Finding Text
2022-002: Period of Performance - Timeliness Criteria - The City is required to establish and maintain an effective control environment, and monitor compliance with the period of performance requirement of this federal award, per Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements for Federal Awards (Uniform Guidance), Subpart D; Section 200.303 Internal Controls and under the provisions of 24 CFR 570.902 of the Community Development Block Grant (CDBG) regulations. A grantee is considered to meet period of performance and be timely, if 60 days prior to the end of the grantee?s program year, the balance in its line-of-credit does not exceed 1.5 times the annual grant. To determine whether entitlement grantees meet timely performance, U.S. Department of Housing and Urban Development (HUD) calculates the ratio of unexpended funds to the annual grant award 60 days prior to the end of the program year. To do this HUD sums the amount of program income the grantee has on hand with the amount of funds remaining in the CDBG line of credit and divides by the amount of the annual grant award. If the ratio is less than or equal to 1.5, then the grantee has met the timely performance requirement. This requirement is monitored using the IDIS CDBG Timeliness Report (PR56 report). Condition - The City?s Department of Community Development did not have an established internal control process to appropriately monitor the timeliness requirement and ensure compliance. The City exceeded the allowable balance in its line-of-credit with a ratio of greater than 1.5, resulting in noncompliance with this period of performance requirement. Cause - The City did not have an established control process in place to appropriately monitor and ensure compliance with these requirements. Effect - The City is not in compliance with the federal program?s period of performance requirement. Noncompliance could have funding implications in the future. Repeat Finding - This is a repeat finding of 2021-002. Recommendation - We recommend the City?s Department of Community Development contact HUD to develop a plan for expending CDBG funds in order to reduce the amount of unexpended funds to a level that will fall within the required parameters. In addition, we recommend implementing a monitoring process over spending of CDBG grant funds to ensure funding is used within the specified time requirements and in compliance with the period of performance requirement. Management Response - The City is in agreement with this audit finding. Due in part to delays in finalizing both the 2021-2022 annual action plan and the 2022-2023 annual action plan, the City was delayed in being able to utilize those funds until approval was provided by HUD. The City continues to direct funds to projects that have the ability to be completed in a timely manner in order to be consistent with the CDBG regulation related to timeliness. The City is aware of the timeliness requirements and will continue to select projects that better allow the City to operate in accordance with these regulations. Estimated Completion Date - Next HUD verification date of May 1, 2024