Determine whether the $714,512 paid for 233 signing bonuses under the ESG CARES Act program were reasonable under the program participant’s particular circumstances, and not more than necessary to house the program participants or repay HUD from non-Federal funds.

Develop and implement written policies and procedures that include internal controls for the ESG program to ensure that it, and its subrecipients, prorate the rent amount for the first month for tenant-based rental assistance. Since the City did not prorate rent, there was an estimated overpayment to landlords of $248,572 that could have been put to better use.

Repay HUD from non-Federal funds $51,235 in overpaid rent to landlords because the first month of rent was not prorated.

Develop and implement written policies and procedures that include internal controls to prevent any duplication of benefits for the ESG program participants with other programs, specifically for rapid rehousing and homeless prevention.

Review the rental assistance payments made for the ESG CARES Act program to identify other possible duplication of benefits with other rental assistance programs that the City operates. The $10,100 in duplication of benefits identified during the audit could have been put to better use.

Develop and implement written policies to ensure that any changes to the expenditure and draw deadlines for the ESG program are provided in a formal document, such as a CPD notice. In this case, implementing these controls would provide clear guidelines to the grantee and help prevent the disbursement of $1,933,693 that was drawn after the draw deadline.

Issue clarifying guidance to ensure that ESG grantees that operate tenant-based rental assistance programs, prorate the rent amount for the first month based on the lease agreement start date.

Issue guidance requiring ESG grantees develop and implement internal controls to prevent any duplication of benefits with other Federal rental assistance programs for the ESG program participants, specifically for rapid rehousing and homeless prevention.

Leverage HUD OIG’s fraud risk inventory and continue using the Office of the Chief Risk Officer’s risk catalog to enhance CPD’s fraud risk management process.

Include grantees in the fraud risk identification process and communicate the risks and schemes identified for the disaster recovery program to relevant stakeholders, including, but not limited to, all HUD staff in the CPD Office of  Disaster Recovery, grantees and sub-recipients.

Use CPD’s fraud risk inventory to identify data needs, potential system enhancements, and implement data analysis techniques to improve CPD’s ability to monitor and respond to fraud risks in the Disaster Recovery program.

Evaluate and enhance its fraud risk management activities by incorporating fraud risk management practices that are in alignment with the best practices identified in GAO’s A Framework for Managing Fraud Risks in Federal Programs and Chief Financial Officers Council’s Antifraud Playbook.

Obtain training or technical assistance on the implementation of fraud risk management practices consistent with the Internal Control Integrated Framework, issued by COSO.

Issue guidance, including technical assistance, to all disaster recovery grantees that waivers for issues related to a disaster’s impact, like waivers of procurement policies, should be for reasonable and limited time periods after a disaster’s occurrence to ensure full and open competition.
 

Require the State to include in its procurement policy a reference to the New York State law which limits a State waiver of policies to 30 days unless renewed and to ensure that it clearly states whether the law affects the Governor’s 2012 waiver. Further, if it does not affect the 2012 waiver, require the State to take action to limit the use of that waiver to ensure full and open competition.
 

Require the State to implement a control, including documenting exceptions, to ensure that all contracts that exceed 5 years are approved by the Corporation.

Require the State to implement a control to ensure that it follows its mini bid process to ensure that it obtains the best services for the best price or document those exceptions and have the Corporation’s approval for them.

Require the State to implement a control to ensure that it follows its procurement policy and limits contract terms to 1 year unless it has the Corporation’s approval and it documents those exceptions.

Revise its procurement policies, practices, and controls to ensure that it executes and renews contracts in a timely manner to prevent lapses and backdating of agreements.

Revise its procurement policies to include requiring Corporation oversight for material changes in an agreement’s scope or amount.