Department of Housing and Urban Development

Please note: Overpayment amounts recovered are reported in the year they were recovered, not the year they were identified. Therefore it is possible in some years to have a recovery rate greater than 100%.

Overpayment amount identified through recovery activities	$32.54 M
Overpayment amount recovered through recovery activities	$22.1 M
Recovery activities recovery rate	67.92 %
Overpayment amount identified through recovery audits	$7.84 M
Overpayment amount recovered through recovery audits	$3.37 M
Recovery audit recovery rate	42.98 %
Recovery audit target recovery rate	75.0 %
Overpayment amount identified for recapture	$40.38 M
Overpayment amount recovered	$25.47 M
Overpayment recovery rate	63.08 %

For internal offsets, over-claimed amounts (negative claims) occur when the mortgagee owes FHA. The Single-Family Claims Branch (SFCB) sends billing letters to lenders for the excess amounts claimed and tracks the receivables using the Accounts Receivables Sub-system (ARS). Receivables are established in SFCB’s ARS and identified by an FHA case number. Each FHA case number is further identified by Section of the Act (which is linked to the appropriate fund) and endorsement date. This later date identifies the cohort year. The Holder of record to which the claim funds were originally disbursed is identified in ARS as the debtor, by default. When the receivable is subsequently liquidated by funds remitted by a Mortgagee or by offset, the collected amount is posted to the previously identified FHA case number, Section of the Act, and cohort year.

If a payment is not received from a lender within 90 days, the receivable is offset against subsequent claims by the lender until the full amount of the receivable is satisfied. If a receivable is not satisfied within 120-150 days, it is referred to the FOC in Albany, NY for enforced collection actions. At that time, the FOC officially confirms acceptance of the transfer of an aged delinquent debt, and that receivables have been removed from the ARS with the notation that it has been referred to the FOC for recovery.
Another avenue by which improper payments are recaptured is through Post Claim Reviews for title II Single Family Insurance Claims. A statistical sample of settled claims is reviewed for compliance with FHA servicing and claim filing requirements. A report on findings, is prepared and issued to the individual mortgagee. Mortgagees can refute the findings by providing additional documents before a final report is issued. If the Mortgagee chooses to pay the monetary findings prior to HUD’s issuance of the final report, those funds are deposited to ARS, which applies them to the Mortgage Insurance (MI) fund. Upon issuance of the final report, it is referred to the FOC which establishes it as a receivable and tracks it until paid in full. If a lender is overpaid on a Multifamily claim, the Multifamily Claims Branch will demand the overage back from the lender. If the lender fails to respond to their demands, the debt is referred to the FOC for collection. Lastly, for Treasury Cross-Servicing, the collection of generic debt is governed by the Debt Collection Improvement Act and HUD policies (Title I and Other Debt Collection Guidance 4740.2). The Act requires federal agencies to refer eligible delinquent debts to Treasury (for Cross-Servicing and TOP) when the debt is 120 days delinquent.

The Treasury’s TOP allows federal agencies to report delinquent non-tax debt to the Treasury’s Bureau of the Fiscal Service (BFS). BFS performs computer matching with disbursement data and processes an offset when an appropriate match is determined. After referral, Treasury and its private collection agencies are responsible for contacting the debtor to collect the payment of the debt. The Treasury’s Cross-Servicing is a process used by BFS to refer the debt collection to a private collection agency, among other actions, to collect delinquent debts on behalf of Federal Agencies.

The FOC’s recapture process establishes receivables in DCAMS and issues a demand notice to the debtor(s). If the debt remains unpaid, DCAMS issues a “Notice of Intent” warning regarding enforced collection measures and informs the debtor regarding their due process rights. DCAMS automatically reports information to credit bureaus and CAIVRS. Penalty and administrative cost charges are also automatically assessed if warranted.

If the debt remains unpaid, it is referred to Treasury (within 180 days) for offset via the government-wide TOP and for direct collection action by Treasury and Treasury contracted private collection agencies. Treasury also initiates referral to the Department of Justice (DOJ) for civil litigation and/or initiates Administrative Wage Garnishment (AWG) action if they deem such action to be appropriate. If Treasury’s Cross-Servicing action is not successful, Treasury “returns” the debt to the FOC. If older than two years, the receivable is written-off and the case is reclassified “currently not collectible.” The FOC keeps the case open if offset via TOP appears fruitful or if other collection measures are applicable (e.g., AWG action by HUD). Otherwise, the FOC terminates collection action, closes the case, and the system issues an IRS Form 1099C “Cancellation of Debt,” the following January if appropriate. Write-off, Termination, close-out, and 1099C issuance can also occur at any point in the above collection cycle if determined appropriate (e.g., debtor is discharged as bankrupt).

Collections from debtors to HUD go to the Treasury Lockbox Network or Pay.gov. Collections from debtors to Treasury or DOJ come to HUD via interagency transfer (i.e., Intra-Governmental Payment and Collection (IPAC)). No matter the route, all payments are posted to the receivable in DCAMS.

Methods currently used to recover overpayments identified in recovery audits

Salaries and Expenses
Administrative Offices - Other Contractual Services
Program Offices - Other Contractual Services
The Office of the Chief Human Capital Officer (OCHCO) Administrative and Budget Services manages Transit Subsidy payments.
For the Payroll, Benefits and Retirement Division (PBRD), OCHCO reviews the unpaid report to ensure all HUD employees are paid based on their certified timecard for the Personnel Office Identifier (POI) 4408. If erroneous payments were made due to an error in personnel and benefits, OCHCO then takes the necessary action(s) to rectify the mistake. For example, OCHCO collaborates with the BFS and the Department of Agriculture’s National Finance Center (NFC) to run all the necessary reports to determine where the discrepancy was made. Once the source has been identified, OCHCO corrects the issue or determines if it is feasible to correct the improper payment. Through the PBRD quality review process, overpayments are identified and validated. Once validated and corrected through the NFC database, the debt is generated, and the employee is notified of the indebtedness. After due process, the collection process is initiated.
Also, the Human Resources (HR) Division performs a quality review based on the personnel data generated from the NFC FOCUS report or NFC Reporting Center application for personnel and benefits actions. The report data is used to determine if there are any incorrect coverage plans, personnel data or duty locations which will cause an overpayment for the employee. If so, the History Correction Update Processing (HCUP) system is used to correct the error, which will automatically generate a bill if it is within twenty-six (26) pay periods. Outside of the pay period timeframe, HR will manually calculate the amount owed and enter the data to be submitted to NFC via the Special Payroll Processing System (SPPS). The employee will be informed of the indebtedness; and have an opportunity to setup a payment plan.
The Office of the Chief Financial Officer (OCFO) provides assistance and advice to HUD program budget offices on improper payroll payments and payroll corrections on an ad-hoc basis and upon request. For other than payroll payments such as travel payments, purchase card payments, contract payments, and Interagency Agreement (IAA) payments, program offices follow the Administrative Control of Funds Policies (Administrative Control of Funds Policies, 1830.2 REV-6) to ensure improper payments are prevented or detected and corrected and OCFO-Budget provides assistance to budget offices upon request. Reports run from HUD’s Financial System (Oracle Business Intelligence/OBI) suite of reports to include the Procurement Request Information System Management (PRISM) and Travel reports, and other payment systems (e.g., Invoice Processing Platform (IPP), Intra.gov, Concur), are used to identify, and sometimes, recover improper non-payroll Salaries and Expenses (S&E) payments. Most program offices have designated individuals to run and review payment reports for discrepancies and improper payments including unauthorized purchases in line with departmental and program office funds control policies. Additionally, program office Contracting Officer Representatives (CORs) ensure invoice payments are proper and made in line with contract guidelines through the use of reports ran through IPP and related OBI reports.
As part of the bi-weekly payroll projection process, OCFO-Budget runs reports from OBI’s repository of payroll reports and flags any payroll corrections or unusual payroll activities for program budget offices. Upon request and on an ad-hoc basis, OCFO-Budget provides assistance in the correction of improper payroll payments by running reports from OBI’s repository of payroll reports (Cost and Hours report) and providing data regarding payroll corrections to program budget offices and Treasury’s ARC.
Additionally, program Budget office’s work with ARC, HUD OCFO, and HUD’s OCPO HUD CPO in the payment recapture process as it relates to non-payroll S&E improper payments. For example, program budget office’s work with OCFO’s travel management staff on the recapture of improper payments.
The Administrative Control of Funds Policies Handbook outlines procedures and points to additional guidance program offices follow that can lead to the identification, recovery, and prevention of future improper payments.

Lead Hazard Reduction
During grant execution, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) reviews grantee invoices, vouchers and supporting documentation. If an improper payment is identified, the Government Technical Representative (GTR) or the COR, as applicable, provides fund recipients with documentation of the determination of the improper payment, the regulatory, grant-specific, and/or contractual basis for recovering the improper payment, a due date for recoupment, and a due-process opportunity to appeal. The appeal, if made, goes to the Grants Division Director (for grants) or the COR (for contracts), as applicable. Should the request not be appealed, or the appeal denied, and the funding recipient did not refund the improper payment, the matter would be referred to the OGC for action.
During the close-out of a grant, if it is determined that a financial error occurred, the grantee is asked to provide an explanation for the problem and, if required by the GTR, the grantee submits a check to resolve the financial shortfall. The COR forwards the check and a letter of explanation to the Budget Officer for the recapturing of funds.
In addition, the GTR includes a copy of the check and the letter of explanation with the close-out package to the Grants Officer. The Grants Officer documents the returned funds on form HUD-1044 (Assistance Award/Assistance). OLHCHH’s process assures quality spending and monitoring for reimbursable funding. The likelihood of improper reimbursements are low due to several reasons. OLHCHH is a reimbursement program; the funds distributed are for services that have already been completed and invoiced. Additionally, every three months, grantees submit information on work performed and provide a financial statement using the Federal Financial Report (SF-425), HUD-Part 3 Budget form, and supporting documentation. The SF-425, HUD-Part 3 Budget form, and the LOCCS VRS Request Voucher for Grant Payment (form HUD-27053) must match data in LOCCS and all totals must be the same. Under remote monitoring, a GTR performs a review to ensure accuracy, as needed. On-site monitoring is conducted once a year after a risk analysis is completed and/or high-risk is determined for each grantee. Poor performing grantees are required to submit weekly or monthly reports. During grant execution, the OLHCHH reviews grantee invoices, vouchers and supporting documentation. If an improper payment is identified, the GTR or the COR, as applicable, provides fund recipients with documentation of the determination of the improper payment, the regulatory, grant-specific, and/or contractual basis for recovering the improper payment, a due date for recoupment, and a due-process opportunity to appeal. The appeal, if made, goes to the Grants Division Director (for grants) or the COR (for contracts), as applicable. Should the request not be appealed, or the appeal denied, and the funding recipient did not refund the improper payment, the matter would be referred to the OGC for action.
During the close-out of a grant, if it is determined that a financial error occurred, the grantee is asked to provide an explanation for the problem and, if required by the GTR, the grantee submits a check to resolve the financial shortfall. The COR forwards the check and a letter of explanation to the Budget Officer for the recapturing of funds.
In addition, the GTR includes a copy of the check and the letter of explanation with the close-out package to the Grants Officer. The Grants Officer documents the returned funds on form HUD-1044 (Assistance Award/Assistance). OLHCHH’s process assures quality spending and monitoring for reimbursable funding. The risks of improper reimbursements are low due to several reasons. OLHCHH is a reimbursement program; the funds distributed are for services that have already been completed and invoiced. Additionally, every three months, grantees submit information on work performed and provide a financial statement using the Federal Financial Report (SF-425), HUD-Part 3 Budget form, and supporting documentation. The SF-425, HUD-Part 3 Budget form, and the LOCCS VRS Request Voucher for Grant Payment (form HUD-27053) must match data in LOCCS and all totals must be the same. Under remote monitoring, a GTR performs a review to ensure accuracy, as needed. On-site monitoring is conducted once a year after a risk analysis is completed and/or high-risk is determined for each grantee. Poor performing grantees are required to submit weekly or monthly reports.

Contracts/Grants (includes Single Family Upfront Grants)
Federal Finance Bank Direct Loans
Home Equity Conversion Mortgage Claims
Home Equity Conversion Mortgage Notes
Multi-Family Insurance Claims
Multi-Family Notes
Multi-Family Property
Single Family Claims
Single Family Property
Title I Notes
Title I Claims
Other Disbursements
The Office of Housing-Federal Housing Administration’s (HSNG–FHA) recovery audit program is part of its overall program of effective internal control over payments. Internal control policies and procedures establishes a system to monitor improper payments and their causes, and includes controls and actions for detecting, preventing, and recovering improper payments. On a recurring basis, these programs generate reports that identify potentially duplicate disbursements. These disbursements are researched, and recovery actions are initiated for payments deemed improper. As part of the recapture audit plan, internal control documents and files are reviewed, and post claim reviews are performed.
Under Title I and Other Debt Collection Guidance Handbook 4740.2, the Financial Operation Center (FOC) is primarily responsible for generic debt collection and customer service activities, including responding to debtor inquiries regarding pay-off, payment plans, compromises, disputes, and appeals. The debt referral package primarily consists of copies of legal documents, mortgages, deeds of trust, judgments and other recorded lien documents, lien assignment documents, repayment agreements, credit reports, correspondence to/from debtors, and compromise agreements and supporting documents.
The Debt Collection Asset Management System (DCAMS) is the application used to support the generic debt collection process. DCAMS is designed to automatically send collection letters, report delinquent debt to credit bureaus and HUD’s Credit Alert Interactive Voice Response System (CAIVRS), assess penalties and administrative costs, and refer eligible debts to the Treasury Offset Program (TOP) and Cross-Servicing. Based on predefined criteria and the status of that case as reflected in DCAMS data fields (not later than 180 days after the demand letter), DCAMS is consistently updated to prevent improper referral for TOP offset.
For internal offsets, over-claimed amounts (negative claims) occur when the mortgagee owes FHA. The Single-Family Claims Branch (SFCB) sends billing letters to lenders for the excess amounts claimed and tracks the receivables using the Accounts Receivables Sub-system (ARS). Receivables are established in SFCB’s ARS and identified by an FHA case number. Each FHA case number is further identified by Section of the Act (which is linked to the appropriate fund) and endorsement date. This later date identifies the cohort year. The Holder of record to which the claim funds were originally disbursed is identified in ARS as the debtor, by default. When the receivable is subsequently liquidated by funds remitted by a Mortgagee or by offset, the collected amount is posted to the previously identified FHA case number, Section of the Act, and cohort year.
If a payment is not received from a lender within 90 days, the receivable is offset against subsequent claims by the lender until the full amount of the receivable is satisfied. If a receivable is not satisfied within 120-150 days, it is referred to the FOC in Albany, NY for enforced collection actions. At that time, the FOC officially confirms acceptance of the transfer of an aged delinquent debt, and that receivables have been removed from the ARS with the notation that it has been referred to the FOC for recovery.
Another avenue by which improper payments are recaptured is through Post Claim Reviews for title II Single Family Insurance Claims. A statistical sample of settled claims is reviewed for compliance with FHA servicing and claim filing requirements. A report on findings, is prepared and issued to the individual mortgagee. Mortgagees can refute the findings by providing additional documents before a final report is issued. If the Mortgagee chooses to pay the monetary findings prior to HUD’s issuance of the final report, those funds are deposited to ARS, which applies them to the Mortgage Insurance (MI) fund. Upon issuance of the final report, it is referred to the FOC which establishes it as a receivable and tracks it until paid in full. If a lender is overpaid on a Multifamily claim, the Multifamily Claims Branch will demand the overage back from the lender. If the lender fails to respond to their demands, the debt is referred to the FOC for collection. Lastly, for Treasury Cross-Servicing, the collection of generic debt is governed by the Debt Collection Improvement Act and HUD policies (Title I and Other Debt Collection Guidance 4740.2). The Act requires federal agencies to refer eligible delinquent debts to Treasury (for Cross-Servicing and TOP) when the debt is 120 days delinquent.
The Treasury’s TOP allows federal agencies to report delinquent non-tax debt to the BFS. BFS performs computer matching with disbursement data and processes an offset when an appropriate match is determined. After referral, Treasury and its private collection agencies are responsible for contacting the debtor to collect the payment of the debt. The Treasury’s Cross-Servicing is a process used by BFS to refer the debt collection to a private collection agency, among other actions, to collect delinquent debts on behalf of Federal Agencies.
The FOC’s recapture process establishes receivables in DCAMS and issues a demand notice to the debtor(s). If the debt remains unpaid, DCAMS issues a “Notice of Intent” warning regarding enforced collection measures and informs the debtor regarding their due process rights. DCAMS automatically reports information to credit bureaus and CAIVRS. Penalty and administrative cost charges are also automatically assessed if warranted.
If the debt remains unpaid, it is referred to Treasury (within 180 days) for offset via the government-wide TOP and for direct collection action by Treasury and Treasury contracted private collection agencies. Treasury also initiates referral to the Department of Justice (DOJ) for civil litigation and/or initiates Administrative Wage Garnishment (AWG) action if they deem such action to be appropriate.
If Treasury’s Cross-Servicing action is not successful, Treasury “returns” the debt to the FOC. If older than two years, the receivable is written-off and the case is reclassified “currently not collectible.” The FOC keeps the case open if offset via TOP appears fruitful or if other collection measures are applicable (e.g., AWG action by HUD). Otherwise, the FOC terminates collection action, closes the case, and the system issues an IRS Form 1099C “Cancellation of Debt,” the following January if appropriate. Write-off, Termination, close-out, and 1099C issuance can also occur at any point in the above collection cycle if determined appropriate (e.g., debtor is discharged as bankrupt).
Collections from debtors to HUD go to the Treasury Lockbox Network or Pay.gov. Collections from debtors to Treasury or DOJ come to HUD via interagency transfer (i.e., Intra-Governmental Payment and Collection (IPAC)). No matter the route, all payments are posted to the receivable in DCAMS.

Programs where recovery audits are not cost effective

1. Salaries & Expenses -Purchase Cards
2. Salaries & Expenses -Travel
3. Public Housing Operating Fund
4. Native American Housing Block Grant (NAHBG) Program
5. Information Technology Fund - Other Contractual Services
6. Choice Neighborhoods Initiative
7. Fair Housing Initiative Program
8. Capacity Building
9. Research and Technology
10. Fair Housing Assistance Program
11. Office of Inspector General - Other Contractual Services
12. Neighborhood Stabilization Program
13. Indian Home Loan Guarantee
14. Native Hawaiian Housing Loan Guarantee
15. Section 811 Housing for Persons with Disabilities (PRAC and Capital Advance)
16. Community Development Block Grants (CDBG)
-CDBG Insular Areas
-CDBG Entitlement
-CDBG Non-Entitlement
17. Public Housing Capital Fund
18. Community Development Fund - Disaster Recovery Assistance (Hurricane Harvey, Irma, Maria)
- Public Laws 115-123, 115-56, and 115-72
19. HOME Investments Partnership Program
20. Community Planning and Development - Disaster Recovery Assistance (Louisiana, Texas, West Virginia, Hurricane IKE, Other Disasters)
21. Contractor Payments
22. Housing Opportunities for Persons with AIDS
23. Housing Trust Fund
24. Housing for Special Populations- Capital Advance portion of expenditures, Section 202
25. Indian Community Development Block Grant (ICDBG) Program
26. Project-Based Rental Assistance Section 8 Moderate Rehabilitation
27. Family Self-Sufficiency Program
28. Project Based Section 8 - Renewal of Expiring Sec. 8 Mod Rehab SRO
29. Rental Housing Assistance Program- Section 236
30. Housing Counseling Assistance
31. Self-Help Homeownership Opportunity Program (SHOP)
32. Master Sub-Servicer (MSS) Default Activity
33. Manufactured Housing
34. Native Hawaiian Housing Block Grants
35. Refunds Program
36. Ginnie Mae - Other Contractual Services
37. Working Capital Fund - Other Contractual Services
38. Housing for the Elderly or Handicapped- DL Liquidating Acct- Section 202
39. Revitalization of Severely Distressed Public Housing (HOPE VI)
40. Community Development Fund - Recovery Act
41. Appalachian Regional Commission (ARC) Projects
42. Community Development Loan Guarantees - Section 108
43. Congressional Earmarks – Economic Development Initiative – Special Projects /Neighborhood Initiatives
44. DOT SURFACE TRANSPORTATION PROJ
45. Economic Development Initiative (EDI)/Brownfields Redevelopment Economic Development Initiatives (BEDI)
46. Homeless Prevention Rapid Re-Housing
47. Nehemiah Housing Opportunity Grants
48. Neighborhood Initiatives Program
49. Rural Housing and Economic Development
50. Rural Innovation Fund
51. Sustainable Communities Initiative Program
52. Veterans Housing Rehab Program
53. MultiFamily Premium Refunds
54. Single Family Notes
55. Single Family Premium Refunds - Distributive Shares and Refund System (DSRS)
56. Federal Housing Administration - Title 1 Premiums
57. Pass Through Assistance Program (PTAP)
58. Soldiers' and Sailors' Civil Relief Act (SSCRA) Program Reimbursement and Multifamily 1% Reimbursement Program
59. Unclaimed Security Holder Payments
60. Housing - Green and Resilient Retrofit Program for Multifamily Housing
61. College Housing Debt Service Grants
62. Emergency Homeowners' Loan Program - DL Financing Acct
63. Emergency Homeowners' Relief Fund
64. Energy Innovation Fund
65. Flexible Subsidy
66. MultiFamily Upfront Grants- GI AND SRI INSURANCE FUND
67. Rent Supplement
68. Title VI Indian Federal Guarantees
69. Permanent Supportive Housing
70. RHAP - Tenant Based Rental Assistance Section 8 Housing Certificate Fund & Tenant Based Rental Assistance
71. Rental Housing Assistance Program (RHAP) - Project Based Rental Assistance
-Project Based Section 8
-Rental Housing Assistance Program- Section 236
-Housing for Persons with Disability- Section 811

Why recovery audits are not cost effective in certain programs

I. Nature of the Program
A payment recapture audit was deemed not be cost-beneficial based on the nature of these programs. Collectability is a concern as tenants may no longer be receiving housing assistance when the overpayments are identified, or many may not be able to repay the subsidy with their own resources. HSNG Owners/ PIH PHAs use the Enterprise Income Verification (EIV) system to verify tenant employment/income information and reduce administrative and subsidy payment errors in accordance with HUD administrative guidance. The program Points of Contact (POC) use EIV to monitor the owner’s compliance with access and use of the system. However, tenant files are stored locally at each Multifamily property and some RHAP activities are administered by PHAs nationwide. A recovery audit would involve substantial travel costs in addition to staff time. There are also no centralized computer database capturing documents used to support the rental subsidy determinations. Therefore, the cost of any additional attempts to recover improper payments would exceed the benefit of improper payments recovered.

II. Lack of Empirical Evidence
The results of HUD’s payment integrity risk assessments identified these programs as not susceptible to significant improper payments. There is no empirical evidence, either through risk assessments, A-123 internal control reviews, and other monitoring reviews, that suggests significant improper payments exist within these programs and activities, and it is not likely that HUD would realize any benefit to payment recapture audits of these programs. Therefore, the cost of any additional attempts to recover improper payments would exceed the benefit of improper payments recovered.

III. Similar Overpayment Recovery Activities for CPD Programs
The CPD funds have a monitoring process in place to assess the quality of performance of the grantee over time and promptly resolve the findings of audits and other reviews. Monitoring provides information about program participants that is critical for making informed judgments about program effectiveness and management efficiency. It also helps in identifying instances of fraud, waste, and abuse. The process involves frequent telephone/email contacts, written communications, analysis of reports and audits, and periodic meetings. Monitoring also provides opportunities to identify program participant accomplishments as well as successful management/ implementation/evaluation techniques that might be replicated by other CPD program participants.
Parties involved include Special Need Assistance Programs (SNAP), Field Offices, Office of Policy Development and Coordination (OPDC), Office of Rural Housing and Economic Development (ORHED), Office of General Counsel (OGC), Budget and OCFO. CPD’s program exhibit 34-1a, Guide for Review of Financial Management and Audits, is designed to monitor non-federal entity’s compliance with requirements of Subparts D and F of 2 Code of Federal Regulations (CFR) part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, except for cost allowability, procurement and equipment. During the monitoring process, program expenditures are reviewed to determine if improper payments were made. If identified CPD determines whether the appropriate corrective actions took place. In most cases, CPD will recapture overpayments by offsetting future draws. Overpayments in the Neighborhood Stabilization Program are addressed through reduction of future allocations as opposed to future draws. If there are no remaining funds on the grant, HUD will typically instruct the grantee to either repay funds from non-federal funds sources to their grant’s line of credit in Line of Credit Control System (LOCCS) or to the Treasury’s account if the grant has been closed. A remittance to the line of credit of less than $2,000 may be made by sending a check to HUD-FAD Collections Ft. Worth PO Box 6200-05, whereas any remittance of more than $2,000 must be sent via wire transfer to the Department of U.S. Treasury’s Financial Communications System (TFCS). CPD programs could also withhold additional funding until the overpayment has been recovered.
In addition, the results of HUD’s payment integrity risk assessment identified these programs as not susceptible to significant improper payments. Therefore, the cost of any additional attempts to recover improper payments would exceed the benefit of improper payments recovered.

IV. Similar Overpayment Recovery Activities for Ginnie Mae Programs
For any overpayments identified, Ginnie Mae will either request reimbursement or offset future payments to the contractor. However, if there are no future invoices to be provided, Ginnie Mae will request reimbursement for the improper payment. To recover overpayments made to the General Services Administration (GSA) for invoice payments to a vendor, Ginnie Mae will process an IPAC. When the cost of recovering improper payments is greater than the benefits, then Ginnie Mae will not pursue any further actions than mitigating strategies as outlined already.
As it relates to the Pass-Through Assistance Program (PTAP) program, which is new for 2021, the process for identifying improper payments includes validation of the request against the loan and pool information submitted to the Reporting and Feedback System (RFS), evaluation of the issuers equity and liquidity as reported with the PTAP request, and evaluation of the custodial account balance from which the Investor payments will be drawn.
The PTAP disbursement process is the same as in all Ginnie Mae disbursement requests. The PTAP disbursement request is processed for review and approval for payment. All payment requests are approved by an Independent Certifying Officer (ICO) (who accepts personal financial responsibility and criminal liability for improper payments they certify). The cost of recovering improper payments would exceed the benefit of improper payments recovered and would not be beneficial to the program.

V. Similar Overpayment Recovery Activities for Other Rental Assistance Programs
The results of HUD’s payment integrity risk assessment identified these programs as not susceptible to significant improper payments. All owners receiving funding from these programs are mandated by 24 CFR 5.233 to fully utilize HUD’s EIV system. EIV is a web-based application which provides owners with employment, wage, unemployment compensation and social security benefit information for tenants participating in HUD’s assisted housing programs. Tenant Rental Assistance Certification System (TRACS) is a system developed to improve the fiscal control over assisted housing programs and acts as the sole repository of all tenant certification data, assistance contract data and crucial payment data. EIV is matched against TRACS and a variance of $2,400 per year generates an error and owners are required to follow-up with the tenant and resolve the error. If an overpayment is identified, tenants may pay the owner in a lump sum or by entering into a repayment agreement. Therefore, the cost of any additional attempts to recover improper payments would exceed the benefit of improper payments recovered.

Of the thirty-seven (37) programs excluded from a Payment Recapture Audit, the remaining fifteen (15) programs have other mechanisms in place to recover overpayments.

Recovery audit amount identified this reporting period that remains outstanding					$6.48 M
Recovery audit amount rate outstanding					82.65 %
Recovery audit amount this reporting period that remains outstanding for 0-6 months					$6.48 M
Recovery audit amount identified this reporting period that remains outstanding for 6 months to 1 year					$0.0 M
Recovery audit amount identified in this reporting period determined not collectible during this reporting period					$0.0 M
Recovery audit rate identified in this reporting period determined not collectible during this reporting period					0 %