Federal Reports

We audited the Kentucky Commission on Human Rights’ fair housing complaint intake process. We initiated this audit based on an internal risk assessment of Fair Housing Assistance Program agencies’ challenges. Our audit objectives were to (1) determine the extent to which the Commission processed fair housing inquiries within 30 days and (2) evaluate its reasons for closing fair housing inquiries.We were unable to determine the extent to which the Commission processed fair housing inquiries within 30 days due to a lack of supporting documentation. Also, the Commission could not provide evidence that would have allowed us to determine whether fair housing inquiries were properly closed. In addition, the Commission did not have clarity on what inquiries should be recorded in the U.S. Department of Housing and Urban Development’s (HUD) Enforcement Management System (HEMS) or what type of documents should be recorded in that system to support closure decisions. These conditions occurred because the Commission lacked staffing for its housing intake process, lacked an effective system to track the processing of inquiries, and was not always able to retrieve documents because some emails were lost. Also, the Commission did not have a record retention policy for its intake, and its staff was inadequately trained for recording intake data in HEMS. As a result, the Commission could not consistently provide assurance to its customers that it properly processed and closed inquiries from complainants in a timely manner. If complainants’ alleged discrimination is not addressed properly and in a timely manner, the Commission may not help to stop ongoing discrimination, hold those responsible for their actions, and deter future discrimination.We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to (1) update its intake policy and procedure to clarify which inquiries are to be recorded in HEMS; (2) develop an internal agency intake training guide, distribute it to all agency housing staff members, and ensure that all intake staff members participate in HUD-approved training related to intake; (3) implement a record retention policy to ensure that decisions on inquiries are sufficiently supported; (4) implement a plan to ensure that it has sufficient staff to meet its obligations under the Fair Housing Assistance Program cooperative agreement; and (5) implement a system to better track the intake and processing of potential fair housing inquiries.

What We LookedWe performed a quality control review (QCR) on the single audit that MSL CPAs and Advisors performed for the Greater Orlando Aviation Authority’s (GOAA) fiscal year that ended September 30, 2022. During this period, GOAA expended approximately $178 million from U.S. Department of Transportation (DOT) programs. MSL determined that DOT’s major program was the Federal Aviation Administration’s Airport Improvement Program. Our QCR objectives were to determine whether (1) MSL’s audit work complied with the Single Audit Act of 1984, as amended, the Office of Management and Budget’s Uniform Guidance, and the extent to which we could rely on the auditor’s work on DOT’s major program and (2) GOAA’s reporting package complied with the reporting requirements of the Uniform Guidance. What We FoundMSL complied with the requirements of the Single Audit Act, the Uniform Guidance, and DOT’s major program. We found nothing to indicate that MSL’s opinion on DOT’s major program was inappropriate or unreliable. However, we identified deficiencies in MSL’s audit work that require correction in future audits. Accordingly, we assigned MSL a rating of pass with deficiencies.

The U.S. Department of Housing and Urban Development’s (HUD) Office of the Chief Human Capital Officer (OCHCO) and the Office of Departmental Equal Employment Opportunity (ODEEO) both have responsibilities related to increasing the percentage of employees who identify as Hispanic or Latino. HUD provides an Annual Equal Employment Opportunity Program Status Report, also known as the Annual Management Directive 715 Report (MD-715), to the U.S. Equal Employment Opportunity Commission. In HUD’s fiscal year (FY) 2022 MD-715 and FY 2021 and FY 2022 Annual Reports on Hispanic Employment, HUD described 14 primary initiatives related to the recruitment of individuals who identify as Hispanic or Latino. The initiatives fall into four categories: barrier analysis, collaboration and partnerships with stakeholders, marketing and outreach, and applicant flow data. In addition to these initiatives, HUD described several other efforts that OCHCO and ODEEO had completed or planned related to increasing the percentage of individuals who identify as Hispanic or Latino. OCHCO and ODEEO collaborated quarterly, and ODEEO presented participation rates at quarterly briefings with general deputy assistant secretaries. OCHCO and ODEEO also hired new staff and filled vacant positions. Additionally, OCHCO established a recruitment event calendar and initiated the procurement process for technology-based recruitment tools, while ODEEO leveraged minority-serving and Hispanic-serving institution databases.We found that OCHCO and ODEEO faced challenges with determining the impact of recruitment efforts related to individuals who identify as Hispanic or Latino. No HUD-wide standard existed for how to measure the success of recruitment efforts. During interviews, both OCHCO and ODEEO officials stated that they considered success to be an increase in participation rates, which is the number of employees who identified as Hispanic or Latino in HUD’s total workforce, and spreading the word about HUD as an employer. Additionally, OCHCO was unable to tie a specific hire to a specific recruitment effort.OCHCO began tracking recruitment events it attended or planned to attend in February 2022 but did not track all recruitment efforts from other HUD program offices or their respective field offices. Collecting and maintaining complete information about all recruitment efforts, as well as being able to measure the impact of those efforts, are crucial to measuring the success of the recruitment process.HUD’s applicant flow data, which is information collected about applicants' demographics, such as race and ethnicity, have only been available since FY 2022 due to HUD’s transition to a new system. This means that OCHCO has not yet determined whether analyzing applicant flow data could help measure the impact of recruitment efforts. OCHCO plans to organize and analyze applicant flow data as more data become available. OCHCO also faced data limitations related to its race and national origin (RNO) data. We identified a risk that the RNO data might not give OCHCO an accurate account of HUD’s workforce because the data do not include a category for those employees who chose not to identify their RNO, as providing RNO data is voluntary.We offer three recommendations to improve OCHCO’s ability to determine the impact of recruitment efforts and to collect information about recruitment efforts across all HUD program offices and their respective field offices.