We recommend that the Deputy Assistant Secretary instruct PRDOH to implement a process to regularly conduct fraud risk assessments and determine a fraud risk profile. The fraud risk profile should include key findings and conclusions from the risk assessment, including the analysis of the types of fraud risks, their perceived likelihood and impact, risk tolerance, and the prioritization of risks.

We recommend that the Deputy Assistant Secretary instruct PRDOH to improve fraud awareness initiatives, such as participating in organized antifraud conferences, reviewing the OIG’s Special Fraud Alerts, Bulletins, and Other Guidance, and attending fraud risk training tailored to the program’s fraud risk profile (including subrecipients).

We recommend that the Deputy Assistant Secretary for Grant Programs evaluate PRDOH’s risk exposure and tolerance as part of HUD’s program-specific fraud risk assessment for disaster grant programs.

We recommend that the Deputy Assistant Secretary for Grant Programs coordinate with HUD’s Chief Risk Officer to (1) provide training and technical assistance to PRDOH with a focus on the design, implementation, and performance of fraud risk assessments, and (2) establish a fraud risk management framework for the organization.

We recommend that the Deputy Assistant Secretary for Grant Programs assess whether grantees have mature fraud risk management programs within the disaster recovery and mitigation programs.

We recommend that the Deputy Assistant Secretary for Grant Programs determine the fraud risk exposure in HUD's disaster recovery and mitigation programs and work with grantees to implement appropriate fraud mitigation activities.

We recommend that the Director, Office of Disaster Recovery, perform monitoring of or otherwise review grantees’ detailed procedures for preventing duplication of benefits for each grant activity within the first year after HUD signs the grant agreement or before grantees process applications for assistance, whichever occurs first.

We recommend that the Director, Office of Disaster Recovery, develop and implement a process to review grantees’ detailed procedures for preventing duplication of benefits and require grantees to correct any deficiencies identified in the review before grantees process applications for assistance.

We recommend that the Director, Office of Disaster Recovery, for future grants, develop and implement procedures to ensure that all applicable requirements for preventing any duplication of benefits are included in the adequacy criteria, grantee certifications, and HUD review checklists supporting the certification.

Consider grantee feedback on the challenges they faced as part of ONAP’s planning for technical assistance and training of ONAP COVID-19 recovery program grantees.

We recommend that the General Deputy Assistant Secretary, Office of Policy Development and Research, and the Deputy Chief Information Officer, Office of the Chief Information Officer develop the project management documents, as required by HUD’s Project Planning and Management Life Cycle V2.0 policy, including obtaining required approvals and ensuring that an adequate project risk management process is established for identifying, analyzing, and responding to project risks.

We recommend that the General Deputy Assistant Secretary, Office of Policy Development and Research; the Deputy Chief Information Officer; and the Director, Office of Disaster Recovery, identify and incorporate at least one additional data source into the Disaster Recovery Data Portal to further assist grantees with duplication of benefits assessments.

We recommend that the Director of the Office of Disaster Recovery require the State to implement policies and procedures that require maintaining documentation to ensure it can support compliance for the installation of 36-inch roof valley flashing.

We recommend that the Director of the Office of Disaster Recovery require the State to determine if the proper roof valley flashing was installed on the completed and in progress homes, and if not, require the State to install the correct roof valley flashing using non-Federal funds.

We recommend that the Director of the Office of Disaster Recovery require the State to enhance the system used to estimate costs, to include the Wildland-Urban Interface Code required roof valley flashing, or document in the system and its output the different materials and costs used.

We recommend that the Director of the Office of Disaster Recovery require the State to develop and implement a policy to identify ownership and primary residency earlier in the review process and potential red flags in documentation.

We recommend that the Director of the Office of Disaster Recovery require the State to document and support its decision regarding duplication of benefits and income verification for additional owners of the property under an application.

Review the loans in our sample that did not receive appropriate loss mitigation options to ensure that the borrowers were remedied by the servicers, when possible, and take administrative actions if appropriate.

Engage with the servicers in our sample to determine reasons for noncompliance and develop a plan to mitigate it going forward.

Provide additional guidance and training to servicers to address common loss mitigation issues found during this audit.