Finding Text
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) within 90 days after the expenditure end date of the grant, in order to initiate the closeout process. The AMCC must detail actual costs incurred from the Date of Full Availability (DOFA) to the completion of the modernization project.
Condition - The Authority received a CFP grant (Grant No. NY01P035501-18) with an expenditure end date of May 28, 2024. The final draw on this grant was made on December 22, 2022. As of the date of this independent auditors’ report, the Authority has not submitted the AMCC to HUD Actual Modernization Cost Certificate (AMCC) to the HUD within the required timeframe.
Cause - The failure to complete 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 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 AMCC and submit the necessary closeout documentation for NY01P035501-18 to HUD. Additionally, the Authority should develop and implement a grant management tracking system to monitor the status of all active grants, including deadlines for closeout and AMCC completion.
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 immediately initiate the closeout process for the two CFP grants by preparing and submitting all required closeout documentation to HUD. This includes completing the AMCC, certifying expenditures, and submitting necessary reports through HUD’s electronic systems, as outlined in the Capital Fund Guidebook.
(c) Planned implementation date of corrective action - Completed by September 30, 2025.