City of Houston, Texas, Weatherization Assistance Program monitoring report, May 2011

8/4/2019 City of Houston, Texas, Weatherization Assistance Program monitoring report, May 2011

1/14


2/14


3/14


4/14

2009 ARRA WEATHERIZATION ASSISTANCE PROGRAM MONITORING REPORTCITY OF HOUSTON

Section I. Financial ReviewRecommended Improvement #1: The COH Administrative costs were at 9% as ofMarch I,2011. This is above the maximum allowable of 5% for the DOE/ARRA contract. COH isreminded that the Administrative costs must be at 5% or lower upon final close-out of the DOEARRA contract or any costs over 5% will be disallowed.Finding #1:

ActionRequired:

Finding #2:

ActionRequired:

Finding #3:

ActionRequired:

ExpenditurelProduction RateAt the time of the review COH had low expenditures for the DOE/ARRAcontract. Based on the data reported through February of2011, COH was at 27%expenditure, while 71% of the contract period had passed.

In order to COH to successfully fulfill the ARRA WAP contract, COH mustincrease unit production and expenditures. COH has in the past assured theDepartment that expenditures and production would increase to a level that wouldallow the COH to be successful; that has not yet happened. The Departmentrequires that COH review its planning and provide an updated plan of action toaddress expected outcomes for the contract as part of the response to this report.Reference: Texas Department of Housing and Community Affairs ContractsSection 4 and Section 3 of ARRA and DOEILi-Heap Contracts; TexasAdministrative Code, Title 10, Part 1, Chapter 5, Subchapter A, Rule 5.14

Section V. ProcurementSubcontractor ContractCOH contracts do not include the provision for compliance with the reporting ofpatent rights. The missing provision is required per the Texas AdministrativeCode and OMB circulars.

COH must revise its contracts with its contractors to include the provision notedabove. Reference: Texas Administrative Code, Title 10, Part 1, Chapter 5,Subchapter A, Rule 5.10: OMB A-110 Appendix AProcurement ProceduresCOH did not submit to the Department an electronic version of a notice ofprocurement opportunity to be posted on the Department's website.COH must assure the Department that an electronic version of any notice ofprocurement opportunity for any future procurement that the COH initiates for theexpenditure of DOE ARRA funding will be forwarded to the Department forposting. Reference: ARRA Contract Section 19

PAGE 4 OF 14


5/14


Section VII. Personnel Policies and PracticesRecommended Improvement #2: A review of the COH's Personnel Policies and Practices,including COH's Executive Orders, concluded that the COH's Affirmative Action/EqualOpportunity Policy #102 with an effective date of February 7, 1983 did not contain a provisionto prohibit discrimination on the basis of political affiliation or belief. The Departmentrecommends this provision be added to the COH's policy manual.Finding #4:

ActionRequired:

Finding #5:

ActionRequired:

Finding #6:

WhistleblowerThe ARRA contract requires the posting of the rights and remedies affordedwhistle blowers underSection 1553 of the American Recovery and ReinvestmentAct of 2009. This notice was not posted anywhere throughout the COH's GeneralServices Department.

The Department requires the COH's General Services Department to place theposter where it can be viewed by staff. Downloadable copies are available at:http://www.recovery.gov/Contact/ReportFraudlDocuments/WhistleblowerPoster.pdf. Reference: ARRA Contract Section 31

Section VIII. Performance ReviewFinal InspectionsOnsite inspection of weatherized units revealed that twenty one (21) of the sixty-five (65) units inspected would require a return to address deficiencies insubcontractor workmanship not noted during final inspections. Deficienciesincluded: large air leaks inside mechanical closets of newly installed HVAC unitsand improper measures addressing knob and tube electrical wiring in a singlefamily home.

The COH must return to the client units listed in Attachment A and address thedeficiencies noted on the unit. The COH must also assure the Department in itsresponse to this report that proactive measures will be taken to prevent futureinstances of poor final inspections. Those measures at a minimum should includeboth periodic visits to client units while work is in progress and ensure that finalinspections will be conducted once all work is finished, to ensure that the qualityof work that is being performed meets the COH requirements, and theDepartment's expectations. Reference: 10 CFR Part 440; 440.16 (g)Materials SpecificationsMaterial specifications were not available for all contractors working within theprogram. Only one contractor had provided a partial list of the materialspecifications, of those items the following was missing:

PAGE 5 OF 14


6/14

2 0 0 9 ARRA WEATHERIZATION ASSISTANCE PROGRAM MONITORING REPORTCITY O HOUSTON

Floor insulation Replacement doors Electric furnaces and water heaters Gas furnaces and water heaters Central air and/or heat pumps

ActionRequired:

Finding #7:

ActionRequired:

COH must obtain the material specifications from all of the contractors for allmaterials they are installing and maintain a file with this information. COH mustensure that all materials installed meet DOE 10 CFR 440 Attachment Aspecifications. COH must also forward a copy of these specifications with itsresponse to this report. Failure to do so will result in disallowed costs for allmaterials installed to date for which adequate specifications are not provided.Reference: 10 CFR 440 Appendix AQuestioned and Disallowed CostCOH installed eighty (80) new water heaters at the Gulf Coast Apartments. Forty(40) of the water heaters were non-existent prior to weatherization, resulting in$47,892.00 in Disallowed Costs. The forty (40) existing water heaters did nothave adequate justification for replacement, resulting in $47,892.00 inQuestioned Costs.

The Department requires the COH to provide justification for the replacement ofthe forty (40) existing water heaters; Failure to do so will result in disallowedcosts for each water heater for which justification for replacement is not provided.The $47,892.00 of Disallowed Costs for the added water heaters must bereimbursed to the department in the form of a check provided with the response tothis report, payable to the Department. Please ensure that the check is noted"Disallowed Costs" and includes the ARRA WAP contract number. Reference:Texas Administrative Code Rule 5.528, 10 CFR 440.18

Client File ReviewFinding #8: Inadequate SupportDocumentationA review of the COH files indicates that some AlC replacements were notincluded in the NEAT or the BWRs. These files include GCA-19 GCA-14

, GCA-19- , GCA-17- , and GCA-18- .

PAGE 6 OF 14


7/14


ActionRequired:

Finding #9:

The Department requires COH to re-run the NEAT on the units listed above toinclude the AlC replacements to determine if they rank with an SIR of I orgreater. COH must ensure that a duplicate audit is created so that the originalaudits are not destroyed. In any case where the AlC does not rank at I or greaterthe cost will be disallowed. These files are part of a multifamily project in whichthis particular measure ranked in all other units. Reference: ARRA ContractSection 13; 10 CFR Part 440; 440.24; Texas Administrative Code 5.526Inadequate SupportDocumentationThe files indicated below had discrepancies in audits, required forms, signatures,lack of justifiable pictures and or form dates, etc. resulting in incomplete files.None of the multi-family files reviewed contained a completed assessment,resulting in Questioned Costs of $248,664.00 for all measures performed.

Sin Ie Familv UnitsClient file #(s) Issues11479-10 Final inspection date on blower door sheet wasone month later than siQ:ned BWR.10128-09 No assessment in file - priority list.14758-10 Failed to reach 30% reduction at finalassessment.12125-10 No client siQ:llature on final inspection form.12125-10,11905-10,10057-04 No audit in files.12479-10 Assessment did not contain site plan or sketchofhome.

Multi-Familv12632-10, 12650-10, 12649-10, No assessments in files for NEAT audits,12652-10, 12860-10, 12850-10, apparently the contractor has on file.12640-10, 12641-10, 12642-10,12645-10, 12691-10, 12670-10,12843-10, 12787-10, 12665-10,12782-10, 15372-11, 12828-10,12718-10, 12703-10, 12838-10,12836-10, 12662-10, 15371-11,12793-10, 12790-10, 12834-10,12811-10, 12725-10, 12721-10,12740-10, 12734-10, 12809-10,12780-10, 12826-10, 12804-10,12,808-10, 12742-10, 12730-10,12766-10, 12814-10, 12816-10All files above No mold forms in all files12808, 12734, 12742, 12725, The NEAT for these files gave gas water12804,12652 heaters an SIR of2.0. They were not input

PAGE 7 OF 14


8/14

2 0 0 9 ARRA WEATHERIZATION ASSISTANCE PROGRAM MONITORING REPORTCITY OF HOUSTON

under health and Safety.12734,12662 No CO readings noted for oven replacement infile.15371 Furnace replaced no pictures or CO readings infile.12650,12652 Solar screens installed but not included inNEAT audit.

ActionRequired: The Department requires the COH to develop a policy to ensure that all forms andfile documentation are completed fully and any omissions are clearly explainedand recorded in each file.COH must also either (1) submit to the Department completed and accurateassessment forms justifying the measures installed for the units listed above; or(2) COH must reimburse the Department $248,664.00 in the form a check for allwork performed on the multi-family units reviewed. These costs would includethe previously identified questioned and disallowed costs for water heaterreplacements. Reference: Texas Administrative Code Rule 5.529, 5.530,5.601, ARRA Contract Section 13, 10 CFR Part 600.121 (3), 600.220,600.153

PAGE 8 OF 14


9/14


10/14


11/14


12/14


13/14


14/14

City of Houston, Texas, Weatherization Assistance Program monitoring report, May 2011

Documents

Transcript of City of Houston, Texas, Weatherization Assistance Program monitoring report, May 2011