Finding 1239514 (2025-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: Monthly progress reports to the Puerto Rico Department of Housing were submitted late due to weaknesses in the reporting workflow.
  • Impacted Requirements: Compliance with 2 CFR Part 200.329 and PRDOH's requirement for timely submission of reports is critical for effective program monitoring.
  • Recommended Follow-Up: Enhance supervision and provide training for staff on report preparation and deadlines to ensure timely submissions moving forward.

Finding Text

Reporting Name of Federal Agency U.S. Department of Housing and Urban Development Pass-through the Puerto Rico Housing Finance Authority Federal Program Community Development Block Grant - Disaster Recovery Federal Award B-18-DP-72-0001 2025 Federal Award Year: 2020 Assistance Listing Number 14.228 Category Significant Deficiency and Noncompliance Compliance Requirement Reporting Criteria 2 CFR 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 normore 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 out comes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due nolater 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 passthrough entity may require annual reports before the anniversary dates of multiple year Federal awards. As per agreement with the Organization Part IV (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. As defined by PRDOH, the submission of progress reports must occur within five (5) days after the end of each month. Condition During our procedures performed to determine compliance with reporting requirements, we noted that the progress reports were not submitted on time to Puerto Rico Department of Housing (PRDOH). Cause The late submission of monthly progress reports to the Puerto Rico Department of Housing (PRDOH) resulted from weaknesses in the Entity’s reporting workflow. In some instances, the Organization submitted the required progress reports after the established deadline. Additionally, PRDOH’s reporting process requires that each monthly report be reviewed and approved before the subsequent report can be submitted. As a result, when an earlier report (e.g., January) is approved several months later (e.g., in April), the next report in sequence (e.g., February) is automatically delayed. This dependency creates a chain reaction that leads to consecutive late submissions, further contributing to the systemic nature of the issue. 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 Cost None Context The condition identified represents a recurring and systemic issue rather than an isolated instance. PRDOH requires the submission of twelve (12) monthly progress reports per fiscal year. For purposes of this audit, we examined the full universe of required reports and determined that several reports were submitted after the established due date. Because the entire population of required progress reports was reviewed, no sampling was performed, and the instances of noncompliance identified reflect the complete set of reporting activities for the year under audit. The prevalence of late submissions indicates weaknesses in the Entity’s reporting controls and affects PRDOH’s ability to perform timely oversight of program activities. This finding is a repeat of the prior year’s finding, reported as item 2024-002 Recommendation The Organization shall ensure effective supervision over its reporting processes to guarantee the timely preparation and submission of progress reports. It is advised that the Organization 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 Management of the Organization agrees with this finding. For details of the actions to be taken, refer to the Corrective Action Plan (CAP) section in this report. Responsible Person José Carrasquillo Delgado Finance Director

Corrective Action Plan

Management acknowledges the delays identified in the submission of certain monthly progress reports corresponding to the 2025 reporting period. However, management respectfully notes that the dates reflected in PRDOH's reporting records should be considered in the context of PRDOH's established sequential reporting and approval process. Under the Puerto Rico Department of Housing's CDBG-DR/MIT Grant Compliance Portal (GCP) procedures, a subrecipient cannot submit a monthly report while a preceding report remains open and pending approval. Specifically, the PRDOH CDBG-DR/MIT Grant Compliance Portal (GCP) Manual, Version 5, dated April 4, 2024, page 35, states: “You cannot submit a report while there is an open past Report” and further provides that, “Once the open report is approved, you can submit the next monthly report.” Accordingly, delays in PRDOH's review, return, resubmission, and approval of one monthly report necessarily affect CRH's ability to submit the following month's report, even when CRH is otherwise prepared to proceed with the subsequent submission. Management therefore reviewed the complete submission and approval history for all twelvemonthly reports corresponding to 2025 in order to distinguish between reports that appear late based solely on the dates reflected in PRDOH's records and reports that were submitted late due to circumstances attributable to CRH. Out of the 12 months of 2025, five reports were submitted late. Of the five late submissions, three of which were due to the PRDOH’s delayed approval of the previous month’s report. Reporting Period Original CRH Submission PRDOH Approval Status January 3/26/25 4/3/25 Submitted late, in order to incorporate new PRDOH data and inventory requirements. February 4/23/25 5/26/25 Submitted late, in order to incorporate new PRDOH data and inventory requirements. March 5/28/25 5/28/25 Submitted late due to PRDOH approval date of previous report April 5/28/25 5/28/25 Submitted late due to PRDOH approval date of previous report. May 6/2/25 6/5/25 Submitted within term. June 7/1/25 7/9/25 Submitted within term. July 8/1/25 8/6/25 Submitted within term. August 9/2/25___ 9/19/25_ Submitted within term. September 10/2/25 10/17/25 Submitted within term. October 11/5/25 12/10/25 Submitted within term. November 12/15/25 12/23/25 Submitted late due to PRDOH approval date of previous report. December 1/5/26 2/4/26 Submitted within term. After considering the original submission dates, PRDOH approval dates, subsequent resubmissions, and the sequential reporting requirement established by PRDOH, only two reports were actually submitted late due to circumstances attributable to CRH. With respect to those reports that were actually submitted late by CRH, the delays occurred principally during a period in which PRDOH was establishing new requirements concerning the information, supporting documentation, classifications, and formatting required for inventory and data, which required overhauls of the CRH’s internal methodologies. In several instances, these requirements were communicated through comments and instructions associated with PRDOH's review of preceding reports, and in others, from e-mail requests establishing new inventory criteria. CRH has since incorporated PRDOH's data and inventory format requirements into its regular procedures, completed the necessary personnel transition and training, and strengthened its internal monitoring of monthly reporting deadlines. As of 2026, CRH's monthly reports have been submitted without a sinlge late submission. Management will continue documenting both CRH submission dates and PRDOH approval dates so that delays resulting from PRDOH's sequential review and approval process can be appropriately distinguished from delays attributable to CRH.

Categories

Subrecipient Monitoring Reporting Significant Deficiency

Other Findings in this Audit

  • 1239513 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.228 Community Development Block Grant-Disaster Recovery (CDBG-DR) $3.41M
10.446 Rural Community Development Initiative (RCDI)-Rural Business Service $91,133
66.306 Enviromental Justice Collaborative Problem-Solving Cooperative Agreement Program $77,381
14.878 HOPE VI Main Street $53,699
14.259 Community Compass Technical Assistance and Capacity Building $39,305