Disaster Relief Funding Compliance

The Governor’s Office of Storm Recovery (“GOSR”)

Yip Associates supports the Monitoring and Compliance Department of GOSR in the on-site monitoring of subrecipients, contractors and their projects to determine whether they are administering Community Development Block Grant-Disaster Recovery (“CDBG-DR”) activities according to all applicable federal, state, and local requirements. Our team reviews and analyzes subrecipient agreements and requirements, including but not limited to:

Civil rights diversity
Contract compliance
Corruption prevention
Environmental and safety
Equal opportunity and workforce utilization
Fair housing
Financial and administrative management
Internal controls
Labor standards
MWBE
Procurement
Program eligibility
Program reporting and recordkeeping
Section 3

Onsite monitoring visits are conducted to subrecipients’ offices and project sites to observe CDBG-DR funded activities, conduct interviews, and perform financial and document reviews to determine whether all costs are eligible and properly documented.

Yip Associates assisted a prime contractor in conducting a review of lien release practices across numerous GOSR construction projects. The work encompassed evaluating existing policies, procedures, processes and operations including management’s oversight practices, escalation procedures, and related reporting. Our team interviewed process owners to determine adherence and compliance with existing policies, performed testing of key process controls. We identified key process improvements, made numerous recommendations based upon industry best practices, and reported our findings to GOSR Executive Management for implementation.

Yip Associates assisted a prime contractor with supporting the GOSR Internal Audit Department in conducting audits of various housing developments and communities that were impacted by Hurricane Irene, Tropical Storm Lee and/or Superstorm Sandy; and as a result, received GOSR funding under the New York Rising Community Reconstruction Program.

The scope of work included:

Assessing compliance with federal grant requirements and GOSR policies and procedures
Conducting interviews and procedural walkthroughs with key GOSR personnel
Developing audit programs and performing testing on a sample of subrecipient programs
Identifying gaps, inefficiencies, and overcharges
Making recommendations to improve current processes and internal controls
Reviewing oversight practices

Yip Associates conducted reviews of various GOSR contractors and vendors to determine GOSR’s ability to prevent, detect, and respond to fraud, waste, and abuse, and/or mismanagement of GOSR funds within the CDBG-DR program. These reviews included:

Assessing management reporting/metrics used for decision-making purposes and conducting sample testing to determine GOSR’s and the contractors’ compliance with terms of the agreement and applicable regulations
Conducting evaluations of management reviews, investigations, escalations and follow-up procedures
Evaluating company policies and procedures, processes, operations and practices
Identifying risks of potential excessive or inefficient billing practices, duplication of services, conflicts of interest and other inappropriate activities by vendors
Performing live observations of the current processes and practices in place

Yip Associates performed a completeness evaluation on the documented internal control procedures as they relate to GOSR’s Program policies for seven (7) of the New York Rising Programs (“Programs”). This evaluation included cross‐referencing policies and procedures from the Programs manuals in order to identify policies within the manuals that were not addressed by procedures documented within their related procedure manuals.

Our firm used its understanding of the Programs’ operations obtained through this review to provide general and program specific suggestions for improvement. All of our findings and documentation were presented to GOSR’s Internal Audit Department to assist in its effort to enhance the operations of the Programs.

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