Reimburse the three CoC program participants $260 from program funds for the underpayment of housing assistance due to inappropriate calculations of housing assistance.

Support or reimburse its CoC program $7,309 from non-Federal funds for the unsupported housing assistance payments.

Enforce its policy or implement an alternate method for the CoC program to ensure that annual recertifications are completed in a timely manner and that housing assistance is not issued before the recertification is completed to ensure that $385,660 in program funds is appropriately used for future payments.

Train its program staff on calculating housing assistance payments for the HOME and CoC programs to ensure that payments are appropriately calculated.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

Repay its program $22,402 for duplicative charges to HOME activity 2292 from non-Federal funds.

Update and implement changes to the City’s HOME and grants management policies and procedures to prevent similar errors and ensure that HOME draws are accurate and in accordance with HUD requirements.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $7,517,486 in 187 program obligations and $62,183 in 9 administrative obligations marked for deobligation as of September 30, 2018.

Review the 473 identified inactive retained obligations with remaining balances totaling $43,005,703 and close out and deobligate amounts tied to obligations that are no longer needed.

Develop and implement a procedure to ensure that all differences identified during financial statement and note validations are corrected before certification.

Develop and implement a process that ensures the routine collection of information needed to accurately complete the narratives required according to GAAP and OMB Circular A-136.

Develop and implement a procedure to ensure that HUD’s quarterly consolidated financial statements accurately reflect HUD’s current contingent liabilities resulting from pending or threatened litigation or unasserted claims.

Restate the following in HUD’s fiscal year 2017 consolidated financial statements: (1) Note 3, Fund Balance with Treasury, so that it is comparable to HUD’s new status of fund balance with Treasury presentation, (2) the statement of net cost by reducing the administrative costs for non-FHA programs by $174 million, and (3) the balance sheet to correct the $136.7 million misstatements in the Commitments and Contingencies and Other Liabilities line items. If a partial restatement or no restatements are made, OCFO should provide justifications and support for the decisions.

In consultation with the Office of Housing FHA Comptroller, develop and establish internal controls to ensure periodic communications for assessing and agreeing to the cost allocation accounting policies and procedures.

Develop and implement a cost allocation methodology that includes all HUD programs and components, including Ginnie Mae, in the distribution of administrative costs.

In consultation with the Office of Chief Human Capital Officer (OCHCO), develop and establish an activity-based costing process to validate the accuracy of factors used to allocate personnel and other administrative costs to each program and ensure that the validation is performed annually.

In collaboration with the Office of the Chief Information Officer (OCIO), implement an improved cost allocation methodology for IT cost based on direct costs used by the programs.

Determine whether HUD’s FSSP, ARC, has resources available to enhance HUD’s cost allocation methodology to identify, trace, and allocate costs directly to program activities periodically and at yearend.

Develop and implement a procedure that (1) detects significant fluctuations or discrepancies in Ginnie Mae’s budgetary data, (2) investigates the fluctuation or discrepancy to determine whether an error has occurred, and (3) performs corrections as needed, in a timely manner.