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.