Update the CPD Monitoring Handbook to incorporate the review of the PR 29 report when performing financial monitoring reviews.

Develop written procedures on how to review PR 29 report submissions and monitor resubmissions, late submissions, and nonsubmissions.

Evaluate and update IDIS to ensure that resubmissions of PR 29 reports are tracked and prior submissions are preserved and correct the system’s misclassification of unsubmitted and uncertified draft PR 29 reports as submitted.

Determine how often grantees’ requests for reimbursement contain cost outside the quarter and in coordination with OCFO, evaluate CPD’s grant accrual methodology and assumptions to ensure that it adequately considers the impact of these late cost reimbursements.

Develop guidance that encourages grantees to draw down funds for reimbursement on a regular schedule, not less than quarterly.

Work with OCFO to ensure that CPD collects and reports to OCFO all of the information needed to properly account for all CPD activities in HUD’s financial statements in accordance with Federal financial reporting requirements and accounting standards.

Update Line 4 - Cash (grant funds) disbursed during the reporting period in the PR 29 report to allow grantees to report all CDBG grant funds disbursed, including funds that have not yet been drawn down from HUD for reimbursement.

Obtain the required approvals under PRA for the PR 29 report.

Develop and execute a detailed plan and timeline for both testing and reporting estimates of improper payments in the PIH-TBRA and PBRA programs in compliance with Federal law and OMB guidance.

Status

As of January 30, 2026, HUD has not provided a management decision, detailed plan, or timeline as to how HUD will respond to the recommendation.  When OIG inquired on the status of this recommendation, HUD reported it had completed work in this area that was reflected in its fiscal year 2025 Annual Financial Report (AFR). However, based on what HUD reported it is unclear if it addressed our recommendation. OIG recently initiated the annual Payment Integrity Information Act (PIIA) audit which reviews HUD’s payment integrity information to determine HUD’s compliance. During this audit OIG will also determine the status of HUD’s efforts in terms of this recommendation.

Analysis

For HUD to close this recommendation, it must finish testing the full life cycle of payments in these programs and publicly report estimates of the improper payments in them. Merely producing a plan with future action target dates is not sufficient to meet the spirit of this recommendation.

PBRA and PIH-TBRA are the two largest program expenditures in HUD's portfolio, totaling $55.6 billion in FY 25, or 62.5 percent of HUD's total expenditures. HUD has been challenged with developing a compliant sampling methodology that can test the full payment cycle, and, that can be executed within the required timeframes. To fully address this recommendation, the sampling methodology should test the full payment cycle, and the associated sample testing and statistical estimation must be completed in time to be included in the Annual Financial Report.
Implementation of this recommendation will result in HUD better-safeguarding taxpayer dollars and decrease improper payments.

We recommend that the Director of Disaster Recovery collect and record the number of days that it or other entities take to complete each milestone in the grant process.

We recommend that the Director of Disaster Recovery establish timing benchmarks for the milestones at each significant step in the allocation and award process based on actual data accumulated for the various grants.

We recommend that the Director of Disaster Recovery take steps to ensure that the milestone point of allocation is formally defined and documented, to allow for accurate tracking of compliance with requirements.

We recommend that the Deputy Assistant Secretary instruct PRDOH to implement a process to regularly conduct fraud risk assessments and determine a fraud risk profile. The fraud risk profile should include key findings and conclusions from the risk assessment, including the analysis of the types of fraud risks, their perceived likelihood and impact, risk tolerance, and the prioritization of risks.

We recommend that the Deputy Assistant Secretary instruct PRDOH to improve fraud awareness initiatives, such as participating in organized antifraud conferences, reviewing the OIG’s Special Fraud Alerts, Bulletins, and Other Guidance, and attending fraud risk training tailored to the program’s fraud risk profile (including subrecipients).

We recommend that the Deputy Assistant Secretary for Grant Programs evaluate PRDOH’s risk exposure and tolerance as part of HUD’s program-specific fraud risk assessment for disaster grant programs.

We recommend that the Deputy Assistant Secretary for Grant Programs coordinate with HUD’s Chief Risk Officer to (1) provide training and technical assistance to PRDOH with a focus on the design, implementation, and performance of fraud risk assessments, and (2) establish a fraud risk management framework for the organization.

We recommend that the Deputy Assistant Secretary for Grant Programs assess whether grantees have mature fraud risk management programs within the disaster recovery and mitigation programs.

We recommend that the Deputy Assistant Secretary for Grant Programs determine the fraud risk exposure in HUD's disaster recovery and mitigation programs and work with grantees to implement appropriate fraud mitigation activities.

We recommend that the Director, Office of Disaster Recovery, perform monitoring of or otherwise review grantees’ detailed procedures for preventing duplication of benefits for each grant activity within the first year after HUD signs the grant agreement or before grantees process applications for assistance, whichever occurs first.

We recommend that the Director, Office of Disaster Recovery, develop and implement a process to review grantees’ detailed procedures for preventing duplication of benefits and require grantees to correct any deficiencies identified in the review before grantees process applications for assistance.