | Office of Inspector General Page | 4
When signing bonuses were offered and paid, they were either 1 or 2 months of the rent amount. The
signing bonuses were paid to landlords for approximately 71 percent of the instances where individuals or
families were housed for the program and the signing bonuses ranged from $900 to $7,388. For
example, one landlord received a signing bonus of $6,400, which was equivalent to two months of rent,
and the maximum allowed by HUD’s requirements for the program.
Subrecipients Made Overpayments Because It Did Not Prorate the First
Months’ Rents for Participants in the Rapid Rehousing Program
The City’s subrecipients overpaid the rent for participants of the City’s rapid rehousing program because
it did not prorate the amount for partial months. Our review of 59 statistically sampled lease agreements
identified 57 that had overpaid rent for the first month totaling $51,235 (see appendix C). Extrapolating
the 57 of 59 leases with overpaid rent to the universe of 319 leases resulted in a projection of at least 297
lease agreements (93%) that had overpaid rent for the first month totaling $248,572. The amounts were
overpaid because the lease agreement started after the first day of the month and the subrecipient paid
a full month of rent instead of prorating the amount based on the lease start date. For example, the
lease agreement for one program participant started on October 28, 2021, with a monthly rent of $2,500.
The subrecipient improperly paid $2,500 to the landlord for October but should have prorated the
amount based on 4 days of occupancy ($333), resulting in an overpayment to the landlord of $2,167. In
addition to the overpayment, the landlord received a $5,000 signing bonus equal to two months’ rent,
which is the maximum allowed by the ESG CARES Act program.
HUD does not have regulations or guidance for the ESG or ESG CARES Act program that allow the
payment of 100 percent of the first month’s rent for partial months for tenant-based rental assistance,
which was the type of assistance provided for the City’s rapid rehousing program. This was only allowed
for project-based and sponsor-based rental assistance. 4 However, the City’s rapid rehousing program
was all tenant-based, and we determined that officials of the City’s subrecipients were unaware that the
exceptions for project and sponsor-based assistance did not apply to tenant-based assistance. The City’s
procedures for the ESG and ESG CARES Act program did not address prorating or paying 100 percent of
the rent for the first month; however, City officials stated they prorate the first month for the ESG
program. Of the 59 lease agreements reviewed, 31 program participants (52.5 percent) occupied the
rental property for 14 days or less for the first month, but the landlord was paid a full month of rent (see
Table 3 below).
4
Project-based rental assistance is tied to specific housing units, so the assistance remains with the property even if
the resident moves out. Tenant-based rental assistance is tied to the individual or family, allowing them to choose
their housing. Sponsor-based rental assistance is where a non-profit or other organization rents units from a
landlord and then sublets those units to eligible individuals or families.
Office of Audit and Evaluation | Office of Inspector General Page | 5
Table 3: Range of days the rental property was occupied for the first month
Days the rental property was Number of lease Percentage of
occupied for the first month agreements sample
1 to 7 days 13 22%
8 to 14 days 18 31%
15 to 21 days 16 27%
22 days or more 12 20%
Total 59
The City Paid Duplicate Benefits for Three Program Participants
Three program participants improperly received duplicative rental assistance from the City’s ESG CARES
Act program and the City’s Rental and Utility Relief Program (RURP) 5 that covered the same property and
period totaling $10,100. For example, in one case, one person received rental assistance on September
21, 2021, totaling $4,500 from the ESG CARES Act program for back rent that covered July to September
2021. This person also received rental assistance totaling $4,950, possibly including lates fees, on
November 23, 2021, from the RURP program for back rent that also covered July to September 2021 (see
Table 4 below).
Table 4: Example of duplication of benefits
Paid by the ESG CARES Act Paid by the RURP
Month Rent amount
program program
July 2021 $1,500 $1,500 $1,665
August 2021 $1,500 $1,500 $1,650
September 2021 $1,500 $1,500 $1,635
Total $4,500 $4,500 $4,950
HUD issued CPD notices 20-08 and 21-08 that required ESG CARES Act grantees to establish and maintain
adequate procedures to prevent any duplication of benefits with ESG CARES Act funds. The City’s
subrecipients had procedures to check for duplication of benefits with other homeless assistance
providers (in the Homeless Management Information System) but did not have controls for preventing a
duplication of benefits with other programs that were not for homeless assistance, such as the City’s
RURP program. Also, the City had plans to establish controls to prevent duplication of benefits, but these
controls were not implemented. Controls to prevent duplication of benefits could include a data analytics
tool that compares the program participants’ name and other identifying information across other rental
5
The City’s RURP program was funded with support from the Department of the Treasury’s Emergency Rental
Assistance program.
Office of Audit and Evaluation | Office of Inspector General Page | 6
assistance programs and a certification from the program participant that they have not applied for
assistance from other sources.
HUD Established Draw Deadlines That Were Not Consistent with
Guidance It Publicly Issued
HUD initially issued guidance through CPD notice 20-08 that included an expenditure deadline of
September 30, 2022, for recipients to spend all ESG CARES Act funds. HUD extended the expenditure
deadline for the first and second allocations of ESG CARES Act funds, through CPD notice 22-06, to
September 30, 2023, except for HMIS and administration funds, and December 31, 2023, for HMIS and
administration funds necessary for the grant closeout. HUD stated, in the notice, that the additional
three months for spending HMIS and administration funds was necessary to give recipients sufficient time
to accurately draw down and report on expenditures completed by September 30, 2023, after fully
completing ESG CARES Act funded activities. For the reallocated ESG CARES Act funds, CPD notice 22-06
included an expenditure deadline of June 30, 2024.
The regulations for Federal awards (2 CFR Part 200) allow recipients 120 calendar days after the
conclusion of the period of performance to liquidate all financial obligations under the Federal award.
Therefore, based on the three expenditure deadlines provided in CPD notice 22-06, we determined there
were three distinct draw deadlines for the ESG CARES Act funds, which were
• January 31, 2024 (120 calendar days after September 30, 2023), for non-HMIS and non-
administration expenses (allocations 1 and 2),
• April 30, 2024 (120 calendar days after December 31, 2023), for administration and HMIS
expenses necessary for the grant closeout (allocations 1 and 2), and
• October 31, 2024 (120 calendar days after June 30, 2024), for reallocated ESG CARES Act funds.
However, HUD used the following single draw deadlines that were not consistent with the three distinct
expenditure deadlines that HUD provided in CPD notice 22-06:
• April 30, 2024, for all ESG CARES Act grants that did not include reallocated funds, and
• October 31, 2024, for all ESG CARES Act grants that included reallocated funds.
These single draw deadlines were provided through a national conference for grantees and a “resource”
document on HUD’s website to assist grantees with the grant closeout process (see Table 5 below). Since
these single draw deadlines were not consistent with the three distinct expenditure deadlines that HUD
provided in CPD notice 22-06, HUD should have provided a formal written notice with these deadlines. A
formal written notice would make all grantees, subrecipients, and the public aware of any extensions or
changes to the deadlines.
Office of Audit and Evaluation | Office of Inspector General Page | 7
The City relied on the single draw deadlines established by HUD and HUD’s systems showed that $1.9
million was drawn by the City for non-HMIS and non-administration expenses (for allocations 1 and 2) 6
from March 14, 2024, to May 22, 2024, which was after the January 31, 2024, draw deadline 7 that we
determined based on the expenditure deadlines from CPD notice 22-06.
Table 5: Expenditure and liquidation deadlines for the ESG CARES Act
Liquidation deadline Liquidation deadline
Expenditure
ESG CARES Act allocation (based on CPD notice (based on HUD
deadline
22-06) document)
Allocation 1 and 2 – Project
09/30/2023 01/30/2024 04/30/2024
expenses
Allocation 1 and 2 –
Administration and HMIS 12/31/2023 04/30/2024 04/30/2024
expenses
Reallocation 06/30/2024 10/31/2024 10/31/2024
Conclusion
The City made an estimated $973,184 in improper payments for its ESG CARES Act program because we
determined the City and its subrecipients were not aware of the requirements surrounding the activities
related to landlord incentives and proration of rent payments. Also, the City did not have controls for
preventing a duplication of benefits. These funds could have been used to further maximize the impact
that the ESG CARES Act program had on participants benefiting from the program who were homeless or
at risk of homelessness. Draw deadlines were inconsistent between what was published on HUD’s
website and formally issued guidance which caused the City to draw $1.9 million in grant funds after the
deadline in formally issued CPD notice 22-06 -. A more formal written notice of the draw deadline would
ensure all grantees are aware of and use the maximum allowed time to execute the program’s objectives.
While the ESG CARES Act program and the alternative requirements that were established has concluded,
there is a risk for similar improper payments in other HUD funded programs that the City operates, which
include the annual ESG program, because these programs allow expenses for similar kinds of activities.
6
According to HUD’s systems, the $1.9 million drawn was for shelter, street outreach, and homeless prevention.
While these are eligible activities, we did not perform any testing to determine if the specific expenses for the draws
were eligible.
7
The $1.9 million drawn after the deadline for non-HMIS and non-administrative expenses included $15,813 of
administration expenses drawn on May 17, 2024, which was after the April 30, 2024, deadline.
Office of Audit and Evaluation | Office of Inspector General Page | 8
Recommendations
We recommend that the Director of HUD’s Honolulu Office of Community and Planning Development
instruct the City and County of Honolulu to
1A. Determine whether the $714,512 paid for 233 signing bonuses under the ESG CARES Act
program were reasonable under the program participant’s particular circumstances, and
not more than necessary to house the program participants or repay HUD from non-
Federal funds.
1B. Develop and implement written policies and procedures that include internal controls for
the ESG program to ensure that it, and its subrecipients, prorate the rent amount for the
first month for tenant-based rental assistance. Since the City did not prorate rent, there
was an estimated overpayment to landlords of $248,572 that could have been put to
better use.
1C. Repay HUD from non-Federal funds $51,235 in overpaid rent to landlords because the
first month of rent was not prorated (see appendix C).
1D. Develop and implement written policies and procedures that include internal controls to
prevent any duplication of benefits for the ESG program participants with other
programs, specifically for rapid rehousing and homeless prevention.
1E. Review the rental assistance payments made for the ESG CARES Act program to identify
other possible duplication of benefits with other rental assistance programs that the City
operates. The $10,100 in duplication of benefits identified during the audit could have
been put to better use.
We recommend that the Deputy Assistant Secretary for Grant Programs to
1F. Develop and implement written policies to ensure that any changes to the expenditure
and draw deadlines for the ESG program are provided in a formal document, such as a
CPD notice. In this case, implementing these controls would provide clear guidelines to
the grantee and help prevent the disbursement of $1,933,693 that was drawn after the
draw deadline.
1G. Issue clarifying guidance to ensure that ESG grantees that operate tenant-based rental
assistance programs, prorate the rent amount for the first month based on the lease
agreement start date.
1H. Issue guidance requiring ESG grantees develop and implement internal controls to
prevent any duplication of benefits with other Federal rental assistance programs for the
ESG program participants, specifically for rapid rehousing and homeless prevention.
Office of Audit and Evaluation | Office of Inspector General Page | 9
Management Response
City and County of Honolulu
The City generally agreed with our recommendations, except for recommendation 1A regarding the
signing bonuses. The City stated that it acted with urgency to address the unprecedented circumstances
of the coronavirus pandemic, relying on interim guidance and working closely with the local HUD field
office and the recommended technical assistance provider. The City further explained that due to the
highly competitive rental housing market in O’ahu and landlords’ reservations on working with the ESG
population based on prior experiences, it authorized landlord incentives of up to two-months of rent
rather than negotiating each case individually. This approach expedited the lease-up process to address
the sense of urgency. The City stated it complied with the pertinent ESG CARES Act program
requirements and suggested that no repayment is owed to HUD. The City also stated their records show
that $708,712 in signing bonuses were paid instead of the $714,512 identified in the report (a difference
of $5,800).
HUD’s Office of Community Planning and Development
HUD’s Office of Community Planning and Development (CPD) provided comments for recommendations
1F (expenditure and draw deadlines) and 1G (prorating rent). No comments were provided for
recommendation 1H (duplication of benefits). HUD agreed to take action for recommendations 1F and
1G but disagreed that it had provided conflicting information regarding a single draw deadline. HUD
stated that it applied a single period of performance for each ESG-CV grant and identified one draw
deadline for each ESG-CV grant rather than separate draw deadlines by cost category. Specifically, the
period of performance end date was either December 31, 2023, or June 30, 2024. The latter date was
used for grants that included reallocated funds. HUD further explained that administration and HMIS
expenses are cost types that could fall under both cost categories (project costs and closeout costs).
HUD’s Integrated Disbursement and Information System (IDIS) does not have the functionality to
distinguish between administration and HMIS costs used for project activities and those used for
closeout. As a result, HUD could not establish separate draw deadlines for project costs and closeout
costs.
Both the City and County of Honolulu and HUD CPD management’s comments are included in Appendix
B.
OIG Evaluation of Management Response
City and County of Honolulu
While we recognize the extraordinary circumstances of the coronavirus pandemic, we disagree that no
repayment is owed to HUD because the City did not follow HUD’s requirements for the signing bonuses.
As noted in the audit report, HUD required grantees to support the landlord incentives costs (which
included signing bonuses of up to two months of rent) by documenting that each cost was reasonable
under the program participant’s particular circumstances and not more than was necessary to house the
program participant. These requirements are included in CPD Notice 21-08. We will collaborate with the
City and HUD during audit resolution on the $5,800 discrepancy for the total signing bonus amount and
an acceptable method for determining whether the 233 signing bonuses were reasonable and not more
than necessary. If the City cannot adequately support these signing bonuses, we recommend repayment
to HUD from non-Federal funds.
Office of Audit and Evaluation | Office of Inspector General Page | 10
HUD’s Community Planning and Development
We acknowledge the reasons that HUD provided for using a single draw deadline for each ESG-CV grant;
however, our position remains that HUD provided conflicting draw deadlines because the use of a single
draw deadline for each ESG-CV grant is not consistent with CPD notices that were formally issued. Based
on HUD’s response, we revised the language in the final report to state the draw deadlines established by
HUD were not consistent with guidance issued in CPD notice 22-06.
HUD’s response indicates the period of performance end date for the City and County of Honolulu was
June 30, 2024, since its ESG-CV included reallocated funds, and could incur and expend eligible costs
during this period. HUD’s response further indicates that the draw deadline for the City and County of
Honolulu was October 31, 2024. As noted above, we disagree with this expenditure and draw deadline
because they are not consistent with the CPD notices.
The CPD notices provided three distinct expenditure deadlines for ESG-CV funds provided to grantees.
Based on these three distinct expenditure deadlines and 2 CFR Part 200, which requires recipients to
liquidate all financial obligations within 120 calendar days after the period of performance, there should
have been three distinct draw deadlines. These CPD notices were issued to all ESG recipients and
subrecipients and published on the HUD website. Given the unique circumstances of the ESG-CV grant,
with three separate allocations and expenditure deadlines compared to only one allocation and
expenditure deadline for annual ESG grants, HUD should have issued formal written notice clarifying its
interpretation of the draw deadlines, rather than providing this information only at the national
conference for grantees and the “resource” document on its website. The three expenditure deadlines
are below:
• CPD notices 20-08 and 21-08 stated that all funds awarded to a recipient through the first and
second allocations of ESG-CV funds must be expended by September 30, 2022.
• CPD notice 22-06 provided a new expenditure deadline for the first and second allocations and
provided the expenditure deadline for the reallocated funds. Specifically, it stated that recipients
must expend all amounts awarded through the first and second allocations of ESG-CV funds by
September 30, 2023, except for administration and HMIS funds necessary for closeout, which
must be expended by December 31, 2023. The notice further states that recipients must expend
the funds reallocated via the reallocation process by June 30, 2024.
We also acknowledge that IDIS may not have the capability to distinguish between administration and
HMIS costs used for project activities and those used for closeout; however, this should not have
prevented HUD from establishing separate draw deadlines for these cost categories. Also, as noted
above, HUD established separate expenditure deadlines for these cost categories through the CPD
notices it issued.
Office of Audit and Evaluation | Office of Inspector General Page | 11
Scope and Methodology
We conducted the audit offsite from July 2024 through June 2025. Our audit covered the period April 1,
2020, to June 30, 2024. All interviews and discussions were conducted offsite. Our audit focused on
whether improper payments existed in the City’s ESG CARES Act program.
To accomplish our objective, we performed the following:
• Reviewed pertinent criteria, including applicable laws, regulations, policies, procedures, and
other relevant documentation related to HUD’s ESG and ESG CARES Act programs.
• Interviewed and/or obtained information from officials from the City, the City’s subrecipients, the
HUD Honolulu field office, and HUD CPD Headquarters.
• Reviewed the policies and procedures for the City and its subrecipients, as well as other relevant
documentation.
• Obtained and reviewed the general ledgers from the City and its subrecipients for the ESG CARES
Act program.
• Reviewed a statistical sample of 59 lease agreements for the ESG CARES Act program to
determine if the amount paid for the first month was proper or improper. The results of the
review were projected to the universe of 319 lease agreements to estimate the number and
amount of lease agreements that were overpaid for the first month.
• Compared the rental assistance payments from the ESG CARES Act program (rapid rehousing and
homeless prevention) to the City’s Rental and Utility Relief Program (RURP) to determine if a
duplication of benefits was paid to landlords on behalf of program participants.
• Reviewed the vouchers paid from HUD’s Integrated Disbursement and Information System (IDIS)
to determine if they were paid before the draw deadline for the ESG CARES Act program.
Initially we selected a sample of five subrecipients, based on risk factors, to include in our review. From
these five subrecipients we obtained a universe of 9,488 ESG CARES Act expenses and selected a
statistical sample of 85 expenses to determine if the payments made were proper or improper. Based on
our initial review of 21 of the 85 expenses, we did not proceed with reviewing the remaining 64 expenses
and instead focused our review on the risk areas we identified. These areas included signing bonuses,
overpaid rent for the first month, duplication of benefits, and a review of the timeliness of the City’s ESG
CARES Act draws.
We relied in part on data that was provided by the City and its subrecipients. We determined that the
data was sufficiently reliable for the purposes of our review because we corroborated the data with
supporting documentation that was provided by the City and its subrecipients.
We conducted the audit in accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to
Office of Audit and Evaluation | Office of Inspector General Page | 12
provide a reasonable basis for our findings and conclusions based on our objective. We believe that the
evidence obtained provides a reasonable basis for our conclusions based on our objective.
Office of Audit and Evaluation | Office of Inspector General Page | 13
Follow-up on Prior Audits
The City and County of Honolulu Should Enhance Its Fraud Risk
Management Practices for Its ESG CARES Act Program Audit Report,
2024-LA-1002; Issued August 6, 2024
The following recommendations were open at the time of this report:
1A. Improve or enhance its antifraud efforts for the ESG program and incorporate fraud risk
management practices that are consistent with the best practices identified in the Government
Accountability Office’s A Framework for Managing Fraud Risks in Federal Programs and Chief
Financial Officers Council and Treasury Bureau of the Fiscal Services’ Antifraud Playbook.
1B. Obtain training or technical assistance as needed on the implementation of fraud risk
management practices.
On November 21, 2024, we agreed with HUD’s proposed management decisions for both
recommendations. The final action target date for completing the corrective actions for 1A was
December 31, 2025, and for 1B was November 21, 2025. The grantee submitted documentation to
support the corrective actions and it was pending HUD review at the time of report publication.
Office of Audit and Evaluation | Office of Inspector General Page | 14
Appendixes
Appendix A – Schedule of Questioned Costs and Funds to Be Put to
Better Use
Table 6: Schedule of questioned costs and funds to be put to better use
Recommendation Funds to be put
Ineligible 1/ Unsupported 2/
Number to better use 3/
1A $ 714,512
1B $ 197,337 8
1C $ 51,235
1E 10,100
1F 1,933,693
Totals $ 51,235 $ 714,512 $ 2,141,130
1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity that
the auditor believes are not allowable by law; contract; or Federal, State, or local policies or regulations.
In this instance, the ineligible costs associated with recommendation 1C are the overpaid rent paid to 57
landlords, on behalf of program participants, totaling $51,235 because the first month of rent was not
prorated.
2/ Unsupported costs are those costs charged to a HUD-financed or HUD-insured program or
activity when we cannot determine eligibility at the time of the audit. Unsupported costs require a
decision by HUD program officials. This decision, in addition to obtaining supporting documentation,
might involve a legal interpretation or clarification of departmental policies and procedures. In this
instance, the unsupported costs associated with recommendation 1A represent the missing
documentation that the 233 signing bonuses totaling $714,512 to landlords were reasonable under the
program participant’s particular circumstances, and not more than necessary to house the participant.
3/ Recommendations that funds be put to better use are estimates of amounts that could be
used more efficiently if an Office of Inspector General (OIG) recommendation is implemented. These
amounts include reductions in outlays, deobligation of funds, withdrawal of interest, costs not incurred
by implementing recommended improvements, avoidance of unnecessary expenditures noted in
preaward reviews, and any other savings that are specifically identified. In this instance, the funds to be
put to better use associated with recommendations 1B, 1E, and 1F represent the (1) estimated
overpayment to landlords because the first month of rent was not prorated, (2) the duplication of
benefits with other rental assistance programs, and (3) the grant funds drawn after the deadline.
8
The amount is the estimated overpayment to landlords of $248,572 less the $51,235 in recommendation 1C.
Office of Audit and Evaluation | Office of Inspector General Page | 15
Appendix B – Management Response
The City and County of Honolulu’s Response
The following comments were provided by the City and County of Honolulu:
OFFICE OF THE MAYOR
KE KE‘ENA O KA MEIA
CITY AND COUNTY OF HONOLULU
530 SOUTH KING STREET. ROOM 300 • HONOLULU, HAWAI I 96813
PHONE: (808)768-4141 • FAX: (808)786-4242 • WEBSITE: honolulu.gov
RICK BLANGIARDI MICHAEL D. FORMBY
MAYOR MANAGING DIRECTOR
MEIA PO'O HO'OKELE
KRISHNA F. JAYARAM
DEPUTY MANAGING DIRECTOR
HOPE PO'O HO'OKELE
January 16, 2026
SENT VIA EMAIL
Ms. Tanya Schulze, Audit Director
U.S. Department of Housing and Urban Development (HUD)
Office of the Inspector General
Grants Management Audit Division
451 7th Street SW, Room 8180
Washington, DC 20410
Tschulze@hudoig.gov
Dear Ms. Schulze:
SUBJECT: Audit Response to Report - The City and County of Honolulu Needed
Stronger Controls to Prevent Improper Payment in its
ESG CARES Act Program
On behalf of the City and County of Honolulu (City), thank you for this opportunity to
respond to your report titled, The City and County of Honolulu Needed Stronger Controls to
Prevent Improper Payment in its ESG CARES Act Program (Report).
The City is grateful for having received $25,649,399 in Emergency Solutions Grant
CARES Act (ESG-CV) funding to address the unprecedented circumstances of coronavirus.
Armed with funds, the City acted with a sense of urgency to prevent, prepare, and respond to
coronavirus, with a focus on individuals and families who were homeless or receiving homeless
assistance and to support additional homeless assistance and homeless prevention activities to
mitigate the impacts of coronavirus.
in acting with a sense of urgency, the City relied on interim guidance as final rules for the
program had yet to be promulgated. The City also found it necessary to adapt to unexpected
circumstances as programs were being implemented. To mitigate the risk of non-compliance,
the City worked closely with the local HUD field office, as well as a recommended technical
assistance provider, the ............... From the City's perspective, waiting for final
rules would have delayed assistance during the height of the pandemic, undermining the
CARES Act's intent and exacerbating harm to vulnerable populations.
The programs funded under ESG-CV achieved meaningful and measurable successes.
Hundreds of individuals and families were rapidly housed, unsheltered homelessness was
reduced in key areas, and households were stabilized during a period of extraordinary economic
*name redacted for privacy reasons
Office of Audit and Evaluation | Office of Inspector General Page | 16
Ms. Tanya Schulze, Audit Director
January 16, 2026
Page 2
and public health disruption. Landlord engagement strategies, including incentives, proved
effective in overcoming market barriers and accelerating placements in a highly constrained
rental environment.
The City notes that all findings identified in this Report are isolated to a single program,
O'ahu Housing Now (OHN), which supported 312 households and 829 people experiencing
homelessness, providing them with limited-term rental assistance, including landlord incentives
and other assistance to the households. The OHN program accounted for $10,255,182 of the
City's ESG-CV expenditures.
Subrecipients Paid Signing Bonuses to Landlords Without Supporting Why the Costs
Were Reasonable
Recommendation 1A - Determine whether the $714,512 paid for233 signing bonuses under
the ESG CARES Act program were reasonable under the program participant's particular
circumstances, and not more than necessary to house the program participants or repay HUD
from non-Federal funds.
Response: The City notes that landlord signing bonuses and incentives are unique to the
ESG-CV program, and rules promulgated for the program had a limitation of three times the rent
charged for each unit.
O'ahu is a desireable place to live and destination to visit. As a result, O'ahu has a
highly competitve rental housing and vacation rental market. During the implementation of OHN,
landlords shared serious reservations based on past experiences in working with the ESG
population (thru programs such as Housing First), including concerns and experience around
excessive damage to units, along with the timeframe when the unit is being restored and is not
able to be rented.
In order to both facilitate and expedite the lease-up to address the sense of urgency, the
City provided guidance to service providers authorizing Landlord incentives of up to two-months
of rent in lieu of reviewing and authorizing individual negotiations on a case-by-case basis. This
approach also improved administrative efficiency by standardizing incentive amounts rather
than negotiating them on a case-by-case basis, allowing staff to focus on rapid housing
placements during the emergency period.
The two months of rent authorized were intended to address landlord concerns related
to potential unit damage and downtime between leases needed to complete repairs as a result
of leasing to ESG-eligible households. It is further noted that, had the City authorized the full
allowable Landlord incentive amount of up to three times the rent for signing bonuses, security
deposits, and cleaning or repairs, the total for the 233 payments would have been $1,233,063.
Relative to the circumstances, the City believes the authority delegated and the approach taken
were reasonable.
Based on the City’s review of its records, the 233 signing bonus payments made
accumulated to $708,712 and not the $714,512, identified in the report. The City notes that:
Office of Audit and Evaluation | Office of Inspector General Page | 17
Ms. Tanya Schulze, Audit Director
January 16, 2026
Page 3
• 63 signing bonuses, accumulating $111,830 paid, represented one-month of rent.
• 170 signing bonuses, accumulating $596,882 paid, represented two-months of rent.
• There were no signing bonuses paid in excess of two-months of rent, while a total of 319
leases were executed.
The City notes that all payments made were within the program rule's limit that allowed
up to three-months of rent. In addition, all signing bonuses authorized were within the guidance
from the City that allowed providers to negotiate signing bonuses not to exceed to two-months
of rent. As a result, the City believes it complied with the pertinent ESG-CV rules and that
respectfully suggests no payment is due to HUD.
The City will work to reconcile the difference between the amount identified in the Report
of $714,512 and the amount identified in our records of $708,712 for the 233 signing bonuses
paid and we will take the necessary action based on our findings relative to the proposed
recommendation. The City expects to resolve this matter to the satisfaction of HUD by March
31,2026.
Subrecipients Made Overpayments Because it Did Not Prorate the First Month’s Rents
for Participants in the Rapid Rehousing Program
Recommendation 1B- Develop and Implement written policies and procedures that include
internal controls for the ESG program to ensure that it, and its subreipients, prorate the rent
amount for the first month for tenant-based rental assistance. Since the City did not prorate
rent, there was an estimated overpayment to landlords of $248,572, that could have been put to
better use.
Recommendation 1C - Repay HUD from non-Federal funds, $51,235 in overpaid rent to
landlords because the first month of rent was not prorated.
Response: As noted above, O'ahu is a highly competitve rental housing and vacation rental
market. In order to expedite the implementation of OHN, service providers worked to actively
enroll both participants and landlords. The failure to pro-rate the first month of rent is the
inadvertent consequence of prioritizing rapid lease-up and landlord participation in a constrained
market, with the goal of minimizing delays in housing placement and reducing the length of time
individuals and families remained unsheltered during the emergency response period.
The City will develop policies and procedures that comply with ESG regulations and
undertake the necessary steps to implement thse policies and procedures, including training
staff and notifying all service providers providing rapid re-housing and homeless prevention
services.
The City will also work to verify OIG’s work on the calculation and $51,235 overpayment
for repayment of the verified amount using non-Federal funds. The target date for both the
completion of the policies and procedures, in addition to the repayment to HUD is March 31,
2026.
Office of Audit and Evaluation | Office of Inspector General Page | 18
Ms. Tanya Schulze, Audit Director
January 16, 2026
Page 4
The City Paid Duplicate Benefits for Three Program Participants
Recommendation 1D - Develop and implement written policies and procedures that include
internal controls to prevent any duplication of benefits for the ESG program participants with
other programs, specifically rapid re-housing and homeless prevention.
Recommendation 1E - Review the rental assistance payments made for the ESG CARES Act
program to identify other possible duplication of benefits with other rental assistance programs
that the City operates. The $10,100 in duplication of benefits during the audit could have been
put to better use.
Response: The circumstances for OHN were certainly unique given the amount of funding
made available for the purposes of rapid rehousing and homeless prevention and the City will
be mindful of expanding prevention efforts when other competing programs are launched, like
the Treasury-funded Rent and Utility Relief Program (RURP) that was managed by a different
City agency.
The City will also work to develop and implement written policies and procedures to
prevent any duplication of benefits for the ESG program participants with other programs,
including rapid re-housing and homeless prevention. Policy and procedure design will consider
elements specific to the instances of duplicated benefit for each instance identified in the
Report.
The new policies and procedures will also include measures to ensure that programs
launched in other City agencies work with the City’s Department of Community Services to
develop detection controls to prevent duplication of benefits. The City plans to complete the
recommended written policies and procedures as well as review of the duplicated payments by
March 31, 2026.
In closing, we thank you for the opportunity to review and respond to the HUD OIG
Report regarding your recent audit of our ESG-CV program. I assure you, we are committed to
better going forward. If you have any questions or concerns regarding this response, you may
contact me by email at anton.krucky@honolulu.gov or by phone at (808) 768-7761.
Sincerely,
Michael D. Formby
Managing Director
cc: James Brady, Assistant Audit Director
U.S. Department of Housing and Urban Development
VIA Email: JBrady@hudoig.gov
Office of Audit and Evaluation | Office of Inspector General Page | 19
HUD Management’s Response
The following comments were provided by HUD Headquarters:
U.S. DEPARTMENT OF HO USING AND URBAN DEVELOPMENT
WASHINGTON, DC 20410 7000
OFFICE OF COMMUNITY PLANNING
AND DEVELOPMENT
MEMORANDUM FOR: Kilah S. White, Assistant inspector General for Audit
Office of the Inspector General
FROM: Caitlyn McKenney, Deputy Assistant Secretary
Office of Special Needs, DN
SUBJECT: Response to Proposed Audit Report: The City and County of
Honolulu Needed Stronger Controls to Prevent Improper Payments
in its Emergency Solutions Grants (ESG) CARES Act Program
The Department of Housing and Urban Development (HUD) reviewed the proposed audit report
titled The City and County ofHonolulu Needed Stronger Controls to Prevent Improper Payments in
its ESG CARES Act Program (Report Number: 2026-LA-100X). The Office of Special Needs
Assistance Programs (SNAPS) and the Honolulu Field Office provide the following comments for
inclusion in the final report.
1. EMERGENCY SOLUTIONS GRANTS (ESG) - CORONAVIRUS (CV)
EXPENDITURE AND DRAW DEADLINES
The report stated that the City and County of Honolulu drew $1.9 million in ESG-CV funds
after the required timeframe and concludes that HUD issued Conflicting guidance regarding the
draw deadlines. The report correctly describes I IUD’s issuance of multiple notices, including the
following:
• HUD initially issued CPD Notice 20-08, which established an expenditure
deadline of September 30, 2022, for ESG CARES Act funds.
• HUD later extended the expenditure deadline for the first and second ESG-CV
allocations through CPD Notice 22-06 to:
o September 30, 2023, for all costs except Homeless Management Information
System (HMIS) and administration; and
o December 31,2023, for HMIS and administration costs necessary for grant
closeout.
• HUD explained that the additional time for HMIS and administration costs was
intended to allow recipients sufficient lime to accurately draw down and report
eligible expenditures incurred by September 30, 2023, after fully completing ESG
CARES Act-funded activities.
However, SNAPS disagrees with the report’s conclusion that these two expenditure
deadlines resulted in two separate draw deadlines
www.hud.gov espanol.hud.gov
Office of Audit and Evaluation | Office of Inspector General Page | 20
• January 31, 2024 (120 calendar days after September 30, 2023), for non-HMIS
and non-administration expenses, and
• April 30, 2024 (120 calendar days after December 31, 2023), for administration
and HMIS expenses necessary for the grant closeout.
SNAPS also disagrees with the conclusion that HUD issued conflicting information by
identifying a single draw deadline of April 30, 2024, for all expenses. SNAPS provides the
following clarifications.
ESG CV Allocations
HUD awarded ESG-CV funds in three allocations: Allocation 1, Allocation 2, and a reallocation
of funds that HUD recaptured from ESG-CV recipients that did not meet the 50 percent draw
deadline.
• Allocation 1: $1 billion distributed using the formula applied to annual ESG awards. The
City and County of Honolulu received $2,429,569 under Allocation 1.
• Allocation 2: $2.96 billion distributed using a different formula that targeted
communities with higher rates of homelessness. Honolulu received $22,370,813 under
Allocation 2.
• Reallocation: $16,810,200 redistributed to 62 ESG-CV recipients using funds that HUD
recaptured from recipients that did not meet the 50 percent draw deadline. Honolulu
received $849,017.21 in reallocated funds. HUD later recaptured $257,445.06 in unspent
funds from Honolulu.
HUD did not establish separate expenditure deadlines for Allocation 1 and Allocation 2.
These allocations were indistinguishable in the Integrated Disbursement and Information System
(IDIS) and were used to fund all eligible ESG-CV activities, including administration, HMIS,
rapid rehousing, homelessness prevention, emergency shelter, and street outreach.
HUD did establish a separate expenditure deadline for reallocated funds because those
awards were made significantly later than Allocations 1 and 2. The expenditure deadline for
reallocated funds was June 30, 2024, which was later than the period of performance end date
and draw deadline for ESG-CV grants that did not include reallocated funds.
Cost Categories and Expenditure Deadlines
The September 30, 2023, and December 31, 2023, deadlines applied to different cost
categories, not to separate allocations:
• Project Costs: Administration, HMIS, rapid rehousing, homelessness prevention,
emergency shelter, and street outreach.
• Closeout Costs: Administration and HMIS costs necessary to complete grant closeout
activities.
Funding for both cost categories included funds from Allocations 1 and 2. Administration
and HMIS are the only cost types that fall under both project costs and closeout costs.
Office of Audit and Evaluation | Office of Inspector General Page | 21
The IDIS system does not have functionality to distinguish between administration and
HMIS costs used for project activities and those used for closeout. All administration and HMIS
costs are recorded under single activity categories in IDIS. As a result, HUD could not establish
separate draw deadlines for project Costs and closeout costs.
Period of Performance and Draw Deadlines
Under 2 CFR 200.344, recipients have 120 days after the end of the period of performance to
draw funds. HUD applied a single period of performance for each ESG-CV grant, during which
recipients could incur and expend eligible costs in accordance with ESG-CV requirements.
The period of performance end dates for ESG-CV grants were:
• December 31,2023, for ESG-CV grants that did not include reallocated funds; and
• June 30, 2024, for ESG-CV grants that included reallocated funds.
Based on these periods of performance end dates, HUD identified one draw deadline per grant
rather than separate draw deadlines by cost category.
Additional HUD Communications
hi addition to the CPD notices cited in the report, HUD communicated applicable expenditure
and draw deadlines to recipients through multiple channels, including:
• An ESG-CV Closeout Review webinar conducted during ESG-CV Recipient Office
Hours;
• Individual, one-on-one emails from ESG-CV Desk Officers to each recipient; and
• An ESG-CV Closeout Memorandum issued to all HUD Field Offices.
2. MANAGEMENT RECOMMENDATIONS
The report recommends that the Deputy Assistant Secretary for Office of Special Needs:
A, Develop and implement written policies and procedures to ensure that any
changes to the expenditure and draw deadlines for the ESG program are provided
in a formal document, such as a CPD notice or memorandum issued to all
grantees; and
B. Ensure that ESG grantees operating tenant-based rental assistance programs
prorate the rent amounts.
In response to these recommendations, SNAPS Office agrees to take the following actions:
A. SNAPS will develop and implement written policies and procedures, issued
through formal documents such as CPD notices or memoranda, to ensure that
Office of Audit and Evaluation | Office of Inspector General Page | 22
ESG recipients are informed of any future changes to ESG expenditure or draw
deadlines; and
B. SNAPS will develop technical assistance materials explaining the requirement to
prorate rent for tenant-based rental assistance and will provide training to ESG
recipients through technical assistance provider support.
cc:
Ronald J. Kurtz, Assistant Secretary for Community Planning and Development, D
Felicia Gaither, Associate Deputy Assistant Secretary, Office of Special Needs, DN
Norm Suchar, Director, Office of Special Needs Assistance Programs, DNS
Tennille S. Parker, Deputy Assistant Secretary, Office of Field Operations
Tanya E. Schulze, Audit Director, Grants Management Audit Division
Office of Audit and Evaluation | Office of Inspector General Page | 23
Appendix C – Schedule of Overpaid Rent to Landlords
Days unit was Prorated Amount
Lease
Sample occupied for 9 Amount overpaid
agreement Rent paid
number the first (OIG (OIG
start date
month calculated) calculated)
1 10/21/2021 11 $ 1,100 $ 403 $ 697
2 08/26/2021 6 900 180 720
3 10/22/2021 10 1,350 450 900
4 08/18/2021 14 1,410 658 752
5 05/17/2021 15 1,550 775 775
6 07/19/2021 13 1,450 628 822
7 01/24/2022 8 1,600 427 1,173
8 04/16/2021 15 1,632 816 816
9 06/02/2021 29 2,000 1,933 67
10 05/25/2021 7 1,800 420 1,380
11 10/28/2021 4 2,500 333 2,167
12 06/25/2021 6 2,500 500 2,000
13 01/11/2022 21 3,000 2,100 900
14 10/06/2021 26 3,000 2,600 400
15 11/22/2021 9 1,150 345 805
16 04/23/2021 8 944 252 692
17 08/01/2021 31 1,150 1,150 0
18 12/15/2021 17 950 538 412
19 10/22/2021 10 1,200 400 800
20 05/01/2021 31 1,200 1,200 0
21 07/09/2021 23 1,250 958 292
22 10/21/2021 11 1,350 495 855
23 12/08/2021 24 1,200 960 240
24 07/23/2021 9 1,350 405 945
25 05/13/2021 19 1,200 760 440
26 08/10/2021 22 1,300 953 347
27 07/23/2021 9 1,350 405 945
28 03/30/2022 2 1,250 83 1,167
29 05/18/2021 14 1,550 723 827
9
Full month rent was paid for all sample items.
Office of Audit and Evaluation | Office of Inspector General Page | 24
30 04/15/2021 16 1,515 808 707
31 09/29/2021 2 1,495 100 1,395
32 03/31/2022 1 1,458 49 1,409
33 01/04/2022 28 1,550 1,447 103
34 05/27/2021 5 1,475 246 1,229
35 12/22/2021 10 1,500 500 1,000
36 12/11/2021 21 1,500 1,050 450
37 11/30/2021 1 1,700 57 1,643
38 04/23/2021 8 1,632 435 1,197
39 07/15/2021 17 1,700 963 737
40 08/13/2021 19 1,700 1,077 623
41 08/12/2021 20 1,600 1,067 533
42 07/22/2021 10 1,625 542 1,083
43 08/30/2021 2 1,625 108 1,517
44 01/06/2022 26 1,700 1,473 227
45 05/28/2021 4 1,885 251 1,634
46 08/03/2021 29 1,895 1,832 63
47 07/19/2021 13 2,200 953 1,247
48 10/18/2021 14 1,800 840 960
49 08/30/2021 2 2,100 140 1,960
50 06/03/2021 28 2,167 2,023 144
51 05/14/2021 18 1,900 1,140 760
52 10/19/2021 13 1,875 813 1,063
53 05/14/2021 18 1,800 1,080 720
54 11/12/2021 19 1,836 1,163 673
55 09/15/2021 16 1,865 995 870
56 04/07/2021 24 1,800 1,440 360
57 03/30/2022 2 2,500 167 2,333
58 09/15/2021 16 2,700 1,440 1,260
59 07/12/2021 20 3,000 2,000 1,000
Totals $ 99,284 $ 48,049 $ 51,235
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