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 audited the City of Modesto’s Community Development Block Grant (CDBG) program. We selected the City based on a hotline complaint (HC-2017-2082) regarding the City’s rehabilitation program and the U.S. Department of Housing Development’s (HUD) and the HUD Office of Inspector General’s risk…

Audit #: 2018-LA-1005 Oversight Area: Community Improvement Date Published: July 3, 2018

Support that the $592,266 spent on the HACS rental rehabilitation projects was reasonable or repay the program from non-Federal funds.

Support that the $401,614 spent on STANCO rental rehabilitation projects was reasonable and met one of HUD’s national objectives and that it completed an environmental review or repay the program from non-Federal funds.

Develop and implement policies to safeguard HUD funds by ensuring that its projects meet national objectives, have a completed environmental review, and have executed agreements for all projects and verify that work is complete before approving payment, including its rental rehabilitation projects.

Update policies and procedures to ensure that costs are reasonable, including preparing an independent cost estimate and a detailed scope of work for each project.

Support that $173,508 spent on homeowner rehabilitation project expenses was reasonable or repay the program from non-Federal funds.

Update and implement policies and procedures to ensure that all procurements are conducted in a manner that promotes full and open competition and avoids any arbitrary action in the procurement process, including ensuring that contractors are given sufficient time to respond to solicitations.

Repay from non-Federal funds $257,737 from voucher 6035061 for the duplicate draw.

Support that $45,304 drawn in advance met eligibility and procurement requirements and costs were reasonable or repay the unsupported amount from non-Federal funds.

Update its policies and procedures to ensure that the City issues payments to vendors and obtains reimbursement from HUD only after the City’s Community and Economic Development Department has verified that work is complete.

Support that $323,563 spent on rehabilitation administration charged in program year 2015 costs was reasonable and benefited the City’s rehabilitation program or repay the program from non-Federal funds any amount determined to be unreasonable or ineligible.

Reclassify $69,794 in employee payroll and benefits for City employees that did not work on rehabilitation-related activities or repay the program from non-Federal funds.

Support that expenses were related to rehabilitation activities for $66,910 in payroll expenses charged to the rehabilitation delivery expenses activity for its former environmental review specialist or repay the program from non-Federal funds.

Support that expenses were related to rehabilitation activities for $13,263 in unsupported payroll or repay the program from non-Federal funds.

Reclassify $517 in miscellaneous expenses that was incorrectly prorated or repay the program from non-Federal funds.

Provide training for its staff to ensure sufficient knowledge of CDBG requirements regarding when to charge delivery costs, including when to charge payroll to rehabilitation administration, versus general administrative costs.

Implement policies and procedures to ensure that the City includes all recipients of CDBG funds in its monitoring plan and that it selects objective sample items for monitoring.

We audited the Sacramento Housing and Redevelopment Agency’s Community Development Block Grant (CDBG) program, based on an Office of Inspector General risk assessment and U.S. Department of Housing and Urban Development (HUD) concerns. The objective of our audit was to determine whether the Agency…

Audit #: 2018-LA-1006 Oversight Area: Community Improvement Date Published: July 25, 2018

Support that the 59 contracts awarded for the emergency repair program were fair and reasonable or repay its program $272,569 from non-Federal funds.

Obtain technical assistance from HUD to revise its Emergency Repair Program to meet CDBG requirements.

Support that the contract awarded for the food incubator study was fair and reasonable and met a final cost objective or repay its program $50,000 from non-Federal funds.

Support that change orders executed outside the scope of the Colonial Heights Library contract were fair and reasonable or repay its program $48,895 from non-Federal funds.

Support that the contract awarded for the Boys and Girls Club feasibility study was fair and reasonable and met a final cost objective or repay its program $13,950 from non-Federal funds.

Provide procurement training to its staff members who work on CDBG program activities and ensure that staff members comply with HUD requirements and use its current procurement policy.

Support that the entrepreneur center feasibility study met a final cost objective or repay its program $55,200 from non-Federal funds.

Reimburse its program $283 from non-Federal funds for unallowable bottled water costs.

Review all invoices provided from its minor repair subrecipient between January 1, 2015, and December 31, 2017, and repay the program from non-Federal funds for all bottled water service payments not identified in this audit report.

Provide training to its employees regarding allowable costs to ensure that all costs submitted by contractors and subrecipients are eligible for reimbursement.

We audited the State of Connecticut’s Small Cities Community Development Block Grant program based on an Office of Inspector General risk assessment, which ranked the State as the highest risk grantee in Connecticut. Our audit objective was to determine whether the State ensured that its grantees…

Audit #: 2018-BO-1005 Oversight Area: Community Improvement Date Published: September 19, 2018

Repay from non-Federal funds the $1,190,977 in ineligible costs charged to the program.

Repay from non-Federal funds the $434,970 in unreasonable costs charged to the program

Support $249,015 in program costs spent on a 2014 grant for which the grantee was unable to provide a tier one environmental review record or repay from non-Federal funds any amount that cannot be supported

Support $676,922 for contracts that were improperly procured or repay from non-Federal funds any amount that cannot be supported.

Support $422,600 in program income that was not used before additional grant fund drawdowns or repay from non-Federal funds any amount that cannot be supported

Strengthen controls over program oversight to ensure that grantees comply with their agreements and program requirements, including tier two environmental reviews, contract procurements, and homeowner and project eligibility, to ensure that (1) all income, including rental income, is considered; (2) loan-to-value ratios do not exceed 90 percent without State approval; and (3) projects do not exceed the program limits without State approval.

Strengthen controls over monitoring to ensure that onsite monitoring and monitoring letters are completed in a timely manner and sufficient supporting documentation is required and reviewed by those responsible for grant oversight.

Develop and implement policies and procedures to assess the validity of all program complaints to ensure that they are addressed and resolved in a timely manner.

Provide additional guidance to its grantees regarding its policy stating that the repair or replacement of paved surfaces should be minimal in cost and incidental to the rehabilitation of the dwelling, including whether grantees are required to consult with the State before starting the work.

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

Audit #: 2018-FW-1007 Oversight Area: Community Improvement Date Published: September 28, 2018

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

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

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

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

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

Audit #: 2018-CH-1008 Oversight Area: Community Improvement Date Published: September 27, 2018

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Audit #: 2018-AT-1011 Oversight Area: Community Improvement Date Published: September 28, 2018

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

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

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

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

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

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

We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of its Community Compass Technical Assistance and Capacity Building (Community Compass) program. We conducted the audit because we received a complaint alleging that HUD did not ensure that the program operated in…

Audit #: 2018-PH-0003 Oversight Area: Community Improvement Date Published: September 28, 2018

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

Require the four Community Compass providers reviewed to either provide documentation to support $845,497 in unsupported labor and travel costs, for personnel not on approved work plans, and for work performed that was not described on the payment request or reimburse HUD from non-Federal funds for any costs that it cannot support.

Develop and implement policies and procedures for the Community Compass program, to include postaward monitoring, that ensures that providers and provider subcontractors comply with applicable requirements to avoid incurring expenses for unapproved personnel and overcharged labor and travel costs, thereby ensuring that as much as $15,475,981 is put to better use.

Develop and implement controls for the Community Compass program to ensure that it uses procurement contracts for services that directly benefit HUD, including the development, maintenance, and operation of the HUD Exchange website and preparation of the Annual Homelessness Assessment Report, thereby ensuring that as much as $5,060,494 is put to better use.

Develop and implement controls for the Community Compass program to ensure that it consistently applies subcontractor wage rates among all providers that use a subcontractor.

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

Audit #: 2019-LA-1003 Oversight Area: Community Improvement Date Published: February 20, 2019

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

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

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

Audit #: 2019-AT-1002 Oversight Area: Community Improvement Date Published: March 18, 2019

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

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

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

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

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

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

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

We audited the Housing Authority of the County of San Bernardino’s Continuum of Care grant funds received from the U.S. Department of Housing and Urban Development (HUD). We audited the Authority because it is among the top 15 percent of competitive grantees in HUD’s Office of Community Planning…

Audit #: 2019-LA-1005 Oversight Area: Community Improvement Date Published: April 17, 2019

Provide support for the administrative fees or repay the Continuum of Care grants $663,070 from non-Federal funds. (See appendix D.)

Submit an indirect cost rate schedule for its Continuum of Care grants to HUD for approval.

Develop and implement written policies and procedures for its administrative fee charges.

Open Recommendations by Oversight Area

Oversight Area

Program Office

Topic

Status

Reports with Priority

The City of Modesto, CA, Did Not Use Community Development Block Grant Funds in Accordance with HUD Requirements

The Sacramento Housing and Redevelopment Agency, Sacramento, CA, Did Not Always Use Community Development Block Grant Funds in Accordance with HUD Requirements or Its Own Policies

The State of Connecticut Did Not Ensure That Its Grantees Properly Administered Their Housing Rehabilitation Programs

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

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

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

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

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

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

The Housing Authority of the County of San Bernardino, CA, Did Not Adequately Support Administrative Fees Charged to Its Continuum of Care Grants

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