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.

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

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

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

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

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

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

We recommend that the Director of HUD’s Houston Office of Public Housing require the Authority to reimburse its Public Housing Operating Fund $5,000 from non-Federal funds for the unrecovered remaining balance of the $20,000 that was paid to the attorney.

We recommend that the Director of HUD’s Houston Office of Public Housing require the Authority to ensure that no Federal funds are used to pay the remaining legal services invoices totaling $24,250, which will result in these funds being put to better use.

We recommend that the Director of HUD’s Houston Office of Public Housing require the Authority to update its policies to ensure the future commissioners obtain training on Texas’ Open Meetings Act requirements and HUD’s training for commissioners within 90 days after appointment, which will ensure that future commissioners understand the requirements for board meetings and procurement actions.

We also recommend that the Director of HUD’s Houston Office of Public Housing evaluate the reported actions the three commissioners took when procuring the legal services contract and, if warranted, pursue administrative sanctions or other corrective actions.

We recommend that Director of the Houston Office of Public Housing require the Authority to Reimburse its low-rent operating fund $2,172 from non-Federal funds for the ineligible travel, training, and credit card expenditures.

We recommend that Director of the Houston Office of Public Housing require the Authority to reimburse its low-rent operating fund $4,469 from its Housing Choice Voucher Program fund for the expenses that should have been paid from its Housing Choice Voucher Program fund.

We recommend that Director of the Houston Office of Public Housing require the Authority to reimburse its Housing Choice Voucher Program fund $704 from non-Federal funds for the ineligible travel and training expenditures.

We recommend that Director of the Houston Office of Public Housing require the Authority to support or repay $31,327 to its low-rent operating fund from non-Federal funds for the various unsupported expenditures.

We recommend that Director of the Houston Office of Public Housing require the Authority to support or repay $584 to its Housing Choice Voucher Program fund from non-Federal funds for the unsupported travel, training, and phone expenses paid with Housing Choice Voucher Program funds.

We recommend that Director of the Houston Office of Public Housing require the Authority to update and implement its policies and procedures, including creating a policy for recording expenses, a cost allocation plan, and a travel policy, to ensure that the Authority appropriately pays and accurately reports its costs.