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CPD Did Not Follow the Departmental Clearance Process When It Issued the July 25, 2013, Guidance for Duplication of Benefits Requirements


The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General audited HUD’s Office of Community Planning and Development’s (CPD) process for making changes to its programs, policies, and operations.  We initiated the audit because of concerns we had with HUD’s disaster recovery delivery sequence and duplication of benefits policies during a previous external audit (Audit Report 2016-DE-1003). Our objective was to determine whether CPD complied with the departmental clearance process and associated Federal requirements when issuing its July 25, 2013, guidance on the duplication of benefits.

We found that CPD did not follow the departmental clearance process when it issued the July 25, 2013, guidance for duplication of benefits requirements. It did not review public communications to determine whether the guidance was a directive and did not ensure that key officials reviewed the directive before issuance. This condition occurred because CPD lacked procedures to ensure that program staff identified all directives and submitted them to the directives management officer for departmental clearance before issuance. As a result, CPD’s guidance for coordinating Community Development Block Grant Disaster Recovery (CDBG-DR) assistance with the Small Business Administration (SBA) was contradictory and unclear.

We recommend that HUD (1) pursue departmental clearance for the July 25, 2013, guidance or take appropriate action to recall the document or policy; (2) develop guidance that helps the public understand its options for assistance between CDBG-DR and SBA and how to comply with Federal requirements; and (3) develop improved procedures and provide training to appropriate staff regarding the departmental clearance process requirements, including determining which guidance is considered to be a directive, and ensuring that HUD constituents have clear, instructive, and helpful information to comply with the applicable requirements and procedures for HUD programs.