Finding Text
Condition: We found that the City of Wilmington Real and Estate and Housing Department did not retain
evidence that a contemporaneous review of the expenditures reported by its subrecipients on the HOPWA
Consolidated Annual Performance and Evaluation Report (CAPER) was performed.
We also found that the expenditures, as reported on the CAPER for one of the City’s four subrecipients during
fiscal year 2023, did not agree to the expenditures submitted to the U.S. Department of Housing and Urban
Development’s (HUD) Integrated Disbursement Information System (IDIS) and that the Real and Estate and
Housing Department did not perform a reconciliation or otherwise document the differences between the two
reports.
Context: IDIS is the draw down and reporting database utilized by grantees to provide HUD with current
information regarding HOPWA (and other programs’) activities. Grantees submit draw down requests by creating
a voucher in the system.
Criteria: Per 24 CFR 91.520 (a), grantees must submit the CAPER no later than 90 days after the close of their
program year.
HUD Grantees are responsible for collecting information on grant funds spent from subrecipients and reviewing
the information for accuracy and completeness prior to submitting the completed CAPER to HUD. HUD’s
HOWPA APR/CAPER User Manual Chapter 2 Submission and Data Validation Process requires this review as
follows (emphasis added):
The HOPWA grantee remains responsible for collecting, reviewing (for accuracy and completeness), and
transmitting to HUD the Consolidated APR/CAPER workbooks. Submission of the complete set of Grantee and
Provider Workbooks together constitute the Grantee’s annual performance report to HUD.
Questioned Costs: None.
Effect: The expenditures reported on the CAPER for one of the subrecipients did not agree to the expenditures
processed in IDIS for FY 2023 and the Real and Estate and Housing Department did not perform a reconciliation
or otherwise document the differences between the two reports, resulting in possibly inaccurate reporting of the
use of program funds during the fiscal year to HUD.
Cause: The Real Estate and Housing Department did not perform contemporaneous reviews of the accuracy and
completeness of the information reported by its subrecipients on the CAPER prior to submission to HUD.
Recommendation: We recommend the Real Estate and Housing Department implement procedures for
preparing and reviewing reports prior to submission to HUD and for maintaining documentation of this review
for audit purposes.
Views of Responsible Authority Officials and Planned Corrective Actions: See corrective action plan.
Responsible Positions: Director of Real Estate and Housing