2012 Peer to Peer Homeless Provider Conference
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- Arlene Russell
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1 2012 Peer to Peer Homeless Provider Conference Springfield, Illinois September 11 and 12, 2012 Inspector General Mission Conduct independent and objective audits and investigations. Prevent waste, fraud, and abuse. Promote economy, efficiency, and effectiveness. Review pending legislation and regulations. Keep the Secretary and Congress informed. 1
2 Inspectors General Authorization Access all records and information of HUD and program participants. Conduct audits and criminal investigations. Issue subpoenas for records and documents. Hire staff and control budget resources. OIG Strategic Plan Align directly with and support HUD s strategic plan. Contribute to resolving significant issues raised or confronted by HUD and our stakeholders. Assist HUD in resolving its major management challenges. 2
3 HUD Inspector General Office of Audit What We Do Internal and External Audits/Surveys Financial Information Systems Program Performance Program/Issue Evaluations/Studies Legislation/Regulation Reviews Audit Plan Audit Follow-up Support for Investigations and Assistant U.S. Attorneys 3
4 Annual Audit Plan: Objective Focus resources on areas of greatest benefit to our customers Congress HUD management HUD stakeholders Taxpayers Annual Audit Plan: The Process Developed to reflect input and concerns of HUD management. Formally updated two times per year. Flexible to meet unexpected needs. 4
5 2012 Priority Areas Contribute to improving the integrity of single-family insurance programs. Contribute to the oversight objectives of the American Recovery and Reinvestment Act of 2009 (e.g. CDBG, NSP2, HPRP). Contribute to a reduction in erroneous payments in rental assistance programs. Contribute to improving HUD s execution of and accountability for fiscal responsibilities. Contribute to resolving significant issues raised or confronted by HUD s and OIG s stakeholders. Use of Office of Community Planning and Development program funds (e.g. HOME, Disaster Recovery) Audit Process Entrance Conference Survey work Audit work (if findings) Draft audit finding outline(s) Discussion draft audit report (for comment) Exit conference Evaluate auditee comments/adjust audit report, if necessary Issue audit report to HUD s responsible action official 5
6 Conflicts of Interest - CFR No person who is an employee, agent, consultant, officer, or elected or appointed official of the recipient and who exercises or has exercised any functions or responsibilities with respect to assisted activities, or who is in a position to participate in a decision making process or gain inside information with regard to such activities, may obtain a personal or financial interest or benefit from the activity, or have an interest in any contract, subcontract, or agreement with respect to the assisted activities. This includes their family. Conflicts of Interest Procurement of services Purchase and sale of foreclosed homes Bulk purchase and sale 6
7 (1) Audit Findings Supportive Housing Program Grantee Grantee unable to sufficiently support its use of: (1) more than $574,000 in Program funds for appropriate lease payments; and (2) more than $72,000 in Program funds for eligible nonlease expenses. Grantee used nearly $16,000 in Program funds for improper nonlease expenses. Grantee could not provide sufficient documentation to support whether its transfers of $25,000 in Program funds among its Program grants were allowable. (1) Audit Findings Supportive Housing Program Grantee (Cont.) Grantee lacked sufficient documentation to support that it followed HUD s requirements in providing more than $330,000 in matching contributions for its Program grants. 7
8 (2) Audit Findings Supportive Housing Program Grantee Grantee used nearly $31,000 in Program funds for of ineligible expenses and lacked sufficient documentation that its use of nearly $175,000 benefitted the Program. Grantee submitted and certified in a Program technical submission that contained inaccurate information, which HUD relied on to award grantee more than $346,000. (3) Audit Findings Supportive Housing Program Grantee Grantee could not adequately support that it met the statutory 25 percent cash match requirement of more than $389,000 for all 12 grants reviewed. Grantee inappropriately charged more than $5,000 in duplicate operational costs that were charged to both HUD and Department of Mental Health and more than $107,000 in unsupported duplicate salaries. 8
9 (4) Audit Findings Supportive Housing Program Grantee Grantee improperly applied ineligible expenses as cash match for 11 of 15 grants. However, while nine of the grants had enough additional sources of funding to meet the cash match requirements, one grant failed to meet the 25 percent cash match requirement of nearly $18,000. In addition, a second grant was deficient in the amount of cash match provided through the first four months of the grant term to ensure that it would have met the cash match requirements by the end of the grant term. Grantee also failed to distinguish the source of the cash match on its annual progress reports to HUD. (5) Audit Findings Supportive Housing Program Grantee Grantee spent more than $294,000 of its more than $1.2 million in grant funds for unsupported (nearly $270,000) and ineligible (more than $24,000) expenses. Grantee s accounting records failed to fully support that it had provided more than $758,000 in required matching funds for more than $429,000 in transitional and permanent housing program grant funds. 9
10 (5) Audit Findings Supportive Housing Program Grantee (Cont.) Grantee prematurely sold two apartment buildings that it had acquired and rehabilitated with Program funds totaling $280,000 without HUD s written approval. Grantee failed to correctly calculate and support the basis of the program participants rents. (6) Audit Findings HPRP Grantee Grantee disbursed more than $93,000 for excess rental arrears and payments issued directly to participants. Grantee made disbursements of nearly $330,000 for unsupported administrative salary expenses. Grantee did not adequately monitor subgrantees. 10
11 (7) Audit Findings HPRP Grantee Grantee advanced more than $138,000 in Program funds without support that the subrecipient had an immediate cash requirement. Grantee awarded more than $392,000 in contracts to two subrecipients of which the competitive selection was not adequately documented. Grantee did not adequately monitor subrecipients. (8) Audit Findings HPRP Grantee Grantee lacked documentation to support that it obligated nearly $215,000 before HUD s obligation deadline. Grantee s subrecipients did not always properly document client eligibility by verifying identification or income. Grantee did not develop policies and procedures for its Program. Grantee did not document monitoring of subrecipients. 11
12 (9) Audit Findings HPRP Grantee Grantee did not ensure that subrecipients properly documented eligibility for 13 of the 16 client files reviewed. The 13 files lacked initial and/or subsequent needs assessments, did not include appropriate evidence of income, and/or contained other miscellaneous errors. Grantee used more than $59,000 in Program funds for the 13 clients. Office of Audit s Affirmative Civil Enforcement Actions 12
13 False Claims Act Title 31, United States Code, section 3729, provides federal agencies, which are the victims of false or fraudulent claim paid or approved by the Government, with a civil remedy to recompense such agencies for losses resulting from such claims. The civil penalty includes a fine of approximately $10,000 plus three times the amount of damages the Government sustains. Program Fraud Civil Remedies Act Of 1986 Title 31, United States Code, section 3801, Program Fraud Civil Remedies Act of 1986, provides federal agencies, which are the victims of false, fictitious, and fraudulent claims and statements, with an administrative remedy to recompense such agencies for losses resulting from such claims and statements; to permit administrative proceedings to be brought against persons who make, present, or submit such claims and statements; and to deter the making, presenting, and submitting of such claims and statements in the future. 13
14 Departmental / Management / Employee Responsibilities Report to OIG Suspected violations of laws, rules, or regulations Gross mismanagement Waste of funds Abuse of authority Cooperate during audits and investigations OIG Internet Web Sites Office of the Inspector General Semi-annual reports to Congress HUD-OIG Hotline Call ; Tuesdays, Wednesdays, and Thursdays between the hours of 10:00 AM and 2:00 PM ET. 14
15 Address/Contact Information Brent G. Bowen, CGAP Assistant Regional Inspector General for Audit U.S. DEPT. OF HUD-OIG 77 West Jackson Boulevard Suite 2201 Chicago, Illinois Phone: (312) Fax: (312) Questions? 15
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