Develop and implement a fraud risk checklist or other instrument as part of CPD’s monitoring oversight requirements, to be completed as part of each remote and onsite monitoring review.

Develop and implement a fraud analytics strategy using available data, including but not limited to data and information collected during the grantee risk assessment and monitoring processes, to begin conducting data analyses to identify potential fraud risks for further review.

Standardize position descriptions and job analyses for mission-critical occupations, high-risk occupations, and positions with high-volume staffing needs.

Develop and share best practices with HUD’s program offices on how hiring managers can execute hiring process responsibilities to meet timeliness goals.

Determine the cause for the variations in the timeliness of the preemployment and security checks step in FY 2017, 2018, and 2019 and develop appropriate process improvements.

Develop and document comprehensive reference documents on the hiring processes, procedures, roles, and responsibilities.

Develop and implement regular training for process owners on the hiring process.

Create and implement a knowledge management strategy, such as developing standard operating procedures, reference sheets, and program office fact sheets.

Corrective Action Taken

OCHCO developed and implemented client profiles for each HUD program office to address knowledge loss and the need for offices to explain or reexplain their mission and functions. The profiles will serve as a central repository to learn about the various programs and missions of HUD and will allow OCHCO staff, other key HUD program office staff, and HUD’s service provider staff to view critical information for each HUD program office.

Conduct a feasibility study for an automated POL.

Develop and implement time-to-hire goals that account for each hiring process step.

Develop and document methodologies on how OCHCO calculates hiring metrics to ensure that its hiring metrics and hiring goals align across all of its data sources, including the POL, the human capital dashboard, and the HCOP.

Track the quality of candidates as measured by the hiring officials.

Track the number of recruit attempts that result in a selection, the number of recruit attempts that result in a successful hire, and the number of positions that are reposted due to unsuccessful first recruit attempts.

Establish and implement a process to ensure that CPD’s supervisory controls are effective related to its staff’s requirement to contact grantees following a disaster. This process should also integrate with other HUD program offices as appropriate to improve consistency with HUD’s overall disaster response and to ensure the effectiveness of disaster controls.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to provide documentation, including but not limited to showing that it (1) notified and allowed a response from bidders regarding the bidding and scoring processes; and (2) awarded home repair master agreement contracts without restriction and were in line with the bid evaluation requirements, or provide a documented re-evaluation of the procurement showing that it provided the best advantage to it and HUD, thereby putting the remaining $9,736,636 award amount to better use.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to support $1,063,364 or repay its CDBG-DR program from non-Federal funds for payments made to one prequalified contractor under its home repair program without independent cost estimates and cost analyses.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to support $170,066 or repay its CDBG-DR program from non-Federal funds for payments made to the demolition contractor under its housing buyout program without independent cost estimates and cost analyses.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to support $27,250 or repay its CDBG-DR program from non-Federal funds for payments made to three appraisal contractors under its housing buyout program without cost analyses.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to develop and implement a HUD-approved written plan and checklists that will correct and prevent the deficiencies outlined in the finding.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to provide training to City staff to ensure that it understands and follows procurement requirements, such as performing independent cost estimates, cost analysis, scoring, including all contract provisions, ensuring that subrecipients understand and follow procurement requirements, and maintaining appropriate procurement documentation.