Developing Efficient Reporting and Record Keeping Systems

Developing Efficient Reporting and Record Keeping Systems

As a general rule, jurisdictions must establish and maintain sufficient records to document that program requirements are met. Both the HOME and CDBG programs have specific requirements regarding records retention—five years for HOME and CDBG, or longer for the HOME affordability period or if there are any unresolved audit findings—but jurisdictions should establish their own requirements for records that should be submitted and retained by their partners. These requirements should enable the jurisdiction to meet HUD requirements and maintain complete information about funded projects.

In addition, record keeping is crucial to the successful management of HOME- and CDBG-funded activities. Insufficient documentation is likely to lead to monitoring findings, and these findings will be more difficult to resolve if records are missing, inadequate, or inaccurate.

To assess the strengths and weaknesses in record keeping systems, jurisdictions should think about the following:

  • Is there a clearly defined process for acquiring, organizing, storing, retrieving, and reporting information about HOME- and CDBG-funded activities?
  • How can the documentation and reporting systems be strengthened to meet HUD requirements?
  • Who is responsible for the majority of record keeping and reporting tasks, and are they properly trained and supported?
  • How can standardized procedures and the removal of duplicative records streamline the record keeping and reporting process?
  • What types of records and reports could be automated (i.e., computerized) that are not now?

For the HOME Program, the following records must be maintained:

  • PJ designation;
  • Program records;
  • Project records;
  • CHDO records;
  • Financial records;
  • Program administration records; and
  • Documentation records (i.e., documenting compliance with Federal requirements such as equal opportunity and fair housing, and conflict of interest).

For CDBG, the following records must be maintained:

  • General administrative records;
  • Financial records;
  • Project/activity records;
  • National Objective records;
  • Income documentation records; and
  • Subrecipient records.

Jurisdictions must provide citizens and other interested parties with reasonable access to records. Access must be consistent with applicable state and local laws regarding privacy and obligations of confidentiality.

HUD and the Comptroller General of the United States, or any of their representatives, have the right to access any records of jurisdictions and subrecipients for auditing, excerpt, or transcript purposes.

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