Open Recommendations

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse its operating fund $107,692 from non-Federal funds for ineligible payments cited in this finding.

The Office of Programs should work with the management control review committee to revise management control documentation to be consistent with Government Accountability Office guidance for internal controls.

Support or repay from non-Federal funds any amounts that it cannot support, including $1,568,245 to its operating fund and $973,126 to its capital fund paid for (1) contracts that were improperly procured, (2) contract overpayments, or (3) contract payments made outside of the contract effective dates.

Develop short-term, intermediate, and long-term outcome performance measures, and additional output performance measures, with appropriate targets and timeframes, to measure the progress and results of theprogram.

Develop and publish a comprehensive management plan for EDSP, including estimates of EDSP’s budget requirements, priorities, goals, andkey activities covering at least a 5-year period.

Annually review the EDSP program results, progress toward milestones, and achievement of performance measures, including explanations for any missed milestones or targets.

Rec. 2.a: The DoD OIG recommended that the Deputy Commandant, Plans, Policies, and Operations, update the small arms accountability guidance in Marine Corps Order 5530.14A consistent with Marine Corps Bulletin 4440 and the updates to Marine Corps Order 8300.1C.

We recommend that the Director of HUD's Buffalo Office of Community Planning and Development reimburse from non-Federal funds $162,923 ($134,711 $28,212) expended on ineligible costs pertaining to street improvement projects not done and a duplicate reimbursement.

We further recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct the City to provide documentation to justify the $1,982,988 in unsupported costs associated with street improvement expenditures incurred between June 2007 and October 2009. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.

We recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct the City to provide documentation to justify the $20,143,219 ($4,902,754 $15,240,465) in unsupported transactions recorded in the CDBG program income account. Any receipts determined to be unrecorded program income should be returned to the CDBG program, and any expenditures determined to be ineligible should be reimbursed from non-Federal funds.

We further recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct the City to reimburse from non-Federal funds the $304,506 related to ineligible clean and seal code enforcement costs.

We further recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct the City to provide documentation to justify the $716,622 ($545,607 $24,069 $146,946) in unsupported clean and seal costs incurred so that HUD can make an eligibility determination. Any costs determined to be ineligible should be reimbursed from non-Federal funds.

Deobligate $279,245 in available funds associated with the ineligible CHDO and reprogram the funds for other eligible HOME activities, thereby putting the funds to better use.

KPMG recommends that the CIO develop and promulgate entity-wide security policies and procedures and assume more responsibility for the coordination and oversight of Program Offices in completing certification and accreditation and other information security requirements and activities.

KPMG recommends that the CIO identify common controls, control responsibilities, boundaries and interconnections for information systems in its system inventory.

Establish Procedures to Track Source of Facts Provided to the Public and Congress.

Require Identification of Federal Crime as Part of Documenting Predication.

Consider Revising Attorney General's Guidelines and DIOG to Reinstate Prohibition on Retention of Irrelevant First Amendment Material from Public Events.

Clarify When First Amendment Cases Should Be Classified as "Acts of Terrorism" Matters.

Develop a systematic approach to identify which states have outdated or inconsistent memorandums of agreements; renegotiate and update those Memorandums of Agreements using the Memorandum of Agreements template; and secure the active involvement and final,documented concurrence of headquarters to ensure national consistency.

Require the Authority to reimburse the net restricted assets fund account from non-Federal funds the $2,583,244 or the current amount owed.

The Office of Programs should develop a mechanism and procedures to update the unilateral freeze codes in the Payment Rate and Entitlement History system when the RRB obtains new information that changes the status of the freeze.

The Railroad Retirement Board's Bureau of Actuary should improve its documentation of the sampling employed in the Financial Interchange process by: Creating a single document that explains the process used to create the sampling frame and sample, including source database(s) used, the variables of interest, and the programs/media used to execute the process steps. The documentation should be written such that a person with the requisite skills, but without knowledge of the Financial Interchange calculations, could understand and replicate the sampling process.

The Railroad Retirement Board's Bureau of Actuary should test more than one post-stratification method and employ the method that minimizes the sampling error.

Require the Authority to account for $134,889 in tenant rent receipts or repay any unsupported amounts to its public housing operating program from nonfederal funds.