Open Recommendations

We recommend that the Director of CPD's Office of Disaster Recovery develop and implement internal controls to ensure that grantees completely and accurately report non-Federal match activities in DRGR.

USAID/Pakistan determine the allowability of $43,418 in unsupported questioned costs detailed on pages 22 to 23 of the audit report and recover any amount that is unallowable.

USAID/Pakistan determine the allowability of $382,115 in questioned costs ($330,782 ineligible and $51,333 unsupported), as detailed on pages 17 to 19 of the audit report and recover any amount that is unallowable.

(U) Rec. 1: Recommendation is Classified.

(U) Rec. 1: Recommendation is Classified.

Update its QC plan and related processes and procedures to align with requirements for loan selection, including maintaining data and documentation showing how sample sizes and loan selections were determined.

Update its QC plan and related processes and procedures to align with requirements for (1) loan file reviews and reverifications of borrower information, (2) mitigation of findings, and (3) reporting findings to HUD when required.

Demonstrate that its training for staff and management has been updated to reflect changes made to its QC plan and related processes and procedures in response to recommendations 1A and 1B, and to cover the underlying HUD requirements for lender QC programs, and provide proof of training to HUD.

Conduct up to 588 additional post-closing QC reviews to meet sample size and composition requirements and submit the results to HUD, including all findings of fraud or material misrepresentation, along with any other material findings that it is unable to mitigate. If required, CMG should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Review the 276 EPD loans not previously selected for review and submit the results to HUD, including all findings of fraud or material misrepresentation, along with any other material findings that it is unable to mitigate. If required, CMG should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Evaluate its QC files for the 242 loans in which it identified material findings to confirm whether it self-reported to HUD all findings of fraud or material misrepresentation, along with any other material findings that its records did not show have been acceptably mitigated. If required, CMG should execute indemnification agreements or reimburse claims paid to help protect the FHA insurance fund from unacceptable risk.

Provide indemnification agreements or documentation to support the eight loans in which it identified fraud, material misrepresentations, or other material findings that it did not acceptably mitigate or self-report to HUD. Implementation of this recommendation will protect the FHA insurance fund from an estimated loss of $639,397.

We recommend that the Centers for Disease Control and Prevention: Develop, implement, and maintain a centralized repository to store required documentation pertaining to PEPFAR funds that are redirected due to a pandemic or other emergency.

We recommend the FSA Chief Operating Officer assess the feasibility and appropriateness of implementing a managerial cost accounting system in consultation with relevant Department officials, the Office of Management and Budget, and other Federal agencies, such as those highlighted in the report referenced above.

We recommend the FSA Chief Operating Officer evaluate the financial information requirements for FSA’s initiatives and projects and determine if FSA’s existing information systems support the reporting of financial information consistent with the expectations of external stakeholders.

We recommend the FSA Chief Operating Officer, in coordination with the Department of Education's Budget Director, ensure that spend plans and quarterly updates are submitted timely and comply with requirements.

The TAS, Executive Director, Systemic Advocacy, should ensure that collaborative teams have measurable outcomes to track program effectiveness.

The TAS, Executive Director, Systemic Advocacy, should develop and implement a quality review process for collaborative teams.

The TAS, Executive Director, Systemic Advocacy, should develop and implement a method to monitor collaborative teams through a dashboard view.

The TAS, Executive Director, Systemic Advocacy, should develop guidance to ensure consistent executive oversight for collaborative teams.

The TAS, Executive Director, Systemic Advocacy, should develop additional performance measures to assess whether systemic advocacy projects are effective in addressing systemic issues.

The TAS, Executive Director, Systemic Advocacy, should ensure that management addresses staffing issues and timely reassigns inventory when delays are identified in the SAMS issue review.

The TAS, Executive Director, Systemic Advocacy, should analyze trends in issues raised in SAMS to help ensure that emerging issues are identified and addressed before they become more widespread.

The TAS, Executive Director, Systemic Advocacy, should revise guidance to contain clear criteria for the SIRE project manager to identify emerging systemic issues submitted to SAMS, including developing a method to track and monitor.

The TAS, Executive Director, Systemic Advocacy, should develop a system to track and monitor systemic issues closed when additional monitoring is needed to ensure that the issue is addressed.