Finding 978901 (2023-007)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-06-26
Audit: 309973
Organization: City of Cambridge Massachusetts (MA)
Auditor: Kpmg

AI Summary

  • Core Issue: The City failed to submit the CAPER for the period July 1, 2021 to June 30, 2022, to HUD on time, leading to material noncompliance.
  • Impacted Requirements: The City lacks effective controls and procedures for timely CAPER submission and accurate reporting from subrecipients, violating HUD's 90-day submission rule.
  • Recommended Follow-Up: Enhance policies and internal controls to ensure all subrecipient CAPERs are reconciled and submitted to HUD within the required timeframe.

Finding Text

Program: Housing Opportunities for Persons with AIDS (HOPWA) ALN #: 14.241 Federal Agency: Housing and Urban Development Federal Award Numbers: MAH22-F005, MAH20-F005, and MAH21-F005 Award Year: July 1, 2022–June 30, 2023 Performance Reporting Type of finding: Material weakness and material noncompliance Prior-year finding: No Statistically valid sample: No 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. HOPWA formula grantees are required to submit a CAPER demonstrating coordination with other Consolidated Plan resources. HUD uses the CAPER data to obtain essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries (which includes racial and ethnic data on program participants). The Consolidated Plan Management Process (CPMP) tool provides an optional tool to integrate the reporting of HOPWA-specific activities with other planning and reporting on Consolidated Plan activities. In accordance with 25 CFR 574.520(a), the City must submit a CAPER to HUD within 90 days of the end of each 12-month program year until all Grant Funds are expended. Key line items of the CAPER include amount of HOPWA funds expended with HOPWA in the program year for each HOPWA-eligible activity. Auditor should review Part 3 Accomplishment Data Planned Goal and Actual Outputs, Table 1 HOPWA Performance Planned Goal and Actual Outputs, Column f HOPWA Actual funds in the CAPER, and Part 3C Summary Overview of Grant Activities Performance and Expenditure Information, Table 1 Performance and Expenditure Information by Activity Type, Column 2 Outputs: Amount of HOPWA Funds Expended. 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. The City failed to submit the CAPER that covers the period from July 1, 2021 to June 30, 2022 to HUD. The report is due to HUD by September 30, 2022. Additionally, the City has been unable to provide documentation that the subrecipient's CAPER has been reconciled to the Integrated Disbursement and Information System (IDIS). 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. Effect Incomplete information from its subrecipients has resulted in the City’s inability to properly comply with HUD’s CAPER reporting requirements. Questioned Costs Not determinable Recommendation We recommend that the City review and enhance its 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 FY22 CAPER was submitted to HUD on June 11, 2024. City will continue to work with all HOPWA subrecipients to ensure that a complete and accurate CAPER is completed in the appropriate format as required by HUD. This will include a focus on inputting the correct (eg, actual expended vs. award amount) funding amount. Implementation Date Beginning with CAPERs submitted for the FY ending 6/30/2024 (City 2024, Federal 2023). Responsible Officials Robert Keller, Project Planner, Cambridge Community Development Department, and Judith Tumusiime, Federal Grants Manager, Cambridge Community Development Department

Categories

Subrecipient Monitoring HUD Housing Programs Material Weakness Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 402448 2023-001
    Significant Deficiency Repeat
  • 402449 2023-001
    Significant Deficiency Repeat
  • 402450 2023-002
    Material Weakness Repeat
  • 402451 2023-002
    Material Weakness Repeat
  • 402452 2023-003
    Material Weakness Repeat
  • 402453 2023-003
    Material Weakness Repeat
  • 402454 2023-004
    -
  • 402455 2023-005
    Material Weakness
  • 402456 2023-005
    Material Weakness
  • 402457 2023-006
    Material Weakness
  • 402458 2023-006
    Material Weakness
  • 402459 2023-007
    Material Weakness
  • 402460 2023-007
    Material Weakness
  • 402461 2023-008
    Material Weakness
  • 402462 2023-008
    Material Weakness
  • 402463 2023-009
    Material Weakness
  • 402464 2023-009
    Material Weakness
  • 402465 2023-010
    Material Weakness
  • 402466 2023-010
    Material Weakness
  • 402467 2023-011
    Material Weakness
  • 402468 2023-011
    Material Weakness
  • 978890 2023-001
    Significant Deficiency Repeat
  • 978891 2023-001
    Significant Deficiency Repeat
  • 978892 2023-002
    Material Weakness Repeat
  • 978893 2023-002
    Material Weakness Repeat
  • 978894 2023-003
    Material Weakness Repeat
  • 978895 2023-003
    Material Weakness Repeat
  • 978896 2023-004
    -
  • 978897 2023-005
    Material Weakness
  • 978898 2023-005
    Material Weakness
  • 978899 2023-006
    Material Weakness
  • 978900 2023-006
    Material Weakness
  • 978902 2023-007
    Material Weakness
  • 978903 2023-008
    Material Weakness
  • 978904 2023-008
    Material Weakness
  • 978905 2023-009
    Material Weakness
  • 978906 2023-009
    Material Weakness
  • 978907 2023-010
    Material Weakness
  • 978908 2023-010
    Material Weakness
  • 978909 2023-011
    Material Weakness
  • 978910 2023-011
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $11.36M
14.267 Continuum of Care Program $4.82M
84.425U American Rescue Plan Elementary and Secondary School Emergency Relief $2.88M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $2.59M
14.218 Community Development Block Grants/entitlement Grants $2.26M
84.425D Elementary and Secondary School Emergency Relief Fund (esser) $1.83M
10.555 National School Lunch Program $1.78M
93.568 Low-Income Home Energy Assistance $1.36M
84.010 Title I Grants to Local Educational Agencies $1.33M
21.027 Coronavirus State and Local Fiscal Recovery Funds $631,858
14.231 Emergency Solutions Grant Program $447,934
97.067 Homeland Security Grant Program $395,216
10.553 School Breakfast Program $350,371
84.027 Special Education_grants to States $342,165
32.004 Universal Service Fund - Schools and Libraries $238,716
10.559 Summer Food Service Program for Children $235,325
84.367 Improving Teacher Quality State Grants $178,360
84.002 Adult Education - Basic Grants to States $165,716
32.009 Emergency Connectivity Fund Program $158,827
93.590 Community-Based Child Abuse Prevention Grants $150,159
84.048 Career and Technical Education -- Basic Grants to States $99,323
84.365 English Language Acquisition State Grants $85,904
14.881 Moving to Work Demonstration Program $84,885
84.424 Student Support and Academic Enrichment Program $82,790
84.173 Special Education_preschool Grants $45,562
14.241 Housing Opportunities for Persons with Aids $45,047
97.042 Emergency Management Performance Grants $39,600
84.425 Education Stabilization Fund $30,287
84.196 Education for Homeless Children and Youth $15,549
14.401 Fair Housing Assistance Program_state and Local $12,746
20.616 National Priority Safety Programs $12,189
97.024 Emergency Food and Shelter National Board Program $11,885
20.600 State and Community Highway Safety $11,337
16.738 Edward Byrne Memorial Justice Assistance Grant Program $10,008
93.499 Low Income Household Water Assistance Program $9,554
93.788 Opioid Str $5,889
84.287 Twenty-First Century Community Learning Centers $363