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) along with the final HUD-50075.1, Performance and Evaluation Report (P&E) within 90 days after the expenditure end date of the grant, in order to initiate the closeout process. The AMCC and P&E must detail actual costs incurred from the Date of Full Availability (DOFA) to the completion of the modernization project. Condition - The Authority failed to submit the final P&E and AMCC to HUD by the 90 day due date for its CFP NY01P062501-17 and NY01P062501-18 grants. Cause - The failure to complete the P&E and AMCC 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 P&E and AMCC 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 P&E and AMCC and submit the necessary closeout documentation for grants mentioned in the Condition above. Additionally, the Authority should develop and implement a grant management tracking system to monitor the status of all active grants, including deadlines to adhere to performance reporting requirements. Management’s Response - (a) Comments on the Finding and Recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action Taken - The Authority will establish internal tracking and reminder systems to ensure all required reports, including the final P&E and AMCC, are completed and submitted to HUD by the required due dates. Grant reporting responsibilities will be clearly assigned, and submission deadlines will be monitored by the Director of Finance to prevent future delays. These procedures will be implemented immediately. (c) Planned Implementation Date - The Authority plans to implement procedures during the year ending March 31, 2026 to resolve the reported finding.