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Our audit found the following: <br /> <br />Deficiencies before 2022 Improvements after 2022 <br />• Compliance with Chapter 11 Improved Compliance with Chapter 11 <br />o Pre -awarded and Over -awarded Credits • Worked with Corporation Counsel to develop a better understanding of the code <br />o Misinterpreted areas of the code • Increased program oversight <br />o Internal Control Systems Program Oversight • Clarified supervisor responsibilities <br />o Segregation of duties • Segregated most incompatible duties <br /> • Formalized policies and procedures <br /> • Increased training <br /> • Improved records maintenance, including DHHL credits <br /> • Hired a consultant to analyze and make recommendations to amend Chapter 11 of the Hawaii County Code <br /> <br />• Written policies and procedures <br />o No Administrative Rules <br />o Vetting developers' qualifications <br />o Contract monitoring of Affordable Housing Agreements (AHA) <br />o Maintaining complete records of credits <br />o Timely recognition of DHHL credits <br /> <br />Based on these conditions, we offer the following seven recommendations: <br /> <br />Clarify County Code <br /> <br />1. We recommend OHCD work with Hawaii County Council to revise applicable sections of <br />Chapter 11. <br /> <br />Establish Administrative Rules <br /> <br />2. We recommend OHCD establish administrative rules to effectively administer the County's <br />Affordable Housing Policy. <br /> <br />Update and Enforce Policies and Procedures <br /> <br />3. We recommend OHCD clarify and enforce policies and procedures to ensure consistency <br />throughout the department and industry best practices. <br /> <br />Increase Monitoring and Program Oversight <br /> <br />4. We recommend OHCD perform ongoing monitoring of their internal control system's design <br />and operating effectiveness as part of their operations. <br /> <br />5. We recommend OHCD use software and technology as a monitoring tool to improve managing <br />affordable housing agreements and credits. <br /> <br />Segregate Incompatible Duties <br /> <br />6. We recommend OHCD management separate incompatible duties. One individual should not <br />oversee key elements of the affordable housing process. <br /> <br />Provide Training <br /> <br />7. We recommend OHCD provide ongoing internal control training to employees involved in the <br />affordable housing process. <br /> <br />2 Executive Summary <br />