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Implement fraud awareness initiatives, such as official anti-fraud training for staff and stakeholders, including subrecipients. This could include developing frequent formal communication containing newsletters or bulletins and post physical visual displays to ensure staff’s fraud awareness when conducting day-to-day activities.
Upon completion of recommendations 1A – 1E, assess whether VIHFA has established and implemented mature fraud risk management practices within its disaster recovery and mitigation programs.
Repay ineligible landlord holding fees of $964,952 drawn from ESG CARES Act funds to HUD from non-federal funds.
Determine if the $58,878 drawn for 18 signing bonuses or additional security deposits from ESG CARES Act funds 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.
Repay risk mitigation overpayments of $6,549 drawn from ESG CARES Act funds to HUD from non-federal funds.
Determine if the remaining risk mitigation expenses of $185,731 drawn from ESG CARES Act funds were reasonable and necessary in accordance with program requirements or repay HUD from non-federal funds.
Support the cost reasonableness of $96,561 drawn from ESG CARES Act funds for the kitchen services contractor or repay HUD from non-federal funds.
Develop and implement additional written procedures and internal controls for the annual ESG program to ensure that it, and its subrecipients, do not charge holding fees and risk mitigation costs as expenses to the program, and that contracts are properly executed and maintained.
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.
