We recommend that the Deputy Assistant Secretary for Operations of Community Planning and Development enhance CPDs existing Grant Accrual Standard Operating Procedures to strengthen governance within CPD and to effectively work within the framework established by the OCFO in recommendation 1A. The updated procedures should include increased ownership and oversight over the reviews, authorizations, approvals, and changes to the CPD grant accrual estimates and methodology.

Develop and implement additional subrecipient monitoring training and guidance for all ESG grantees.

Take corrective action for the subrecipient monitoring and agreement issues cited for eight of the ESG-CV grantees reviewed, and provide additional guidance and technical assistance as needed to ensure that they understand requirements.

Obtain training or technical assistance as needed on the implementation of fraud risk management practices.

Improve or enhance its antifraud efforts for the ESG program and incorporate fraud risk management practices that are consistent with the best practices identified in the Government Accountability Office’s A Framework for Managing Fraud Risks in Federal Programs and Chief Financial Officers Council and Treasury Bureau of the Fiscal Services’ Antifraud Playbook.

Obtain training or technical assistance on the implementation of fraud risk management practices consistent with the principles of GAO’s Standards for Internal Control in the Federal Government (Green Book).

Establish a separate fraud risk management framework or evaluate and build upon its ERM framework by incorporating fraud risk management practices that are consistent with the principles of GAO’s Standards for Internal Control in the Federal Government (Green Book), including developing a fraud risk management framework in alignment with best practices identified in GAO’s A Framework for Managing Fraud Risks in Federal Programs and the Chief Financial Officers Council’s Antifraud Playbook.