Finding Text
Finding 2023-004 Reporting – Internal Control and Compliance over Reporting
Information of the Federal Programs:
Assistance Listing Number: 14.218
Assistance Listing Title: Community Development Block Grants - Entitlement Grants
Federal Agency: Department of Housing and Urban Development (“HUD”)
Federal Award Number and Award Year: B-20-MC-060559, B-20-MW-060559, B-21-MC-060559, and
B-22-MC-060559
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation):
Pursuant to the Guidance on Consolidated Annual Performance and Evaluation Report (“CAPER”) (24 CFR 91.520). Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) – Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee’s program year. Section IV.B.2.(c) of the CDBG-CV Notice reiterated the waiver authorized by a May 7, 2020, HUD memorandum (found in the waiver information link noted in IV. Other Information, below) that waives the 90 day requirement for program year 2019 annual performance and evaluation reports, subject to the condition that within 180 days after the evaluation reports, subject to the condition that within 180 days after the close of a jurisdiction’s program year that it submit its performance report. Auditors are only expected to test information extracted from IDIS in the following system-generated reports and which include (1) PR26 – CDBG Financial Summary Report (“PR26”).
A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Pursuant to Guidance on Section 15011 of the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit, not later than 10 days after the end of each calendar quarter, a report containing: information regarding the amount of funds received; the amount of funds obligated or expended for each project or activity; a detailed list of all such projects or activities, including a description of the project or activity; and detailed information on any subcontracts or subgrants awarded by the recipient. This report is limited to CDBG-CV funding and does not include other CDBG funds that may be used to address coronavirus. Grantees and subrecipients have reported data meeting the Section 15011 requirements at usaspending.gov. The Pandemic Response Accountability Committee (PRAC), an independent oversight committee within the Council of the Inspectors General on Integrity and Efficiency, has determined that the data reported in usaspending.gov has fulfilled these reporting requests. (“Section 15011 Report”).
Condition:
The City did not submit the CAPER on time. The CAPER was submitted on February 28, 2024. In addition, the City did not submit Section 15011 report for the first three quarters during the year end June 30, 2023. The City started submitting Section 15011 report for the quarter ended June 30, 2023. However, the report was submitted on July 27, 2023 which was after the due date July 10, 2023.
Cause:
Insufficient training and ineffective policies and procedures to ensure that the reports were submitted timely in accordance with the timelines established by HUD.
Effect or Potential Effect:
Delay in filing the reports resulted in noncompliance with the compliance requirements.
Questioned Costs:
None.
Context:
See condition above for context of the finding.
Identification as a Repeat Finding, If Applicable:
Repeated finding as 2022-003.
Recommendation:
We recommend that the City provide training to staff and update policies and procedures to strengthen the report submission process to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City should request an extension from the funding agency and maintain a record of the approval.
View of Responsible Officials:
Management concurs the finding.