Leverage HUD OIG’s fraud risk inventory and continue using the Office of the Chief Risk Officer’s risk catalog to enhance CPD’s fraud risk management process.

Include grantees in the fraud risk identification process and communicate the risks and schemes identified for the disaster recovery program to relevant stakeholders, including, but not limited to, all HUD staff in the CPD Office of  Disaster Recovery, grantees and sub-recipients.

Use CPD’s fraud risk inventory to identify data needs, potential system enhancements, and implement data analysis techniques to improve CPD’s ability to monitor and respond to fraud risks in the Disaster Recovery program.

Conduct risk assessments in public housing without adequate lead-based paint inspection documentation to ascertain the existence of lead-based paint hazards.

Conduct lead-based paint inspections at public housing abated through removal methods where an abatement report is unavailable to ensure that units are “lead-free.”

Abate or implement interim control measures to reduce the risk of exposure to lead-based paint hazards identified through risk assessments.

Implement an ongoing maintenance program for lead-based paint to ensure unabated and “lead-safe” units remain hazard free.

Implement adequate policies and procedures regarding the management of lead-based paint in its public housing, including maintaining adequate records, completing interim controls, and conducting ongoing maintenance for lead-based paint hazards.

Ensure that it provides appropriate and accurate lead-based paint disclosures to prospective and current tenants.

Revise and update the Authority’s policies to ensure that environmental investigations are completed for EBLL cases and ensure that HUD and residents are notified of the results of environmental investigations in a timely manner.

Coordinate with HUD to provide training for the Authority’s employees on managing of lead-based paint hazards and to provide technical assistance such as developing written procedures, improving internal controls, or contracting with subject matter experts to address the issues cited in this report.

Provide evidence that it abated lead-based paint hazards in one EBLL case where the Authority did not abate the hazards identified in an environmental investigation.

Evaluate and enhance its fraud risk management activities by incorporating fraud risk management practices that are in alignment with the best practices identified in GAO’s A Framework for Managing Fraud Risks in Federal Programs and Chief Financial Officers Council’s Antifraud Playbook.

Obtain training or technical assistance on the implementation of fraud risk management practices consistent with the Internal Control Integrated Framework, issued by COSO.

Use the fraud risks and fraud schemes HUD OIG identified and involve relevant stakeholders to create a program-specific fraud risk inventory to support HUD’s anti-fraud efforts and enhance oversight of the Capital Fund program.

Communicate Capital Fund program fraud risks and schemes to all its stakeholders, including PHAs, to increase program effectiveness.

Determine whether data currently collected from PHAs can be leveraged to identify and mitigate fraud risks and consider whether any additional data needs to be collected or systems enhanced to mitigate fraud risks.

Issue guidance, including technical assistance, to all disaster recovery grantees that waivers for issues related to a disaster’s impact, like waivers of procurement policies, should be for reasonable and limited time periods after a disaster’s occurrence to ensure full and open competition.
 

Require the State to include in its procurement policy a reference to the New York State law which limits a State waiver of policies to 30 days unless renewed and to ensure that it clearly states whether the law affects the Governor’s 2012 waiver. Further, if it does not affect the 2012 waiver, require the State to take action to limit the use of that waiver to ensure full and open competition.
 

Require the State to implement a control, including documenting exceptions, to ensure that all contracts that exceed 5 years are approved by the Corporation.