Finding 571743 (2024-005)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-07-22
Audit: 362742
Organization: City of Cambridge Massachusetts (MA)
Auditor: Kpmg

AI Summary

  • Core Issue: The City failed to submit the CAPER report to HUD by the September 30, 2023 deadline, resulting in material noncompliance.
  • Impacted Requirements: Compliance with performance reporting requirements, specifically the timely submission of the HUD-4155 CAPER and reconciliation of subrecipient reports.
  • Recommended Follow-up: Establish and enforce policies and internal controls to ensure all subrecipient CAPER reports are reconciled and submitted on time to HUD.

Finding Text

Finding Number: 2024-005 Program: Housing Opportunities for Persons with AIDS (HOPWA) ALN #: 14.241 Pass-through Entity: N/A- Direct Award Federal Agency: Department of Housing and Urban Development Federal Award Year: July 1, 2023–June 30, 2024 Compliance Requirement: Performance Reporting Type of finding: Material weakness and material noncompliance Criteria Performance Reporting for the HOPWA Consolidated Annual Performance and Evaluation Report Per HUD, the Consolidated Annual Performance and Evaluation Report (CAPER) provides annual performance reporting on client outputs and outcomes that enables an assessment of grantee performance in achieving the housing stability outcome measure. The CAPER fulfills statutory and regulatory program reporting requirements and provides the grantee and HUD with the necessary information to assess the overall program performance and accomplishments against planned goals and objectives. Both HOPWA formula and competitive grantees submitting reports after January 1, 2023, must complete and submit the HUD-4155 “Consolidated APR/CAPER” (OMB number 2506-0133). HOPWA Formula Grantees that accept the supplemental funding authorized under the CARES Act should report on the use of supplemental grant funds in the same performance report as their use of entitlement funds. Both formula and competitive grantees are required to submit their completed HUD-4155 no later than 90 days after the close of their program or operating year. Competitive grantees have 120 days after the end of their grant’s last period of performance to submit the final HUD-4155. Grantees should be able to demonstrate that funds disbursed through federal financial systems are traceable in local accounts and accurately reported in Key Line Items in the HUD-4155. Lastly, 2 CFR 200.303(a) states, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The City does not have properly designed controls and documented procedures in place to ensure compliance with the following requirements: • CAPER report is submitted to HUD within 90 days of the end of the 12-month program year. • Review of subrecipient’s CAPER to ensure complete and accurate reporting over key line items. Cause Subrecipients are required to submit their individual CAPER reports to the City prior to the City submitting its report to HUD. The City has had difficulty in getting the subrecipients to comply with the CAPER reporting, which is primarily due to staffing issues at the subrecipients. As a result, the City did not submit its CAPER to HUD within the required time-frame. Proper perspective The City failed to submit the CAPER that covers the period from July 1, 2022 to June 30, 2023 to HUD by the September 30, 2023 deadline. The City ultimately submitted the CAPER on May 3, 2024. Additionally, the City has been unable to provide documentation that the subrecipients’ CAPER has been reconciled to the Integrated Disbursement and Information System (IDIS). Possible asserted effect Incomplete or inaccurate information from its subrecipients has resulted in the City’s inability to properly comply with HUD’s CAPER reporting requirements. Questioned costs Not determinable Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding Yes, 2023-007 Recommendation We recommend that the City establish policies, procedures, and internal controls to ensure that all subrecipient CAPER reports are reconciled to the IDIS system and submitted to HUD within 90 days of year-end. Views of responsible officials and corrective actions The City will continue to work with all agencies receiving HOPWA to complete their annual CAPER correctly and in a timely manner. This emphasis will be reiterated throughout the awarding process and will be subject to regular status updates to ensure compliance and accuracy. Further, the City will work with HUD to establish a correct methodology in reporting consistency with IDIS, as the annual CAPER and HOPWA contracts do not operate open uniform timelines, nor do they involve consistent financial reporting structures. The City does not believe the simple and direct correlation to IDIS is a reasonable or useful metric for the CAPER, but acknowledges that there should be a consistent standard that can be reconciled to financial activity during the year covered by each CAPER.

Corrective Action Plan

The City will continue to work with all agencies receiving HOPWA to complete their annual CAPER correctly and in a timely manner. This emphasis will be reiterated throughout the awarding process and will be subject to regular status updates to ensure compliance and accuracy. Further, the City will work with HUD to establish a correct methodology in reporting consistency with IDIS.

Categories

Subrecipient Monitoring HUD Housing Programs Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Internal Control / Segregation of Duties Material Weakness Period of Performance Reporting

Other Findings in this Audit

  • 571740 2024-002
    Material Weakness
  • 571741 2024-003
    Material Weakness Repeat
  • 571742 2024-004
    Material Weakness Repeat
  • 571744 2024-006
    Material Weakness
  • 571745 2024-007
    Material Weakness
  • 571746 2024-008
    Material Weakness Repeat
  • 571747 2024-009
    Material Weakness Repeat
  • 1148182 2024-002
    Material Weakness
  • 1148183 2024-003
    Material Weakness Repeat
  • 1148184 2024-004
    Material Weakness Repeat
  • 1148185 2024-005
    Material Weakness Repeat
  • 1148186 2024-006
    Material Weakness
  • 1148187 2024-007
    Material Weakness
  • 1148188 2024-008
    Material Weakness Repeat
  • 1148189 2024-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $12.81M
21.027 Coronavirus State and Local Fiscal Recovery Funds $12.01M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $5.81M
14.267 Continuum of Care Program $5.36M
84.425U Covid-19 American Rescue Plan Elementary and Secondary School Emergency Relief (arp Esser) $3.27M
14.241 Housing Opportunities for Persons with Aids $2.14M
14.218 Community Development Block Grants/entitlement Grants $2.01M
10.555 National School Lunch Program $1.92M
84.010 Title I Grants to Local Educational Agencies $1.41M
93.568 Low-Income Home Energy Assistance $1.10M
84.002 Adult Education - Basic Grants to States $535,942
97.067 Homeland Security Grant Program $534,027
10.553 School Breakfast Program $488,257
32.009 Emergency Connectivity Fund Program $321,885
93.590 Community-Based Child Abuse Prevention Grants $203,354
20.205 Highway Planning and Construction $197,052
10.559 Summer Food Service Program for Children $191,874
84.027 Special Education Grants to States $188,661
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $179,868
32.004 Universal Service Fund - Schools and Libraries $161,051
84.048 Career and Technical Education -- Basic Grants to States $137,884
93.499 Low Income Household Water Assistance Program $94,620
14.881 Moving to Work Demonstration Program $89,757
84.365 English Language Acquisition State Grants $79,903
84.525D Covid-19 Elementary and Secondary School Emergency Relief Fund (esser) $56,862
84.424 Student Support and Academic Enrichment Program $52,395
20.600 State and Community Highway Safety $45,646
84.425 Education Stabilization Fund $40,640
97.042 Emergency Management Performance Grants $39,600
20.616 National Priority Safety Programs $28,969
14.401 Fair Housing Assistance Program $20,394
84.196 Education for Homeless Children and Youth $14,399
93.788 Opioid Str $10,884
14.231 Emergency Solutions Grant Program $8,074
10.582 Fresh Fruit and Vegetable Program $7,155
16.922 Equitable Sharring Program $4,920
84.173 Special Education Preschool Grants $2,214
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $750
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $216
97.024 Emergency Food and Shelter National Board Program $116