CONFIRM CDBG RECAPTURE & DUPLICATION OF BENEFITS POLICIES
One of the requirements for all federal grants including HUD CDBG-DR and CDBG-NDR grants is that each Grantee establish and adhere to a Recapture Policy and Duplication of Benefits Policy involving recovery of funds which are determined through ongoing internal audit and compliance review to be ineligible or overpayments to beneficiaries, contractors, sub-recipients, anyone or entity receiving grant funds. During the course of staff's review, it was found these two policies to have no record of City Council approval. While these policies meet HUD requirements including having been posted on the city website, there is not a clear written record of the reasoning and basis for administratively establishing these policies.
It is recommended the City Council confirm the CDBG-DR/NDR Recapture Plan and Duplication of Benefits Policy administratively established since 2013 but not previously approved by the City Council.