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    TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRStuww. tdhca,state, tx. us

    Rick PetryGOVERNOR

    Michael GerberEXECUTIVRDIRECfORJune 28, 2010

    Mr. Bill Howelton, Jr.Executive DirectorCity ofLubbock, CommunityDevelopmentP.O. Box 2000Lubbock, TX 79457

    BOARD MBMOC. Kent. Conine, CGloria RaYl Vice CLeslie Bingham EscarTom H. GLowell A. KJuan S. Mufioz, Ph

    Re: Department ofEnergy (DOE) Weatherization Assistance Program (WAP) Contract #56090000466DOE - American Recovery and Reinvestment Act WAP Contracts # 16090000668 &16090000708Low-Income Home Energy Assistance Program WAP Contract # 81090000499Dear Mr. Howerton,Enclosed is a report that details the monitoring review of City of Lubbock, CommunityDevelopment (CO Lubbock) Weatherization Assistance Program contracts with theTexas Depaltment of Housing and Community Affairs (The Department). Thisinformation is provided to ensl)fe that compliance with the contracts is maintained andthat services to the poor, elderly and disabled are offered in the most expeditious andeconomical manner.The monitoring repot:t inc111des six (6) findings, two (2) recommended improvements andone (1) note. Please submit a response to this report to this office within thirty (30) daysof the date of this letter.If we can be of any assistance, please feel free to contact Matt Embry at (512) 936-9988or [email protected]. The assistance provided to the Program Officer by theagency is greatly appreciated. .Sincerely,1f)-Sharon GambleManagerEnergy Assistance SectionCc: Peter Laverty, Board Chair221 EAST 11 TH P. O. Box 13941 AUSTIN, TBXAS 78711-3941 (800) 525-0657 (512) 475-3800

    () PrSIIU,{ ~ t rtrydrdpllp"

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    Section I.Section II.Section III.InsuranceSection IV.Section V.Section VI.Section VII.Section VII.Section IX.Section X.Section XI.Section XII.

    2009 WEATHERIZATION MONITORING REPORTOF

    CITY OF LUBBOCK

    Directory ofMonitoring Sections

    Financial ReviewTravel and TimesheetsGeneral Liability and Pollution Occurrence

    Property ManagementProcurementAuditPersonnel Policies and PracticesPerformance ReviewAdministrativeMulti-Family ReviewDenied FilesSummary

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    Dates ofReview:

    2009 WEATHERIZATION MONITORING REPORTOF

    CITY OF LUBBOCK

    March 29- April!, 2010

    Focus OF REVIEWCONTRACT NAME CONTRACT *CONTRACT . CONTRACTDATESNUMBER AMOUNT

    DOE 56090000466 $263,407.00 4/1/2009 to 3/31/2010LIHEAP 81090000499 $321,938.00 4/1/2009 to 3/31/2010ARRA 16090000668 $1,272,305.00 9/1/2009 to 8/31/20 IIARRA 16090000708 $1,176,924.00 9/1/2009 to 8/31/2011

    .. Latest contract amendmentsOn-site review of the City of Lubbock's (CO Lubbock) implementation of theDepartment of Energy's (DOE) and Low Income Home Energy Assistance Program's(LIHEAP) Weatherization Assistance Program (WAP) and the DOE American Recoveryand Reinvestment Act WAP (ARRA). Specific areas of review included FinancialRepOlting, Contract Agreements, Procurement, Personnel, and the Management of theDepartment ofEnergy and Low Income Home Energy Assistance Program contracts.

    PROGRAM EVALUATIONThe evaluation of the program consisted of: interviews with the CO Lubbock personnel,analysis of the fiscal system, review of programmatic records, on-site inspections, clientinterviews, and inventory review.The following was noted during the review: Low Expenditures, DOE, LIHEAP, and ARRA Invoicing- Material/Labor Separation

    Insurance- Lead Based Paint Occurrences Procurement-Health and Safety area on Bid needs Material/Labor Categories Audit- Procurement Due 2010 Lead Safe Work-Client Information Compliance with Program Rules- Requested Information not Provided Multi-Family- Outreach Denied Files-Incomplete, Appeals Procedure, Denial Procedure LIHEAP, DOE, ARRA- Conflict ofInterest

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    2009 WEATHERIZATION MONITORING REPORTOFCITY OF LUBBOCK

    Section I. Financial ReviewFinding #1:

    Action Required:

    Low Expenditure Rates DOE. LIHEAP, ARRAAt the time of the review CO Lubbock had low expenditures forDOE, LIHEAP and ARRA contracts (see table below). Reporteddata as of February, 2010 for DOE indicates CO Lubbock has noDOE units in progress. Reported data as of February, 2010 forUREAP indicates that CO Lubbock has 12 units in progress. Atcurrent Cost Per Unit (CPU) rates an additional estimated$45,460.56 will be expended in the final month of the LIHEAPcontract, bringing the PY09 UREAl' total to an estimated$227,338.07 or 70.62% of the total contract. Reported data as ofFebruary, 2010 for ARRA indicated 0 units in progress, theProgram Officer noted that the ARRA program had just beganimplementation.The Department requires Co Lubbock to provide a written plan ofaction to address expected outcomes for all categories. Reference:Texas Administrative Code, Title 10, Part 1, Chapter 5,Subchapter A, Rule 5.141; OMB Circular A-102 (2) (b); 10CFR 600.142; 10 CFR 600.236 (3)

    EXPE)'IDITURES AS OF FEBRUARY 2010CONTRACT YEAR-TO-DATE % OF ORIGINAL #UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESSAMOUNT *

    DOE $226,546.72 82.87% 37 0LIHEAP $181,877.51 56.49% 39 12ARRA $2,448,48.50 0.19% 0 0

    At the time of mOnllormg. Finding #2: InvoicesA review of back-up documentation from contractor invoicesrevealed that in 12 of 15 of client files reviewed the contractor isnot itemizing costs between labor and materials.Action Required: The Department requires CO Lubbock to require all WAPcontractors to provide an invoice that has separate labor andmaterial charges. Reference: DOE Contract, Section 10, (A) (5)Page 4 of9

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    2009 WEATHERIZATION MONITORING REPORTOF

    CITY OF LUBBOCKand (6); LIHEAP Contract, Section 10, (A) (5) and (6); andARRA Contract, Section 10, (A) (5) and (6)Section III. General Liability and Pollution Occurrence

    InsuranceFinding #3:

    Action Required:

    Lead Based Paint or RelatedWorkA review of CO Lubbock insurance policies revealed that thepolicy riders did not include a rider for Lead Based Paintoccurrences.The Department requires CO Lubbock to document that the currentself-insurance policy covers Lead Based paint occurrences or thatCO Lubbock purchase a rider specific to lead Based Paintoccurrences and to provide written documentation as prot of theresponse to this report. Reference: DOE Contract, Section 18;LIHEAP Contract, Section 18; ARRA Contract, Section 22

    Section V. Procurement .Recommended Improvement #1: A review of the bid packet revealed that the bid formprovided for the contractors did not contain separate categories for material and laborestimates. The Depllltment recommends that CO Lubbock revise the bid form to reflectmaterial and labor estimates.

    Section VI. AuditNote #1: CO Lubbock went out for bid on audit services in 2006. the Department notesthat CO Lubbock is due for audit services procurement in 2010.

    Section VII. Performance ReviewFinding #4:

    Action Required:

    Lead Safe Works Practices (LSW)A review of client file revealed that 5 of 16 files reviewed did notinclude documentation of client receipt of the Renovate RightImportant Lead Hazard Information for Families, Child CareProviders and Schools.The Department requires CO Lubbock to provide training for allWAP staff regarding the documentation requirements for LSW.The Department requires CO Lubbock to provide writtendocumentation of this training and a roster of those in attendanceas part of the response to this report. Reference: WeatherizationProgram notice 09-6

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    Finding #5:

    Action Required:

    2 0 0 9 W E A T H E R I Z A T I O N M O NI TO R IN G R E P OR TOF

    CITY O F L UB BO C K

    Compliance with Program RulesAt the time of monitoring, a CO Lubbock holiday caused timeconstraints, resulting in the inability to collect BuildingWeatherization Repot1s (BWR) for units inspected. Multiplecontacts were made with CO Lubbock staff (via phone- 4/27/2010,Brad Reed; 4/29/20I0, Daniella Garza; via email 4/27/2010 BradReed; 4/29/2010 and 4/30/2010, Daniella Garza; 4/30/2010, JoeRangel; and 4/30/20 I 0, Bill Howerton) to obtain the requestedinformation. At the time of this report, no information has beenreceived from CO Lubbock.The Department requires CO Lubbock to submit back up BWR'sfor clients 09T0281, 090S340, 09EV231 and one ARRA finalinspection as pmt of the response to this report. Failure to providethe requested documentation may result in disallowed costs.Reference: Texas Administrative Code, Title 10, Part 1,Chapter 5, Subchapter A, Rule 5.16Section X. Multi-Family Review

    Recoinmended Improvement #2: A review of client files indicated that at the time ofthe review CO Lubbock had not completed Weatherization measures for any MultiFamily units. The Department recommends that CO Lubbock consider conductingoutreach to target Multi-Fmnily units, specifically the Department recommends that COLubbock COl,1sult the DOE/HUD agreement concerning HUD approved Multi-Fmnilyunits. Section XI. Denied FilesFinding #6: Denied File DocumentationA review of denied files revealed incomplete or inadequatedocumentation, specifically; incomplete applications, missingdenial notices, missing income documentation and inadequateexplanation for denial.Action Required: The Department requires CO Lubbock to provide training to allWAP staff regarding documentation requirements for denied files.

    The Department requires CO Lubbock to provide writtendocumentation of this training and a roster of those in attendanceas patt of the response to this report. Reference: TexasAdministrative Code, Title 10, Part 1, Chapter 5, SubchapterE, Rule 5.505; 10 CF R 440.24

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    2009 WEATHERIZATION MONITORING REPORTOF

    CITY OF LUBBOCK

    Section XII. ARRA SummaryNote #2: ARRA Procurement StandardsA review of ARRA Procutement documentation tevealed that COLubbock had' entered in to a contract for WAP ARRA with Lee. Rangel; dba Lee's Home Imptovement. Lee's Home Improvementwas also an existing contractor for DOE and LIHEAP WAPprograms for PY09. Lee Rangel is a first degree relative (btother)

    of WAP Contract Coordinator, Joe Rangel. The Ptogram Officerdetermined that this relationship constituted a ''perceived or real"conflict of interest pursuant to the Conflict of Interest andNepotism sections of the DOE, LIHEAP and ARRA contracts, 10CFR 600.142, 10 CFR 600.236 and the Texas AdministrativeCode, Title 10, Part I, Chapter 5, Subchapter A, Rule 5.10.Upon return to Austin, the Program Officer discussed this issuewith supervisors and was advised to tesolve this matterimmediately. The Department requested and received furtherinformation regarding this issue from the City of Lubbock underseparate covel'. The Department is currently reviewing thatinformation and will provide a written response to City of Lubbockpromptly.

    Texas Depmtment of Housing and Community Affairs Ptogram Officers, Matt Embryand Doug Misenheimer participated in: an exit conference with Bill Howerton:, BradReed, Rodney Durain, Russell Sell, Phyllis Brown, Joe Rangel and Rhonda Gentry.

    Matt Embry, Progrmn OfficerEnergy Assistance, TDHCA

    Date:

    Date:

    Signature: J 1 ~ ~ i - / . ~ : : : : = = = = : : - - - : ~ o u g Misenheimer, Program ,Officer.Energ Assistance, TDHCA

    Signature: _ h - ~ : : l ~ ~ ~ = = = - - -

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    2009 WEATHERIZATION MONITORING REPORTOF

    CITY OF LUBBOCK

    ATTACHMENT AUnits Fund Source Return CommentsInsDected

    09L027 I* LIHEAP No No issues.

    0908340* LIHEAP No No issues.

    09IN242* LIHEAP No No issues.

    09RU60S* DOE/LIHBAP Yes Return to bring attic insulation up to R-38.09RA240* LIHBAP No No issues.

    09MARI- DOB/LIHBAP No No issues.

    09SA290* ARRAlLIHBAP No No issues, final inspection.

    09MA230* LIHBAP No No issues.

    09T028 I * DOE/LIHEAP No No issues.

    09EV231* DOE Yes Oven CO is 190 PPM. Stove replacement. Bathroomexltaust fan 'eplacement.

    09BR213* DOE/LIHEAP No No issues.

    09REND- LIHEAP No No issues.

    09LU560* DOE No No issues.

    09BR301* DOE/LIHEAP No No issues.

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    TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRSwww.tdhca.state.tx.us

    Rick PerryGOVERNOR

    Michael GerberExBCUTIVE DIRECfOR

    July 9, 2010Mrs. Merita SandovalCommunity Development DirectorCity ofOdessa119 W 4th Street, Suite 104Odessa, TX 79761

    BOARD MEMC. Kent Conine, CGloria Ray! Vice CLeslie Bingham EscuTom H. GLowell A.]1l311 S. Mufioz. P

    Re: Department ofEnergy ARRAWeatherizationAssistance Program Contract #16090000749

    Dear Mrs. Sandoval:Enclosed is a report that details the unit inspection review of City of Odessa's WeatherizationAssistance Program contract with the Texas Department of Housing and Community Affairs (TheDepartment). This information is provided to ensure that compliance with the contract ismaintained and that services to the poor, elderly, and disabled are offered in the most expeditiousand economical manner.The monitoring report includes two (2) findings. Please submit a response to this report to thisofficewithin thirty (30) days of the date of this letter.If we can be of any assistance, please feel free to contact Rosy L. Falcon, Program Officer, at(512) 936-7810. The assistance provided to the Program Officer by the agency is greatlyappreciated.Sincerely,"'67 )Sharon GambleManagerCommunity Affairscc: Richard MOlton

    221 EAST liT" P. O. Box 13941 AUSTIN. TEXAS 7 8 7 1 1 ~ 9 4 1 (800) 525-0657 (512) 475-3800() Pr/I/uaOjl flqr/tdP"ltt

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    PY 2009 WA P UNIT INSPECTION IUPORTCITY OP ODeSSA

    WEATHERIZATIONASSISTANCE PROGRAM (WAP)CORRECTIVE ACTION REQUIRED AND RECOMMENDED IMPROVEMENTS

    Dates of Review: May 25 - 27,2010

    Focus OF REVIEW

    CONTRACTNAME CONTRACT CONTRACT CONTRACTDATESNUMBER AMOUNTDOE/ARRA 16090000749 $585,091.00 9/1/2009 to 8/31/2011

    PROGRAM EVALUATIONThe evaluation of the program consisted of client file reviews, on-site inspections, interviews withclients, and analysis ofboth quality of subcontractor workmanship and final inspection techniques.The following was noted during the review: The Building WeatherizationReport (BWR) did not mirror the audit in ten (10) files. The Blower Door Data form was incomplete in ten (10) files. Documentation verifying Lead Safe Work Practices was not included in two (2) files. Subcontractor workmanship deficiencies on ten (10) client units inspected.

    Client File ReviewFinding #1:

    ActionRequired:

    A review of City of Odessa's client files revealed inaccurately completeddocumentation in all ten (10) files. The BWR documentation in all ten (10)files did not mirror the NEAT Audits, they were not recorded in Savings toInvestment Ratio (SIR) order, and the incorrect categories were charged forvarious items. The Blower Door Data Sheets were incomplete; all files weremissing the final blower door reading, files CD-10-061 and CD-10-037 aremissing all fields except for the initial blower door reading, and file CD-10-012 is missing the Building Tightness Limit formula. Files CD-lO-001 andCD-10-030 did not contain sufficient documentation to complywith the LeadSafe Work Practices.City ofOdessamust verify that all documentation is adequately completedfor all future projects. All items on the BWRmust be entered in ranking SIRorder showing the measure with the highest SIR first and in descending order.The CombustionAir charge must be charged to Health and Safety from all

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    PY 2009 WAP UNIT INSPECTION REPORTCITY OF ODESSA

    files and the Shower Head charge must be charged to regular measures andtaken offHealth and Safety in files CD-10-028. CD-10-061. CD-lO-022, CD10-030, and CD-IO-OS8. City of Odessa must submit their reviseddocumentation as part of their response to this report. Reference: ARRAContract Section 13. Record Keeping Requirements, Code of FederalRegulations 440.24, Texas Administrative Code 5.524, TexasAdministrative Code 5.530.

    Performance ReviewFinding #2: Onsite home inspection of weatherized units revealed that ten (10) of the ten(10) units inspected would require a return to address deficiencies insubcontractor workmanship. Deficiencies included: no evidence of patchingwork in the domestic water heater and furnace closets (insulation was insidethese closets and some of the combustion air pipes), inadequate installation ofpipe and tank insulation, lack of clearance around Single Wall Vent in attic,lack of damming around the range hood vent (insulation was falling onto thestove), lack of insulation rulers, lack of adequate attic hatch blocking (currentblock is not properly securing the insulation), and no evidence of patchingwork being done in the domestic water heater closet and furnace closet.Action Required: City of Odessa must return to the client units listed in Attachment A andaddress the deficiencies noted on each unit. City of Odessa must also assurethe Department in its response to this report that proactive measures will betaken to prevent future instances of poor workmanship from itssubcontractors. Those measures at a minimum should include periodic visitsto client units while work is in progress, to ensure that the quality of workthat is being performed meets City of Odessa's requirements, and theDepartment's expectations. Reference: 10 CFR Part 440 Appendix A; 10

    CFR Part 440.16 (g), Weatherization Field Guide, 2006 InternationalResidential Code R.808.1 Insulation Clearance,

    Texas Department ofHousing and Community Affairs representative Rosy L. Falcon participated inan exit conference with City ofOdessa representatives Merita Sandoval and Jamie Minor.

    Si

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    PY 2009 WAP UNIT INspeCTION REPORTCITYOF ODeSSA

    ATTACHMENT AUnits Fund Return CommentsInspected Source

    Address pipe and tank insnlation of the water heaterSeal the furnace closetand repab' the moisture damage on theceiling immediately in front ofthe furnace closet.Provide a furnace cleaning and tune up.ARRA Yes Address the patching work needed in both the furnace and waterheater closets.Add insulation ruler(s) in the attic.

    PreWAP: 1380 CFMsoMonitoring: 2 I45 CFMsoReplace smoke detector.Address pipe and tank insulation of the water heaterAddress the patching work needed in both the furnace and waterheater closets.

    - - ARRA Yes Address attic hatch.Provide the water heater flue pipe a 3 inch clearance fromcombustible materials in the attic.Add insulation mler(s) in the attic.PreWAP: 2450 CFMsoMonitoring: 2220 CFMs,Address pipe and tank insulation of the water heaterSeal the furnace closet and water heater closet.Address the patching work needed in both the furnace and water.- heater closets.ARRA Yes Add insulation mler(s) in the attic.Provide the water heater flue pipe a 3 inch clearance fromcombustiblematerials in the attic.PreWAP: 1980 CFMsoMonitoring: 2535 CFMsoReplace smoke detector.

    Address pipe and tank insulation of the water heaterAddress the patchingwork needed in both the furnace and water... ARRA Yes heater closets.Repair attic hatch.Add insulation ruler(s) in the attic.PreWAP: 2150 CFMsoMonitoring: 772 CFMsoSeal around range hood to prevent insulation from entering theunit.Address pipe and tank insulation of the water heaterSeal the furnace closet.Address the patching work needed in both the furnace andwater

    .-rARRA Yes heater closets (hole in ceiling ofwaterheater closet.)

    Address combustion air pipe in thewater heater closet.Add insulation mler(s) in the attic.Providethewater heater flue pipe a 3 inch clearance fromcombustiblematerials in the attic.PreWAP: 1930 CFMs,Monitoring: 976 CFMs,CarbonMonoxide detector needed (already paid for by program)

    ARRA Yes Seal around range hood to prevent insulation from entering theunit.Address oioe and tank insulation of thewater heaterPage 3 of4

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    PY 2009WAP UNIT INSPECTION REPORTCITV OF ODESSASeal the furnace closet and water heater closet.Address the patchingwalk needed in both the furnace and waterheater closets.Fix attic hatch.Provide the water heatet flue pipe a 3 inch clearance fromcombustible materials in the attic.Pre WAP: 1970 CFMsMonitorin :2050 CFMs

    ARRA

    ARRA

    ARRA

    ARRA

    Yes

    Yes

    Yes

    Yes

    Replace smoke detector.Address pipe and tank insulation of the water heaterSeal the furnace closet and watet heater closet.Address the patching worle needed in both the furnace and waterheater closetsAdd insulation raler(s).Provide the water heater flue pipe a 3 inch clearance fromcombustible materials in the attic.

    Pre WAP: 1975 CFM,.Monitorin : 1955 CFM,.Seal the furnace closet and water heater closet.Address the patching work needed in both the furnace and waterheatet closetsPtovide the water heater flue pipe a 3 inch clearance fromcombustible materials in the attic.Add insulation ruler(s).

    Pte WAP: 2360 CFM,.Monitorin :2005 CFMsReplace Carbon Monoxide detector.Seal the furnace closet and water heater closet.Address the patching work needed in both the furnace and waterheater closetsAddress combustion air pipe in the water heatet closet.Provide the waleI' heatet flue pipe a 3 inch clearance fromcombustible matetials in the attic.Pre WAP: 1970 CFM,oMonitorin : 2100 CFMsoSeal around rangehood to prevent insulation from entering theunit.Seal the furnace closet.Addtess the patching wotk needed in both the furnace and waterheater closetsRepair escutcheon plate.Provide the waleI' heatet flue pipe a 3 inch clearance fi'omcombustible materials in the attic.

    Pte WAP: 1850 CFMsoMonitotin : 2070 CFM,oCity ofOdessa must return and address all units as indicated and include in its response to thisreport a summary of all actions and measures taken to address the units indicated above.

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    TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRStf}WW. tdbca.stttte. (X . tIS

    Rick PerryGOVERNOR

    Michael GerberExHCUTIVE DIRECfORJuly 28, 20 I0

    Ms. Phyllis CookExecutive DirectorPanhandle Community ServicesP.O. Box 32150Amarillo, Texas 79120-2150Re: DOE Weatherization Assistance Program Contract# 56090000468LIHEAP Weatherization Assistance Program Contract # 81090000501ARRA Weatherization Assistance Program Contract # 16090000670Dear Ms. Cook:

    BOARD MEMBERSC. Kent Conine. ChaitGloria Ray, V'CQ GIMhLeslie Bingham EscarefioTom H, GallnLowel l A. KeigJuan S. MuIioz. Ph.D

    Enclosed is a report that details the monitoring review of Panhandle Comm1mity Services (PCS)Weatherization Assistance Program contracts with the Texas Department of Housing andCommunity Affairs (The Department). This information is provided to ensure that thecompliance with the contracts is maintained and that services to the poor, elderly, and disabledare offered in the most expeditious and economical manner.The monitoring report includes four (4) findings and two (2) recommendations. Please submit aresponse to this report to the office within thirty (30) days of the date of this letter. A copy ofthis monitoring repOit will be provided to your board chair.If we can be of any assistance, please feel free to contact Brian P. Fayhee, Program Officer, at(512) 475-3822. The assistance provided to the Program Officer by the agency is greatlyappreciated.Sincerely,t D Sharon GambleManagerEnergyAssistance Sectioncc. Judge Ronnie Gordo, PCS Board Chair

    221 EAST 11 TH P. O. Box 13941 AUSTIN, TBXAS 78711-3941 (800) 525-0657 (512) 475-3800() Prlllyd till rtqdfdPllit1

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    Section I.Section II.Section III.

    Directory ofMonitoring Sections

    Financial ReviewTravel and TimesheetsGeneral Liability and Pollution OccurrenceInsurance

    Section IV. Property ManagementSection V. ProcurementSection VI. AuditSection VII. Personnel Policies and PracticesSection VIII. Performance ReviewSection IX. Client File ReviewSection X. Multi-Family ReviewSection XI. Denied FilesSection XII. Summary

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    Dates of Review:

    2009 WEATHERIZATION MONITORING REPORTOF

    PANHANDLE COMMUNITY SERVICES

    March 29- April 1, 2010

    Focus OF REVIEWCONTRACTNAME CONTRACT CONTRACT CONTRACTDATESNUMBER AMOUNT

    DOE 56090000468 $643,857.00 4/1/2009 to 3/3l!20 10LIHEAP 81090000501 $806,233.00 411/2009 to 3/31/2010ARRA 16090000670 $3,093,124.00 9/112009 to 8/31/2011

    .. Latest contract amendmentsOn-site review of the Panhandle Community Services, (PCS) implementation of theDepartment of Energy's (DOE) and Low Income Home Energy Assistance Program's(LIHEAP) Weatherization Assistance Program (WAP) and the DOE American Recoveryand Reinvestment Act WAP (ARRA). Specific areas of review included FinancialReporting, Contract Agreements, Procurement, Personnel, and the Management of theDepartment ofEnergy and Low Income Home Energy Assistance Program contracts.

    PROGRAM EVALUATION

    The evaluation of the program consisted of: interviews with the PCS personnel, analysisof the fiscal system, review of programmatic records, on-site inspections, clientinterviews, and inventory review.The following was noted during the review:

    High Cost Per Unit in LIHEAP Program Untimely submittal ofExpenditure Reports Lead Safe Work-Client Information Denied Files-Incomplete, Appeals Procedure, Denial Procedure

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    2009 WEATHERIZATION MONITORING REPORTOF

    PANHANDLE COMMUNITY SERVICES

    EXPENDITURES AS OF MAY 2010

    CONTRACT COST PER UNIT % OF ORIGINAL # UNITS # UNITS INNAME CONTRACT COMPLETED PROGRESSAMOUNT *DOE $4,545.27 81.99% 90 0

    LIHEAP $4,038.98 50.82% 78 7ARRA $5,390.26 7.48% 32 14

    Section I. Financial Review

    FiDlling #1: Late submittal of expenditure reportsPCS was delinquent for submittal of expenditure reports for DOE,ARRA, and LIHEAP. July's DOE and LIHEAP reports weresubmitted on August 18 th, 2010. Novembers DOE ARRA reportwas submitted on December 11 th , 2010.Action Required: The Department requires PCS to submit DOE and LIHEAPexpenditure reports on or before the 15 th of each following month,

    and submittal ofARRA reports by the 5th of the following month.Reference: DOE Contract, Section 11, (A); LIHEAP Contract;Section 10, (A); and ARRA Contract, Section 11, (A).

    Recommended Improvement #1: At the time of the review PCS exceeded the Cost PerUnit requirements LIHEAP contract. Reported data for the final program reportsubmitted in May, 2010 for of the LIHEAP indicates that PCS is $38.96 above thecontractual amount for Cost Pel' Unit (CPU). Prior to finalizing future reports PCS willproperly expend all LIHEAP funds for the contractual amount.

    Section V. ProcurementRecommended Improvement #2: A review of the bid packet revealed that the bid formprovided for the contractors did not contain separate categories for material and laborestimates. The Department recommends that PCS revise the bid form to reflect materialand labor estimates.

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    2009 WE A T H E R IZ A T IO N MO N I T O R I N G R E P O R TOF

    PANHANDLE C O MMU N IT Y SERVICES

    Section VII. Performance ReviewFinding #2:

    Action Required:

    Lead SafeWorks Practices (LSW)During the onsite review of 12 units, 3 separate clients stated thatthe contracted workers performing weatherization work did notperform adequate Lead Safe Work Practices. nor provide onsiteeducation to the client about Important Lead Hazard Information.The Department requires PCS to establish a quality assurance planfor Lead Safe Work Practices and submit a copy of this plan to theDepartment as part of the response to this report. The Departmentrequires PCS to provide training for all WAP staff regarding theproper overall procedures for LSW, which includes onsiteeducation. Documentation of this training including a roster o fthose in attendance will be submitted as part of the response to thisreport. Onsite inspections are required and must be documented byPCS weatherization staff while weatherization work is beingcompleted on residences and multifamily units that require LeadSafe Renovating. Reference: Texas Administrative Code, Title10, PaI't 1, Chapter 5 Rule 5.524; EPA Final Rule

    ,

    Section VII. Client File ReviewFinding #3: Incomplete assessment formReview of client files indicated that three client files hadincomplete blower door data forms, showing lack of signatures on

    the initial assessment (09PT039. 09RN026), and final inspection(09GR051),Action Required: The Department requires that PCS implement in their StandardOperating Procedures to make it mandatory for staff to sign alldocumentation when weatherization work has been performed orassessments have been conducted. Reference: TexasAdministrative Code, Title 10, Part 1, Chapter 5, SubchapterE, Rule 5.530; 10 CF R 440.2

    Section X. Multi-Family ReviewNote: Two multi-family units were reviewed and determined as incomplete due to lateshipments of refrigerators and stoves, The late shipments prevented a final inspection ofthe units. The blower door was set up and administered on each unit indicating that oneunit had issues that needed to be addressed before the unit could be deemed weatherized.Unit 201B, Job #2009PT040 has air infiltration on the bottom left of the back doorreleasing a substantial amount of ail'. Prior to finalizing the unit PCS must return to theunit and administer C.O. testing and prevent ail' infiltration in the bottom left of the backdoor,

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    2009 WEATHERIZATION MONITORING REPORTOF

    PANHANDLE COMMUNITV SERVICES

    Section XI. Denied FilesFinding #4: Denied File Documentation

    A review of denied files revealed incomplete 01' inadequatedocumentation, specifically; incomplete applications due to lack ofsignatures required by PCS employees, and missing incomedocumentation.Action Required: The Department requires PCS to provide training to all WAP staffregarding documentation requirements for denied files. TheDepartment requires PCS to provide written documentation of thistraining and a roster of those in attendance as palt of the responseto this repOlt. Reference: Texas Administrative Code, Title 10,

    Part 1,Chapter 5, Subchapter E, Rule 5.505Texas Department ofHousing and Community Affairs Program Officers, participated inan exit conference with Phyllis Cook, Angela Ascencio, Ken Rusler, Doug Burton, andCarol Luke,

    Signature: 4 ~ U 1 3 r i a 1 1 l l Y h ~ e , ~ ~ m Officer

    Page 5 of6

    Date: 1 # ~ 1 t ( /

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    2009 WEATHERIZATION MONITORING REPORTOF

    PANHANDLE COMMUNITY SERVICES

    DOE/LIHEAPUnits Inspected 4- - - Units Inspected Returns__O__

    09PT11109RN02609PT086

    ATTACHMENT A

    DOE/LIHEAP No return required.DOE/LIHEAP No return re uired.DOE/LIHEAP No return re uiredDOE/LIHEAP No return re uired.

    Page 6 of6

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    TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRSUJtvw. tdhca.state. tXt us

    Rick PerryGOVERNOR

    Michael GerberExEcUTlVE DIRECTOR

    July 19,2010Mr. Felix TaylorExecutive DirectorRolling Plains Management CorporationP.O. Box 490Crowell, Texas 79227

    BOARD MBMBC. Kent Conine, ChGloria Ray. Vice ChLeslie Bingham EscarcTom H. GaLoweJl A. KJuan S. Muiioz, Ph

    Re: ARRAWeatherization Assistance Program Contract #16090000675Dear Mr. Taylor:Enclosed is a repOlt that details the unit inspection review of your American Rec;very andReinvestment Act (ARRA) Weatherization Assistance Program (WAP) contract with the TexasDepartment ofHousing and Community Affairs (the Department). This information is providedto ensure that compliance with the contrac is maintained and that services to the poor, elderly,and disabled are offered in the most expeditious and economical manner.The Department has identified one (1) finding requiring corrective action for the WeatherizationAssistance Program. Please submit a response to this repolt to this office within thirty (30) daysof the date of this letter.If we can be of any assistance, please contact Jason A. Seale, Program Officer, at (512) 4630172. The assistance provided to the Program Officer by Rolling Plains ManagementCorporation is greatly appreciated.

    -Sharon GambleManagerEnergyAssistance Section

    2Z1 EAST liT" 1'. O. Box 13941 AUSTIN, TRXAS 787113941 (800) 525-0657 (512) 475 3800

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    PY09 ARRA WAP UNIT INSPECTION REPORTOF

    ROLLING PLAINS MANAGEMENT CORPORATION

    WEATHERIZATION ASSISTANCE PROGRAM (WAP)CORRECTIVEACTION REQUIRED AND RECOMMENDED IMPROVEMENTS

    Dates ofReview: June 7,2010 - June 9, 2010

    FoCUS OF REVIEW

    CONTRACTNAME CONTRACT CONTRACT CONTRACT DATESNUMBER AMOUNT

    DOE/ARRA 16090000675 $1,660,427.00 9/1/2009 to 8/31/2011

    PROGRAM EVALUATIONThe evaluation of the program consisted of sixteen (16) client file reviews,. fifteen (15) on-siteinspections, interviews with clients, and analysis of both quality of subcontractor workmanshipand final inspection techniques.The following was noted during the review:

    Subcontractor workmanship deficiencies on one (1) client unit inspected.

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    Finding #1:

    ActionRequired:

    PY09 ARRA WAP UNIT INSPECTION REPORTOF

    ROLLING PLAINS MANAGEMENT CORPORATION

    Performance ReviewOn-site home inspection ofweatherized units revealed that one (1) of thefifteen (15) units inspected would require a return to address deficienciesin subcontractor workmanship. Deficiencies include additional ventilationto bring the unit above the Building Tightness Limit (BTL).RPMC must return to the client unit listed in Attachment A, and addressthe deficiency noted. RPMC must also assure the Department in itsresponse to this report that proactive measures will be taken to preventfuture instances of poor workmanship from its subcontractors. Thosemeasures at a minimum should include periodic visits to client units whilework is in progress, to ensure that the quality of work that is beingperformed meets RPMC's requirements, and the Department'sexpectations. Reference: 10CFR Part 440; 440.16 (g)

    Jason A. SealeProgram Officer, Energy Assistance

    2

    Date

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    PY09 ARRA WAP UNIT INSPECTION REPORTOF

    ROLLING PLAINS MANAGEMENT CORPORATION

    ATTACHMENT A

    Units Inspected -'15 ARRA Unit Returns - 1 ARRAUnits Fund Return CommentsInspected Source... ARRA Ves Return to install additional ventilation to bring unit above theBuilding Tightness Limit (BTL)- ARRA No No returns.., ARRA No No returns.., ARRA No No returns. . ARRA No No returns., ARRA No No returns. . ARRA No No returns. . ARRA No No I'etums ARRA No No retums. . ARRA No No returnsARRA No No retums. . ARRA No No retums-- ARRA No No returns-.w ARRA No No retums.., ARRA No No returns

    3

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    TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRSwww.tdhca,state.lx.ttl

    Rick PerryGOVERNOR

    Michael Gerberl l i r n c ~ N J e n ~ ~ 8 ~ 2 0 1 0

    MI'. Laurence DoxseyEnvironmental Policy DirectorCity of San AntonioP.O. Box 839966San Antonio, Texas 78283Re: DOE/ARRAWeatherization Assistance Program Contracts#16090000751DearMI'. Doxsey:

    BOARD MSMOC. Kent ConIne, CGloria Ray, ViC8 CLeslie Bingham EscarTom H. GLowell A. KJuan S. MUfloz., Ph

    Enclosed is a report that details the follow-up monitoring of the City of San Antonio (COSA)Weatherization Assistance Program contract with the Texas Department of Housing andCommunity Affairs (The Department). This information is provided to ensure that compliancewith the contract is maintained and that services to the pOOl', elderly, and disabled are offered inthe most expeditious and economical manner. 'The monitoring repOlt includes six (6) findings and one (1) recommended improvement. Pleasesubmit a response to this report to this office within thirty (30) days of the date of this letter.Ifwe can be of any assistance, please feel free to contact J.R. Mendoza, Senior Program Officer,at (512) 936-7811. The assistance provided to the Program Officers by the agency is greatlyappreciated.Sincerely,VC) - -Shat'on D. GambleCommunity Affairs DivisionCc: Ms. Sheryl Sculley, CityManager

    221 EAST 11"H P. O. Box 1394[ AUSTIN, TEXAS 78711-3941 (800) 5250657 (5[2) 4753800o Prill/tilDIImyd,d paptr

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    2009 WEATHERIZATION MONITORING REPORTCITY OF SAN ANTONIO

    Dh'ectory ofMonitoring Sections

    Section I. Financial RepOl'lingSection II. Travel and TimesheetsSection III. General Liability and Pollution Occurrence InsuranceSection IV, Property ManagementSection V, ProcurementSection VI. AuditSection VII. Personnel Policies and PracticesSection VlII. Performance ReviewSection IX. AdministrationSection X. MultifamilySection XI. Denied Files

    PAGE 2 OF 8

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    Dates of Review:

    2 0 0 9 WEATHERIZATION MONITORING REPORTCITY O F SAN ANTONIO

    May 10-13,2010

    F o C U S OF REVIEW

    CONTRACTNAME CONTRACT CONTRACT CONTRACTDATESNUMBER AMOUNTDOEARRA 16090000751 $6,213,863.00 9/1/2009 to 8/31/2011

    The May 10-13, 2010 on-site monitoring consisted of a review of the City of San Antonio (COSA)implementation of the Department of Energy's ARRA Weatherization Assistance Program. Specificareas of review included Financial Repolting, Contract Agreements, Procurement, Personnel, and theManagement of the Department of Energy and Low Income Home EnergyAssistance Program contracts,

    PROGRAM EVAI,UATIONThe evaluation of the program consisted of: interviews with the COSA personnel, analysis of the fiscalsystem, review of programmatic records, on-site inspections, client interviews, and inventory review,Additionally, CaSA subcontracts the programmatic portion o f the weatherization program to City PublicService (CPS), the utility provider for the City of San Antonio and surrounding areas. Progl'ammaticmonitoring was conducted at the CPS offices. This is the first year that CaSA and CPS have operated aWeatherization Program from TDHCA, COSA performs the administrative oversight of the progmm andCPS conducts the outreach, intake, unit assessment, creation of work ordel's, manages the constructionsubcontractors who install the weatherization measures, performs the final inspections and maintain clientfiles. CPS incurs the costs of program staff, weathcrization materials and labor then requestsreimbursement from CaSA,

    The following was noted dul'lng the review: LIHEAP Administrative expenditure percentage is above the allowable maximum of 5% InconsistentBlower Door readings No documentation of compliance with 10 CPR 44 0 Appendix A No documentation ofLead Safe Work (LSW) practices A whole house evaluation was not thorough Missing documents in the client files Incorrect income documents were used to determine program eligibility

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    2009 WEATHERIZATION MONITORING REPORTCITY OF SAN ANTONIO

    Section I. Financial ReportingEXPENDITURES AS OF AUGUST 2009

    CONTRACT YEAR-TODATE % OFORIGINAL #UNITS #UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESSAMOUNT

    DOEARRRA $350,519.10 6% 113 266

    Recommended Improvelnent #1: At the time of monitoring, COSA Administrative expenditurepercentage was at 9% which is above the maximum allowable percentage of 5%. TheDepaliment reminds COSA that the Administrative expenditure percentage must be at 01' below5% by the end of the contract period. Failure to bring the Administrative percentage below themaximum will result in disallowed costs.

    Reference: Contract Attachment A

    Finding #1:

    ActionRequired:

    Finding #2:

    Requh'edAction:

    Ineonsistant Blower Door Readings A review ofBlower Door Data Sheetsshowed inconsistent initial blower door readings compared to other initial and finalblower door readings. Multiple blower door data sheets had initial readings ofaround 800 cfm at 50 pascals and the final blower door readings were above 1500cfm with no measures performed to increase ail' infiltmtion.

    As part ofthe response to this report, COSA must provide an assurance that allblower doors will be performed according to the manufacturer directions. Thiswill provide the highest possibility of obtaining the correct reading on a unit. Inaddition, if training is required on the use of the blower door, a training requestshould be documented in the response to this report.Reference: Texas B1owel' Door StandardsInadequate SUPJ)ort Documentation for Material Stundards At the time ofmonitoring, COSA did not have documentation that all weatherization materialsinstalled by its contractors, met the minimum standards as stated by DOE. Failureto ensure each product meets DOE requirements will result in disallowed costs.

    A copy of all material products used by each of its contractors must be maintained.In addition, each product must conform to DOE minimum standards. As part of theresponse to this repoli, COSA must provide a copy of the materials requiringspecification, from each contmctor. In addition COSA must provide an assurancethat a file will be maintained to ensure all materials installed meet DOErequirements.

    PAGE 4 OF 8

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    Finding #3:

    RequiredAction:

    2009 WEATHERIZATION MONITORING REPORTCITY OF SAN ANTONIO

    Inadequate Support Documentation for LS W Practices At the time ofmonitoring, there was no documentation of LSW practices being performed onweatherized units built pre1978. To ensure compliance that LSW practices arebeing performed according to EPA guidelines, policies should be created thatdetail the procedures to ensure LSW will be performed on each unit, whenapplicable and the process to verify that the practices are being performed. At aininimum, contractors should provide pictures of LSW practices on each unit andCOSA or CPS should provide on-site verification of, LSW practices, on a certainpercentage of pre-I 978 units.

    As part of the response to this report, COSA must ensure that verification of LSWpractices will be performed. In addition, COSA should provide a copy of the policythat details how the verification will be performed.Reference: DOE WPN 09-6 and EPA Final RuleFinding #4: Deficiencies in ansite Inspections Onsite inspection of weatherized units notedthe following:A) Assessments of window air conditioners did not meter the unit to obtain theexisting efficiency. Assessments contained efficiencies of the unit at the time itwas manufactured. Obtaining efficiencies from the date the unit wasmanufactured may result in unreliable SIR readings in the NEAT audit.B) Propel' tools and equipment were not purchased to perform thorough finalinspections. Where as onsite unit inspections did not reveal major issues, finalinspectors did not have adequate ladders or drills to climb in to attics or to checkfor wall insulation.C) An inspection of six (6) weatherized units, revealed two (2) units where exteriorwalls were not insulated. To comply with DOE and the State Historic reviewrequirements CPS attempted to insulate exterior walls through the interior. In thetwo (2) units noted above, clients refused to have the wall insulated through theinterior. CPS did not contact SHPO for approval to insulate the wall(s) throughthe exterior. This resulted in the wall(s) not being insulated, reducing the potentialfor additional energy savings. A SHPO review of the work order and otherrequired documents, will provide the needed documentation to determine ifcertain weatherization measures can be performed.D) Revealed a return on each unit to address additional weatherization measures ormeasures that were not installed correctly. An inspection of two (2) units revealedheat sources not being blocked. In addition, in one (1) unit the contractor closedoff the retul'll air access for the air handler and in another unit, the contractor

    installed the floor insulation incorrectly.RequiredAction: As part of the response to this report,

    A) COSA must assure the Department that all window air conditioning units will bemetered to obtain the existing efficiency and that these efficiencies will be

    PAGE50F8

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    2009 WEATHERIZATION MONITORING REPORTCITY OF SAN ANTONIO

    documented in the assessment, COSA must also provide documentation of whattools or equipment (watt meters) was purchased to obtain the required readings.Reference: DOE ARRA Contract Section 13B) COSA must assure the Department that final inspectors will have the essential

    tools to provide a more thorough final inspection. COSA must providedocumentation of the tools that were purchased. At a minimum, the Departmentrecommends "A" frame ladders, drills, flashlights and screw drivers.Reference: DOE ARRA Contract Section 13C) COSA must develop a policy and assure the Department that all weatherizationmeasures will be addressed regardless if it requires a review by SHPO, COSAmust provide a copy of the policy with the response to this repOlt.Reference: DOEARRA Contract Section 11D) COSA must return to each unit and address all items as noted in Attachment A of

    this repOlt. As part of the response to this report, COSA must providedocumentation of the corrections.Reference: DOE ARRA Contract Section 11Finding #5:

    ActionRequh'ed:

    Finding #6:

    ActionRequired:

    Incomplete Blower Door Data Sheets A review of ten (10) client files revealedBlower Door Data Sheets in four (4) client files that did not contain signatures ofthe individuals performing the Blower 0001' reading. In addition, three (3) clientfiles did not contain documentation that the clients received the Lead safetypamphlet,As part of the response to this report, COSA must provide an assurance and detailhow it will ensure a1l required documents and forms will be completed andmaintained in the client file, when applicable, COSA must return to 9316BARR,9245ROUN and 9446MCKI to obtain a signature on the receipt of the Lead SafePamphlet and as part of the response to this report, provide a copy of thesereceipts, Refel'ence: DOE ARRA Contract Section 13Denied File Deficiency A review of five (5) Denied files revealed one (1) file where theW-2 tax document was used to determine income eligibility, The use of the W-2document resulted in the denial of services for client 9807LAMA. Pl'Ogratn requirementsrequire income documentation fl'om the previous thirty (30) days from the date ofapplication,

    As part of the response to this report, COSA must provide an assurance that programeligibility determinations will be derived f1'om the previous thirty (30) days income fromthe date of application. .In addition, COSA must notify client 9807LAMA, that it willreview its application and that updated income documentation must be submitted fordetermination of program eligibility. As part of the response to this repOlt, COSA mustprovide an llpdate on the status ofthis clients application.Reference; DOE ARRA Contl'llct Section 13

    PAGE60F8

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    2009 WEATHERIZATION MONITORING REPORTCITY OF SAN ANTONIO

    Texas Depmtment of Housing and Community Affairs representative, J.R. Mendoza participated in anexit conference with MI'. Laurence Doxsey, MI'. Philip Gates, Ms. Faouzia Stanley, Ms. Sarah Kirby andMs. Maria Koudouris.

    1 ~ : ? 7 ?eedonioMendoza Jr.Senior Progmm Officer

    PAGE70F8

    rt/o /.2-&/0Date

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    2009 WEATHERIZATION MONITORING REPORTCITY OF SAN ANTONIO

    ATTACHMENT A

    [ ~ r . ~ I J q ; ~ i . ~ ~ ~ ~ ~ ~ ~ & ; ; B * U ! J ~ ; ~ I : : ; , : ; i ~ f ( i ! ~ l i ! ! r : ~ ~ Y : t f h . i ~ ' ! \ \ ~ ~ ~ ) ; ! ! : l : : I \ I I ~ r 1 i ' ) 1 \ ~ ~ ' i i i l ~ l k ~ ~ ! i l i l t ~ { , J ! I , t ~ I , ' < ' 1 ? 1 ~ ~ J ( W ~ 1 1 1 ) t l t ~ i ~ I f . 4 l ~ , t ~ l t . ~ ' 1 r l \ i J l \ j \ \ \ \ ~ i l f i { : ;':;'1:',;,,, '.". [, .'\\;"" /:'1, ,,: ' , ~ , );:7" ~ < ~ I I : ~ ' , " " , ' ~ : ( , , 1 1 ~ ; r"liL.,. 1,::1..\ x c p ~ ~ ~ I,ll', ,11, ' " . , ." ,,:. ,'. t , n ~ \ > ' < , J 3 ' ' ' ' ~ ! " d , t 1 , : , I L 1 . : , ; . ~ ; ~ ~ ' , ' ~ ; '( , , , ~ "", " " l . h ~ '9137ARLI ARRA Block Heat sources95442SANT ARRA Weatherstrip door to the furnaceBlock around furnace accessProvide additional return air for air handler9140BETA ARRA Address wall Insulation on exterior wallFloor insulation was installed Incorrectly. Removeand reinstall.9410RUNN ARRA Return and address ducts9245ROUN ARRA No Return9121ROUN ARRA No Return

    PAGE80F8

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    TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRSruww. tdhca.state. 'IX. us

    Rick PerryGOVERNOR

    Michael Gerber.E.x.nCUTIVll DIRI!CTOR

    July 23, 2010Mr. Robert PhilJipsExecutive DirectorSheltering Arms Senior Services, Inc.3838 Aberdeen WayHouston, Texas 777025Re: ARRA Weatherization Assistance Program Contract #16090000673Unit Inspection Report

    BOARD MBMBERC. Kent Conine, ChaGloria Ray, Vl(.'t' ChaLeslie Bingham EscarefTom H, GonLowel l A. KeJuan S. Mufioz, Ph,D

    Dear Mr. PhilJips:Enclosed is a report that details the unit inspection review of Sheltering Arms Senior Services, Inc.(SASS) Weatherization Assistance Progl'am (WAP) contract with the Texas Department ofHousing and Community Affairs (the Depmtment). This information is provided to ensure thatcompliance withthe contracts is maintained and that services to the poor, elderly, and disabled areoffered in the most expeditious and economical manner.The monitoring report includes four (4) findings. Please submit a response to this repolt to thisoffice within thirty (30) days of the date of this letter.Ifwe can be of any assistance, please feel free to contact David Escamilla, Sr. Program Officer, at(512) 475-3859. The assistance provided to the Program Officer by the agency is greatlyappreciated.Sincerely,

    Sharon GambleManagerEnergy Assistance Section

    Cc: Mr, Keith Rowden, Board Chair

    221 EAST 11" p, 0 , Box 13941 AUSTIN, TEXAS 787113941 (800) 5250657 (512) 4753800() /'tIl/ltd 1'1/ utltl,d ptlptr

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    PY09 ARRA WAP UNIT INSPECTION REPORTOF

    SHUTERING ARMS SENIOR SERVICES, INC.

    AMERICAN RECOVERY AND REINVESTMENT AC T OF 2009 (ARRA)WEATHERIZATION ASSISTANCE PROGRAM (WAP)

    Dates ofReview: May 10,2010 - May 13,2010

    F o C U S O F REVIEW

    CONTRACTNAME CONTRACT CONTRACT CONTRACTDATESNUMBER AMOUNT

    DOE/ARRA 16090000673 $11,176,032.00 9/1/2009 to 8/31/2011

    P R O G R A M EVALUATIONThe evaluation of the program consisted of eighty-three (83) client file reviews, eighty-three (83)on-site inspections, interviews with clients, and analysis of both quality o f subcontractorworkmanship and final inspection techniques.The following was noted during the review:

    Subcontractor workmanship deficiencies on seventeen (17) units requiring retUl'ns. Inadequate Chent FIle Documentahon Inadequate Energy Audit Procedures Inadequate Building Weatherization Reports (BWR)

    I

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    PY09 ARRA WAP UNIT INSPECTION REPORTOF

    SHELTERING ARMS SENIOR SERVICES, INC.Performance Review

    Finding #1: Unit Inspection ReturnsOn-site inspection ofweatherized units revealed that seventeen (17) of theeighty-three (83) units inspected would require a return to address issuesconcerning weather stripping installation, additional air infiltrationmeasures and addition of mechanical ventilation to bring two units abovethe Building Tightness Limit (BTL).Action Required: Sheltering Arms Senior Services, Inc. (SASS) must return to the clientunits listed in Attachment A, and address the issues noted. SASS must alsoassure the Department in its response to this report that proactive measuresin its final inspection procedures will be taken to prevent future instances

    of returns from its subcontractors. Those measures at a minimum shouldincludeperiodic visits to client units while work is in progress, to ensurethat the quality of work that is being performed meets the Department'srequirements and expectations. Reference: 10 CFR 44Q.16 (g)

    Finding #2: Inadequate Client File DocumentationA review of the client files revealed that SASS is not completingdocumentation as required by the contract. Of the eighty-three (83) clientfiles reviewed: Thirteen (13) files were missing appliance assessment forms. All eighty-three (83) files contained wall and attic inspection fOlmswith dates that are identical to the work end date on the BWR. One (1) file contained a final blower door data sheet completedbefore the work end date on the BWR.

    Action Required: SASS must provide the Department with a written procedure indicatinghow the ag.enc.y will comply with the requirement of completedocumentation as required by the contract. The written procedure must besubmitted in response to this report, Reference: ARRA ContractSection 13 (8)(11), ARRA Contract Section 13 (8)(12)

    2

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    PY09 ARRA WAP UNIT INSPECTION REPORTOF

    SHELTERING ARMS SENIOR SERVICES, INC.Finding #3 Inadequate Energy Audit Procedures

    Of the eighty-three (83) client flIes reviewed, seventeen (17) flIes revealedmeasures listed on the BWR that were not entered in the NEAT Audit. Nodocumentation was provided explaining the measures installed into theapplicable units without justification.

    Actioll Required: As part of the response to this report, SASS must input the omittedmeasures into in the NEAT Audit to determine if installed measures areallowable. Additionally, SASS must submit documentation to theDepartment for all measures installed in all applicable units and anypertinent documentation supporting if a measure was or was not allowableto be installed from the revised NEAT Audit. Any measure installed thatdoes not meet the criteria of a Savings-to-Investment Ratio (SIR) of one(I) or greater will be disallowed. A list of the referenced units can befound in Attachment B of this report. Reference: TAC 5.527 (ll)Finding #4 Iuadequate BuildiugWeatherization Reports (BWR)A review of the client files revealed that SASS is not completing theBWR's as required by the contract. One (I) client flIe did not contain theBuilding Weatherization RepOit (BWR), but was recovered prior toexiting the file review. The BWR was accurate once reviewed. Seven flIes. indicated that efficiency measures were not properly entered into theEnergy Audit.Action Required: SASS must provide the Department a written procedure indicating howthe agency will comply with the requirement of filling out the BWR as

    required by the contlact. The written procedure must be submitted inresponse to this report. Reference: ARRA Contract Section 13 (B)(4)

    Giovani" '0 ' iuncaProgram Officer, Energy Assistance

    Date

    Date

    3

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    ATTACHMENT AUnits Inspected - 83 ARRA

    PAGE10FS

    Unit Returns -17 ARRAUnits Insnected Fundinl> Sonl'ce Return Comments

    C2702 ARRA No No l'etu1'11s necessalYC0272 ARRA No No retu1'11S necessalYC2701 ARRA No No returns necessatyC2704 ARRA No No retums necessalYC2703 ARRA No No returns necessaryC02706 ARRA No No returns necessaryC2708 ARRA No No retul'ns necessalYC2709 ARRA No No returns necessalYC2710 ARRA No No returns necessaryC2711 ARRA No No I'eturns necessalYC209A ARRA No No returns necessalYC208A ARRA No No retul'lls necessaryC207A ARRA No No returns necessatyC0204C ARRA No No retul'lls necessaryC203 ARRA No No relul'lls necessary

    C0202C ARRA No No retul'lls necessaryC0200C ARRA No No returns necessaryC0199C ARRA No No retul'lls necessalYC0197C ARRA No No I'elul'lls necessal'Y207B ARRA No No retul'lls necessaryC2723 ARRA No No retul'lls necessalYC2722 ARRA No No l'etul'llS necessary

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    ATTACHMENT AUnits Inspected - 83 ARRA

    PAGE20F5

    Unit Returns - 17 ARRAUnits Iusneeted Fuudhll! Source Return Comments

    C2721 ARRA No No retul'Jls necessaryC2719 ARRA No No retul'llS necessalYC2717 ARRA No No relul'lls necessaryC2716 ARRA No No relul'lls necessalYC02715 ARRA No No relul'llS necessalYC02714 ARRA No No returns necessalYC02713 ARRA No No returns necessalYC02712 ARRA No No I'eturns necessaryCOI97B ARRA No No returns necessalYC0204A ARRA No No returns necessaryC0203A ARRA No No retu1'lls necessaryC0202A ARRA No No, returns necessaryC020lA ARRA No No returns necessatyCOl99A ARRA No No returns necessaryCOl98A ARRA No No returns necessalYC2705 ARRA No No returns necessalYC2724 ARRA No No returns necessatyC209B ARRA No No returns necessaryC204B ARRA No No returns necessaryC0203B ARRA No No retul'llS necessalYCOl98B ARRA No No retu1'lls necessatyC0200B ARRA No No reltu'ns necessary

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    ATTACHMENT AUnits Inspected - 83 ARRA

    PAGE30F5

    Unit Returns - 17 ARRAUuits Insllected Fuudin!! Source Return Comments

    COI06 ARRA No No retul'Us necessaryC0243 ARRA No No refums necessal'YC0244 ARRA No No returns necessaryC0245 ARRA No No retul'US necessal'YC0247 ARRA No No returns necessaryC0248 ARRA No No returns necessaryC0266 ARRA Yes Return to caulk/seal at window frame to h'hnC0268 ARRA Yes Return to adjustweatherstrip at HVACcloset door to frameC0269 ARRA Yes Return to adjustweatherstrll) at HVACcloset door to fmmeC0271 ARRA Yes Return to adjustweatherstrip at HVACcloset door to ti'ameC0228 ARRA No No returns necessaryC0262 ARRA No No returns necessal'Y .C0259 ARRA Yes BTL calculated at 932cfm@ 50Pa. Blower

    door reading at Inspcction was 747cfm@50Pa. Return to install additional vcntllatlonto bring unit above the BTL.C0215 ARRA Yes Retul'll to adjustweatherstrip at HVACcloset uoor to nameC0216 ARRA Yes Retnrn to adjust weatherstrip at HYACcloset door to frameC0221 ARRA Yes Return to adjust weatherstrip at HVACcloset door to frameC0222 ARRA Yes Return to adjustweatherstrip at HYACcloset door to frame

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    ATTACHMENT A PAGE40FSUnits Inspected - 83 ARRA Unit Returns -17 ARRA

    Units Ins ected Fundin Source Retul'll CommentsC0223 ARRA No No returns necessaryC0224 ARRA Yes Retnrn to adjust weatherstrip atHVAC .closet door to frameC0251 ARRA Yes Return to adjnst weatherstrip at HVACcloset door to fraUleC0254 ARRA Yes BTL calculated at 932cfin@ 50Pa. Blowerdoor I'eadlng at Inspection was 919clin@50Pa. Return to Install additional ventilationto bl'lug unit above the BTL.C0255 ARRA Yes Return to adjustweatherstrip atHVACcloset door to frameC02S8 ARRA No No returns necessaryC0260 ARRA No No returns ne,cessaryC026I ARRA No No returns necessary

    ARRA No No retums necessaryARRA Yes Returu to add weatherstripping to back doorARRA No No returns necessal'yARRA No No retums necessmyARRA Yes Retul'll to Ilatch holes in ceiling abovefurnaceReturn to place weatherstripping aroundurnace 001' 'aUleRetlll'll to add caulkiug to the bottom portion

    of both windows in north-facing bedl'oomupstairsARRA Yes Return to add weatllerstripping al'oundfurnace door fmUleARRA No No returns necessaty

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    ATTACHMENTA PAGE50F5Units Inspected - 83 ARRA Unit Returns -17 ARRA

    Fundin Source Retul'll CommentsARRA No No returns necessaryARRA No No returns necessaryARRA No No returns necessaryARRA No No returns necessaryARRA Yes Return to pateh sheet I'oel. in closet aroundfurnace to I'educe air Intlltratioll

    COl86B ARRA No No returns necessaryC20lB ARRA No No returns necessalY

    SASS must return and address all units as indicated and include in its response to this reportwithin thirty (30) days a summary 0/ all actions and measures taken to address the unitsindicated above.

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    ATTACHMENT BUnits Related To Finding #3 ofSASS rY09 ARRAWAr Unit Inspection Report

    C2708C02712C2709C02715C02714C02713C207AC02706C02707C2711C2721C2705C2716C2722C2701C2702C2703

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    TEXAS DEPARTMENT OF HOU'SING AND COMMUNITY AFFAIRSwww.tdhca.state.tx.us

    R l c k P ~ " yGOVERNOR

    Michael Gorber.Ex1lcUT1VB DIRECTOR

    June 3, 2010Mr. Bill PowellExecutive DirectorSouth Plains Community Action AssociationP. O. Box 610Levelland, TX 79336

    BOARD MEMBERC . Kent C on in e, ChflGloria Ray. Vice C/",;Leslie Bingham EscarellTom H. GaoLowen A. KelJuan S. Mufio>t, Ph.D

    Re: Department ofEnergy Weatherization Assistance Program Contract #56090000472Department ofEnergy ARRA Weatherization Assistance Program Contract #16090000676LIHEAP WeatherizationAssistance Program Contract #81090000505Southwestern Public Service Weatherization Program Contract#409066DearMr. Powell:Enclosed is a report that details the monitoring review of South Plains Community ActionAssociation's, Inc. (SPCAA) Weatherization Assistance Program contracts with the TexasDepmtment of Housing and Community Affairs (The Department). This information is providedto ensure that compliance with the contracts is maintained and that services to the poor, elderly,and disabled are offered in the most expeditious and economical mmmer.The monitoring report includes two (2) recommended improvements and twelve (12) findings.Please submit a response to this report to this office within forty-five (45) days of the date of thisletter.If we can be of any assistance, please feel free to contact Rosy 1. Falcon, Program Officer, at(512) 936-7810. The assistance provided to the Program Officer by the agency is greatlyappreciated.

    t J ~ e l ) ' __Sharon GambleManagerEnergy Assistance SectionCC: Joe Dee Brooks

    221 EAST 11 TH P. O. Box 13941 AUSTIN. TEXAS 78711-3941 (800) 525-0657 (512) 4753800( ) P,JI1"d 01/ rrqrl,d pnptT

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    Directory ofMonitoring Sections

    Section I. Financial ReviewSection II. Travel and TimesheetsSection III. General Liability and Pollution Occunence InsuranceSection IV. Property ManagementSection V. Procurement.Section VI. AuditSection VII. Personnel Policies and PracticesSection VIII. Performance Review and Onsite InspectionsSection IX. AdministrativeSection X. Client File Review Work Sheet and Multi-FamilyReviewSection XI. Denied FilesSection XII. Summary

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    Dates of Review:

    2009 WEATHERIZATION MONITORING REPORTOF

    SOUTH PLAINS COMMUNITY ACTION ASSOCIATION

    April 5-8, 2010

    Focus OF REVIEWCONTRACTNAME CONTRACT *CONTRACT CONTRACT DATESNUMBER AMOUNT

    DOE 56090000472 $182,303.00 4/112009 to 3/31/2010LIHEAP 81090000505 $202,041.00 4/112009 to 3/3112010

    DOEARRA 16090000676 $821,522.00 911/2009 - 8/3112011Southwestern Public Service 409066 $63,024.00 111/2009 to 12/31/2009

    >Ie Latest contract amendmentsOn-site review of the South Plains Community Action Association's, (South Plains CAA)implementation of the Department of Energy's and Low Income Home Energy AssistanceProgram's Weatherization Assistance Program (WAP). Specific areas of review includedFinancial Reporting, Contract Agreements, Procurement, Personnel, and the Management of theDepartment of Energy and Low Income Home Energy Assistance Program contracts.

    PROGRAM EVALUATIONThe evaluation of the program consisted of: interviews with the South Plains CAA personnel,analysis of the fiscal system, review of programmatic records, on-site inspections, clientinterviews, and inventory review.The following was noted during the review:

    Low Expenditures in ARRA, LIHEAP, and DOE contracts. Monthly genera11edgers did not reconcile with the expenditure reports submitted. DOE and LIHEAP Administrative expenditures were above the maximum allowed. Lack of support documentation for expenditures in PY 09 and PY 08 closeout.

    PAGE 2 OF 13

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    2009 WEATHERIZATION MONITORING REPORTOF

    SOUTH PLAINS COMMUNITY ACTION ASSOCIAnON Stafftimesheets contained inadequate information. Travel funds were used for an unapproved training event. Lack of documentation for maintenance ofequipment and vehiCle. Contractor contracts lacked the "Rights to Inventions Made Under a Contract or

    Agreement" clause. PersOlmel Policies lacked compliance with protection against "political affiliation or

    belief." Lack of documentation of services and outreach efforts in Bailey and Yoakum

    Counties. Energy Audits completion date was the same date as the weatherization work

    completion date. Health and Safety, Attic, Foundation, Window, Mobile Home, Water Heater,

    Baseload Measures, Air Conditioning, and Energy Repair Measures were notadequately addressed.

    Weatherized homes were found to have various deficiencies in measure installation. Weatherized homes with gas appliances did not have a Carbon Monoxide detector

    andlor smoke alarm installed. Incorrect R-values, Heating/Cooling Costs, and Appliance Efficiencies were inputted

    into the audit and the Building Weatherization Report had significant deficiencieswhen compared to the Audit.

    Client files were incomplete and were found to have insufficient information.

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    2009 WEATHERIZATION MONITORING REPORTOF

    SOUTH PLAINS COMMUNITY ACTION ASSOCIATION

    Section I. Financial ReviewEXPENDITURES AS OF FEBRUARY 2010CONTRACT YEAR-TO-DATE % OF ORIGINAL # UNITS # UNITS INNAME EXPENDITURES CONTRACT COMPLETED PROGRESSAMOUNT *

    DOE $71,349.31 39.14% 21 10DOEARRA $43,992.23 5.35% 0 0LIHEAP $64,479.08 31.91% 21 10SPS $45,802.35 72,67% 19 0 At thetnne ofmonitoring

    Finding#l:

    ActionRequired:

    A review of the January 2010Monthly Expenditure Report for LIHEAP and DOErevealed inconsistent reporting between the Monthly Expenditure Reports andSouth Plains CAA general ledger. The DOE Monthly Expenditure Reportshowed the Agency was under repOlting $915.20 in their Administrativeexpenditures and $884.00 for their LIHEAP Administrative expenditures. Areview of additional months was required in order to .identify the funds inquestion.It is expected that South Plains Community Action Agency (South Plains CAA)will adhere to all accounting requirements in order to maintain accounting recordsreconciled with the monthly expenditure reports. It is highly recommended thatSouth Plains CM add a variance report to their working papers in order toaccount for variances that may happen due to a difference in closing dates forfunding sources and the Agency. Reference: OMB Circular A-llO, SubpartC_.21

    Recommended Improvement #1: As of February 2010 the ratio of the Administrativeexpenditure for DOE was at 8.74% and at 13.36% for LIHEAP, well above the maximumallowable expenditure. South Plains CAA is reminded that expenditure for Administration mustbe at or below 5% for DOE and at 01' below 7.22% for LIHEAP by the end of the contact term.Immediate attention must be paid to production schedules in order to meet the above mentionedratio. Any expenditure above the allowable maximum expenditure is subject to disallowed costs.Reference: DOE, DOEARRA, and LIHEAP Contract Attachment A.

    PAGE 4 OF 13

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    Finding #2:

    RequiredAction:

    Finding #3:

    ActionRequired:

    Finding #4:

    ActionRequired:

    2009 WEATHERIZATION MONITORING REPORTOF

    SOUTH PLAINS COMMUNITY ACTION ASSOCIATION

    A review of South Plains CAA's expenditures revealed inadequate supportdocumentation in three out of twenty expenditures reviewed. Nine out of twentyexpenditures lacked an itemized material and labor charge per fund for chargesrelated to client homes. One out of the twenty expenditures utilized LIHEAPlabor funds in the amount of $1,850.00 with check #40758 for repair of theMuleshoe office. The re-classification of this expenditure was completed at thetime ofmonitoring.South Plains CAA must include sufficient support documentation for allWeatherization Assistance Program expenditures. Any procurement expendituresmust include a copy of the South Plains CAA's Record of Procurement formalong with a copy of the invoice and Program Voucher. All expenditures relatedto Weatherization Assistance Program measures installed in client homes must beaccompanied with an invoice which clearly delineates each material and laborcharge per fund, along with a copy of the Program Voucher. South Plains isreminded that any expenditures under DOE, DOE ARRA, and LIHEAP materialand labor charges are for Weatherization Assistance Program measures installedin income eligible households only. Reference: OMB Circular A-llO,Attachment C_.21 (b) (2) (3) (4), 1 T.A.C. 5.141

    As of Febr\lary 2010 South Plains CAA has expended 31.91% of funds inLIHEAP, 39,14% in DOE, and 5.35% in ARRA while 92% of their DOE andLIHEAP and 20.8% of their ARRA contract period has expired.South Plains CAA must submit to the Department in response to this report a planof action detailing how they plan to expedite expenditures for the WeatherizationAssistance Program. Reference: OMB Circular A-llO, Subpart C _.21 (b) (2)(3) (4), 1 T.A.C. 5.141

    A review of PY08 closeout expenditures revealed inadequate supportdocumentation for two out of the nine expenditures reviewed. The supportdocumentation for check #399623 in the amount of $2,868.22 for roofingmaterials was not adequate to substantiate the expenditure of WeatherizationAssistance Program funds. The support documentation reviewed lacked thelocation information for which the materials were purchased for. In addition, thesupport documentation for the purchase of 24 refrigerators with check #400037 inthe amount of $13,169.88 was inadequate in tracing the refrigerator installation to24 income eligible households. This lack of adequate support documentationresulted in $16,038.10 in questioned costs.South Plains CAA must submit adequate suPPOtt docunientation to theDepartment as patt of their response to this report in order to substantiate theabove mentioned expenditures. South PlainsCM must include the location for

    PAGE 5 OF 13

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    2009 WEATHERIZATION MONITOR.ING REPORTOF

    SOUTH PLAINS COMMUNITY ACTION ASSOCIATION

    which the roofing materials were purchased for as well as document how it wasan eligible household. Any expenditure lacking the appropriate supportdocumentation is subject to disallowed costs. Reference: 10 CFR 440.18

    Section II. Travel and TimesheetsRecommended Improvement #2: In order to clearly have timesheets substantiate expendituresthe Department strongly recommends the inclusion ofWeatherization Assistance Program staffposition titles to all timesheets. Reference: OMD Circular A-122 Attachment D 8

    Finding #5:

    ActionRequired:

    Finding #6:ActionRequired:

    A review of South Plains CAA's Training and Technical Assistance supportdocumentation revealed the use of Training and Technical Assistance funds forattendance at Housing Quality Standards training. There was a lack of sufficientsupport documentation detailing the benefits the Weatherization AssistanceProgram stands to gain from this expenditure. This lack of documentation reveled$790.00 in questioned costs.South Plains CAA is expected to submit to the Department adequate SUpp0l1documentation that substantiates the expenditure as part of their response to thisreport. The support documentation is to include, but is not limited to, a copy ofthe detailed Housing Quality Standards training curriculum and any informationdetailing the benefit to the Weatherization Assistance Program. The Departmentreminds South Plains CAA that Training and Technical Assistance funds are onlyfor trainings which show a direct benefit to the Weatherization AssistanceProgram. Reference: ARRA Contract Section 35, DOE and LIHEAPContracts Section 29.

    Section IV. Property ManagementSouth Plains CAA had insufficientmaintenance records.South Plains CAA must ensure that adequate maintenance procedures aredeveloped, that maintenance records are kept up to date, and that the vehicles andequipment are kept in good working order. Current vehicle and equipment mustbe inspected to determine if any maintenance is needed. If it is detelmined thatany equipment and/or the vehicle is in need of repair or maintenance appropriateaction must be taken immediately. As South Plains CAA's vehicle andequipment inventory is. going to increase soon, they must ensure theimplementation ofmaintenance procedures and maintenance records is done priorto the use of such goods. Reference: 10 CFR 600.134 (t) (5) and 10 CFR600.232 (d) (4)

    PAGE 6 OF 13

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    Finding #7:

    ActionRequired:

    J!'inding #8:

    ActionRequired:

    Finding #9:

    ActionRequired:

    Finding #10:

    2009 WEATHERIZATION MONITORING REPORTOF

    SOUTH PLAINS COMMUNITY ACTION ASSOCIATION

    Section V. ProcurementSouth Plains CAA's procurement contracts are missing the contract provision for"Rights to Inventions Made Under a Contract or Agreement" within thecontractor contracts.South Plains CAAmust amend their current contractor contacts to provide for theinclusion of the above mentioned contract clause. South Plains CAA mustinclude this as part of the response to this report. Reference: OMB All0Appendix A

    Section VII. Personnel Policies and PracticesA review of South Plains CAA Personnel Policies and Procedures revealed amissing provision in the Personnel Policies' Equal Opportunity Statement. SouthPlains CAA current Equal Opportunity Statement does not include for theprotection against political affiliation or belief.South Plains CAA must immediately implement the inclusion to the currentEqual Opportunity Statement as this is a pending issue from the PY 08 monitoringA copy of the Agency's updated Policies and Procedures must be submitted to theDepartment as part of their response to this report. Reference: ARRA ContractSection 32, DOE and LIHEAP Contracts Section 27.

    Section VIII. Performance ReviewA review of South Plains CAA February 2010 Monthly Expenditure RepOltrevealed a lack of weatherization services and outreach activities in Bailey, andYoakum Counties.South Plains CAAmust ensure that they serve their service area in an equitablebasis. In addition, a well documented record must be kept for all outreach relatedactivities throughout the service area. Special attention must be paid to thoseareas that have been historically underserved. Reference: DOE and LIHEAPContract Section 3, Texas Administrative Code 5.703 .South Plains CAA is performing inadequate onsite inspections of the homes theyweatherize. The Health and Safety issues, Attic, Foundation, Floor, Window,Mobile Home, Watel' Heater, Baseload, Air Conditioner, and Energy Repairrneasures were not adequately addressed.

    PAGE 7 OF 13

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    2009 WEATHERIZATION MONITORING REPORTOF

    SOUTH PLAINS COMMUNITY ACTION ASSOCIATION

    The onsite review also revealed that South Plains CAA was not conductingthorough final inspections of units weatherized. The units require a return toseven (7) out of the eleven (11) units inspected for additional work to assurecompliance with current program requirements.RequiredAction:

    Finding #11:

    RequiredAction:

    South Plains CAA must ensure all assessors and inspectors are adequately trainedto perform assessments/inspections taking the whole house approach. Allmeasures that could be addressed in the home should be assessed. All assessmentforms must be adequately completed to reflect what the assessment of each itemresulted in; if a measure must be omitted a reason why must be clearlydocumented.In order to insure program compliance, South Plains CAA must return andaddress units as indicated in Attachment A of this report. As part of the responseto this report, South Plains CAA must submit a written 'plan that outlines howfinal inspections will be more thorough and comprehensive. Reference: ARRAContract Section 13 B (F), Weatherization Field Guide

    Section IX. AdministrativeA review of the Agency's Easy Energy Audit system revealed the incolTect datawas entered in the Audit. The Building Weatherization Report did not parallel theEnergy Audit.South Plains CAA is expected to begin using the NEAT Audit and ensure that theCOlTect values are entered. The Department is gearing up to discontinue the use ofthe Easy Energy Audit thus spending time adjusting this audit and continuing touse it will not be beneficial to the Agency and its production goals. The Agency'stime will be better utilized working on the NEAT Audit. Reference: 10 C.F.R.440.21,10 C.F.R. 600.121 (3) & 220

    Section X. Client File Review WorksheetFinding #12: A review of South Plains CAA client files revealed client file deficiencies ineleven (11) out of the thirteen (13) files reviewed in the completion of theWeatherization Assistance Program required forms. All of the client filescontained invoices and Building Weatherization Reports that did not clearlydocument which measures were charged to each fund. Please refer to table belowfor the specific deficiencies and required action for each. These deficienciesrevealed $15,758.70 in questioned costs and $3,949.40 in disallowed costs.

    PAGE 8 OF 13

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    ActionRequired:

    2009 WEATHERIZATION MONITORING REPORTOF

    SOUTH PLAINS COMMUNITY ACTION ASSOCIA nONSouth Plains CAA must submit documentation as listed below to the Departmentas part of their response tothis report. South Plains Community Action Agencymust provide the Department a written procedure indicating how the agency willcomply with the requirement of completing the forms as required by the contract.The written procedure must be submitted in response to this report. Any itemlacking sufficient support documentation will result in disallowed costs.Reference: Texas Administrative Code S.S26, DOE and LIHEAP ContractsSection 10, ARRA Contract Section 13, Texas Administrative Code S.20

    e09-TE-0004 Incomplete income. This revealed $5,720.30 in questioned costs.Agency must provide the income documentation forLaren Garcia.09LY-0004 Incomplete income.The interim blower door test was conducted after the work end date on thebuilding weatherization report (BWR). This review revealed $2,286.00 inquestioned costs.Agency must obtain a complete 30 days of income forMary Salinas.Agency is reminded that an Interim blower door test is to be done pl'lor toany work completion and typically while the work is still nndergoing.09-LA-0001 Incomplete income.Easy Audit indicates that it was completed and dated on the same day as thework end date on the BWR.File indicated that the wall and attic inspection form dates were from beforethe application date.Initial blower door test date on the form is before the application date.The agency and client signatw'e was missing on the BWR, This reviewrevealed $2,288.40 in questioned costs.Agency mnst obtain Income documentation for Kimberly Spoon.TheAgencymust send the appropl'iate staffto the next availableWeatherization Management Course In order to assul'e they are preparedto accurately complete the needed forms. Any fnture Andits reflecting thesame Information will resnlt In disallowed costs as it Is in direct violationwith Texas Administrative Code 5.526. The Agencymust obtain thesignatnre of the client certitylng that they are satisfied with the work done.The Agency must submit supporting documentation to the Department aspart of their response to this report.09YO-0002 Th.e blower door interim test was conducted 7 months before the work startdate on the BuildingWeatherization ReportThe certification date on the BWR is before the work end date.Agency must send the appropriate staff to the next availableWeatherizationManagement Course in order to assure they are prepal'edto accurately complete thc needed forms.09GA0004 Declaration of Income Statement was missing the Executive and ProgramDirector signature and date.The interim blower door test was conducted 3 months before the work startdate on.the BWR.Agency must correct this issue immediately. The Agencymust send theappropriate staff to the next availableWeatherization Management

    _ '" .. .~ u r s e in order to a s s ~ ~ t ; y a r l ! ~ ! ! . ! : ~ . ! . t t o ~ u r a t l ! ! r C ! l l l p ! ~ ~ l ~ ~ ..._._ ...

    PAGE 9 OF 13

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    2009 WEATHERIZATION MONITORING REPORTOF__ ' S O _ u T I : U ~ ~ A I N ~ _ ~ Q . . ~ M U N I . ' ! : . Y _ ~ ~ T I O ' . ! " : L ~ ~ ~ < ? _ ~ ! . ~ ! - I : ( ) . t : ' I __.,.". ., .__ .. ._.. __needed forms.09-LY-000l Final blower doOl' tests were conducted 2 months after the work end date onthe building weatherization report,South Plains CAA is reminded that the final blower door testmust becompleted aCtel' all work is completed and prior to approving the home forpayment. Agency must provide documentation showing that contractorswere not paid prior to finalizing the home; I f contractorwas paid prior toconducting the final blower door theAgency must submit documentationdetailing how they were sure the work completed was done correctly,09-LY-0002 Final blower door tests were conducted 2 months after the work end date onthe building weatherization report,South Plains CAA is reminded that the final blower door testmust becompleted after all work is completed and priol'to approving the home COl'payment. Agency must provide documentation showing that contractorswel'e not paid prior to finalizing the home. I f contractor was paid prior toconducting the final blower door the Agency must submit documentation

    d ~ t a i l i n g how they were sure thework completed was done corl'ectly.09-GA-0003 The blower door interim test was done two weeks before the work start date onthe-BWR.The Agencymnst send the appropriate staff to the next availableWeatherization Management Course In m'der to assure they are preparedto accurately complete the needed forms.09-LA-0003 EasyAudits indicated that they were done and dated on the same day as thework end date on the BWR, The windows did not rank as a repair/replacemeasure in the Audit. This revealed $3,949.40 in disallowed costs.The Agency must send the appropriate staff to the next availableWeatherization Management (:ourse in order to assuI'e they are preparedto accurately comillete the needed forms. Any future Audits reflecting thesame information will resnlt in disallowed costs as it is in direct violationwith Texas Administrative Code 5.526. The Agency must reimburse theDepartment $3,949.40; BWR did not clearly reflect which measures werepaid by each grant. The Agency must submit a BWR that clearly reflectswhich items were charged to which fund. The Agency is reminded that inorder to replace windows the measuremust rank with an SIR of 1 orbetter.09-HO-000l The final blower door reading is 3 months before the work end date on theBuildingWeatherization Report, The water heaterwas replaced under otherrepairs instead ofHealth and Safety, There was a gas stove present and staffdid not perform an assessment of the appliance,The Agency mnst tl'ansfer thewater heater cost to the Health and Safetycategory and snbmit the snpporting docnmentatlon to the Department.The Agellcy is reminded that all combustible appliances must be tested forCO and assessed and the assessment must be documented and kept In thefile.09-HO-0004 The stove, gas line repair and furnace were all charged to other measuresinstead ofHealth and Safety, The refrigerator replacement was notjustifiedwith an assessment form, EZAudit showedno measures installed had an SIRof I 01' better, and the whole house SIRwas 0.00, therefore under Programregulations this home was ineligible for selvices, Monoxer calibration wasdone indoors next to the stove_!9 be t e s t ! ? l ! , - : r J . 1 j ~ ! . ~ . i e w ! . e ~ ' ! l ! ~ d in . ~ 5 , 4 ~ ~ . , 0 0 __

    PAGE 10 OF 13

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    ,2009 WEATHERIZATION MONITORING REPORTOFSOUTH PLAINS COMMUNITY ACTION ASSOCIATION--..----- in q ~ e s t i o n e d costs for thiS hOlUe:--..----- ..- - - - - - - - ..-- ..-------- ....-

    SPCAA must redo the Easy Audit and submit the revised audit to theDepartmeut foi' review. Any measure iustalled that does not rank will bea disalloWed cost. In addition SPCAA must tJ'ansfer the cost of the stove,glls line repair and furnace to the Hellith and Safety category aud submitsupportiug documentation to the Depllrtment. Included within the supportdocnmentation must be the llssessment of the stove along with the COreadings necessary to replace the stove withHealth and Safety funds. TheAgency must submit the assessment form for the refl'igeratordocumenting the need for the Jeplacement. Failure to submit necessarydocuments supporting the measures done will result in disallowed costs. SPCAA must also request from the Department training on insulatingmobile homes as they will be expected to insulate the mobile homes ifneeded._ ~ ~ . _ . ~ ...._.... ~ ~ ' ~ ' H . H . ~ _ .. " _ , ~ __ .._. __._, ...,.... __ ~ _ H__H....H'.' . .....

    Texas Depmtment of Housing and Community Affairs representatives, Rosy 1. Falcon andWalter Griner participated in an exit conference with Bill Powell, Executive Director, VeronicaHerrera, Accountant, Henry Terango, Director of Housing, and Christopher Cristan,Weatherization Coordinator.

    Signature:

    Signature: ~ d c A - Program Officer

    PAGE 11 OF 13

    ~ ate5jZ '6[ 7.-1110Date

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    2009 WE A T H E RI Z A TI O N M O N I T O RIN G REPORTOF

    S O UT H P L AI N S COMMUNITY ACTION ASSOCIATION

    ATTACHMENT A

    Units Fund Source Return CommentsInspected09-GA-002 DOE/LIHEAP/ Yes Return to vent attic. Repair water heater to code specifications.SPS Not practicing Lead Safe Work practices.3500 @ 50 Final BlowerDoor reading on BWR.1957 @5 0 Final Blower Door reading on Blower 0 0 0 1 ' fmID.1622@50 Blower 0 0 0 1 ' reading at time ofmonitoring.Texas Weatherization Field Guide-Attic ventilation Pg.53Water HeaterMeasures Pg.3209-GA-0004 DOEfLIHEAP/ Yes Return to vent attic. Install parting stop on living room window bySPS couch. Install bottom sash on the interior ofwindow installed inleft bedroom at entrance. Install door on water heater closet in

    kitchen and repair to code specifications.Texas Weatherization Field Gnlde-Attic ventilation Pg.53Water HealerMeasures Pg.32Window installation andrepairs. Pg.7209-LY-0002 DOE/LIHEAP No No retum.SPS09-GA-0003 DOE/LIHEAP No No retumSPS09-GA-0004 DOE/LIHEAP No No return.SPS09-LY-OOOI DOE/LIHEAP No No retum.SPS09-HO-0004 DOEfLIHEAP Yes Rcturn to replace vent in the kitchen. Address the needed b ~ l l ySPS insulation for the mobile home.2280 @ 50 Final Blower Door Reading3583 @5 0 BlowerDoor Reading at time of monitoring.09-HO-0001 DOEfLIHEAP/ Yes Address thewater heater vent pipe; it was not given enonghSPS clearance from combustiblematerial. Return to vent the attic.2012 @ 50 F