Puerto Rico and U.S. Virgin Islands
C-FACTS has served on both the Puerto Rico and U.S. Virgin Islands (USVI) technical assistance teams. Our team has been responsible for the financial management, compliance and monitoring, internal controls and recordkeeping components of both TA engagements and for the workforce development and HUD Section 3 programs in USVI. Over the last year, we have made significant strides in building the capacity of both grantees, leading to the approval of their financial certifications, action plan and implementation plan. We have continued to provide both on-site and remote assistance to launch CDBG-DR programs. Through our TA the grantees were able to demonstrate to HUD their capacity to manage DR funds.
Our team accomplishments:
PR: Reviewed and provided feedback and recommendations on all policies and procedures that comprise the financial certifications to meet CDBG-DR requirements and HUD approval. The TA team received the draft certification package from the grantee only one week before the due date. We were able to quickly assemble a team of seasoned accountants to review over 600 pages of documents, provide feedback to the grantee, make the needed corrections and submit the certifications by the due date. As part of the review process, we facilitated a two-day on-site session with the grantee to review and correct the deficiencies. We provided our rationale and supporting documentation such as references to 2CFR200 and other HUD regulations that helped the grantee better understand requirements. The result was that the HUD reviewers had just a few comments or concerns with the certifications.
USVI: We provided similar feedback to the grantee in the USVI under the same tight deadlines but were unable to convince the grantee, who was relying on the advice of paid contractors, to adopt our recommendations before submission to HUD. We provided the HUD reviewers with our list of deficiencies which expedited their review process. HUD comments mirrored many of our recommendations which increased the grantee’s confidence to use our TA going forward. Over the next 30 days we helped the grantee correct the deficiencies which ultimately led to approval of the financial certifications.
Helped grantees showcase their financial capacity to HUD’s CFO office. We designed process maps accompanied by written standard operating procedures to demonstrate that grantees had adequate internal controls over expenditure of HUD funds. Both grantees gave presentations to the CFO’s office that were well received. The CFO’s office continues to provide oversight to grantee internal controls and has been pleased with the progress made thus far.
Conducted several training sessions using classroom techniques, interactive sessions with participants and webinars on the following topics using readily available HUD materials sometimes customized for each grantee: Essentially CDBG and CDBG-DR, Financial Cost Principles, Cost Allocation, Indirect Cost Rates, Sub-recipient orientation, Sub-recipient management, Compliance and Monitoring, and Timekeeping.
Helped both grantees establish good accounting systems to properly track and report CDBG-DR expenditures. This includes design of the chart of accounts and utilization of Yardi and SAP software features. Grantees have the capability to produce reports that align with DRGR and quarterly performance reports. We facilitated several interactive sessions with finance and program staff to develop payment procedures for various programs, vendors, sub-recipients and internal expenditures documented by process maps. The process maps were also used as an analytical tool to reduce duplication and inefficiencies and to assess staffing levels required to process payments in a timely fashion.
Assisted the grantee with the design of timesheets that align with their programs and accounting software and a user manual for internal staff and sub-recipients seeking reimbursement for personnel and other program costs.
Reviewed and provided feedback, guidance and training on numerous policies and procedures, program operating manuals and RFPs to ensure HUD compliance and integration of best practices.