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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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Community Improvement

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We audited the City of New York’s Infrastructure Rehabilitation and Reconstruction of Public Facilities Program. We selected this program for review because the City had allocated nearly $91 million to the program and disbursed more than $59.6 million as of October 31, 2017, and as part of our…

Oversight Area: Disaster Relief

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $594,012 disbursed due to the use of multipliers was for eligible, reasonable, necessary, and supported costs or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $2,689 disbursed due to a higher than required overtime rate was supported by documentation from the trade unions or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to reimburse its program $1,198 from non-Federal funds for overpaid wages due to billing and payroll errors.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to pay $544 in unpaid wages to the subcontractors of the affected employees and submit evidence that these employees have been paid.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide training to its staff to help ensure compliance with applicable cost principle, procurement, and Davis-Bacon requirements.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that it has strengthened its invoice review process to ensure that costs are eligible and supported before disbursing Disaster Recovery funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that payments made under the Rockaway Boardwalk construction management services contract complied with Davis-Bacon and Related Acts requirements and that restitution is made to affected workers for any underpayments identified.

We audited the State of Louisiana’s Restore Louisiana Homeowner Assistance program as part of our annual audit plan to review Community Development Block Grant Disaster Recovery programs. Our objective was to determine whether the State ensured that it complied with (1) its eligibility…

Oversight Area: Community Improvement

We recommend that the Deputy Assistant Secretary for Grant Programs require the State to support that seven applicants met the ownership and occupancy requirements or repay $396,905 to its program from non-Federal funds.

We recommend that the Deputy Assistant Secretary for Grant Programs require the State to support that it complied with the elevation requirements for two applicants or repay $118,244 to its program from non-Federal funds.

We recommend that the Deputy Assistant Secretary for Grant Programs require the State to implement additional controls and revise policies and procedures to ensure that adequate documentation is maintained in its files to support (1) recapture decisions, (2) eligibility related to ownership or occupancy, (3) ineligible decisions, (4) elevation considerations, and (5) mitigation of duplication of benefits issues related to override procedures and incorrect data provided by other agencies.

We recommend that the Deputy Assistant Secretary for Grant Programs require the State to implement additional controls and revise policies and procedures to ensure that the website is maintained and updated in compliance with requirements.

We audited Hamilton County’s subrecipient agreement with People Working Cooperatively, Inc. (corporation), for a Community Development Block Grant-funded housing repair services program based on a request from the U.S. Department of Housing and Urban Development’s (HUD) Columbus Office of Community…

Oversight Area: Community Improvement

Implement adequate procedures and controls to ensure that it obtains and reviews source documentation, such as invoices and time sheets, to support that expenses are eligible before providing Block Grant funds to the corporation for housing repair services.

Reimburse its Block Grant program from non-Federal funds for the $5,810 it provided to the corporation for labor that exceeded actual labor costs (more than $4,800) and indirect costs associated with the excessive labor costs (nearly $1,000).

Review the labor costs associated with the remaining 1,645 (1,668 - 23 reviewed) jobs that we did not review to determine whether the Block Grant funds it provided the corporation for labor exceeded the actual labor costs for each job. If the labor exceeded the actual labor cost for a job, the County should reimburse its Block Grant program from non-Federal funds for the excessive labor costs and the indirect costs associated with the excessive labor costs that the County provided to the corporation.

Implement adequate procedures and controls to ensure that it does not provide the corporation Block Grant funds for excessive labor costs.

Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that the cost of materials and services acquired for the program is reasonable.

Reimburse its Block Grant program from non-Federal funds for the $182 it provided to the corporation for a 4 percent surcharge that was inappropriately included on all materials.

Support or reimburse its Block Grant program from non-Federal funds for the $6,140 it provided to the corporation for indirect costs for which the corporation lacked sufficient documentation to support whether the indirect costs included lobbying-related expenses.

Support or reimburse its Block Grant program from non-Federal funds for the $1,541 it provided to the corporation for jobs for which the corporation lacked sufficient income documentation to support that the households were eligible for assistance.

Implement adequate procedures and controls to ensure that sufficient income documentation is maintained to ensure that households are eligible for assistance under the program and income is verified in accordance with HUD’s requirements and the subrecipient agreement.

Implement adequate procedures and controls to ensure that it properly documents compliance with HUD’s environmental review procedures before the start of each job.

Implement adequate procedures and controls to ensure that third emergency repairs are documented in writing and reported to the County before completion of assistance in accordance with the subrecipient agreement.

Support or reimburse its Block Grant program from non-Federal funds for the $4,953 it provided to the corporation for one job for which the corporation lacked sufficient documentation to support that a member of the household was physically disabled.

Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that accessibility modifications are provided only to households with at least one member who is physically disabled.

Reimburse its Block Grant program from non-Federal funds for the $4,127 it inappropriately provided to the corporation due to not ensuring that the corporation reduced all of its program income from its invoices for housing repair services.

Support or reimburse its Block Grant program from non-Federal funds for the $107 it provided to the corporation for the January 2016 invoice that the corporation generally could not explain.

Implement adequate procedures and controls to ensure that the corporation reduces program income from its invoices for housing repair services.

We audited the City of Hattiesburg’s HOME Investment Partnerships (HOME) program based on a referral from the U.S. Department of Housing and Urban Development (HUD), Office of Community Planning and Development’s field office in Jackson, MS, to address a request by the City’s mayor for a…

Oversight Area: Community Improvement

Require the City to support $441,202 ($370,729 $20,000 $50,473) or reimburse its program from non-Federal funds for commitments and expenditures not adequately supported.

Require the City to reimburse its program $33,258 from non-Federal funds for inappropriate costs incurred before the written agreements were executed.

Recapture and thereby put $32,019 to better use, which the City did not commit by its 24-month statutory commitment deadline in fiscal year 2015 funding for activity 1464.

Require the City to develop and implement HOME procedures, including training for the City’s employees, to ensure that (1) commitments are accurately entered into IDIS to maintain data integrity and (2) the HOME program is administered in accordance with HUD’s and its own requirements.

Verify that the remaining 14 (Footnote 5 - As detailed in the Scope and Methodology section of this report, we reviewed 23 of the 37 commitments entered into IDIS by the City.) commitments made during the period January 1, 2013, through December 31, 2017, were properly supported with written agreements and accurately entered into IDIS.

Require the City to follow its newly developed policy regarding the execution of a written agreement that is signed and dated by all parties before the commitment of any funds in IDIS.

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…

Oversight Area: Community Improvement

Require the four Community Compass providers reviewed to reimburse HUD $13,384 from non-Federal funds for ineligible costs from overcharged labor or travel costs.

Require 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.

Develop 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.

Develop 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.

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.

We audited the City of San Bernardino, CA’s HOME Investment Partnerships program. We audited the City based on the Region 9 Office of Inspector General’s 2016 risk analysis of Los Angeles area community planning and development grantees. In addition, although the County of San Bernardino had been…

Oversight Area: Community Improvement

Repay its program $22,402 for duplicative charges to HOME activity 2292 from non-Federal funds.

Update and implement changes to the City’s HOME and grants management policies and procedures to prevent similar errors and ensure that HOME draws are accurate and in accordance with HUD requirements.

We audited the Louisville-Jefferson County Metropolitan Government’s tenant-based rental assistance (TBRA) activity in its HOME Investment Partnerships and Continuum of Care (CoC) programs, based on a hotline complaint alleging inappropriate administration of TBRA. In addition, we selected…

Oversight Area: Community Improvement

Reimburse its HOME program $10,389 ($8,797 $1,592) from non-Federal funds for the overpayment of housing assistance due to inappropriate recertifications and calculations of housing assistance.

Reimburse the four HOME program participants $468 from program funds for the underpayment of housing assistance due to inappropriate calculations of housing assistance.

Reimburse its CoC program $112,827 ($109,259 $3,568) from non-Federal funds for the overpayment of housing assistance due to inappropriate recertifications and calculations of housing assistance.

Reimburse the three CoC program participants $260 from program funds for the underpayment of housing assistance due to inappropriate calculations of housing assistance.

Support or reimburse its CoC program $7,309 from non-Federal funds for the unsupported housing assistance payments.

Enforce its policy or implement an alternate method for the CoC program to ensure that annual recertifications are completed in a timely manner and that housing assistance is not issued before the recertification is completed to ensure that $385,660 in program funds is appropriately used for future payments.

Train its program staff on calculating housing assistance payments for the HOME and CoC programs to ensure that payments are appropriately calculated.

We audited the State of New York’s Community Development Block Grant Disaster Recovery-funded New York Rising Buyout and Acquisition program. We initiated this audit due to concerns related to whether properties purchased were substantially damaged. The objective of this audit was to determine…

Oversight Area: Disaster Relief

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to reimburse from non-Federal funds the $2,595,127 paid to purchase six properties that were not substantially damaged. Further, the State should identify and reimburse from non-Federal funds any additional Disaster Recovery funds used to acquire and dispose of the properties.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to reimburse from non-Federal funds the $783,571 paid to purchase two properties that did not comply with flood hazard requirements and for which the State did not have sufficient documentation to show that the properties were substantially damaged. Further, the State should identify and reimburse from non-Federal funds any additional Disaster Recovery funds used to acquire and dispose of the properties.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to provide documentation to support the hardship letter provided for a property located outside the 500-year floodplain and documentation to show that the property was substantially damaged or reimburse from non-Federal funds the $435,069 in settlement costs paid to purchase the property. Further, the State should identify and reimburse from non-Federal funds any additional Disaster Recovery funds used to acquire and dispose of the property.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to reimburse from non-Federal funds the $183,500 in incentives paid to a homeowner that failed to maintain flood insurance.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to provide documentation to show that the five properties for which the homeowners failed to maintain flood insurance were eligible for assistance and documentation to show that the properties were substantially damaged or reimburse from non-Federal funds the $1,336,883 paid to purchase the properties, including incentives for one property. Further, the State should identify and reimburse from non-Federal funds any additional Disaster Recovery funds used to acquire and dispose of the properties.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to provide documentation to show that the remaining nine properties were substantially damaged or reimburse from non-Federal funds the $4,158,836 paid to purchase the properties. Further, the State should identify and reimburse from non-Federal funds any additional Disaster Recovery funds used to acquire and dispose of the nine properties.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to conduct a review of the universe of properties purchased through the acquisition component of its program to ensure that properties were eligible and reimburse from non-Federal funds the Disaster Recovery funds used in connection with any additional properties found to be ineligible. For example, the State’s review could include verification that (1) its files contained the required substantial damage letters, (2) the letters provided by applicants reflected the most recent substantial damage determination made by local officials, (3) substantial damage determinations were adequately supported, (4) properties met flood hazard requirements, and (5) properties were not FEMA-noncompliant.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the State to provide documentation showing that the acquisition component of its program has ended or improve its controls over the program to ensure that properties purchased are eligible. This recommendation includes but is not limited to updating its policies and procedures and implementing verification processes to ensure that it verifies information provided by applicants and other entities.

We audited the North Carolina Department of Commerce’s Neighborhood Stabilization Program (NSP) grants as part of our annual audit plan because the Department received more than $57 million in NSP1 and NSP3 funding. Our audit objective was to determine whether the Department administered its NSP1…

Oversight Area: Community Improvement

Put $417,113 in unspent NSP1 funds associated with three activities to better use by reprogramming the funds to other subrecipients using an appropriate method or return the funds to HUD.

Support or reimburse its NSP1 grant $1,300,000 from non-Federal funds for the unsupported reallocation of grant funds.

Establish and implement a written policy and procedures to recapture and reallocate unused NSP funds in a timely manner.

Support or reimburse the appropriate NSP grant $1,186,105 from non-Federal funds for the unsupported subrecipient and administrative expenditures.

Update its records retention policy to meet HUD’s records retention requirements for supporting documentation for Federal program expenses, including salaries.

Update the NSP program income information in HUD’s grant tracking system and quarterly performance reports and reconcile with the Department’s records.

Establish and implement written procedures and provide adequate training to staff associated with administering the NSP grant to help ensure accurate reporting of program income.

Develop and implement a remediation plan for the six NSP activities to show that the national objectives have been met as required to support $11,916,072 in program funds drawn or reimburse its program from non-Federal funds.

Work with the Department so that it plans properly to ensure that the six activities identified in this report meet a national objective thereby avoiding extended project delays.

Review the Department’s remaining NSP grant expenditures before its drawdowns to ensure that the expenditures are eligible and adequately supported.

We audited the city of Dallas’ management of its community housing development organizations (CHDO). We performed this audit because of our previous audit work on the City’s Home Investment Partnerships program. During that audit, we concluded that the City did not follow HOME regulations and its…

Oversight Area: Community Improvement

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to repay $2,398,872 from non-Federal funds to the City’s HOME program for funds committed to projects before the completion of an environmental review or HUD approval.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to support or repay $424,325 from non-Federal funds to the City’s HOME program for funds committed without documentation of an environmental review.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to comply with HOME’s environmental requirements, including required restrictive contract language, and maintaining documentation of environmental reviews.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to support or repay $1,959,913 from non-Federal funds to the City’s Community Development Block Grant program for funds expended for Serenity Place Apartments because the City cannot locate any of the project files.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to support or repay $1,402,875 from non-Federal funds to the City’s HOME program for CHDO draws paid with no supporting documentation.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to support or repay $80,842 in program income from non-Federal funds to the City’s HOME program.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to repay $105 in ineligible costs from non-Federal funds to the City’s HOME program.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to strengthen and comply with its underwriting and project evaluation policies and procedures, including ensuring that when it signs and commits funds, project construction can begin within 12 months.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to develop and implement policies and procedures on documentation required to support draws.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to comply with requirements to obtain the required income documentation, including ensuring that employees know and apply the requirements.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to develop and implement policies and procedures to review source income documentation as required by the HOME regulations.

We recommend that the Director of the Fort Worth Office of Community Planning and Development require the City to develop and implement policies and procedures for documenting the results of its recertification procedures, including documenting the results of unpaid taxes, the resolution of CHDO audit findings, and the resolution of ineligible CHDO board members or employees because of a SAM search.

Open Recommendations by Oversight Area

Oversight Area

Status

Priority

The City of New York, NY, Did Not Always Use Disaster Recovery Funds Under Its Program for Eligible and Supported Costs

The State of Louisiana, Baton Rouge, LA, Did Not Always Maintain Adequate Documentation or Comply With Website Reporting Requirements

Hamilton County, OH, and People Working Cooperatively, Inc., Did Not Always Comply With HUD’s Requirements in the Use of Community Development Block Grant Funds for a Housing Repair Services Program

The City of Hattiesburg, MS, Did Not Always Administer Its HOME Investment Partnerships Program in Accordance With HUD’s and Its Own Requirements

HUD Did Not Have Adequate Oversight of Its Community Compass Technical Assistance and Capacity Building Program

The City of San Bernardino, CA, Did Not Fully Administer Its HOME Investment Partnerships Program in Accordance With HUD Requirements

Louisville Metro, Louisville, KY, Did Not Always Administer the TBRA Activity in Its HOME and CoC Programs in Accordance With Program Requirements

The State of New York Did Not Ensure That Properties Purchased Under the Acquisition Component of Its Program Were Eligible

The North Carolina Department of Commerce Did Not Administer Its Neighborhood Stabilization Program Grants as Required by HUD

The City of Dallas, Dallas, TX, Did Not Follow Environmental Requirements or Effectively Manage Its Community Housing Development Organizations

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