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Open Recommendations by Oversight Area

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Open Recommendations by Oversight Area
Oversight Area	Priority Recommendations	Open Recommendations
Housing Assistance	75	100
Community Development	3	75
Disaster Recovery	3	82
Financial Risk and Accountability	6	130
Technology and Cybersecurity	4	88
Health and Safety	1	53
HUD's Operations	4	100
Total	96	628

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Disaster Relief

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We audited the Virgin Islands Housing Finance Authority’s monitoring of its Community Development Block Grant Disaster Recovery (CDBG-DR)-funded activities. We initiated the audit because of the large amount of CDBG-DR funds awarded to the U.S. Virgin Islands for the 2017 disasters and to aid in…

Oversight Area: Disaster Relief

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement monitoring policies and detailed procedures to guide the Authority’s CMU staff in assessing activity performance to meet the subrecipient monitoring requirements and establish written performance metrics to progressively achieve the performance outcome for those activities the Authority administers.

We recommend that the Deputy Assistant Secretary instruct the Authority to revise subrecipient agreements to include performance metrics and milestones tailored to the activity in sufficient detail to enable the Authority to collect information to effectively assess the activity’s performance.

We recommend that the Deputy Assistant Secretary instruct the Authority to revise the monthly status report template to allow the subrecipient to report its current progress against the established performance metrics.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop a tracking process to ensure that the Authority issues monitoring reports and receives responses to these reports within the timeframe required by its policy. This process should also include a referral to management when the timeframe requirements are not met.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop detailed procedures to ensure that the corrective action tracking process is consistently followed to ensure proper resolution.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement policies and detailed procedures to establish the CMU’s responsibilities related to verifying that the CDBG-DR activity meets the stated national objective.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement policies and detailed procedures to identify the risk analysis process for monitoring all CDBG-DR-funded activities during the course of the activity and require that the monitoring files document the basis for why an activity is or is not monitored.

We recommend that the Deputy Assistant Secretary instruct the Authority to train the CMU staff on the newly developed policies and procedures and obtain technical assistance from HUD as needed.

We selected the State of California’s 2018 disaster owner-occupied rehabilitation and reconstruction program to audit after an internal risk assessment of disaster grantees showed the grant was newer and had not yet disbursed the majority of its funding. The State received more than $1 billion for…

Oversight Area: Disaster Relief

We recommend that the Director of the Office of Disaster Recovery require the State to implement policies and procedures that require maintaining documentation to ensure it can support compliance for the installation of 36-inch roof valley flashing.

We recommend that the Director of the Office of Disaster Recovery require the State to determine if the proper roof valley flashing was installed on the completed and in progress homes, and if not, require the State to install the correct roof valley flashing using non-Federal funds.

We recommend that the Director of the Office of Disaster Recovery require the State to enhance the system used to estimate costs, to include the Wildland-Urban Interface Code required roof valley flashing, or document in the system and its output the different materials and costs used.

We recommend that the Director of the Office of Disaster Recovery require the State to develop and implement a policy to identify ownership and primary residency earlier in the review process and potential red flags in documentation.

We recommend that the Director of the Office of Disaster Recovery require the State to document and support its decision regarding duplication of benefits and income verification for additional owners of the property under an application.

We performed an audit related to the U.S. Department of Housing and Urban Development’s (HUD) Disaster Recovery Data Portal. The Disaster Recovery Data Portal is a technological solution planned by HUD to facilitate the rapid and secure transmission of data from the Federal Emergency Management…

Oversight Area: Disaster Relief

We recommend that the General Deputy Assistant Secretary, Office of Policy Development and Research, and the Deputy Chief Information Officer, Office of the Chief Information Officer develop the project management documents, as required by HUD’s Project Planning and Management Life Cycle V2.0 policy, including obtaining required approvals and ensuring that an adequate project risk management process is established for identifying, analyzing, and responding to project risks.

We recommend that the General Deputy Assistant Secretary, Office of Policy Development and Research; the Deputy Chief Information Officer; and the Director, Office of Disaster Recovery, identify and incorporate at least one additional data source into the Disaster Recovery Data Portal to further assist grantees with duplication of benefits assessments.

We performed an audit examining HUD’s efforts to prevent duplication of benefits when using Community Development Block Grant (CDBG) Disaster Recovery and Mitigation funds. Our objective was to determine how the U.S. Department of Housing and Urban Development (HUD) assesses the adequacy of…

Oversight Area: Disaster Relief

We recommend that the Director, Office of Disaster Recovery, perform monitoring of or otherwise review grantees’ detailed procedures for preventing duplication of benefits for each grant activity within the first year after HUD signs the grant agreement or before grantees process applications for assistance, whichever occurs first.

We recommend that the Director, Office of Disaster Recovery, develop and implement a process to review grantees’ detailed procedures for preventing duplication of benefits and require grantees to correct any deficiencies identified in the review before grantees process applications for assistance.

We recommend that the Director, Office of Disaster Recovery, for future grants, develop and implement procedures to ensure that all applicable requirements for preventing any duplication of benefits are included in the adequacy criteria, grantee certifications, and HUD review checklists supporting the certification.

We audited the Puerto Rico Department of Housing’s (PRDOH) fraud risk management practices to assess the maturity of its antifraud efforts. HUD heavily relies on its grantees to detect and prevent fraud, waste, and abuse and PRDOH is HUD’s second largest Community Development Block Grant Disaster…

Oversight Area: Disaster Relief

We recommend that the Deputy Assistant Secretary instruct PRDOH to implement a process to regularly conduct fraud risk assessments and determine a fraud risk profile. The fraud risk profile should include key findings and conclusions from the risk assessment, including the analysis of the types of fraud risks, their perceived likelihood and impact, risk tolerance, and the prioritization of risks.

We recommend that the Deputy Assistant Secretary instruct PRDOH to improve fraud awareness initiatives, such as participating in organized antifraud conferences, reviewing the OIG’s Special Fraud Alerts, Bulletins, and Other Guidance, and attending fraud risk training tailored to the program’s fraud risk profile (including subrecipients).

We recommend that the Deputy Assistant Secretary for Grant Programs evaluate PRDOH’s risk exposure and tolerance as part of HUD’s program-specific fraud risk assessment for disaster grant programs.

We recommend that the Deputy Assistant Secretary for Grant Programs coordinate with HUD’s Chief Risk Officer to (1) provide training and technical assistance to PRDOH with a focus on the design, implementation, and performance of fraud risk assessments, and (2) establish a fraud risk management framework for the organization.

We recommend that the Deputy Assistant Secretary for Grant Programs assess whether grantees have mature fraud risk management programs within the disaster recovery and mitigation programs.

We recommend that the Deputy Assistant Secretary for Grant Programs determine the fraud risk exposure in HUD's disaster recovery and mitigation programs and work with grantees to implement appropriate fraud mitigation activities.

From 2001 to 2022, the Community Development Block Grant - Disaster Recovery program provided almost $98 billion to states, cities, counties, and territories to help them recover from disasters. Administering disaster recovery has been a recurring U.S. Department of Housing and Urban Development…

Oversight Area: Disaster Relief

We recommend that the Director of Disaster Recovery collect and record the number of days that it or other entities take to complete each milestone in the grant process.

We recommend that the Director of Disaster Recovery establish timing benchmarks for the milestones at each significant step in the allocation and award process based on actual data accumulated for the various grants.

We recommend that the Director of Disaster Recovery take steps to ensure that the milestone point of allocation is formally defined and documented, to allow for accurate tracking of compliance with requirements.

In January 2017, HUD awarded the City $141.2 million in Community Development Block Grant National Disaster Resilience grant funding for disaster resilience. HUD designed the grant to give states flexibility in planning program activities and help state and local communities recover from past…

Oversight Area: Disaster Relief

We recommend that HUD require the City to reassess the eight infrastructure projects still in the design or planning phase to determine whether the City can complete the projects or how the remaining funds could be best used within the 6 years remaining for the grant period to ensure that the City is protected from future storm and rain events.

We recommend that HUD require the City to for the $14,683,335 originally budgeted for the Milneburg and Microgrid projects, work with HUD to (1) determine whether its planned action plan amendment would constitute the need to submit a substantial action plan amendment, (2) ensure that any modifications in its action plan amendment would lessen the susceptibility of rain and flood events within the Gentilly area, and (3) require that any activities pursued under the action plan amendment could reasonably be expected to be completed by the September 30, 2029, deadline.

We recommend that HUD require the City to review the number and type of positions for its National Disaster Resilience staff that are responsible for the oversight and completion of infrastructure projects and ensure that it has the appropriate staffing levels to complete adequate monitoring and oversight of the projects.

We recommend that HUD require the City to revise its risk assessment plan and process to ensure that monitoring is regularly conducted for its infrastructure projects through project completion, including establishing a monitoring schedule to ensure the progression and completion of the infrastructure projects.

We recommend that HUD require the City to develop and submit to HUD for approval an updated planning and administration budget and staffing plan, after reassessing the infrastructure projects in recommendation 1A, to complete the National Disaster Resilience projects with the funds and within the timeframe remaining.

We recommend that HUD require the City to analyze the method used to charge planning and administration costs to ensure that all costs are applied to the correct costs category and are valid charges to the National Disaster Resilience grant.

We recommend that HUD require the City to review misallocated planning and administration funds and reallocate any mistakenly allocated funds to the correct National Disaster Resilience project or grant activity. This measure could make available additional funds for program oversight.

We recommend that HUD require the City to develop a plan for how the City will continue to fulfill the required monitoring and oversight responsibilities of the National Disaster Resilience programs and projects if it runs out of planning and administration funds before it completes these programs and projects.

We recommend that HUD require the City to provide monitoring reports and supporting documentation to show that it conducted periodic monitoring of NORA’ s performance and compliance with program rules and regulations and ensured that NORA promptly remedies any findings or concerns. This includes, but is not limited to, ensuring that NORA (1) provides adequate oversight of the contractors providing service under the program and (2) maintains documentation to support eligibility for program participants.

We recommend that HUD require the City to develop and implement a methodology for NORA to conduct periodic evaluations at appropriate points during the construction process to assess the quality of the work on all new properties and correct any issues identified.

We recommend that HUD require the City to develop and implement a plan for how to review the condition of the property updates and determine where repairs are needed.

We recommend that HUD require the City to analyze the effectiveness of the Retrofit program and identify what improvements are needed to better benefit program participants and lessen their burden, to include obtaining input from program participants, and implement those improvements.

We recommend that HUD require the City to support or repay, from nonfederal funds, $5,078 in the square footage overcharge for work not completed, according to the project design and invoice documentation.

We recommend that HUD require the City to provide supporting documentation for the 4 program participants that did not have adequate income documentation. If the supporting documentation cannot be provided, repay, from nonfederal funds, $99,347.

We recommend that HUD require the City to since the property updates have been completed for the 24 program participants that did not receive the green infrastructure training, provide documentation that any subsequent program participants completed the green infrastructure training workshop before the grant agreement is signed and construction begins.

We audited the Puerto Rico Housing Finance Authority’s (PRHFA) Homebuyer Assistance Program (HBA), which provides eligible applicants with closing costs and downpayment assistance for the purchase of a primary residence. The U.S. Department of Housing and Urban Development (HUD) provided its…

Oversight Area: Disaster Relief

Work with PRDOH to determine whether its current method of measuring how many applicants purchased their home through the program is the best way to measure the HBA program’s impact.

Based on the results of recommendation 1A, update the HBA guidelines and the Puerto Rico disaster recovery action plan.

Instruct PRDOH and PRHFA to develop and implement clear and consistent guidelines and procedures that establish a verifiable methodology for determining the amount of financial awards granted to eligible HBA participants.

Include, as part of the revised procedures, a requirement to document within each case in SSP a detailed (1) calculation of the household income and (2) the analysis and computations conducted by the PRHFA underwriter for determining the amount of the financial assistance award.

Instruct PRDOH and PRHFA to provide training and guidance to participating lending institutions related to the updated guidelines and procedures for determining the financial award granted to HBA participants to ensure that program funds are distributed in an equitable manner.

We audited the project activity status for 12 grantees that received funds under the U.S. Department of Housing and Urban Development’s (HUD) Community Development Block Grant (CDBG) National Disaster Resilience (NDR) grant to determine whether the grantees have accomplished or are on track to…

Oversight Area: Disaster Relief

We recommend that HUD work with Connecticut and Shelby County to fully realize the program benefits by (1) assessing whether any of the current project activities need to be replaced with more viable project activities, thereby ensuring that any modifications to the project activities will lessen the susceptibility of rain and flood events; (2) assessing whether administrative funds have been properly allocated and charged to identify any possible cost savings; (3) determining whether enough administrative funds or other available funds exist to complete the administration of the grant project activities; and (4) developing and implementing a written plan of action that will assist with expediting the project activities that could reasonably be expected to be completed by the September 30, 2029, deadline.

We recommend that HUD conduct onsite or remote monitoring for the City of Minot and Tennessee, which have not had any monitoring since grant inception, to ensure that these grantees are on track to meet their program goals.

We recommend that HUD for grantees with delayed project activities (California, Connecticut, Louisiana, Tennessee, Virginia, New York City, Minot, and Shelby County), require each grantee to provide a detailed timeline with milestone dates of when projects should be completed and provide updates to ensure that grantees stay on schedule.

We recommend that HUD for its disaster-related program wide activities, revise the action plan and quarterly performance review checklists to a format that more specifically and directly addresses the subject program.

We recommend that HUD for its disaster-related program wide activities, require grantees to provide documentation showing that they have upfront collaboration with partnering entities in executing the grant program. If the grantee plans to hire contractors, HUD should ensure that grantees have a plan to quickly onboard contractors early in the program.

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General (OIG) is auditing the use of Community Development Block Grant Disaster Recovery (CDBG-DR) funds as non-Federal match for the Federal Emergency Management Agency’s (FEMA)Public Assistance Program. Our…

Oversight Area: Disaster Relief

We recommend that the Director of CPD’s Office of Disaster Recovery require active disaster recovery grantees to report in DRGR other sources of funding used for non-Federal match activities.

We recommend that the Director of CPD’s Office of Disaster Recovery develop and implement internal controls to ensure that grantees completely and accurately report non-Federal match activities in DRGR.

Open Recommendations by Oversight Area

Oversight Area

Status

Priority

Virgin Islands Housing Finance Authority Ineffectively Monitored CDBG-DR Activities

State of California, 2018 Disasters Owner-Occupied Rehabilitation and Reconstruction Program

Disaster Recovery Data Portal

Preventing Duplication of Benefits When Using Community Development Block Grant Disaster Recover and Mitigation Funds

The Puerto Rico Department of Housing Should Enhance Its Fraud Risk Management Practices

CPD Could Improve the Timing of Delivery of Disaster Recovery Funding

After More Than 6 Years, The City of New Orleans’ National Disaster Resilience Project Activities Had Made Little Impact on Resilience

The Puerto Rico Housing Finance Authority’s Homebuyer Assistance Program Positively Impacted Participants but May Not Have Distributed Disaster Recovery Funds Equitably

Grantees Were Delayed in Completing National Disaster Resilience Program Activities, but Remain On Track to Accomplish Goals

Opportunities Exist for CPD To Improve Collection of Disaster Recovery Grantee Data for Non-Federal Match Activities

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