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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

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We audited information system controls over the U.S. Department of Housing and Urban Development’s (HUD) computing environment. This review was conducted as part of our audit of HUD’s financial statements for fiscal year 2018 under the Chief Financial Officers Act of 1990. Our objective was to…

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.

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General audited HUD to ensure that public housing agencies (PHA) have access to information in the Federal Do Not Pay system. We performed this audit because the Housing Opportunity Through Modernization Act of 2016…

Oversight Area: HUD Business Functions

Issue guidance to PHAs to ensure any applicant for or tenant of public or assisted housing whose name appears on the SAM excluded parties list are reviewed by PHAs to determine eligibility in a manner consistent with the regulations in 2 CFR 180 and 2424 so that ineligible applicants or tenants are not admitted or recertified to put up to $13.7 million to better use.

Take corrective actions for the 729 tenants reported as deceased to put $6.1 million to better use.

Establish a method to provide information in the Do Not Pay system to PHAs and require its use.

In accordance with the statutory requirements of the Digital Accountability and Transparency Act of 2014 (DATA Act) and standards established by the Office of Management and Budget (OMB) and the U.S. Department of the Treasury, we audited the U.S. Department of Housing and Urban Development (HUD),…

Oversight Area: HUD Business Functions

Implement adequate procedures and controls to ensure that all required data are complete, accurate, and reported in a timely manner. These procedures and controls should include but not be limited to ensuring that all transactions are recorded and reported within the proper period and listing the source of each of the data elements, including how to obtain the source documentation from HUD’s various program offices or systems.

Implement adequate procedures and controls to ensure that all data elements are traceable to the source documentation.

Revise internal DATA Act policy and procedure documents to resolve inconsistencies to ensure full, appropriate, and consistent implementation of the DATA Act.

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General audited HUD’s compliance with the purchase card program requirements for fiscal years 2017 and 2018 based on our risk assessment. Our audit objective was to determine whether HUD maintained accurate records of…

Oversight Area: HUD Business Functions

Implement a process to periodically audit or reconcile ARC’s records.

Implement a process to periodically review approving officials’ span of control to ensure that the requirement is not exceeded.

Implement a process with ARC to ensure that cardholders and approving officials are notified before purchase card training is due to allow training to be completed in a timely manner.

Implement a process to ensure that purchase cards are suspended when a cardholder or approving official fails to complete training.

Research why ARC provided incomplete monthly transactional data and identify a solution to ensure the completeness of future transmissions.

Enhance the process to periodically analyze data for split transactions or improper MCCs and follow up on any potential issues identified.

Require ARC to update its MCC tracking log, to include the amount, the date of MCC override removal, and staff assigned, to ensure that an override is removed after the approved purchase is made.

Implement a process with Citibank and ARC to provide global notifications to cardholders and approving officials before autoclosures of credit card statements.

Implement a process to suspend cardholders or approving officials who repeatedly cause HUD to pay interest.

Obtain supporting documentation for the $1,807 spent on two cardholders’ purchase cards or require the vendors or cardholders to repay the funds to the applicable HUD program.

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General audited HUD’s compliance with the travel card program requirements for fiscal year 2018 based on our risk assessment.Our audit objective was to determine whether HUD travel cards were used for potentially…

Oversight Area: HUD Business Functions

Suspend the travel cards for 35 employees who made 166 improper, illegal, or erroneous purchases, if warranted based on the nature of misuse, and coordinate with the related program offices, the Office of the Chief Human Capital Officer, and the Office of Employee Labor Relations to take appropriate disciplinary actions against these employees and their supervisors who did not follow up on the monitoring reports.

Ensure that ARC has properly updated the monitoring report criteria to include transaction categories that were previously missing from the monitoring reports.

Coordinate with the Office of Employee Labor Relations and the Office of the Chief Human Capital Officer to update HUD’s travel card policy with the table of penalties and disciplinary actions for travel card misuse and provide the updated policy and tiered instructions for disciplinary actions to administrative officers and approving officials.

Require program offices to report all disciplinary actions taken against employees who made improper purchases.

Generate a periodic report of travel cards for employees who do not travel and cancel the travel cards if not needed.

Inform all travel cardholders and approving officials about specific travel program requirements and repercussions for disregarding these requirements.

Verify with ARC on a regular basis that all travel cardholders have completed their training as required.

Require justification and approval for selecting a nonrefundable rate in the travel system comments section.

Generate a periodic monitoring report that would identify employees who did not use their government travel card when required and send this report to employees’ supervisors and the Assistant Secretary of related program offices for proper action.

Require justification and approval in the travel system comments section when requesting lodging expense reimbursement to the traveler’s bank account.

Update HUD’s travel card policy to require approving officials’ review of travel documents for appropriate methods of payment and work with the Office of Employee Labor Relations and the Office of the Chief Human Capital Officer to prescribe disciplinary actions for not using the government travel card when required.

Inform all HUD travel cardholders and approving officials about the mandatory use of the government travel card and disciplinary actions for not using it.

Follow up with the 19 employees identified as failing to use their government travel card and coordinate with the related program offices to ensure these employees receive training, counseling or other appropriate disciplinary action, if necessary, on the mandatory use of the government travel card.

We are required to audit the consolidated financial statements of the U.S. Department of Housing and Urban Development (HUD) annually in accordance with the Chief Financial Officers Act of 1990 as amended. Our objectives were to express an opinion on the fair presentation of HUD’s consolidated…

Oversight Area: HUD Business Functions

Ensure that all of the sampled amounts used for extrapolation in OCFO grant accrual validation estimates are properly supported with documentation that substantiates the amounts certified in the surveys.

Implement a refined accrual validation methodology, to include more comprehensive review procedures to substantiate the amounts certified by the grantee.

Review CPD’s grant accrual estimation methodology to ensure that all assumptions and variables used are properly supported and verifiable with the validation procedure.

After PIH prepayment validations are completed, apply all corrections to CAM 1 codes and Voucher Management System (VMS) expenses to all of the data supporting the fiscal year 2019 beginning balance, and recalculate the fiscal year 2019 PIH prepayment estimate. Based on the recalculation, determine whether restatement is needed to the correct errors in the fiscal year 2019 estimate calculation to ensure consistency between comparative statements.

Revise its review of the PIH prepayment estimate calculations performed by contractors to ensure that the contractors are following the established methodology and any changes to the methodology are applied to the data supporting the beginning balance, if appropriate.

Review all duties currently assigned to action officials to determine which duties can be centralized within OCFO or its Federal shared service provider. For any duties that cannot be centralized, (1) provide an explanation as to why they cannot be centralized and (2) assign these duties to appropriate positions within the program offices. Further, update the Debt Collection Handbook to include any changes made as a result of the review.

Implement monitoring and control activities to ensure that all debt collection action officials perform their duties in accordance with the Debt Collection Handbook

In coordination with each program office, identify the possible debts that could arise from normal business and monitoring activities and create a listing of these scenarios. Based on this listing, implement control activities to ensure that all debts that result from these activities are considered in financial reporting, U.S. Department of the Treasury reporting, and debt collection activities.

Develop and implement a procedure that requires OCFO to identify and research all debts that are more than 120 days old to ensure (1) validity, (2) that proper debt collection efforts occur, and (3) that the status reported in the TROR is correct according to Treasury’s TROR requirements.

Review the 76 sustained audit receivables not under repayment agreement totaling $59.6 million to determine validity and ensure that debt collection procedures are followed if applicable, to include (1) issuing demand letters, (2) creating repayment agreements if appropriate, and (3) referring delinquent debt or initiating writeoffs as appropriate. For all receivables determined to be valid, ensure that they are accurately reported to Treasury in the quarterly TROR. For all receivables determined to be invalid, remove the receivables from HUD’s accounts receivable balance.

Develop and implement standard operating procedures for calculating and reporting HUD’s quarterly allowance for loss based on periodic evaluation of each type of HUD’s accounts receivables in accordance with GAAP. The procedures should also include steps to ensure proper note disclosure for significant classes of accounts receivables.

Reassess HUD’s SFFAS 50 implementation by correcting HUD’s IUS PP&E opening balance instead of the yearend balances and recognize capitalized IUS development, maintenance, and enhancement costs incurred during fiscal year 2019. If not reassessed, provide auditable documentation supporting the application of the methodology used supporting HUD’s assertion that the IUS zero balance valuation complies with SFFAS 50 and FASAB Technical Release 18 implementation guidance.

Reevaluate capitalization and useful life thresholds included in HUD’s PP&E policy to ensure that they are comparable based on HUD’s funding level and size of operations and in accordance with capitalization thresholds and useful life requirements for leasehold improvements according to SFFAS 6 PP&E.

Recognize unrecorded assets and liabilities related to leasehold improvements and make proper disclosures regarding HUD’s leasehold improvement liability in the financial statements and notes.

Collaborate with OCFO to review methodologies used to produce grant accrual estimates, to include testing and verification of the resulting accrual estimates.

Implement a procedure to periodically, not less than annually, review HUD’s funds from dedicated collections to ensure that those funds fulfill the criteria established by FASAB. Additionally, update HUD’s financial reporting standard operating procedures with this new periodic review.

Collaborate with Treasury to correct the reporting type code for the funds associated with RAD to ensure that the reporting type code within HUD’s GTAS file reflects the correct reporting type.

Update all financial statement note checklists to include a review for completeness with the accounting standards and OMB Circular A-136.

Implement information security controls over the Section 108 loan guarantee database that prevent and detect unauthorized changes to program data (or implement an updated Section 108 loan guarantee database with information security controls that prevent and detect unauthorized changes to program data).

Develop a formal enterprise risk management policy for program offices’ risk owners, including guidance for completing the annual risk profile refresh, requirements for completing risk mitigation strategies, and reporting risk mitigation progress to the Risk Management Council

Execute system code requests, including new program-level class and code, CAM 1 codes, in accordance with internal OCFO system standard operating procedures. Specifically, the CFO system code coordinator should verify that OCFO budget officers and program budget officers provide adequate documentation showing that the new CAM1 code is covered by an approved funds control matrix or sufficient justification for not requiring a funds control matrix.

Develop and implement policy and procedures for the incremental obligation process used for project-based Section 8 funds, including documentation for determining the incremental amounts and controls to review the amounts for accuracy.

Assign independent, contract officers to review and certify the initiating contract buyer’s compliance with policies for initiating and authorizing interagency agreements and later modifications for all amounts in accordance with Acquisition Instruction 13-07, HUD Contracting Officers.

Ensure that contracting officers and OCPO field offices review and follow the records management policies and procedures, including completing and signing Forms 7600A and 7600B, to ensure consistency among contract officers approving interagency agreements in the procurement system of record.

This report presents the results of our audit of Ginnie Mae’s fiscal year 2019 financial statements, including our report on Ginnie Mae’s internal control and test of compliance with selected provisions of laws, regulations, and contracts applicable to Ginnie Mae. In fiscal year 2019, we were…

Oversight Area: HUD Business Functions

Test whether a cumulative housing price appreciation (HPA) variable should be added to the probability of prepayment, probability of default, foreclosure timeline, buyout time models, and cure rate assumptions. Ginnie Mae should provide an analysis if it believes that adding an HPA variable would not be appropriate to support its position.

Develop and implement policies and procedures to require a sufficiently granular decomposition analysis that can adequately explain the impact of all the model changes made.

Develop and implement policies and procedures or enhance or clarify, as appropriate, existing policies and procedures that will require additional analyses whenever thresholds are breached or other analyses indicate potential modeling issues.

Document the economic rationale behind unintuitive model coefficients to support that the unintuitive relationships are appropriate.

Document all model assumptions that are undocumented, providing the basis for any assumptions or decisions made when developing each model assumption.

Develop and implement policies and procedures to ensure compliance with model risk management guidance regarding adequate and well-documented model assumptions.

Develop and implement controls that ensure the updating of model documentation when model changes are made.

Improve model documentation by addressing the model documentation deficiencies cited in this report and narrowing or consolidating them into fewer pieces of documentation, as appropriate.

Formalize and define coding best practices within Ginnie Mae’s model governance framework.

Apply coding best practices during model development processes and add a control for reviewing model code for compliance with best practices.

Ensure that documentation is maintained to support reimbursable cost receivables recorded on Ginnie Mae’s financial statements or write off the reimbursable costs receivables that are not valid or cannot be supported.

Establish audit trails to ensure that supporting documentation can be easily traced and verified to the recorded transactions in the general ledger.

Establish and implement remedial action plans to document the implementation testing of the effectiveness of its internal control over financial reporting in accordance with OMB Circular A-123, appendix A.

Update its internal controls descriptions to reflect controls in place and implement monitoring activities to ensure that it carries out the controls and documents their performance and results.

Resolve the issues identified with the mastersubservicers to improve the data quality and timing of the raw data received for SLDB monthly processing and minimize manual adjustments.

Modify the standing operating procedures for the SLDB data quality checks that address mastersubservicer data deficiencies, data quality rules, and severity levels, to include periodic assessments of the appropriateness of the severity levels.

Review VAPE data validation procedures to improve preventive controls to determine the reasonableness of the inbound VAPE data before SLDB processing.

Implement the planned SLDB code fixes and enhancements to reduce future manual adjustments.

We evaluated the U.S. Department of Housing and Urban Development (HUD) practices for identifying and protecting personally identifiable information (PII). The evaluation assessed HUD’s current capabilities to properly manage and protect PII and to properly maintain paper and electronic PII…

Oversight Area: HUD Business Functions

Designate a Senior Agency Official for Records Management at the Assistant Secretary level or its equivalent.

Update and issue agency formal records policy, including detailed procedures and requirements for completing and maintaining program office and agencywide inventories of systems, records, and PII.

Update and obtain final NARA approval of all HUD records retention schedules, including the Capstone email schedule, to comply with Federal requirements, including OMB M-19-21.

Develop and approve an enterprise strategy to meet all M-19-21 electronic transition requirements.

Issue a formal policy and requirements for managing CUI.

Establish and disseminate a policy on safeguarding or prohibiting the transportation of PII records out of the office for telework purposes.

Complete the development of performance measures and establish a formal records evaluation process to measure the effectiveness and progress of the records management program.

Standardize processes and duties for all RMLOs.

Conduct a staffing resource assessment for the HUD records program and identify any skills gaps or resource needs.

In accordance with the Chief Financial Officers Act of 1990, as amended, we are required to annually audit the consolidated financial statements of the U.S. Department of Housing and Urban Development (HUD). Our objective was to express an opinion on the fair presentation of HUD’s consolidated…

Oversight Area: HUD Business Functions

Prepare a white paper regarding the accounting treatment for each type of funding disbursed under the HCVP, to include a comparison of the qualities the funding embodies against the qualities that are necessary for it to be considered a prepayment versus an expense according to generally accepted accounting principles. The Chief Financial Officer should work with PIH to gather the information necessary to complete this analysis and have PIH review it to ensure the accuracy of the program information used.

Develop and implement a policy that requires OCFO to review all new program notices, new regulations, and new types of funding and evaluate each against the accounting standards and current accounting treatment (as documented in white papers or other forms) to determine whether OCFO’s treatment complies with generally accepted accounting principles and if not, propose changes. The policy should include formal designation of roles and responsibilities as well as internal controls to ensure proper review and approval of conclusions.

Once additional data are available, and at least quarterly, reduce the CARES Act PIH prepayment by the amount actually spent by PHAs or an estimated amount with a low level of estimation uncertainty.

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.

Research the survey responses that resulted in a positive cash on hand balance to determine whether a cash advance exists. If so, the Chief Financial Officer should coordinate with CPD to (1) determine whether the grantees have proper documentation and approvals allowing for cash advances and (2) develop and implement procedures to estimate and account for cash advances for financial reporting purposes.

Investigate other methods for validating CPD’s accrued grant liabilities estimate, including the use of other sampling units, which could provide additional relevant information that can be used to produce more reasonable results and reduce estimation uncertainty to a low level.

Work with the Director of the Office of Multifamily Asset Management and Portfolio Oversight to ensure that all debt owed to HUD is identified, accurately reported in HUD’s financial records, and properly monitored to ensure compliance with applicable laws and regulations.

Reevaluate and adequately document justification for the establishment of the percentages and other key assumptions used to determine the accrual amount for each program in CPD’s accrued grant liabilities estimate.

Implement the requirements of HUD’s current Debt Collection Handbook, to include (1) assigning a program office manager, (2) developing and implementing debt collection standard operating procedures, (3) designating program action officials, and (4) ensuring that program action officials are trained and perform debt collection duties in a timely manner in accordance with the Debt Collection Handbook; HUD Handbook 2000.06, REV-4, Audits Management System; and other pertinent guidance and policies to ensure the accurate reporting of receivables in the general ledger.

Review all executed repayment agreements in HUD’s Tenant Rental Assistance Certification System (TRACS) to determine which repayment agreements have not been fully repaid and represent an amount owed to HUD and work with OCFO to record these receivables.

Include a field in TRACS to identify which repayment agreements represent an amount owed to HUD and implement controls to ensure the accuracy of the listing in TRACS.

Develop and implement controls to track and enforce repayments owed to HUD to ensure that owners are not delinquent on their repayment agreements.

Ensure that OCFO has the data it needs to record a reasonable PIH prepayment estimate related to supplemental pandemic funding in fiscal year 2021 and beyond if additional funding is provided.

We audited rent credits that the U.S. Department of Housing and Urban Development (HUD) received from the U.S. General Services Administration (GSA) during fiscal years 2015 through 2018 in exchange for financial contributions for building improvements. We initiated this audit due to concerns we…

Oversight Area: HUD Business Functions

We recommend that HUD’s Chief Financial Officer investigate the facts surrounding the potential Antideficiency Act violation involving the $7,787,675 in rent credits and make a formal determination. If it is determined that a violation occurred, the Chief Financial Officer should develop corrective action plans or internal process improvements as necessary, take disciplinary actions as appropriate, and report the identified violations to the oversight authorities including the HUD Secretary, the President, OMB, Congress and the Comptroller General.

We recommend that HUD’s Chief Administrative Officer implement the corrective actions and internal process improvements in internal control developed as a result of the Chief Financial Officer’s investigation addressed in recommendation 1A.

We recommend that HUD’s Chief Administrative Officer provide training to responsible staff and officials to ensure that those that may be involved with negotiating any GSA rent credits, like the credits addressed in this report, identify such potential rent credit transactions and follow the corrective actions and process improvements implemented to resolve recommendation 1B.

Open Recommendations by Oversight Area

Oversight Area

Status

Priority

Fiscal Year 2018 Review of Information Systems Controls in Support of the Financial Statements Audit

HUD Paid Rental Subsidies To Benefit Public Housing and Voucher Tenants Reported as Excluded From Federal Programs or Deceased

HUD’s Office of the Chief Financial Officer Generally Complied With the Digital Accountability and Transparency Act of 2014 With a Few Exceptions

HUD’s Purchase Card Program Had Inaccurate Records, Untimely Training, and Improper Purchases

HUD’s Travel Cards Were Used for Illegal, Improper, or Erroneous Purchases and Were Not Always Used When Required

Additional Details To Supplement Our Fiscal Year 2019 U.S. Department of Housing and Urban Development Financial Statements Audit

Audit of the Government National Mortgage Association’s Financial Statements for Fiscal Year 2019

HUD Personally Identifiable Information (PII) Records Protection and Management

Audit of HUD’s Fiscal Year 2020 Consolidated Financial Statements

Reimbursements Received Through Rent Credits From the General Services Administration

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