Finding Text
Name of Federal Agency
US Department of Housing and Urban Development (HUD)
Pass-through the Puerto Rico Housing Department
Federal Program
14.288 Community Development Block Grant - Disaster Recovery
Category
Compliance / Internal control
Compliance Requirements
Reporting
Criteria
Uniform Guidance, Part 200.329 (c)(i) established that the non-Federal entity must submit performance
reports at the interval required by the Federal awarding agency or pass-through entity to best inform
improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor
more frequent than quarterly except in unusual circumstances, for example where more frequent reporting
is necessary for the effective monitoring of the Federal award or could significantly affect program
outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no
later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be
due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or
pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards.
As per agreement with the Authority clause II (b) established that the Authority shall submit regular
monthly progress reports to the Puerto Rico Department of Housing (PRDOH), on the form and with the
content to be specified and required by the PRDOH. The PRDOH will later notify the Authority in writing
the guidelines and requirements applicable to the submittal of the monthly progress reports, and such
notification shall be deemed incorporated by reference to this Agreement. This clause is in accordance with
the guidance of the Subrecipient Guide.
Condition
During our procedures performed to determine compliance with reporting requirements, we noted that the
Progress Report was not submitted on time to Puerto Rico Department of Housing (PRDOH).
Cause and Potential Effect
Noncompliance with the reporting requirements could lead to significant administrative actions by the
grantor, including a reduction in the amounts to be awarded. In addition, it prevents the grantor from
monitoring the performance of the program and could be interpreted as a failure to achieve program
objectives.
Questioned Costs
None
Recommendation
The Authority shall ensure effective supervision over its reporting processes to guarantee the timely
preparation and submission of progress reports. It is advised that the Authority prioritize providing
comprehensive training to personnel responsible for preparing, reviewing, and approving performance
reports. This training should focus on equipping them with the necessary skills and knowledge to include
all relevant data elements and adhere to deadlines consistently.
Views of responsible officials:
Pursuant to the Subrecipient Agreement, on July 2, 2020, the Authority became the administrator of the
Program. However, it wasn’t until June 1, 2021, when the Authority formed the Division, which consists
of a team of employees designated to administer and implement the Program, and its priorities include
ensuring that all Program requirements are being met. This includes submitting the Progress Reports that
were past due before the Division’s formation and making sure that all future reports are submitted on time.
Since then, the Division has been submitting the Progress Reports on time and is currently up to date.
Moreover, the following measures have been taken to ensure compliance with this requirement:
1. On October of 2021, the Progress Reports began to be submitted electronically through the Grant
Compliance Portal (GCP), making this process more efficient and faster.
2. The staff members responsible for submitting the Progress Reports are given frequent training on the
report’s requirements and the GCP usage.
3. The Division continues to recruit additional personnel as needed.
Therefore, the Program is currently in compliance with the Progress Reports submittal and the issues that
might have caused any delays in submitting such reports before the Division’s formation were addressed.
Responsible Person:
Mrs. Janet Pérez / Mrs. Sheila Hernández