Recommendations

Open Recommendations by Oversight Area

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Priority Recommendations
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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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HUD Business Functions

130 Results

Clear

We conducted this engagement in coordination with the Pandemic Response Accountability Committee (PRAC) to gain an understanding of the U.S. Department of Housing and Urban Development’s (HUD) fraud risk management practices and develop an inventory of fraud risks that HUD had not already…

Oversight Area: HUD Business Functions

Coordinate with CPD program staff to clarify the (1) roles and responsibilities of the CRO, HCCRT, and CPD’s risk management staff with regard to identifying, assessing, and mitigating fraud risks and (2) purpose and role of HUD’s ERM processes and program office risk management processes with regard to identifying, assessing, and mitigating fraud risks.

Complete a program-specific fraud risk assessment and risk profile for the CDBG and ESG programs, with emphasis on CARES Act funding, and replicate this process to create program-specific fraud assessments and risk profiles for other CPD programs.

Consider OIG’s fraud risk inventory to improve CPD’s own fraud risk assessments and develop a program-specific fraud risk map and compendium.

Implement efforts to increase the awareness of fraud at all levels (headquarters, field offices, grantees, subrecipients, etc.), including but not limited to regularly publishing articles on known fraud schemes and identified instances of fraud in periodic newsletters or on CPD’s intranet website, providing recurring fraud risk trainings to HUD employees and grantees and working with OIG to develop materials to support fraud awareness.

Develop and implement a fraud risk checklist or other instrument as part of CPD’s monitoring oversight requirements, to be completed as part of each remote and onsite monitoring review.

Develop and implement a fraud analytics strategy using available data, including but not limited to data and information collected during the grantee risk assessment and monitoring processes, to begin conducting data analyses to identify potential fraud risks for further review.

We reviewed the U.S. Department of Housing and Urban Development’s (HUD) ability to effectively complete information technology (IT) acquisitions. HUD’s IT systems and its modernization plans depend heavily on contractors, yet HUD has historically faced significant challenges with implementing…

Oversight Area: HUD Business Functions

Conduct a departmentwide comprehensive staff capacity assessment to identify resource and skills gaps of staff involved in IT acquisitions.

Develop a departmentwide human capital plan or evaluate and revise existing plans to guide the recruitment, retention, and skill development of staff involved in IT acquisitions. The plan should include related metrics to measure plan implementation and effectiveness.

Evaluate IT acquisition process workflows and identify ways to simplify the processes, facilitate more effective stakeholder coordination across offices, and create efficiencies when possible.

Status

In November 2024, OCPO submitted an IT Acquisition Workflow Report and a document outlining responsibilities as evidence for closure. Although these documents clarified existing roles and documented one sample workflow, they did not propose or implement revised IT-acquisition policies or procedures producing measurable improvements. As of July 2025, OIG received no further information that identifies improvements in the IT acquisition process.

Analysis

To fully address this recommendation, HUD must provide evidence that it has published its standard operating procedures resulting from its evaluation of workflows and efforts to simplify processes and facilitate more effective coordination.

Implementation of this recommendation will result in defined IT acquisition process workflow procedures to increase efficiency and ensure coordination across program offices.

Establish a centralized acquisition tracking system that allows for input and monitoring by all offices involved with the IT acquisition process by: a. Developing a plan with detailed implementation milestones; b. Obtaining appropriate approvals and funding; and c. Implementing a centralized acquisition tracking system, based on the implementation plan and approvals from 4a and 4b.

Develop a plan for clearly defining, communicating, and enforcing IT acquisition process standards, including acquisition process roles and responsibilities.

We contracted with the independent public accounting firm of CliftonLarsonAllen LLP (CLA) to audit the financial statements of HUD as of and for the fiscal years ended September 30, 2021 and 2020,1 and to provide reports on HUD’s 1) internal control over financial reporting; and 2) compliance with…

Oversight Area: HUD Business Functions

As part of the validation process for CPD’s accrued liabilities, improve its validation process to ensure that it is based on verifiable grantees responses and supporting documentation.

We are recommending OCFO reopen the following recommendation reported in audit report 2021-FO-0003-0001-D: 1B. As part of the validation process for CPD’s accrued grant liabilities, review CPD’s accrued grant liabilities estimation methodology to ensure that it is based on verifiable grantee supporting documentation and all assumptions and variables used for the grant accrual estimate were properly established, supported, and documented.

Implement a policy to ensure the federal regulation responsibilities for outgoing HUD employees are reassigned to appropriate HUD personnel to enable HUD to continue to address those federal regulation requirements.

Establish controls to determine if single audits for HUD grantees are being completed and reported in a timely manner in accordance with 2 CFR §200.512.

Provide a means for which HUD grantees and their auditors can request technical advice and counsel.

Establish controls to determine if follow-up is being conducted to determine if the grant recipients have taken appropriate and timely corrective action. That follow-up must include the following: a. Issuing a management decision letter as prescribed in 2 CFR §200.521; b. Monitoring recipients to ensure they are taking appropriate and timely corrective action; c.Using cooperative audit resolution mechanisms (see 2 CFR §200.25) to improve federal program outcomes through better audit resolution, follow-up, and corrective action; and d. Developing a baseline, metrics, and targets to track, over time, the effectiveness of HUD’s process to follow-up on audit findings and on the effectiveness of single audits in improving recipient accountability and their use by HUD in making award decisions.

Establish controls to ensure that HUD provides Office of Management Budget (OMB) annual updates to the compliance supplement6 and works with OMB to ensure that the supplement focuses the auditor to test compliance requirements most likely to cause improper payments, fraud, waste, abuse or generate audit findings for which HUD will take sanctions.

Establish a control to hold HUD’s Single Audit Accountable Official responsible for improving the effectiveness of the single audit process based on single audit metrics that HUD will establish in response to recommendation 4D above.

We contracted with the independent public accounting firm of CliftonLarsonAllen LLP (CLA) to audit the financial statements of FHA as of and for the fiscal years ended September 30, 2021 and 2020, and to provide reports on FHA’s 1) internal control over financial reporting; and 2) compliance with…

Oversight Area: HUD Business Functions

Request an opinion from HUD’s Office of the Chief Financial Officer’s Appropriation Law Division on whether the abnormal balance in account 4901 constitutes a violation of the Antideficiency Act.

Enhance standard operating procedures around system and account reconciliations to ensure that they cover all possible scenarios and are easy to follow.

Appropriately train and monitor new personnel to ensure that they understand and execute the procedures and controls.

Update procedures to clearly define error thresholds that require follow-up and the communication process for elevating errors to supervisors, managers, and senior leadership.

Establish clear lines of communication within and between divisions to ensure that all personnel become aware of issues that may impact their duties and responsibilities.

Strengthen controls over the preparation of HECM-related reconciliations, reviews, and oversight by ensuring that (1) program personnel preparing such reconciliations understand how such reconciliations impact financial accounting and reporting and (2) financial personnel sufficiently understand programs and systems to determine their general ledger impact.

Enhance the quarterly variance analysis to identify the business reasons for changes in account balances and pay specific attention to abnormal balances and activity.

Strengthen the financial statement review controls by completing a compliance matrix to ensure all balances that are presented and disclosed reflect the most up-to-date financial accounting and reporting guidance.

Perform a comprehensive analysis for all cohort years and assess the impact that the use of the scheduled UPB instead of the current UPB has on the LGL. If significant based on a quantitative threshold, update the SF cash flow model to incorporate the current UPB data.

Develop and implement a new process to require the annual validation of the fourth quarter endorsement volume estimation method for the SF Forward model. The process should include a management review and approval control component. The process should be documented and should demonstrate that management’s estimate is based on the analysis of past experiences, current policy, and market considerations, and, if necessary, incorporate improvement recommendations.

Perform a comprehensive review of the SF and HECM model documentation and update the specific sections with the current practices and procedures required to execute the model activities.

Establish a process that requires the timely review and update of model documentation. The process should include tracking the dates and nature of the revisions.

Provide training and periodic reminders to field staff and management to ensure that the data fields in DAP and on the final Form HUD-290 are accurate and consistent.

Develop and implement written procedures that provide guidance or best practices that should be followed to address data anomalies. At a minimum, these written procedures should include the following: (1) a process for identifying key data attributes that significantly impact the results, (2) the determination of preset thresholds for analyst and management attention, (3) the treatment of data anomalies, such as null values or values that exceed preset thresholds, (4) a process for providing feedback to the upstream data provider(s) for corrective and preventive actions when data integrity issues are detected and management concludes the issue is significant, and (5) a process for preparing documentation to support management decisions.

The Federal Information Security Modernization Act of 2014 (FISMA) directs Inspectors General to conduct an annual evaluation of the agency information security program. FISMA, Department of Homeland Security (DHS), Office of Management and Budget (OMB) and National Institute of Standards and…

Oversight Area: HUD Business Functions

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.

Define and communicate policies and procedures to ensure that its products, system components, systems, and services comply with its cybersecurity and supply chain risk management (SCRM) requirements. This recommendation includes (a) identification and prioritization of externally provided systems (new and legacy), components, and services; (b) how HUD maintains awareness of its upstream suppliers; (c) the integration of acquisition processes, tools, and techniques to use the acquisition process to protect the supply chain; and (d) contract tools or procurement methods to confirm that contractors are meeting their obligations.

Corrective Action

HUD finalized its Supply Chain Risk Management (SCRM) policy in April 2025, which utilizes a SCRM questionnaire to assess each vendor’s supply chain risk, and identifies and prioritizes risks accordingly. HUD’s SCRM program team manages a supply chain risk register which records prior and current vendors, and those that have undergone risk assessments to maintain visibility into its upstream suppliers and track changes over time. HUD also used multiple tools such as supply chain risk criteria and sourcing research and market analysis to evaluate vendors and strengthen protection of the supply chain during acquisition. By implementing these procedures, as well as, having HUD’s program management team conducting annual and quarterly performance reviews for all vendors, HUD ensures contractors are meeting their contractual obligations.

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.

We audited the U.S. Department of Housing and Urban Development’s (HUD) transitioning of offices from mandatory to maximum telework during the coronavirus disease 2019 (COVID-19) pandemic, based on a request from Representative Gerald Connolly, to review whether HUD was employing best practices and…

Oversight Area: HUD Business Functions

Ensure that future policies and guidance developed to return HUD’s offices to normal operations include the specific criteria, metrics, and defined geographic area to be used by all offices as applicable.

Develop and implement sufficient policies and controls to ensure that (1) applicable criteria in any future guidance are met and all safety measures are sufficiently completed before returning HUD’s offices to normal operations and (2) sufficient documentation is maintained to support that the applicable criteria were met.

We audited the U.S. Department of Housing and Urban Development’s (HUD) grant closeout processes and compliance with the Grants Oversight and New Efficiency (GONE) Act. The GONE Act required that we conduct a risk assessment to determine whether an audit of HUD’s grant closeout process was…

Oversight Area: HUD Business Functions

Develop and implement controls for use of the bulk grant closeout process going forward to ensure that grants are closed in accordance with all applicable requirements, including that administrative actions and required work under the grant award have been completed by the grantee before the grant is closed out. These controls should include but not be limited to increased collaboration and communication between headquarters and field offices.

Develop and implement controls to ensure that future grant data reporting to stakeholders is consistent and accurate, including defining how records should be counted and data should be presented and ensuring that accurate POP dates are maintained in HUD’s systems.

In an effort to increase transparency and accountability in the use of Federal funding in program activities, Federal law and guidance requires the U.S. Department of Housing and Urban Development (HUD) and its prime recipients to ensure that complete and accurate subaward data is posted on…

Oversight Area: HUD Business Functions

Work with the prime award recipients that had subaward reporting deficiencies to ensure that their subaward information is reported or reported accurately.

Update and expand the guidance on FFATA subaward reporting requirements provided to prime award recipients by (1) updating program website(s) with comprehensive information about FFATA, (2) implementing training, (3) issuing formal communication, and (4) implementing a feedback mechanism to ensure that all prime award recipients have the opportunity to share challenges with HUD and ask questions.

Integrate FFATA reporting requirements into program monitoring procedures for all programs and conduct regular reviews to assess compliance.

Ensure that programs with subaward activity include specific clauses related to FFATA compliance in their grant agreements, and notices of funding opportunities.

Work with the prime award recipients that had subaward reporting deficiencies to ensure that their subaward information is reported or reported accurately.

Update and expand the guidance provided to prime award recipients by (1) updating program website(s) with comprehensive information about FFATA, (2) implementing training, (3) issuing formal communication, and (4) implementing a feedback mechanism to ensure that all prime award recipients have the opportunity to share challenges with HUD and ask questions.

Integrate FFATA reporting requirements into the program monitoring procedures for all programs and conduct regular reviews to assess compliance.

Develop a policy or update the existing Grants Management Policy to include 1) the process and controls that HUD will use to hold the prime recipients accountable for FFATA compliance and 2) clearly defined roles and responsibilities between OCFO and the program offices to ensure that action is prioritized by the correct responsible parties regarding FFATA compliance.

Work with applicable program offices to develop training materials and tools, such as dashboards, to assist program offices in monitoring their grant portfolios for subaward reporting compliance.

To determine whether all the unexpended obligations of HUD are valid and meet funding guidelines, the Office of the Chief Financial Officer (OCFO) coordinates annually an Open Obligation Review (OOR) of all program and administrative funds. This review determines which funds are still needed and…

Oversight Area: HUD Business Functions

Deobligate the 835 administrative obligations totaling $38,525,836.88 identified for deobligation during the fiscal year 2024 OOR that had not been deobligated as of February 28, 2025.

Deobligate the 101 program obligations totaling $1,967,991.45 identified for deobligation during the fiscal year 2024 OOR that had not been deobligated as of February 28, 2025.

HUD did not comply with PIIA because it did not report compliant improper and unknown payment estimates for the Office of Public and Indian Housing’s Tenant-Based Rental Assistance (PIH-TBRA) program and the Office of Multifamily Housing Programs’ Project-Based Rental Assistance (MF-PBRA) program. …

Oversight Area: HUD Business Functions

Update HUD Handbook 1900.40, Do Not Pay policy, to clearly define the responsibilities for all parties and align it with current laws, processes, and procedures. This should include defining responsibilities for preaward and prepayment verification, and developing a process and governance structure to ensure that preaward and prepayment verification are consistently performed across HUD’s programs.

Status

HUD has until August 25, 2025, to provide its corrective action plan to OIG for review.

Analysis

Updating the HUD Handbook 1900.40 will define responsible parties for ensuring compliance with the Do Not Pay Initiative (DNP).

The implementation of this recommendation will result in consistent use of DNP, allowing for instant verification of eligibility across the billions in payments that HUD processes, resulting in the reduction of future improper payments.

Develop a standard operating procedure to ensure that the OCFO is 1) monitoring the DNP Computer Matching agreement to ensure continuity, 2) reporting accurately on its DNP matching, and 3) working with program offices to adjudicate any payments that are identified as potentially improper during the computer matching process.

Work with Multifamily Housing to investigate the 11 of 24 entities with expired SAM.gov registrations to determine if those entities should have received payments totaling $212,208,450 and perform the required follow-up actions once a determination is made.

Open Recommendations by Oversight Area

Oversight Area

Status

Priority

Fraud Risk Inventory for the CDBG and ESG CARES Act Funds

HUD’s Processes for Managing IT Acquisitions

Audit of HUD’s Fiscal Years 2021 and 2020 Consolidated Financial Statements

Audit of FHA’s Fiscal Years 2021 and 2020 Consolidated Financial Statements

Fiscal Year 2021 Federal Information Security Modernization Act (FISMA) Evaluation Report

HUD Did Not Always Comply With Its Internal Guide When Transitioning Offices From Mandatory to Maximum Telework During the COVID-19 Pandemic

HUD Did Not Implement Adequate Grant Closeout and Reporting Processes To Ensure Consistent Application of GONE Act Requirements

HUD’s Subaward Data on USASpending.gov Were Not Complete nor Accurate

HUD Open Obligations Review Results

HUD Did Not Comply With the Payment Integrity Information Act of 2019

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