Finding Text
Finding Number: 2024-005
Program: Housing Opportunities for Persons with AIDS (HOPWA)
ALN #: 14.241
Pass-through Entity: N/A- Direct Award
Federal Agency: Department of Housing and Urban Development
Federal Award Year: July 1, 2023–June 30, 2024
Compliance Requirement: Performance Reporting
Type of finding: Material weakness and material noncompliance
Criteria
Performance Reporting for the HOPWA Consolidated Annual Performance and Evaluation Report
Per HUD, the Consolidated Annual Performance and Evaluation Report (CAPER) provides annual
performance reporting on client outputs and outcomes that enables an assessment of grantee performance
in achieving the housing stability outcome measure. The CAPER fulfills statutory and regulatory program
reporting requirements and provides the grantee and HUD with the necessary information to assess the
overall program performance and accomplishments against planned goals and objectives.
Both HOPWA formula and competitive grantees submitting reports after January 1, 2023, must complete
and submit the HUD-4155 “Consolidated APR/CAPER” (OMB number 2506-0133). HOPWA Formula
Grantees that accept the supplemental funding authorized under the CARES Act should report on the use
of supplemental grant funds in the same performance report as their use of entitlement funds. Both formula
and competitive grantees are required to submit their completed HUD-4155 no later than 90 days after the
close of their program or operating year. Competitive grantees have 120 days after the end of their grant’s
last period of performance to submit the final HUD-4155.
Grantees should be able to demonstrate that funds disbursed through federal financial systems are
traceable in local accounts and accurately reported in Key Line Items in the HUD-4155.
Lastly, 2 CFR 200.303(a) states, the nonfederal entity must establish and maintain effective internal control
over the federal award that provides reasonable assurance that the nonfederal entity is managing the
federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal
award. These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Condition
The City does not have properly designed controls and documented procedures in place to ensure
compliance with the following requirements:
• CAPER report is submitted to HUD within 90 days of the end of the 12-month program year.
• Review of subrecipient’s CAPER to ensure complete and accurate reporting over key line items.
Cause
Subrecipients are required to submit their individual CAPER reports to the City prior to the City submitting
its report to HUD. The City has had difficulty in getting the subrecipients to comply with the CAPER
reporting, which is primarily due to staffing issues at the subrecipients. As a result, the City did not submit
its CAPER to HUD within the required time-frame.
Proper perspective
The City failed to submit the CAPER that covers the period from July 1, 2022 to June 30, 2023 to HUD by
the September 30, 2023 deadline. The City ultimately submitted the CAPER on May 3, 2024.
Additionally, the City has been unable to provide documentation that the subrecipients’ CAPER has been
reconciled to the Integrated Disbursement and Information System (IDIS).
Possible asserted effect
Incomplete or inaccurate information from its subrecipients has resulted in the City’s inability to properly
comply with HUD’s CAPER reporting requirements.
Questioned costs
Not determinable
Statistical sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat finding
Yes, 2023-007
Recommendation
We recommend that the City establish policies, procedures, and internal controls to ensure that all
subrecipient CAPER reports are reconciled to the IDIS system and submitted to HUD within 90 days of
year-end.
Views of responsible officials and corrective actions
The City will continue to work with all agencies receiving HOPWA to complete their annual CAPER
correctly and in a timely manner. This emphasis will be reiterated throughout the awarding process and will
be subject to regular status updates to ensure compliance and accuracy. Further, the City will work with HUD to establish a correct methodology in reporting consistency with IDIS, as the annual CAPER and HOPWA contracts do not operate open uniform timelines, nor do they involve
consistent financial reporting structures. The City does not believe the simple and direct correlation to IDIS
is a reasonable or useful metric for the CAPER, but acknowledges that there should be a consistent
standard that can be reconciled to financial activity during the year covered by each CAPER.