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

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

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.

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.

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.

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, including documenting exceptions, to ensure that all contracts that exceed 5 years are approved by the Corporation.

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.

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.

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.