Finding 963351 (2023-009)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299217
Organization: City of Wilmington (DE)

AI Summary

  • Core Issue: The City of Wilmington's Real Estate and Housing Department failed to keep records showing they reviewed subrecipient expenditures reported on the CAPER.
  • Impacted Requirements: This oversight violates HUD regulations requiring accurate and complete reviews of expenditures before CAPER submission.
  • Recommended Follow-Up: Establish procedures for thorough report preparation and review, ensuring documentation is maintained for future audits.

Finding Text

Condition: We found that the City of Wilmington Real and Estate and Housing Department did not retain evidence that a contemporaneous review of the expenditures reported by its subrecipients on the HOPWA Consolidated Annual Performance and Evaluation Report (CAPER) was performed. We also found that the expenditures, as reported on the CAPER for one of the City’s four subrecipients during fiscal year 2023, did not agree to the expenditures submitted to the U.S. Department of Housing and Urban Development’s (HUD) Integrated Disbursement Information System (IDIS) and that the Real and Estate and Housing Department did not perform a reconciliation or otherwise document the differences between the two reports. Context: IDIS is the draw down and reporting database utilized by grantees to provide HUD with current information regarding HOPWA (and other programs’) activities. Grantees submit draw down requests by creating a voucher in the system. Criteria: Per 24 CFR 91.520 (a), grantees must submit the CAPER no later than 90 days after the close of their program year. HUD Grantees are responsible for collecting information on grant funds spent from subrecipients and reviewing the information for accuracy and completeness prior to submitting the completed CAPER to HUD. HUD’s HOWPA APR/CAPER User Manual Chapter 2 Submission and Data Validation Process requires this review as follows (emphasis added): The HOPWA grantee remains responsible for collecting, reviewing (for accuracy and completeness), and transmitting to HUD the Consolidated APR/CAPER workbooks. Submission of the complete set of Grantee and Provider Workbooks together constitute the Grantee’s annual performance report to HUD. Questioned Costs: None. Effect: The expenditures reported on the CAPER for one of the subrecipients did not agree to the expenditures processed in IDIS for FY 2023 and the Real and Estate and Housing Department did not perform a reconciliation or otherwise document the differences between the two reports, resulting in possibly inaccurate reporting of the use of program funds during the fiscal year to HUD. Cause: The Real Estate and Housing Department did not perform contemporaneous reviews of the accuracy and completeness of the information reported by its subrecipients on the CAPER prior to submission to HUD. Recommendation: We recommend the Real Estate and Housing Department implement procedures for preparing and reviewing reports prior to submission to HUD and for maintaining documentation of this review for audit purposes. Views of Responsible Authority Officials and Planned Corrective Actions: See corrective action plan. Responsible Positions: Director of Real Estate and Housing

Categories

HUD Housing Programs Reporting Subrecipient Monitoring Cash Management

Other Findings in this Audit

  • 386909 2023-009
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $22.45M
66.458 Capitalization Grants for Clean Water State Revolving Funds $3.04M
66.468 Capitalization Grants for Drinking Water State Revolving Funds $1.32M
10.559 Summer Food Service Program for Children $454,820
10.558 Child and Adult Care Food Program $301,321
97.042 Emergency Management Performance Grants $157,141
14.218 Community Development Block Grants/entitlement Grants $148,674
95.001 High Intensity Drug Trafficking Areas Program $100,090
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $78,291
14.241 Housing Opportunities for Persons with Aids $75,035
16.034 Coronavirus Emergency Supplemental Funding Program $64,156
16.738 Edward Byrne Memorial Justice Assistance Grant Program $50,000
16.607 Bulletproof Vest Partnership Program $34,394
16.575 Crime Victim Assistance $28,252
97.056 Port Security Grant Program $24,999
20.600 State and Community Highway Safety $14,880
15.904 Historic Preservation Fund Grants-in-Aid $11,879
20.607 Alcohol Open Container Requirements $10,899
16.922 Equitable Sharing Program $10,000
20.616 National Priority Safety Programs $2,313
14.239 Home Investment Partnerships Program $1,464
16.833 National Sexual Assault Kit Initiative $492
14.231 Emergency Solutions Grant Program $-48,008