Finding Text
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.329 which provides the recipient and subrecipient are responsible for the oversight of the Federal award. The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity. Grant Agreement No. B-22-CP-OH-0725 Article VI Program-Specific Reporting Requirement states that in addition to the general reporting requirements that apply under provisions of this Agreement, the following program-specific reporting requirements apply to the grantee: A. The Grantee must submit a performance report in the Disaster Recovery Grant Reporting System (DRGR) on a semi-annual basis and must include a completed Federal financial report as an attachment to each performance report in DRGR. Performance reports shall consist of a narrative of work accomplished during the reporting period. During the Period of Performance, the Grantee must submit these reports in DRGR no later than 30 calendar days after the end of the 6-month reporting period. The first of these reporting periods begins on the first of January or June (whichever occurs first) after the date this Grant Agreement is signed by HUD. B. The performance report must contain the information required for reporting program performance under 2 CFR 200.329(c)(2) and (d), including a comparison of actual accomplishments to the objectives of the Project as described in Article III, section A of this Grant Agreement, the reasons why established goals were not met, if appropriate, and additional pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs. The County submitted a semi-annual performance report for the time period ending June 30, 2025, for the Economic Development Initiative, Community Project Funding, and Miscellaneous Grants program (AL# 14.251, B-22-CP-OH-0725) indicating total funds expended of $0. The County accounting records for the time period ending June 30, 2025, had expenditures of $1,272,967, resulting in a variance of $1,272,967. The County could not provide evidence that the semi-annual performance report for the time period ending December 31, 2025, for the Economic Development Initiative, Community Project Funding, and Miscellaneous Grants program (AL# 14.251, B-22-CP-OH-0725) was submitted. Therefore, the expenditures of $2,238,372 that were spent as of December 31, 2025, were not reported. The County uploaded the semi-annual performance report for the time period ending December 31, 2025, in the DRGR system; however, the report has not been submitted by the County. The expenditures noted on this uploaded report was $0. Due to inadequate policies and procedures and insufficient controls over the reporting of semi-annual performance reports, the County failed to submit accurate amounts and the required reports. This could result in action being taken by the grantor. The County anticipates contacting HUD to amend these reporting errors. Additional controls should be implemented to help ensure accuracy of the reports.