Disaster Recovery: HUD Should Take Additional Action to Assess Community Development Block Grant Fraud Risks

What GAO Found

GAO identified four categories of fraud risks facing the Department of Housing and Urban Development’s (HUD) Community Development Block Grant – Disaster Recovery (CDBG-DR) from 2007 to 2020, including risks from contractors, disaster recovery applicants, grantees, and others, as shown below. In total, we identified 78 cases from Department of Justice (DOJ) public announcements and 110 HUD Office of Inspector General (OIG) enforcement cases. For example, in 2012 following Hurricane Sandy, a New Jersey couple applied for disaster assistance and fraudulently received $79,000 in CDBG-DR funds, according to HUD OIG records. The couple was convicted of conspiracy, falsification, and theft and was sentenced to 5 years imprisonment. The funding was for a seaside property they fraudulently claimed was their primary residence, but was later determined to be a summer vacation home that was ineligible for assistance. GAO also found that the CDBG-DR operates in a decentralized risk environment that may make it vulnerable to fraud since CDBG-DR funds flow through a number of entities before reaching their intended beneficiaries. In addition, the risk environment in which CDBG-DR operates may contribute to negative financial impacts, such as improper payments. Fraud can have nonfinancial impacts as well, such as fraudulent contractors obtaining a competitive advantage and preventing other businesses from obtaining contracts.

Fraud Risks of Department of Housing and Urban Development’s (HUD) Community Development Block Grant – Disaster Recovery (CDBG-DR)

HUD has taken some steps to assess fraud risks agency-wide. For example, HUD conducts an agency-wide assessment of risks through a Front-End Risk Assessment, which also considers fraud risks. In 2020, HUD redesigned its agency-level approach to evaluate fraud risks through its Fraud Risk Management Maturity Model. While HUD has taken some steps to assess fraud risks agency-wide, GAO found that HUD has not conducted a comprehensive fraud risk assessment of CDBG-DR, as called for in GAO’s Fraud Risk Framework. Further, HUD’s current fraud risk approach does not involve relevant stakeholders such as grantees. Leading practices include tailoring the fraud risk assessment to the program and also involving relevant stakeholders responsible for the design and implementation of the program’s fraud controls in the assessment process. Ensuring that a fraud risk assessment is completed specifically for CDBG-DR may provide greater assurance that HUD addresses CDBG-DR fraud risks, including ones identified in this report.

Why GAO Did This Study

In response to a historic string of natural disasters, Congress appropriated approximately $39.5 billion in CDBG-DR grant funds in 2017 through 2019, with most of the funding designated for Texas, Florida, Puerto Rico, and the U.S. Virgin Islands. However, accompanying this unprecedented amount of funding is an increased vulnerability to fraud given that CDBG-DR involves multiple factors.

GAO was asked to review a range of disaster recovery issues following the 2017 disaster season. This report addresses: (1) the fraud risks and risk environment of CDBG-DR and their impacts; and (2) the steps HUD has taken to assess fraud risk agency-wide, and specifically for CDBG-DR, in alignment with leading practices. GAO reviewed DOJ public announcements and HUD OIG enforcement cases to identify CDBG-DR fraud risks. GAO assessed HUD’s procedures against leading practices in the Fraud Risk Framework. GAO interviewed HUD officials responsible for CDBG-DR and fraud risk assessment; and conducted site visits to Florida and Texas, selected partly for the amount of CDBG-DR funds they received, among other factors.

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Further, older individuals in the Southeast and West had much higher median mortgage and student loan debt, as well as student loan delinquency rates, in 2019 than in 2003. Percent of Households Age 50 or Older with Any Debt (Left) and Median Leverage Ratio (Right) for These Households, 1989 to 2016 Note: The bars above and below the lines represent the bounds of 95 percent confidence intervals. While older Americans' overall debt and debt stress decreased as they aged, those in low-income households experienced greater debt stress according to GAO's analysis of Health and Retirement Study (HRS) data, a nationally representative survey that follows the same individuals over time. The share of older households in this cohort that had debt continuously decreased as they aged, from about 66 percent of households in 1992 to 38 percent in 2016, and the median leverage ratio declined from about 19 to 13 percent over this period (see figure). However, low-income households in this cohort consistently had greater levels of debt stress than high-income households. This disparity in debt stress increased as these households aged. Estimated Percent of Households with Any Debt for Those Born in 1931-1941 (Left) and Median Leverage Ratio for Those Households from 1992-2016 (Right) Notes: The lines overlapping the bars represent 95 percent confidence intervals. According to experts GAO interviewed, differences in debt type (that is, credit card versus housing debt) and debt stress levels will have varying effects on the retirement security of different groups. For example, experts noted that credit card debt has negative implications for older Americans' retirement security because credit cards often have high, variable interest rates and are not secured by any assets. In contrast, an increase in mortgage debt may have positive effects on retirement security because a home is generally a wealth-building asset. Experts also said that older individuals with lower incomes and unexpected health expenses are likely to experience greater debt stress, which can negatively affect retirement security. Similarly, experts noted that the increased debt stress faced by low-income households is also faced by non-White households. Further, GAO's analysis of data from the Survey of Consumer Finances found that in 2016, debt stress levels were about two times higher for Black, Hispanic/Latino, and Other/multiple-race households than for White households. Experts GAO interviewed noted it is too early to evaluate the retirement security implications of the recession caused by the COVID-19 pandemic, in part because CARES Act provisions suspend or forbear certain debt payments. However, as with past recessions, the COVID-19-related recession may reveal any economic fragility among older Americans who, for example, lost jobs or cannot work because of the pandemic. Why GAO Did This Study GAO reported in 2019 that an estimated 20 percent of older American households aged 55 or older had less than $22,000 in income in 2016 and GAO reported in 2015 that about 29 percent of older households had neither retirement savings accounts (such as a 401(k) plan) nor a defined benefit plan in 2013. Older Americans held nearly half of the total outstanding debt in 2020—and these debts may affect retirement security. The Census Bureau projects the number of older Americans will increase. GAO was asked to report on debt held by older Americans. This report examines (1) how the types, levels, and outcomes of debt changed for older Americans over time, including for different demographic and economic groups; (2) how the types and levels of debt held by the same older Americans changed as they aged, including for those in different demographic groups; and (3) the implications of these debt trends for the general retirement security of older Americans and their families. GAO analyzed data from two nationally representative surveys–the SCF (1989 through 2016 data) and the HRS (1992 through 2016 longitudinal data)–and nationally representative administrative data from the Federal Reserve Bank of New York's CCP (2003 through 2019). These datasets were the most recent available at the time of GAO's analyses. GAO also reviewed studies and interviewed experts that GAO identified from these studies to further analyze the relationship between debt and retirement security. For more information, contact Kris Nguyen, (202) 512-7215 or NguyenTT@gao.gov.
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