Criteria - Per Capital Fund Program (CFP) (Assisting Listing Number 14.872) regulations (24 CFR
905.322), a Public Housing Authority is required to submit form HUD-53001, Actual
Modernization Cost Certificate (AMCC) along with the final HUD-50075.1, Performance and
Evaluation Report (P&E) within 90 days after the expenditure end date of the grant, in order to
initiate the closeout process. The AMCC and P&E must detail actual costs incurred from the Date
of Full Availability (DOFA) to the completion of the modernization project.
Condition - The Authority failed to submit the final P&E along with the AMCC to HUD by the 90
day due date for its CFP NY01P099501-16, NY01P099501-17 and NY01P099501-18 grants.
Cause - The failure to complete the P&E with the AMCC and closeout process appears to stem from
administrative oversight and a lack of monitoring controls to ensure compliance with HUD’s grant
requirements.
Effect - Failure to timely submit the P&E with the AMCC may is not compliant with HUD
regulations, which may affect the Authority’s ability to secure future funding allocations.
Questioned Costs - None identified.
Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample.
Recommendation - The Authority should expedite the completion of the P&E with the AMCC and
submit the necessary closeout documentation for grants mentioned in the Condition above.
Additionally, the Authority should develop and implement a grant management tracking system to
monitor the status of all active grants, including deadlines to adhere to performance reporting
requirements.
Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding.
The Authority also agrees with the recommendations, please see below for action taken.
(b) Action taken - The Authority submitted all required closeout documentation and
received approval from HUD on July 3, 2025.
(c) Planned implementation date of corrective action - Completed by December 31, 2025.
Criteria - Per Capital Fund Program (CFP) (Assistance Listing Number 14.872) regulations (24
CFR § 905.314(l)), Capital Funds transferred to operations (Budget Line Item (BLI) 1406) are not
considered obligated until the Authority has both budgeted the funds in BLI 1406; and submitted a
voucher request in the Line of Credit Control System (LOCCS) for those funds. The voucher
request date in LOCCS constitutes the point at which the funds become obligated. The reported
obligation amount and date in LOCCS must match the Authority's accounting records, and the
voucher request date must occur before funds are reported as obligated in LOCCS.
Condition - For sampled transactions where CFP funds were transferred to operations, the voucher
request dates in LOCCS occurred after the funds were reported as obligated in the Obligation &
Expenditure tab.
Cause - The Authority did not establish procedures to ensure that the voucher request in LOCCS
was submitted prior to reporting the funds as obligated under the Obligation & Expenditure tab.
Effect - The Authority is not in compliance with the obligation requirements for funds transferred to
operations under CFP. This practice may result in inaccurate reporting of obligations and potential
disallowance of costs not properly obligated according to federal requirements.
Questioned Costs - None identified.
Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample.
Recommendation - The Authority should revise its procedures to ensure that voucher requests for
BLI 1406 funds are submitted in LOCCS before funds are reported as obligated in the Obligation &
Expenditure tab. Additionally, the Authority should provide training to staff responsible for CFP
administration on the correct sequence for obligating and drawing down funds in accordance with
24 CFR § 905.314(1).
Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding.
The Authority also agrees with the recommendations, please see below for action taken.
(b) Action taken - The Authority will begin submitting voucher requests for BLI 1406
before funds are reported as obligated.
(c) Planned implementation date of corrective action - Completed by December 31, 2025.
Criteria - Per Capital Fund Program (CFP) (Assisting Listing Number 14.872) regulations (24 CFR
905.322), a Public Housing Authority is required to submit form HUD-53001, Actual
Modernization Cost Certificate (AMCC) along with the final HUD-50075.1, Performance and
Evaluation Report (P&E) within 90 days after the expenditure end date of the grant, in order to
initiate the closeout process. The AMCC and P&E must detail actual costs incurred from the Date
of Full Availability (DOFA) to the completion of the modernization project.
Condition - The Authority failed to submit the final P&E along with the AMCC to HUD by the 90
day due date for its CFP NY01P099501-16, NY01P099501-17 and NY01P099501-18 grants.
Cause - The failure to complete the P&E with the AMCC and closeout process appears to stem from
administrative oversight and a lack of monitoring controls to ensure compliance with HUD’s grant
requirements.
Effect - Failure to timely submit the P&E with the AMCC may is not compliant with HUD
regulations, which may affect the Authority’s ability to secure future funding allocations.
Questioned Costs - None identified.
Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample.
Recommendation - The Authority should expedite the completion of the P&E with the AMCC and
submit the necessary closeout documentation for grants mentioned in the Condition above.
Additionally, the Authority should develop and implement a grant management tracking system to
monitor the status of all active grants, including deadlines to adhere to performance reporting
requirements.
Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding.
The Authority also agrees with the recommendations, please see below for action taken.
(b) Action taken - The Authority submitted all required closeout documentation and
received approval from HUD on July 3, 2025.
(c) Planned implementation date of corrective action - Completed by December 31, 2025.
Criteria - Per Capital Fund Program (CFP) (Assistance Listing Number 14.872) regulations (24
CFR § 905.314(l)), Capital Funds transferred to operations (Budget Line Item (BLI) 1406) are not
considered obligated until the Authority has both budgeted the funds in BLI 1406; and submitted a
voucher request in the Line of Credit Control System (LOCCS) for those funds. The voucher
request date in LOCCS constitutes the point at which the funds become obligated. The reported
obligation amount and date in LOCCS must match the Authority's accounting records, and the
voucher request date must occur before funds are reported as obligated in LOCCS.
Condition - For sampled transactions where CFP funds were transferred to operations, the voucher
request dates in LOCCS occurred after the funds were reported as obligated in the Obligation &
Expenditure tab.
Cause - The Authority did not establish procedures to ensure that the voucher request in LOCCS
was submitted prior to reporting the funds as obligated under the Obligation & Expenditure tab.
Effect - The Authority is not in compliance with the obligation requirements for funds transferred to
operations under CFP. This practice may result in inaccurate reporting of obligations and potential
disallowance of costs not properly obligated according to federal requirements.
Questioned Costs - None identified.
Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample.
Recommendation - The Authority should revise its procedures to ensure that voucher requests for
BLI 1406 funds are submitted in LOCCS before funds are reported as obligated in the Obligation &
Expenditure tab. Additionally, the Authority should provide training to staff responsible for CFP
administration on the correct sequence for obligating and drawing down funds in accordance with
24 CFR § 905.314(1).
Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding.
The Authority also agrees with the recommendations, please see below for action taken.
(b) Action taken - The Authority will begin submitting voucher requests for BLI 1406
before funds are reported as obligated.
(c) Planned implementation date of corrective action - Completed by December 31, 2025.