Open Recommendations

We recommend that HUD's Deputy Assistant Secretary for Single Family Housing require the lenders to support that the borrower for FHA case number 451-1165810 was not reimbursed for the cost of labor or indemnify the loan with an estimated loss amount of $83,715, based on the loss severity rate of 50 percent of the unpaid principal balance of $167,429 as of January 29, 2015.

Support that the repair conditions and comments indicated in the direct endorsement underwriter form, form HUD-54114, were satisfied for FHA case number 501-8198149. If the repair conditions and comments were not properly addressed, the lenders should indemnify the loan with an estimated loss amount of $39,367, based on the loss severity rate of 50 percent of the unpaid principal balance of $78,733 as of January 29, 2015.

Determine the number of 203(k) loans impacted by the incorrect loan-to-value ratio for mortgage insurance premium calculations and when applicable, reimburse borrowers or apply the overpaid premiums as credits toward borrowers' future premium payments.

Rec. 6: The DoD OIG recommended that the Army Deputy Chief of Staff for Personnel, the Chief of Naval Personnel, and the Air Force Deputy Chief of Staff for Manpower, Personnel, and Services ensure that programs of instruction for commissioned and noncommissioned officers include the updated guidance regarding religious accommodations contained in Department of Defense Instruction 1300.17.

Reimburse FHA borrowers $376,102 for the unallowable, misrepresented discount fees and $7,110 for fees that were not customary or reasonable.

Develop and implement written policies and procedures with an emphasis on increased controls toward the monitoring, tracking, underwriting, and evaluating of the Section 184 program. Implementing these controls would reduce the current high level of risk in the program and result in potentially $76,967,618 in funds to be put to better use (see appendix A).

Develop and implement policies and procedures for a standardized monthly delinquency report format that lenders must follow when submitting information to OLG.

Develop and implement policies and procedures to deny payments to direct guarantee lenders for claims on loans that have material underwriting deficiencies.

Develop and implement policies and procedures to ensure that OLG uses enforcement actions available under 12 U.S.C. 1715z-3a(g) for lenders that do not underwrite loans according to the Section 184 processing guidelines.

Ensure that only underwriters that are approved by OLG are underwriting Section 184 loans.

Develop and implement written policies and procedures for situations in which the borrower for a Section 184 loan is an Indian housing authority, a tribally designated housing entity, or an Indian tribe.

Reconcile the total list of guaranteed Section 184 loans to the complete loan file storage list and identify and locate any missing loan files.

Rec. 3.b: The DoD OIG recommended that the Commander of the Naval Supply Systems Command implement controls in the Defense Travel System to automatically route all travel orders for travel outside of the continental United States to transportation office personnel to check Patriot Express availability before booking commercial transportation.

Submit all supporting documentation showing the eligibility and propriety of $538,485 drawn from its treasury account or reimburse the HOPWA program line of credit from non-Federal funds.

Rec. 2: The DoD OIG recommended that the Assistant Secretary of the Navy (Financial Management and Comptroller) develop a process or system interface between Navy Enterprise Resource Planning and Wide Area Work Flow that provides timely processing of transactions and update the Department of the Navy's system business processes to ensure transactions are processed in compliance with the Statement of Federal Financial Accounting Standards 1.

Establish FedRAMP compliance guidelines and oversight for the Department, and ensure that each Operating Administration put plans in place to meet FedRAMP requirements.

The Office of Programs should ensure that Palmetto applies statistical analysis and stratified random sampling where practical to the high volume risk categories.

The Office of Programs should work with Palmetto and the Centers for Medicare and Medicaid Services to conduct a thorough cost benefit analysis that will identify the resources needed to maximize timely and efficient recovery of improper payments for chiropractic services over the five year recovery period.

The Office of Programs should work with Palmetto and the Centers for Medicare and Medicaid Services to recover the improper chiropractic service payments for the five year period, where determined to be cost effective based on an accurate cost benefit analysis.

The Office of Programs should work with Palmetto and the Centers for Medicare and Medicaid Services to share information identified during the post-payment reviews as appropriate with the Recovery Audit Contractors and Zone Program Integrity Contractors where it can be used to identify improper or fraudulent non-Railroad Medicare chiropractic service payments.

We recommend WCB develop and implement a plan that ensures the closure of pending appeals in a timely manner, and prioritizes the resolution of appeals filed 2010 and earlier.

Repay HUD $3,119,448 from non-Federal funds for program funds spent on ineligible participants.

Provide supporting documentation for $136,346 in program funds used for participants for whom eligibility could not be determined or repay HUD from non-Federal funds (see appendix D).

The Executive Committee should take all of the necessary steps to prepare and submit the required plans within the 90 day reporting requirement.

The Executive Committee should ensure that the necessary policies and procedures are developed and documented for the agency’s use for the preparation of a risk assessment process that meets Improper Payments Elimination and Recovery Act of 2010 requirements.