Action Item Title 2023-003 – Federal Award Findings Status (Open: In-process) Condition Matching Non-Federal Funds The Corporation expended $523,590 from FEMA funds but did not meet the required cost-sharing amount of $52,359 from the Community Development Block Grant - Disaster Recovery (CDBG-DR) f...
Action Item Title 2023-003 – Federal Award Findings Status (Open: In-process) Condition Matching Non-Federal Funds The Corporation expended $523,590 from FEMA funds but did not meet the required cost-sharing amount of $52,359 from the Community Development Block Grant - Disaster Recovery (CDBG-DR) funds. On September 9, 2021, the Corporation signed a Community Development Block Grant – Disaster Recovery (CDBG-DR) Non-Federal Match Program Agreement with the PRDOH, to comply with FEMA's matching requirement. The Corporation only requested a reimbursement of $4,224. Identified root cause The Corporation’s failure to request the full matching amount was due to inadequate monitoring and oversight of the matching requirement. The Corporation did not ensure that the necessary CDBG funds were allocated to meet the 10% cost-sharing requirement. Grantee resolution plan Matching Non-Federal Funds The Corporation’s CDBG Subrecipient Agreement does not currently support FEMA’s 10% local match requirement due to stricter federal compliance rules under HUD, which exceed FEMA’s. As a result, the Corporation contacted the Central Office for Recovery, Reconstruction, and Resiliency (COR3), its pass-through entity, to request assistance in identifying alternative funding sources to fulfill the 10% matching requirement. We recognize the importance of complying with the matching requirements established by the federal regulations applicable to the program. We clarify that the funds used as "matching" come from eligible sources by the regulations of the Department of Housing and Urban Development (HUD) and have been properly documented in our financial records. During the audited period, all necessary actions were taken to ensure that the matching funds met the requirements of eligibility, proportionality, and traceability. Nevertheless, we have considered the auditor’s comments and, as a corrective and proactive measure, we are strengthening our controls and documentation procedures to ensure full compliance with future audits. We appreciate the observation noted in the Single Audit report regarding compliance with the matching fund requirements for CDBG funds. We would like to clarify that our entity has complied with the applicable federal provisions regarding the contribution of equivalent funds, as established in 24 CFR Part 570 and the guidelines issued by HUD. Supporting documentation that validates compliance with the required match has been collected. It is available for review, including financial statements, reports of local contributions, and project records demonstrating the investment of non-federal resources applicable to the program. If there is any discrepancy in the interpretation regarding the source or eligibility of the matching funds presented, we are willing to clarify and provide additional evidence to support their use in accordance with the regulations. It should also be noted that the Corporation is periodically audited by the Housing Department, ensuring compliance with all relevant requirements. We remain committed to transparency and the rigorous fulfillment of all federal requirements. We appreciate the recommendations provided to continue strengthening our internal control and documentation processes. Completion date Pending assistance and resolution from COR3. Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov