Update its internal controls descriptions to reflect controls in place and implement monitoring activities to ensure that it carries out the controls and documents their performance and results.

Resolve the issues identified with the mastersubservicers to improve the data quality and timing of the raw data received for SLDB monthly processing and minimize manual adjustments.

Modify the standing operating procedures for the SLDB data quality checks that address mastersubservicer data deficiencies, data quality rules, and severity levels, to include periodic assessments of the appropriateness of the severity levels.

Review VAPE data validation procedures to improve preventive controls to determine the reasonableness of the inbound VAPE data before SLDB processing.

Implement the planned SLDB code fixes and enhancements to reduce future manual adjustments.

Ensure that all of the sampled amounts used for extrapolation in OCFO grant accrual validation estimates are properly supported with documentation that substantiates the amounts certified in the surveys.

Implement a refined accrual validation methodology, to include more comprehensive review procedures to substantiate the amounts certified by the grantee.

Review CPD’s grant accrual estimation methodology to ensure that all assumptions and variables used are properly supported and verifiable with the validation procedure.

After PIH prepayment validations are completed, apply all corrections to CAM 1 codes and Voucher Management System (VMS) expenses to all of the data supporting the fiscal year 2019 beginning balance, and recalculate the fiscal year 2019 PIH prepayment estimate. Based on the recalculation, determine whether restatement is needed to the correct errors in the fiscal year 2019 estimate calculation to ensure consistency between comparative statements.

Revise its review of the PIH prepayment estimate calculations performed by contractors to ensure that the contractors are following the established methodology and any changes to the methodology are applied to the data supporting the beginning balance, if appropriate.

Review all duties currently assigned to action officials to determine which duties can be centralized within OCFO or its Federal shared service provider. For any duties that cannot be centralized, (1) provide an explanation as to why they cannot be centralized and (2) assign these duties to appropriate positions within the program offices. Further, update the Debt Collection Handbook to include any changes made as a result of the review.

Implement monitoring and control activities to ensure that all debt collection action officials perform their duties in accordance with the Debt Collection Handbook

In coordination with each program office, identify the possible debts that could arise from normal business and monitoring activities and create a listing of these scenarios. Based on this listing, implement control activities to ensure that all debts that result from these activities are considered in financial reporting, U.S. Department of the Treasury reporting, and debt collection activities.

Develop and implement a procedure that requires OCFO to identify and research all debts that are more than 120 days old to ensure (1) validity, (2) that proper debt collection efforts occur, and (3) that the status reported in the TROR is correct according to Treasury’s TROR requirements.

Review the 76 sustained audit receivables not under repayment agreement totaling $59.6 million to determine validity and ensure that debt collection procedures are followed if applicable, to include (1) issuing demand letters, (2) creating repayment agreements if appropriate, and (3) referring delinquent debt or initiating writeoffs as appropriate. For all receivables determined to be valid, ensure that they are accurately reported to Treasury in the quarterly TROR. For all receivables determined to be invalid, remove the receivables from HUD’s accounts receivable balance.

Develop and implement standard operating procedures for calculating and reporting HUD’s quarterly allowance for loss based on periodic evaluation of each type of HUD’s accounts receivables in accordance with GAAP. The procedures should also include steps to ensure proper note disclosure for significant classes of accounts receivables.

Reassess HUD’s SFFAS 50 implementation by correcting HUD’s IUS PP&E opening balance instead of the yearend balances and recognize capitalized IUS development, maintenance, and enhancement costs incurred during fiscal year 2019. If not reassessed, provide auditable documentation supporting the application of the methodology used supporting HUD’s assertion that the IUS zero balance valuation complies with SFFAS 50 and FASAB Technical Release 18 implementation guidance.

Reevaluate capitalization and useful life thresholds included in HUD’s PP&E policy to ensure that they are comparable based on HUD’s funding level and size of operations and in accordance with capitalization thresholds and useful life requirements for leasehold improvements according to SFFAS 6 PP&E.

Recognize unrecorded assets and liabilities related to leasehold improvements and make proper disclosures regarding HUD’s leasehold improvement liability in the financial statements and notes.

Implement a procedure to periodically, not less than annually, review HUD’s funds from dedicated collections to ensure that those funds fulfill the criteria established by FASAB. Additionally, update HUD’s financial reporting standard operating procedures with this new periodic review.