Review any ongoing time-and-materials contracts and if requirements were not followed, remedy the noncompliance or reprocure the contracts to ensure compliance with HUD requirements.
2022-NY-1002 | March 30, 2022
The Housing Authority of Plainfield, NJ, Did Not Always Comply With Requirements When Administering Its Public Housing Programs
Public and Indian Housing
- Status2022-NY-1002-002-COpenClosed
- Status2022-NY-1002-002-DOpenClosed
Ensure that all Authority staff members working with procurements and contract administration receive procurement training on applicable requirements, including the requirements related to cost reasonableness, contract types, the number of bids or quotations, contract provisions, and maintaining documentation to show the history of procurements.
- Status2022-NY-1002-002-EOpenClosed
Establish and implement adequate record-keeping procedures to comply with applicable procurement requirements, including a register of all contracts with key information and a checklist for each procurement action, to ensure that it completes required steps and receives all required documentation.
2022-KC-0002 | March 22, 2022
Approximately 31,500 FHA-Insured Loans Did Not Maintain the Required Flood Insurance Coverage in 2020
Housing
- Status2022-KC-0002-001-AOpenClosed$1,090,636Funds 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.
Require lenders to provide evidence of sufficient flood insurance or execute indemnification agreements for the 21 loans in our statistical sample that did not have sufficient flood insurance at the time of our audit to put nearly $1.1 million to better use. (See appendix A.)
- Status2022-KC-0002-001-BOpenClosed$1,506,887,996Funds 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.
PriorityPriorityWe 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.
Develop a control to detect loans that did not maintain the required flood insurance to put $1.5 billion to better use by avoiding potential future costs to the FHA insurance fund from inadequately insured properties.
Corrective Action Taken
In November 2022, FHA published the Acceptance of Private Flood Insurance for FHA-Insured Mortgages final rule (Docket No. FR-6084-F-02) in the Federal Register and issued Mortgagee Letter 2022-18, Acceptance of Private Flood Insurance for FHA-Insured Mortgages (ML 2022-18). These policy changes not only strengthened Single Family’s Mortgagee requirements regarding flood insurance, but they also introduced the ability for borrowers and Mortgagees to purchase private flood insurance. In January 2023, the sections in ML 2022-18 that pertain to HUD’s forward mortgage programs were superseded by the FHA Single Family Housing Policy Handbook (Handbook 4000.1), adding a requirement that the Mortgagee review all FHA-insured properties annually to determine if the property is located within a Special Flood Hazard Area (SFHA). For properties located within a SFHA, the Mortgagee must ensure flood insurance is in force for the life of the mortgage and that the property has sufficient flood insurance coverage. To ensure compliance with the policy requirements, the Mortgagee must include updated flood insurance information for properties where flood insurance is required in the Servicing and Claims File. In addition, Handbook 4000.1 includes flood insurance servicing policy updates. HUD submitted a revised management decision reflecting this action on June 22, 2023.
- Status2022-KC-0002-001-COpenClosed
Consult with the Office of General Counsel to review the language in the statutes, regulations, and handbooks and if warranted, make adjustments to the forward mortgage handbook to ensure consistency with the statute.
- Status2022-KC-0002-001-DOpenClosed
Consult with the Office of General Counsel to review the language in the statutes, regulations, and handbooks and if warranted, make adjustments to the HECM handbook to ensure consistency with the statute and regulation.
2022-NY-0001 | March 09, 2022
HUD Did Not Implement Adequate Grant Closeout and Reporting Processes To Ensure Consistent Application of GONE Act Requirements
Chief Financial Officer
- Status2022-NY-0001-001-AOpenClosed
Develop and implement controls for use of the bulk grant closeout process going forward to ensure that grants are closed in accordance with all applicable requirements, including that administrative actions and required work under the grant award have been completed by the grantee before the grant is closed out. These controls should include but not be limited to increased collaboration and communication between headquarters and field offices.
- Status2022-NY-0001-002-AOpenClosed
Develop and implement controls to ensure that future grant data reporting to stakeholders is consistent and accurate, including defining how records should be counted and data should be presented and ensuring that accurate POP dates are maintained in HUD’s systems.
2022-CH-0002 | February 15, 2022
HUD Did Not Always Comply With Its Internal Guide When Transitioning Offices From Mandatory to Maximum Telework During the COVID-19 Pandemic
Office of Administration
- Status2022-CH-0002-001-AOpenClosed
Ensure that future policies and guidance developed to return HUD’s offices to normal operations include the specific criteria, metrics, and defined geographic area to be used by all offices as applicable.
- Status2022-CH-0002-001-BOpenClosed
Develop and implement sufficient policies and controls to ensure that (1) applicable criteria in any future guidance are met and all safety measures are sufficiently completed before returning HUD’s offices to normal operations and (2) sufficient documentation is maintained to support that the applicable criteria were met.
2022-BO-0001 | February 07, 2022
HUD Did Not Have Adequate Policies and Procedures for Ensuring That Public Housing Agencies Properly Processed Requests for Reasonable Accommodation
Public and Indian Housing
- Status2022-BO-0001-001-AOpenClosed
We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs update its compliance monitoring guidance to include a requirement for personnel to review PHAs reasonable accommodations policies and procedures.
- Status2022-BO-0001-001-BOpenClosed
We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs update and consolidate requests for reasonable accommodation policies and procedures to ensure that there is centralized guidance available for the field offices and PHAs.
- Status2022-BO-0001-001-DOpenClosed
We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs require that PHAs track requests for reasonable accommodation, including the date of the request, the type of request, and the disposition and date of any action taken that should be made available to HUD at its request.
- Status2022-BO-0001-001-EOpenClosed
We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs review the joint agreement between HUD PIH and FHEO, including the Section 504 checklist, and modify, update, or recommit to it to ensure that the role of PIH and the responsibility for conducting civil rights front-end reviews is clearly defined.
- Status2022-BO-0001-001-FOpenClosed
We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs ensure that personnel receive training on how to conduct the civil rights front-end reviews, including a review of PHAs reasonable accommodation policies and procedures.
2022-LA-1001 | January 20, 2022
The Los Angeles Homeless Services Authority, Los Angeles, CA, Did Not Always Administer Its Continuum of Care Program in Accordance With HUD Requirements
Community Planning and Development
- Status2022-LA-1001-001-BOpenClosed
Develop and implement strategies to address capacity and organizational problems or obtain technical assistance to address these issues.
- Status2022-LA-1001-001-COpenClosed
Develop and implement procedures and controls to clearly define and update point-of-contact staff for subgrantees.
- Status2022-LA-1001-001-DOpenClosed
Work with HUD and subgrantees to reevaluate its CoC program’s performance goals and set targets that help to ensure that funds for future CoC grants are fully and effectively used to advance the goal of ending homelessness.
- Status2022-LA-1001-003-AOpenClosed
Complete and implement policies and procedures to ensure that APRs are submitted by the closeout deadline.