Open Recommendations

We recommend that the Chief Financial Officer enhance existing policies to establish a formal grant accrual risk management framework to help ensure consistent standards across HUD with regard to the development, review, and execution of the grant accrual and validation.

We recommend that the Deputy Assistant Secretary for Operations of Community Planning and Development enhance CPDs existing Grant Accrual Standard Operating Procedures to strengthen governance within CPD and to effectively work within the framework established by the OCFO in recommendation 1A. The updated procedures should include increased ownership and oversight over the reviews, authorizations, approvals, and changes to the CPD grant accrual estimates and methodology.

The Railroad Retirement Board's Bureau of Information Services should review and update its policy to routinely maintain its Record Disposition Schedule to ensure all the required and necessary financial/nonfinancial data is retained, specifically for its benefit payments to allow management to support its financial activity and support its requirement to obtain an audit of the Railroad Retirement Board's financial statements.

The Railroad Retirement Board's Bureau of Information Services should review and update the entirety of the Railroad Retirement Board Records Disposition Schedule including the removal of items that are no longer relevant.

The Railroad Retirement Board's Office of Programs should, in coordination with the Bureau of Field Service, determine, develop, and document policies and procedures including end-to-end business processes for its Railroad Retirement Act annuity payments. Those procedures should include: (a) an implementation of a checklist when reviewing and accepting employee applications for benefits payments that must be signed by the appropriate preparer and reviewer; (b) requirement that all eligibility documentation is complete and accessible; and (c) the development of an in-depth guide that outlines how the Payment Rate Entitlement History (PREH) completes the benefit payment calculations.

The Railroad Retirement Board's Bureau of Fiscal Operations, Audit and Compliance Section should perform an assessment of the Railroad Retirement Board's internal control program, identify the gaps, and implement remediation actions to address the documentation, implementation, and assessment gaps identified.

The Railroad Retirement Board's Bureau of Fiscal Operations should implement a process to ensure both accounting and financial reporting processes Accounting Procedures Guides are reviewed and updated periodically to support its accounting and financial reporting processes.

The Railroad Retirement Board's Bureau of Fiscal Operations should implement a process to ensure the review and approval of Accounting Procedures Guides are properly documented with a date stamp of when the Audit Program Guides were approved along with an authorizing official's signature indicating the approval.

The Railroad Retirement Board's Bureau of Fiscal Operations should maintain a master list of all Accounting Procedures Guides for tracking and archival purposes.

The Railroad Retirement Board's Bureau of Fiscal Operations should withdraw and archive outdated Accounting Procedures Guides that are no longer followed or needed.

The Railroad Retirement Board's Office of Administration should develop, implement, and document the necessary standard operating procedures to establish an effective control environment, along with the end-to-end business processes and quality assurance process to verify all balances recorded are supported by underlying source documentation. At a minimum, the procedures should include establishing and maintaining relationships with key business process owners, including sub-processes, across the Railroad Retirement Board to maintain all relevant documentation for undelivered obligations in a central location in the Financial Management Integrated System (FMIS).

The Railroad Retirement Board's Office of Administration should develop training or reference guides to teach users of the Financial Management Integrate Systesm (FMIS) to properly attach supporting documentation when recording obligations in FMIS.

The Railroad Retirement Board's Office of Administration should analyze Undelivered Orders balances quarterly to verify balances are still valid for obligations that are open for an extended period after the end of the period of performance. At a minimum, continue the quarterly analysis until the Office of Administration has determined the updated internal controls as effective.

The Railroad Retirement Board's Bureau of Fiscal Operations should develop and adhere to the standard operating procedures for the fluctuation analysis on all financial statements for every quarter of the fiscal year.

The Railroad Retirement Board's Bureau of Fiscal Operations should develop and implement effective controls necessary to ensure transactions recorded are United States Standard General Ledger compliant.

The Railroad Retirement Board's Bureau of Fiscal Operations should assess the training necessary to ensure learning objectives are met and the required skills obtained by Bureau of Fiscal Operations management and staff to ensure compliance with Treasury's United States Standard General Ledger.

The Railroad Retirement Board's Office of Administration should develop, implement, and document the necessary standard operating procedures to establish an effective control environment. along with the end-to-end business processes and quality assurance process to ensure these undelivered orders are supported with underlying source documentation with the intent to verify the agency is Antideficiency Act compliant.

The Railroad Retirement Board's Office of Administration should assess the training necessary to ensure established policy and procedures for records management are communicated and effectively implemented to comply with the Antideficiency Act.

Design and implement controls to ensure the population used in the review and follow-up of nonreporting loan status reports or loan status reports with errors is complete and accurate.

Determine enforceable actions and controls to hold lenders accountable for submitting loan status reports timely and correctly.

Assess the sufficiency of implemented controls to monitor incomplete or inaccurate PPP lender loan status reports on an ongoing basis, including the identification and resolution of the root causes of reporting noncompliance.

Design and implement an automated system control to accurately reduce the outstanding principal balance after the processing of all forgiveness payments.

Perform a thorough review of the outstanding PPP loan guarantees and determine the impact on the outstanding guarantee and eligibility for forgiveness of loans determined to not be in conformance with the related legislation and program’s terms.

Design, implement, and document an effective PPP forgiveness review process for loan guarantees that were forgiven that addresses both the eligibility and the accuracy of the loan approval and forgiveness amounts.

Design and implement an effective funds recovery plan to ensure PPP funds disbursed on behalf of ineligible recipients are recovered and reported accurately in a timely manner. The plan should include an effective process to provide the information necessary to the Office of Performance, Planning, and the Chief Financial Officer to record any required accounting adjustments.