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