Provide training to State staff to ensure that it understands and follows (1) requirements to maintain adequate documentation to support that program disbursements are eligible and reasonable and (2) procurement requirements, including independent cost estimates, cost analyses, proposal scoring, and the timely checking of the SAM data for contractors’ eligibility.
2022-AT-1002 | September 16, 2022
The State of North Carolina Generally Had Capacity and Mostly Followed Disbursement Requirements, but Its Procurement Process Needs Improvement
Community Planning and Development
- Status2022-AT-1002-001-COpenClosed
2022-LA-0002 | August 17, 2022
Emergency Solutions Grants CARES Act Implementation Challenges
Community Planning and Development
- Status2022-LA-0002-001-AOpenClosed
Consider grant recipients’ feedback on challenges with (1) capacity, (2) multiple other sources of funding, and (3) subrecipient monitoring as part of CPD’s risk assessments.
2022-FO-0005 | June 27, 2022
HUD Compliance with the Payment Integrity Information Act of 2019
Community Planning and Development
- Status2022-FO-0005-003-AOpenClosed
Collaborate with the Deputy Chief Financial Officer to work with grantees in identifying where improper and unknown payments could occur in the CPD-HIM program throughout the payment cycle, to include the risks associated with subgrantee billing, and document this analysis.
- Status2022-FO-0005-003-BOpenClosed
Collaborate with the Deputy Chief Financial Officer and use the analysis developed in 3A to ensure that HUD’s improper and unknown payment testing procedures are (1) designed to test the full payment cycle and (2) include the review of documentation that supports that final beneficiaries were eligible, goods and services were received, and payments went to the correct final beneficiaries and were for the correct amount.
- Status2022-FO-0005-003-COpenClosed
Work with the Office of Community Planning and Development’s Chief Risk Officer and grantees to better identify the risks of improper and unknown payments throughout the payment cycle, to include the risks associated with grantees and subgrantees, and consider these risks when performing the CDBG and Homeless Assistance Grant risk assessments.
- Status2022-FO-0005-003-DOpenClosed
Work with the Deputy Chief Financial Officer to develop and design a process to ensure that each attribute evaluated during the PIIA risk assessment is evaluated at all levels of the full payment cycle.
Chief Financial Officer
- Status2022-FO-0005-001-BOpenClosed
Consult with OMB on the appropriate reporting for the untested portions of the payment cycle (such as reporting as unknown) and report accordingly.
- Status2022-FO-0005-001-COpenClosed
Implement a procedure, which ensures that future improper and unknown payment testing that does not test the full payment cycle is reported in accordance with OMB’s guidance.
- Status2022-FO-0005-004-AOpenClosed
Coordinate with OMB to ensure that all of HUD’s data posted on OMB’s PaymentAccuracy.gov are accurate, including data before fiscal year 2021.
- Status2022-FO-0005-004-BOpenClosed
Update its procedures to include verifying all HUD data on PaymentAccuracy.gov immediately after the data are published on the public website to ensure that all data are accurate and if not, coordinate any corrections with OMB.
2022-AT-1001 | March 30, 2022
The State of Florida Administered Its Housing Repair and Replacement Program Effectively but Not Always in a Cost-Efficient and Prudent Manner for the Projects and Activity Delivery Costs Reviewed
Community Planning and Development
- Status2022-AT-1001-001-AOpenClosed$107,036Questioned 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.
Provide support for the reimbursement to its housing program of $107,036 from non-Federal funds if justification cannot be provided to support that the overhead and profit amounts paid to the contractors were reasonable.
- Status2022-AT-1001-001-BOpenClosed
Perform a review of the remaining 453 contracts and any additional contracts issued under the old invitations to bid to ensure that overhead and profit amounts charged by contractors were reasonable. The State should either provide justification or support for the reimbursements to its housing program from non-Federal funds for the unsupported amounts.
- Status2022-AT-1001-001-COpenClosed
Update policies and procedures to ensure that a cost reasonableness assessment is performed on all cost elements, including the overhead and profit percentages charged by contractors for future contracts.
- Status2022-AT-1001-001-DOpenClosed
Develop and implement procedures to ensure the execution of newly developed policies that require contractors that work on multiple programs to provide adequate support to distinguish the proper amount of time and cost spent on each program. The State should also be required to provide procedures that implement the policy changes.
- Status2022-AT-1001-001-EOpenClosed
Train staff to ensure that expenditures, including payments made to contractors, are classified to the proper project activity in the DRGR system and provide support for training conducted.
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-1002-001-FOpenClosed
Improve controls over the proper execution and recording of all declaration of trust documents.
- Status2022-NY-1002-001-GOpenClosed
Implement controls to ensure that it does not enter into future third-party agreements unless the Authority follows applicable requirements in Notice PIH 2017-24 (HA), the annual contributions contract, 24 CFR Part 970, and the United States Housing Act of 1937.
- Status2022-NY-1002-001-HOpenClosed
Implement controls to ensure that future disposition proceeds are properly accounted for and used only for planned, approved purposes.
- Status2022-NY-1002-001-IOpenClosed
Place the Authority onto a zero threshold review process, requiring that all draws for funds go through field office review until the Authority completes all actions needed to close recommendations 1A through 1H.
- Status2022-NY-1002-001-KOpenClosed
Provide technical assistance to the Authority regarding the deficiencies identified with the rooftop lease and related proceeds, and Federal requirements for property disposition.