CITY OF WILMINGTON

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

The City of Wilmington, Real Estate and Housing Department as 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 constitutes the Grantee’s annual performance report to HUD. Included in this submission is the Grantee Performance Report and all of the Provider Performance Reports together. Staff in the Real Estate and Housing Department review them to the best of our ability for accuracy and completeness. The finding notes that the documentary evidence of this review was not retained other than the subsequent data validation which occurs with HUD’s Technical Assistance (TA) HOPWA Data Validation team and through Cloudburst email. In the future the Real Estate and Housing Department will note to file the email confirmation of the received report is as complete and error free as possible.

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2015-009