Establish an improper payment council within HUD that consists of senior accountable officials from across the Department with a role in the effort that would work to identify risks and challenges to compliance and identify solutions as a collaborative group.

Status

The Office of the Chief Financial Officer (OCFO) noted that this recommendation cannot be completed by OCFO because OCFO is dependent on other HUD offices. The OCFO believes that this should be closed in light of the recommendation we made in the subsequent January 24, 2024, Management Alert: "Action Is Needed From HUD Leadership To Resolve Systemic Challenges With Improper Payments" which recommended that the Deputy Secretary Develop and execute a detailed plan and timeline for both testing and reporting estimates of improper payments in the Office of Public and Indian Housing’s Tenant-Based Rental Assistance (PIH-TBRA) and Office of Multifamily Housing Programs’ Project-Based Rental Assistance (PBRA) programs in compliance with Federal law and Office of Management and Budget guidance.

Analysis

The January 24, 2024, Management Alert: "Action Is Needed From HUD Leadership To Resolve Systemic Challenges With Improper Payments" found the lack of proper planning and coordination from leadership in HUD’s program and support offices prevents HUD from addressing the root causes behind the failure to comply with improper payment laws.

In response to the Management Alert, the Deputy Secretary stated that she would provide a plan in 30 days. On April 10, 2024, the Chief Financial Officer, Assistant Secretary for Housing, and Principal Deputy Assistant Secretary for Public and Indian Housing (PIH) stated their respective executives have been working together to develop a plan to accelerate HUD’s ability to produce statistically valid estimates. With respect to project-based rental assistance (PBRA), HUD plans to use ongoing data collection for fiscal year (FY) 2023 tier 1 and tier 2 payments to develop a statistical estimate in FY 2024. With respect to PIH-TBRA, in lieu of pursuing an estimate for the FY 2024 reporting cycle, PIH will focus on “its existing efforts to enhance PIH [IT] systems”, which HUD considers to be a more strategic use of resources. It is not clear from HUD’s response what PIH will do differently than it already had planned prior to the management alert as HUD did not provide a detailed plan or timeline for OIG review. As of June 21, 2024, a detailed plan or timeline has not been provided.

To improve coordination, HUD should establish an improper payment council within HUD that consists of senior accountable officials from across the Department. The council would work to identify risks and challenges to compliance and identify solutions as a collaborative group.