Federal Reports

Why We Did This Report

The U.S. Environmental Protection Agency Office of Inspector General conducted this audit to assess the EPA’s oversight of state subrecipient monitoring in the Clean Water State Revolving Fund Program, including the monitoring of subrecipients of Infrastructure Investment and Jobs Act funds.

Summary of Findings

While the annual review procedures for nondiscrimination laws, suspension and debarment, and single audit requirements follow statutory requirements, we found opportunities for the EPA to improve its oversight practices in the annual review steps devoted to subrecipient monitoring activities in these areas. The EPA provided CWSRF Program guidance that supported the three states that we reviewed in monitoring the subrecipients in their state CWSRF programs. The EPA could further support the states in their subrecipient monitoring activities by providing a guide of best practices for subrecipient monitoring and a best practices guide for helping equivalency subrecipients compliance.

We also made observations outside of our audit objective. The CWSRF capitalization grant terms and conditions could include a requirement that recipients and subrecipients must report violations of federal criminal law involving fraud, bribery, or gratuity violations to the OIG. The EPA could also encourage states to include a provision in their CWSRF loan agreements consistent with 2 C.F.R. § 200.113.

The objective of this evaluation was to determine whether the U.S. Consumer Product Safety Commission (CPSC) was in compliance with the Payment Integrity Information Act of 2019 (PIIA) for the fiscal year (FY) ended September 30, 2024. The Office of Inspector General retained the services of KPMG, an independent public accounting firm, to evaluate the CPSC’s FY 2024 PIIA compliance. This evaluation was performed in accordance with the Council of Inspectors General on Integrity and Efficiency’s Quality Standards for Inspection and Evaluation.

HUD did not comply with PIIA because it did not report compliant improper and unknown payment estimates for the Office of Public and Indian Housing’s Tenant-Based Rental Assistance (PIH-TBRA) program and the Office of Multifamily Housing Programs’ Project-Based Rental Assistance (MF-PBRA) program.   These were HUD’s two largest program expenditures, totaling more than $50 billion in fiscal year 2024.  This noncompliance is significant because this is the eighth consecutive year in which HUD has been unable to produce PIH-TBRA and MF-PBRA improper and unknown payment estimates, and that deficiency has contributed to HUD’s noncompliance with improper payment laws for 12 consecutive years.  

These programs present payment integrity challenges because they entail thousands of program administrators outside of HUD processing large volumes of payments using nonstandarized processes, and supporting documentation needed for testing is not maintained at HUD.  The lack of a detailed approach to resolve these systemic challenges, including coordination by leadership, has prevented HUD from making the progress needed to achieve compliance.  

 We also determined that HUD did not comply with the Do Not Pay Initiative (DNP) as required by the Payment Integrity Information Act of 2019 because it did not consistently use DNP for prepayment verification.  This occurred in large part because the computer matching agreement between HUD and Treasury, related to DNP, expired in 2019 and has still not been renewed.  Additionally, we found HUD’s governance of DNP implementation to be weak.  Without this computer matching process in place and because of weak governance around DNP implementation, HUD’s risk of improper payments increased.  At least $212 million of HUD funds were technically improper payments since the funds were paid to at least 11 entities that did not have an active registration on SAM.gov.