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Special HCHA meeting November 15, 2019 <br /> with staff or I will share with staff a list of the other waivers that grantees have <br /> received over the last 10 years, just an example of what kind of things, <br /> special...special conditions individual grantees have needed to tweak our <br /> regulations to fit their conditions...and we really are very flexible, the whole point <br /> is to meet your needs and not to be held back by a rule that we have the ability <br /> to change. We want to be as flexible as possible so that you can follow through <br /> on your determinations of what is needed, what is the best way to spend those <br /> funds. <br /> This is kind of a list of some of the highlights of where other grantees have gotten <br /> in trouble in the past. The big thing is procurement...it's a lot of money flowing <br /> and making sure that the procurement is done properly there's always an <br /> interest in rushing and getting things done as fast as possible but if you don't do <br /> it right, it can cause a lot of troubles down the road. Make sure the CDBG <br /> requirements, there's contract...CDBG contract requirements that need to be in <br /> every contract, like a...like a due date, if your contract was something to do "x" <br /> you have to have a date for when "x" is going to be done, you can't leave <br /> contracts open ended. It seems reasonable. And just the procurements are <br /> often so large that it...it...it's can be more complex. <br /> The contractors, sub-recipients there all going to have requirements that they <br /> need to do and they might not be used to doing them. All the labor...labor <br /> laws, the environmental reviews that are required, that they might not know that <br /> they need to fill out, those need to be in the contract, and the grantee needs to <br /> be making sure that...that there's over...proper oversight of those contracts to <br /> make sure that they are doing everything they need to do. And then also you <br /> monitoring the contractors performance, sub-recipients performance. Cause it is <br /> so much money and if you make a mistake most people don't have a lot...a lot <br /> of money to pay...to pay back funds so you...you don't have a whole lot of <br /> tolerance for mistakes at the monetary level and you don't want to have to be <br /> paying things back and the way to avoid that is to be having that good <br /> level...high level of oversight of contracts and procurement to make sure that <br /> things are done properly. In fact in...this is relatively new for the disaster recovery <br /> grants, we require an internal auditor, independent internal auditor, operating <br /> within the program that reports to generally the Mayor or the head of a <br /> department that plays an additional oversight role, just to make sure everythings <br /> are going well just because the volume is big. <br /> I talked a little bit about financial policies and procedures, you need to...there's <br /> pretty detailed standards we have now that you have to accomplish up <br /> front...document up front before we actually enter the grant agreement but <br /> then also have to make sure that you follow them...and people don't follow <br /> their procedures...that's an often...often a problem that we find, is that we have <br /> great policies and procedures but in the actual fact, you didn't follow those <br /> Page 9 of 31 <br />