Improvements are Needed in HUD’s Fraud Risk Management Program

We audited the U.S. Department of Housing and Urban Development’s (HUD) fraud risk management program at the enterprise and program-office levels and assessed its overall maturity.  Our objective was to determine HUD’s progress in implementing a fraud risk management framework at the enterprise and program-office levels that encompasses control activities to prevent, detect, and respond to fraud. The Antifraud Playbook established by the Chief Financial Officers Council and the U.S. Department of the Treasury assess maturity of an agency’s fraud risk management program in four phases: (1) culture, (2) identifying and assessing fraud, (3) preventing and detecting fraud, and (4) turning insight into action.  We found that in all four phases HUD’s fraud risk management program was in the early stages of development, or at an “ad hoc” maturity level.  HUD’s program is still in its infancy because HUD had not previously dedicated sufficient resources to lead and implement fraud risk management activities.  Although HUD has recently taken steps to mature its program, HUD needs to commit resources to enhancing antifraud controls and promoting a culture of fraud risk management. Without improvements to its program, HUD may miss opportunities to identify and eliminate fraud vulnerabilities, leaving its funds and reputation at risk. We recommend that the Chief Risk Officer (1) perform a complete agency-wide fraud risk assessment and develop a plan to improve the maturity of HUD’s fraud risk management program; (2)  communicate to program staff the differences between HUD’s processes for enterprise risk management, Payment Integrity Information Act of 2019, and financial risk management risk assessment and how those processes relate to HUD’s fraud risk management program; (3) develop policies, procedures, and strategies for collecting and analyzing data to identify fraud within HUD’s programs, promote fraud awareness, and develop antifraud risk mitigation tools.  We also recommend that the Chief Financial Officer determine and seek to fulfill an appropriate level of dedicated staff resources to administer HUD’s enterprise and fraud risk management programs effectively and increase fraud risk awareness and strengthen antifraud controls in HUD’s program offices.