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Due to deficiencies found in prior reviews of two Intergovernmental Personnel Act (IPA or Act) assignments, we audited the U.S. Department of Housing and Urban Development’s (HUD) implementation and oversight of the IPA mobility program. The audit objectives were to determine whether (1) HUD’s use of IPA agreements met the purpose and intent of the IPA mobility program, (2) HUD’s policies and procedures related to IPA agreements were adequate to ensure that its agreements met requirements and established proper oversight and monitoring of the personnel and activities involved, and (3) HUD used IPA agreements to circumvent other requirements.

HUD failed to ensure that its IPA agreements met the purpose of the Act because it did not have sufficient policies and procedures for negotiating, reviewing, and executing agreements, and its staff ignored requirements, altered standard documents, and did not disclose information to decision makers.  Based upon the evidence, HUD abused the IPA mobility program to circumvent other hiring authorities and had no assurance that the agreements were in its best interest, negotiated at a reasonable cost, or free from conflicts of interest.  Also, HUD did not properly manage the assignees.  This occurred because HUD did not have a central means of tracking assignees or promptly out-processing them, leaving HUD vulnerable to security threats.

We recommended that HUD establish an independent, central point of review for IPA agreements to ensure they are reasonable, meet requirements, and avoid potential conflicts of interest.  Further, the Office of General Counsel should review all IPA agreements before their effective dates.  In addition, HUD should ensure that all IPA assignees receive required training and that it promptly out-processes them when they leave.  HUD should also follow procedures to address the payment of $224,906 in ineligible costs for two invalid IPA agreements and have organizations support or repay $49,989 in unsupported payments to employers.