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Fraud Risk Inventory for the CDBG and ESG CARES Act Funds

We conducted this engagement in coordination with the Pandemic Response Accountability Committee (PRAC) to gain an understanding of the U.S. Department of Housing and Urban Development’s (HUD) fraud risk management practices and develop an inventory of fraud risks that HUD had not already identified for the funds appropriated by the Coronavirus Aid, Relief, and Economic Security (CARES) Act for the Community Development Block Grant (CDBG) and Emergency Solutions Grant (ESG) programs.

We identified five overall risk factors that contribute to the risk of fraud for the CDBG and ESG CARES Act funds.  We used these risk factors and the results of brainstorming sessions; interviews; and reviews of audit reports, investigations, and press releases to develop a fraud risk map containing 31 fraud schemes that can be used to misappropriate CDBG and ESG CARES Act funds.  We also identified opportunities to improve HUD’s fraud risk management practices, including clarifying roles and responsibilities, performing fraud-specific risk assessments, and raising awareness of fraud and fraud risks.

We recommend that the Office of the Chief Financial Officer coordinate with Office of Community Planning and Development program staff to clarify the roles and responsibilities for fraud risk identification, assessment, and mitigation.  We recommend the Principal Deputy Assistant Secretary for Community Planning and Development 1) complete program-specific fraud risk assessments and risk profiles for the CDBG and ESG programs, 2) consider OIG’s fraud risk inventory to improve their fraud risk assessments, 3) implement efforts to increase the awareness of fraud at all levels, 4) develop and implement a fraud risk checklist or other instrument to be completed as part of each monitoring review, and 5) develop and implement a fraud analytics strategy using available data.