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

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Financial Risk and Accountability

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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 audited the City of Pittsburgh, PA’s administration of its Community Development Block Grant program. We conducted the audit because the City’s program had the second largest number of completed activities without accomplishment information reported nationwide. Our audit objective was to…

Audit #: 2017-PH-1001 Oversight Area: Community Improvement Date Published: March 21, 2017

Provide documentation to show that prices paid for products and services totaling $1,423,262 for three activities were fair and reasonable or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $942,636 for activity 7099 were for employees’ actual time spent benefiting the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $100,000 for activity 6865 benefited the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that seven activities with costs totaling $2,266,543 were exempt or categorically excluded from environmental reviews or repay its program from non-Federal funds for any amount that it cannot support (excluding any amount repaid as a result of recommendations 1A, 1B, and 1C).

Revise its policies and procedures to address compliance with applicable procurement regulations requiring independent cost estimates before receiving bids or proposals.

Train its staff on requirements for documenting costs funded by multiple funding sources.

Develop and implement controls to ensure that subrecipients comply with requirements for documenting costs funded by multiple funding sources.

Determine whether it has complied with environmental review requirements for all activities since October 2010 and provide a copy of its determination to HUD. If it did not comply, either provide the necessary support for the activities or repay its program from non-Federal funds for any activity costs it cannot support.

Develop and implement controls to ensure that it complies with environmental review requirements.

Review accomplishment data that it reported in IDIS for open and completed activities to ensure that accomplishments were reported accurately.

Train its staff on reporting accomplishments in IDIS and develop and implement policies and procedures for supervisory review to ensure accuracy.

Include compliance with environmental review requirements in its project-specific reviews in its next periodic monitoring of the City’s Block Grant program.

We audited Clark County, NV’s Community Development Block Grant (CDBG) program. We selected Clark County for review due to its large grant size and the U.S. Department of Housing and Urban Development’s (HUD) risk assessment. The reporting objective of the audit was to determine whether Clark…

Audit #: 2017-LA-1001 Oversight Area: Community Improvement Date Published: April 13, 2017

Support the reasonableness of the amount paid for the food facility consolidation and expansion project or repay the program $1,663,758 from non-Federal funds.

Correct any citations from the Southern Nevada Health District at the Pettiti public pool before May 2017 using non-Federal funds or repay the entire project cost of $596,126 from non-Federal funds and support the reasonableness of the change orders for the Pettiti pool project or repay the program from non-Federal funds.

Support the cost reasonableness of $2,809 in change orders for the ADA pool improvement project or repay the program from non-Federal funds.

Provide supporting documentation for $4,955 in unsupported costs or repay the program from non-Federal funds.

Provide support showing that the ADA pool improvement project allows equal and independent access for people with disabilities through a third party or correct the access issue.

Develop and implement procurement policies and procedures for monitoring subrecipients to ensure that the scope of work developed by its subrecipients is sufficiently detailed to allow contractors to submit informed bids, reducing the number of change orders after the contract, and that its subrecipients do an independent cost analysis before all procurement transactions, including change orders, to ensure that it receives a reasonable price and allows for full and open competition.

Develop and implement policies and procedures that ensure labor wage interviews are completed and documented.

Provide training to its staff on CDBG program rules and requirements to ensure that its staff adequately implements policies and procedures.

Identify the national objective met for the park project or repay the program $2,000,000 from non-Federal funds.

Develop monitoring practices to ensure that all projects that use limited clientele criteria exclusively serve the specific population claimed.

Repay $48,323 to the program from non-Federal funds for non-program-related payroll costs.

Determine the allocable amount of CDBG payroll costs for the employees who worked on CDBG and non-CDBG activities and adjust the funding amount as necessary or repay the program $573,064 from non-Federal funds.

Repay $71,397 to the program from non-Federal funds for the use of CDBG funds for code enforcement costs related to general government expenses.

Revise its code enforcement program to meet CDBG requirements for the remaining $33,603 budgeted or amend the use of the funding to another CDBG-eligible activity.

Determine the CDBG proportional benefit of the $329 charged for indirect automotive costs and repay the program any unsupported charges using non-Federal funds.

Obtain training or technical assistance from HUD concerning CDBG code enforcement, allocation of payroll, and indirect administrative costs.

We audited the City of Huntington Park’s Community Development Block Grant (CDBG) program. We selected the City based on the high risk assessment score and prior findings identified by the U.S. Department of Housing and Urban Development (HUD). The objective of the audit was to determine whether…

Audit #: 2017-LA-1005 Oversight Area: Community Improvement Date Published: June 16, 2017

Repay the program $7,323 from non-Federal funds for ineligible code enforcement costs.

Support the $576,997 in code enforcement costs (activities 499, 512, and 531), including meeting code enforcement and cost allocation requirements, or repay the program from non-Federal funds.

Implement revised code enforcement program policies and procedures to meet CDBG requirements. This will help ensure that the remaining $328,918 budgeted for code enforcement activity 531 is put to better use.

Support the reasonableness of the $110,000 Graffiti Removal program (activities 504 and 520) cost allocations or repay the program from non-Federal funds.

Support the $31,186 After School program (activity 501) costs, including the reasonableness of the contract costs and meeting the limited clientele national objective, or repay the program from non-Federal funds.

Support the reasonableness of the $95,736 in cost allocations charged as CDBG administrative (activity 522) costs or repay the costs from non-Federal funds.

Implement additional policies and procedures to ensure that salaries and wages and cost allocations are charged in compliance with HUD requirements.

Implement additional procedures and controls to ensure that documentation is obtained to support that the limited clientele national objective was met.

Obtain training or technical assistance on CDBG program requirements.

We audited the City of Birmingham, AL’s Community Development Block Grant Disaster Recovery (CDBG-DR) grant. We selected the City for review based on concerns by the U.S. Department of Housing and Urban Development’s (HUD) Birmingham Office of Community Planning and Development in regard to the…

Audit #: 2017-AT-1008 Oversight Area: Community Improvement Date Published: July 21, 2017

Develop and implement HUD-approved policies and procedures to ensure that the process for conducting an internal audit complies with HUD regulations and the policies and procedures are submitted and certified to HUD.

Immediately conduct an internal audit of the CDBG-DR grant funds.

Update, finalize, and implement its procurement policies to comply with 2 CFR 200.317-326.

We audited the City of Fresno’s Community Development Block Grant (CDBG) program. We selected the City based on prior findings identified by the U.S. Department of Housing and Urban Development (HUD) and continuing issues with the program. The objective of the audit was to determine whether the…

Audit #: 2017-LA-1006 Oversight Area: Community Improvement Date Published: August 9, 2017

Support the eligibility of $6,529,500 in code enforcement costs, including meeting code enforcement requirements, preparing time distribution reports, and supporting vehicle costs, or repay the program from non-Federal funds (appendix D).

Suspend funding to its code enforcement program until it can show that it has implemented controls, addressed its capacity issues, and understands and abides by HUD requirements.

Repay the program $4,565 from non-Federal funds for ineligible code enforcement program costs.

Repay the program $139,071 from non-Federal funds for ineligible tire team code enforcement program costs.

Repay the program $19,919 from non-Federal funds for ineligible antigraffiti program salary costs.

Support the eligibility of the $1,107,000 in after school program costs, including meeting the limited clientele national objective, or repay the program from non-Federal funds.

Support the eligibility of the $218,028 in antigraffiti costs or repay the program from non-Federal funds.

Support the eligibility of the $55,000 subrecipient drawdown or repay the program from non-Federal funds.

Develop and implement written code enforcement policies and procedures to meet CDBG requirements or amend the funding for another CDBG-eligible project. Improving code enforcement controls will result in $428,373 in funds to be put to better use.

Execute contractual agreements with each CDBG recipient department to ensure compliance with all Federal guidelines.

Develop and implement written policies and procedures for specific departments, update and implement CDBG-specific written policies and procedures, and provide formal training and technical assistance to the Development and Resource Management Department employees to ensure that they understand and follow CDBG requirements.

Develop and implement a monitoring program within the City’s Development and Resource Management Department to ensure that it periodically monitors and provides guidance to its subrecipient(s) and City departments on how to administer CDBG funds.

We audited the State of New Jersey’s Community Development Block Grant Disaster Recovery-funded Sandy Homebuyer Assistance program. We conducted the audit because (1) it was the State’s only home-buyer assistance program, (2) the State had spent a high percentage of its allocated funds, and (3)…

Audit #: 2017-PH-1005 Oversight Area: Community Improvement Date Published: August 14, 2017

We audited the City of Albuquerque’s Community Development Block Grant (CDBG) program based on our risk analysis and as part of the Office of Inspector General’s annual audit plan to review community planning and development funds. The audit objective was to determine whether the City administered…

Audit #: 2017-FW-1010 Oversight Area: Community Improvement Date Published: August 16, 2017

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $568,629 in ineligible costs for its violation of procurement requirements. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $572,929 in ineligible costs for its violation of Federal requirements and procurement procedures when it acquired a property with CDBG funding. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to obtain technical assistance from HUD related to differentiating between subrecipients and contractors and ensuring that the correct procurement requirements are followed when obtaining a subrecipient or contractor.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to amend and implement its conflict-of-interest policy and procedures to ensure that it complies with Federal conflict-of-interest requirements and includes elected and appointed positions.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to support that environmental requirements and client eligibility were met for dental services or repay $59,604 to its CDBG line of credit from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to support that environmental requirements were met for the roof replacement of a food bank or repay $260,000 to its CDBG line of credit from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to support that environmental requirements were met for homeowner rehabilitation or repay $181,053 to its CDBG line of credit from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $73,186 in ineligible costs for its statutory violation of environmental requirements when it rehabilitated a home without completing the environmental review. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to provide training for staff members to ensure that they know their roles and responsibilities with respect to CDBG program oversight and that documentation and other requirements are met.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $507,218 in ineligible costs for its violation of its home rehabilitation policy and procedure when it exceeded the allowed maximum assistance per home with no cost justifications. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $110,647 in ineligible costs for the rehabilitation costs that exceeded the allowed HOME value limits. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $474 in ineligible costs for violation of Federal travel regulations. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reclassify the $9,476 to program administration and recalculate its cap to determine whether it exceeded the allowed 20 percent. Any amount that is over the allowed cap would be ineligible, and repayment of the overage amount to its CDBG line of credit would be required. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to implement recommendations made from its internal and external auditors that will ensure compliance with applicable regulations related to cost reasonableness and eligibility and that costs are adequately supported.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to support that subrecipient 1 met a national objective, environmental requirements, and client eligibility or repay $123,831 to its CDBG line of credit from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to support that subrecipient 2 met a national objective, environmental requirements, and client eligibility or repay $69,000 to its CDBG line of credit from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to support that subrecipient 3 met a national objective, environmental requirements, and client eligibility or repay $304,975 to its CDBG line of credit from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $565 in ineligible costs for its failure to provide subrecipient oversight, which should have identified that the subrecipient had incorrectly applied eligibility requirements for homeless clients served. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $1,400 in ineligible costs for its failure to provide subrecipient oversight, which should have identified the ineligibility of clients whose income exceed the threshold as reported. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to develop and implement written CDBG policies and procedures, which detail the requirements, including but not limited to (1) meeting Federal procurement requirements, (2) executing written agreements for all subrecipients and contractors that meet minimum requirements, (3) documenting all conflicts of interest, (4) complying with HUD environmental review requirements, (5) maintaining documentation to support that its CDBG-funded projects met one or more national objectives, (6) properly and accurately monitoring subrecipients for compliance with all requirements, and (7) consistently and accurately reporting activities in IDIS.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development continue to classify the City of Albuquerque as a high risk grantee until such time as HUD has determined the City has implemented an effective program in compliance with all requirements.

We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of the disposition of real properties assisted with Community Development Block Grant (CDBG) funds. We conducted the audit as part of our annual audit plan. Our audit objective was to determine whether HUD had…

Audit #: 2017-NY-0002 Oversight Area: Community Improvement Date Published: September 29, 2017

We recommend that the Deputy Assistant Secretary for Grant Programs issue guidance reminding grantees of the requirement to properly report the addresses of assisted properties in IDIS and properly calculate and report program income from the disposition of these properties.

We recommend that the Deputy Assistant Secretary for Grant Programs develop a process to ensure that grantees properly report the addresses of assisted properties in IDIS and properly calculate and report program income from the disposition of these properties regularly. This process could include but is not limited to developing a process to extract data reported in IDIS on activities with the matrix codes related to real property, and training and instructing the Office of Community Planning and Development’s field office staff to extract this data and manually check for address and program income data on grantees’ activities, particularly activities that are completed but have properties that could still be subject to program income requirements.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Newark, NJ, field office to require Jersey City to provide documentation to show that a notice was provided to affected citizens as required or take action to advise affected citizens that they disposed of the property.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Newark, NJ, field office to require Jersey City to provide documentation to support the fair market value of the property at the time of disposition. If documentation cannot be provided, the grantee should be required to reimburse $503,550 to its CDBG line of credit from non-Federal funds. If documentation can be provided, the grantee should be required to determine and reimburse its local bank account from non-Federal funds any additional program income not already reported and properly report the additional program income in IDIS under the activity ID that generated the income.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Philadelphia, PA, field office to require Luzerne County to provide documentation to support the fair value of the property at the time of disposition. If documentation cannot be provided, the grantee should be required to reimburse $575,263 to its CDBG line of credit from non-Federal funds. If documentation can be provided, the grantee should be required to determine and reimburse its local bank account from non-Federal funds the additional program income not already reported and properly report the additional program income in IDIS under the activity ID that generated the income.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Philadelphia, PA, field office to require Luzerne County to reclassify program income already reported to the activity ID in IDIS that generated the income, ensuring that the $798,273 in program income is properly accounted for.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Los Angeles, CA, field office to require the County of Los Angeles to reclassify program income to the activity ID in IDIS that generated the income, ensuring that the $300,330 in program income is properly accounted for.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Milwaukee, WI, field office to document that no portion of the four State of Wisconsin’s activities reviewed is currently subject to the change of use requirements or remind the State of Wisconsin that the portions of the activities related to the voluntary grant reductions are still subject to the change of use requirements.

We recommend that the Deputy Assistant Secretary for Grant Programs issue guidance to HUD staff and grantees to clarify the applicability of change of use requirements in cases where there is both a repayment from non-Federal funds and a voluntary grant reduction.

We audited Hudson County, NJ’s HOME Investment Partnerships program (HOME) as part of the activities in our annual audit plan. We selected the County based on a risk analysis that considered the amount of funding, the risk score assigned to it by the U.S. Department of Housing and Urban…

Audit #: 2018-NY-1001 Oversight Area: Community Improvement Date Published: January 11, 2018

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development require the County to strengthen its policies and procedures to ensure that environmental reviews and environmental review exemptions are completed and documented before HOME funds are committed.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development require the County to strengthen its policies and procedures to ensure that activity address information in IDIS is current as required.

We audited the Jefferson Parish Community Development Department in response to a citizen complaint and in accordance with our annual audit plan to review the U.S. Department of Housing and Urban Development’s (HUD) community planning and development programs, including the Community Development…

Audit #: 2018-FW-1001 Oversight Area: Community Improvement Date Published: January 28, 2018

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to develop and implement a HUD-approved written plan and procedures and take actions that will correct and prevent the deficiencies noted in the finding, improve program administration effectiveness, strengthen the control environment, ensure compliance with HUD regulations and its own policies and procedures, and ensure that it has the continuing capacity to carry out its HOME program activities as required. Implementing this recommendation should ensure that the $216,663 in HOME funding allocated for the Parish’s property rehabilitation program is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to Repay its program from non-Federal funds for $9,849 in payments made to contractors for duplicate payments and overpayments.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support or repay its program from non-Federal funds $1,020,121 for payments made (1) for work that the contractor(s) did not perform and excessive material costs; (2) that lacked adequate supporting documentation for change orders, independent cost estimates, and invoice documentation; or (3) for the 10 HOME-funded rehabilitated homes not brought up to code.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to establish and implement desk and onsite monitoring policies and procedures to ensure that documentation is maintained to support that (1) adequate supporting documentation for payments is filed, tracked, and maintained; (2) the necessity for all change orders is verified and reasonableness of the costs is assessed; (3) cost estimates are completed before the bidding process; (4) work is completed before pay requests are approved and payments are made to the contractor; and (5) contractors are properly monitored throughout the rehabilitation process, including progress and final inspections.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to correct the property deficiencies identified during the onsite inspections related to the 20 contracts as applicable.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to inspect the remaining 33 homes for compliance with the contract specifications and HUD requirements and correct deficiencies as applicable.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to establish and implement complaint policies and procedures and ensure that its staff is aware of the procedures to ensure that participant complaints are properly handled in a timely manner.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to review and adjust staffing levels as needed to ensure adequate coverage.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to provide training to staff members to ensure that they are aware of policies and procedures and their responsibilities related to expenditures, monitoring, and addressing participant complaints.

Open Recommendations by Oversight Area

Oversight Area

Topic

Status

Reports with Priority

The City of Pittsburgh, PA, Did Not Always Administer Its Community Development Block Grant Program in Accordance With HUD and Federal Requirements

Clark County, NV, Did Not Always Use Community Development Block Grant Funds in Accordance With HUD Requirements

The City of Huntington Park, CA, Did Not Administer Its Community Development Block Grant Program in Accordance With Requirements

The City of Birmingham, AL, Did Not Ensure That Adequate Policies and Procedures Were Implemented for Its Internal Audits and Procurement Process

The City of Fresno, CA, Did Not Administer Its Community Development Block Grant in Accordance With HUD Requirements

The State of New Jersey Did Not Always Disburse Disaster Funds for Its Sandy Homebuyer Assistance Program To Assist Eligible Home Buyers

The City of Albuquerque, NM, Did Not Administer Its Community Development Block Grant Program in Accordance With Requirements

HUD Could Improve Its Controls Over the Disposition of Real Properties Assisted With Community Development Block Grant Funds

Hudson County, NJ, Generally Committed and Disbursed HOME Program Funds in Accordance With HUD and Federal Requirements

Jefferson Parish, Jefferson, LA, Did Not Always Properly Administer Its Rehabilitation Program

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