Audit 368421

Agency: U.S. Department of Housing and Urban Development (HUD) Federal program: Community Development Block Grant – Disaster Recovery (CDBG-DR) ALN: 14.228 Compliance requirement: Reporting Category: Compliance / Internal Control over Compliance Questioned Costs: None Repeat finding: No Condition: Monthly progress reports required under the CDBG-DR program were not filed within the required deadline of the 5th day following the reporting month. Although management prepared the reports, submission to the PRDOH system was delayed until the prior month’s report was reviewed and approved. As a result, all reports were ultimately submitted late. Criteria: 2 CFR 200.328 and the subrecipient agreement requires subrecipients to submit performance and financial reports by the deadlines established by the awarding agency. PRDOH has established that monthly reports must be filed no later than the 5th day of the month following the reporting period. Cause: Management indicated that reports were completed on time but could not be filed until PRDOH cleared the previous month’s report. This dependency caused delays outside of the Organization’s direct control. Effect: The Organization was not in compliance with established reporting deadlines. While no questioned costs were identified, late submission reduces the timeliness of information available for monitoring and increases the risk of additional oversight or restrictions by PRDOH. Recommendation: We recommend that management maintain evidence that reports are prepared by the required due date, even if PRDOH system delays prevent immediate submission. Copies of completed reports and correspondence with PRDOH should be retained to demonstrate compliance efforts. Management should also formally communicate with PRDOH regarding systemic delays and seek clarification to minimize future reporting exceptions.