Develop and implement standard operating procedures for recording and periodically evaluating sustained audit receivables to ensure that (1) all receivables are supported by a claim to cash and (2) an allowance for loss is recorded that reasonably estimates uncollectible amounts to reduce the gross amount of receivables to its net realizable value.

Develop and implement procedures that require action officials to certify the validity of accounts receivables periodically, at least quarterly. OCFO should use this information to assess the reasonableness of the allowance for loss estimate.

Work with action officials to determine the validity of all receivables from OIG sustained audit findings, determine whether restatement is necessary, and adjust HUD’s current and prior-year accounts receivable balances accordingly, ensuring that all writeoffs are reported to the Treasury.

Perform a validation, comparing the data used in OCFO’s PIH prepayment estimate calculation to the data used by PIH in its RNP reports to ensure that all CAM 1 codes and VMS fields are appropriately included. If it is determined that CAM 1 codes or VMS codes are missing or not properly included, OCFO should update the standard operating procedure and all estimates made to ensure that they are included.

Design and implement a procedure that ensures periodic communication between OCFO and PIH regarding all events that impact the PIH prepayment estimate.

Review FMC’s final December 31, 2016, balances and update the PIH prepayment beginning balance accordingly.

Delegate responsibilities to the appropriate program office and assign risk owners to provide responses for the acceptance, mitigation, and elimination of risks identified in HUD’s ERM risk profile.

Develop, implement, and document internal controls in response to identified risks from HUD’s ERM risk profile in compliance with OMB Circular No. A-123, Management's Responsibility for Enterprise Risk Management and Internal Control.

Complete and issue final FERA policy to the Department and communicate the requirements within the policy to program offices in a timely manner.

Assign and communicate the responsibility of FERA policy implementation and oversight to ensure that program offices are performing FERAs on a routine and timely basis to ensure effectiveness and efficiency of operations at the HUD program level and compliance with HUD internal policy and procedure.

Assign and communicate the responsibility of the MCR program policy, implementation, and oversight to ensure that program offices routinely conduct reviews to support a compliant internal control framework.

Conduct the OOR more frequently than annually to ensure that all obligations are adequately reviewed and deobligations are processed by the end of the fiscal year

Develop departmental policy that outlines the open obligation review process, to include (1) internal controls, (2) timeframes, and (3) roles and responsibilities of OCFO, OCPO, and program offices. These policies must outline sufficient internal controls in place to ensure that the Secretary can certify that all of HUD’s obligations are valid as of the end of the fiscal year.

Update standard operating procedures on the departmentwide unliquidated obligations review to conduct a routine review of justifications provided by the program offices for retained obligations, while ensuring that they are for a bonafide need and to support the annual certification made by the Secretary on open obligations.

As part of the OOR process, conduct monitoring activities of obligations sent to OCPO for deobligation by developing a mechanism to routinely track the status, to include key information, such as but not limited to the owner (program), date transmitted to OCPO, point of contact, last contact date, and current status. OCFO should use this information to ensure that all information has been communicated among all parties involved to enable timely deobligation.

Implement a process to ensure that ongoing ADA violation investigations are properly documented as the investigation progresses to enable timely review of open cases.

Ensure that $1,385,791 ($1,229,684 in housing assistance payments and $156,107 in associated administrative fees) used by the Lexington-Fayette Urban County Housing Authority is supported through a valid and retroactive exemption from HUD’s third-party requirements. If a retroactive exemption cannot be issued, HUD should follow recovery procedures prescribed in HUD Handbook 2000.06, REV-4.

Revise the standard MTW agreement for all existing 39 MTW housing agencies to clearly and specifically support which provision(s) waive the third-party inspection requirements.

Issue clarifying guidance to all existing 39 MTW housing agencies advising that HUD intended to waive the third-party inspection requirements via attachment C to the standard agreement.

Ensure that reviews of MTW annual plans are thorough by verifying that the MTW plan accurately identifies the appropriate exemptions as authorized in the MTW agreements.