Recommendations

Transparency to stakeholders is a key priority within HUD OIG. The Recommendation Dashboard provides stakeholders and the public with data on open and closed recommendations for HUD programs and funding recipients. Through the dashboard, users can identify the total number of open recommendations, review the costs associated with specific recommendations, and visualize key data elements through graphs and charts. For additional information visit recommendations FAQs.

Open Recommendations by Oversight Area

Housing Assistance

Community Development

Disaster Recovery

Financial Risk and Accountability

Technology and Cybersecurity

Health and Safety

HUD's Operations

Priority Recommendations
Open 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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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…

Audit #: 2022-FO-0004 Oversight Area: HUD Business Functions Date Published: December 9, 2021

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…

Audit #: 2022-FO-0003 Oversight Area: HUD Business Functions Date Published: December 9, 2021

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 U.S. Department of Housing and Urban Development (HUD), Office of Inspector General (OIG), completed a corrective action verification (CAV) of recommendations from four prior home equity conversion mortgage (HECM) audit reports. The CAV was initiated because protecting the Federal Housing…

Audit #: 2022-PH-0801 Oversight Area: Homeownership Date Published: December 10, 2021

We recommend that the Office of Single Family Housing coordinate its efforts with the Office of Public and Indian Housing and the Office of Multifamily Housing Programs to further ensure that appropriate controls are in place to prevent HECM borrowers from violating principal residency requirements.

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General (OIG), completed an audit to determine whether FHA-insured borrowers properly received the COVID-19-related forbearance. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), signed into law on…

Audit #: 2022-KC-0001 Oversight Area: Homeownership Date Published: December 15, 2021

Perform data analysis of FHA’s portfolio to identify borrowers who are delinquent and did not fully benefit from the COVID-19 forbearance, including those in bankruptcy;

Develop a standardized brochure or informational pamphlet that would inform delinquent borrowers of their right to a forbearance under the CARES Act; and

Ensure that this information is distributed to delinquent borrowers so it can benefit the greatest number of borrowers to put $5.43 billion to better use by avoiding potential future losses on 112,160 loans.

Review the 21 loans with improperly administered forbearance to ensure that the borrowers were remedied by the servicers, if possible, and ensure that these servicers updated their forbearance procedures to prevent future noncompliance.

Ensure that the issues found during our audit are incorporated into QAD’s servicing monitoring reviews.

Provide additional guidance to the servicers so they will limit their communication and collection efforts for the borrowers in forbearance.

We audited the City of Houston’s Hurricane Harvey Community Development Block Grant Disaster Recovery (CDBG-DR) program. We initiated this audit as part of our commitment to helping the U.S. Department of Housing and Urban Development (HUD) address its top management challenges and to support…

Audit #: 2022-FW-1001 Oversight Area: Disaster Relief Date Published: January 4, 2022

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to include milestones and appropriate consequences for not meeting those milestones in future subrecipient agreements to ensure that expenditure deadlines remain on track. Implementing this recommendation could assist the Texas GLO in avoiding possible future litigation based on the lack of required benchmarks in its contracts.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to ensure that processes are in place to assist those participants transitioning from the City’s programs to the Texas GLO’s programs.

With HUD’s approval of action plan amendment 8, we recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to continuously monitor the City’s pace and performance in its remaining Hurricane Harvey CDBG-DR program and take appropriate action to ensure that program goals are met. The plan should include a process for repurposing additional grant funds, if necessary, to avoid potential recapture due to the City’s inability to meet the expenditure deadline established under its subrecipient agreement with the Texas GLO and to allow the Texas GLO to meet the expenditure deadline for its grant award.

With HUD’s approval of action plan amendment 8, we recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to set performance and financial milestones, including approval of the City’s projects and obligation and expenditure of funds, for all programs and activities funded under the City’s subrecipient agreement through the remainder of the contract and deadlines for the City to achieve those milestones. This requirement would include the Texas GLO’s (1) providing its plan to continually assess whether the City is meeting the established milestones within the prescribed period; (2) taking appropriate action as outlined in the subrecipient agreement for any missed deadlines; and (3) if necessary, determining whether programs need to be combined or eliminated from the subrecipient agreement.

With HUD’s approval of action plan amendment 8, we recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to ensure that the City will comply with the Texas GLO’s program guidelines and required onsite technical assistance and supportive services. This plan would include (1) precise instructions and deadlines for submitting or resubmitting program and implementation guidelines, (2) terms for settling technical assistance and supportive services disagreements, and (3) appropriate consequences for noncompliance with the requirements the Texas GLO imposes.

We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of Federal Housing Administration (FHA) refunds based on a hotline complaint alleging that HUD was trying to make it difficult for claimants to obtain refunds or discourage them from pursuing the refunds, which are…

Audit #: 2022-LA-0001 Oversight Area: Homeownership Date Published: January 7, 2022

Develop and implement written policies and procedures and controls for the FHA refund process to address the deficiencies identified in the audit report. These should include (1) controls to ensure that the website for the public listing of all unpaid refunds is complete, (2) controls to ensure that refund applications are sent only to the homeowners who requested them, (3) controls to ensure that refund applications are sent to all homeowners on the loan after loan termination, and (4) a formal monitoring framework for tracking the status of refunds.

Develop and implement written policies and procedures (1) for locating homeowners who have unpaid refunds (for both existing and new refunds), (2) to establish a standard timeframe for mailing refund applications to homeowners after they are requested, and (3) to establish requirements for verifying the termination date based on supporting documents provided by homeowners.

Research, develop, and implement policies and procedures to reduce the number of refunds that have remained unclaimed for an extended period, including consideration of a statute of limitations.

Develop and implement written policies and procedures regarding the designation of legal representation for applicants.

Obtain the required approvals under the Paperwork Reduction Act for the insert document mailed with the refund application and the Tracer Found Case form.

We audited the Buffalo Municipal Housing Authority’s management of its Commodore Perry Homes development. We selected the Authority based on congressional interest. Half of the development’s buildings were demolished more than 20 years ago, and the majority of the remaining buildings and units…

Audit #: 2022-NY-1001 Oversight Area: Rental Assistance Date Published: January 11, 2022

Work with the Authority to determine whether the buildings represent an imminent threat to public safety from physical deterioration and whether activities to control the situation would be exempt under the Part 58 environmental review process or excluded under the Part 50 environmental review process. If it qualifies, require the Authority to immediately take actions necessary to control the imminent threat to public safety before the full environmental review is done.

Determine whether it would be beneficial for HUD to conduct a Part 50 environmental review of the development or if the Authority should conduct a Part 58 environmental review, and implement the decision to ensure that the environmental review is conducted as soon as possible as required under the action plan.

Continue to provide training and technical assistance to ensure that the Authority understands relevant requirements for the various asset repositioning options, including milestone and disposition requirements.

Provide certifications and supporting documentation to show that it has identified and addressed urgent health and safety issues at the development, such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors.

Develop and implement a plan to routinely identify and address recurring urgent health and safety issues such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors while the property remains vacant and throughout future asset repositioning efforts.

Develop and implement a plan to use available asset repositioning options for the remaining 284 public housing units at the Commodore Perry Homes development, including 274 dwelling units and 10 nondwelling units.

Develop and implement a plan for the original property related to the 46 units converted under the RAD transfer of assistance option to ensure that the property and proceeds from its disposition are used in accordance with requirements.

If the Authority does not follow through on its asset repositioning plans, misses deadlines, or it otherwise becomes clear that the plan is no longer feasible, work with the HUD’s Special Applications Center, Office of Recapitalization, and other offices as appropriate, to consider and use available remedies such as revoking approval and enforcing required conversion.

We audited the Los Angeles Homeless Services Authority’s Continuum of Care (CoC) program. The audit was initiated because of the homelessness crisis in the City of Los Angeles, which has the highest number of unsheltered people in the United States. In addition, the Los Angeles city controller…

Audit #: 2022-LA-1001 Oversight Area: Community Improvement Date Published: January 20, 2022

Develop and implement policies and procedures to ensure that subgrantee agreements are executed in a timely manner, effective monitoring is performed, and subgrantees maintain an emphasis on using their CoC funds, thereby preventing similar occurrences of $3.5 million (see appendix D) in CoC funding going unused.

Develop and implement strategies to address capacity and organizational problems or obtain technical assistance to address these issues.

Develop and implement procedures and controls to clearly define and update point-of-contact staff for subgrantees.

Work with HUD and subgrantees to reevaluate its CoC program’s performance goals and set targets that help to ensure that funds for future CoC grants are fully and effectively used to advance the goal of ending homelessness.

Adequately support the eligibility of payroll costs or repay its CoC grants $824,302 from non-Federal funds.

Adequately support the eligibility of rent costs or repay its CoC grants $55,545 from non-Federal funds.

Develop and implement additional written procedures and controls to ensure that employees charge time in accordance with program requirements and that the Authority fully documents and supports that salary and rental cost allocations are charged to its CoC grants in accordance with its cost allocation plan.

Complete and implement policies and procedures to ensure that APRs are submitted by the closeout deadline.

Develop and implement policies and procedures to ensure that relevant personnel are routinely and regularly trained on the grant closeout process.

We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of its public housing agencies’ (PHA) reasonable accommodation policies and procedures. We initiated this audit because we identified an increase in housing discrimination complaints based on a failure to provide a…

Audit #: 2022-BO-0001 Oversight Area: Rental Assistance Date Published: February 7, 2022

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs update its compliance monitoring guidance to include a requirement for personnel to review PHAs reasonable accommodations policies and procedures.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs update and consolidate requests for reasonable accommodation policies and procedures to ensure that there is centralized guidance available for the field offices and PHAs.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs conduct additional outreach efforts to educate tenants and PHAs on their rights and responsibilities related to requests for reasonable accommodation, including technical assistance, webinars, and external communications to inform PHAs about their responsibilities and how to evaluate requests for reasonable accommodation, and help families understand their rights.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs require that PHAs track requests for reasonable accommodation, including the date of the request, the type of request, and the disposition and date of any action taken that should be made available to HUD at its request.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs review the joint agreement between HUD PIH and FHEO, including the Section 504 checklist, and modify, update, or recommit to it to ensure that the role of PIH and the responsibility for conducting civil rights front-end reviews is clearly defined.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs ensure that personnel receive training on how to conduct the civil rights front-end reviews, including a review of PHAs reasonable accommodation policies and procedures.

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…

Audit #: 2022-CH-0002 Oversight Area: HUD Business Functions Date Published: February 15, 2022

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.

Open Recommendations by Oversight Area

Oversight Area

Program Office

Topic

Status

Reports with Priority

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

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

HUD Did Not Always Implement Corrective Actions To Further Ensure That HECM Borrowers Complied With Principal Residency Requirements

FHA Borrowers Did Not Always Properly Receive COVID-19 Forbearances From Their Loan Servicers

The City of Houston, Houston, TX, Faced Challenges in Administering Its Hurricane Harvey Program and Risked Losing Its Funding

HUD Did Not Have Adequate Controls in Place to Track, Monitor, and Issue FHA Refunds Owed to Homeowners

The Buffalo Municipal Housing Authority, Buffalo, NY, Needs To Improve Its Management of the Commodore Perry Homes Development To Address Longstanding Concerns

The Los Angeles Homeless Services Authority, Los Angeles, CA, Did Not Always Administer Its Continuum of Care Program in Accordance With HUD Requirements

HUD Did Not Have Adequate Policies and Procedures for Ensuring That Public Housing Agencies Properly Processed Requests for Reasonable Accommodation

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

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