Audit Report

The Department of Energy's 

Weatherization Assistance Program

under the American Recovery and 

Reinvestment Act for the City of 

Phoenix – Agreed-Upon Procedures

OAS-RA-11-03 November 2010

U.S. Department of Energy

Office of Inspector General

Office of Audit Services
Department of Energy 

Washington, DC 20585 

November 30, 2010 

MEMORANDUM FOR THE DEPUTY ASSISTANT SECRETARY FOR ENERGY 

EFFICIENCY AND RENEWABLE ENERGY 

FROM: Rickey R. Hass 

Deputy Inspector General 

 for Audit Services 

Office of Inspector General 

SUBJECT: INFORMATION: "The Department of Energy's Weatherization 

Assistance Program under the American Recovery and Reinvestment 

Act for the City of Phoenix – Agreed-Upon Procedures" 

 Audit Report No.: OAS-RA-11-03 

INTRODUCTION AND OBJECTIVE

The attached report presents the results of an agreed-upon procedures review of the Department 

of Energy's (Department) Weatherization Assistance Program in the City of Phoenix, Arizona, 

under the American Recovery and Reinvestment Act of 2009 (Recovery Act). The Office of 

Inspector General (OIG) engaged an independent certified public accounting firm, Lopez and 

Company, to perform the agreed-upon procedures for Phoenix, a sub-recipient of the 

Department's Recovery Act Weatherization funding for the State of Arizona. 

The Recovery Act was enacted to promote economic prosperity through job creation and 

encourage investment in the Nation's energy future. As part of the Recovery Act, the 

Weatherization Assistance Program was implemented to reduce energy consumption for lowincome households through energy efficient upgrades. The State of Arizona received $57 

million in Weatherization Assistance Recovery Act grant funding, of which $7.2 million was 

allocated to the City of Phoenix. The Arizona Department of Commerce was responsible for 

administering Weatherization grants, including sub-grants provided to the City of Phoenix. This 

grant provided more than a fifteen-fold increase in funds available to Arizona for weatherization 

over the amount authorized in Fiscal Year 2009. 

OBSERVATIONS AND CONCLUSIONS

The review identified opportunities for the City of Phoenix to improve its administration of 

Recovery Act funds made available by the Department's Weatherization Assistance Program. In 

particular, the City of Phoenix had not always ensured that costs charged for the weatherization 

of homes were reasonable. Specifically, Phoenix had not: 
2

Procured contractor weatherization services through a competitive process as required by 

Federal regulations, nor had it performed cost analyses in the selection of contractors to 

ensure price competiveness; 

Obtained or reviewed supporting documentation for contractors' invoices totaling 

$275,375 for 30 homes/units to ensure that materials and labor costs incurred on projects 

were associated with allowable weatherization services and materials; and, 

Ensured that employees charging payroll costs to the Weatherization Program Recovery 

Act grants were actually providing such services to the Program. In fact, the City of 

Phoenix charged payroll costs to the Program totaling $73,082 for three full time 

employees even though payroll information to support such costs did not exist. 

The City of Phoenix did not have written policies and/or procedures for ensuring cost 

reasonableness and supportability. Additionally, the City's payroll system was not structured to 

track employee's time incurred on projects. Payment for expenditures not appropriately 

documented and accounted for can potentially reduce the number of homes of low-income 

residents that can be weatherized. As a result of weaknesses in the City of Phoenix's 

administration of Weatherization Assistance Program, we question $348,457 in costs incurred. 

RECOMMENDATIONS

The attached agreed-upon procedures report makes recommendations to the State of Arizona and 

the City of Phoenix to improve administration of the Department of Energy Weatherization 

Assistance Program grant. 

As part of its responsibilities for managing the national Weatherization Program, we recommend 

that the Acting Director, Weatherization Assistance and Intergovernmental Programs, Office of 

Energy Efficiency and Renewable Energy ensure that appropriate action is taken by the State of 

Arizona to improve the City of Phoenix's administration of Recovery Act Weatherization 

Assistance Program funds. We also recommend that the Contracting Officer resolve identified 

questioned costs. 

MANAGEMENT COMMENTS 

In discussions with the Office of Inspector General, Office of Energy Efficiency and Renewable 

Energy management agreed to address the issues in this report as part of their ongoing 

monitoring of the State of Arizona's Weatherization Assistance Program and to promptly resolve 

all questioned costs identified. 

To its credit, the Arizona Department of Commerce stated that it had engaged the City of 

Phoenix in resolving questioned costs. For its part, the City of Phoenix reported that it had 

implemented a new Recovery Act Weatherization program that used a competitive low bid 

process to ensure cost reasonableness and full and open competition. Also, the City of Phoenix 

stated that it currently requires additional documentation on equipment costs in both bid 

proposals and invoices. The City of Phoenix said that it was engaged in finding an alternative 
3

method to more accurately support its personnel costs charged to Recovery Act funding. 

However, the City of Phoenix also believed that its existing methodology for allocating 

personnel costs to Recovery Act projects actually resulted in charging about $75,000 in 

personnel costs less than would have resulted from a pro rata distribution of costs based on 

production or on a direct time-card basis. Management comments from the Arizona Department 

of Commerce and the City of Phoenix are included in the attached agreed-upon procedures 

report. 

AGREED UPON PROCEDURES

The agreed-upon-procedures were performed in accordance with attestation standards 

established by the American Institute of Certified Public Accountants (AICPA) as well as those 

additional standards contained in the Government Auditing Standards, issued by the Comptroller 

General of the United States. 

The OIG monitored the progress of the agreed-upon procedures performed and reviewed the 

report and related documentation. Our review disclosed no instances where Lopez and 

Company, in all material aspects, did not comply with the attestation requirements. Lopez and 

Company is responsible for the attached report dated November 23, 2010, and the conclusions 

expressed in the report. 

The agreed-upon procedures included gathering an understanding of policies and procedures and 

reviewing documentation from the City of Phoenix. They also included an analysis of inspection 

results, records of corrective actions, and re-inspections of completed homes/units to ensure that 

any failures were properly corrected. Finally, an analysis of associated cost data was performed 

to test the appropriateness of payments. 

Attachment 

cc: Deputy Secretary 

 Acting Under Secretary for Energy 

Chief of Staff 

Assistant Secretary for Energy Efficiency and Renewable Energy 
3452 East Foothill Boulevard ▪ Suite 820 ▪ Pasadena ▪ California 91107

Phone: 626-583-1116 ▪ Fax: 626-577-8439 ▪ www.lopezllp.com

AGREED-UPON PROCEDURES 

OF

Recovery Act Weatherization Assistance Program 

City of Phoenix 

____ 

PERFORMED FOR 

U.S. DEPARTMENT OF ENERGY 

OFFICE OF INSPECTOR GENERAL 

Prepared by 

Lopez and Company, LLP 

CONTRACT NUMBER: DE-IG0000017 

WORK ORDER NUMBER: 2010-02
Table of Contents 

Independent Accountant's Report On Applying Agreed-Upon Procedures ................. 1

SECTION I. City of Phoenix's Weatherization Assistance Program ........................... 2

SECTION II. Agreed-Upon Procedures Performed....................................................... 3

SECTION III. Classification of Findings ........................................................................ 5

SECTION IV. Summary of Findings ............................................................................... 6

SECTION V. Schedule of Findings .................................................................................. 7

SECTION VI. City of Phoenix Response ....................................................................... 12

SECTION VII. Arizona Department of Commerce Response .................................... 14
3452 East Foothill Boulevard ▪ Suite 820 ▪ Pasadena ▪ California 91107

Phone: 626-583-1116 ▪ Fax: 626-577-8439 ▪ www.lopezllp.com

Page 1 

INDEPENDENT ACCOUNTANT'S REPORT ON APPLYING AGREED-UPON

PROCEDURES 

To the Inspector General, 

Department of Energy: 

We have performed the procedures which have been agreed to by the U.S. Department of 

Energy's (Department) Office of Inspector General (Inspector General) solely to assist 

you in evaluating whether the City of Phoenix (the City), a sub recipient of the State of 

Arizona, complied with relevant Federal requirements and program guidelines in 

administering the Department's Weatherization Assistance Program (Weatherization 

Program) funds provided by the American Recovery and Reinvestment Act (Recovery 

Act) of 2009 for the period of July 1, 2009 to December 31, 2009. 

City management is responsible for compliance with relevant Federal requirements and 

program guidelines. 

This agreed-upon procedures engagement was conducted in accordance with attestation 

standards established by the American Institute of Certified Public Accountants and the 

U.S. Government Accountability Office. The sufficiency of these procedures is solely 

the responsibility of the Inspector General. Consequently, we make no representation 

regarding the sufficiency of the procedures described below either for the purpose for 

which this report has been requested or for any other purpose. 

The agreed-upon procedures performed and findings developed based on these 

procedures are presented on the following pages. 

We were not engaged to and did not conduct an examination, the objective of which 

would be the expression of an opinion on the City's compliance with relevant Federal 

requirements and program guidelines in administering the Department's Weatherization 

Assistance Program funds provided by the Recovery Act of 2009. Accordingly, we do 

not express such an opinion. Had we performed additional procedures, other matters 

might have come to our attention that would have been reported to you. 

This report is intended solely for the information and use of the Inspector General, and is 

not intended to be and should not be used by anyone other than the specified party. 

/s/ Lopez and Company, LLP 

November 23, 2010 
Page 2 Lopez and Company, LLP

SECTION I. City of Phoenix's Weatherization Assistance Program

The City of Phoenix operates under a Council-Manager form of government as provided 

by its Charter, which was adopted in 1913. Under this organizational structure, the 

Mayor and Council appoint a city manager to act as the chief operating officer. The 

Mayor and City Council set policy direction and the city manager implements those 

policies. The Mayor is elected at-large, while Council members are elected by voters in 

each of eight separate districts they represent. The Mayor and each Council member 

have equal voting power.

Weatherization Assistance Program Goals and Funding

The Goal of the Weatherization Assistance Program (Weatherization Program) in 

Arizona is to increase the energy efficiency of housing occupied by low-income persons 

and households and reduce their total residential energy expenditures. Arizona's 

Department of Commerce administers the Weatherization Program through sub-grants to 

local agencies, including the City. Under the sub-grant with Arizona, the City's 

Neighborhood Services Department is responsible for determining applicant eligibility, 

weatherizing homes, and conducting home assessments and inspections. Arizona 

allocated $7.2 million of its $57 million Recovery Act Weatherization Program funds to 

the City, to be expended over three years. In accordance with Weatherization Program 

criteria, the City provides weatherization services to families with income of less than 

200 percent of the poverty level as defined by the U.S. Department of Health and Human 

Services.
Page 3 Lopez and Company, LLP

SECTION II. Agreed-Upon Procedures Performed

1. We obtained an understanding of the City of Phoenix's Weatherization Program, its 

management and administration of risks and mitigating controls, through interviews 

with City officials, review of available information, policy and procedures 

documentation, and preliminary analysis of completed homes/units and associated 

cost data, in order to decide on an appropriate sample size and test focus.

2. Based on preliminary work performed in step 1, we judgmentally selected a sample of 

30 completed homes/units.

3. We reviewed the sampled applicants' files for documentation supporting the 

applicants' eligibility for weatherization services under the Program. If the home/unit 

had prior weatherization work performed, we determined whether the prior work was 

completed on or before September 30, 1994. Weatherization Program regulations 

prohibit additional weatherization work if performed after this date.

4. We reviewed the sampled files for inspection results, records of corrective actions, 

and re-inspections to ensure any failures noted were properly corrected. We also 

interviewed weatherization service recipients to confirm that weatherization work 

took place on their property and they were satisfied with the services.

5. We evaluated the selected completed home/units' savings to investment ratios (SIRs) 

based on reported costs to determine whether the SIRs were less than one. If so, we

determined the reasons for the non-compliance.

6. For the sampled homes/units, we selected relevant detailed cost data to determine 

whether:

a. Costs incurred were allowable;

b. Weatherization measures/materials complied with 10 CFR 440.18(d) (1) and 

10 CFR 440, Appendix A, and that specifically stated unallowable items such 

as freezer-only units and/or sub-standard weatherization measures/materials 

were not used.

7. Using the City's vendor master list, employee master list and the Accounts Payable 

disbursement file for the period under review, we: 

a. Compared vendor names per the disbursement's database with those of the vendor 

master list to determine whether there were unauthorized and/or ghost vendors, 

and/or same vendor/similar name schemes (i.e. S.D. Baker, SD Baker, SDBaker);

b. Compared vendor names and addresses with employee names and addresses to 

determine whether there were employees disguised as vendors; and,
SECTION II Agreed-Upon Procedures Performed (cont.)

Page 4 Lopez and Company, LLP

c. In lieu of applying data-mining algorithms, we reviewed vendor payment 

information to determine whether there were duplicate payments and split 

transaction payments (i.e. breaking one large amount invoice into two or more 

small amount invoices, and multiple payments for the same or similar invoice 

number from the same vendor using a similar name scheme).

8. We obtained a list of all monthly reimbursement requests and determined whether 

each request was adequately supported by detailed documentation, reconciled to 

appropriate summary ledgers, and reviewed and approved by appropriate 

management.

9. Since the City of Phoenix has no vehicles or equipment with a cost of over $5,000 

purchased with Recovery Act funds, we did not apply the agreed-upon procedures 

pertaining to purchase authorization, record keeping, title, custody, usage, and 

maintenance of Federally funded vehicles and equipment. 

10. We obtained and reviewed a sample of thirty executed subcontract agreements 

between the City and its subcontractors for Recovery Act Weatherization Program 

work to determine whether the agreement was properly executed by both parties and 

whether the agreement provided for weekly certified payrolls with corresponding 

approved Davis-Bacon wage rates. For each subcontract selected, we tested a sample 

of two weekly-certified payrolls to determine whether the subcontractor was paying 

the prevailing wages according to the provisions of the subcontract agreement.

11. We obtained a master list of program identification or job codes used by the subrecipient to separately record transactions under the Recovery Act weatherization 

program and transactions under other projects. We traced the identification or job 

code to the sample detailed cost data to determine whether the Weatherization 

Program Recovery Act project identification or code was actually used in separately 

recording and identifying weatherization transactions.

12. We selected one quarterly Recovery Act mandated performance progress report that 

contained the "Number of Jobs Created and Saved" information, reviewed relevant 

definitions and supporting calculation schedules to determine whether "Jobs Created 

and Saved" was consistently applied, and whether the number of "Jobs Created and 

Saved" was calculated accurately.
Page 5 Lopez and Company, LLP

SECTION III. Classification of Findings

The findings in this report are classified as follows:

Material Weakness

For purposes of this engagement, a material weakness is a significant deficiency, or 

combination of significant deficiencies, that results in more than a remote likelihood that 

a material misstatement of the subject matter will not be prevented or detected.

Significant Deficiency

A significant deficiency is a deficiency in internal control, or combination of deficiencies, 

that adversely affects the City's ability to initiate, authorize, record, process, or report 

data reliably in accordance with the applicable criteria or framework such that there is 

more than a remote likelihood that a misstatement of the subject matter that is more than 

inconsequential will not be prevented or detected. These are not considered material 

weaknesses, as previously defined.
Page 6 Lopez and Company, LLP

SECTION IV. Summary of Findings

Area/Finding 

Questioned Costs 

V.1 Questioned Costs for Weatherization Services Provided (Material 

Weakness) 

V.2 City of Phoenix Payroll Costs for Implementation of the Weatherization 

Program (Significant Deficiency) 
Page 7 Lopez and Company, LLP

SECTION V. Schedule of Findings

Questioned Costs Findings

V.1 Questioned Costs for Weatherization Services Provided (Material Weakness)

Condition

Based on our review of 30 completed homes/units, we found that the City of Phoenix was 

not ensuring that weatherization costs were either reasonable or supportable. More 

specifically, the City of Phoenix had not, at the time of our review: 

a) Complied with Federal regulations which require that procurements for 

weatherization efforts be conducted in a manner providing full and open competition 

and, therefore, could not ensure that costs were reasonable. The City provides 

weatherization of eligible homes/units by awarding projects to contractors that have 

been evaluated and determined to be qualified to provide these weatherization 

services. The City distributes the weatherization projects to the qualified contractors 

on a "next in line" basis with the overall cost of the project negotiated between the 

City's rehabilitation specialist and the contractor. However, there was no competitive 

bidding and/or cost analysis in the contractor evaluation and selection process to 

ensure that cost competitive contractors were selected and that costs charged were 

reasonable. 

b) Obtained or reviewed documentation for contractors' invoices to ensure that materials 

and labor costs on projects were associated with allowable weatherization services 

and materials. Federal and State requirements state that to be allowable under Federal 

awards, costs must be adequately documented. Based on the agreement between the 

Arizona Department of Commerce and the City of Phoenix, the City is required to 

comply with Federal requirements. Without adequate detailed information to support 

the costs charged by the contractors, the City cannot determine whether the costs 

were for allowable materials since the contractor invoices did not include descriptions 

of materials used and items installed. 

As a result of the lack of contractor competition or an evaluation of reasonableness and

insufficient documentation to support costs billed, we question the $275,375 associated 

with the 30 homes/units in our sample. 
SECTION V Schedule of Findings (Cont.)

Page 8 Lopez and Company, LLP

V.1 Questioned Costs for Weatherization Services Provided (Cont.)

Cause

We determined that the City of Phoenix did not have written policies and/or procedures 

to address the issues of cost reasonableness and supportability. Management believed

that using the "next in line" process was sufficient to ensure cost reasonableness. More 

specifically, it believed its rehabilitation specialists, whom it felt were knowledgeable 

about costs, could negotiate fair prices on projects to ensure costs were reasonable. In 

terms of supportability, management was not aware of the necessity of requiring the 

contractors' invoices to include descriptions of materials used and items installed. This is 

because these issues had not been identified in previous Weatherization Program reviews.

During the exit conference, management acknowledged the finding and its implication, 

and stated that it would make improvements to address the finding. More importantly, as 

a result of this audit finding, the City of Phoenix revamped its Weatherization Program 

procurement methodologies. The work to be performed on individual homes/units is now 

being bid and lowest responsible bidders are being awarded the work. Further, the City 

of Phoenix has hired independent firms to conduct pre- and post- evaluations of 

weatherization work to ensure that weatherization measures installed comply with 

Federal Requirements for Savings to Investment Ratio.

Effect

The lack of an element of cost competition during the selection of contractors coupled 

with the absence of written procedures requiring submission of detailed invoices on 

projects resulted in an inability to evaluate costs to ensure that costs incurred were

reasonable and allowable. Further, the risk of fraud, waste and abuse is elevated in the 

City of Phoenix's Weatherization Program.

Recommendations

1. We recommend that the Arizona Department of Commerce review the City of 

Phoenix's revised policies and procedures to ensure that the City:

1.1. Evaluates and selects contractors based on competitive bidding; and, 

1.2. Obtains sufficient documentation of costs charged by contractors to allow the 

City to review and establish that costs charged are reasonable and allowable.

2. We also recommend that the Arizona Department of Commerce work with the City of 

Phoenix to address the costs questioned in this finding.
SECTION V Schedule of Findings (Cont.)

Page 9 Lopez and Company, LLP

City of Phoenix Response

The City of Phoenix concurred with the finding and recommendation V.1.1 and has 

implemented a competitive low bid process to ensure cost reasonableness and full and 

open competition.

V.1 Questioned Costs for Weatherization Services Provided (Cont.)

The City also concurred with the finding and recommendation V.1.2 and now requires 

contractors to submit detailed documentation on all weatherization proposals to support 

allowable equipment costs. See Section VI for the City's full response.

Arizona Department of Commerce Response

The Arizona Department of Commerce concurred with the findings and 

recommendations put forth. See Section VII for the Arizona Department of Commerce's 

full response.
SECTION V. Schedule of Findings

Page 10 Lopez and Company, LLP

Questioned Costs Findings (Cont.)

V.2 City of Phoenix Payroll Costs for Implementation of the Weatherization 

Program (Significant Deficiency)

Condition

The City charged three full time employees to Weatherization Program Recovery Act 

grants as direct costs even though payroll information to support such costs did not exist.

Further, these personnel provide support to other City programs that were not funded by 

the Recovery Act. Federal regulations require that costs must be adequately supported 

and documented in order to be allowable under Federal awards. 

At the time the City applied for Weatherization Program Recovery Act funds, officials 

determined that the additional weatherization efforts would necessitate hiring three 

additional staff. There was no formal study or analysis performed to support the City's 

estimate that three workers were necessary to support the Recovery Act Weatherization 

Program. The City's grant manager stated that since the employees were hired to address 

the support needs of the Weatherization Program, their full costs are charged to the 

Weatherization Program Recovery Act funds. We determined, however, that these 

employees provided support to other City programs and that other (non-Recovery Act 

funded) City workers provided support to the Recovery Act funded Weatherization 

Program. The City could not demonstrate actual staffing needs, nor could we determine 

how much time was actually spent by City workers conducting Recovery Act 

weatherization efforts. 

Cause

The City's payroll system was not set up to track employees' time incurred on projects, or 

on any other functional basis. Management used an undocumented cost estimate in 

support of the three personnel charged to the Recovery Act funded Weatherization 

Program. Management did not understand the Weatherization Program requirements for

tracking employees' time incurred on projects. Further, it did not initially recognize the 

need for a formal study to support costs charged to Recovery Act funded Weatherization 

Program for three personnel. 

During the exit conference, management acknowledged the finding and did state that it 

was in the process of preparing a formal study of program needs supporting its decision 

to charge three staff to the Weatherization Program. According to the Department's 

Weatherization Program staff, the City of Phoenix' Weatherization Program may only 

account for hours of staff assigned to and performing on behalf of the Program. In 

addition, the fiscal records should be adjusted to reflect the actual hours of the work 

performed by these staff on behalf of the Program.
SECTION V. Schedule of Findings

Page 11 Lopez and Company, LLP

V.2 City of Phoenix Payroll Costs for Implementation of the Weatherization 

Program (Cont.)

Effect

Without documentation of the level of effort provided by City employees to the Recovery 

Act Weatherization Program, we question the $73,082 charged to the Weatherization 

Program for the three employees at the time of our review.

Recommendations

We recommend that the Arizona Department of Commerce ensure that the City of 

Phoenix: 

1. Prepares a formal analysis which clearly supports the amount charged for the 

City's weatherization personnel costs in terms of full-time staff equivalents for 

review and approval by the Arizona Department of Commerce.

City of Phoenix Response

The City of Phoenix concurred with this finding and recommendation. The City has 

submitted a work force analysis indicating that the City incurred weatherization 

personnel costs in excess of amounts charged to the weatherization grant and the analysis 

appears adequate. The City is actively engaged in finding an alternative method to more 

accurately support future weatherization personnel costs in cooperation with the Arizona 

Department of Commerce. See Section VI for the City's full response.

Arizona Department of Commerce Response

The Arizona Department of Commerce concurred with the finding and recommendation

put forth. See Section VII for the Arizona Department of Commerce's full response.
Page 12 Lopez and Company, LLP

SECTION VI. City of Phoenix Response
SECTION VI. City of Phoenix Response

Page 13 Lopez and Company, LLP
Page 14 Lopez and Company, LLP

SECTION VII. Arizona Department of Commerce Response 
SECTION VII. Arizona Department of Commerce Response

Page 15 Lopez and Company, LLP
IG Report No. OAS-RA-11-03

CUSTOMER RESPONSE FORM

The Office of Inspector General has a continuing interest in improving the usefulness of 

its products. We wish to make our reports as responsive as possible to our customers' 

requirements, and, therefore, ask that you consider sharing your thoughts with us. On the 

back of this form, you may suggest improvements to enhance the effectiveness of future 

reports. Please include answers to the following questions if they are applicable to you:

1. What additional background information about the selection, scheduling, scope, or 

procedures of the inspection would have been helpful to the reader in understanding 

this report?

2. What additional information related to findings and recommendations could have 

been included in the report to assist management in implementing corrective actions?

3. What format, stylistic, or organizational changes might have made this report's 

overall message more clear to the reader?

4. What additional actions could the Office of Inspector General have taken on the 

issues discussed in this report which would have been helpful?

5. Please include your name and telephone number so that we may contact you should 

we have any questions about your comments.

Name Date 

Telephone Organization 

When you have completed this form, you may telefax it to the Office of Inspector 

General at (202) 586-0948, or you may mail it to:

Office of Inspector General (IG-1)

Department of Energy

Washington, DC 20585

ATTN: Customer Relations

If you wish to discuss this report or your comments with a staff member of the Office of 

Inspector General, please contact Felicia Jones at (202) 253-2162.
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Your comments would be appreciated and can be provided on the Customer Response Form.