Finding Text
Finding: 2022-004 Reporting ? Internal Control and Compliance over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-21-MC-06-0577, B-20-MW-06-0577 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the City?s Administrative Policy & Procedures Ref: APP-2022-002: Action Plan - Due to HUD by May 15th for the following fiscal year which begins July 1, CAPER - Due 90 days after the end of the fiscal year (September 30th). Pursuant to the Uniform Guidance April 2022 Compliance Supplement: PR29, Cash on Hand Quarterly Reports ? PR29 in the IDIS reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to HUD on a quarterly basis, 30 days after the reporting period end date. The due dates of each quarterly report is noted below: Reporting Period Grantee Submission (End Date) Deadlines September 30, 2021 October 30, 2021 December 31, 2021 January 30, 2022 March 31, 2022 April 30, 2022 June 30, 2022 July 30, 2022 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 systemgenerated 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. Condition: During the audit, we noticed that the City did not prepare the Annual Action Plan within the timeframe to meet its grant management policy. 1) FY2021-2022 Annual Action Plan was adopted on August 10, 2021 (not before May 15, 2021) 2) FY2022-2023 Annual Action Plan was adopted on August 9, 2022 (not before May 15, 2022) During the audit, we noticed that three out of four quarters the PR29 were not filed within the deadline and noted below: Reporting Period Grantee Submission (End Date) Deadlines Filed Date September 30, 2021 October 30, 2021 March 6, 2023 December 31, 2021 January 30, 2022 March 6, 2023 March 31, 2022 April 30, 2022 July 28, 2022 June 30, 2022 July 30, 2022 July 28, 2022 During the audit, we noticed that the PR26 and the CAPER was not filed as of March 22, 2023. Cause: The City did not follow the grant management policies in place to ensure the reporting requirements are met. Effect or Potential Effect: The City was not in compliance with the program?s reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City follow its grant management policies to ensure the reporting requirements are met. Views of Responsible Officials: Management concurs the finding.