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Brought to you by the Council of the Inspectors General on Integrity and Efficiency
We recently issued an audit report on the City and County of Honolulu’s (City) fraud risk management practices, which determined the grantee did not adequately develop a fraud risk management framework for the Coronavirus Aid, Relief, and Economic Security (CARES) Act funding provided for the Emergency Solutions Grant (ESG) program to prevent, detect, and respond to fraud (Audit Report No. 2024-LA-1002, issued August 6, 2024). This audit follows that recent work, in which we audited the City’s ESG CARES Act program with the objective of determining if improper payments existed.
The City made some improper payments in its ESG CARES Act program because it did not always follow HUD’s requirements. Specifically, the City and its subrecipients did not (1) determine that 233 landlord signing bonus payments totaling $714,512 were reasonable and necessary, (2) prorate the rent amount for partial months resulting in $51,235 in overpaid rent (projected to be $248,572 in overpayments based on our statistical sample), and (3) ensure there were no duplication of benefits for three program participants totaling $10,100. We also determined that HUD communicated draw deadline dates to grantees that were inconsistent with guidance it publicly issued, causing the City to draw $1.9 million in grant funds after the deadline. These conditions occurred because we determined that officials of the City and its subrecipients were not aware of some of HUD’s requirements for the ESG CARES Act program and did not have controls for preventing a duplication of benefits. In addition, HUD used a single draw deadline for grantees, which conflicted with the three separate expenditure deadlines that it established, but did not issue formal written notice so that all grantees, subrecipients, and the public would be aware of the single deadline. These results reduced the number of participants that could have been served by the program, intended to reduce or mitigate homelessness, and impacted the City’s ability to maintain program and payment integrity of the ESG CARES Act program. Although the ESG CARES Act program has concluded, the City could make some of the same types of improper payments in the annual ESG program and other HUD-funded programs it operates, since these programs allow expenses for similar activities.
We recommend that the Director of HUD’s Honolulu Office of Community Planning and Development instruct the City to (1) determine whether the $714,512 paid for 233 signing bonuses under the ESG CARES Act program were reasonable and necessary, (2) develop and implement written policies and procedures for the ESG program to ensure that rents are prorated for the first month for tenant-based rental assistance, (3) repay HUD from non-Federal funds $51,235 in overpaid rent to landlords, (4) develop and implement written policies and procedures to prevent duplication of benefits, and (5) review the rental assistance payments made for the ESG CARES Act program to identify other possible duplication of benefits with other rental assistance programs that the City operates.
We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of the Moving to Work (MTW) demonstration program. We also reviewed three of the 39 initial MTW public housing agencies (PHA) for compliance with the MTW program’s statutory requirements. We selected the three PHAs for review based on our analysis of risk factors for initial MTW PHAs. Our objective was to (1) assess HUD’s monitoring of initial MTW PHAs’ compliance with the statutory requirements of the MTW demonstration program, which includes HUD’s confirmation of PHAs’ activities and related outcomes and (2) determine whether the selected PHAs complied with three of the statutory requirements (creating a reasonable rent policy that encourages employment and self-sufficiency, continuing to assist substantially the same number of eligible families, and maintaining families of similar sizes as the PHA would have if it had not participated in the demonstration program). Further, we reviewed the PHAs’ activities to assess their established metrics and reported outcomes related to the statutory objectives.
We found that HUD’s monitoring of PHAs’ MTW demonstration programs had weaknesses. Specifically, HUD relied on PHA self-reported data and certifications to determine full compliance with the statutory requirements and did not confirm program activities. We determined that two of the three selected PHAs complied with the statutory requirements that we reviewed. However, (1) one PHA did not always comply with the statutory requirement of serving substantially the same number of families as it had before joining the program, which HUD had identified through its monitoring; and (2) two PHAs’ reporting of local non-traditional households (LNT), which impacts that same requirement, had errors and were not supported. Further, all three PHAs did not always use appropriate metrics when assessing program activities and related outcomes. Lastly, two PHAs did not consistently maintain support for their program activities.
These issues occurred because HUD did not verify PHAs’ reported information due to limited resources and its systems did not capture PHA data needed to determine full compliance with the statutory requirements. Further, PHAs relied on third-party contractors to administer programs for LNT households without providing sufficient oversight to ensure that data reported for their MTW programs were accurate. Additionally, HUD's standard metrics did not always align with the PHAs’ program activities; therefore, the PHAs could not consistently meet benchmarks and accurately report outcomes to HUD. The PHAs also did not consistently maintain support for activities reported in their MTW reports because they believed that documentation was not needed or had relied on third-party contractors to develop and implement MTW activities on their behalf. As a result, HUD did not have complete and accurate information to determine PHAs’ full compliance with the statutory requirements and evaluate their MTW activities to make program decisions that could impact assisted housing, increase housing choices, and encourage low-income families to gain self-sufficiency.
We make several recommendations in this report to address the improvements needed in HUD’s monitoring of initial MTW PHAs to ensure accuracy and reliability of the information PHAs report to HUD related to program activities and outcomes. Specifically, we recommend that the General Deputy Assistant Secretary for Public Housing Investments require the MTW Program Office to develop and implement a review and verification process to ensure that data provided by MTW PHAs is accurate, complete, and supported, and ensure corrections or updates to PHA information are reflected in either restated or subsequent MTW annual reports. Further, establish a requirement for PHAs to retain supporting documentation for all data elements reported in their annual reports and program data not captured within HUD systems. Based on the changes HUD made related to its reporting requirements and performance metrics during this audit, we recommend that HUD conduct an analysis to determine whether those changes will allow PHAs and HUD to appropriately measure the benefits and impacts of PHAs’ MTW program to include whether additional changes are warranted to appropriately evaluate results of the MTW program. We also recommend that HUD develop and implement a review process to ensure that appropriate outcomes are assessed for each PHA’s local MTW program.
Financial Audit of USAID Resources Managed by Infectious Diseases Institute Limited in Multiple Countries, Under Multiple Awards July 1, 2024, to June 30, 2025
Audit of the Office of Justice Programs Victim Assistance Funds Subawarded by the Vermont Center for Crime Victim Services to Disability Rights Vermont, Inc., Montpelier, Vermont
This is an annual report to Congress regarding the U.S. Consumer Product Safety Commission’s (CPSC) efforts to prevent and protect trafficking victims in 2025 in accordance with the Trafficking Victims Prevention and Protection Reauthorization Act of 2022.
Our objective was to determine whether the U.S. Census Bureau has implemented adequate data collection procedures to ensure that American Community Survey (ACS) estimates are reliable. We found that the bureau did not effectively implement its data collection and quality control procedures to ensure that ACS estimates were reliable. We also found that the bureau did not sufficiently monitor ISR data collection procedures and did not effectively implement personal visit data collection and quality control procedures.