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Report of Investigation 2024 0010

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100% found this document useful (1 vote)
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Report of Investigation 2024 0010

Report of Investigation 2024 0010

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We take content rights seriously. If you suspect this is your content, claim it here.
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COJ Office of Inspector General | 1

Executive Summary

In October 2023, the OIG learned that the City of Jacksonville (COJ) chose to terminate a contract
agreement awarded to Bridges to the Cure LLC (BTTC), who had been selected to oversee the Cure the
Violence Program. As part of the OIG’s oversight responsibility, we initiated an administrative
investigation to determine why the contract was canceled, evaluate contract oversight, and examine if the
contractor abided by the terms of the agreement.
We found severe deficiencies with the COJ’s oversight, including failure to review contractor invoices,
perform site visits, and secure property purchased by the contractor with city funds. We also found serious
issues with the contractor regarding transparency, use of contract funds, adherence to reporting
requirements, records retention, and cooperation with the COJ. Representatives of BTTC were offered an
opportunity to speak with investigators regarding our findings, but they declined to provide a sworn
statement.
Scope:
Our investigation's purpose was to determine why the contract was terminated prematurely. We did not
review the contractor's effectiveness or the program's impact on curbing violence. Our review
concentrated on BTTC’s adherence to the contract terms and the efficacy of the COJ's oversight.
Background:
Cure the Violence
COJ initiated the Cure the Violence Health Model Site Implementation in May 2019 in three parts of the
city. This program was designed by Cure the Violence Global (CTVG). This Chicago-based non-profit
organization has developed a program to help communities prevent violence by detecting and
interrupting potentially violent situations, identifying and changing the thinking and behaviors of high-
risk individuals, and changing group norms that perpetuate the use of violence. The COJ purchased this
program from CTVG and hired them to provide training and oversight to three contractors selected to
implement this program in three different parts of the city.
Bridges to the Cure, LLC
BTTC is a for-profit Limited Liability Company located at 3416 Moncrief Road, Suite 200, Jacksonville,
FL 32209. It was formed on April 18, 2019, and is reportedly a Northwest Jacksonville Community
Development Corporation (NWJCDC) subsidiary. This non-profit organization specializes in providing
low-income individuals with access to housing and social services. The NWJCDC receives some funding
from the COJ, but the bulk of its funding comes from other governmental organizations and private
donations. Paul Tutwiler, who is the Chief Executive Officer (CEO) of the NWJCDC, formed the BTTC.
During the contract with the COJ, Tutwiler was reported to be the Director of the BTTC, and Mildred
Jennings was listed as the Program Director. Jennings is also the Social Services Director of the
NWJCDC.
On May 31, 2019, a month after being formed, the BTTC received a $275,000.00 single-source contract
from the COJ to implement the Cure the Violence Program in the Moncrief section of the city.
(Attachment #1) Subsequent awards were received in October 2019 for $710,500.00, October 2020 for
$800,000.00, October 2021 for $800,000.00, and October 2022 for $865,000. The contract was canceled
for convenience in March 2023. The total value of all the contracts COJ awarded to BTTC was
$3,450,500.00, although the amount received by BTTC was significantly less than the total value.
COJ Office of Inspector General | 2

Division of Grants and Contract Compliance


The COJ Division of Grants and Contract Compliance (DGCC) was assigned to oversee the Cure the
Violence Program as part of their violence reduction program responsibilities. This office is responsible
for providing technical assistance to the contractor and assuring the contractor abides by the contract
specifications. They also review the contractor’s request for funds and its required reports. They are
ultimately responsible for approving financial reports by the contractor and assuring that the contract
funds are being used for work within scope. Since 2019, this office has had a significant turnover, with
the Chief and Grant Administrator positions changing several times.
Investigation:
We initiated an investigation on November 8, 2023, after receiving information that the COJ contract with
BTTC had been canceled. Contracts can be canceled for several reasons. However, seeing that three
contracts were awarded for the Cure the Violence program and only the BTTC contract was canceled,
there was reason to believe there was a failure somewhere in the process. We initiated an investigation to
determine what factors contributed to this failure.
City of Jacksonville, Division of Grants and Contract Compliance
Failure to Review Contractor Invoices and Conduct Site Visits
To obtain records and identify potential interviews regarding this contract, we met with DGCC Staff,
including Audrey Gibson, Chief; John Snyder, Human Services Planer Supervisor; and Terry Powell,
Human Services Planner. This meeting took place in October 2023, before case initiation, as we were
developing the scope of our review. We were told at this meeting that Powell was the last Human Services
Planner to oversee the BTTC contract and would be able to fulfill any document requests. Snyder
represented that he was not very involved with this contract, and Gibson was newly appointed to her
position, so she did not have any specific knowledge. Both Gibson and Powell have resigned from their
positions with COJ since this meeting for reasons unrelated to this investigation.
We contacted Damien Cook, the original Grants Administrator responsible for overseeing this program.
Cook now works for a non-profit that is not affiliated with COJ. He spoke with investigators briefly but
declined to sit for a formal interview.
We attempted to contact Kendra Mervin, the last Grants Administrator, over this contract and the official
responsible for terminating the agreement. We discovered that Mervin left the COJ and soon after took a
position with Cure the Violence Global. We contacted the COJ Office of Ethics to determine if Mervin
asked for an ethics opinion before taking a position with a COJ contractor. We were told they did not
have a record of her requesting an opinion. Mervin did not respond to our attempts to contact her
regarding this contract award.
The contract terms required BTTC to file monthly progress, financial, and project monitoring reports
during the contract. Initially, the agreement required BTTC to be reimbursed a set amount if they met
their prescribed goals. The DGCC was required to review the reimbursement requests, verify the
supporting documentation, and conduct site visits. For each contract month, the Human Resources
Planner assigned should review the contractor invoice and supporting documentation, review the
contractor narrative of activities, complete the contract payment checklist, and conduct a site visit. We
examined the records provided by DGCC and found gaps in the information required to be provided by
COJ Office of Inspector General | 3

the BTTC for reimbursement and the oversight documentation that COJ employees should have secured.
The following chart represents the document review of the information provided by DGCC.
BTTC/Cure the Violence
Month/Year Total Amount Requested/Actual Expenses Total Amount Approved Invoice Support Narrative Grant Admin/Manager Contract Payment Checklist Site Review Checklist
May-19 $21,934.17 $50,000.00 none yes Damian Cook/John Snyder yes yes
Jun-19 $20,695.40 $50,000.00 none yes Damian Cook/John Snyder yes yes
Jul-19 $34,593.60 $50,000.00 none yes Damian Cook/John Snyder yes yes
Aug-19 $48,256.59 $50,000.00 none yes Damian Cook/John Snyder yes yes
Sep-19 ? $40,000.00 none yes Damian Cook/John Snyder yes yes
Oct-19 $33,415.00 $46,000.00 none yes Damian Cook/John Snyder yes yes
Nov-19 $44,655.09 $46,000.00 none yes Damian Cook/John Snyder yes yes
Dec-19 $31,449.84 $50,000.00 none yes Damian Cook/John Snyder yes yes
Jan-20 $32,620.00 $50,000.00 none yes Damian Cook/John Snyder yes yes
Feb-20 $26,537.10 $62,500.00 none none none none
Mar-20 $36,406.61 $62,500.00 none none none none
Apr-20 $30,584.52 $62,500.00 none none none none
May-20 $42,254.00 $62,500.00 none none none none
Jun-20 $34,537.29 $62,500.00 none none none none
Jul-20 $30,037.23 $62,500.00 none none none none
Aug-20 $36,333.90 $62,500.00 none none none none
Sep-20 $62,084.17
Oct-20 $62,084.17
Nov-20 $46,607.78
Dec-20 $71,691.97
Jan-21 $59,827.93 $59,827.93 partial none Kendra Mervin/John Snyder none none
Feb-21 $55,856.31 $55,856.31 none none Kendra Mervin, Najera Johnson yes none
Mar-21 $58,605.71 $58,605.71 partial none Kendra Mervin, Najera Johnson yes none
Apr-21 $59,415.61 $59,415.61 yes none Kendra Mervin, Najera Johnson yes none
May-21 $64,905.47 $64,905.47 yes none Kendra Mervin, Najera Johnson none none
Jun-21 $49,634.46 $49,634.46 yes none Kendra Mervin, Najera Johnson none none
Jul-21 $105,573.70 $105,573.70 yes none Kendra Mervin, Najera Johnson none none
Aug-21 $51,505.10 $51,505.10 yes none Kendra Mervin, Najera Johnson yes none
Sep-21 $99,094.17 $99,094.17 yes none Kendra Mervin, Najera Johnson yes none
Oct-21 $62,084.17 $62,084.17 none none Kendra Mervin, Erika Miller none none
Nov-21 $46,607.78 $46,607.78 none none Kendra Mervin, Erika Miller none none
Dec-21 $71,691.97 $71,691.97 none none Kendra Mervin, Erika Miller none yes
Jan-22 $32,027.85 $32,027.85 none none Kendra Mervin, Terry Powell yes none
Feb-22 $54,627.77 $54,627.77 none none Kendra Mervin, Terry Powell yes none
Mar-22 $46,548.60 $46,548.60 none none Kendra Mervin, Terry Powell yes none
Apr-22 $58,009.60 $58,009.60 none none Kendra Mervin, Terry Powell yes none
May-22 $53,535.97 $53,535.97 none none Kendra Mervin, Terry Powell yes none
Jun-22 $53,702.44 $53,702.44 none none Kendra Mervin, Terry Powell yes none
Jul-22 $75,234.55 $73,234.55 none none Kendra Mervin, Terry Powell yes none
Aug-22 $54,689.80 $54,689.80 none none Kendra Mervin, Terry Powell none none
Sep-22 $103,022.47 $103,022.47 none none Kendra Mervin, Terry Powell none none
Oct-22 $40,065.19 $40,065.19 none none Kendra Mervin, Terry Powell yes none
Nov-22 $44,673.76 $44,673.76 none none Kendra Mervin, Terry Powell yes none
Dec-22 $62,488.23 $62,488.23 none none Kendra Mervin, Terry Powell yes none
Jan-23 $46,480.71 $46,480.71 none none Kendra Mervin, Terry Powell yes none
Feb-23 $46,633.28 $46,633.28 none none Kendra Mervin, Terry Powell yes none
$2,303,321.03 $2,424,042.60

Chart #1

In summary of the above chart, the DGCC could not provide an invoice from BTTC for September 2019,
although they still received $40,000.00. There were months that the DGCC could not provide any
information related to this contract. From September 2020 to December 2020, DGCC could not provide
any of the reports or even name the personnel assigned to the contract despite funds being released to
BTCC. There is no information on who was assigned to oversee the contract for all of 2020. Very little
proof exists that any site visits were conducted, and five different Human Services Planners were assigned
from 2019 to 2023.
To understand more about how the contract was administered, we interviewed Terry Powell, the Human
Services Planner who monitored the BTTC contract from January 2022 until it was canceled in March
2023. (Attachment #2) Powell stated his responsibilities included organizing meetings between
stakeholders, reviewing invoices from the contractor, coordinating with Cure the Violence Global, and
making recommendations to the Grants Administrator. He described himself as the first layer of review of
the invoices submitted by the contractor. If there were any questionable expenses, he would coordinate
with Jennings, the BTTC Site Manager, to clarify and correct the requests for reimbursement.
After his review, Powell passed the invoices to his supervisor, John Snyder, who reviewed them and gave
them to Mervin for final approval. They were then passed on to Finance for payment.
Powell was responsible for conducting monthly site visits. During these visits, he reviewed BTTC’s
compliance with the contract terms and scored them on the deliverables. These scores involved the
COJ Office of Inspector General | 4

number of participants and their progression towards their stated goals. He does not know how this was
handled before he took on his oversight responsibilities.
We also spoke to John Snyder, Human Services Planner Supervisor (Attachment #3). Before the contract
was awarded, the COJ advertised a Request for Proposal (RFP). Snyder was not involved in evaluating
the proposals that were received. The City Council eventually made the selections and tasked the DGCC
with oversight. However, the DGCC had limited oversight because the City Council decided to make
these performance contracts. If the contractor met specific metrics or goals each month, they would get an
agreed-upon amount of funds but would not have to justify their expenses to get reimbursed.
Snyder believed the contractor's goals included outreach, community events, and tracking participant
numbers. For the first couple of years of the contract, Cure the Violence Global initially monitored these
goals. Snyder did not know who decided to use Cure the Violence Global to monitor BTTC's performance
goals.
Snyder could not explain why there were gaps in the information retained by DGCC. At some point in
2020, the monitoring of the contract goals was transferred from Cure the Violence Global to the DGCC.
Simultaneously, the City Council altered the contract terms from one based on performance to a direct
reimbursement agreement. Snyder noted that the City Council did not communicate this change to the
DGCC, leading to a period when the DGCC did not verify BTTC’s expenses before paying the invoices.
Termination of the Contract
Throughout the contract, employee salaries were paid through a payroll service; however, Tutwiler and
Jennings's compensation was paid by check to the NWJCDC. Powell did not know why the compensation
to Tutwiler and Jennings was paid in this manner, and this practice was in place before he took over the
contract. He was also aware that BTTC was paying rent to the NWJCDC over $3,000.00 per month for
the space where they were located. Snyder did not have an opinion on this amount, but Powell felt there
was some overlap between the space rented by the BTTC and the space occupied by the NWJCDC.
Towards the end of 2020, BTTC submitted an invoice to Powell that included a bonus of $10,000.00 for
Tutwiler and $10,500.00 for Jennings. Powell said Mervin and Snyder rejected these amounts and
questioned why the other employees were not receiving bonuses. Jennings tried to justify the bonuses by
explaining that the executive team was doing a great job, and the rest of the staff was not performing “up
to snuff.”
After consulting with Mervin and Snyder, Powell instructed BTTC that they were allowed to give
bonuses to staff, but they had to be reasonable and shared equitably. Powell believed each employee
received approximately a $2,000.00 bonus from COJ funds. Bonuses were not excluded under the
agreement, but $10,000.00 did not meet the reasonable test. Snyder said that bonuses are usually
calculated at approximately 1% or 2% of the employee's salary. It was later determined through a review
of the bank records that Tutwiler and Jennings did receive significant bonuses despite the instructions
from the DGCC staff.
Soon after, Mervin terminated the contract for convenience. (Attachment #4) Snyder said the bonuses
were the last straw for Mervin. The rent, management fees, and various administration fees just added up
to the point where Mervin decided to terminate their agreement.
Powell said that Mervin used her authority as Grants Manager to “Terminate for Convenience,” a clause
in the agreement. Powell said Mervin had grown tired of BTTC’s continued issues with their monthly
invoices. There were numerous instances where staff had to decline reimbursements or ask for
COJ Office of Inspector General | 5

clarifications of expenses. It appeared to become a situation where BTTC tried to exhaust the contract
funds with whatever expenses they could attribute to the budget categories and push the envelope to see
what would be approved. Powell agreed that the final straw for Mervin was the request for exorbitant
bonuses for Tutwiler and Jennings.
Failure to Maintain Records and Secure Property Purchased with Contract Funds
Snyder said that after the termination, BTTC was responsible for turning over all the equipment they
purchased with COJ funds, which cost more than $1,000.00. They were also required to turn over all their
participant files. Although surrendering the equipment is a requirement, it rarely happens with contractors.
Usually, because the COJ does not have a mechanism to repurpose the property, it winds up sitting in an
office somewhere.
After the agreement was terminated, Powell requested that BTTC provide all its documents related to the
contract, including employee personnel files and participant folders. Surprised by the contract's
termination, Tutwiler initially refused to turn over the requested documents but eventually relented.
Powell received approximately 26 participant files and some miscellaneous electronic devices.
Snyder was not surprised that they only turned over approximately 26 participant files. Most of their files
were stored in a proprietary system administered by Cure the Violence Global. Snyder said that BTTC’s
statistical accomplishments were “pretty decent.”
We contacted representatives of Cure the Violence Global and requested the statistical accomplishments
of BTTC for the life of the contract. (Attachment #5) There were a total number of 186 participants
listed from June 2019 to May 2023. The bulk of the participant information is stored in the proprietary
program administered by Cure the Violence Global, and BTTC could only produce approximately 26
paper files for participants. The contract clearly states that the contractor is required to retain all
participant case files, conflict mediations, and referrals for 5 years. BTTC failed to adhere to this
provision of the contract.
According to the records provided by BTTC, numerous items were purchased by BTTC with COJ funds
valued in excess of $1,000.00. These items, including a refrigerator and whiteboard, should have been
returned to COJ. Additionally, there were items purchased by BTTC that do not have any apparent
relation to the Cure the Violence Program, including audio recording equipment, a deep freezer, and an
oriental rug, as reported in the equipment log provided by BTTC. (Attachment #6)
Bridges to the Cure
In December 2023, we contacted Paul Tutwiler regarding his role in the COJ contract with BTTC.
Tutwiler said he was never given a reason why the COJ canceled the contract. He said BTTC filed all
necessary paperwork and had great reviews during the entire contract period. We requested that Tutwiler
turn over all Cure the Violence contract records or grant OIG investigators access. As per the contract,
BTTC was required to retain all the records related to the contract and make them available or provide
copies to the COJ upon request.
Tutwiler subsequently secured counsel in January 2024, and a subpoena was issued for the information
held by BTTC related to the COJ contract. The subpoena requested, in part, bank records for all known
accounts, loan applications, all accounting ledgers, supporting records and documents, payroll ledgers,
tax returns, employee files, participant files, and a list of all equipment purchased with COJ funds.
COJ Office of Inspector General | 6

Eventually, some of the requested information was provided to investigators. After a review, investigators
identified some questionable costs. Also, the “Expenditures by Vendor Summary” (Attachment #7)
provided by the BTTC did not correspond with the bank records in several categories, as per the chart
below.

BTTC Summary Bank Records


Amazon $ 8,219.61 $ 16,601.31
High Standard Roofing $ 18,000.00 $ 9,000.00
Mildred Jennings $ 36,018.10 $ 32,344.99
NWJCDC $ 838,452.95 $ 683,705.02
Paul Tutwiler $ 24,824.86 $ 19,824.86
Villages of North Port $ 29,000.00 $ 7,250.00
T-Mobile $ 16,059.06 $ 28,984.96
Chart #2

There is a significant difference between the amount claimed to be paid to Amazon and the actual amount
discovered in the bank records. While purchasing items from Amazon could be a legitimate expenditure
of contract funds, the discrepancy shows that BTTC could have been trying to conceal the actual
amount they were spending on these purchases. Additionally, BTTC did not provide any receipts related
to these purchases.
We also questioned the payments to High Standard Roofing because BTTC reportedly rented office space
in a building owned by NWJCDC. In most cases, a tenant does not pay for a landlord's roof, and there is
no explanation in the contract records for this expense.
The payments to Mildred Jennings are questionable because they include bonuses, per diem, and mileage.
Jennings received three bonuses while managing BTTC: $2,500.00 in July 2021, $2,250 in June 2022,
and the largest one of $10,500.00 in September 2022. (Attachment #8) She received an average of
$400.00 per month for mileage, a perk only granted to her and Tutwiler. The total amount paid to
Jennings listed above does not reflect the monthly management fee paid to the NWJCDC on her behalf,
averaging $3,700.00 per month. We do not know what Jennings's compensation was from the contract or
the NWJCDC, as we will highlight later in this report.
The payments to NWJCDC are questionable because of the large discrepancy in the amounts listed. This
also appears to indicate that the BTTC is concealing the amount of funds they are sending to the
NWJCDC. It is clear from the bank records that the BTTC paid the NWJCDC for rent, administrative
fees, and bookkeeping. However, there are numerous checks from the BTTC to the NWJCDC where the
check does not articulate any explanation. See below Chart #3.
COJ Office of Inspector General | 7

Date Amount Payee


Friday, February 18, 2022 $ 10,000.00 NWJCDC
Wednesday, March 2, 2022 $ 15,000.00 NWJCDC
Monday, March 14, 2022 $ 25,000.00 NWJCDC
Wednesday, March 23, 2022 $ 30,000.00 NWJCDC
Friday, April 8, 2022 $ 11,112.50 NWJCDC
Friday, May 27, 2022 $ 15,000.00 NWJCDC
Monday, June 13, 2022 $ 20,000.00 NWJCDC
Wednesday, September 7, 2022 $ 18,133.07 NWJCDC
Thursday, November 3, 2022 $ 12,500.00 NWJCDC
Tuesday, January 3, 2023 $ 15,000.00 NWJCDC
Total $ 171,745.57
Chart #3

Bank records revealed that approximately $54,673.92 was taken out of the BTTC accounts in cash, and
$142,163.40 in cash was deposited during the contract's life. These cash transactions appear to have been
conducted by Tutwiler. Bank records also showed that $40,594.56 was transferred to the BTTC Petty
Cash Account during the contract. Although Tutwiler did not provide the records of this account, we
obtained them, and a review showed that most of these funds were spent on food purchases, payroll, and
some travel expenses.
Snyder was asked if it was typical for large amounts of cash to flow between NWJCDC and BTTC. He
said they typically do not allow cash transactions because contractors must account for everything.
However, there could be an instance where they would need to use cash to interrupt violence by getting a
person out of a situation. It would have to be used for an allowable expense, but it is possible that they
would need cash.
Snyder explained that at the beginning of the contract, Snyder and Damien Cook met with Tutwiler and
Jennings and explained to them that they had to have separate accounting systems for the contract funds
and could not comingle funds from the NWJCDC. He also advised them not to double-dip income from
two separate programs because that would be a violation of federal regulations. Our review showed
significant commingling of funds between BTTC and NWJCDC.
The payments listed in Chart #3 attributable to Tutwiler are comprised of bonuses, mileage, and travel
expenses. These are direct payments to Tutwiler and do not include the Management Fee charged by
BTTC to the contract for his services. Like Jennings, we do not know Tutwiler’s compensation from this
contract because NWJCDC charged BTTC monthly for his services. These monthly payments averaged
approximately $3,600.00, and from the information provided, we do not know how much of that was paid
to Tutwiler. The bank records revealed a $10,000.00 check to Tutwiler in September 2022, which is
assumed to be a bonus, although the check did not have any information on the memo line. (Attachment
#8)
The contract records for the payments to the Villages of Northport do not explain why there is such a
discrepancy between what BTTC reported and what was found in the bank records. According to the
Florida Division of Corporations, Tutwiler is the Executive Director of the Villages of North Point LLC,
which is believed to be affiliated with the NWJCDC.
COJ Office of Inspector General | 8

We could not determine why there was such a discrepancy between the reported payments to T-Mobile
and what the bank records reflected. Cell phone services are allowable expenses under the contract
terms, but a $12,000.00 discrepancy is significant.
Payroll Protection Act Loans
We discovered that BTTC applied for and received two Payroll Protection Program (PPP) loans from the
U.S. Small Business Administration (SBA) during our investigation. According to the SBA website:
“PPP is a loan designed to directly incentivize small businesses to keep their workers on payroll.
First Draw PPP loans can be used to help fund payroll costs, including benefits, and may also be
used to pay for mortgage interest, rent, utilities, worker protection costs related to
COVID-19, uninsured property damage costs caused by looting or vandalism during 2020, and
certain supplier costs and expenses for operations.”
The COJ fully funded BTTC, so we question their eligibility to receive these funds and do not believe
they met the categories listed above. Snyder confirmed this information, stating that BTTC was formed
for the specific purpose of administering the Cure the Violence Program, and during the program, there
was never a disruption in funding. Additionally, as previously demonstrated in Chart #1, BTTC had over a
year of monthly payments from COJ, which were greater than their operational expenses. Since PPP is
not a COJ-funded program, we did not secure the loan applications but will refer this matter to the SBA
for whatever action they deem appropriate.
We also discovered that the NWJCDC received two PPP loans. Since the COJ does not fully fund the
NWJCDC, we do not question its eligibility for this program.
The loans for both entities were forgiven. Below is the loan information from the SBA.
COJ Office of Inspector General | 9

Additionally, we believe that by receiving this PPP loan, BTTC could have violated the dual payment
prohibition of the contract, which states:
XXVIII. DUAL PAYMENTS PROHIBITION

Provider shall not apply the Funds received under this Agreement to Services that are being or
have been paid or reimbursed, in whole, from other sources. Partial payment for Services from the
Funds under this Agreement, together with partial payment for the Services from other funding
sources is permissible if the total amount of all funds do not exceed the agreed upon monetary value
for the Service provided. Except as allowed in the immediately preceding sentence, application for
and receipt of dual payments is a material breach of this Agreement and may be grounds for
immediate termination, on 24 hours oral notice, and Provider shall be subject to damages in the
amount of the Funds that were received as dual payments.
COJ Office of Inspector General | 10

Return of Organization Exempt from Income Tax


We reviewed the NWJCDC Return of Organization Exempt from Income Tax, commonly referred to as
Form 990. (Attachment 10) The NWJCDC is required to file this form with the Internal Revenue Service
as part of its non-profit status and as a condition of receiving funds from the COJ. Since the BTTC is
reported to be a subsidiary of the NWJCDC, the funds, expenses, and officer compensation should be
reported on this form. We reviewed the Form 990 provided by Tutwiler, which was reported for the fiscal
year October 1, 2021, to September 30, 2022. During this time, the NWJCDC reported to have six
employees and paid $1,120,193.00 in compensation.
Below is an excerpt from the provided Form 990 related to the compensation of the NWJCDC officers.

There are several problems with the Form 990 provided by Tutwiler. No current officers or directors are
listed, no key employees are listed, and no compensated employees are listed where the form requires the
top five. Finally, the box checked above cannot be an accurate statement because the bank records reflect
compensation to both Tutwiler and Jennings during this period.
Non-profit organizations that receive COJ funding should be transparent. Form 990 is one tool used to
assure this transparency. An area of concern is the lack of a clear explanation of compensation to
officers in the contract documents and Form 990.
Findings
Division of Grants and Contract Compliance

x Failed to adequately monitor the contract due to personnel turnover and a lack of a formal
electronic contract management system.
x Failed to secure property purchased with contract funds and records required under the
agreement.
x Failed to adequately secure and maintain required contract documents, including invoices, site
visits, checklists, and narrative reports.
Bridges to the Cure
x Failed to adhere to the COJ requirement related to comingling funds.
x Failed to account for expenditures of contract funds and comply with records retention
requirements.
COJ Office of Inspector General | 11

x Failed to adhere to the dual payment prohibition of the contract agreement.


x Failed to surrender to the COJ all items purchased with contract funds valued at over $1,000.00.
x Lacked transparency in supervisor compensation.

Recommendations:
1. Provide DGCC with a formal electronic tracking system to ensure a seamless transition in
contract oversight should an employee's assignment change.
2. Develop a program to secure items purchased with contract funds that must be
surrendered to the COJ after the agreement has expired.
3. Consider administrative action for NWJCDC, BTTC, and related individuals for failing to adhere
to the contract agreement.
4. Ensure that organizations receiving COJ funds have adequate accounting systems to prevent
funds from being co-mingled with other sources.

Attachments:
1. COJ Contract with BTTC for the Cure the Violence Site Implementation
2. Memorandum of Interview, Terry Powell, COJ, Human Services Planner
3. Memorandum of Interview, John Snyder, Human Services Planner Supervisor
4. COJ Letter of Termination of Contract
5. Program Statistical Accomplishments from Cure the Violence Global
6. BTTC Equipment Log
7. BTTC Expenditures by Vendor Summary
8. $10,500.00 Check to Mildred Jennings from BTTC
9. $10,000.00 Check to Paul Tutwiler from BTTC
10. Form 990 Return of Organization Exempt from Income Tax

Inspector General Standards

This report/review has been conducted in accordance with the ASSOCIATION OF INSPECTORS
GENERAL Principles and Quality Standards for Investigations.

“Enhancing Public Trust in Government Through Independent and Responsible Oversight”


Attachment #1
Attachment #2
OFFICE OF INSPECTOR GENERAL
CITY OF JACKSONVILLE
MEMORANDUM OF INTERVIEW

Case No: 2024-0010


Date(s) of Interview: OIG Investigator(s):
December 6, 2023 Harry Cigliano
Person interviewed: Terry Powell COJ, Human Services Planner
Others present: Richard Samples Title: Interview of Terry Powell

On December 6, 2023, Investigator Harry Cigliano and Deputy Inspector General for
Investigations Richard Samples from the Office of Inspector General (OIG) interviewed
Human Services Planner Terry Powell. This interview took place at the COJ, Mayor’s
Office of Grants and Contract Compliance, 214 N. Hogan Street, Jacksonville, FL
32202. After agreeing that this interview would be voluntary and recorded, POWELL
provided the following information in part and substance.
POWELL has been employed with COJ for approximately ten years. His current position
is to oversee the Richard A. McKissick Memorial DAWN Program, which assists
incarcerated youth in transitioning back into society with tools and skills that give them
alternatives to the behaviors that led to their incarceration.
In approximately January 2022, POWELL was assigned an additional duty to oversee
the COJ grants to various entities under the Cure the Violence Initiative. POWELL
currently oversees the DAWN Program, but he recently transferred oversight of the
public service grant to Human Resources Planner Antonio Starke.
From approximately January 2022 to March 2023, he managed the Cure the Violence
grant to Bridges to the Cure LLC (BTTC). His responsibilities included organizing
meetings between stakeholders, reviewing invoices from the grantee, coordinating with
Cure the Violence Global, and making recommendations to the Grants Administrator.
POWELL described himself as the first layer of review of the invoices submitted by the
grantee. If there were any questionable expenses, POWELL would coordinate with
BTTC Site Manager MILDRED JENNINGS to clarify and correct the requests for
reimbursement.
After POWELL conducts his review, he passes the invoices to his supervisor, John
Snyder. SNYDER then passes the invoice to the Grants Administrator for final approval
and transfer to Finance for payment. The Grants Administrator when POWELL was
overseeing the BTTC program was Kendra Mervin.
POWELL was also responsible for doing monthly site visits. During these visits, he
would review BTTC’s compliance with the grant terms and score them on the
deliverables. These scores involved the number of participants and their progression
towards their stated goals. MERVIN always delegated these site visits to POWELL. He

Page 1 of 3
MEMORANDUM OF INTERVIEW OF TERRY POWELL (CONTINUED)

does not know how this was handled before he took on his oversight responsibilities.
BTTC was also required to have monthly events to advertise the program and support
the participants. These events were also part of the overall site visit score. POWELL did
not interview any of the participants in the BTTC program during site visits.
BTTC was required to have photos of the community events and post them on social
media. POWELL said he believed that there were times when BTTC claimed to have a
community event that did not happen. Also, there were times when the BTTC and the
Northwest Jacksonville Community Development Corporation (NJCDC) held joint
community events.
Paul Tutwiler is the Director of the NJCDC and BTTC. JENNINGS is also an employee
of the NJCDC and the site director of BTTC. The primary contact for BTTC was
JENNINGS. She was responsible for providing the information for the site visits and
submitting all invoices to the COJ for reimbursement.
POWELL would review these invoices and make sure that the requests for
reimbursement were allowable, allocable, and reasonable. BTTC was required to
submit receipts and other documentation supporting their invoices. These expenses had
to be attributable to a budget category outlined in the grant. Occasionally, BTTC
requested to move funds from one budget category to another. These requests were
reviewed and approved by the Grants Administrator. Once he reviewed the invoices and
ensured that the expenses fit the allowable, allocable, and reasonable test, SNYDER
would check his analysis. If SNYDER had any questions, he would usually place a
sticky note on the invoice and ask POWELL to request clarification from JENNINGS.
Once corrected or clarified, MERVIN would approve the invoice after she reviewed the
request. POWELL said there have been instances when grantees have overspent on
their grants and were forced to reimburse the COJ for the unfunded expenses.
Towards the end of 2020, BTTC submitted an invoice that included a bonus of
$10,000.00 for TUTWILER and $10,500.00 for JENNINGS. POWELL said MERVIN and
SNYDER rejected these amounts and wanted to know why none of the other
employees were receiving bonuses. JENNINGS tried to justify the bonuses by
explaining that the executive team was doing a great job, and the rest of the staff was
not performing “up to snuff.”
After consulting with MERVIN and SNYDER, it was decided that BTTC was allowed to
give bonuses to their staff, but they had to be reasonable and shared equitably.
POWELL believed each employee received approximately a $2,000.00 bonus from
grant funds. Bonuses are not precluded under the grant agreement, but $10,000.00 did
not meet the reasonable test.
POWELL said the bonuses were allocated under the compensation category. Employee
salaries and compensation to the executive team were also categorized as
compensation. The salaries to TUTWILER and JENNINGS were paid as an invoice from
the NJCDC. These invoices were listed as Management Fees from the NJCDC to

Page 2 of 3
MEMORANDUM OF INTERVIEW OF TERRY POWELL (CONTINUED)

BTTC. POWELL does not know why the compensation to TUTWILER and JENNINGS
was paid this way, and this practice was in place before he took over the grant.
POWELL did have conversations with MERVIN and SNYDER about this management
fee, but he could not remember the reasons for this arrangement.
BTTC was in an office within a business owned by NJCDC, and as a result, rent was
paid from grant funds to the NJCDC each month. POWELL said there was some
overlap in the space used by BTTC and NJCDC.
Also paid from grant funds were mileage reimbursements each month for travel
attributable to program activities. However, reimbursements were only paid to
TUTWILER and JENNINGS. POWELL said JENNINGS implied that she was claiming
the mileage and reimbursing the employees for their expenses, but he did not believe
this was true.
During his tenure over the grant, POWELL was notified that a female BTTC employee
filed a sexual harassment complaint against a male supervisory employee. He did not
handle any issues related to this complaint, and all those communications were
forwarded to MERVIN. He heard that this complaint was resolved because the
employee who filed the complaint was fired. He thought that firing this employee was
questionable.
The same employee who filed the complaint also received grant funds to assist her in
paying her rent. POWELL said this was allowable because the employees are
participants first, and the program was designed to support them too. BTTC did not
conceal this rental payment, and POWELL approved this expense.
Eventually, MERVIN decided to terminate the grant with BTTC. MERVIN used her
authority as Grants Manager to “Terminate for Convenience," a clause in the grant
agreement. POWELL said MERVIN had grown tired of BTTC’s continued issues with
their monthly invoices. There were numerous instances where grant staff had to decline
reimbursements or ask for clarifications for expenses. It appeared to become a situation
where BTTC tried to exhaust the grant funds with whatever expenses they could
attribute to the budget categories and push the envelope to see what would be
approved. The final straw for MERVIN was the request for the exorbitant bonuses to
TUTWLER and JENNINGS.
As part of the termination procedure, POWELL requested that BTTC provide all their
documents related to the grant, including employee personnel files and participant
folders. TUTWILER, surprised by the grant's termination, initially refused to turn over the
requested documents but eventually relented. POWELL agreed to allow access to all
the records recovered from BTTC.

Page 3 of 3
Attachment #3
OFFICE OF INSPECTOR GENERAL
CITY OF JACKSONVILLE

MEMORANDUM OF INTERVIEW

Case No:2023-10-003 OIG Investigator(s): Harry Cigliano


Person interviewed: John Snyder Interview Location: 214 Hogan St.,
Jacksonville, FL
Title: Bridges to the Cure Date of Interview: June 17, 2024

On June 17th, 2024, Investigator Harry Cigliano interviewed John Snyder, Human Services
Planner for the City of Jacksonville (COJ), Division of Grants and Contract Compliance
(DGCC), formerly the Office of Grants and Contract Compliance (OGCC). SNYDER was
interviewed regarding a COJ grant awarded to Bridges to the Cure LLC. SNYDER agreed to
have the interview recorded and provided the following, in part and substance.

SNYDER has been a COJ employee for approximately 28 years. He started as a mental health
counselor and has been assigned to the OGCC for 22 years. He currently reports to Maribel
Hernandez, the Acting Chief Grants Administrator. The former Chief Grants Administrator,
Audrey Gibson, left her position the week before this interview.
In approximately May 2019, the City Council and Mayor awarded significant grants to address
the violence occurring in several parts of the city. The COJ partnered with a contractor named
Cure the Violence Global, which had a program designed to use members of the community to
interrupt and suppress violence. The grant for the Moncrief neighborhood was awarded to
Bridges to the Cure LLC, an affiliate of the North West Community Development Corporation
(NWCDC). OGCC terminated the grant in January 2023.
The grant was awarded under Chapter 118 of the Jacksonville Code of Ordinances. This chapter
does not require that a grantee be an approved non-profit entity. If this grant had been a Public
Service Grant, they would have been required to be a non-profit. Snyder was aware that the
NWCDC was prohibited from receiving grant funds when they were being considered for the
funds because they had failed to submit a timely audit. Snyder said this is typical of grantees and
something they deal with regularly. All grantees must submit their standard Form 990, “Return of
Organization Exempt from Income Tax,” and a schedule of expenses with the Council Auditors
Office.
Even if the NWCDC was on the non-compliance list and prohibited from receiving COJ grant
funds, the Cure the Violence Grant would have gone through because it was not technically
going to the NWCDC. The official grantee was Bridges to the Cure LLC.
Before the grant was awarded, the COJ advertised a Request for Proposal (RFP). SNYDER was
not involved in evaluating the proposals that were received. Eventually, the City Council wanted
the funding moved to Chapter 126, which falls under the procurement code and has a different
set of guidelines relating to audits, expenditures, and expenses.

1
The City Council eventually made the grant selections and tasked the OGCC with oversight.
However, the OGCC had limited oversight because the City Council decided to make these
performance grants. If the grantees met specific metrics or goals each month, they would get an
agreed-upon amount of grant funds but would not have to justify their expenses to get
reimbursed.
SNYDER clarified that he was not part of the initial oversight of the grant. This responsibility
fell to Grants Administrator Damian Cook, a former employee. As Bridges to the Cure was on a
performance grant, there was no immediate need to verify their expenses as long as they met
their goals. These goals, which SNYDER believed included outreach, community events, and
participant numbers, were initially monitored by Cure the Violence Global. While COJ does not
typically issue performance grants, there have been instances where they have been used for
specific programs.
Performance grants are difficult to monitor because a grantee cannot earn profit from grant
funds. SNYDER reviewed a financial report from Bridges to the Cure in which they were given
$65,000.00 in grant funds but only reported approximately $44,000.00 in expenses. He was not
aware of the difference between the payment and the expenses, and he said he would have
contacted the Chief Financial Officer for an accounting of the additional funds. Even though they
received funding above their expenses, they are restricted in how they use the money and should
only use it for grant expenses.
At some point in 2020, the monitoring of the grant was transferred to the OGCC.
Simultaneously, the City Council altered the terms of the grant to a direct reimbursement grant.
SNYDER noted that the City Council did not communicate this change to the OGCC, leading to
a period when the OGCC did not verify Bridges to the Cure's expenses before providing them
with funding.
SNYDER learned at some time that Bridges to the Cure applied for a Payroll Protection Plan
(PPP) Loan. He does not know what was reported to become eligible for that loan because it was
a federal program. He could say that during the grant period, there was never a disruption to the
funding granted to Bridges to the Cure from the COJ. Also, he believed that Bridges to the Cure
was formed for the specific purpose of administering the Cure the Violence Program and was
solely funded by grant funds.
Sometime in 2021, Kendra Mervin became the Grants Administrator. SNYDER said there were
times when he filled in as the Grants Administrator and would sometimes review the financial
reports of Bridges to the Cure. Still, he only served in an advisory capacity and had no authority
to approve invoices. Aside from the Grants Administrator, a Human Services Planner is usually
in charge of reviewing the invoices. This person usually serves as the technical representative to
the Grants Administrator. This grant had at least two Grants Administrators and probably four
separate Humans Services Planners assigned.
The last Human Services Planner was Terry Powell. SNYDER could not explain the gaps in the
financial reports provided by POWELL. Specifically, September 2020 to December 2020 were

2
missing from the COJ records. He agreed to search for those records and provide them after the
interview.
SNYDER did not remember why, in March 2021, the demands for documentation from Bridges
to the Cure became more detailed. However, he remembered that a meeting had been held
between OGCC personnel, Paul TUTWEILER and Mildred Jennings. TUTWIELER and
JENNINGS were the managers of the Bridges to the Cure and are both employees of the
NWCDC.
At the beginning of the grant, he and Damien Cook met with TUTWEILER and JENNINGS and
explained to them that they had to have separate accounting systems for the grant funds and
could not comingle funds from the NWCDC. He also advised them not to double-dip income
from two separate programs because that would be a violation of federal regulations. It took
them about five months to set up the separate account and get the reports straightened out.
Soon after, he discovered that the NWCDC was billing Bridges to the Cure for TUTWEILER
and JENNINGS as a management fee. He believed that this was a partial salary. He felt this was
unusual, but it happens on other grants. He did not have an opinion on the over $3,000.00 a
month that the NWCDC was charging the Bridges to the Cure for rent at a property they owned.
He also did not know what the $400.00 a month administrative or the $4,000.00 periodic
bookkeeping fee was for. He was unaware of the $18,000.00 roofing fee that was charged to the
grant or why $29,000.00 in grant funds went to the Villages of Northport LLC, a company
owned by TUTWEILER.
SNYDER was informed that according to the records provided, approximately $838,000.00 in
grant funds were paid to the NWCDC from Bridges to the Cure for management fees, rent,
bookkeeping, and administration fees. He said it was his opinion that it seemed like a lot of
money. Additionally, the expense reports provided by Bridges to the Cure do not reconcile with
the expenditures listed on the general ledger provided by TUTWEILER. SNYDER said this is
typical with grantees.
SNYDER was asked if it was typical for large amounts of cash to flow between NWCDC and
Bridges to the Cure. He said they typically do not allow cash transactions because they need to
account for everything. However, there could be an instance where they would need to use cash
to interrupt violence by getting a person out of a situation. It would have to be used for an
allowable expense, but it is possible that they would need cash.
While Kendra Mervin was the Grants Administrator, Bridges to the Cure requested
reimbursements for bonuses to TUTWEILER and JENNINGS. SNYDER said that bonuses are
usually calculated at approximately 1% or 2% of the employee's salary, but the request was for
$15,000.00 and $10,000.00 to TUTWEILER and JENNINGS, respectively. There was a lot of
discussion in the office about this request, and Bridges to the Cure was eventually told they
could not pay these exorbitant bonuses. To award bonuses, they had to be reasonable and spread
out equitably amongst all employees. Soon after, MERVIN terminated the grant for convenience.
SNYDER said the bonuses were the last straw for MERVIN. The rent, management fees, and

3
various administration fees just added up to the point where MERVIN decided to terminate their
agreement.
At the conclusion of the grant, Bridges to the Cure was responsible for turning over all of the
equipment they purchased with grant funds, which cost more than $1,000.00. They were also
required to turn over all of their participant files. Although surrendering the equipment is a
requirement, it rarely happens with grantees. Usually, because the COJ does not have a
mechanism to repurpose the property, it winds up sitting in an office somewhere. He
remembered that it was an issue between the OGCC and Bridges to the Cure related to closeout.
The OGCC eventually received some material and equipment from Bridges to the Cure, but he
was not part of the inventory of these items.
He was not surprised that they only turned over approximately 26 participant files. A proprietary
system administered by Cure the Violence Global stored most of their participant files. SNYDER
believed that Cure the Violence Global would provide that information if requested. SNAYDER
said, overall, Bridges to the Cure’s statistical accomplishments were “pretty decent.” The Grants
Administrator would also have access to the database and would be able to verify the
interventions that Bridges to the Cure claimed.
The former Grants Administrator, MERVIN, left the COJ and works for Cure the Violence
Global.

4
Attachment #4
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Attachment #9
Attachment #10

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