Interim Report - Potential Antideficiency Act and Generally Accepted Accounting Principle Violations Occurred With Disaster Relief Appropriation Act, 2013, Funds

Date Issued: 
Tuesday, May 15, 2018
Publication/Report Type: 
Memorandums
Memorandum Number: 
2018-FW-0802
Program Area(s): 
Chief Financial Officer
State: 
District of Columbia
Summary: 

While performing audit work to determine whether the U.S. Department of Housing and Urban Development’s Office of Community Planning and Development (HUD CPD) monitored and ensured that grantees complied with the 24-month statutory expenditure requirement contained in the Disaster Relief Appropriations Act, 2013, we noted issues with (1) the recording of grants in the Line of Credit Control System (LOCCS) and (2) the grantees’ recording of expenditures in the Disaster Recovery Grants Reporting (DRGR) system.  These issues require immediate action by the Office of the Chief Financial Officer (OCFO) as they are potential violations of the Antideficiency Act (ADA) and do not appear to follow generally accepted accounting principles (GAAP). 

As of January 19, 2018, two of the six grantees had recorded total expenses in the DRGR system in excess of what CPD had obligated for a grant round, which totaled more than $160 million.  Five grantees also recorded expenses in the DRGR system before CPD executed a grant round amendment and after a grant round expired, which totaled more than $435 million.  In addition, four grantees made revisions to completed and revised vouchers totaling more than $496 million in the DRGR system a year or more after they entered the initial voucher.  These issues had a variety of causes, including (1) systemic weaknesses in the DRGR system, (2) CPD’s entering into one grant agreement with multiple amendments with multiple deadlines, (3) how CPD and OCFO treated the grants in LOCCS, (4) a lack of voucher monitoring by CPD’s Office of Block Grant Assistance (OBGA), and (5) OBGA’s incorrect decisions on how to account for the funds.  These expenses appeared to have been potential ADA and GAAP violations and could potentially have a negative effect on both HUD’s and the grantees’ financial statements.  If OCFO does not require corrections to how it and CPD account for Disaster Recovery funds, these issues will continue to occur with the remaining $6.4 billion in 2013 Disaster Recovery funding and the future $35.4 billion for 2017 and 2018 Disaster Recovery funding. 

We recommended that OCFO determine whether (1) summary expenditures totaling more than $160 million, which exceeded the grant round obligations for the two grantees; and (2) revised and completed detail transactions totaling to more than $435 million, which occurred before and after grant rounds obligation and expenditure dates, were ADA violations. We also recommended that OCFO determine whether the revised and completed transactions totaling more than $496 million and made more than a year after the original DRGR voucher entry were GAAP violations.  We further recommended that CFO enter expiration terms into LOCCS for DRGR funding and require CPD to implement additional controls to prevent the identified issues from occurring in 2017 and 2018 Disaster Recovery funding.

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