Incorporate data and system enhancements such as those mentioned in this report into its plans to improve HUD’s ability to monitor and respond to fraud risks in the Single Family Housing program.

Use the OIG’s fraud risk inventory to enhance its program-specific fraud risk inventory for the Single Family Housing program.

Develop a comprehensive process to ensure that complaints received by HUD’s Multifamily Housing Clearinghouse are resolved in a timely manner.Corrective Action TakenThe  Federal Housing Administration (FHA) Resource Center fields complaint calls and directs them to the appropriate party. When a FHA Resource Center complaint is referred to the Multifamily Regional Office, it is entered into the Asset Management Processing System (AMPS), the…

Require the State to include in its procurement policy a reference to the New York State law which limits a State waiver of policies to 30 days unless renewed and to ensure that it clearly states whether the law affects the Governor’s 2012 waiver. Further, if it does not affect the 2012 waiver, require the State to take action to limit the use of that waiver to ensure full and open competition. 

Develop and implement policies and procedures that align with HUD’s requirements and controls to ensure that owners follow the requirements of the LSHR.

Issue guidance requiring ESG grantees develop and implement internal controls to prevent any duplication of benefits with other Federal rental assistance programs for the ESG program participants, specifically for rapid rehousing and homeless prevention.

Conduct an analysis to determine whether the changes to form HUD-50900 allow PHAs and HUD to appropriately measure the benefits and impacts of PHAs’ MTW program to include whether additional changes to the form are warranted to appropriately evaluate results of the MTW program.

Issue clarifying guidance to ensure that ESG grantees that operate tenant-based rental assistance programs, prorate the rent amount for the first month based on the lease agreement start date.

Develop and implement a review and verification process to ensure that data provided by MTW PHAs as support for compliance with the statutory requirements, that is not reported in HUD systems is accurate, complete, and supported.

Develop and implement a process to ensure that corrections or updates to PHA information are reflected in either restated or subsequent MTW annual reports.

Require PHAs to retain supporting documentation for all data elements reported in their annual reports and program data not captured in HUD systems.

Develop and implement a process to ensure that appropriate outcomes are assessed for each PHA’s local MTW program.

Support the cost reasonableness of $96,561 drawn from ESG CARES Act funds for the kitchen services contractor or repay HUD from non-federal funds.

Determine whether the $714,512 paid for 233 signing bonuses under the ESG CARES Act program were reasonable under the program participant’s particular circumstances, and not more than necessary to house the program participants or repay HUD from non-Federal funds.

Develop and implement additional written procedures and internal controls for the annual ESG program to ensure that it, and its subrecipients, do not charge holding fees and risk mitigation costs as expenses to the program, and that contracts are properly executed and maintained.

Develop and implement written policies and procedures that include internal controls for the ESG program to ensure that it, and its subrecipients, prorate the rent amount for the first month for tenant-based rental assistance. Since the City did not prorate rent, there was an estimated overpayment to landlords of $248,572 that could have been put to better use.

Repay HUD from non-Federal funds $51,235 in overpaid rent to landlords because the first month of rent was not prorated.

Develop and implement written policies to ensure that any changes to the expenditure and draw deadlines for the ESG program are provided in a formal document, such as a CPD notice. In this case, implementing these controls would provide clear guidelines to the grantee and help prevent the disbursement of $1,933,693 that was drawn after the draw deadline.

Review the rental assistance payments made for the ESG CARES Act program to identify other possible duplication of benefits with other rental assistance programs that the City operates. The $10,100 in duplication of benefits identified during the audit could have been put to better use.

Develop and implement written policies and procedures that include internal controls to prevent any duplication of benefits for the ESG program participants with other programs, specifically for rapid rehousing and homeless prevention.