We also recommend that the Director of HUD’s Cleveland Office of Public Housing determine whether the Authority qualifies for an exemption from preaward review.
2023-CH-1002 | Mayo 24, 2023
The Stark Metropolitan Housing Authority, Canton, OH, Did Not Always Comply With Federal and Its Own Procurement Requirements
Public and Indian Housing
- Status2023-CH-1002-001-IOpenClosedClosed on Septiembre 06, 2023
- Status2023-CH-1002-001-EOpenClosed
For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to support the reasonableness of the change orders that increased the price of the contract (0216) by more than $1.1 million or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable.
2023-CH-0003 | Mayo 23, 2023
Improvements Are Needed To Ensure That Public Housing Properties Are Inspected in a Timely Manner
Public and Indian Housing
- Status2023-CH-0003-001-AOpenClosed
Prioritize the inspection of public housing properties that were (1) not included in the NSPIRE demonstration but were identified as high priority under the Center’s Big Inspection Plan and (2) approved to participate under the NSPIRE demonstration that the Center was unable to inspect by March 31, 2023.
- Status2023-CH-0003-001-BOpenClosedPrioridadPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
Implement adequate policies, procedures, and controls to ensure that public housing properties will be inspected within required timeframes.
Status
While the NSPIRE regulations on inspection timing are completed, the Real Estate Assessment Center is not able to make the required modifications in the NSPIRE system to enforce the regulatory guidelines as this time. HUD is uncertain whether the vendor can make the needed modifications or if additional funding is needed. As of June 2024, PIH was not able to provide an expected time of when HUD will be able to make that determination.
Analysis
To fully address this recommendation, HUD must provide evidence demonstrating that it has implemented control activities to ensure that public housing properties are inspected within required timeframes. Implementation of this recommendation will result in HUD accurately tracking the dates in which public housing properties should be inspected and that they are timely completed. Due to the uncertainty of when software changes to NSPIRE can take place to enforce the timing of inspections, REAC cannot enforce the requirements of inspection timing.
2023-FO-0009 | Mayo 22, 2023
HUD Did Not Comply with the Payment Integrity Information Act of 2019
Chief Financial Officer
- Status2023-FO-0009-001-AOpenClosedPrioridadPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
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.
- Status2023-FO-0009-001-COpenClosedClosed on Septiembre 29, 2023
Develop a secure platform for the collection and storage of PIIA data that contain PII and formally assign a staff with adequate training and skillsets to administer the data and application (including maintaining and managing access controls of a chosen application that will be used to store the PIIA data with PII).
- Status2023-FO-0009-001-BOpenClosedClosed on Marzo 12, 2024
Develop and complete a detailed plan and timeline for completing compliant PIH-TBRA and PBRA program estimates and ensure that the improper payment council prioritizes completion of the plan in time for fiscal year 2023 reporting.
- Status2023-FO-0009-002-COpenClosedClosed on Septiembre 29, 2023
Reassess the Homeless Assistance Grants program as part of the fiscal year 2023 risk assessment.
- Status2023-FO-0009-002-AOpenClosedClosed on Septiembre 29, 2023
Reevaluate the methodology and reassess the weight assigned to each risk factor to ensure that appropriate weight is given to risks associated with non-Federal administrators or consider doing one risk assessment for HUD’s internal payment cycle and another risk assessment for the non-Federal entities that administer HUD’s program funds.
- Status2023-FO-0009-002-BOpenClosedClosed on Septiembre 29, 2023
Until program-specific fraud risk assessments are completed, revise the PIIA fraud risk questionnaire process to compensate for the lack of program-specific fraud risk assessments.
2023-FW-0002 | Mayo 17, 2023
HUD’s Oversight of CDBG-DR Grantees’ Use of Program Income
Community Planning and Development
- Status2023-FW-0002-001-COpenClosed
We recommend that the Director for HUD’s Office of Disaster Recovery develop and implement controls to ensure that program income balance discrepancies are identified and corrected.
- Status2023-FW-0002-001-AOpenClosed$2,551,375Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
We recommend that the Director for HUD’s Office of Disaster Recovery require grantees to support or repay to its program $2,551,375, from nonfederal funds, for the 9 vouchers that did not have adequate supporting documentation for expenditures.
- Status2023-FW-0002-001-HOpenClosed
We recommend that the Director for HUD’s Office of Disaster Recovery provide training to grantees regarding the reporting, tracking, and expenditure of program income.
- Status2023-FW-0002-001-FOpenClosed
We recommend that the Director for HUD’s Office of Disaster Recovery implement quality control procedures to ensure that HUD staff completes the action plan and QPR checklists.
- Status2023-FW-0002-001-BOpenClosed
We recommend that the Director for HUD’s Office of Disaster Recovery work with its grantee to resolve or correct program income balances for the three grants that had program income balances outstanding.
- Status2023-FW-0002-001-EOpenClosed
We recommend that the Director for HUD’s Office of Disaster Recovery establish a mechanism to train grantees and HUD staff on existing guidance regarding supporting documentation for expenditures, FFRs, and program income balances on a recurring basis. Additionally, provide guidance and establish recurring training for HUD staff to monitor grantees for program income and submission of the FFRs..
- Status2023-FW-0002-001-GOpenClosedClosed on Marzo 31, 2024
We recommend that the Director for HUD’s Office of Disaster Recovery develop and implement controls to ensure that grantees’ policies and procedures related to program income are adequate.
- Status2023-FW-0002-001-DOpenClosed
We recommend that the Director for HUD’s Office of Disaster Recovery develop and implement controls to ensure that untimely FFRs are identified and corrected.
2023-NY-0002 | Mayo 15, 2023
HUD Can Improve Oversight of Its Temporary Endorsement Policy for Loans in COVID-19 Forbearance
Housing
- Status2023-NY-0002-001-HOpenClosed
Review and correct indemnification agreement data in HUD’s computer systems as needed for all agreements currently classified as having 2-year terms and all agreements related to 2-year agreements contained on its SharePoint site to ensure that its systems contain accurate data for monitoring and enforcement of agreements. This recommendation includes but is not limited to reviewing the agreement number, agreement term, billing lender, expiration date, refinance indicator, and source indicator.
- Status2023-NY-0002-001-GOpenClosed$3,493,636Funds Put to Better Use
Recommendations that funds be put to better use estimate funds that could be used more efficiently. For example, recommendations that funds be put to better use could result in reductions in spending, deobligation of funds, or avoidance of unnecessary spending.
Record indemnification agreement data in its system for the 34 loans for which the lender properly executed an indemnification agreement before endorsement and HUD had not recorded the agreement in its system to put up to $3,493,636 to better use by avoiding potential losses.