The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

Create and implement a policy that documents how it handles and addresses conflict of interest complaints.

Determine whether data currently collected from PHAs can be leveraged to identify and mitigate fraud risks and consider whether any additional data needs to be collected or systems enhanced to mitigate fraud risks.

Communicate Capital Fund program fraud risks and schemes to all its stakeholders, including PHAs, to increase program effectiveness.

Revise its ethics, conflict-of-interest and contractor certification policies and forms to address issues that can arise, including when using embedded consultants.

Use the fraud risks and fraud schemes HUD OIG identified and involve relevant stakeholders to create a program-specific fraud risk inventory to support HUD’s anti-fraud efforts and enhance oversight of the Capital Fund program.

Obtain training or technical assistance on the implementation of fraud risk management practices consistent with the Internal Control Integrated Framework, issued by COSO.

Revise its procurement policies to include requiring Corporation oversight for material changes in an agreement’s scope or amount.

Revise its procurement policies, practices, and controls to ensure that it executes and renews contracts in a timely manner to prevent lapses and backdating of agreements.

Require the State to implement a control to ensure that it follows its procurement policy and limits contract terms to 1 year unless it has the Corporation’s approval and it documents those exceptions.

Evaluate and enhance its fraud risk management activities by incorporating fraud risk management practices that are in alignment with the best practices identified in GAO’s A Framework for Managing Fraud Risks in Federal Programs and Chief Financial Officers Council’s Antifraud Playbook.

Require the State to implement a control to ensure that it follows its mini bid process to ensure that it obtains the best services for the best price or document those exceptions and have the Corporation’s approval for them.

Provide evidence that it abated lead-based paint hazards in one EBLL case where the Authority did not abate the hazards identified in an environmental investigation.

Coordinate with HUD to provide training for the Authority’s employees on managing of lead-based paint hazards and to provide technical assistance such as developing written procedures, improving internal controls, or contracting with subject matter experts to address the issues cited in this report.