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Brought to you by the Council of the Inspectors General on Integrity and Efficiency
Federal Reports
Report Date
Agency Reviewed / Investigated
Report Title
Type
Location
Environmental Protection Agency
Audit of Procurement Risk Related to Construction Bidding Processes for Clean Water State Revolving Fund Projects
The U.S. Environmental Protection Agency Office of Inspector General performed this audit to determine whether the EPA’s annual appropriations and Infrastructure Investment and Jobs Act, or IIJA, funds in the Clean Water State Revolving Fund, or CWSRF, Program are at risk from procurement fraud related to construction bidding processes.
Summary of Findings
Federal dollars flowing through the CWSRF Program are at risk of procurement fraud in the construction bidding process. This risk primarily stems from two factors. First, the CWSRF Program’s structure as a partnership between the EPA and the states means that the states are primarily responsible for administering the state-level programs and projects. Second, the Uniform Guidance provides that loans from a pass-through entity to a subrecipient, such as loans made under a state revolving fund program, are not subject to the procurement standards.
The Tennessee Valley Authority’s (TVA) Enterprise Risk Management (ERM) business unit (BU) focuses on identifying and prioritizing enterprise risks. Annually, ERM leads the preparation of an enterprise risk portfolio, which includes risks across TVA, to aid leadership in strategic and business planning processes. Each BU includes their specific risks in the portfolio and documents the probability of occurrence, financial impact, and actions to manage the risk. TVA Nuclear included Asset/Equipment Failure – Low-Pressure Turbines risk in fiscal year (FY) 2025 ERM risk portfolio. The risk description stated that one or more low-pressure turbines fail to perform as designed and the details only included Units 2 and 3 at Browns Ferry Nuclear Plant (Browns Ferry). The actions to address the risk included installing new turbines and steam-path upgrades. Due to the importance of the reliability of TVA’s nuclear assets, we performed an evaluation of the risk mitigation of low-pressure turbines to determine if TVA was taking planned actions and measuring the impact of completed actions.
We determined TVA has taken actions or has plans in place to address the low-pressure turbine risk. TVA Nuclear has completed 11 of 15 mitigating actions identified for the risk. The 4 remaining actions are expected to be completed between 2028 and 2030. However, we determined TVA was not effectively measuring the impact of completed actions and a change in the risk scope on the probability of occurrence and financial impact. In addition, we identified some risk information was not documented accurately.
On October 10, 2023, the North Carolina General Assembly enacted the Clean Energy and Energy Efficiency Portfolio Standard (CEPS) requiring rural electric cooperatives and municipal electric suppliers in North Carolina to meet 10 percent of their energy needs through clean energy resources or energy efficiency measures. Additionally, North Carolina CEPS requires a percentage of retail sales be attributed to solar, poultry, and swine resources. The Tennessee Valley Authority’s (TVA) renewable energy certificates (REC) portfolio management process includes obtaining and retiring RECs to meet the requirements set forth in CEPS on behalf of its four local power companies (LPC) in the state. By September 1 of each year, TVA is required to file an annual compliance report for the prior year. Also, at that time, TVA files its compliance plans for the calendar year in which the plan is filed and the following 2 years. Due to increased power demand from data centers in North Carolina, we performed an evaluation to determine if TVA has adequate RECs to meet regulatory requirements in North Carolina for LPCs.
We found that TVA appropriately retired enough RECs to achieve compliance with North Carolina CEPS in 2024 and has enough RECs to meet the general, solar, and swine requirements for compliance year 2025. However, there is a risk that TVA will not be able to meet the poultry requirement for 2025. TVA has taken action to reduce this risk by submitting a request for offers in 2025 to purchase poultry RECs. Additionally, our review of the 2024 CEPS Compliance Report identified an understatement of RECs to be carried forward for use in future years.
Audit of the Office of Justice Programs Victim Assistance Funds Subawarded by the Alabama Department of Economic and Community Affairs to One Place Family Justice Center, Montgomery, Alabama
The National Oceanic and Atmospheric Administration's (NOAA's) Office of Marine and Aviation Operations (OMAO) is overseeing the construction of new ships, known as Class B ships, to replace hydrographic survey ships that are nearing the end of their planned service lives. Shipbuilding is a complex, multistage industrial process that requires structured oversight and controls at each phase. If the existing hydrographic survey ships are not replaced on time, NOAA has estimated a loss of 90 to 100 percent of its charting and mapping capability for the country’s Pacific Islands and Tropical Pacific and West Coast regions by 2028.
Our objective was to assess the management and oversight of the Class B ship acquisition by OMAO. We found that OMAO’s acquisition planning did not fully account for the resources, requirements, and processes that are necessary to perform Government Contract Quality Assurance (GCQA) management and oversight tasks for a new shipbuilding program. Specifically, for its Class B ship construction, OMAO (1) did not fully develop and implement the necessary controls to conduct GCQA, (2) did not identify or develop the necessary personnel, skills, and experience to conduct GCQA, and (3) did not have a system or method to record and track quality deficiencies and observations. Correcting these issues is critical to ensure that the ship construction meets contract requirements and an acceptable level of quality.
We made five recommendations to help OMAO implement its quality assurance program for ship construction, address shortfalls in workforce planning and technical oversight, and ensure that quality assurance oversight metrics during ship construction are tracked and stored. NOAA concurred with our recommendations and is working to implement them.
We audited the U.S. Department of Housing and Urban Development (HUD), Office of Residential Care Facilities’ (ORCF), oversight of Section 232 residential care facilities’ mortgage insurance program. We performed this audit because HUD-insured residential care facility loan defaults were rising. As of June 2024, 167 of the 3,670 HUD-insured Section 232 borrowers, or nearly 5 percent, defaulted on their mortgages. These 167 loans had an unpaid principal balance of more than $1.1 billion. Our audit objective was to assess the extent to which HUD identifies and mitigates risks in Section 232 residential care facility portfolios.
We reviewed 4 portfolios composed of 70 properties with 84 loans with a collective unpaid balance of more than $410.6 million. A portfolio is two or more borrower entities that are under common ownership and/or common control. HUD rated all 84 loans as troubled as of June 2024. Our review revealed that HUD ORCF can better recognize and address risks in its portfolios. Specifically, HUD ORCF is not promptly mitigating financial risks reported in borrowers’ audited financial statements. The audited financial statements disclosed that (1) borrowers withdrew funds from the properties when the properties did not have available surplus cash, (2) properties had cash deficiencies, and (3) properties did not generate sufficient cash flow to pay the current debts. HUD ORCF did not (1) receive the audited financial statements from all borrowers as required, (2) ensure that all borrowers fully developed their action plans to address risks that threaten the viability of a property, and (3) notify the Departmental Enforcement Center before the borrowers defaulted on their HUD-insured loans.
These conditions occurred because HUD ORCF staff lacked the time to conduct the detailed analysis needed. HUD ORCF stated that, due to the size and complexity, staff did not have the manpower to conduct the analysis required to identify whether borrowers improperly removed funds from the properties (unauthorized distributions). In addition, the staff decreased from 61 employees in October 2024 to 38 employees in May 2025. The average number of properties that staff managed changed from 60 - 80 to 165 - 200 properties each, which might increase the risk to the program. HUD ORCF workload management practices led to no team having insight into an entire portfolio. Although regulations require borrowers and operators to report risks to HUD at any time, regulations do not require borrowers and operators to develop and implement action plans to address these risks until defaults. As of July 2025, lenders could make insurance claims for 58 of 84 loans totaling more than $329.5 million.
We recommend that HUD’s ORCF Director of Asset Management (1) work with the borrowers and lenders to develop a plan to address the issues for each of the 58 troubled loans and implement corrective action for the 58 loans, thereby protecting HUD’s investment of more than $329.5 million; (2) quantify the amount of unauthorized distributions in the portfolio with 35 loans reported by the independent public accountant on the borrowers’ audited financial statements and require the borrowers to repay the amount of unauthorized distributions or pursue enforcement of the borrowers’ regulatory agreements by a written referral to HUD’s Departmental Enforcement Center (DEC); and (3) develop and implement policies and procedures to ensure that borrowers and lenders develop and implement action plans that properly list all specific risks at a property, identify the root causes of each risk, specify the actions to address each root cause, and establish a timetable to complete each action.
We also recommend that HUD’s ORCF Director of Asset Management (4) develop and implement policies and procedures to ensure that borrowers and lenders execute action plans that properly list all specific risks at a property, the root causes of each risk, the actions to address each root cause, and a timetable to complete each action; and (5) develop and implement policies and procedures to ensure that HUD account executives document each action plan, properly list all specific risks at a property, identify the root causes of these risks, specify the actions to address the root causes, establish timetables for completion, and document monthly progress towards completion of the actions in the Integrated Real Estate Management System (iREMS).