Finding Text
Major Program Department of Housing and Urban Development Community Development Block Grants/ State?s Program and Non-Entitlement Grants in Hawaii Pass-through: Texas General Land Office (GLO) Disaster Recovery Program Infrastructure Projects ALN: 14.228 Criteria Per Section 4.4 Release of Funds - 4.4.4 Minimizing the Time Between Draw & Disbursement of the GLO CDBG-DR Implementation Manual, "Subrecipients should submit costs to the GLO for draw within 60 days of receipt of invoices to minimize the volume of individual draws that the GLO must review and approve" and "Subrecipients utilizing the cash advance method must minimize the time elapsing between the transfer of funds from the GLO and the disbursement by the subrecipient for eligible costs. This period must not exceed 3 business days from the date of receipt/deposit of funds, without specific, documented reasons for such a delay in very infrequent circumstances. Subrecipients must maintain written procedures for minimizing this time period." Statement of Condition The City submitted one invoice for reimbursement after the allotted 60 day period, and as such is not in compliance with the requirements documented above. Statement of Cause The GLO typically does not accept requests for payment that are under $2,500. As such, it is the City?s practice to group multiple GLO-eligible invoices together in order to exceed this threshold amount. In the case noted above, the City was attempting to group several small reimbursement requests that were individually less than $2,500 with a larger reimbursement request that was in excess of the $2,500 amount, and in doing so, allowed the larger reimbursement request to exceed the 60 day deadline. Statement of Effect or Potential Effect This significant deficiency in the City?s internal control could result in a compliance issue associated with receiving reimbursements for grant expenditures. Questioned Costs No questioned costs were identified in association with this finding. Perspective Information This finding appears to be an isolated incident and does not appear to be a systemic issue. Identification of Repeat Findings N/A Recommendation The City should continue to work with its Grant Administrators to track required reimbursement deadline dates and ensure that all reimbursement requests are in compliance with these guidelines. The City should avoid grouping smaller reimbursement requests with larger reimbursement requests if doing so will result in those requests exceeding the 60 day time frame.