May/June 2019, Volume 7 Issue 09
Working Together to Protect Housing Counseling Funds
The Office of Housing Counseling has many responsibilities related to supporting counseling agencies. We design a fair competition for funding through Notices of Funding Availability (NOFAs); monitor agencies’ spending of grant awards; and provide technical assistance to ensure that grantees are aware of and in compliance with the various regulations and requirements associated with the grants.
But we also have a responsibility to protect housing counseling funding. In addition to helping agencies set up fiscal policies and procedures that protect from accounting and bookkeeping errors that could result in either inappropriate use of grant funds or the appearance of inappropriate use of grant funds, we also respond to any possibility of intentional actions that result in the misuse of grant funds. Although it is an infrequent occurrence, there have been several incidents over the last six years where unscrupulous individuals have engaged in schemes for personal gain.
How Are We Alerted?
There are several sources the Office of Housing Counseling depends upon for leads to dishonest behavior. The majority of individuals who work in housing counseling are dedicated to the program and those it serves. We encourage everyone to follow the principle “if you see something, say something.” This is applicable to anyone who is not employed in the industry (i.e., clients), and suspects wrongdoing. They can contact us at firstname.lastname@example.org.
Occasionally, the press will pick up on cases of alleged misuse and contact HUD officials. During our performance review process, we will google an agency to see if there have been reports that should be reviewed.
Other times, a party may feel that an action is sufficiently egregious and will report it to the Office of the Inspector General (OIG), who may alert us to their investigation.
How Does the Office of Housing Counseling Investigate?
The Housing Counseling Program New Certification Requirements Final Rule, effective January 2017, specifically addresses the issue of material violations. A material violation can be described as a misuse of funds that is not the result of a lack of recordkeeping or other inadvertent action. The penalty for a material violation is severe and can include return of grants funds and permanent disbarment from the counseling program for the agency.
Since the program penalties are so drastic, the Office of Housing Counseling must be very careful in its review of any allegations or suspicions. After some preliminary steps, we refer the alleged issue to and work with OIG at their direction. The Office of Housing Counseling has cooperated with OIG in more than seven cases. The OIG process is long and thorough, and often the results are not shared with the Office of Housing Counseling. However, we are aware of two successful prosecutions that resulted in both jail time and recovery of funds.
The Office of Housing Counseling and OIG remain committed to pursuing any wrongdoing that reduces the funds available to clients. It is important that we hear about any suspected inappropriate or unfair actions that affect our counseling agencies and their clients. The Office of Housing Counseling has assigned a program manager, Phyllis Ford, to address issues and complaints. She is available to those employed in the industry, as well as to clients and industry stakeholders. Phyllis can be reached via email at email@example.com or by phone at (202) 815-1484.
Other times, a party may feel that an action is sufficiently egregious and will report it to OIG, who may alert us to their investigation. The OIG website provides instructions for contacting them at their direct email, firstname.lastname@example.org, or toll-free at 1-800-347-3735. Written communication can be sent to: HUD Inspector General Hotline (GFI), 451 7th Street, SW, Washington, DC 20410, Attention: Mike Powell.