We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of its Community Compass Technical Assistance and Capacity Building (Community Compass) program. We conducted the audit because we received a complaint alleging that HUD did not ensure that the program operated in compliance with applicable requirements and we had not audited the program. Our audit objective was to determine whether HUD had adequate oversight of its Community Compass program to ensure that it complied with applicable requirements.
HUD did not have adequate oversight of its Community Compass program to ensure that it complied with applicable requirements. The allegations in the complaint had merit. Specifically, HUD did not ensure that (1) expenditures always met program requirements, (2) services were properly procured, and (3) provider subcontractors were approved with consistent wage rates. These conditions occurred because HUD did not (1) have adequate policies and procedures to ensure that providers complied with Federal regulations, (2) believe that the services it procured were a direct benefit to HUD, (3) perform postaward monitoring reviews, and (4) have sufficient controls over its wage rate process. As a result, HUD lacked assurance that providers administered program funds in accordance with requirements as it incurred ineligible costs of $13,384 and unsupported costs of $845,497. In addition, more than $20.5 million in funds can be put to better use if HUD strengthens its internal controls and awards contracts according to procurement requirements.
We recommend that HUD require the providers reviewed to (1) reimburse $13,384 from non-Federal funds for ineligible costs paid to providers for overcharged labor or travel costs, and (2) support or repay $845,497 in unsupported wage and travel costs from non-Federal funds. In addition, we recommend that HUD develop and implement policies and procedures for the Community Compass program to ensure that providers comply with all applicable requirements, thereby putting more than $20.5 million to better use.
Recommendations
Community Planning and Development
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Status2018-PH-0003-001-AOpenClosed$13,384.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on July 31, 2020Require the four Community Compass providers reviewed to reimburse HUD $13,384 from non-Federal funds for ineligible costs from overcharged labor or travel costs.
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Status2018-PH-0003-001-BOpenClosed$845,497.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on July 31, 2020Require the four Community Compass providers reviewed to either provide documentation to support $845,497 in unsupported labor and travel costs, for personnel not on approved work plans, and for work performed that was not described on the payment request or reimburse HUD from non-Federal funds for any costs that it cannot support.
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Status2018-PH-0003-001-COpenClosed$15,475,981.00Funds Put to Better Use
Recommendations 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.
Closed on September 30, 2020Develop and implement policies and procedures for the Community Compass program, to include postaward monitoring, that ensures that providers and provider subcontractors comply with applicable requirements to avoid incurring expenses for unapproved personnel and overcharged labor and travel costs, thereby ensuring that as much as $15,475,981 is put to better use.
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Status2018-PH-0003-001-DOpenClosed$5,060,494.00Funds Put to Better Use
Recommendations 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.
Closed on August 10, 2020Develop and implement controls for the Community Compass program to ensure that it uses procurement contracts for services that directly benefit HUD, including the development, maintenance, and operation of the HUD Exchange website and preparation of the Annual Homelessness Assessment Report, thereby ensuring that as much as $5,060,494 is put to better use.
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Status2018-PH-0003-001-EOpenClosedClosed on September 18, 2019
Develop and implement controls for the Community Compass program to ensure that it consistently applies subcontractor wage rates among all providers that use a subcontractor.