Open Recommendations

Develop processing centers pending actions performance measures with goals to reduce the pending actions backlog from year to year.

Establish timeframe targets for processing centers workloads to limit increases to improper payments caused by processing delays and the burden they place on beneficiaries.

Provide evidence that the owners corrected the 248 deficiencies for the 48 units with outstanding deficiencies. If the owners fail to make corrections, the Authority should implement its stop payment procedures and provide supporting documentation to HUD.

Implement a quality control process for monitoring its contracted inspectors to ensure that units meet HUD's requirements to prevent nearly $36 million in program funds from being spent on units that do not meet HQS over the next year.

Implement procedures and controls regarding its quality control inspections to ensure that the results of those inspections are appropriately used to evaluate and monitor the performance of the Authority's contracted inspectors and documentation is maintained on communications with the contractor on corrective actions taken to address recurring inspection deficiencies.

Implement procedures and controls regarding its stop payment process to ensure that it consistently (1) stops payments as required by its HCV Program administrative plan and HUD requirements, (2) verifies and documents the correction of deficiencies, and (3) maintains sufficient documentation to support the stop payment for each unit.

Implement controls over its inspection processes and procedures to ensure that emergency failures are properly identified, reinspected, and corrected within 24 hours in accordance with its HCV Program administrative plan or the housing assistance to the owner is stopped.

Work with its contractor to ensure that the contractor's inspectors receive training on how to properly identify and categorize life-threatening deficiencies.

Develop and implement policies and procedures that align with HUD's requirements and controls to ensure that owners follow the requirements of the LSHR.

Work with HUD's Office of Lead Hazard Control and Healthy Homes to provide technical assistance to the Authority's staff to develop and implement policies, procedures, and controls for managing cases of children with EBLLs to ensure compliance with the LSHR, including attempts to collaborate with public health departments to identify cases of EBLL in children under 6 years of age under its HCV Program and updating its policies and procedures accordingly.

Conduct route reviews for all routes in the Puerto Rico District, create a prioritized list of routes needing adjustments based on the reviews, and coordinate with Headquarters Delivery Operations to create a plan to perform the necessary adjustments.

Enhance the Commission’s internal controls related to oversight of third-party service providers and implement performance monitoring procedures. These procedures should allow for the effective tracking of the service providers’ actual deliverables against the requirements prescribed in the IAA.

Evaluate third-party service providers’ performance against the milestones and timeline expectations identified in the IAA or SLA. The evaluation mechanisms and tools should incorporate any performance metrics outlined in the IAA or SLA.

Enhance its procedures over the review of, and reconciliation between, the data on the Request for Personnel Action (SF-52) and the Notification of Personnel Action (SF-50) for the same personnel event, to ensure that the Commission detects and addresses discrepancies in a timely manner.

Implement measures to ensure that LC3 Solutions properly completes and processes SF-52s in accordance with the nature of the personnel event.

Implement measures to facilitate closer coordination with GSA CABS to ensure that it processes and approves SF-50s in a timely manner, and that it only makes retroactive approvals based on the conditions described in the OPM GPPA.

Implement a contract tracking system that will enable the contract administration team to perform a detailed analysis of small business awards in each of the small business categories and compare the award value for each category against the total value for all awards to ensure that the Commission can effectively monitor its award activities with regard to its small business procurement goals.

Implement a contract-writing system that integrates an industry-standard, automatically updated provision and clause database. The Commission should also have associated controls in place to ensure that the database is up to date and meets the pertinent acquisition regulations and statutory requirements.

Update its COWP policy to ensure that it has appropriately evaluated and assigned its warrant threshold designations. This evaluation should be based on the contracting.

Implement a more robust contracts tracking system that includes validating data against the source documents and ensuring that when an individual updates the tracking system, another individual reviews those updates. The frequency of the quality checks or data validation reviews required is contingent on the volume and complexity of the contracting activities.

The Under Secretary for Health requires facilities to review designated time for Maternity Care Coordinator caseload, and assigned collateral duties, to determine if additional staffing resources are needed to support Veterans Health Administration Maternity Care Coordination, and takes action as appropriate.

Ensure Veterans Benefits Administration staff use improved methodologies similar to the Office of Inspector Generals review to identify eligible veterans, readjudicate claims, and send outreach letters to potential Nehmer class members who could qualify for retroactive benefits under the National Defense Authorization Act.

Evaluate the feasibility of continuously monitoring incentive program participation at facilities with future electric vehicle and charging infrastructure deployments, to include conducting cost-benefit analysis and enlisting the possible use of contractors to support this action.

Formally define and document in writing ISOO’s monitoring methodology to address at a minimum program risk, staff responsibilities, and monitoring of program performance.

Develop and implement written internal policies and procedures that provide clear guidelines and timelines for CUI program management and oversight processes.