Finding Text
Noncompliance with Special Tests and Provisions (Public Housing Capital Fund CFDA 14.872)
Criteria: Federal Code of Regulations, CFR § 905.314 (l) requires the Authority to first drawdown Budget Line item 1406 Operations before amounts are obligated. Furthermore, per CFR § 905.306, the Authority is required to Obligate funds in ELOCCS when a binding agreement (executed by all parties) for work that will result in outlays of Capital Funds.
Condition: During the year, the Authority made two Operations draws from CFP 2020 and CFP 2021 in the amounts of $151,467 and $202,968, respectively. The Operations draw for CFP 2020 was made after amounts were reported as obligated in ELOCCS. Following further training, the CFP 2021 Operations Draw was properly reported. Furthermore, the Authority also made Budget Line Item 1480 – General Capital Activity draws from CFP grants 2020-2023 during the fiscal year. The General Capital Activity Draws for CFP 2020 grant were not reported accurately based upon the underlying expenditures and/or binding contracts. Following further training, the remaining expenditures and/or contracts were properly reported for CFP grants 2021-2023.
Questioned
Costs: None.
Effect: The Authority did not properly follow the requirements of CFR § 905.314 (l) and 905.306.
Cause: The Authority did not have an adequate understanding of the Capital Fund Program requirements as related to Operations Budget Line Item 1406 draws and reporting of Obligations and Expenditures in ELOCCS.
Recommendation: The Authority’s staff should familiarize themselves with Capital Fund Program reporting requirements.
Management
Response: Management was unaware of the proper CFP reporting requirements at the time the CFP grant 2020 was being reported. After further training, the Authority’s staff ensured that beginning with CFP 2021, all obligations and expenditures were properly reported in ELOCCS.