WAP Monitoring_Part 2

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T EX AS D EPARTM EN T OF HOUSING AN D COMMUNITY AFFAIRS

www.tdhca.state.tx.us

R1ckPerryGOVERNOR

Michael Gerber

ExECUTIVE DIRI!CTOR

June 21, 2010

Mr. David OjedaExecutive DirectorCommunity Services Agency of South TexasP. O. Bo x 488Carrizo Springs, TX 78834-6488

BOARD MEMBHRS

C. Kent Conine, ChairGloria Ray, Vlcet Chair

Leslie Bjngham EscarenoTom H. Gann

Lowell A. KelgJuan S. Muf toz, Ph,D.

Re: Department of Energy Weatherization Assistance Program Contract #56090000457Department of Energy ARRA Weatherization Assistance Program Contract #16090000769LIHEAP Weatherization Assistance Program Contract #81090000490LIHEAP Comprehensive Energy Assistance Program Contract #58090000403

Deal' Mr. Ojeda:

Enclosed is a report that details the monitoring review of Community Services Agency of South Texas'Weatherization Assistance Program and Comprehensive Energy Assistance Program contracts with theTexas Department o f Housing and Community Affairs (The Department). This information is provided toensure that compliance with the contracts is maintained and that services to the poor, elderly, and disabledare offered in the most expeditious and economical manner.

The monitoring report includes two (2) recommended improvements and sixteen (16) findings for theWeatherization Assistance Program, and two (2) findings for the Comprehensive Energy AssistanceProgram. Please submit a response to the Weatherization Assistance Program monitoring report to thisoffice within thirty (30) days o f the date of this letter, and within forty-'flve (45) days for theComprehensive Energy Assistance Program monitoring report.

I f we can be of any assistance, please feel free to contact Rosy L. Falcon, Program Officer, at (512) 9367810. The assistance provided to the Program Officer by the agency is greatly appreciated.

Sincerely,

~ n i l i kManagerCommunity Affairs

cc: Mr. Roel Rodriguez, Jr.

221 EAST 11 TH • P. O . Box 13941 • AUSTIN, TBXAS 78711·3941 • (800) 525·0657 • (512) 475-3800



Directory of Monitoring Sections

Section I. Financial Review

Section II. Travel and Timesheets

Section III. General Liability and Pollution Occurrence Insurance

Section IV. Property Management

Section V. Procurement

Section VI. Audit

Section VII. Personnel Policies and Practices

Section VIII. Performance Review and Onsite Inspections

Section IX. Administrative

Section X. . Client File Review Work Sheet and Multi-FamilyReview

Section XI. Denied Files

Section XII. Summary



2009 WEATHERIZATION AND COMPREHENSIVE ENERGY ASSISTANCE PROGRAMMONITORING REPORT

OFCOMMUNITY SERVICES AGENCY OF SOUTH TEXAS

Dates of Weatherization Program Review: February 8·11, 2010Dates of Weatherization an d CEAP Review: March 1-4,2010

Focus O F R EV IE W

CONTRACT NAME CONTRACT * CONTRACT CONTRACT DATESNUMBER AMOUNT

DOE 56090000457 $388,597.00 4/1/2009 to 3/31/2010

UHEAP 81090000490 $473,654.00 4/1/2009 to 3/31/2010

DOEARRA 16090000769 $1,842,716.00 9/1/2009 to 8/31/2011

UHEAP - CEAP 58090000403 $1,056,927.00 1/1/2009 to 12/31/2009

>II Latest contract amendments

On-site review of the Community Services Agency of South Texas' (CSA of South Texas)implementation of the Department of Energy and Low Income Home Energy AssistanceProgram's Weatherization Assistance Program (WAP) and Comprehensive Energy AssistanceProgram (CEAP). Specific areas of review included Financial Reporting, Contract Agreements,Procurement, Personnel, and the Management of the Department of Energy and Low IncomeHome Energy Assistance Program contracts.

PROGRAM EVALUATION

The evaluation of the program consisted of interviews with the Community Services Agency ofSouth Texas' personnel, analysis of the fiscal system, review of programmatic records, on-siteinspections, client interviews, and inventory review.

The following was noted during the review:

• Monthly general ledger did not reconcile with submitted expenditure reports.

• At the time of monitoring the DOE, LIHEAP, and ARRA Administrativeexpenditures were higher than the allowable maximum.

• At the time of monitoring the UHEAP average cost pel' unit was higher than theallowed maximum.

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2 0 0 9 WEATHERIZATION AN D COMPREHENSIVE ENERGY ASSISTANCE PROGRAM

MONITORING REPORT


• Lack of support documentation for expenditures.

• DOE and LIHEAP expenditures are significantly lower than the necessary to fulfill

contract term.

• Bank reconciliatio.ns and corrections are not performed in a timely manner; there was

a lack of support documentation for adjusting entries.

• Bank signature cards are not updated regularly.

• Lack of effective separation of duties.

• Lack of accountability on interest earned above $250.00.

• Units charged to Program Year 2008 were not completed in accordance to thecontract.

• Stafftimesheets contained inadequate information.

• Lack of documentation for inventory of materials and maintenance of equipment.

• Lack of mileage logs and maintenance schedule for vehicles.

• Lack o f p r o c u r e m ~ n tdocumentation.

• At the time of monitoring the Audit Certification Letter had not been submitted to thePortfolio Management and Compliance Division.

• Lack of documentation of services and outreach efforts in Edwards and Real County.

• Lack of documentation that both the Lead Hazard Information Pamphlet wasprovided to the clients and that Lead Safe Work Practices were followed.

• Lack of documentation for the Multifamily Project.

• Lack of sufficient support documentation for denied client files.

.• Lack of adequate assessments in the Heating and Cooling component of the CEAPprogram.

• Replacement of Heating and/or cooling appliances that did not rank utilizing theCEAPtoo!

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WEATHERIZATION ASSISTANCE PROGRAM

Section I. Financial ReviewEXPENDITURES AS O F D EC EM B ER 2009

• At the Ume ofmomtormg

CONTRACT YEAR-TO-DATE % OF ORIGINAL # UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESS

AMOUNT'"

DOE $120,252.75 30.95% 30 4

LIHEAP $215,245.81 33.27% 33 4

DOEARRA $0.00 0.00% 0 0. .

Finding#l: A review of the September and December 2009 Monthly Expenditure Reports forLIHEAP and the August and December 2009 Monthly Expenditure Reports forDOE revealed an inconsistency between the Monthly Expenditure Reporting tothe Department and the Agency's general ledger. At the time of monitoring therewas no appropriate backup prepared to justify the variance. A second visit was

required in order to verify adjusting entries were properly processed and thatsupporting documentation was attached.

ActionRequired:

CSA of South Texas must maintain accurate, current, and complete generalledgers, working papers, and any other financial documents used in ensuring theaccuracy of the Agency's reporting. CSA of South Texas must prepare financialdocuments in a timely manner in order to minimize the need for correctingjournalentries. The Department recommends CSA of South Texas institute an internalclosing date for debit postings in order to facilitate more accurate MonthlyExpenditure Reporting. Reference: OMB Circular A-110, Subpart C_.21

Recommended Improvement #1: As of December 2009 the Administrative expenditure ratiofor DOE was at 9.36% and at 10.65% for LIHEAP, well above the maximum allowableexpenditure. CSA of South Texas is reminded that expenditures for Administration must be at orbelow 5% for DOE and 7.22% for LIHEAP by the end of the contract term. I t is imperative thatcloser attention be paid to the production schedule in order to not exceed the above referencedmaximum allowable expenditure ratios. Any expenditure above the allowable maximum issubject to disallowed costs. Reference: DO E an d LIHEAP Contracts Attachment A.

PAGE 4 OF 23




OF

COMMUNITY SERVICES AGENCY OF SOUTH TEXAS

Recommended Improvement #2: As of December 2009 the average cost per unit for LIHEAPwas at $4,109.52, wel1 above the maximum al10wed expenditure. eSA of South Texas isreminded that average cost per unit must be at or below the maximum allowed expenditure by

the end of the contract term. I t is imperative that closer attention be paid to the productionschedule in order to meet the above mentioned ratio. Any expenditure above the allowablemaximum is subject to disallowed costs. Reference: DOE and LIHEAP ContractsAttachment A.

Finding #2:

ActionRequh'ed:

Finding #3:

ActionRequired:

Finding #4:

ActionRequired:

A review of eS A of South Texas' September, August, and December 2009expenditures revealed lack of support documentation for Check #55491 made outto Nolan's Office Products in the amount of $2,904.03. Insufficient backupresulted in $100.00 of questioned costs.

e SA o f South Texas must submit sufficient support documentation to account for$2,904.03 in expenditures. eSA of South Texas is expected to maintain adequaterecords of all expenditures. Reference: OM B Circular A·llO, Subpart C .21

As of December 2009 CSA of South Texas has expended 33.27% of funds inLIHEAP, 30.95% in DOE, and 0.00% in DOE ARRA while 84% of theirLIHEAP and DOE contract period and 16.66% of their DOE ARRA contractperiod has expired.

CSA of South Texas must submit a plan of action clearly detailing how they willexpend all funds in their various contracts, as part of their response to this report.eSA o f South Texas must pay immediate attention to production schedules inorder to expedite current expenditures for the Weatherization Assistance Program.CSA of South Texas must seek out training opportunities in order to elU'ich theirworkforce as well as expend their funds in a timely manner. Reference: OMBCircular A-llO, Subpart C _.21 (b) (2) (3) (4)

A review of CSA of South Texas' November and December 2009 reconciliationreports revealed untimely processing, insufficient support documentation tojustify adjusting entries, and a lack of an effective separation of duties forprocessing and review, as well as review and approval of variances.

CSA of South Texas must establish and immediately implement a monitoringprocess to reconcile fund activity on a monthly basis. In addition eSA of SouthTexas must establish and implement separation of duties in the preparation,review, and approval of all reconciliations, adjusting entries, and journal entries.Any adjusting entries must be properly documented and kept available for review,and must be performed on a monthly basis and not done at year end. TheDepartment recommends that eSA of South Texas obtain outside technical

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assistance to assure they are in compliance. OMB Cir. A-110, Att.C_.21(b)(2)(3)(4),1 Texas Administrative Code § 5.141

Finding #5:

ActionRequired:

Finding #6:

ActionRequired:

A review of CSA of South Texas' internal controls revealed a lack of separationof duties in the preparation, authorization, and distribution of checks as well as anoutdated bank signature card on file since 2004. Currently the Chief FinancialOfficer (CFO) of CSA of South Texas is both the supervisor for theWeatherization and Comprehensive Energy Assistance Programs and theAccounting Department. This structure as not efficient as it allowed for the sameperson to initiate, authorize, and process the same transaction, thus bypassing anyeffective checks and balances. At the time of monitol'ing the staff could notdetermine where the safe was, which contained both check signature stamps. Thekey to the safe was kept by the CFO who is able to authorize and pl'int checks.

CSA of South Texas is instructed to follow their Accounting Policies andProcedures when preparing, authol'izing, and distributing checks. CSA of SouthTexas must submit to the Department an Organizational Chart, and mustimplement procedures ensuring separation of duties will be followed whenexperiencing vacancies. The Organizational chart must reflect a clear separationbetween. the Financial Department and Program Services. Under no

circumstances should one person authorize purchases for the Program andAccounting Departments.

CSA of South Texas is also expected to immediately update the Signature BankCard and perform any necessary updates in a timely manner. CSA of SouthTexas is expected to establish a permanent location for the safe and key(s) beissued to staffwithout access to check authorization and/or printing only.

CSA of South Texas must purchase a safe that is not easily misplaced, and mustfind a secure permanent location for it. Referencf;l: OMB Circular A-110,Subpart C_.21. '

A review of CSA of South Texas' General Fund Accounting revealed a lack oftracking of interest earnings as well as a lack of procedures to ensure interestearned in excess of $250.00 is reimbursed in accordance with federalrequirements.

CSA of South Texas must establish procedures to ensure interest earned onfederal grants is reimbursed to the proper funding source in accordance withfederal regulations, governing program income. CSA of South Texas is urged to

procure training in their MIP Accounting software so it is possible to clearly trackexpenditures and revenues for each grant since all money coming into the Agencyis kept in one account. Reference: OMB Circular A-110, Subpart C_.24.

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2 0 0 9 WEATHERIZATION AND COMPREHENSIVE ENERGY ASSISTANCE P R O G R A M

M O N I T O R I N G R E P O RT

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C O MM U NI T Y S E RVI C E S A GE N CY OF SOUTH TEXAS

Section II. Travel an d Timesheets

Finding #7:

ActionRequired:

A review of CSA of South Texas' Weatherization Assistance Program stafftimesheets revealed inadequate information. Timesheets did not substantiateexpenditures for each employee.

CSA of South Texas must ensure the charges for the Weatherization AssistancePl'ogram staff timesheets are correctly allocated to reflect duties pel'formed andthat positions al'e clearly charged to the appropriate categories. CSA of SouthTexas must add a job title field to theil' Program Activity FOl'm and is expected toutilize their Progl'am Activity Form for each employee paid with WAP funds.Reference: OMB Circular A·122 Attachment B § 8


Finding #8: CSA of South Texas did not pl'Ovide documentation that a physical inventory isperformed for materials kept in the warehouse or that a control system is in placethat will allow for the safeguarding of program materials. CSA of South Texastemporarily houses refrigerators that are not able to get installed in client homeswhen delivered. CSA of South Texas did not provide documentation that allowsfor the tracking of such materials from the vendor to a client's home.

Through staff interviews, a review of procurement documentation, and an onsitevisit to CSA of South Texas' warehouse it was determined that CSA of South

Texas was allowing their contractors the use of the Agency's insulation blowermachine, generator, and trailer free of charge. In addition it was determined thatCSA of South Texas did not have a rental agreement between the Agency and thecontractors in place for the use of the tools and equipment. During theDepartment's visit and through various emails CSA of South Texas wasinstructed to stop the use of the insulation blowel' machine until a fee schedulewas settled and a l'ental agreement is in place between the Agency and eachcontractol'. Continued use of the equipment prior to the fee scheduleestablishment and rental agreement wi1llead to disallowed costs.

Action

Required:

CSA of South Texas is expected to immediately establish a control system for

matel'ials kept in their possession, to include materials housed on a temporarybasis, such as refrigerators. CSA of South Texas must establish a fee schedulethat satisfies all requirements along with a rental agreement that ensures theequipment will be safeguarded and clearly delineates the responsibilities andliabilities that lies with each party. CSA of South Texas must submit a copy of

the fee schedule and rental agl'eement to the Department as part of their l'esponse

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2 0 0 9 WEATHERIZATION AND COMPREHENSIVE ENERGY ASSISTANCE PROGRAMMONITORING REPORT

OFCOMMUNITY SERVICES A GE NC Y O F S OU TH T EX AS

to this report. Reference: DOE and LIHEAP Contracts Section 17, 10 CF R600.232, OMB A-110 Section 34 (b)

Finding #9:

ActionRequired:

Finding #10:

ActionRequired:

CSA of South Texas was unable to provide documentation that equipment andvehicles are maintained in good working order, vehicle records were found to belacking a proper mileage log, and no property management standards forequipment were followed.

CSA of South Texas must ensure that adequate maintenance procedures aredeveloped and equipment and vehicles are kept in good working order.Equipment and vehicles acquired from Maverick County must be inspected todetermine i f any maintenance is needed. If it is determined that any equipment isin need of repair or maintenance appropl'iate action must be taken immediately.

Proper mileage logs must be created and maintained for each WeatherizationAssistance Program vehicle. One mileage log entry shall not encompass theentire trip; each trip should have at minimum two entries, one reflecting thedeparture from the Agency and another reflecting the return to the Agency. Thefirst entry must be logged from the Agency to the desired destination and a secondentry is necessary reflecting the information from the desired destination back tothe Agency, and the purpose of the trip must also be clearly noted. CSA of SouthTexas must establish and follow proper property management standards for allequipment owned. Reference: 10 CF R 600.134 (I) (5) an d 10 CFR 600.232 (d)(4), OMB Circular A-122 Attachment B, 10 CFR 600.232, OMB Circular A110 .34 Equipment


CSA of South Texas was unable to provide documentation of the procurementprocess used to procure Grainger, Fernando Munoz, and Ernest White. Thisreview revealed a lack of documentation for $8,567.22 in expenditures.

CSA of South Texas must reimburse the Department $8,567.22, please indicateLIHEAP Contract # 81090000490 on the check. CSA of South Texas mustreimburse the Department $692.00, please indicate DOE Contract #56090000457

on the check. The total amount CSA of South Texas must reimburse theDepartment is $8,567:22. The Department expects CSA of South Texas willensure proper procurement procedures for all weatherization \llaterials, labor, andservices will be followed as well as maintaining proper documentation for allprocurement as it pertains to the Weatherization Assistance Program. Reference:Texas Administrative Code §5.10

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Section VI. Audit

Finding #11: At the time of monitoring CSA of South Texas had not submitted their AuditCertification Letter to the Portfolio Management and Compliance Division.

ActionRequired:

Finding #12:

ActionRequired:

Finding #13:

ActionRequired:

Finding #14:

CSA of South Texas is expected to submit the Agency's Audit Certification Letterto the Texas Department of Housing and Community Affairs PortfolioManagement and Compliance Division. Reference: DOE and LIHEAPContract Section 16, OMB Circular A-133.

Section VIII. Performance Review

A review of CSA of South Texas' December 2009 Monthly Expenditure Reportrevealed a lack of weatherization services in Edwards and Real Counties.Furthermore, there was also a lack of documentation of any outreach effortsperformed in Edwards and Real Counties.

CSA of South Texas must ensure that they serve their service area in an equitablebasis. Outreach efforts must be documented for every county and a file must bemaintained for monitoring purposes. Reference: DOE and LIHEAP ContractSection 3, Texas Administrative Code §5.703

A review of CSA of South Texas client files revealed a lack of documentation forproviding clients with Lead Hazard· Informational Pamphlets and that the LeadSafe Work Practices were followed.

CSA of South Texas must ensure all future work done under the contractcomplies with all Lead Safety requirements. I t is of special importance to assureall contractors attend a Lead Renovators Certification training as soon as possible,but no later than April 22, 2010. A copy of all Lead Safe trainings andcertifications must be kept in at the Agency for monitoring purposes. Reference:Weatherization Program Notice 09-6, Texas Administrative Code §5.521,Texas Administrative Code §5.524

CSA of South Texas had deficiencies in the installation of insulation, ventilationand the water heater replaced on three (3) out of the twenty three (23) unitsinspected. There was improper use of the Carbon Monoxide (CO) detector duringthe inspections. The CO reading was tested after the baseline was taken indoorsnext to the lit combustion appliance to be tested.

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ActionRequired:

CSA of South Texas must return to the units listed in Attachment A and addressthe deficiencies noted within the attachment. CSA of South Texas must submit inresponse to this report a summary of all actions and measures taken to address the

units requiring a return. CSA of South Texas must familiarize themselves withthe proper use of their equipment in order to ensure the Health and Safety of theirclients. The Department wants to remind CSA of South Texas of the importanceof CO testing as part of their assessment/final inspection process and that thebaseline must be taken for 60 seconds outdoors in order to obtain an accuratereading. Reference: 10 C.F.R. Part 440, Attachment A

Section X. Multifamily Review

Finding #15: A review of CSA of South Texas' files revealed the lack of a master file for theCrystal City. Housing Authority, lack of sufficient documentation to determineeligibility, lack of Landlord Financial Participation Form, lack of Permission toConduct an Energy Audit Form, insufficient income documentation, and impropercompletion of assessment tools. .

Expenditures charged to Program Year 2008 were in violation of CSA of SouthTexas's own Accounting Policies and Procedures, and in violation of programguidelines as only one (vacant unit) out of the 26 applicati\)ns was obtainedduring Program Year 2008.

There is a discrepancy between application dates, income and income verification,

assessments, audits, and purchase orders and invoices that create a question as tothe ability to fully determine the qualification of the project (See Attachment B).The twenty five (25) applications for this project were obtained in April 2009 andMay 2009 which was not Program Year 2008; income verification performed on3/30/09 and 3/31109, consumption reports were obtained in April 2009 and May2009, all assessments were completed on 3/31/09, the EZ Audit was completed on3/31/09 for seventeen (17) units, and materials were purchased prior to theapplication being received as well as the audit being run for twenty (21) of theunits. Documentation for this project demonstrates that on 3/3112009 one staffmember performed income verification on four (4) units, twenty six (26)assessments in Crystal City, created seventeen (17) EZ Audits, purchased

materials for all twenty six (26) units, and was going through a TDHCA ProgramMonitoring in Carrizo Springs, while the employee vehicle mileage log shows theemployee to be in Uvalde, TX and is certified by the employee signature.

The lack of proper recordkeeping in CSA of South Texas made it not possible forthem to determine how much of this project's expenditures were charged toProgram Year 2008. This lack of documentation and timing irregularitiesrevealed $71,007.88 in questioned costs.

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M O N I T O R I N G REPORT

OF

COMMUNITY SERVICES AGENCY O F S OU TH TEXAS

ActionRequired:

CSA of South Texas must provide the Department, documentation within theirresponse to this report, proving they had the necessary Landlord forms

completed, obtain the necessary proof of income from the listed tenants in

Attachment B, and that tenants were income eligible prior to performing thewhole house energy assessments, audits and the purchase of the materials. CSAof South Texas must submit documentation detailing the expenditures per fundcharged to Program Year 2008 and Program Year 2009. Included in thisexpenditure report they must indicate which units were charged to Program Year2008 and which were charged to Program Year 2009. In addition, CSA of SouthTexas must submit documentation detailing how the process for this multifamilywas accurately done when one staff member performed income verification onfour (4) units, twenty six (26) assessments in Crystal City, created seventeen (17)EZ Audits, purchased materials for all twenty six (26) units, and was goingthrough a TDHCA Program Monitoring in Carrizo Springs, while the employee

vehicle mileage log shows the employee to be in Uvalde, TX and is certified bythe employee signature.

The Department expects CSA of South Texas will ensure the proper proceduresfor all multifamily projects will be followed as well as maintaining properdocumentation as it pertains to the Weatherization Assistance Program. CSA isexpected to receive extensive training on income verification, case management,and multifamily preparation as soon as training is available. CSA of South Texasmust complete a Masterfile for all multifamily projects it is planning toweatherize. Reference: Texas Administrative Code §S.S2S an d TexasAdministrative Code §S.20, Texas Administrative Code §5.S29, DOE and

LIHEAP Section 10 Record Keeping Requirements, 10 C.F.R. 440.22


Finding #16:' A review of CSA of South Texas's denied files revealed a lack of proper supportdocumentation. Support documentation for denials did not contain sufficientsupport documentation needlJd to not have the Agency's determination overturnshould an appeal be filed with the Department.

Action

Required:

CSA of South Texas is expected to utilize assessments and pictures when the

Agency must deny weatherization services and a signed statement from the clientwhen the client is refusing services. Reference: Texas Administrative Code§5.S0S.

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2 0 0 9 WEATHERIZATION AN D COMPREHENSIVE ENERGY ASSISTANCE PROGRAM

MONITORING REPORT

OF



CSAof

South Texasis

not only expected to follow all rules and regulations but must alsoadhere to Best Practices as they relate to the Weatherization Assistance Program, It isnecessary for CSA of South Texas to receive extensive technical assistance on all aspectsof the Weatherization Assistance Program, especially strategic planning, Training on themanagement and implementation of the program is vital to the success of CSA of SouthTexas' Weatherization Assistance Program.

Due to the deficiencies in AccoUnting and record keeping, lack of documentation fOl'

procurements, irregularities on the multifamily project, lack of effective separation of

duties, and a lack of effective safeguards for the check processing and distribution CSAof South Texas must be placed on Cost Reimbursement immediately,

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2009 WEATHERIZATION AN D COMPREHENSIVE ENERGY ASSISTANCE PROGRAMMONITORING REPORT


COMPREHENSIVE ENERGY ASSISTANCE PROGRAM

EXPENDITURES AS OF DECEMBER (FINAL) 2009

CATEGORY! YEAR-TO-DATE % OF CONTRACTCOMPONENT EXPENDITURES

ADMINISTRATION $75,990.09 7.2%

ASSURANCE 16 $64,518.29 6.12%

ENERGY CRiSIS $185,788.09 17.62 %

CO-PAYMENT $52,903.69 5.02%

ELDERLY DISABLED $404,899.96 38.39 %

HEATING AND $224,848.44 21.32%.COOLING

DIRECT SERVICE $45,757.00 4.34%SUPPORT

Finding #17: A review of employee timesheets revealed:A) CSA paid one time merit payments to six (6) employees out of CEAP funds.

While there is a provision to allow merit payments, CSA did not cost allocatethe payment by program, according to the percentage of time each employeespends on a specific program. The entire merit payment was paid solely out ofCEAP program funds. As uesult, the Department has questioned $ 2,178.80and disallowed $ 625.07 from the merit payments (see Attallhment C).

B) CSA fails to complete Change of Status forms in the employee files. Whilereviewing support documentation, Change of Status or Employee StatusChange forms were not complete as the distribution codes do not documentwhat funding source changed. The inability to document the changes makes itdifficult or impossible to justify salaries charged to the CEAP program 'whichmay result in questioned or disallowed costs.

Action Required: As part of the response to this report,A) CSA must assure the Department that any future merit payments or increase in

pay will be Cost allocated according to the duties of the employee asdocumented in the employee file. In addition, as part of the response to thisreport, CSA must provide support documentation for the questioned costs, tojustify the correct allocation from the funding sources the employee was

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previously paid from. Lastly, CSA must reimburse the Department $ 625.07for the non CEAP percentage of the merit payments noted in Attachment C.

B) CSA must provide an assurance to the Department that any Change of Status

or a merit increase, will have the change of status fOlm completed in itsentirety, to include documenting the correct funding sources and any otherspecific section when applicable.

Reference: Circular A122 at t B 8 M ; Circular A 102 and A-87

Finding #18: A review of seventeen (17) Heating and Cooling files revealed:

A. Fifteen (IS) files lacked assessments or were not complete. The lack of completeassessments do not allow for the determination whether or not an appliance is efficient,thus any replacement 01' repair of any and all heating and cooling is not justified. The lackof justification for repair 01' replacement results in disallowed 01' questioned costs.

B. Nine (9) files that contained incomplete assessments, had heating 01' cooling appliancesreplaced when the assessment did not allow for replacement. Appliances were replacedwhen the assessment stated the existing unit was documented as "new", "making a rattlingsound" or the assessment showed efficient appliances. Replacement of units that aredocumented as "new" or efficient is not allowable since the documentation provides theassumption that the appliance is not consuming energy inefficiently. The purpose of thecomponent is to only address (repair, replace 01' retrofit) inefficient appliances.

C. One (I ) file where a window ail' conditioner was replaced and three (3) files where waterheaters were replaced in each when the appliance tool did not show the minimum savingsneeded for replacement of said unit.

D. One (1) file where a Central HV AC system was replaced when the appliance wasdocumented as inoperable. By replacing an inoperable unit, CSA only increased theenergy consumption of the household defeating the purpose of the component, which is toreduce energy consumption.

Attachment D reflects Findhig #18

Action Required:A. As part of the response to this report, CSA must provide an assurance that all heating and

cooling assessments will contain detailed information to determine and justify the repair,replacement 01' retrofit of a Heating and Cooling appliance. As a result of the fifteen (IS)units, that did not have complete assessments, The Department has determined

$40,727.00 in disallowed costs and $50.00 in questioned costs. As part ofthe response tothis report, CSA must reimburse the Department $40,727.00 and provide justification onthe expenditure of $50.00 for an assessment when the assessment was not complete.

B. As part of the response to this report, CSA must provide an assurance that heating andcooling appliances will not be replaced when the documentation states the appliance isnew, making a rattling sound or when the appliance is efficient. As a result of thisfinding, the Department has determined $8,632.00 to be disallowed expenditures and$5,000.00 in questioned costs. CSA must provide documentation on the questioned costs

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M O N I T O R I N G REPORT

OF

C OM MU NI TY S E RV I CE S A GE NC Y O F SOUTH TEXAS

that provides adequate justification detailing the need for replacement from theefficiencies of the replaced and replacement appliance. As part of the response to thisreport CSA must reimburse the department $8,632.00.

C. As part of the response to this report, CSA must provide an assurance that replacement ofHeating and Cooling appliances will only be replaced when the assessment tools providethe minimum required savings of twenty-five percent (25%) for windoW air conditionersand a one (1) 01' greater for water heaters. As a result of this finding the Department hasdetermined $2,368.07 to be disallowed and CSA must submit the reimbursement as partof the response to this report.

D. As part of the response to this report, CSA must provide an assurance that heating andcooling appliances will not be repaired, replaced or retrofitted, when the appliance isinoperable. As a result of th e finding CSA must reimburse the Department $4,000.00 forthe replacement of the Central HVAC and must submit the reimbursement as part of theresponse to this report.

Reference: T.A.C. 10 § 5.426

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MONI TORING REPORT

OF


ATTACHMENT A

UnitsF u n d Source Return Comments

InsDected09 DIG 9S6 DOE I No No Return

LIHBAP09 ZAC 9S1 DOE No No Return

09ZAG9SS DOB No No Return

09 LSR970 DOB/LIHEAI No No Return

09ZAR 748 DOB/LIHBAI No No Return

09UVG982 Attic insulation at rear part of the honse not up to R- value. Approxbuate R-12DOE Yes p.... ent.

Return and instaU insulation up to the required R-value.09UVQ978 DOB/LIHAP No No Return

09UVM979 LlHEAP No No Return

09ZAM749 DOE/LIHAP No No Return

09ZAM749 DOB/LIHEAI No No Return

09MVS964 L1HEAP No No Return

09MVR993 LlHEAP No No ReturnI

09MVM989 DOB No No Return

09MVS966 LlHEAP Yes Return to add additional vent ventilation to attic. Install door bottom ou back northdoor,

09MVQI002 DOEILIHBAP Yes Return to bring up the water he.ter th.t was replaced to code.

09UVM958 DOEILIHEAP No No Return.

09UVR983 DOElLlHEAP No No return.

09VVMlOlO LIHBAP No No return

RB DOEILIHEAP No No return.

M e DOEILIHEAP No No return.

082AM733 DOEILIHBAP No No return.

082HA726 DOEILIHBAP No No return,

082AP743 DOEILIHEAP No No return.

PAGE 16 OF 23





OF

C O MM U NI T Y S E RV I CE S A GE NC Y OF S OU T H T EX AS

ATTACHMENT B

Unit CommentsApplication obtained during Program Year 2009. Pleaseprovide the following documentation clearly detailing how:

• the client's income verification (3/31/09) could beaccurately determined prior to them applying (4/8/09) for• services;• the audit (5/14/09) conld be accurately pl'Ocessed prlo,·to obtaining the consnmptionreport;• it was determined the client was eligible for services (assessment [3/31/09])prior to completing the

aoollcationorocess.Application obtained during ProgramYcar 2009. Please provide the following docnmentation clearly detailing how:

• the cllent's income verification (3/30/09) could be accurately determinedprior to them applying (5/25/09)for services;. . • income eligibility was reached as the income proof was insufficient, it was a December2008 timesheetandnot a paystub, the employee and time-keeper signature line was blank;

• the consumption report(4/28/09) couldbe obtained prior to the cllent signing the release form (5/25/09);• it was detel'lllined the client was ellglble for services (assessments [3/31/09]) prior to completing the

aoollcatlonorocess.Appllcationobtained durIng Program Year 2009. Please provide the following documentation clearly detailing how:

• the cllent's Income verification (3/30/09) could be accurately determined prior to them applying (4/8/09)forservices;

- • income ellglbllity was reached as income documentation was InsuffiCient, the Housing Authorityverification form utilized was from April 2008; Agency is reminded that the Income must be from the

. thirty (30) day period prior to the date of application and all work must bo completed withinone (I) year ofthe proofof Income (4/2009)and work was completed on 6/25/2009;

• the consnmption report(4/16/09) could beobtained prior to the client sIgning the release form (4/8/09);• it was determIned the client was eligible for services (assessments [3/31/09]) prior to completing the

annlicatlon orocess.

- Appllcatlon obtained In Program Year 2008. Please provide the following docnmentatlon clearly detailing how:• It was determined this vacant unit was eligible for services (assessments [3/31/09]) prior to establishing

building eligibilitv.Applicationobtained during Prog"im Year 2009. Please provide the following documentationclcarly detailing how:

• the client's income verification (3/30/09) could be accurately determinedprior to them applying (5/25/09)

. .for services;

• the c o ~ s u m p t i o nreport (4/28/09) could be obtained prior to the client signing therelease form (5/25/09);• it was determined the client was eligible for services (assessments [3/31/09]) prior to completing the

applicationprocess.Application obtained during Program Year 2009. Piease providethe followIng documentation clearly detailing how:

• the client's income verification (4/8/09) conld be accurately determined prior to tI,em applying (4/9/09) forservices;

• it was detel'mlned the client was ellgible for services (assessments [3/31/09]) prior to completing theaDDlication process.

Application obtained during ProgramYea" 2009. Please provide the following documentation clearly detailing how:• the client's income verification (3/30/09) could be accurately determined prior to them applying (4/7/09)

for services;

-• Income eligibility was reached as the income proof was insufficient, it was an improperly completed

Employer Verification form from 2008;

• the Agency met all recordkeeping requirements deHneated in their contracts, since there is no consumptionreport in this file;

• it was determined the client was eligible for services (assessments, audit, work start, materials purchasedrail done on 3/311091) 01'101'to comnleting the annllcation process. ,

Application date blank, unable determine whlcii Program Year this application belongs to. (The release form wassigned on 4/8/09, and the application process Is not considered complete until an the parts within it are filled onl,

1!8signed, and dated.) Please providethe following documentationclearly detailing how:

• the client's income verification (3/30/09) could be accurately determinedprior 10 them applying (no date)for services;

• the Agency met all r e c o r d k e e p l n ~reouirements delineated in their contracts since there is no consumption

PAGE 17 OF 23




MONI TORING REPORT

OF


report in this file;• the audit (3/31/09) could be accurately processed prior to the obtaining the consumption report (none

provided);• it was determined the client was eligible for scrvices (assessments, audit,work start(3/30/09), materials

purchased [all not noted done on 3/31109]) prior to completing the application process;

• it was d e t e ~ ~ i n e dweatherization work maYt ~ e g i n(BWR begin date 3/30109) prior to conducting theassessments 3131109) and nrocesslnR the audit 3/31109).Application date blank, unable determine which Program Year this application belongsto. (The application processis not considered complete untilall the parts within it are fllled out, signed, and dated.) Please provide the followingdocumentation cleady detailing how:

• the client's income verlflcatlon (3/30109) could be accurately determinedprior to them applying (no date)for services;.., • the audit (3131109) could be accuratelyprocessed prior to the obtaining the consumptionrepnrt (514109);

• it was .determined the client was ellgible for services (assessments (3/31109), audit (3/31109), workstart(3130/09), materials purchased(3130/09)prior to completing the application process;

• it was determined weatherization work may begin (BWR begin date 3/30/09) prIor to conducting theassessments (3131109) and processing the audit (3131109);

• it was determined whichmaterials and how much to purchase (3/30109) prior to performing the assessments(3131109) and nrocessina the audit (3/311091.

Appllcatlon was obtained in Program Year2009. Please provide the following documentation clearly detailing how:

• the elient's Income verlflcation (3130109) eould be accurately determinedprior te them applying (4113109)for services;. . • It was determined theclient was ellglbie for services (assessments(3/31/09), work start(3130l09),materialspurchased(3/30/09) prior to eompleting the application process;

• it was determined weatherization work may begin (BWR begin date 3130109) prior to conducting theassessments (3/31109) and precessing the audit (4124109);

• it was determined which materials and how much to purchase (3130109) prior to performing the assessments(3/31109) and nrocessinR the audit(4/24109),

Applieation was obtained in Program Year 2009. Please provide the following documentation clearly detailing how:• the elient's ineome veriflcation (3131109) could be accurately determinedprior to them applying (417109). . for services;• the audit (3131109) could be aceurately processedprior to obtaining the consumption report(4116/09);• It was determined the client was eligible for services (assessments(3/31109), work start(3131109), materials

nurchased(3131109)nrior to cempletlnl{ the annlication process.

Application was obtained in Program Year 2009. Please provide the following documentation clearly detailing how:• the cllent's Income veriflcatlon (3/30109) could be accurately determined priorto them applying (417/09)for

~ services;• the audit (3121/09) could be accurately processedprior to oblalning the consumption report (5113/09) and

performing the assessments (3/31109);• it was determined the cllent was eligible for services (assessment [3/31/091, audit [3/21109), purchase of

materials 13/31/091. and slart of work-r3131109]) orlor to comnletin2 the anlllication IIrocess.Applleation date blank, unable delerminewhich Program Year this application belongs to. (The application processis not considered complete until all the parts within it are fliled out, signed, and dated.) Please provide the foliowlngdocumentation clearly detailing how:

• the client's Income verlflcation (3/30109) could be accurately determined prior to tilem applying (no date)~ for services;• the Agency met all rccordkeeping requirements delineated in their contracts, since there is no consumption

report In this me;• the audit (3/31109) could be accurately processed withoutti,e consumption report;

• it was determined the elient was eligible for serviees (assessments (3/31109), audit (3131109), and worksla,t(3131109) priorto comllletin. the application process.

Application was obtained In Program Year 2009. Please providethe foliowing documentationclearly detailing how:• the client's income veriflcation (3130109) could be accurately determined priorto them applying (4/8109)~ for services;• the audit(3/31109) conld be accurately processedprior to obtaining the ·consnmption report (4/22109);•. It was determined the client was eilgible for services (assessments(3/31109), work slal'l(3/31109), materials

nurchased(3131109)nrlor to comnletin2 theaDolicstion orocess.... Application was ebtalned in Program Year 2009. Please provideIhe foliowing documentation clearly detalling how:• the cllent's income verlflcatlon (3130/09) could be accuratelv determined priorto them aoolvina (4/1109)

PAGE 18 OF 23




MONITORING REPORT

OF

COMMUNITY SERVICES AGENCY OF SOUTH TEXASfor services;

• Income eligibility was reached as the income proof was insufficient. it was an Employer Verification formfrom 2008;

• the audit (3/31109) could be accurately processed prlor to obtaining the consumption repOit (4116/09);• it was determined the client was eligible for services (assessments [31311091. work start [3/30/09]) prior to

completing the application process;• it was determined weatherization work may begin (BWR begin date 3/30109) prior to conducting theassessments 13/31109land nrocessin. the audit (3/31109) and prior to completinR the application Process.

Application was obtained in Program Year 2009. Please provide the following documentation clearly detailing how:• the client's income verification (3/30/09) could be accurately determined prior to them applying (417109)

for services;. . • the audit (3/31109) could be accurately processed without obtaining the consumption report;• it was determined the client was eligible for services (assessments [3/31109], work stnlt [3/30/09]) prior to

completlog the application process;• it was determined weatherlzatlon work may begin (BWR begin date 3/30/09) prior to conducting the

assessments (3/31109\ and nrocessinR the audit (3/31109) and prior to c o m p l e t i n ~the application process.Application was obtained in Program Year 2009. Please provide the following documentation clearly detailing how:

• the client's income verification (3/30/09) could be accurately determined prior to them applying (4/8109)for services;

• income eligibility was reached as the Income proof was insufficient;

. .• the Agency met all r e c o r d k e e p i ~ grequirements delineated in their contracts, since there is no consumption

report in this file;• the audit (3/31109) could be accurately processed without obtaiuing the consumption report;• it was determined the client was eligible for services (assessments [3/311091, work stnlt [3/30/091) prior to

completing the application process;• it was determined weatherizntion work may begin (BWR begin date 3/30/09) prlor to conducting the

assessments (3/31109) and nrocessin. the audit (3/31109) and nrior to comnletlng; theapplication process.Applicatioll was obtailled In Program·Year 2009. Please provide the following documentation clearly detailing how:

• the cliellt's income verification (3/31109) could be accurately determilled prior to them applying (417109). . for sei'vices;• the audit (3/31109) could be acourately processed prior to obtaining the consumption report (511/09);• it was determined the client was eligible for servioes (assessments [3/311091, work statt (3/311091) prior to

comnletin. the aDnlieation nrocess.Application was obtained In Program Year 2009. Please provideth. following documentation clearly d.taillng how:

• the client's income verification (3130/09) could be accurately determined prior to them applying (417109)for services;

• income ellgibllity was reached as the income proof was insufficient, only one pay stub in the file and clientgets paid weekly, Agency must secure proof of income for the 30 days prior to application;. . • the consumption report ( 4 / ~ W 0 9 )could be obtain without the consumption release form signed by theclient;

• the audit (3/31109) could be accurately processed prior to obtaining the consumption report(4f22/09);• it was determined the client was eligible for services (assessments [3/31/091, work statt [3/30/09]) pdor to

completing the application process;• it was determined weatherization work may begin (BWR begin date 3/30109) prior to conducting the

assessments (3/31109) and Drocessin. the auditl3/31/09) and nrior to comnletin. the annllcatlon process. .Application was obtained In Program Year 2009. Please provide the following documelltation clearly detailing how:

• the cli.nt's income verificatioll (3/31/09) could be accurately determIned prior to them applying (417109)for services;

...• income eHgfbility was reached as the Income proof was insufficient;• the audit (3/31/09) could be accurately processed withont prior to obtaining the consumption report

(4/22/09);• it was determined the client was eligible for servtces (assessments [3/311091, work statt [3/31109]) prior to

comnletln. the annllcation nrocess.Application date blank, unable determille which Program Year this application belongs to. (The application processis not considered complete until all the parts within it are filled o u ~signed, and dated.) Please provide the following. . documentation cleady detalling how:

• the olient's income verification (3/30/09) could be accurateiy determined prior to th.m applyiog (110 date)for services;

• the audit (3/31/09) couid be accurately processed prior to obtain in . the consumption rellort (4/22/09);

PAGE 19 OF 23



2009 WEATHERIZATION AND COMPREHENSIVE ENERGV ASSISTANCE PROGRAM

MONITORING REPORT

OF

COMMUNITY SERVICES AGENCY OF SOUTH TEXAS• it was d ~ t ~ m l n e g lthe client was eligible for services (assessments [3/31/09], audit [3/31/09], purchasing

matcrials 3/31/09 and work start [3/31/091\ nrior to comoletln2 the aoollcation nrocess,Applloation was obtained In Program Vear 2009. Plcase provide the following documentationolearly detailing how:

• the ollent's Income verlfioation (3/31/09) couldbe accurately determined prior to them applying (4/8/09)for services;

• Inoome eligibilitywas reaohed as the income

proofwas insuffioient, the

paystub was

from2008;

. .• the audit (3/31/09) could be accurately processed without prior to obtaining the consumption report

(4/20/09);• It was determined the client was eligible for services (assessments [3/31/09]. audit [3/31/09]. work start

[3/30/09], and purchase of materials [3/30/09]) prior to completing the application process;• It was d e t e : ~ l n e d, ~ e a t h e r i z a t i o nwork may, ~ e g l n(BWR begin date 3/30/09) prior to conducting the

assossments 3/31/09 and nrocessln. tile audit 3/31/0!)) and nrior to comnletin" the annllcatlon nrocess,Application was obtained In Program Vear 2009, Please providethe fonowing dooumentation ciearlydetailing how:

• the cllent's income verification (3/30/09) could be accurately determined prior to them applying (4/9/09)for services;. . • the audit (3/31/09) could be accurately processed without prior to obtaining the consumption report(4/20/09);

• it was determined the client was eligible for services (assessments [3/31/09], audit [3/31/09], work start[3/30/09]. and purchase of materials [3/30/09])prior to completing the application process;

•it was determined weatherization work may begin (BWR begin date 3/30/09) prior to 'conducting theassessment;i3/31/091-and nrocessln. the audit (3/31/0!)) and nrior to comnletln. the annllcatlon orocess,

Application was obtained In Program Veal' 2009, Please provide the fonowing documentation clearlydetailing how:• the cllont's income verification (3/31/09) could be accuratelydetermined prior to tbem applying (4/8/09)

for services;• Income eligibility was reached as tbc income proof was Insufficient. thepay stub was from 2008;. . • the audli (3/31/09) could be accurately proccsscd without prior to obtaining the consumption report

(4/20/09);• it was dotormlned the client was eligible for sorvlces (assessments [3/31/09]. audit [3/31/09], work start

[3/30/09]. and purchaseof materials [3/30/09])prior to completing theapplication process;• it was determined weatherization work may begin (BWR begin date 3/30/09) prior to conducting the

,assessments (3/31/09) and orocessin. tbe audit (3/31/09\ and ;,rior to comnletin. the aoollcation orocess.Application was obtained in Program Veal' 2009. Please providethe fonowing documentation clearly detailing how:

• the cllent·s income verification (3/30/09) could be accuratoly determined prior to them applying (4/7/09)for services;

~ • income eligibility was reached as the income proof was insufficient, the pay stubs were from 2008;• the audit (3/31/09) could be accurately processed without prior to obtaining the consumption report(4/16/09);

• ;; was , ~ ~ t c r m l h e dthe client was e , I ~ ~ l b l cf g ~ )services (assessments [3/31/09], audit [3/31/09]. work start3/31/09 and nurchase of materials 3/31/09) orior to comDIetin2 the aoolicatlon nroce,",

Application was obtained In Program Veal' 2009, Please provide the following documontation clearlydetailing how:• ihe client's Income verification (3/30/09) could be accurateiy determined prior to them applying (4/8/09)

for services;• the audit (3/31/09) could be accurately processed without prior to obtaining the consumption repOlt... (4/22/09);• it was determined the cllont was eligible for services (assessments [3/31/09], audit [3/31/09], work start

[3/30/09]. and purchase of materials [3/30/09])prior to completing the application process;• It was determined woatherization work may begin (BWR begin date 3/30/09) and the purchase of materials

made (3/30/09) prior to conducting theassessments (3/31/09) and processing the audit (3/31/09) and priorto com""letin. theaoollcation nrocess. ,

PA GE 20 OF 23



2009 WEATHERIZATION AN D COMPREHENSIVE ENERGY ASSISTANCE PROGRAMMONITORING REPORT


Community Services Agency of South Texas Monitoring ReportAttachment C

Emplovee #I Total Payment Questioned Disallowed Comments:11020 $1909.16 - $ 381.83 Average oUhe two most recent pay allocations

denote that employee II 11020 only worked 80%of his time under the CEAP nrOl!ram.

10029 $ 500.00 $ 500.00 - Unable to determine what program paid thts ontime merit payment. Provide support .documentation to document what program paifor the one time merit payment. In addition,provide the last change of status form (prior tthe one time merit payment) that documents wh

I prOllram the emplovee Is belllIlPatd from.10890 $ 702.48 $ 702.48 -. Unable to determine what program paid this on

time merit payment. Provide supportdocumentation to document what program paidfor the one time merit payment. In addition,provide the last change of statns form (prior tothe one lime merit payment) that documents whprOllram the employee Is belnl! paid f.'om.

11055 $ 976.32 $ 976.32 - Unable to determine what program paid this olime merit paymeat. Provide supportdocumentation to document what program paidfOr the one lime merit payment. I . ~addition,provide the last change of status form (priorthe one time merit payment) that documents wprOllram the emplovee Is behlll paid from.

11061 $ 935.53 - 243.24 Average of the two most recent pay allocations

denote that employee II 11061 only worked 74%of his time under the CEAP nrollram.Total $ 2.178.80 $ 625.07

PAGE 21 OF 23





OF


Community Services Agency of South Texas Monitoring ReportATTACHMENT D

Case # Issue Ouestloned Disallowed CommentsR3561 Replaced "new" Central HVAC - $ 3,600.00 Assessmentwas not filled out completely

Svstem did state that the unit was "new"R3561 Lack of complete assessments $ 50.00 · JustifY assessment chargeif the assessme

are not comnlete.84990 None · · N/AVI478 Replaceda water heaterthat did not · $ 348.15 Water heater replacement assessment st

rank "poor" but the item did not rank (.I) in threnlacementtool.

RI728 Replaced a Central HVAC system - $4,080.00 Assessmentfor Central HVAC did notwithout capturing existing contain data to justlfY repla¢ementdata/efficiencY

02858 Lack of complete assessment - $ 2,950.00 Assessmentfor CentralHVAC did not·contaln data tojustify renlacementB0530 Lack of complete assessment · $ 4,485.00 ASsessment for Central HVAC did·not·

contain data to lustify replacement.V0120 Lack of assessment · $ 4 345.00 No assessments in file provided.05587 Lack of complete assessment - $ 4,000.00 Assessmentfor Central HvAc did not

.contain data to iustifv renlacementD5587 Lack of Assessment · · Did not assess refrigeratorR7817 Replaced a CentralHVAC system · $ 4,000.00 Replaceda system that was not consumin

that was documented as "not any energyworking"

R7817 Lack of Assessment · · Old not assess refrigeratorC2802 Lackof complete assessment - $ 4,377.00 'Replaced a Central HVAX system that w

documented as "making a rattling sound"

C2802 Lack of Assessment · - Did not assess Water heater

A4469 Replaced a Central HVAC system · $ 4,255.00 Replaced a system that was assessed asthat was documented In "good" energy efficient.condition

07688 Replaced three(3) window units that · $ 1,359.96 Unit ranked 11 %, 15% and 3%. Minimumdid not rank renlacementnercentage·ls25%

07688 Replaced Water Heaterthat did not · $ 329.98 Waterheater replacedwhen unit ranked arank :Docuinentatlonnoted of rust on unit.

04692 Replaced Water Heater that did not · $ 329.98 Water heater replaced when unit rankecl arank Documentatlonnoted appearaJiceof heat

picture.05768 Replaceda Central HVAC system $ 5,000.00 · bid not providejustification on how the nsvstem would be more efficient.

H6829 R:eplaced a Central HVAC system - $4,290.00 Assessmentfor Central HVAC did notcontain data to justlfy replacement

L8825 Replaced a Central HVAC system · $ 4,345.00 Assessmentfor Central HVAC did not.contain data to justify replacement

PAGE 22 OF 23





OF


Texas Department of Housing and Community Affairs representatives, Rosy L. Falcon, andGiovanni Giunca palticipated in an exit conference with David Ojeda, Executive Director (via

telephone), Isabel Benavidez, Chief Financial Officer, Johnny Rosas, WeatherizationCoordinator, and Manuel Garcia, Director of Community Services.

Signature: ~ , ; : J ~ ~ ~ ~ ~ ~ ~ ~ ~ _

Signature: - - k : = ~ ~ ~ ~ ~ ~ - - - - : : : c - ; ; ; - - - - - en oza, TDHCA Program Officer

Signature: - - J < ! ~ < l . C : ! < ! l . , " " = j S ; ~ ~ , ¥ > - - = - - - - - : c - : : : : - - : - - - Program Officer

Signature: - . J t ~ f b . ~ ~ r 4 J ¢ : : : : : : : : : : : : : : : " " _ - . " . . . , . c - - - - DHCA Program Officer

PAGE 23 OF 23

-!J1I'OIOOLODate

Date

Date



T E X A S D E PA RT M E N T OF H O U S I N G AND C O M M U N I T Y A F FA I R S

www.,dhca.state,tx.mRlckPenyGOYnRNOR

Michael GeiberExeCUTIVE DIRECToR

June 28, 2010

Ms. Pauletta HinesExecutive DirectorCommunity Services, Inc.P.O, Box612

Corsicana, TX 75151-0612

Re: DOE Weatherization Assistance Program Contract #56090000458LlHEAP Weatherization Assistance Program Contract #81 090000491ARRA Weatherization Assistance Pl'Ogram Contract #16090000660ARRA Weatherization Assistance Program Contract #16090000756ARRA Weatherization Assistance Program Contract #16090000757ARRA Weatherization Assistance Program Contract #16090000758ARRA Weatherization Assistance Program Contract #16090000759ARRA Weatherization Assistance Program Contract #16090000779ARRA Weatherization Assistance Program Contract #16090000781

Dear Ms, Hines:

BOARD MEMBBR

C. Kent Conine, CIJGloria Ray, Vlt:e ChLeslie Bingham Escareno

Tom H. G aLowell A, K

Juan S. Mufioz, Ph.D

Enclosed is a report that details the monitoring review of your Weatherization Assistance Programcontracts with the Texas Department of Housing and Community Affairs. This infonnation is provided to

ensure that compliance with the contract(s) is maintained and that services to the poor, elderly, anddisabled are offered in the most expeditious and economical manner.

The Department has identified olle (1) fillding and three (3) recommelldatiolls for the WeatherizationAssistance Program. Please submit a response to this report to this office within thirty (30) days of thedate o f this letter.

If we can be of any assistance, please contact Jason A. Seale, Program Officer, at (512) 463-0172. Theassistance provided to the Program Officer by Community Services, Inc. is greatly appreciated.

Sincerely,

'6JD-Sharon GambleManagerEnergy Assistance Section

221 EAST l i T " • P. O. Box 13941 • AUSTIN, TaXAS 78711-3941 • (800) 525·0657 • (512) 475·3800

() I'ri""d 011 myrftd JII}a



PY09 WAP MONITORING REPORTOF

COMMUNITY SERVICES, INC.







Section VI. Audit

Section VII. Personnel Policies and Procedures

Section VIII. Performance Review/Onsite Inspections


Section X. Client File/Multifamily Review


1



Dates of Review:



May 10,2010 - May 14,2010

Focus of Review

CONTRACT NAME CONTRACT CONTRACT CONTRACT DATESNUMBER AMOUNT

DOE 56090000458 $1,019,169.00 4/1/2009 to 3/31/2010

LIHEAP 81090000491 $1,283,986.00 4/1/2009 to 3/31/2010

ARRA 16090000660 $4,889,348.00 9/1/2009 to 8/31/2011

ARRA - City of Denton 16090000756 $374,097.00 / 9/1/2009 to 8/31/2011

ARRA - City of Lewisville 16090000757 $147,053.00 9/1/2009 to 8/31/2011

ARRA - City of Plano 16090000758 $301,794.00 9/1/2009 to 8/31/2011

ARRA - City of Tyler 16090000759 $434,519.00 9/1/2009 to 8/31/2011

ARRA-GEUS 16090000779 $309,461.00 9/1/2009 to 8/31/2011

ARRA - Life Rebuilders 16090000781 $559,461.00 9/1/2009 to 8/31/2011

On-site review of Community Services, Inc. (CSI) implementation of the Department of Energy,Low Income Home Energy Assistance Program and American Recovery and Reinvestment Actof2009 Weatherization Assistance Program (WAP). Specific areas of review included FinancialReporting, Contract Agreements, Procurement, Personnel and the Management of theDepartment of Energy, Low Income Home Energy Assistance Program and American Recoveryand Reinvestment Act of2009 contracts.

2





Program Evaluation

The evaluation of the ptogram consisted of: Interviews with the CSI personnel, analysis of the

fiscal system, review of progrannnatic records, on-site inspections, client file reviews andinventory review.

Th e following was noted during the review:

• Low Expenditures for ARRA Contracts• High Administrative Expenditure for DOE and ARRA Contracts• High Health and Safety Expenditure for ARRA Contracts• High Cost Per Unit (CPU) for ARRA Contracts


EXPENDITURES AS OF MARCH (DOE/LIHEAP) AND APIlIL ( AR RA ) 2 01 0

CONTRACT YEAR-TO-DATE % OF ORIGINAL # UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESS

AMOUNT

DOE $522,191.00 52.01% 111 9

LIHEAP $683,788.00 53.26% 187 38

ARRA $888,771.00 18.18% 105 186

ARRA $22,137.00 5.92% 6 6(Denton)

ARRA $4,913.00 3.34% I I

(Lewisville)

ARRA (Plano) $11,220.00 3.72% 3 2

ARRA (Tyler) $53,528.00 12.32% 11 I

ARRA(GEUS) $8,829.00 3.53% I 2

ARRA(Life $1,097.00 0.22% 0 0Rebilders)

3





Recommended Improvement #1 Review of the March 2010 expenditure repOlt for the DOEcontract and April 2010' expenditure report for the DOE ARRA contracts revealedAdministrative expenditures were above the maximum allowable of 5%. Current Administrativeexpenditures for the DOE contract are 6.80%. Current Administrative expenditures for theARRA - City of Lewisville contract are 58.79%, ARRA - City of Plano contract are 8.75% andARRA - GEUS contract are 17.87%. The Depaltment reminds CSI that Administrativeexpenditures must be at or below the contract maximum by the contract closeout or be subject todisallowed cost.

Recommended Improvement #2 Review of the March 2010 expenditure reports for DOEARRA contracts #16090000759 and #16090000660 revealed Health and Safety expenditureswere above the maximum allowable of 20%. Current Health and Safety expenditures for thereferenced contracts are 21.92% and 21.23% respectively. The Department reminds CSI thatHealth and Safety expenditures must be at or below the contract maximum by the contractcloseout or be subject to disallowed cost.

Recommended Improvement #3 Review of the March 20 I0 expenditure report for the DOEARRA contract #16090000660 revealed cost-per-unit expenditures above the maximumallowable of $6,500.00. Current cost-per-unit expenditures for the referenced DOE ARRAcontract are $7,348.77. The Department reminds CSI that cost-per-unit expenditures must be ator below the contract maximum by the contract closeout or be subj ect to disallowed cost.Additionally, any unit that will exceed the maximum amount allowed by the DOE ARRAcontract must be submitted to the Department for approval.

Finding #1

ActionRequiJoed

As of the April 2010 monthly expenditure repOlts, CSI had expended

18.18% of DOE ARRA contract #16090000660, 5.92% of DOE ARRAcontract #16090000756, 3.34% of DOE ARRA contract #16090000757,3.72% of contract #16090000758, 12.32% of contract #16090000759,3.53% of contract #16090000779 and 0.22% of contract #16090000781.The DOE ARRA Contract requires the development and implementationof equitable W AP services throughout the entire service area.

The Depattment requires CSI to submit a detailed plan of action toincrease production and adherence to the DOE Production Schedule in theresponse to this repolt. Failme to submit a plan to the Department may

result in suspensionof

DOE ARRA contracts. Reference: ARRAContract Section 4

4





Program Officer Jason A. Seale conducted an exit interview with CSI staff members PaulettaHines, Tim Boyd and Steve TlJn·y.

Signa tu re - - - - ; J - l ; i\ 6 : - - -Jason A. SealeEnergy Assistance Program Officer

5

Date





ATTACHMENT A

Units Reviewed

10 units reviewed

Comments

2 LIHEAP, 2 ARRA, 3 ARRAILIHEAP, 3 DOE/LIHEAP

Client Return(s) To Address

09-H-735 No returns

09-D-396 No returns

09-C-435 No returns

09-C-434 No returns

09-C-430 Return to replace fascia board/soffit behind rearliving addition to protect insulation

09-C-43'7 No returns

09-H-727 No returns09-I-I-736 No returns

09-I-I-740 No returns

09-I-I-745 No returns

Action Required: Return and address. Upon completion, verification of returns must besubmitted to the Department within thitty (30) days of this report.

6



T E X A S DEPARTMENT OF H O U S I N G AND C O M M U N I T Y AFFAIRS

www.tdhca.state.tx.U$Rick PerryGOVHnNOR

Mkhael GerberExECUTIVE DIRRCfOR

June 28, 2010

Mr. Mark BethuneExecutive DirectorConcho Valley Community Action Agency36 West Beauregard Suite B-IOOSan Angelo, Texas 76902

BOARD MEMDBC. Kent Conine, ChaGloria Ray, Vice Ch(l

Leslie Bingham EscarefioTom H. Gan

Lowel l A. KeJgJ U l l b S. Muf ioz, Ph.D

Re: Departmentof

Energy Weatherization Assistance Program Contract #56090000459Department of Energy ARRA Weatherization Assistance Program Contract #16090000783Department of Energy ARRA Weatherization Assistance Program Contract #16090000657Department of Energy ARRA Weatherization Assistance Program Contract #16090000760LIHEAP Weatherization Assistance Program Contract #81090000492

Dear Mr. Bethune:

Enclosed is a report that details the monitoring review of Concho Valley Community ActionAgency's (Concho) Weatherization Assistance Program contracts with the TexasDepartment of

Housing and Community Affairs (The Department), This information is provided to enSljre thatcompliance with the contracts is maintained and that services to the poor, elderly, and disabled areoffered in the most expeditious and economical manner.

The monitoring report includes six (6) recommended improvements and eight (8) findings. Pleasesubmit a response to this office within thirty (30) days of the date of this letter.

I fwe can be of any assistance, please feel free to contact Rosy L, Falcon, Program Officer, at(512) 936-7810. The assistance provided to the Program Officer by the agency is greatlyappreciate.d.

Sincerely,

' t t c ) ~Sharon GambleManagerEnergy Assistance Section

221 EAST 11 TH • P. O. Box 13941 • AUSTIN, TBXAS 78711-3941 • (800) 525-0657 • (512) 475-3800




SecHon I. Financial Review





Section VI. Audit


Section VIII. Performance Review and Onsite Inspections


SectionX.

Client File Review Work Sheet and Multi-FamilyReview





Dates of Review:

2009 WEATHERIZATION MONITORING REPORTOF

CONCHO VALLEY COMMUNITY ACTION AGENCY

April 26-29, 2010

Focus O F R E V I E W

CONTRACT NAME CONTRACT *CONTRACT CONTRACT DATESNUMBER AMOUNT

DOE 56090000459 $382,013.00 4/1/2009 to 3/31/2010

LIHEAP 81090000492 $464,986.00 4/1/2009 to 3/31/2010

DOEARRA 16090000783 $500,090. 00 9/1/2009 - 8/31/2011

DOEARRA 16090000657 $1,810,127.00 9/1/2009 - 8/31/2011

DOEARRA 16090000760 $421,717.00 9/1/2009 - 8/31/2011

'" Latest conhact amendments

On-site review of the Concho Valley Community Action Agency, (Concho) implementation ofthe Department of Energy's and Low Income Home Energy Assistance Program'sWeatherization Assistance Program (WAP). Specific areas of review included FinancialReporting, Contract Agreements, Procurement, Personnel, and the Management of theDepartment of Energy and Low Income Home Energy Assistance Program contracts.

P R O G R A M E VA L U AT I O N

The evaluation of the program consisted of: interviews with the Concho personnel, analysis ofthe fiscal system, review of programmatic records, on-site inspections, client interviews, andinventory review.

The following was noted during the review:,

• DOE ARRA and LIHEAP Administrative expenditures are above the maximum

allowed.

• DOE ARRA Health and Safety expenditures are above the maximum allowed.

• Cost per unit for LIHEAP is above the maximum allowed.

PA G E 2 OF 15



2009 WEATHERIZATION MONITORING R E P O RT


• Current program expenditures are insufficient to expend all contract funds.

• Lack of sufficient support documentation for program expenditures.

• Lack of support documentation for expenditures in program

• DOE PY 08 funds are still outstanding.

• Inadequate travel and timesheet records.

• Inadequate mileage logs and vehicle and equipment maintenance and inventory

records.

• Procurement contracts missing Reporting and Patent Rights contract clause.

• Lack of weatherization services and outreach efforts in Schleicher, Concho, Sutton,

Irion, and Coke Counties.

• Inadequate Lead Safe Work Practices and RRP Final Rule records.

• Inadequacies in measures installed and record keeping.

• Inadequate support documentation for denied files.

Section I . Financial Review

E X P E N D I T U R E S AS O F M A R C H 2010

CONTRACT .YEAR-TO-DATE % OF ORIGINAL # UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESS

AMOUNT*

DOE $251,140.14 65.74% 29 8

DOEARRA $87,289.86 17.46% 6 19

LIHEAP $182,205.55 39.19% 29 8DOEARRA $227,85055 12.59% 21 68

DOEARRA $72,160.28 17.11% 5 17

• Al the I.me ofmomlo,',ng

PA G E 3 O F 15



2009 W E ATH E RI Z AT I O N M O N I TOR I N G REPORT

OF


Recommended Improvement #1: As of March 2010 Concho's Administrative ratio is at8.19% for DOEARRA #16090000657, DOE ARRA # 16090000459 is at 6.62% and LIHEAP isat 14.10% well above the maximum allowed for each of these grants. Concho is reminded thatthe Administrative ratio for DOE ARRA must be at or below 5% and the LIHEAPAdministrative ration must be at or below 7.22% by the end of the contract term. Any costabove the maximum allowed ratio is subject to disallowed costs. Reference: DOE, LIHEAP,and DOE ARRA Contracts Attachment A.

Recommended Improvement #2: As of March 2010 Concho's Health and Safetyexpenditures are at 28.43% for DOE ARRA #16090000657, 30.39% for DOE ARRA#16090000760, and at 28.06% for DOE ARRA #16090000783 well above the allowablemaximum ratio for each of these grants. Concho is reminded that the Health and Safety ratio forall DOE ARRA grants must be at 01' below 20% for each of their contracts by the end of thecontract term. Any expenditure above the allowable maximum ratio will be subject to

disallowed costs. Reference: Texas Administrative Code §5.528

Recommended Improvement #3: As of March 2010 Concho's cost per unit was at $4,563.31well above the maximum allowed per dwelling. Concho is reminded that the cost per unit mustbe at or below $4,000.00 by the end of the contract term. Any expenditure above the allowedmaximum will be subject to disallowed costs. Reference: Texas Administrative Code §5.603.

Finding #1:

ActionRequired:

Concho's current program expenditures are at 7.67% for DOE ARRA#16090000657, at 6.74% for DOE ARRA #16090000760, at 7.42% for DOEARRA #16090000783; at 65.74% for DOE and 39.19% for LIHEAPwhile29.16% of their DOE ARRA and 100% of their DOE and LIHEAP contract has

expired. Reference: OMB A-BO, Texas Administrative Code §5.141.

Concho must submit a plan of action to the Department detailing how they willreach their production goals for ARRA as well as how they will expend all DOEand LIHEAP funds for Program Year 2010. In addition Concho must begin to

have their assessors perform assessments individually. The Agency is remindedthat charges to Program Support must be tied directly to a home and if theassessors are not performing assessments they cannot charge their time to

Program Support. In addition, salary hours that are tied to a home and charged toProgram Support have a negative effect on the amount of funds that can actuallybe used in the client's home for energy improvements. If four (4) people areworking on assessing the same home the funds left for use in the home diminishessignificantly. The plan of action must be submitted as part of the response to thisreport.

PAGE 4 OF 15



2 0 0 9 WEATHERIZATION MONITORING REPORT

C O NC H O VA LL EV COMMUNITY ACTION AGENCY

Recommended Improvement tl4: A review of Concho's program expenditures revealed alack of support documentation within the files. Although further research showed allexpenditures were allowable, Concho must attach additional support documentation for eachexpenditure as it pertains to the program and expenditure. All procurement expenditures musthave the quotes obtained attached so as to show compliance with procurement regulations, allmileage reimbursements must have completed and detailed mileage logs, and all expendituresupport documentation must clearly denote fund and category charges. Reference: OMBCircular A-110, Texas Administrative Code §5.141.

Finding tl2:

ActionRequired:

A review of Concho's closeout documentation revealed the lack of documentationfor the reimbursement of Program Year 2008 year end DOE funds to theDepartment. This lack of documentation resulted in $195,95 of disallowed costs.Reference: DOE and LIHEAP Contracts Section 11.

Concho must reimburse the Department$195.95, please indicate DOE Contract#567069 on the check. Concho is reminded that any funds owed to the

Department at the end of the contract term is due within sixty (60) days from theend of the program year.

Section II. Travel an d Timesheets

Recommended Improvement tiS: A review of Concho's travel and timesheets revealed aneed for improvement in their record keeping. In order to substantiate the Agency's salaryexpenditures the Department strongly recommends that Concho administration add staff titles tothe timesheets. In order to further transparency in the use of government funds Concho must

attach a travel voucher to each travel expenditure that is to be fully completed prior to thedisbursement of any funds, an agenda andlor description of the training must be attached, and acost breakdown must be clearly shown on each travel expenditure. Reference: A-122Attachment B, ARRA Contract Section 35, DOE an d LIHEAP Contract Section 29.

Section III. Property Management

Finding #3: A review of Concho's vehicle and equipment records revealed inadequacies intheir mileage log, a lack of maintenance logs and equipment inventory. The

Agency's mileage log was missing specifics on location and purpose for visit; theequipment inventory list is insufficient and there is no maintenance log orschedule in place to assure the proper care and maintenance of all vehicles andequipment. Reference: OMB A·123, ARRA Contract Section 21, DOE andLIHEAP Contract Section 17,10 CF R 600.134 an d 232.

Action Concho must improve the Agency's mileage log to have each individual trip listed

PAGE 5 OF 15



Required:

2 00 9 WEATHERIZATION M O NI TO R IN G R E P O RT

OFCONCHO VALLEY COMMUNITY ACTION AGENCY

per entry, a specific location and purpose must be clearly identified per trip, and astaff signature must accompany each trip. Concho must implement a maintenancelog and schedule for each vehicle that is paid for by weatherization funds in orderto ensure proper care is completed. Each mileage and maintenance log mustclearly tie back to each vehicle. An inventory of all tools and equipment must be

kept in order to track all items purchased by weatherization funds.

Section IV. Procurement

Note: The Department would like to remind Concho that i f they decide to allow the use of

Agency diagnostic equipment they must first establish policies and procedures detailing thespecifics' of the agreement between the two parties and how the Agency will ensure theequipment purchased through the use of government funds will be kept secure and in properworking order.,

Finding #4:

ActionRequired:

Finding#5:

ActionRequired:

A review of the Agency's procurement contracts revealed the lack of inclusion of

the Reporting and Patent Rights clause from all contracts. Reference: OMBCircular A·110 Appendix A.

Concho must amend their contracts to reflect the inclusion of the Reporting anPatent Rights clause in each of the Weatherization Assistance Program currentand future contracts.

Section V. Performance

A review of Concho's March 2010 Expenditure and Programmatic Reportsrevealed a lack of weatherization service and outreach activities in Schleicher,Concho, Sutton, Irion, and Coke counties. Reference: ARRA Contract Section4, Texas Administrative Code §5.503.

Concho must ensure that they serve their service area in an equitable basis. Inaddition, a well documented record must be kept for all outreach related activitiesthroughout the service area. Special attention must be paid to those areas that

have been historically underserved. Concho must submitto

the Departmentdocumentation of where the funds for the above mentioned counties wereallocated and how they calculated that for Program Year 2009 and how they planto serve the counties with the ARRA funds as part of the Agency's response tothis report.

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2009 WEATHERIZATION MONITORING REPORTCONCHO VALLEY COMMUNITY ACTION AGENCY

Recommended Improvement #6: Concho Valley must begin and maintain a file with alldoCumentation as it pertains to compliance with the Lead Renovation, Remodeling, and PaintingFinal Rule from the Environmental Protection Agency (EPA). In addition, the Agency mustmaintain a record of their Firm Certification, as well as celiification for all of their LeadRenovators and that of their contractors. Concho must also ensure that their Lead CertifiedRenovator(s) keep up with their duties as required by EPA's Final Rule. This procedure must allbe in place prior to beginning and performing any work on any homes that were built pre-1978.Reference: Weatherization Program Notice 09-6, EPA Final Rule, 10 Texas AdministrativeCode §5.524.

Finding#6: The Department conducted sixteen (16) unit inspections out of which Conchomust return to fourteen (14) units. All of the noted issues and reasons for thereturn are noted in Attachment A, found at the end of this report.

There was a lack of evidence in the use of all twenty (24) tubes of caulk in two (2)of the units. In foul' (4) of the units inspected there were "Other Heater Repair"

cost associated with installation of water heater vent cap on top of roof, pel' sub·agency representative. However, the first floor vent merges into second floor ventsultin in onl vent cap. This has revealed $800.00 in questionable costs

Reference: (Please refer toexas Administrative Code §5.529,ttachment A for returns on un ts),

Texas Administrative Code §5.528.

ActionRequired:

Concho must return to address all deficiencies in the 14 units referenced inAttachment A of this report. A detailed list of measures done must be includedwith their response to this report.

Concho must account for all measures installed more accurately. If a situationarises in which an abnormal amount of material may need to be used this shouldbe noted somewhere on the file, preferably on the B WR. Any future issues withthe reconciliation of the BWR and the matel'ials installed may result in disallowedcosts. Concho must subniit to the Department all the necessary supportdocumentation as proofthat no first floor units in this complex have a charge for avent cap. For those units that had a charge at the time of monitoring supportdocumentation must be submitted to reflect the correction in charge and that theWeatherization Assistance funds were appropriately charged. Concho mustinclude this with their response to this report.

Section VI. Client File Review

Finding #7: A review of Concho's client files revealed three (3) out of the nine (9) lacked thenecessary thirty (30) day proof of income for the residents. In seven (7) of thenine (9) files the Building Weatherization Report (BWR) did not contain an

PAGE 7 OF 15



ActionRequired:

Finding #8:

ActionRequired:

2 009 W E AT HE R I ZAT I ON M O N ITO R IN G R E P O RT

OF

CONCHO VAL LE Y C OM MU NI T Y A C TI O N AGENCY

accurate description or quantity of;the materials installed. The BWR stated airinfiltration measures were performed but did not separate what each airinfiltration measure was; instead it only indicated the total amount spent. In seven(7) of the nine (9) files the inaccurate target reduction calculation was used. In allnine (9) files the outdated "Protect your family from lead in your home" pamphletwas used. Reference: Texas Administrative Code §5.20, TexasAdministrative Code §5.530, DOE an d UREAP Contracts Section 10, ARRAContract Section 13, 10 C.F.R. §440.24.

Concho must submit proof of income for client files 09ME013, 09WC024, and09WC026 along with a copy of the application in order to substantiate servicesrendered. Concho must ensure that all files contain the required proof of incomeprior to providing any services. Concho must ensure that all BWRs mirror each·audit and that all measures are accounted for individually. Concho staff mustattend the Training Academy Management Course in order to obtain help incompleting all Departtpent forms accurately. Effective immediately Concho must

utilize the Department's updated forms and information for all their files.

Section VII. Denied Files

A review of Concho's denied files revealed a lack of support documentation forthe denial. Of the eight (8) client files reviewed three (3) denials due to incomedid not contain the income verification and proof of income; one (1) denial wasdue to needing more than what the Weatherization Assistance Program couldprovide and one (1) was deemed already energy efficient, however neither

contained any assessments nor documentation that an actual assessment tookplace. Reference: 10 Texas Administrative Code §6.8 an d 6.108.

Concho must maintain detailed records of the reason for the denial of a client aswell as all supporting documentation needed in order to not have the Agency'sdecision overturned should it be appealed to the Department. If a client must bedenied due. to income the income verification calculations along with all thesubmitted proof of income must be kept in the file. If a client must be deniedbecause the needs of the house are beyond the scope of weatherization then fullassessments, notes, and pictures must accompany this file as supportdocumentation. By no means may a client be denied because the house isdetermined to already be energy efficient based on the year of construction. Afull assessment and High Energy Burden and High Energy Consumptioncalculations must accompany these types of files. It is very important thatConcho have the required support documentation needed should an appeal befiled. Every file, be it a denial or not, must speak for itself, as that is the only wayto assure that government funds are without a doubt used efficiently.

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2 0 0 9 W E AT HE R I ZAT I O N M O N ITO R IN G REPORT

C O NC H O VAL LE Y COMMUNITY ACTION AGENCY

Texas Department of Housing and Community Affairs representatives, Rosy L. Falcon andGiovanni Giunca participated in an exit conference with Mark Bethune, Executive Director,Janet Appleton, WAP Coordinator, and Lyla Blue, Fiscal Officer"

Signature:Date

Signature: .#JI 9 ' ~Giovanni GlUnca, TDHCA Program Officer

PAGE 9 OF 15

Date



2009 W E AT H ER I Z ATI O N M O N I TO R IN G R E P O RT

OFCONCHO VALLEY COMMUNITY ACTION AGENCY.

ATTACHMENT A

Units Fund Source Return CommentsInspected

Return and address the following:09ME014 DOE/LIHEAP Yes 1) Secure loose wood plugs at exterior wall. CFR

440.16, TAC 5.5292) Add partial insulation (where missing) at exteriorwall. CFR 440.16, TAC 5.5293) Co reading at stove Front Right burner, 54ppm.Repair/Replace under Health and Safety measures, TAC5.5284) Gaps/crack at wall, can see through to the outside. Fillin gaps at wall joints where wall addition occurred in thepast. CFR 440.16, TAC 5.529

5) Water heater TPRV discharge pipe not draining in anapproved manner. Correct TPRV discharge pipe tocomply with IRC - P2803.6.1 requirements.6) Install gas vent at water heater to comply with IRC -G2426.4, G2426.6 requirements.7) Install insulation shield at HVAC water heater vent atattic area to be in compliance with IRC-G2425.4

Return and address the following:09ME015 DOE/LIHEAP Yes 1) Add attic insulation to required R-value. CFR 440,16,

TAC 5.5292) Add partial insulation (where missing) at exteriorwall, CFR 440.16, TAC 5.529

09MC024 DOE/LIHEAP No (resident not home, inspected exterior only)

Return and address the following:09MC026 DOE/LIHEAP Yes 1) Install drain pan at the water heater to conform to IRC

- P2801.5, P2801.5.1, and P2801.5...2 requirements.2)Water heater TPRV discharge pipe not draining in anapproved manner. Correct TPRV discharge pipe tocomply with IRC - P2803.6.1 requirements.

Return and address the following:09MC029 DOE/LIHEAP Yes 1)Repair water leak at water heater hot water line

connection. CFR440,16, TAC 5.5292) Water heater TPRV discharge pipe not draining in anapproved manner. Correct TPRV discharge pipe tocomply with IRC - P2803.6.1 requirements.

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2 0 0 9 W E AT HE R I ZAT I ON M O N ITO R IN G R E P O RT

C O NC H O VA LL E Y COMMUNITY ACTION AGENCY

3) Install gas vent at water heater to comply with IRCG2426.4, G2426.6 requirements.4) Heater/Air Handler unit, flexible gas line throughappliance housing,Reinstall appliance fuel connector to be in compliancewith IRC-C2421.1.2

5) Install electric disconnect at newly installedcondensing unit to conform to IRC-E4001.5r e q u i ~ e m e n t s,

09MC034

. .

DOE

ARRA

ARRA

No (resident not home, inspected exterior only)

Return and address the following:Yes 1) Reinstall combustion air ducts at HVAC mechanical

closet to comply with IRC-G2i107, 11,1 and IRC-2407, 152) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 24

3) Heater/Air Handler unit, flexible gas line throughappliance housing.Reinstall appliance fuel connector to be in compliancewith IRC-C2421.1.24) HV AC unit, install mastic at unit to be in compliancewith IRC- MI601.3,15) Install insulation shield at HV AC vent and waterheater vent at attic area to be in compliance with IRCG2425.46) Bathroom vent not connected to vent duct at atticarea, Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attic insulation to required R-Value, CFR 440.16,TAC 5.529 (unit is located on the first floor, atticinsulation price is allocated to first and second floor)

Return and address the following:Yes 1) Reinstall combustion air ducts at HVAC mechanical

closet to comply with IRC-G2407.11,1 and IRC-2407.152) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 243) Heater/Air Handler unit, flexible gas line throughappliance housing.Reinstall appliance fuel connector to be in compliancewith IRC-C2421.1.24) HVAC unit, install mastic at unit to be in compliancewith IRC- M160J.3.15) Install insulation shield at HVAC vent and waterheater vent at attic area to be in compliance with IRC-

PAGE 11 OF 15



2 0 0 9 WEATHERIZATION MONITORING REPORTOF


G242S.46) Bathroom vent not connected to vent duct at atticarea. Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attic insulation to required R-Value. CF R 440.16,

TAC5.529

Return and address the following:- ARRA Yes I) Reinstall combustion air ducts at HV AC mechanicalcloset to comply with IRC-G2407.11.1 and IRC-2407.1S2) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 243) Heater/Air Handler unit, flexible gas line throughappliance housing.Reinstall appliance fuel connector to be in compliancewith IRC-C242 I. 1.2

4) HVAC unit, install mastic at unit to be in compliancewith IRC- MI601.3.15) Install insulation shield at HV AC vent and waterheater vent at attic area to be in compliance with IRC-02425.46) Bathroom vent not connected to vent duct at atticarea. Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attic insulation to required R- Value. CFR 440.16,TAC 5.5298) Attic hatch not boxed. CFR 440.16

Return and address the following:

.. ARRA Yes I) Reinstall combustion air ducts at HVAC mechanicalcloset to comply with IRC-G2407.11.1 and IRC-2407.IS2) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 243) Heater/Air Handler unit, flexible gas line throughappliance housing.Reinstall appliance fuel connector to be in compliancewith IRC-C242 1. 1.24) HVAC unit, install mastic at unit to be in compliancewith IRC- MI601.3.15) Install insulation shield at HVAC vent and waterheater vent at attic area to be in compliance with IRC-G2425.46) Bathroom vent not connected to vent duct at atticarea. Install/Connect bathroom vent to be in compliancewith IRC-R303.3

PA GE 12 OF 15



2009 WE ATH ERIZATION MONITORING REPORTCONCHO VALLEY C OM MU NI TY A C TI O N A GE NC Y

7) Add attic insulation to required R-Value. CFR 440.16,TAC 5.529

. . Return and address the following:ARRA Yes 1) Reinstall combustion ail' ducts at HVAC mechanical

closet to comply with IRC-02407.l1.1 and IRC-2407.l5

2) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 243) Heater/Air Handler unit, flexible gas line throughappliance housing.Reinstall appliance fuel connector to be in compliancewith IRC-C242 I. 1.24) HV AC unit, install mastic at unit to be in compliancewith IRe- M1601.3.l5) Install insulation shield at HVAC vent and waterheater vent at attic area to be in compliance with IRC-02425.4

6) Bathroom vent not connected to vent duct at atticarea. Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attic insulation to required R-Value. CFR 440.16,TAC 5.529

- Return and address the following:ARRA Yes I) Reinstall combustion air ducts at HV AC mechanical

closet to comply with IRC-02407.1l.l and IRC-2407.152) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 24

3) Heater/Air Handler unit, flexible gas line throughappliance housing.Reinstall appliance fuel connector to be in compliancewith IRC-C242 I. 1.24) HV AC unit, install mastic at unit to be in compliancewith IRC- M1601.3.1

. 5) Install insulation shield at HVAC vent and waterheater vent a t attic area to be in compliance with IRC-02425.46) Bathroom vent not connected to vent duct at atticarea. Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attic insulation to required R- Value. CFR 440.16,TAC 5.529 (unit is located on the first floor, atticinsulation price is allocated to first and second floor)

~ Return and address the following:ARRA Yes I) Reinstall combustion air ducts at HVAC mechanical

PAGE 13 OF 15



2 0 0 9 W E AT H ER I ZAT IO N M O NI T OR I NG R E P ORT

OFCONCHO VALLEY COMMUNITY ACTION AGENCY

closet to comply with IRC-02407.11.1 and IRC-2407.152) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 243) Heater/Air Handler unit, flexible gas line throughappliance housing.

Reinstall appliance fuel connector to be in compliancewith IRC-C242 1.1 ,24) HVAC unit, install mastic at unit to be in compliancewith IRC- MI601.3.15) Install insulation shield at HVAC vent and waterheater vent at attic area to be in compliance with IRC-02425.46) Bathroom vent not connected to vent duct at atticarea. Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attie insulation to required R- Value, CFR 440,16,

TAC 5.529

- Return and address the following:ARRA Yes 1) Reinstall combustion air ducts at HVAC mechanical

closet to comply with IRC-02407.11.1 and IRC-2407.l52) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 243) Heater/Air Handler unit, flexible gas line throughappliance housing,Reinstall appliance fuel connector to be in compliancewith IRC-C2421.1.24) HVAC unit, install mastic at unit to be in compliancewith IRC- MI601.3.15) Install insulation shield at HVAC vent and waterheater vent at attic area to be in compliance with IRC-02425.46) Bathroom vent not connected to vent duct at atticarea. Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attic insulation to required R-Value, CFR 440.16,TAC 5.529 (unit is located on the first floor, atticinsulation price is allocated to first and second floor)

Return and address the following:ARRA Yes 1) Reinstall combustion air ducts at HVAC mechanical

~ -

closet to comply with IRC-02407.11.1 and IRC-2407.152) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 243) Heater/Air Handler unit, flexible gas line through

PAGE 14 OF 15



2009 WEATHERIZATION MONITORING REPORTCONCHO VALLEY COMMUNITY ACTION AGENCY

appliance housing,Reinstall appliance fuel connector to be in compliancewith IRC-C242 I . 1.24) HVAC unit, install mastic at unit to be in compliancewith IRC- M1601.3.15) Install insulation shieltl at HVAC vent and waterheater vent at attic area to be in compliance with IRC-G2425,46) Bathroom vent not connected to vent duct at atticarea, Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attic insulation to required R-Value. CFR 440.16,TAC 5.529

~ Return and address the following:ARRA Yes I) Reinstall combustion air ducts at HVAC mechanical

closet to comply with IRC-G2407.11.1 and IRC-2407.15

2) Install gas vent at HVAC unit to be in compliancewith IRC-Chapter 243) Heater/Air Handler unit, flexible gas line throughappliance housing.Reinstall appliance fuel connector to be in compliancewith IRC-C242I ,1.24) HVAC unit, install mastic at unit to be in compliancewith IRC· MI601.3.15) Install insulation shield at HVAC vent and waterheater vent at attic area to be in compliance with IRC-G2425,4

6) Bathroom vent not connected to vent duct at atticarea, Install/Connect bathroom vent to be in compliancewith IRC-R303.37) Add attic insulation to required R-Value. CFR 440.16,TAC 5,529 (unit is located on the first floor, atticinsulation price is allocated to first and second f l o o ~ )

PA G B 1 5 0 F 1 5



T E X A S D E PA RT M E N T OF H O U S I N G AN D C O M M U N I T Y A F FA I R S

Jvwru. ,dhen.state. tx, us

Rick Perry

GOVERNOR

Michael GetberExUCUTIVB DIRECTOR

Mr. Zachary ThompsonDallas County Health and Human Services2377 North Stemmons Freeway,2nd FloorDallas, Texas 75207-2710

June 7,.2010

Re: DOE Weatherization Assistance Program Contract # 56090000469LIHEAP Weatherization Assistance Program Contract #81 090000493DOE·ARRA Weatherization Assistance Program Contract #16090000661DOE·ARRA Weatherization Assistance Program Contract #16090000748DOE-ARRA Weatherization Assistance Program Contract #16090000754DOE·ARRA Weatherization Assistance 'Program Contract # 16090000761DOE·ARRA Weatherization Assistance Program Contract #16090000762DOE·ARRA Weatherization Assistance Program Contract # 16090000763DOE-ARRA Weatherization Assistance Program Contract #16090000764

Deal' Mr. Thompson:

BOARD MBM.B

C. Kent Cot llnc , ChGloria Ray, Vlel Ch

Leslie Bingham EscareTom H. Gao

Lowell At KJuan S. M\Jfloz, Ph.D

Enclosed is a report that details the monitoring and desk review of Dallas County Department of Healthand Human Services Weatherization Assistance Program contracts with the Texas Depa.tment of Housingand Community Affah's (The Department). This information is provided to ensure that compliance withthe contracts is maintained and that services to the poor, elderly, and disabled are offered in the mostexpeditious and economical manner,

The monitoring repolt includes three (3) findings, and two (2) I·ecommendations. Please submit aresponse to this report to this office within thilty (30) days ofthe date of this leller.

If we can be of any assistance, please feel free to contact Matt Embl'y, Program Officer at (512) 936998.8. The assistance provided to the Program Officers by the agency is greatly appreciated,

~ ~haron Gamble

Program ManagerEnergy Assistance Division

221 EAST 11 TH • P. O. Box 13941 • AUSTIN, TEXAS 78711-3941 • (800) 525·0657 • (512) 475·3800

o Prlllrttl,,, rltJtftd !npa



2 0 0 9 WEATHERIZATION MONITORING R E P O RT

D A LL A S C OU N TY HEALTH AND H U MA N S E RVI C E S

Directoryof

Monitoring Sections

Section I. Financial Reporting





Section VI. Audit



Section IX. AdministrationSection X. Multifamily


PAGE 2 OF 13



Dates of Review:

Focusof

Review

2009 WEATHERIZATION MONITORING REPORTDALLAS COUNTY HEALTH AND HUMAN SERVICES

March 1-5, 2010

CONTRACT NAME Contract Number Contract amount contract datesDOE 56090000469 $1,405,458.00 4/1/2009 to 3/31/2010LIHEAP 81090000493 $1,775,712.00 4/1/2009 to 3/31/2010DOE-ARRA 16090000661 $6,738,109.04 9/1/2009 to 8/31/2011DOE-ARRA 16090000748 $702,155.02 9/1/2009 to 8/31/2011DOE-ARRA 16090000754 $633,937.98 9/1/2009 to 8/31/2011DOE-ARRA 16090000761 $192,417.38 9/1/2009 to 8/31/2011DOE"ARRA 16090000762 $445,319.59 9/1/2009 to 8/31/2011DOE-ARRA 16090000763 $266,086.86 9/1/2009 to 8/31/2011

DOE-ARRA 16090000764 $180,695.10 9/1/2009 to 8/31/2011

On-site review of the Dallas County Department ofHealth and Human Services (DCHHS)implementation ofthe Department of Energy's and Low Income Home Energy Assistance Program'sWeatherization Assistance Program (WAP) and the Depaltment of Energy's American Recovery andReinvestment Act (ARRA) Weatherization Assistance Program. Specific areas of review includedFinancial Repolting, Contract Agreements, Procurement, Personnel, and the Management of theDeplUtment of Energy and Low Income Home Energy Assistance Program contracts.

Program Evaluation

The evaluation of the program consisted of: i n t e r v i e ~ swith the DCHHS personnel, analysis of the fiscal

system, review of programmatic records, on-site inspections, client interviews, and inventory review.

The following issues were noted during the review:

• Low Expenditures ARRA• Lead Safe Work Practices- Lead Safe Work measures and Lead Safe client information• Onsite inspections- Building Tightness Limits• Client File Review-Income Documentation• Performance Review-StaffTraining• On site inspections- Return items

PAGE 3 OF 13




Expenditures as of January 2010

CONTRACT Contract Number YEAR-TO-DATE % OF ORIGINAL # UNITS # UNlTS INNAME EXPENDITURES Contract amount COMPLETED PROGRESS

DOE 56090000469 $1,405,458.00 57.96% 205 4LIHEAP 81090000493 $ 1,775,712.00 29.87% 151 30DOE-ARRA 16090000661 $6,738,109,04 4.16% 39 lISDOE-ARRA 16090000748 $702,155.02 0.00% 0 0DOE-ARRA 16090000754 $663,937.98 2.05% 3 20DOE-ARRA 16090000761 $192,417.38 0.00% 0 0DOl:l-ARRA 16090000762 $445,319.59 0.77% I 1DOE-ARRA 16090000763 $266,086.86 5.39% 2 6DOE-ARRA 16090000764 $180,695.10 0.00% 0 0DOE-ARRA $9,188,720.97 0.18% 45 142

Total

Section 1- Financial Reporting

Finding #1:

Action Required:

. Finding #2:

Lead Safe Work Pl'acticesA review of monthly repOlts revealed that DCHHS had low expenditure levelsfor adequate expenditure of ARRA funds. The Program Officer noted thatDCHHS had qnits in progress. Refel 'ence: Texas Administrative Code (TAC);Title 10; Part I; Chapter I; Subchapter A; Rule § I . l9

The Depaltment requires DCHHS to develop a written plan of action detailinghow DCHHS will achieve adequate expenditure levels in order to execute ARRAweatherization activities within the contract time-frame.

Section 8 " Performance Review

Lead Safe WorkPl'acticesA. Onsite inspection of work in progress revealed that Lead Safe Work Practices(LSW) were not adequate. Whi le there was some attempt by the contractor tofollow LSW, the contractor had not fuIly implemented the requirements forLSW. The Department has informed DCHHS staff that beginning April 22, 2010th e Environmental Protection Agency (EPA) will begin enforcement actionregarding required Code of Federal Regulations (CFR); Title 40; Palt 745- LeadBased Paint Poisoning Prevention in Certain Residential Structures. Reference:Weatherization Program Notice (WPN) 09-6 and Environmental ProtectionAgency Final Rule.B. A review of client files revealed that 3 of 16 files reviewed did not contain 01'

contained incomplete Renovate Right; Important Lead Hazard Information forFamilies, Child Care Providers, an d Schools (Renovate Right) pamphlet client

PAGE 4 OF 13



ActIon Required:

Finding #3:

Action Required:


receipt forms. In the majority of multi-family units there was no Renovate Rightpamphlet client receipt fOlm. DCHHS staff indicated that the landlord for eachset of multi-family units had signed a Renovate Right pamphlet client receiptform, which was contained in the multi-family master file. Reference: WPN 09 -

6.

A. The Department requires DCHHS to provide a written plan of action detailinghow DCHHS will insure that all contractors are complying with all aspects ofboth the Weatherization Progl'am Notice (WPN) 09-6 and EnvironmentalProtection Agency Final Rule as part of the response to this report.B. The Department requires DCHHS to review documentation requirements forclient receipt of the Renovate Right pamphlet and to proVide the Departmentwritten documentation of this review with a Plan of Action on implementation ofdocumentation procedures fro client receipt of the Renovate Right pamphlet.

Building Tightness LimitsA review of client files revealed that the final Cubic Feet per Minute (CFM)measurement for client file 09DA2855-212 was 429 CFM. The BuildingTightness (BtL) Limit for the unit according to the calcnlation on the BlowerDoor Data Sheet was 660 CFM. Reference: Texas Administrative Code (TAC);Title 10; Palt I; Chapter 5; Palt Ei Rule § 5.530

The Depaltment requires DCHHS to return to client unit #09DA2885-212 andtake appropl'iate measures, such as mechanical ventilation, to raise the BTLabove the minimum BTL of 660 CFM. the Department requires DCHHS toprovide documentation of measures taken to address the BTL limits as part of theresponse to this report.

Recommended Improvement #1: Client Income Documentation.- A review of client files revealedheavy usage of the Declaration of Income Statement (DIS) at one apartment complex (client filebeginning with 09DA2915), two (2) instances of incomplete Social Security income information (client

files # 09DA2897·104 and 09DA2897-403), and one (1) instance of missing income documentation(client file # 09DA2793). The Department reminds DCHHS that complete income documentation isrequired in all client files and the DIS is only to be used in extenuating circumstances.

Recommended Improvement #2: Staff Training- The Department recommends that DCHHS staffmember Sahela Faheem attend a NEAT training conducted by DOE staff member Marc Turnis at thesoonest available date. The specification of training provided by Marc TUl'llis is intended to provide Ms.Faheem with technical training regarding library set-up, and work order and invoice production. Ms.Faheem is aware that this training will enhance her ability to track invoices and to produce repOlts. Withthe increase in production in the coming months it is vital that Ms. Faheem receive this training as soon aspossihle. Contractor Training- DCHHS W AP staff need to review contractor LSW practices and ensurethat LSW practices are being followed.

PAGE 5 OF 13



2009 WEATHERIZATION MONITORING REPORT

DALLAS COUNTY HEALTH AN D HUMAN SERVICES

Texas Depaltment of Housing and Community Affairs staff members Matt Embry and Glovani Giuncapalticipated in an exit interview with Zachary Thompson, Daniel Araiza, Saleha Faheem and DianneRuecker.

/

Signature:

dLf 1 Cut;r- " - 7 - 1 0

'f""'" Matt Embrv TDHCA Proll.ramOfficer Date:,/

Signature:

!dftt<a01~ e - r b - 7 - ( o

~ ,Giovanl Giunca, TDHCA Proi\ram Officel' Date:

PAGE 6 OF 13



AITACHMENT A

2009 WEATHERIZATION MONITORING R E P O RT

D AL L AS C O UN T Y HEALTH AND H UM A N S E RVI C E S

09DA2897

' -

09DA2897

09DA2897

09DA2897

09DA2897

09DA2897

09DA2897

09DA2897

LIfIEAP

LIHEAP

LIHEAP

LIHEAP

LIHEAP

LIHEAP

LIHEAP

LIHEAP

LIHEAP

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

- 2 of 3 windows not installed, $396.00.

No Issues.

No Issues.

No Issues.

No Issues.

No Issues.

No Issues.

No Issues.

No Issues.

PAGE 7 OF 13



2 0 0 9 W E ATH E R IZ AT IO N M O N I TO R I N G R E P O RT

DALLAS COUNTY HEALTH AND H U MA N S E RV I C ES

09DA2897

09DA2897

09DA2897

09DA2897

09DA2897

09DA2897

09DA2897

09DA2897

LIHEAP

LIHEAP

LIHEAP

LIHEAP

LIHEAP

LIHEAP

DOE/LIHEAP

LIHEAP

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No Issues.

No Issues.

No Issues.

No Issues.

No Issues.

No Issues.

No Issues.

No Issues.

. . . DOE/LIHEAP Yes No Issues... LIHEAP Yes No Issues.

09DA2897 DOE/LIHEAP Yes No Issues.

PAGE 8 OF 13



2009 W E ATH E R IZ AT IO N M O N I TOR I N G R E P O RT

D A LL AS C OU N TY HEALTH AND HUMAN SERVICES

09DA2897

09DA2897

09DA2897

09DA2897

09DA2919

09DA2919

09DA2919

09DA2919

09DA2919

09DA2919

,DOE/LIHEAP

DOEILIHEAP

DOE/LIHEAP

LlHEAP

DOE/LIHEAP

DOE

DOE

DOE

DOE·

DOE

DOE

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No Issues.

No Issues.

No Issues.

No Issues.

No Issues,

-No CFL installed.

-No CFL installed.

-No CFL installed,

-No CFL installed.

-No CFL installed.

-No CFL installed.

PAGE 9 OF 13



2 0 0 9 WEATHERIZATION MONITORING R E P O RT

DALLAS COUNTY HEALTH AND H UM AN S E RV I CE S

09DA2919

09DA2919

09DA2919

DOE

DOE

DOE

DOE

Yes

Yes

Yes

Yes

-No CFL installed.

-No CFL installed.

-No CFL installed.

-No CFL installed.

09DA2741 DOE No -Partially missing insulation at HVAC duct work. Returnand install insulation up to recommended R-value.- Range top burners co readings above the recommendedguidelines, Rear Left 36ppm, Front Left 33ppm, FrontRight40ppm, oven l76ppm.Return and replace/repair range underHealth and Safety.

09DA2729 DOE No -Secondary heat sources, two bathrooms, containing anunvented gas space heater of 8()00btu each, not equippedwith an oxygen-depletion sensing shut"off system.Not in compliance with Department of Energy,

Weatherization Program Notice 08-4, Effective Date:March 3, 2008.Return and correct deficiency to be in compliance withDepartment of Energy, Weatherization Progl'am Notice08.4. Effective Date: Mal'ch 3, 2008.- Range top burners co reading above the recommendedguidelines, Rear Left 28ppm, Front Left does not light.Return and replace/repair range under Health and Safety.-Mechanical closet, ceiling insulation falling through airventilation screen.Return and install barrier to prevent ceiling insulation fromfalling inside mechanical closet.

09DA2721 DOE No -Partially missing insulation at HVAC ductwork.Return and install missing insulation at ductwork.

PAGE 10 OF 13



2009 W E ATH E R IZ AT IO N M O N I TO R I N G REPORT

D A LL A S C O UN T Y HEALTH AND HUMAN SERVICES

09I;>A2839 ARRA Yes -Combination smoke/co detector. •

09DA3010 ARRA N/A -Weatherization work in progress at time of inspection.

-No LSW practices observed, work in progress at time ofinspection consisted of window replacement.

09DA2832 ARRA No -Mechanical closet, ceiling insulation falling through ail'ventilation screen.Return and install barrier to prevent ceiling insulation fromfalling inside mechanical closet.-Combustion vent at gas hot water heater not ventedthrough the roof.Return and install gas vent to be in compliance with IRC-2427.

- Range top burner co reading above the recommendedguidelines, Front Left 30ppm.Return and replace/repair range under Health and Safety.-Combination smoke/co detector. •

09DA2853 ARRA Yes -Combination smoke/co detector. •


09DA2803 ARRA Yes No Issues

09DA2789 ARRA No -Mechanical closet, ceiling insulation falling through ail'ventilation screen. Return and install barrier to preventceiling insulation from falling inside mechanical closet.

09DA2843ARRA

Yes-AiC

Tune-up, two charges for a total of$160.00. Onewindow unit Ale new/replaced no tune-up needed. Oneexisting window unit AlC tune-up performed.


PAGE 11 OF 13



. 2009 WEATHERIZATION MONITORING REPORT

DALLAS COUNTY HEALTH AND HUMAN SERVICES

09DA2860 ARRA N/A Weatherization work in progt'essat time of inspection,-No LSW practices observed,work In progress at time ofinspection consisted of window replacement.

09DA2740 DOE No -Mechanicalcloset, ceiling insulation falling throughairventilation screen.Returnand install barrierto pl'eventceiling insulationfromfalling inside mechanicalcloset.

09DA2846 ARRA Yes -BWR,stated Water Heater-Gas50 gal. 67 01' greater,replaced under Healthand Safety, Unit inspection'revealed a electric watel'heater. Questionable cost$1500.00

09DA2800 ARRA No - Range top burners co readingabove the recommendedguidelines, Front Right 34ppm.Returtl andreplace/repairrangeunder Healthand Safety.

09DA2815 ARRA Yes No issues

09DA287I ARRA Yes No Issues

09DA2793 ARRA Yes No Issues

09DA2776 DOE No CO test on stove left fl'om 51, on initial inspection 12 wasindicated,decking whereAir Handlerinstalled wasdeteriorated.

Action Required: Return and address deficiencies identified in the report.

*Combination smoke/COdetector-installation charged twiceon each unit.For the following units windowswere installed using LSW practices and the totalcost of the windowwascharged to Healthand Safety. Only the labor cost shouldbe charged to Health and Safety. TheDepal1mentrequires DCHHS to move thematerialcost for all installed windowsfor thefollowingflies to ProgramSupport:

PAGE 12 OF 13



2009 W E AT HE R I Z ATI O N M O N ITO R IN G REPORT

D AL L AS C O UN T Y HEALTH AND H UM AN S E RV I CE S

PA G E 13 O F 13



TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRS

furutu.tdhca,statd. tx. us

RlckPerry

GOVERNOR

Michael GerberEXECuTIve DIRECfOR

June 28, 20I0

Ms. Johnette HicksExecutive DirectorEconomic Advancement Opportunities Advancement Corporation of Planning Region XI500 FranklinWaco, TX 76701

Re: DOE Weatherization Assistance Program Contract # 56090000461LIHEAP Weatherization Assistance Program Contract #81090000494DOEI ARRA Weatherization Assistance Program Contract #16090000662DOE/ARRA Weatherization Assistance Program Contract #16090000752

Dear Ms. Hicks:

BOARD MBMBBR

C. Kent ConIne,Q/udr

Gloria Ray, Vie" ChalLeslie Bingham Escare60

Tom H, GauL ow el l A. K ei g

Juan S. Munoz, Ph.D.

Enclosed is a repol't that details the monitoring and desk review of Economic Advancement OpportunitiesAdvancement Corporation of Planning Region Xl's Welltherization Assistance Program contracts withthe Texas Depallment of Housing and Community Affairs (The Department). This information isprovided to ensure that compliance with the contracts is maintained and that services to the poor, elderly,and disabled are offered in the most expeditious and economical manner.

The monitoring report includes one (I) finding and two (2) recommended improvements. Please submit aresponse to this repOll to this office within thirty (30) days of the date of this letter.

If we can be of any assistance, please feel free to contact Kevin Glienke, Program Officer, at (512) 4753852. The assistance provided to the Program Officers by the agency is greatly appreciated.

Sincerely,

-Sharon GambleEnergy Assistance ManagerCommunity Affairs Division

Cc: Bobby Deike, Weatherization Coordinator

221 EAST l iT" • P. O. Box 13941 • AUSTIN, TEXAS 78711-3941 • (800) 525-0657 • (512) 475-3800

( ) Prilll,d 01/ rup:I"J pdpU




EOAC of Planning Region XI


Section 1. Financial Reporting.





Section VI. Audit


Section VIII. Perfonnance Review

Section IX. Administration

Section X. Multifamily


PA G E 2 0 F S



Dates of Review:

Focus OF REVIEW

2009 WEATHERIZATION MONITORING REPORTEOAC of Planning Region XI

June 9 - 11,2010


DOE 56090000461 $464,162.00 4/1/2009 to 3/31/2010

LlHEAP 81090000494 $573,146,00 4/1/2009 to 3/31/2010

DOE/ARRA 16090000662 $2,216,779.00 9/1/2009 to 8/31/2011

DOEIARRA 16090000752 $353,861.00 9/1/2009 to 8/31/2011

On-site review of Economic AdvancementOpportunities Advailcement Corporationof Planning RegionXl's (EOAC) implementation of the Department of Energy's and Low Income Home EnergyAssistance Program's Weatherization Assistance Program (WAP). Specific areas of reviewincluded Financial Reporting, Contract Agreements, Procurement, Personnel, and theManagement of the Department of Energy and Low Income Home Energy Assistance Programcontracts,

PROGRAM EVALUATION

The evaluation of the program consisted of: interviews with the EOAC personnel, analysis of thefiscal system, review of programmatic records, and inventory review.

The following was noted during the review:

• Low expenditures for ARRA contract #16090000662.• Personnel Policies lacking "political affiliation or belief' clause in Equal

Employment Opportunity statement.

P A G E 3 0 F S



2009 WEATHERIZATION MONITORING REPORTEOAC ofPlllnning Region XI


EXPENDITURES AS OF MA Y 2010

CONTRACT NAME YEAR·TO·DATE- % OF ORIGINAL # UNITS # UNITS IN

EXPENDITURES CONTRACT COMPLETED PROGRESSAMOUNT

DOE $382,417.52 95.54% 63 0#56090000461

LIHEAP $404,922.19 82.81% 87 12

#81090000494

DOE/ARRA $936,742.65 33.41% 91 50#16090000662

DOE/ARRA $573,210.39 46.14%72

38#16090000752

Recommended Improvement #1: Through May 2010, EOAC had expended just 33.41 % of thefunds in the DOE/ARRA contract #16090000662 while 37.5% of the contract period hadexpired. The Department recognizes that EOAC is ahead of the ,overall production schedule forEOAC's two combined DOE/ARRA contracts. The Department expects that EOAC will be ableto meet all the benchmarks required for both DOE/ARRA contracts individually in order to

expend the entire contract amount in the appropriate time period. Reference: TexasAdministrative Code, Title 10, Part 1, Chapter A, Subchapter A, Rule § 1.19; OMBCircular A-ltO, Subpart C _.21 (b) (2) (3) (4)


Finding #1: A review of EOAC's personnel policies revealed the lack of the "politicalaffiliation or belief' provision in the equal opportunity clause.

Action Required: EOAC must amend their personnel policies for the inclusion of the abovementioned clause. Reference: ARRA Contract Section 27; DOE an dLIHEAP Contracts Section 27


Recommended Improvement #2: The Department recognizes that EOAC currently has aprocess to provide education to the client's served to promote energy savings. The Departmentrecommends that EOAC develop a written procedure for client education to ensure consistentclient educational procedures are followed. Reference: Texas Administrative Code, Title 10,Part 1, Chapter 5, Subchapter E, Rule §5.521

P A G E 4 0 F 5



2 0 0 9 WEATHERIZATION MONITORING REPORT

EOAC ofPlannhtg Region XI

Texas Depal'tment of Housing and Community Affairs repl'esentative Kevin Glienke participatedin an exit conference with EOAC I'epl'esentatives Ms. Johnette Hicks, Mr. Bobby Deike, MI'.

Michael Thompson, and Ms. Stacy White.

Signatul'e: IL G ~ (p/Z'V/ (0

Kevin Olienke, TDHCA ProlZram Officer Date:

P A G E 5 0 F 5



TEXAS D EPARTMENT OF H O U S I N G AND C O M M U N I T Y AFFAIRS

www.ttlhca.$Iate.tx.usRickPcrtyGOVERNOR

Michael GerberExEcUTiVE DIRECTOR

July 20,2010

Mr. William LillyDirectorCommunity and Human DevelopmentCity of El Paso

2 Civic Center, 8th FloorEI Paso Texas 79901-1196

Re: Monitoring Report for Weatherization Contract. DOE ARRA WAP Contract #16090000704

DearMr, Lilly:

BOARD.MBMBBRC. Kont Conine, ChaiGloria Ray, Vici Chair

Leslie Bingham RacarefioTom H. Gann

Lowell A. KelgJuanS. Mufioz, Ph.D.

Enclosed is a report that details the monitoring review of the City of El Paso's WeatherizationAssistance Program contract with the Texas Department of Housing and Community Affairs (TheDepartment), This information is provided to ensure that compliance with the contracts ismaintained and that services to the poor, elderly, and disabled are offered in the most expeditiousand economical manner,

The monitoring report includes six (7) findings, seven (7) recommended improvements and one (I)note. Please submit a response to this report to this office w i t ~ i nthirty (30) days of the date of thisletter.

If we can be of any assistance, please feel free to contact Enrique H. Trejo, Program Officer, at(512) 475-2299, The assistance provided to the Program Officer by the agency is greatlyappreciated.

Sincerely,

< : Q 0 ~ -SharonD. GambleManagerEnergy Assistance Section

cc: Joyce Wilson. City Manager

221 EAST 11 TH• P. O. Box 13941 • AUSTIN, TEXAS 78711-3941 • (800) 525-0657 • (512) 475·3800



Section I.

Section II.

Section III.

Section IV.

Section V.

Section VI.

Section VII.

Section VIII.

Section IX.

SectionX.

Section XI.

Section XII.

Section XIII.


Financial Review

Travel and Timesheets

General Liability and Pollution Occurrence Insurance

Property Management

Procurement

Audit

Personnel Policies and Practices.Performance Review

Administrative

Client File Review Worksheet

Multi-Family Review

Denied Files

Summary



Dates of Review:

2009 WEATHERIZATION MONITORINGREPORTOF

CITY OF EL PASO

May 17 - 21,2010

Focus of Revlew

CONTRACT NAMECONTRACT CONTRACT CONTRACT

NUMBER AMOUNT DATES

DOEARRA WAP 16090000704 **$4,007,592.00 9/1109 to 8/31111

• 50% of proposed 10101 allocal.lon

TDHCA staff conducted an on-site review of the City of EI Paso's implementation of theDepartment of Energy (DOE) Weatherization Assistance Progl'am (WAP). Specific areas ofreview included Financial Reporting, Contmct Agreements, Procurement, Personnel, and theManagement of the Department of Energy and Low Income Home Energy Assistance Programcontracts.

Program Evaluation

The evaluation of the program consisted of: interviews with City of El Paso personnel; analysisof the fiscal system; review of progmmmatic records; on-site inspections; client interviews; andinventory review.

Th e following was noted (Jut'lng the review:

• Late Submittal of Expenditure and Performance Reports• Low DOE ARRA WAP Contract Expenditures

• High Administrative Expenditures

• Not Submitting 1512 Quarterly Repol1s to TDHCA

• Lack of Materials Standards Documentation

• On-Site Inspections Requil'ing Returns

• Inconsistent Usc of Attic Tags and Attic Rulers

• Inadequate Record Keeping in Client Files• Development of a Quality Assurance Plan

Page 2 ofl0




CITY OF EL PASO

SECTION I. FINANCIAL REVIEW

EXPENDITURES AS OF THE TIME O F M O NI TO R IN G

CONTRACT YEAR·TO·DATE %OFAMENDED # UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESSAMOUNT

*DOE ARRA WAP $26,354.10 . .66% 0 0

*Expendltul'cs as of Mal'ch 2010

Finding #1: Late Submittal of Expenditure an d Performance ReportsAt the time of monitoring, the City of EI Paso had not submitted the AprilExpenditure and Performance RepOlts. Failure to submit reports when duegives an inadequate picture of the Subrecipients expenditure and

performance to TDHCA. The City of EI Paso is reminded that on or beforethe fifth (5th

) of the month, the Subrecipient shall electronically submit anExpenditure RepOlt and a Performance Report of the previous month'sactivities to the Department.

Action Required: The City of El Paso must correct any deficiencies in policy or procedure thatprevents the timely submittal of the Expenditure and Performance Reports toTDHCA. Specifically, the City of EI Paso must provide written assurancethat Expenditure and Performance Repolts will be sent to TDHCA on orbefore the fifth (5 Ih

) of the month. Please provide the written assurance aspart of the response to the Monitoring Report.Reference: DO E ARRA Contract Section 14 Reporting Requirements

Finding #2: Low DO E ARRA WAP Contract ExpendituresAt the time of monitoring, the City of EI Paso had expended $26,354.1 0 or0.76% of the DOE ARRA contract #1609000064 according to submittedExpenditure RepOlts to TDHCA. The City ofEl Paso was asked toproducea Plan of Action to Imulement DOE ARRA WAP as a result of thePreliminary Monitoring held January 11, 20 10. The City of EI Pasoreceived a Notice of Possible Deobligation letter in May with therequirement to submit a Mitigation Action Plan. The Mitigation ActionPlan submitted to TDHCA includes hil'ing additional inspectors, procuringadditional contractors and targeting multi-family units for weatherization.

Action Required: City of EI Paso must provide assurance that that they will adhere to theMitigation Action1'lan and revise as needed. TDHCA will provide continualmonitoring of the DOE ARRA WAP contract.Reference: DO E ARRA WAP Contract Section 4: Su b recipientPerformance

Page 3 ofl0




CITY OF EL PASO

Recommended Improvement #1: At the time of monitoring, City of EI Paso's Administrativeexpenditure ratio was above the maximum allowable of 5.0% for DOE ARRRA WAP Contract#16090000704. The Administrative expenditure ratio was 57.6%. The City of El Paso providedthe most current financial documentation that included the month of April. The Department

reminds the City of El Paso that the Administrative expenditure ratio must be at or below themaximum allowed percentage by the end of the contract period. Expenditures above theallowable percentage will be disallowed. See DOE ARRA WAP Contract Attachment A.

Recommended IInlJl'ovement #2: A review of financial expenditures indicates that the City of

El Paso is including Health and Safety expenditures in the Material/Labor/Program Supportcategory. The Department reminds the City of El Paso that there is line item in the budget forHealth and Safety expenditures. The Department recommends that the City of EI Paso chargehealth and safety expenditures to the Health and Safety budget category. See DOE ARRA WAPContract Attachment A.

Recommended Improvement #3: The Program Officer appreciates the development of internalaccounting policies and procedures for the Weatherization Assistance Program. The draft manualtitled Accounting for the Weatherization Assistance Program states that Activities will bereconciled to the Fund - General Activity and Trial Balance reports as generated by Peoplesoft.The Program Officer recommends including a monthly target date to complete reconciliations.

SECTION III. GENERAL LIABILIATY & POLLUTION OCCURRENCE INSURANCE

Recommended Improvement #4: At the time of monitoring, the City of EI Paso had notpurchased Pollution Occurrence Insurance. .Although Pollution Occurrence Inslirance is notrequired, DOE strongly recommends obtaining Pollution Occurrence Insurance. SeeWeatherization Program Notice 09-1

SECTION IV. PROPERTY MANAGEMENT

Recommended Improvement #5: City ofEI Paso staff use vehicles from the motor pool as wellas their personal vehicles to assess and inspect units. The City of EI Paso is prohibited from

purchasing 01' leasing vehicles with Weatherization program funds. The City of EI Paso hasptoposed to rent vehicles from the City Motor Pool. The Program Officer has reviewed thedocumentation provided during the monitoring and via email and recommends that City of EI

Paso Weatherization staff enter into a rental agreement with the City Motor Pool to ensure thatvehicles suitable for weatherization are made available for Weatherization Inspectors.

Page 4 af lO




CITY OF EL PASO /

Recommended Improvement #6: The Program Officer recommends purchasing additionalequipment for weatherization inspectors. Specific recommended equipment includes cordlesselel?tric screwdrivers, flashlights and digital cameras. Upon request, the Department can providea general list of recommended tools for weatherization assessors. The Department reminds thatall equipment purchased with DOE funds must be listed on the WAP Inventory List found on theDepartment website.

SECTION VIII. PERFORMANCE REVIEW

Finding #3: Not Submitting 1512 Ouarterly Reports to TDHCAAt the time of monitoring, the City Of EI Paso had not submitted 1512

Reports to TDHCA. City ofEI Paso staff had submitted 1512 Reports to thefederal agencies not realizing the requirement to submit reports to TDHCA.According to the DOE ARRA contract, Subrecipients shall track all fundsand their projected statuses separately from all other funds and shall assist

the Department of Housing and Community Affairsin

preparing and filingthe Department's recipient reports required by Section 1512 of the AmericanRecovery and Reinvestment Act of 2009. Subreclpients shall provide to theDepartment, not later than five (5) calendar days after the end of eachcalendar quarter (1) an estimate of the number of jobs created and retainedby the project; and (2) vendor information including description of service,name, zip code, DUNS number and payment amount ..

Action Required: The City ofEl Paso must provide written assurance that 1512 reports will besubmitted to TDHCA on 01' before the due date' for each upcoming quarteruntil the end of the contract period. City of El Paso is current with the 1512

Reports to TDHCA. /Please provide the written assurance as part of theresponse to the Monitoring Report.Reference: DOE ARRA WAP Contract Section 15 Assistance inPreparing Report's on Use ofFunds

Finding #4: L ac k o f Materials Standards DocumentationAt the time of monitoring, the City of El Paso did not have materialsstandards documentation for material used in weatherization. Any materialsnot meeting DOE specifications will be disallowed. Material standardsdocumentation for weatherization materials purchased with DOE WAP

program funds must be maintained by the Subrecipient and comply withAttachment A of 10 CFR 440 Final Rule.

Action Required: The City of El Paso must provide material standards documentation for allweatherization materials supplied from each subcontractor. Please providematerial standards documentation as patt of the response to the MonitoringReport.Reference: DOE ARRA WAP Contract Section 13 Record Keeping

Page 5 of l0




CITY OF EL PASO

Finding #5: On-Site Inspections Requiring ReturnsThe Program Officer inspected five (5) DOE ARRA units on May 19,2010.Department on-site inspections of weatherized units require three (3) returnsout of five (5) units inspected. Returns' are necessary to address theinsufficient installation of weatherization measures and/or the lack o fweatherization measures. All units were weatherized using the Priority List.

Action Required: The City of El Paso must establish a Quality Assurance Plan that includesassurance that subcontractors will install weatherization measures toDepartment of Energy, International Residential Code and TexasDepartment of Housing and Community Affairs standards. Please providethe Quality Assurance Plan as part of the response to the monitoring report.Specifically, the City of El Paso must address and/correct the followingissues and provide documentation that the issues were resolved:

a. 09Mart9871: I) Reset and glaze the window in the back bedroom. 2)Replace pane in the living room window. 3) Replace window in frontbedroom as an ail' infiltration measure. 4) Seal around vent pipe in thewater heater closet.

b. 090rti1ISS: I) Install smoke detector between kitchen and backbedrooms. 2) Add solar screen to east window. 3) Replace thresholdby front door.

c. 09Anay2704: 1) Add solar screen to back bedroom. 2) Found fiberglass batt insulation (R-19). Add additional insulation to ensure R·30.3) Replace stove as a Health and Safety measure. Include a COreading of the installed stove as part of the response to the MonitoringReport. 4) Optional to install reflective film to window panes where asolar screen would not be appropriate,

Refel'euce: DOE ARRA WAP Contract and 10 CF R 440 Final Rule

Page 6 oflO



2009 WEATHERIZA n O N MONITORING REPORTOF

CITY OF EL PASO

Finding #6: Inconsistent Use of Attic TailS an d Attic RulersDepartment on-site inspections of weatherized units indicated that multipleunits did not have attic tags and/or attic rulers. Weatherized units receivingattic insulation are not in compliance with International Residential Code

standards. According to Section 102.1.1 Building thermal envelopeInsulation, the insulation installer shall provide a certification listing thetype, manufacturer and R-value of insulation installed in each element of thebuilding thermal envelope. For blow-in or sprayed insulation (fiberglassand cellulose), the initial installed thickness, settled thickness, settled R-value, installed density, coverage area and the number of bags installed shallbe listed on the certification. The insulation installer shall sign, date and postthe certification in a conspicuous location on the job site. In addition,insulation markers (attic rulers) shall be provided for every 300 square feetof attic area, attached to the trusses, rafters 01' joists, and indicate in I inchhigh numbers the installed thickness of the insulation.

Action Required: The City of EI Paso must provide written assurance that units receiving atticinsulation will have attic tags and attic rulers. In addition, submit asampleceltification with the required information from each subcontractor thatinstalls attic insulation as part of the response to this monitoring report.Reference: International Residential Code (2006) Section 11: EnergyEfficiency & DOE ARRA Contract Section 4 Subreclplent Performance

Recommended Improvement #7: The Program Officer recommel).ds that the City of El Pasodevelop a policy/procedure. to verify compliance with the EPA Lead Renovator Rule. The policyshould include how, when and how often subcontractors will be inspected by City of EI PasoWeatherization staff. The City of EI Paso has two staff members who have successfullycompleted the Lead Renovator training. One subcontractor has completed the tmining andapplied to be Lead Renovator Firm. The City of El Paso is reminded that contractors performingweatherization work must be certified and follow specific work practices to prevent leadcontamination. Failure to follow EPA Lead Renovator Rule guidelines may result in fines up to$37,500.00 for each violation. The EPA Lead Renovator Rule went into effect on April 22, 2010.

SECTION X. CLIENT FILE REVIEW

Page 7 oflO




OFCITY OF EL PASO

Finding #7: Inadequate Record Keeping in Client FilesDepartment review of client files indicates inadequate record keeping.Examples of inadequate record keeping include incomplete and missingBlower Door Forms; missing Refrigerator porms; and incomplete BuildingWeatherization Reports (BWRs). Inadequate ~ e c o r dkeeping may lead toquestioned costs and poor program performance. Subrecipients are requiredto have all necessary assessment forms indicated in the DOE ARRA WAPcontract. In addition, subrecipients are expected to completely fill out allassessment forms.

Action Required: The City of EI Paso must provide written assurance that client files will havethe required assessments forms that are completely fill out. In addition, theCity ofEI Paso must provide a Quality Assurance Plan that includes a policy01' a protocol for client file review.Reference: DO E ARRA ContI'act Section 13: Record Keeping

Requirements

Note #1: The Program Officer appreciates the development of the Accounting/or WeatherizationAssistance Program manual and the Home Inspector Initial Assessment Procedural Checklist.These documents become part of an overall Quality Assurance Plan for the City of EI PasoWeatherization Assistance Program. The Quality Assurance Plan is a set of internal policies andprocedures to assure compliance with Weatherization Assistance Program Contract, the TexasAdministrative Code and the International Residential Code. Specifically. the Quality AssurancePlan includes a written policy 01' standard operating protocol for 1) Unit Assessments; 2) EnergyAudits; 3) Final Inspections; 4) Client File review; 4) compliance with Interagency Agreementregarding historic properties; and 5) compliance with EPA Lead Renovator Rule.

Page 8 0£10




OFCITY OF EL PASO

Texas Department of Housing and Community Affairs representative, Enrique H. Trejo, ProgramOfficel' participated in an Exit Conference with William Lilly, Director of Human and

Community Development; Raul Gonzalez, Weatherization Coordinator; Frank Keaton, FinancialReporting Coordinator; and Robert Veliz, Weatherization Inspector.

O?!/iPMO/6~ tDate

.. ,

Page 9 of10




OF

CITY OF EL PASO

ATTACHMENT A

Units

Insnected

09Mart9871

090rti1155

090rte916

09Anay2704

09See18804

Fund

Source

ARRA

ARRA

ARRA

ARRA

ARRA

Return

Yes

Yes

No

Yes

No

Comments

Installed CO and smoke detector; 3 wall patches; 8 tubes of caulk, R"38insulation (R"30 required); R"13 wall insulation (80sl); 2 door jambs; 2thresholds; 2 door bottoms; 1 thermostat; and 10 CPLs, No attic tagsand no attic lUiers. Recommend attic dams - discussed at ExitConference. BWR not complete.

,Installed CO and smoke detector; 8 tubes of caulk, R"19 insulation; 4solar s C J : e e n s ~1 thermostat; and 20 CFLs. N o attic tags but found oneattic tuler, Install a smoke detector by kitchen ne . . laundry room, Addsolar screen on east window. BWR not complete and no reft'igeratorform.

Installed CO and smoke detector; 9 tubes o f caulk, 6 inches of insulation;R"13 wall insulation: 10 solar screens; 1 thermostat; 3 jamb ups; 3ti>resholds; 3 door bottoms and 19 CFLs. No attic tags but fouod oneattic ruler. BWR not complete and no refrigerator form,

Installed CO and 2 smoke detector; 7 801:\1: screens; 1 thermostat; 2thresholds; and 18 CFLs, No CO measurements, Conducted CO testand oven was 156 ppm, Attic had 5 inches of fiberglass batt insulation,Add insulation to reach R-30, Install 2 thresholds, Weathe£stdp twodoors . Replace oven, Add reflect ive ftIm as Qn option to solar screens.B'WR no t complete and no l'eftigerator fOlm.

InstaUed CO and smoke detector; 2 solar screens; 3 jamb ups; 3 doorbottoms; 3 thresholds; and one thermostat. BWR no t complete andrcf1'igerator form.

Units Inspected: ARRA - 5 - Unit Returns: ARRA -.l..

Page 10 of10



T EX AS D EP AR TM EN T O F H O U S I N G AND C O M M U N I T Y A F FA I R S

W t Q W ~tdhca.ltats.tx, tISRick Pe,lJ'

·GOVBftNOR

Michael Gerber.Ex.EcUTIVE DIRECfOR

June 28, 20 I0

Ms. Jane TomchikInterim Executive DirectorEI Paso Community Action Program- Project BRAVO, Inc.4838 Montana Ave.EI Paso, Texas 79903

BOARD MEMBERC. Kent ConIne, ChaGloria Ray, Vice Chai

Leslie BIngham Ellcarcf10Tom H. Gan

Lowell A. KeiJuan S. MufJ,oz, Ph.D

Re: Monitoring Report for Weatherization ContractsDOE Weatherization Assistance Program Contract #56090000462LIHEAP Weatherization Assistance Program Contract #81090000495DOE ARRA Weatherization Assistance Program Contract #16090000663, #16090000776 &#16090000784El Paso Electric Contract #329038

Dear Ms. Tomchik:

Enclosed is a report that details the monitoring review of EI Paso Community Action ProgramProject Bravo, Inc., (Project BRAVO) Weatherization Assistance Program contracts with the Texas

Department of Housing and Community Affairs (The Department). This infol1nation is provided toensure that compliance with the contracts is maintained and that services to the poor, elderly, anddisabled are offered in the most expeditious and economical manner.

The monitoring report includes five (5) findings, five (5) recommended improvements and two (2)notes. Please submit a response to this report to this office within thhty (30) days of the date o f thisletter.

I f we can be of any assistance, please feel free to contact Enrique H. Trejo, Program Officer, at (512)475-2299. The assistance provided to the Program Officer by the agency is greatly appreciated.

Sincerely,7TJ-haron D. Gamble

ManagerEnergy Assistance Section

cc: Dr. Maria Arias, Board Chair

221 EAST 11 TH• P. O. Box 13941 • AUSTIN, TBXAS 78711·3941 • (800) 525-0657 • (512) 475.3800

() P,/muf OIl ",yatl paptf



Section I.

Section II.

Section III.

Section IV.

Section V.

Section VI.

Section VII.

Section VIII.

Section IX.

Section X.

Section XI.

Section XII.

Section XIII.


Financial Review



Property Management

Procurement

Audit

Personnel Policies and Practices

Performance Review

Administrative

Client File Review Worksheet

Multi-Family Review

Denied Files

Summary



2009 WEATHERIZATION MONITORINGREPORTOF

EL PASO COMMUNITY ACTION PROGRAM - PROJECT BRA VO, INC.

Dates of Review: March 29 - April I, 2010

Focus OF REVIEW

CONTRACT NAMECONTRACT CONTRACT CONTRACT

NUMBER AMOUNT DATES

DOE 56090000462 *$750,876.00 411/09 to 3/31110

LIHEAP 81090000495 *$950,642.00 411/09 to 313 III 0

DOEARRA 16090000663 **$3,636,064.00 911/09 to 813111 I

DOEARRA 16090000776 **$499,410.00 911109 to 8/3111 I

DOEARRA 16090000784 **$250,000.00 911109 to 8/31/11

*Latest contIact amendments ** 50% of proposed total allocation

TDHCA staff conducted an on-site review of the EI Paso CommunityAction Program - ProjectBRAVO's (Project BRAVO) implementation of the Depaltment of Energy and the Low IncomeHome Energy Assistance Program Weatherization, Assistance Programs (WAP).Specific areas of review included Financial RepOiting, Contract Agreements, Procurement,Personnel, and the Management of the Department of Energy and Low Income Home EnergyAssistance Program contracts.

PROGRAM EVALUATION

The evaluation of the program consisted of: interviews with Project BRAVO personnel, analysisof the fiscal system, review of programmatic records, on-site inspections, client interviews, andinventory ,review.

The following was noted during the J'eview:

• High Administrative Ratio Expenditure for DOE ARRA

• Low DOE ARRA WAP Contract Expenditures

• Missing Information on Attic Tags

• Lack 01' Missing Attic Rulers• LaCK of CO Readings for Combustion Appliances

• On-Site Inspections Requiring Returns for COl1'ectiveAction

PAGE 2 OF 10




EL PASO COMMUNITY ACTION PROGRAM - PROJECT BRAVO, INC.

SECTION I. FINANCIAL REVIEW

EXPENDITURES AS OF TH E TIME O F M ON I TO R IN G

CONTRACT YEAR-TO·DATE % OF AMENDED # UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESS

AMOUNT"DOE $482,794.60 64.3% 165 5

"L1HEAP $715,762.22 75.29% 186 .

5

"DOEARRA $25,302.19 .70% 0 1716090000663

""DOEARRA $0.00 0.0% NA NA16090000776

""DOBARRA $0.00 0.0% NA NA16090000785

"Expenditures as of February 2010 **Contracls SIgned II I January 2010

Recommended Improvement #1: At the time of monitoring, Project BRAVO's Administrativeexpenditure ratio was above the maximum allowable of 5.0% for DOE ARRA Contract

.#16090000663. The Administrative expenditure ratio was 22.9% for DOE ARRA. TheDepartment reminds Project BRAVO that the Administrative expenditure ratio must be at orbelow the maximum allowed percentage by the end of the contract periods. Expenditures abovethe allowable percentage will be disallowed. See DOE ARRA Contract Attachment A.

Finding #1: Low DOE ARRA WAP Contracts ExnendituresAt the time of monitoring, Project BRAVO had expended $25,302.19 or0.70% of the DOE ARRA contract #1609000063 and $0.00 or 0.0% of theDOE ARRA contracts #16090000776 and #16090000785. Project BRAVOwas asked to produce a Plan of Action to Implement DOE ARRA WAP as aresult of the Preliminary Monitoring held January 11, 2010. ProjectBRAVO received a Notice of Possible Deobligation letter in May with therequirement to submit a Mitigation Action Plan. The Mitigation ActionPlan submitted to TDHCA Includes additional procurement for assessorsand subcontractors; a focus on multi·family complexes; and outreachactivities to target the City of Socorro.

Action Requh'ed: Project BRAVO must provide assurance that that they will adhere to theMitigation Action Plan and revise as needed. TDHCA will provide continualmonitoring of all DOE ARRA WAP contracts.Reference: DOE ARRA WAP Contract Section 4: SubreciplentPerformance

PA G E 3 OF 10




OFEL PAS O C OM MU NI TY A CT IO N P RO GR AM - PROJECT BR A VO, INC.

SECTION II. TRAVEL AN D TIMESHEETS

Recommended Improvement #2: The Program Officer recommends that Project BRAVOinclude a category in the timesheets for DOE ARRA if an employee will be paid with DOEARRA funds. Timesheets should be an accurate record of how an employee allocates his or hertime among funding sources. .

SECTION VI. AUDIT

Notc #1: Project BRAVO conducted a Request for Proposal for audit services for Fiscal Year·2006. Project BRAVO must procure for audit services for Fiscitl Year 2010.

SECTION VII. PERSONAL POLICIES AND PRACTICES

Note #2: Project BRAVO is reminded that according to ARRA Contract Section 33 Jo b

Postings on Workintexas.com, all DOE ARRA contract related job opportunities must be

posted on Workintexas.com website. Please print out applicable job postings for monitoringreview.

SECTION VIII. PERFORMANCE REVIEW

Recommended Improvement #3: The Program Officer recommends that Project BRAVOcreate attic hatch openings that are at least 22 inches on each side. Please refer to page 53 of theTexas Weatherization Field Guide.

Recommended Improvement #4: The Program Officer recommends that Project BRAVOconstruct an attic dam around each attic access hatch opening where the attic hatch is found inthe conditioned area. The attic dam should be constructed to a height that matches the depth of

the installed attic insulation. Please refer to page 53 of the Texas Weatherization Field Guide.

PAGE 4 OF 10




OFEL PASO COMMUNITY ACTION PROGRAM - PROJECT BRAVO, INC.

Finding #2: Missing Information on Attic TagsDepartment on-site inspections of weatherized units indicated that attic tagsdid not have the required information according to International ResidentialCode standards. Weatherized units receiving attic insulation are not in

compliance with International Residential Code standards. According toSection 102.1.1 Building thermal envelope Insulation, "the insulationinstaller shall provide a certification listing the type, manufacturer and R-

value of insulation installed in each element of the building thermalenvelope. For blow-in or sprayed insulation (fiberglass and cellulose), theinitial installed thickness, settled thickness, settled R-value, installeddensity, coverage area and the number of bags installed shall be listed on thecertification." .The insulation instaUer shall sign, date and post thecertification in a conspicuous location on the job site."

Action Requi red : Project BRAVO must submit a sample cettification with the required

information from each subcontractor that installs attic insulation as part ofthe response to this monitoring report. Projeot BRAVO must provideassurance that attic insulation will have the required oertification.Reference: International Residential Code (2006) Section 11: EnergyEfficiency & DOE ARRA Contract Section 4 Subreeipient Performance

Finding #3: Lack or Missing Attic RulersDepartment on-site inspections of weatherized units indicated that therewere missing attic rulers. Weatherized units with attic rulers did not have asufficient number of attic rulers. Weatherized units receiving attic insulationare not in compliance with International Residential Code standards.According to Section 102.1.1.1 Blown or sprayed roof/celling insulation,"(T)he thickness of blown in or sprayed roof/ceiling insulation (fiberglass orcellulose) shall be written in inches on markers that are installed at least onefor every 300 square feet throughout the attic space. The market's shaU be

affixed to the trusses 01' joists and marked with the minimal initial instaUed

thickness with numbers a minimum of I inch in height. Each marker shallface the attic access opening."

Action Required: Project BRAVO must provide assurance that attic insulation wlll have therequired number of insulation markers as patt of the response to thismonitoring report.Reference: International Residential Code (2006) Section 11: EnergyEfficiency

PAGE 5 OF 10




OF

EL PA SO C OM MU NI TY A CT IO N P RO GR AM - PROJECT BRAVO, INC.

Finding #4: Lack of Documented CO Readings for Combustion AppliancesDepartment on-site inspections and review of client files indicate a lack ofcarbon monoxide (CO) testing for all combustible appliances for each client.There were missing CO readings for N4213, N4139, NI343 and E874.

Carbon monoxide readings were taken during the on-site inspection of units.Exposure to high CO levels may leave a home in an unhealthy situationleading occupants to experience headaches, flu-like symptoms, and nausea.Adequate whole house assessment includes taking CO readings to ensurethat CO levels are not at unhealthy levels.

Action Required: Project BRAVO must establish a Quality Assurance Plan that includes aprocedure/policy to ensure that carbon monoxide readings are taken for allc o m b ~ l s t i o nappliances in a household as part of a whole house assessment.Provide the Quality Assurance Plan as part of the response to the monitoring .report.

Reference: DOE and LIHEAP Contrllcts Section 10. lind DOE ARRAContrllct Section 13. Record Kecping

Finding #5: On-Site Inspections Requiring ReturnsProgram Officers inspected six (6) DOE ARRA units on March 30, 2010and seven (7) DOE, LIHEAP and El Paso Electric units on March 31, 2010.Department on-site inspections of weatherized units require eleven (11)returns out of the thirteen (13) units inspected. Returns are necessary toaddress the insufficient installation of weatherization measures and/or thelack of weatherization measures.

Action Required: Project BRAVO must include in the Quality Assurance Plan assurances thatsubcontractors will install weatherization measures to Department ofEnergy, International Residential Code and Texas Department of Housingand Community Affairs standards. Specifically, Project BRAVO mustcorrect the following issues and provide documentation that issues wereaddressed:

a. N4213: I) Replace the pipe from the Temperature Pressure Relief(TPR) valve so that it does not drain up hill. .

2) Install a drain pipe to the exterior from the water heaterdrain pan.

b. N4139: I) A solar screen was found under aporch. Move solar screento adjacent window.

2) Invoices include a charge for a door viewer that was notfound during on-site inspection. Install a door viewer orreimburse the program.

PAGE 6 OF 10




EL P AB O COMMUNITY ACTION PROGRAM - PROJECT BRAVO, INC.

c, Y2760: I) Two solar screens were found in the house. Install the solarscreens according to the work order.

d. Y2984: I) A solar screen was installed underneath a carport, Solar

screens reduce solar heat gain and should be placed onwindows that receive direct sunlight. Remove and reinstallthe solar screen on an appropriate window.

e, N1343: I) CO testing of the oven revealed a high CO reading.Replace the stove and install a vent hood that is vented tothe exterior.

f. N1696: I) On-site inspection blower door testing produced a readingthat was approximately 400 CFM above the target blowerdoor reading. Conduct additional air sealing to reduce theblower door reading below the target of2590 CFM.

g. E1386: I) On-site inspection revealed significant air infiltration in theair handler closet and laundry room. Conduct additional airsealing measures in the air handler closet and laundryroom.

2) On-site inspection revealed tears in the duct system. Repairthe duct system underneath the mobile home and provideprotection in the form of skirting around the mobile home

h, E1l7: I) On-site inspection blower door testing produced a readingthat was approximately 1,300 CFM above the target blowerdoor reading. Conduct additional air sealing to reduce theblower door reading below the target of 2940 CFM.

1. E1237: I) On-site inspection blower door testing produced a readingbelow the Building Tightness Limit (BTL). Installmechanical ventilation in the kitchen andlor bathroom.

j. E874: I) CO testing of the oven revealed a high CO reading.Replace the stove and install a vent hood that is vented tothe exterior.

k. Y2296: I) Mastic the plenum to prevent air infiltration leaks.2) The filter l'ack is lt1accessible and the furnace must be

reinstalled in order to have the ability to replace air filters.3) Reconnect and seal the duct at the register in the dining

room.Reference: DO E ARRA, DO E l\nd LIHEAP Contl'l\cts 10 l\nd CF R 440

Finlll Rule

PAGE 7 OF 10



2009 WE A THERIZATION MONITORING REPORT

OFEL PASO COMMUNITY ACTION PROGRAM - PROJECT BRAVO, INC.

Recommended Improvement #5: The Program Officer strongly recommends that ProjectBRAVO include a policy/procedure to verify compliance with the Environmental ProtectionAgency (EPA) Lead Renovator Rule practices in the Quality Assurance Plan. The policy shouldinclude how, when and how often subcontractors will be inspected. The Department remindsProject BRAVO that new rules went into effect on April 22, 20 I 0 specifying that contractorsperforming weatherization work must be cel1ified and follow specific work practices to preventlead contamination. Failure to follow EPA Lead Renovator Rule guidelines may result in finesup to $37,500.00 for each violation.

PAGE 8 OF 10




EL PASO COMMUNITY ACTION PROGRAM - PROJECT BRAVO, INC.

A T T A C H M E N T A

UnitsInspected

82289

N4181

N4213

N4139

Y2760

Y2984

N1343

N1696

E1386

Fund Source Return

ARRA No

ARRA Yes

ARRA Yes

ARRA Yes

ARRA Yes

ARRA Yes

DOE!LIHEAP Yes

DOE!EPE Yes

DOE!LIHEAP Yes

Comments

Attic hatch is too small. Recommend 22" x 22". No attic tags, Noattic rulers. The blower dam WA S configured wl'ong And reading wasunreliable. Corrected by third house.

Could not view the Rltic because the client did not let inspectorsmove the furniture. The blowet door was configured wrong andreading was unreliable. Corrected by third house.

No CO readings, CO testing during on-site inspection revealed a 27CO reading on left front burner. No Rltic tags. No attic rulers.TPRvslve pipe goes down then up. DtRin pan does not dtRin to theexterior.

No CO readings. Solar sc'een under a porch. Charged for a dOOI'viewer that could not be found.

No attic tags. One attic ruler not attached to a truss. 1\vo solarscreens found in the house and not on windows.

Insulation in the furnace due to roofers. (F'lXed immediatelyQ Lllckof ftltet box access. One solar scxeen on a North window and one

solar screen under a carport.

Information on the attic tag is insufficient. Hole undel' sink but too

close to the BTL. No CO readings.

Inspection blower door was above the tRIget and the fmalinspection. Need additional air sealing.

Target ai ' sealing in the air handler closet and laundly room. Theduct underneath the mobile home is torn. Protect the dnct from thedog.

E117

E1237

E874

Y2296

DOE!LIHEAP

LIHEAP!EPE

LIHEAP

DOE!LIHEAP

Yes

Yes

Yes

Yes

Inspection blower door was way above the target. Conductadditional air sealing.

House is below the BTL by 47 CFM. Install a vent in the kitchen

and or bAthroom.

No CO readings. Inspectots conducted CO tests on the stove andoven. Oven had a leading of 254 and should be replaced.

No Attic dam. Infolmation on the attic tag is insufficient. Mastic theplenum, Install an accessible filter tRck. Reconnect or seal the ductat the register in the dining room. Insulation blew thtough register,

PAGE 10 OF 10




EL PAS O C OM MU NI TY A CT IO N P RO GR AM - PROJECT B RAVO , I N C.

Texas Department of I-lousing and Community Affairs representatives, Emique H. Trejo,Program Officer and Giovani Giunca, Program Officer participated in an Exit Conference withJane Tomchik, Interim Executive Director; Mike Martinez, Welltherization Coordinator, Armida

Saavedra, Executive Secretary and Martin Dominguez, ChiefFinancial Officer,

Signature: ~ 4 1 1 ~ ~ t ; 1 ~ ~ ~ - k . ~ = = : : : . ._CA Program Officer

( ) ~ / I ~ 'Date

PA G E 9 OF 1 0



T E X A S D E PA RT M E N T O F H O U S I N G AN D C O M M U N I T Y A F FA I R S

wruw.tdhca.state.tx.us

RlckPerryGOVERNOR

Michael GerberExHcuTIVE D'IUlCTOR

June 28, 2010

Ms. Tama ShawBxecutive DirectorHill Country Community Action AssociationPO Box 846San Saba, TX 76877

Re: DOB Weatherization Assistance Program Contract # 56090000464LIHEAP Weatherization Assistance Program Contract #81090000497DOE!ARRA Weatherization Assistance Program Contract #16090000665DOE/ARRA Weatherization Assistance Program Contract #16090000765DOE/ARRA Weatherization Assistance Program Contract #16090000778DOE/ARRA Weatherization Assistance Program Contract #16090000785

Dear Ms. Shaw:

BOARD MEMBC. Kent Conine, ChGloria Ray, Vice Ch

Leslie Bingham BscarTom H. Gan

Lowell A. KJuan S. Muf toz, Ph.

Enclosed is a report that details the monitoring and desk review of Hill Country Commnnity ActionAssociation's Weatherization Assistance Program contracts with the Texas Department of Housing andCommunity Affairs (The Depaltment). This information is provided to ensure that compliance with thecontracts is maintained and that services to the poor, elderly, and disabled are offered in the mostexpeditious and economical manner.

The monitoring report includes two (2) findings and four (4) recommended improvements. Please submita response to this report to this office within thirty (30) days of the date of this letter.

I fwe can be o f any assistance, please feel free to contact Kevin GHenke, Program Officer, at (512) 4753852. The assistance provided to the Program Officers by the agency is greatly appreciated.

Sincerely,

Sharon GambleEnergy Assistance ManagerCommunity Affairs Division

Cc: Frances Little, CFO

221 EAST 11 TH • P. O. Box 13941 • AUSTIN, TEXAS 78711-3941 • (800) 525·0657 • (512) 475·3800

( ) P,JIlt(d ~ I jmydrd p"ptr




HILL COUNTRY COMMUNITY ACTION ASSOCIATION





Section IV. Propelty Management


Section VI. Audit



Section IX. Administration

Section X. Multifamily


PA G E 2 OF 7



Dates of Review:

2009 WEATHERIZATION MONITORING REPORTHILL COUNTRY COMMUNITY ACTION ASSOCIATION

June 1- 4 ,2010

Focus 'O F REVIEW


DOE 56090000464 $464,162.00 4/1/2009 to 3/31/20 I0

LIHEAP 81090000497 $573,146.00 4/1/2009 to 3/31/20 I0

DOE/ARRA 16090000665 $2,216,779.00 91112009 to 8/3 1/20I I

DOE/ARRA 16090000765 $353,861,00 9/1/2009 to 8/31/201 I

DOE/ARRA 16090000778 $250,00.00 9/1/2009 to 8/31/20 I I

DOE/ARRA 16090000785 $250,0()Q.00 9/1/2009 to 8/31/201 I

On-site review of Hill Country Community Action Association's (HCCAA) implementation ofthe Department of Energy's and Low Income Home Energy Assistance Program'sWeatherization Assistance Program (WAP), Specific areas of review included FinancialReporting, Contract Agreements, Procurement, Personnel, and the Management of theDepartment of Energy and Low Income Home Energy Assistance Program (LIHEAP) contracts.

PROGRAM EVALUATION

The evaluation of the program consisted of: interviews with the HCCAA personnel, analysis ofthe fiscal system, review of programmatic records, on-site inspections, client interviews, andinventory review.

Th e foliowing was noted during the review:

• DOE/ARRA administrative expenditures are high.• LIHEAP administrative expenditures finished high.• Low expenditures for ARRA contracts.• All counties in service area were not served equitably with DOE 01' LIHEAP

contracts.

P A G E 3 0 F 7




Section I . Financial Reporting

Recommended Improvement #1: At the time of monitoring, DOE/ARRA contract#16090000665 had an administrative expenditure of 10.64 percent. HCCAA is reminded thatDOE/ARRA administrative expenditures must be at 5.00 percent by the end of the contractperiod. Reference: DOE/ARRA Contract Attachment A

Finding #1: Disallowed Cost of $11,771.87. Review of HCCAA's final PY09LIHEAP monthly expenditure reports revealed that the administrativeexpenditures were at 9.99%, which is above the allowable limit of 7.22%.

Action Required: The Department sent a letter to HCCAA on June 8, 2010 (attached)requesting a reimbursement of these funds. Please provide a copy of thattransaction as part of the response to this report. Reference: LIHEAPContract Attachment A

Finding #2: Low expenditures for ARRA contracts. Through April 2010, HCCAA hadexpended just 14.99% of the funds in one of the four DOE/ARRAcontracts while 33% of the contract period had expired. It is expected thatHCCAA will be able to meet the requirements outlined in the productionschedule submitted to the Department in order to expedite currentexpenditures for the Weatherization Assjstance Program.

Action Required: The Depattment has received the response from HCCAA in regards to thepossible de-obligation because ofthis low production level at this point inthe contract. The Department will continue to monitor HCCAA and their

. production level to ensure that HCCAA will achieve adequate expenditure

levels in order to execute ARRA weatherization activities within thecontract time-frame. Reference: Texas Administrative Code, Title 10,Part 1, Chapter A, Subchapter A, Rule § 1.19; OMB Circular A-110,Subpart C _.21 (b) (2) (3) (4)


Recommended Improvement #2: A review ofHCCAA's final monthly expenditure reportrevealed that 6 counties (Burnet, Erath, Lampasas, Mills, Sommervell, Williamson) were notserviced with PY09 DOE WAP funds and 4 counties (Burnet, Erath, Sommervell, Williamson)were not served with PY09 LIHEAP funds. During the time of monitoring, HCCAA provideddocumentation that services had been provided to all counties in service area since PY07. TheDepartment is aware that HCCAA coordinates with multiple utility funding sources whenproviding services, but reminds HCCAA that service must be provided to the entire service areaon an equitable basis. Reference: DOE an d UHEAI> Contracts Section 3

PA GE 4 O F ?



2 0 0 9 WEATHERIZATION MONITORING REPORT. HILL COUNTRY COMMUNITY ACTION ASSOCIATION

Recommended Improvement #3: A review of the client files revealed that the Hill CountryCommunity Action Association needs to complete the Building Weatherization Report forms asrequired. The BWR requires that the beginning date be either: ( l) the day the Audit/Priority Listhas been completed or (2) the day the materials have been ordered for that home. Reference:Building Weatherization Report Form Instructions

Recommended Improvement #4: Onsite home inspection of weatherized units revealed thatone ( l) of the ten (10) units inspected would require a return to address deficiencies insubcontractor workmanship. HCCAA must return to the home listed in Attachment A andaddress the issues listed. HCCAA should make sure that all attics are properly assessed forventilation. Reference: 10 CFR Part 440; §440.16 (g)j Weatherization Field Guide page 53.

PAGE 5 OF 7



2 0 0 9 W E AT H ER I Z ATI O N M O N I TOR I N G R E P O RT

H I L L COUNTRY COMMUNITY A C T IO N A S SO C IAT IO N

Texas Department of Housing and Community Affairs representatives, Kevin Glienke andWalter Griner, participated in an exit conference with Hill Country Community ActionAssociation representatives Ms. Tama Shaw, Ms. Frances Little, Ms. Patti Owen, Mr. JamesStewart and Mr. Chad Turner.

Signature: ~ bt -k - c./l.P//p~ evin Glienke, TDHCA Program Officer Date:

Signature: Mil:: ~~ ! 2 . f / ; ( J~

Walter Griner, TDHCA Program Officer Date:

PAGE 6 OF 7




ATTACHMENT A

UnitSFund Source Return Comments

Inspected35489 DOE Yes Return to address the attic ventilation and install the.. ARRA/LIHEAP smoke detectorthat was missing at the time of

monitoring.

Hill Country Community Action Association must return and address the unit as indicated andinclude in it's response to this report a summary of all actions and m'easures taken to address theunit indicated above.

P A G E 7 0 F 7



TEXAS DEPARTMENT OF H O U S I N G AND C O M M U N I T Y AFFAIRS

fVWW. tdhca,#flte. Ix . liSRfckPerryGOVERNOR

Michael GerberExEcUTNH DIRBCfOR

June 28, 2010

Mr. Forest R. "Bob" Christy, Jr.Interim Director, General Services DepartmentCity of HoustonP.O. Box 61189Houston, Texas 77208-1189

BOARD MnMB

C. Ke.Q.t Conine, ChGloria Ray, Vit'6 ChLeslie Bingham Bscareft

Tom H. GanLowell A. K

Juan S. Mufioz. Ph.D

Re: DOE ARRA Weatherization Assistance Program Contract # 16090000689

Dear Mr. Christy:

Enclosed is a report that details the monitoring review of your Department of Energy (DOE)American Recovel'y and Reinvestment Act (ARRA) Weatherization, Assistance Program(WAP) contract with the Texas Department of Housing and Community Affairs (theDepartment). This information is provided to ensure that compliance with the contract ismaintained and that services to the poor, elderly, and disabled are offered in the mostexpeditious and economical manner.

The monitoring report includes eight (8) findings and one (1) recommendation. Pleasesubmit a response to this report to this office within thirty (30) days of the date of this letter.

I f we can be of any assistance, please feel free to contact David Escamilla, Senior ProgramOfficer, at (512) 475-3859. The assistance pl'ovided to the Pl'ogram Officers by the agencyis greatly appreciated.

Sincerely,

OJ':) -Sharon D. GambleManagerEnergy Assistance Section

cc: Honorable Annise D. Parker, Mayor, City of Houston

221 EAST l i T " • P. O. Box 13941 • AUSTIN, TEXAS 78711·3941 • (800) 525·0657 • (512) 475.3800



A R R A WEATHERIZATION ASSISTANCE P R OG R AM M O N IT O R IN G R E P O RT

O F

CITY O F H OU ST ON







Section VI. Audit

Section VII. Personnel Policies and P r a c t i c ~ s



Section X. Client File Review/Multifamily Review



PA G E 2 OF 9



A R R A WEATHERIZATION ASSISTANCE PROGRAM MONITORING REPORT

OFCITY OF HOUSTON

DATES OF REVIEW: MAY J - MA Y 7,2010

Focus OF R E V I E W


ARRA 16090000689 $11,783,198.00 9/1/2009 to 8/31/2011

On-site review of the City of Houston's (COH) implementation o f the Department of Energy's(DOE) American Recovery ·and Reinvestment Act (ARRA), Weatherization Assistance Program(WAP). Specific areas of review included Financial Reporting, Contract Agreements, Pr()curement,Personnel, and the Management of the DOE ARRA WAP contract.


The evaluation of the program consisted of interviews with the City of Houston personnel, analysisof the fiscal system, review of programmatic records, on-site inspections, client interviews, andinventory review.


• Low ARRA contract expenditures.• One paid vendor invoice for materials and labor services reviewed in the amount of

$16; 018.54, did not identifY clients served.• Travel expenditures in the amount of $797.42, were incorrectly charged to Materials,

Program Support and Labor.• Same subcontractor utilized for initial unit assessment services, also perfolmed

weatherization services work.• No debarment verification review was conducted for contracted subcontractors.

• Ousite review of weatherized units revealed that COH did not conduct a thoroughfinal inspection on seven (7) of the eight (8) units inspected.• Client file review conducted, revealed that several files did not contain required

client documentation, and/or contained forms that were not properly and/or fullycompleted.

PAGE 3 OF 9




OFCITY OF HOUSTON

• Three (3) appeal files reviewed revealed that annual income calculation wascalculated incorrectly; as Federal non-cash benefit for Medicare was counted as partof annualized gross income, resulting in applicants being denied services in error.

Section I . Financial ReviewEXPENDIT U RE S AS OF M A R C H 2010

CONTRACT YEAR·TO-DATE % OF ORIGINAL # UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESS

AMOUNT

ARRA $120,574.01 1.02% 53 210..

Recommended Improvement #1: At the timeof

monitoring, COR had an administrativeexpenditure ratio of 92.68% for ARRA WAP. COR is reminded that administrative expendituresmust be at or below 5%, by the end of the contract period. Any expenditure above the maximumallowable limit will be sUbject to disallowed costs.

Finding #1:

ActionRequired:

As of the March 2010, expenditure report, COR had expended $120,574.01,01' 1.02% of ARRA W AP contract funds, and 25% of the contract period hadelapsed. COR was asked to produce a Plan of Action to implement DOEARRA WAP, as a result of the Preliminary Monitoring visit conducted onDecember 14,2009. COR also received a Notice of Possible Deobligationletter in May 2010, with the requirement to submit a Mitigation Action Plan.That Mitigation Action Plan submitted to the Department included actionsteps COR will undertake to include implementing more aggressive outreachactions, hiring of additional intake staff, subcontracting an additionalinspector, and pursuing multi-family unit weatherization opportunities.

COR must assure the Department in its response to this report that the actionsteps outlined in the Mitigation Action Plan will be implemented and thatfurther plan revisions will be made as needed, to insure COR meets theDepartment's production goals. Additionally, COR can expect theDepartment to provide continual monitoring of COR's performance, toinclude conducting follow-up monitoring visits throughout the contractperiod.Reference: Contract; Section 4, an d Section 24

PAGE 4 OF 9



A R R A WEATHERIZATION ASSISTANCE PROGRAM MONITORING R E P O RT

OF

CITY O F H O US TO N

Finding #2: A review of vendor invoices for materials and labor services revealed thatone (1) paid subcontractor invoice (PMG) in the amount of $16,018.54, didnot identifY clients served.

Action

Required:

Finding #3:

ActionRequired:

Finding #4:

ActionRequired:

COH must reconcile the vendor invoice noted above, and identify costsassociated with each client served by the subcontractor for the amount billed.A copy of the reconciled invoice must be submitted to the Department withCOH's response to this report. Additionally, COH must assure theDepartment in its response to this report that improved financial reviewprocedures will be implemented to insure that all subcontractor invoicesclearly identify clients served before the invoices are paid.Reference: 10 CFR Part 440; §440.24

A review of program expenditures revealed that travel expenditures in theamount of $797.42 were incorrectly charged to Materials, Program Supportand Labor.

COH must perform the necessary accounting actions to correctly charge thetravel costs noted above to the appropriate budget category. A copy of thecorrective action accounting' adjustment must be submitted to the DepaltmentWith COH'sresponse to this report. Additionally, COH must assure theDepattment in its response to this report that improved financial proceduresWill be implemented to insure that program expenditures are correctlycharged to the appropriate budget category. 'Reference: Contract; Section 11, and Section 35


A review of procurement action documentation for subcontractor servicesrevealed that COH was utilizing the same subcontractor that provided initialunit assessment services, to also perform weatherization work measures.

In an effort to insure program integrity, COH must conduct a procurementaction to obtain an independent subcontractor that will performweatherization work measures independently of the initial unit assessmentwork activity. The benefit of having two (2) separate subcontractors performeach work activity independently assures program integrity and is an internalcontrol safeguard against the potential risk of fraud and abuse. A copy of theprocurement action to obtain a separate subcontl'actor to conduct independentinitial inspections andlor weatherization work

PA G E 5 OF 9



A R R A WEATHERIZATION ASSISTANCE P R OG R AM M O N ITO R IN G R E P O RT

OF

CITY OF HOUSTON

measures must be submitted to the Department with COH's response to thisreport.Reference: Contract; Section 26

Finding #5:

ActionRequired:

Finding #6:

ActionRequired:

Finding #7:

A review of procurement action documentation for subcontractor servicesrevealed that COH did not conduct a vendor debarment verification review,for each vendor awarded an ARRA W AP contract for materials and/or laborservices.

COH must conduct a vendor debarment verification review for eachsubcontracted vendor awarded an ARRA WAP contract for materials and/orlabor services; A copy of the vendor debarment verification document foreach subcontracted vendor !1-warded an ARRA WAP contract for materialsand/or labor services, must be submitted to the Department with COH'sresponse to this report. Failure to provide the required vendor debarmentverification documentation will result in disallowed costs for all materialsinstalled and/or labor services provided.Reference: Contract; Section 37

Section VIII ..Performance Review

·Onsite review of weatherized units revealed that COH did not conduct athorough final inspection on seven (7) of the eight (8) units inspected. .

COH must retUITI to the client· units identified as reqUl1'1ng retUITIS inAttachment A, and address the additional work measures noted on each unit.Additionally, COH must also assure the Department in its response to thisreport that procedures will be implemented that will insure final inspectionsof completed units are conducted in a more thorough and comprehensivemanner.Reference: 10 CF R Part 440; §440.16 (g)

Section X. Client File Review

Client file review revealed that several files as noted below; did not containrequired client documentation, andlor contained forms that were not properly,and/or fully completed.

PAGE 6 OF 9



A R R A WEATHERIZATION ASSISTANCE PROGRAM MONITORING R E P O RT

OF

CITY O F H OU ST ON

Client File #: Issue:10542-10 The income eligibility documentation is not

within 12 months from the work start dateindicated on the BWR.

10417-10, 10024-09, 10027-09, 10542-10, These files are missing the BWR certification10361.10, 10205-09,10383-10, 10123-09 of final inspection page, and invoices for

materials purchased, and/or invoices for laborservices.

10027-09, 10417-10, 10024·09 The Blower Door Data Sheet is missing a Sub-recipient Representative final test signature.

10027-09, 10417-10, 10024·09, 10542-10 The work start date noted on the BWR is notthe date that the actual work started on home.

ActionRequired:

Finding #8:

ActionRequired:

COR must address the client file documentation issues noted above. A copyof each corrected and/or obtained client file document noted above must besubmitted with the response to this report. Additionally, COR must alsoassure the Department in its response to this report that procedures will beimplemented that will insure client file recordkeeping requirements will beadhered to as outlined in the ARRA W AP contract.Reference: Contract; Section 13


A review of the applicant denial/appeal files revealed that three (3) applicantswere denied assistance in error, as the Federal non-cash benefit for Medicareeach applicant received was counted as part of their annualized gross income.

The Department acknowledges that i t provided the names of the threeapplicants to COR during the Exit Conference, and instructed COH tocontact each applicant and inform them that their application would beprocessed for ARRA WAP assistance. However, COH must assure theDepartment in its response to this report that procedures will be implementedthat will insure client applications are screened more thoroughly and inaccordance with program income eligibility guidelines.Reference: 10 TA C §5.19 (b) (2) (L)

P A G E 7 0 F 9



A R R A WEATHERIZATION ASSISTANCE PROGRAM MONIT9RING RE PORT

OFCITY OF HOUSTON

Date '

Datealter Grmer, Program OfficerSignature:

Signature:

Texas Department of Housing and Community Affairs representatives; David Escamilla, andWalter Griner, participated in an exit conference with Mr. Gavin Dillingham, Ms. Ana Shah, Ms.Tanja Rouse, Ms, Olga Ramirez, Ms, Marisol Medina, and Mr. Renon Libunao, and Mr. WarrenCampbell.

P A G E 7 0 F 8




OF

CITY O F H OU STON

AT T A C H M E N T A

I ' " ~ I" ' ' ' ' " ' , "If"jl "" , , ' 1 ' " ' I I ' ' ' ' ' ' ' ' ' ' ' ,,, ,"" " · ' ' ' 1 ' ' ' ' ' ' , """';'1; / ~ ~ ~ , ' , J ) ' . r l . : ' ~ , J h : h ' ~ U ~ F ,H , ~ S ) ~ t o \ ' , : , \ ~ ) , H I M ' } { ( ' ; ~ ' ) l I h i ~ 1 X ' h l \ 1~ ' . " / ' ,L ~ " : , , , ' . ; , , ; :' / ' ; ' ;,:',.'{J,'" " J,

' ' ' ' > \ '. ' ,( , 1, ."/ 'I, .' I I ,'. J f' , " '" , I " ' i . \ ,j , :', " . r <" { 'I , . ~

. 1 u / ' } I . H ~ , , ~ l J ! ; 1 ~ . U ; 1 1 ; t l l C . \ ,.lb'... ;( ,) > ~ ' ' . . : , hi! ,', , ' . ; ',' , ' ~ , ' ~ \ v' , , :,:' . " , l ~ J

#10417-10 ARRA Return to seal register in the den; sealthe ale door with a jamb-up and door-sweep; perform a tune-up on theHVAC. ana install additiQnalinsulation in the walls up to therequired r-value amount.

#10361-10 ARRA Return to install additional wallinsulation up to the required r-valueamount; and block the heat source inthe attic.

#10383·10 ARRA No return required.#10205-09 ARRA Return to repairand/or replace cook-

stove.

#10027-09 ARRA Return to address additional airinfiltration measures.

#1002A-09 ARRA Return to adjust door-sweep on frontdoor; seal registers in den; and installan additional 4 CFL bulbs.

#10542-10 ARRA Retum to bring the water heater up tolocal code; and block the heat sourcein the attic.

#10123·09 ARRA Return to connect the HV AC flue inthe closet.

PA G E 9 0 F 9



TEXAS D E PA RT M E N T OF H O U S I N G AND C O M M U N I T Y A F FA IR S

tlJww.tdhca,state, tx. tiS

RlckPettyGOVERNOR

Michael GerberExEcUTiVE DIRECTOR

June 21, 2010

Mr. Ben FigueroaExecutive DirectorInstitute of Rural Development9I5 South 9 1h StreetKingsville, Texas 78363

Re: DOE Weatherization Assistance Program Contract # 56090000465LIHEAP Weatherization Assistance Program Contract # 8 I 090000498ARRA Weatherization Assistance Program Contract # 16090000787

Deal' MI'. Figueroa:

BOARD MEMBERS

C, Kent Conine, CluGloria Ray. Vic, Cha

LeslIe Bingham Bscaref\oTom H. Gann

Lowel l A. KeiJuan S. Mufioz. Ph.D

Enclosed is a rcpOlt that details the monitoring review of your Depmtment of Energy (DOE),Low Income Home Energy Assistance Program (LIHEAP), and American Recovery andReinvestment Act (ARRA), Weatherization Assistance Program (WAP) contracts with the TexasDepartment of Housing and Community Affairs (the Department). This information is providedto ensure that compliance with the contract is maintained and that services to the poor, elderly,and disabled are offered in the most expeditious and economical manner.

The monitoring repOlt includes foul' (4) findings and two (2) recommendations, and one (I ) note.Please submit a response to this repolt to this office within thirty (30) days of the date of thisletter. .

If we can be of any assistance, please feel free to contact David Escamilla, Senior ProgramOfficer, at (512) 475-3859. The assistance provided to the Program Officers by the agency is

greatly appreciated.

Sincerely,

~ a : b ;ManagerEnergy Assistance Section

cc: Mr. AlbeIt Garcia, Board Chair, Institute of Rural Development

221 EAST llTH • P. O. Box 13941 • AUSTIN, T'XAS 787ll ·3941 • (800) 525·0657 • (512) 475·3800



Section I.

Section II.

Section III.

Section IV.

Section V.

Section VI.


Financial Review



Property Management

Procurement

AuditSection VII. Personnel Policies and Practices



Section X. Client File Review/MuItifamily Review





2009 WEATHERIZATION ASSISTANCE PROGRAM MONITORING REPORT

OFINSTITUTE OF RURAL DEVELOPMENT

DATES OF REVIEW: MAY 10 - MA Y 14,2010

Focus O F R E V I E W


DOE 56090000465 $51,947.00 4/1/2009 to 3/3112010

LIHEAP 81090000498 $43,568.00 4/112009 to 3/31120 I0

ARRA 16090000787 $225,708,00 911/2009 to 8/3l/20 I I

On-site review of the Institute of Rural Development (IRD) implementation of the Department ofEnergy's and Low Income Home Energy Assistance Program's Weatherization AssistanceProgram (WAP), and the American Recovery Reinvestment Act (ARRA) WeatherizationAssistance Program. Specific areas of review included Financial RepOiting, ContractAgreements, Procurement, Personnel, and the Management of the Department of Energy andLow Income Home Energy Assistance Program and American Recovery Reinvestment Actcontracts,


The evaluation of the program consisted of interviews with the Institute of Rural Developmentpersonnel, analysis of the fiscal system, review of programmatic records, on-site inspections,client interviews, and inventory review.


• Monthly bank statement reconciliations were not thoroughly documented, and agedoutstanding checks were not being formally tracked. .

• Foul' (4) out of six (6) units inspected will require a return to address additional workmeasures.

• No documentation of which energy audit was utilized to weatherize homes.• Complete BWR forms were not in client file.• No documentation of verification of LSW practices,

PAGE 2 OF 7



2009 WEATHERIZATION ASSISTANCE PROGRAM MONITORING REPORTOF

INSTITUTE OF RURAL DEVELOPMENT


EXPENDITURES AS OF MARCH 2 0 1 0

CONTRACT YEAR·TO·DATE % OF ORIGINAL # UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESS

AMOUNT

DOE $35,567.85 68.47% 14 0

LIHEAP $39,181.16 89.93% 14 0

ARRA *$38,955.66 17.26% 13 3

*Expendltures as of Apnl2010

Recommended Improvement #1: A review of the accounting work papers (Monthly ExpenseWorksheets) for the months of February-2010 (DOE/LIHEAP), and March·2010(DOE/LIHEAP/ARRA), 2010, revealed that various expenditure differences existed in variousbudget categories when compared to the Monthly Expenditure Reports. The differencesoccurred due to adjustments made to each account to conect expenditures charged in enol' fromone WAP grant to another WAP grant. Documentation provided to explain the adjustments wasprovided during the monitoring visit. The Depaltment acknowledges that the April·2010 ARRAWAP Monthly Expenditure Report accurately reflected the expenditures contained within theaccounting work papers (Monthly Expense Worksheet). Accordingly the Deptl1tmentrecommends that IRD continue to implement process improvements to insure acco\mting workpapers and repOlt integrity remain constant and transparent.

Recommended Impl'ovement #2: A review of the March 2010, Monthly Expenditure Reportrevealed that IRD had an administrative expenditure ratio of 12.31% for DOE WAP, and 8.12%for LIHEAP WAP. IRD is reminded that administrative expenditures must be at 01' below 5%for DOE WAP and 7.22% for LIHEAP WAP, by the end of the contract period. Anyexpenditure above the maximum allowable limit wiJI be subject to disallowed costs.

Note #1: As of the May-201O, ARRA WAP Monthly Expenditure Report, IRD has expended30% of contract funds. The Department will continue to closely monitor IRD's production to

assure services to eligible Duval County applicants are provided.

Finding #1: A review of bank statement reconciliation records for the months ofJanuary through March, 2010, revealed that IRD was not fullydocumenting the reconciliation process; to include who conducted thereconciliation and who verified the results. Additionally, it was also notedduring the bank statement review that IRD had no formal documentedtracking process to track aged outstanding checks (90 days and older).

P A G E 3 0 F 7



2009 WEATHERIZATION ASSISTANCE P RO G RA M M O NI TO R IN G R E PO RT

OF

INSTITUTE OF R U R A L D E V EL O P M EN T

ActionRequired:

Finding #2:

ActionRequired:

Finding #3:

ActionRequired:

IRD must implement procedures that will insure monthly bank statementreconciliations are fully documented, and must also implement a formaldocumented process to track aged outstanding checks. A c,opy of the

formal written implemented procedures must be submitted with theresponse to this report.Reference: 2 C FR P a rt 215; §215.21 (b) (2) (3)


Onsite inspection of weatherized units revealed that four (4) of the six (6)units inspected, will require a return to address additional work measures.

IRD must return to the client units identified as requ1l'1ng returns in

Attachment A, and address the additional work measures noted on eachunit. IRD must also insure that the additional work measures performed onPY-2009 WAP client unit (WAP-DUV-230-SD) are charged to agencyumestricted funds, as the PY2009 W AP contract period has elapsed. IRDmust also llssure the Department in its response to this I'eport that futurefinal inspections of completed units will be conducted in a more thoroughand comprehensive manner.Reference: 10 C FR P ar t 440; §440.16 (g)

During the monitoring visit unit review, it was discovered that IRD hadnot formally documented which energy audit was completed andlorutilized for each home weatherized. Additionally, it was also noted duringthe unit review that the BWR documentation for each client ullit inspected,only contained the certification of final inspection page, and 1l0t the firsttwo (2) pages, that detail the measures performed, associated cost for eachmeasure, and which grant fund was utilized to pay for each measureperformed.

The Department acknowledges that IRD informed the Department duringthe unit review that it was utilizing the Priority List, as the energy audit foreach home weatherized. However, no formal Priority List documentationwas available in each client file for the units reviewed. Accordingly, IRDmust submit to the Department with its response to this repOlt, a copy ofthe Priority List documentation utilized for each client unit weatherized.The Priority List documentation should have detailed information forwhich measures were performed and which were omitted, withjustification for the omissions. IRD must also provide to the Departmentwith its response to this repolt, a copy of the fully completed BWRdocument for each unit weatherized. Failure to provide the required

P A G E 4 0 F 7



2 0 0 9 WEATHERIZATION ASSISTANCE PlWGRAM MONITORING REPORT

OF

I NS T IT U TE O F R UR AL D EV EL OP M EN T

documentation will result in disalIowed costs for alI costs associated withthe weatherization of each client unit. IRD must also assure theDepartment in its response to this report, that action will be taken to insureeach client unit will have an energy audit completed and/or documented

before each unit is weatherized, and that will insure that BWRdocumentation will be fulIy completed for each weatherized unit, after alI

weatherization measures are performed.Reference: 10 TAC §5.526, and Contract; Section 13 (B) (4)

Finding #4:

ActionRequired:

A review of W AP client files for the units inspected, revealed that IRDhad no formal documentation of verification of Lead Safe Weatherization(LSW) practices.

IRD shalI document verification of LSW practices for all unitsweatherized that were built before 1978. The documentation shouldinclude photos to verify LSW practices are folIowed. AdditionalIy, alI

completed units must be inspected to insure compliance with LSWprocedures and practices. IRD must submit to the Department with itsresponse to this report the LSW verification plan that has beenimplemented by IRD to insure compliance with LSW requirements.Reference: 10 TA C §5.524

P A G E S O F 7



2009 W E AT HE R I ZAT I ON A S SI S TA NC E P R O GR A M M O N I TO R I N G REPORT

OF

I NS T IT UT E O F R U RA L D EV EL O PM EN T

Texas Department of Housing and Community Affairs representative; David Escamilla,participated in an exit conference with Mr. Ben Figueroa, Ms. Tonie Perez, Ms. Lisa Alvarado,and MI'. David Flores.

Signature:

P A G E 6 0 F 7



2009 WEATHERIZATION ASSISTANCE PROGRAM MONITORING REPORTOF

INSTITUTE OF RURAL DEVELOPMENT

A T T A C H M E N T A

WAP·DUV·230·SDWAP·DUV·034-SDWAP·DUV·054·RL

DOE/LIHEAP Return to address additional infiltration in hallway andbackdoor.

DOE/LIHEAP No return required.

DOE/LIHEAP No return required

WAp·ARRA·058SDWAP·ARRA·IGSDWAPARRA-162·SD

ARRA

ARRA

ARRA

Return to address additional applicable Priority Listmeasures.

Return to address certification tag for attic insulation, solarscreens, and additional applicable Priority List measures.

Return to address floor insulation, and additional applicablePriority List measures.

WAP Monitoring_Part 2

Documents

Transcript of WAP Monitoring_Part 2