Develop and implement procedures to review the reasonableness of the amounts included in the Missing Documents Report before recording the reclassification entry. Include steps to be followed if the amounts in the report do not appear reasonable.
2023-FO-0003 | November 16, 2022
Audit of FHA’s Fiscal Years 2022 and 2021 Financial Statements
Housing
2023-FO-0003-001-J
Closed on September 29, 20232023-FO-0003-001-K
Closed on September 27, 2023Coordinate with the NSC to take all the actions necessary required by HUD Handbook 4000.1 to ensure that FHA’s interests are protected with respect to the partial claims for which FHA has not received the original promissory note and recorded mortgage.
2023-FO-0003-001-L
Closed on September 29, 2023Coordinate with the NSC to conduct a detailed review of the HECM assigned notes portfolio to identify and record all default events that have occurred to date and initiate collection proceedings in accordance with the applicable HUD Handbooks.
2023-FO-0003-001-M
Closed on May 30, 2024Coordinate with the NSC and the OCPO to determine whether the information technology system could be enhanced to track the annual payment of state property taxes for the HECM portfolio.
2021-OE-0008 | November 15, 2022
Fair Housing and Equal Opportunity’s Oversight of Fair Housing Enforcement Agencies
Fair Housing and Equal Opportunity
2021-OE-0008-01
Closed on January 03, 2024Provide more detailed guidance to HUD reviewers on benchmarks for each performance standard.
2021-OE-0008-02
Closed on January 03, 2024Update the PAR template to ensure that HUD reviewers include required information.
2021-OE-0008-03
Closed on October 04, 2023Assess HUD reviewers’ skills and readiness to determine the appropriate frequency of training.
2021-OE-0008-04
Closed on January 03, 2024Provide more detailed guidance to HUD reviewers and FHEO regional directors on when and under what circumstances to recommend or issue a PIP.
2023-BO-0001 | November 04, 2022
HUD and FHAP Agencies Can Better Document Decisions Not To Investigate Fair Housing Complaints
Fair Housing and Equal Opportunity
2023-BO-0001-001-A
Closed on March 27, 2024Update HUD Handbook 8024.01, REV-2, and regional intake policies and procedures as necessary to include (1) minimum requirements that all regions follow for documenting in HEMS attempts to reach out to claimants when additional information is needed before closing inquiries; (2) policies and procedures for collecting, recording, and documenting all relevant electronic intake information in HEMS; and (3) clarifying that communications with claimants regarding inquiry closure, requests for additional information, and notices of jurisdiction information clearly inform the claimant of the ability to provide additional information within the statute of limitations.
2023-BO-0001-001-B
Closed on March 27, 2024Develop a process to oversee housing discrimination allegations that FHAP agencies close and do not submit to HUD for dual-filing to ensure that the closure and jurisdictional determinations are consistent with the Fair Housing Act. To help address this recommendation, HUD should consider requiring FHAP agencies to enter data on closed inquiries in HEMS and make updates to FHAP agreements as necessary.
2023-FO-0001 | October 26, 2022
Improvements are Needed in HUD’s Fraud Risk Management Program
Chief Financial Officer
2023-FO-0001-001-A
PriorityPriorityWe believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
Perform a complete agency-wide fraud risk assessment (which incorporates the fraud risk assessments performed at the program level) and use the results to develop and implement an agency-wide plan to move HUD’s fraud risk management program out of the ad hoc phase.
Status
HUD continues to make progress in advancing HUD’s Fraud Risk Management program. HUD issued its Fraud Risk Policy on March 31, 2022. Since then, HUD has integrated fraud risk considerations into risk assessment work completed across HUD, to include processes for Front End Risk Assessments (FERA) and the annual risk profile refresh. Leveraging the history of reports issued by HUD oversight partners, HUD has (1) compiled program level oversight reports to identify fraud risk concerns; (2) initiated a repository to stratify elements of the reports to isolate fraud risk concerns; and (3) isolated trends and themes from the source reports. This baseline work will support the Department’s Fraud Risk Exposure report, due September 2024.
The Chief Risk Officer (CRO) has indicated that it is nearing completion on an entity wide fraud risk exposure analysis. This analysis will tell HUD what programs should be prioritized and reviewed regularly, and which programs can be reviewed less frequently. The programs ranked highest will be first on the list for a full fraud risk assessment and the CRO will lay out a plan and timeline for completing the others. The CRO is also working on a plan to transition from the use of contractor support to full time staff, the plan will occur in phases until 2027, with the first hiring actions occurring soon. The Office of Multifamily Housing (MFH) met with OIG on April 7 to demonstrate the progress they have made on their program-specific fraud risk assessment for the Project Based Rental Assistance Program. MFH expects to complete the assessment by July 15th. the Offices of Public and Indian Housing and Community and Planning and Development have not completed fraud risk assessments, but are working on assigning or hiring staff for dedicated risk management roles.
Analysis
While HUD has made considerable progress in the area of fraud risk management, there is still a lot of work to be done for HUD to complete an entity wide fraud risk assessment. While HUD's exposure analysis will help it to determine where to focus its efforts, HUD still needs to conduct program specific fraud risk assessments. Based on the demonstration by MFH, we believe that MFH has made great progress in its fraud risk assessment and we are encouraged that it has identified areas of weakness that it plans to target. However, PIH and CPD have not been able to demonstrate progress in this area and we do not believe that they will be able to complete program specific fraud risk assessments by 9/30/24.
To fully address this recommendation, HUD must provide evidence that it has performed an agency-wide fraud risk assessment performed at the program level, adopted and implemented its fraud risk assessment program departmental policy and that each HUD program office has established office-specific risk programs/p>
2023-FO-0001-001-B
Closed on September 30, 2024Develop and implement a procedure to collect and analyze reported suspected instances of fraud, along with other relevant data points, that can be leveraged to develop more robust antifraud risk mitigation tools.
2023-FO-0001-001-C
Closed on September 30, 2024Communicate to HUD program staff the differences between HUD’s enterprise risk management, PIIA, and financial risk management risk assessment processes to ensure an understanding of their roles and responsibilities within HUD’s fraud risk management program.
2023-FO-0001-001-D
Closed on September 30, 2024Develop and implement activities to raise awareness of fraud, such as participating in organized antifraud conferences or a newsletter that includes instances of recent fraud in Federal programs.
2023-FO-0001-001-E
Develop and implement a strategy for collecting and analyzing agency-wide data, to include subrecipient and beneficiary data, to identify trends and potential indicators of fraud across programs.
2023-FO-0001-001-F
Closed on September 30, 2024Collaborate with the Chief Risk Officer to conduct a workforce assessment to determine the level of dedicated full-time staff resources needed by the Chief Risk Officer to effectively (1) administer HUD’s enterprise and fraud risk management programs and (2) support program risk officers by increasing employee and stakeholder awareness of potential fraud schemes that could impact each program respectively.
2023-FO-0001-001-G
Closed on September 30, 2024If the workforce assessment determines that additional staff are needed, work with the Chief Risk Officer to staff the necessary positions.
2023-LA-0002 | October 19, 2022
HUD Could Improve Its Tracking and Monitoring of Continuum of Care Grantee Spending Levels
Community Planning and Development
2023-LA-0002-001-A
Closed on April 25, 2024$47,000,000Funds Put to Better UseRecommendations that funds be put to better use estimate funds that could be used more efficiently. For example, recommendations that funds be put to better use could result in reductions in spending, deobligation of funds, or avoidance of unnecessary spending.
Implement written procedures to ensure consistency among field offices in reviewing spending issues, potentially preventing up to an estimated $47 million in annual CoC recaptures.
2023-LA-0002-001-B
Closed on August 02, 2024Design and implement a training program and other development tools to help grantees. The goal of such training would be to provide ideas and other development tools to help the CoCs better provide assistance with implementation of their grants and monitoring of their grantees, including assistance with developing outreach strategies, partnering with community providers, financial budgeting, and best practices. The training should focus on the needs of first-year grantees and CPD should take steps to encourage participation.
2023-LA-0001 | October 13, 2022
Sale of Section 184 Properties on Tribal Trust and Other Restricted Lands
Public and Indian Housing
2023-LA-0001-001-A
Closed on January 25, 2023Consider conducting an analysis of staffing resources needed to manage the REO and notes sales on tribal trust properties program and adjust staffing accordingly.