Update HUD Handbook 1900.40, Do Not Pay policy, to clearly define the responsibilities for all parties and align it with current laws, processes, and procedures. This should include defining responsibilities for preaward and prepayment verification, and developing a process and governance structure to ensure that preaward and prepayment verification are consistently performed across HUD’s programs.

Status

HUD has until August 25, 2025 to provide its corrective action plan to OIG for review.

Analysis

Updating the HUD Handbook 1900.40 will define responsible parties for ensuring compliance with the Do Not Pay Initiative (DNP).    

The implementation of this recommendation will result in consistent use of DNP, allowing for instant verification of eligibility across the billions in payments that HUD processes.

Develop a standard operating procedure to ensure that the OCFO is 1) monitoring the DNP Computer Matching agreement to ensure continuity, 2) reporting accurately on its DNP matching, and 3) working with program offices to adjudicate any payments that are identified as potentially improper during the computer matching process.

Work with Multifamily Housing to investigate the 11 of 24 entities with expired SAM.gov registrations to determine if those entities should have received payments totaling $212,208,450 and perform the required follow-up actions once a determination is made.

Deobligate the 101 program obligations totaling $1,967,991.45 identified for deobligation during the fiscal year 2024 OOR that had not been deobligated as of February 28, 2025.

Develop and execute a written agreement with ONDCP on the reporting methodology for the CoC annual numeric targets and actuals that would meet future reporting requirements and comply with the Strategy and timeframe for implementation.

Develop and execute a written agreement with ONDCP on the use of reporting annual numeric targets for the RHP performance measures that would meet future reporting requirements and comply with the Strategy and timeframe for implementation.

Establish and implement formal policies and procedures that include (1) the ONDCP reporting process between HUD’s OCFO and CPD, (2) the process for reporting to ONDCP, (3) references to any written agreements between HUD and ONDCP, and (4) a requirement for periodic reviews of these written agreements to address any changes in administration, roles, responsibilities, reporting programs, reporting requirements, and reporting methodologies.

Develop a policy or update the existing Grants Management Policy to include 1) the process and controls that HUD will use to hold the prime recipients accountable for FFATA compliance and 2) clearly defined roles and responsibilities between OCFO and the program offices to ensure that action is prioritized by the correct responsible parties regarding FFATA compliance.

Work with applicable program offices to develop training materials and tools, such as dashboards, to assist program offices in monitoring their grant portfolios for subaward reporting compliance.

Develop a strategy to comprehensively assess and respond to fraud risks across NYCHA. The strategy should identify who within NYCHA is responsible for designing and overseeing activities to prevent and detect fraud. The strategy should also include how NYCHA will (1) assess fraud risks across NYCHA methodically and periodically, (2) create response plans for fraud risks that are identified, and (3) monitor and evaluate the effectiveness of fraud risk management activities. The strategy should also designate fraud risk responsibilities across NYCHA.

Based on the strategy, (1) complete an assessment of fraud risks across NYCHA, (2) create response plans for fraud risks that are identified, and (3) develop procedures to monitor and evaluate the effectiveness of fraud risk management activities.

Assess whether HUD’s other extra-large PHAs have mature fraud risk management programs and use the assessment to develop a strategy to reduce the fraud risk exposure to HUD. The strategy should include working with extra-large PHAs to implement appropriate fraud mitigation activities.

Work with HUD’s Chief Risk Officer to issue a notice to all PHAs explaining that PHAs are responsible for fraud risk management and play a role in fulfilling HUD’s requirement to identify and mitigate fraud risks. This notice should clearly indicate that PHAs should implement fraud risk management, which includes (1) completing an assessment of fraud risks, (2) creating response plans for fraud risks that are identified, and (3) developing procedures to monitor and evaluate the effectiveness of fraud risk management activities.

Provide evidence to support that the Authority corrected the 11 unit deficiencies for the 5 units and 7 building deficiencies for 4 buildings with outstanding deficiencies.

Determine the frequency of its quality control reviews of its inspections and work orders and update its quality control policy, training materials, and other resources as appropriate to ensure that its quality control process is consistently implemented.

Support that it has implemented its quality control policy for (1) monitoring the effectiveness of its unit and building inspections to ensure compliance with HUD’s and its own requirements and (2) reviewing work orders to ensure that cited deficiencies are corrected in accordance with HUD’s and its own requirements.

Provide evidence to support that the Authority corrected the four non-life-threatening deficiencies for the three units with outstanding deficiencies.

Implement adequate procedures and controls to ensure that the deficiencies identified during annual self-inspections are properly categorized and corrected in a timely manner.

Develop and implement a plan to manage and reduce its backlog of work orders. This plan should include but not be limited to (1) assessing and addressing staffing needs; (2) creating a timeline for completion of the work orders to ensure that its properties are maintained in decent, safe, and sanitary condition and in good repair; and (3) providing documentation showing that it is on track to meet the completion timeframe.

Implement adequate procedures and controls to ensure that inspection reports are uploaded to the Authority’s electronic filing system and work orders are created in a timely manner. This process should include but not be limited to providing training to its staff on the Authority’s systems, establishing timeframes for the creation of work orders, and monitoring the work order process.