Federal Reports

We audited the U.S. Department of Housing and Urban Development’s (HUD) Office of Community Planning and Development’s (CPD) monitoring of grantees’ compliance with civil rights requirements. Our audit focused on the Community Development Block Grant (CDBG) and the HOME Investment Partnerships Program (HOME). Our audit objective was to assess the extent to which CPD monitored civil rights compliance in its program activities.

CPD could improve its civil rights compliance monitoring reviews. Specifically, CPD performed civil rights monitoring reviews for 2 percent of the CDBG and HOME grantees it monitored in fiscal year 2023. CPD suspended its limited civil rights monitoring in fiscal years 2021 and 2022 pending the Affirmatively Furthering Fair Housing (AFFH) rules. In fiscal year 2023, it resumed its limited civil rights monitoring. However, guidance issued by management did not instruct staff to conduct civil rights monitoring, which led to confusion among field staff. In addition, CPD could improve its monitoring by requiring its field staff to fully complete the CPD Handbook 6509.2, chapter 22, civil rights monitoring checklists while conducting remote monitoring. Without clear guidance and in depth monitoring reviews, CPD could miss opportunities to identify errors in grantees’ policies, procedures, and practices related to nondiscriminatory responsibilities in CPD programs, thus overlooking the potential to communicate fair housing concerns to HUD’s Office of Fair Housing and Equal Opportunity (FHEO) for resolution.

We recommend that HUD’s General Deputy Assistant Secretary for Community Planning and Development coordinate with FHEO to implement training for civil rights monitoring reviews. Additionally, CPD should (1) ensure that training on civil rights monitoring reviews is regularly provided to CPD staff (such as quarterly, semiannually, etc.); (2) implement updated guidance or protocols for monitoring civil rights compliance and require CPD staff to incorporate civil rights monitoring into the risk analysis process; and (3) develop guidance clarifying the use of the exhibit for on-site, hybrid, and remote monitoring to ensure a full review  of grantees’ compliance with civil rights requirements, and incorporate this guidance into training developed as a result of the first recommendation. HUD took steps during the audit to implement the second recommendation.

The objective of our inspection was to review the U.S. Department of Education’s (Department) administration of its reasonable accommodation program. This included determining whether reasonable accommodation requests were processed timely and in accordance with applicable policies and procedures. We found that improvements are needed in the Department’s processing of reasonable accommodation requests. Specifically, we found that the Department did not always process employee reasonable accommodation requests in accordance with relevant policies and procedures or maintain adequate documentation to allow for a determination of whether it complied with these policies and procedures, including those related to processing timeframes. In addition, we found that the Department did not adequately process applicant reasonable accommodation requests to ensure that accommodations were only provided to applicants with a qualifying disability. We also found that the Department does not have adequate processes to track and report on reasonable accommodation requests. The processes used by the Department do not ensure that all requests are captured, that data specific to the requests is adequately tracked, and that data is properly reported. We also noted issues with the quality of the data included in spreadsheets used by the Department to track and report on reasonable accommodation requests.

In an effort to increase transparency and accountability in the use of Federal funding in program activities, Federal law and guidance requires the U.S. Department of Housing and Urban Development (HUD) and its prime recipients to ensure that complete and accurate subaward data is posted on USASpending.gov.  We audited HUD to determine whether the prime award recipients of HUD funding met all of the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements for their subawards on USASpending.gov, including the amount of the subaward and a description of the products or services provided.  

We found that HUD’s prime award recipients of the Offices of Community Planning and Development (CPD) and Office of Lead Hazard Control and Healthy Homes (OLHCHH) programs did not always report their subawards of $30,000 or greater as required by FFATA.    Specifically, 25 prime awards in CPD programs and 10 prime awards in OLHCHH programs from 2 separate statistical samples of 70 prime awards made at least 1 subaward that they did not report to USASpending.gov.  Additionally, we found that 31 of 68 sampled subawards under the CPD programs were noncompliant with subaward reporting requirements, primarily because the subaward description was not adequate to provide the stakeholders with an understanding of the purpose of the awarded funds.   HUD’s prime award recipients lacked knowledge of the FFATA subaward reporting requirements due to insufficient guidance and oversight by HUD program offices and lack of an enterprise-level policy.  This noncompliance impairs the transparency and accountability of Federal spending, limiting stakeholders’ ability to fully evaluate the use of Federal funds within their communities.