Finding Text
dentification of the Federal Programs:
Assistance Listing Number: 14.218
Assistance Listing Title: Community Development Block Grants (CDBG) –
Entitlement Grants Cluster
Federal Agency: Department of Housing and Urban Development
Federal Award Number: B-20-MW-060559; B-23-MC-060559
Federal Award Year: FY 2024
Criteria or Specific Requirements:
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.
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”).
Identified Condition:
The City did not submit the CAPER within the required timeframe, resulting in a delayed submission on October 17, 2024, which was 17 days past the deadline. Furthermore, three of the four required quarterly Section 15011 Reports for the fiscal year 2024 were not prepared or submitted. The only report submitted, the third quarterly report for the fiscal year 2024, was submitted late on April 15, 2024, which was 5 days past the deadline.
Cause:
The delay in submission and non-submission of the reports was attributed to inadequate internal processes and a lack of oversight, which hindered the timely completion and submission of the required documentation.
Effect or Potential Effect:
The delayed submission of the reports could result in noncompliance with federal reporting requirements, potentially jeopardizing future funding opportunities. It may also lead to increased scrutiny from oversight agencies and diminish confidence in the City’s ability to meet critical deadlines and manage federal programs effectively.
Questioned Costs:
None.
Recommendation:
We recommend that the City establish clear internal timelines and accountability measures, ensuring all responsible staff are aware of reporting deadlines. The City should proactively request an extension from the relevant federal agency if circumstances arise that might impact the timely submission of the reports. This includes providing a clear justification for the delay, outlining the steps being taken to complete the report, and proposing a revised timeline. Regular communication with the agency during the extension period will demonstrate accountability and commitment to compliance.
Views of Responsible Officials and Planned Corrective Action Plan:
Gabriel Linares, Director of Community Development, will enhance the department’s policy/desk procedure to ensure timely filing of the CAPER and Section 15011 reports starting Quarter Four, FY2024 -25.
Personnel Responsible for Implementation: Gabriel Linares
Position of Responsible Personnel: Director of Community Development
Expected Date of Implementation: June 30, 2025