Ensure that contracting officers and OCPO field offices review and follow the records management policies and procedures, including completing and signing Forms 7600A and 7600B, to ensure consistency among contract officers approving interagency agreements in the procurement system of record.

Implement a process to periodically audit or reconcile ARC’s records.

Implement a process to periodically review approving officials’ span of control to ensure that the requirement is not exceeded.

Implement a process with ARC to ensure that cardholders and approving officials are notified before purchase card training is due to allow training to be completed in a timely manner.

Implement a process to ensure that purchase cards are suspended when a cardholder or approving official fails to complete training.

Research why ARC provided incomplete monthly transactional data and identify a solution to ensure the completeness of future transmissions.

Enhance the process to periodically analyze data for split transactions or improper MCCs and follow up on any potential issues identified.

Require ARC to update its MCC tracking log, to include the amount, the date of MCC override removal, and staff assigned, to ensure that an override is removed after the approved purchase is made.

Implement a process with Citibank and ARC to provide global notifications to cardholders and approving officials before autoclosures of credit card statements.

Implement a process to suspend cardholders or approving officials who repeatedly cause HUD to pay interest.

Obtain supporting documentation for the $1,807 spent on two cardholders’ purchase cards or require the vendors or cardholders to repay the funds to the applicable HUD program.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $78,021 in two administrative obligations marked for deobligation as of September 30, 2017.

Ensure that originating base IAAs and modifications are maintained in HUD’s procurement system of record, PRISM, including manual documentation and records from HIAMS.

Develop, document, and implement policies and procedures for initiating, recording, and approving IAAs and subsequent modifications.

Monitor the records management procedures of OCPO field offices for administering consistency among contracting officers processing IAAs and corresponding modifications.

Strengthen current purchase card controls to ensure that purchases are supported by all required approvals before the purchase is made.

Review the four cardholders with incomplete approvals and determine whether the purchases were allowable and proper. If they were not for official government use, OCPO should determine whether the cardholders paid the credit bill for the improper charges, request reimbursement when applicable, and ensure that appropriate administrative sanctions are taken.

Review the two cardholders with incomplete approvals and determine whether the purchases were allowable and proper. If they were not for official government use, OCPO should determine whether the cardholders paid the credit bill for the improper charges, request reimbursement when applicable, and ensure that appropriate administrative sanctions are taken.

Complete all steps necessary for an effective evaluation effort.

Work with grant program offices to overcome reporting challenges. Ensure that grant program offices report OMB-requested data. Learn from and leverage results of participating grant programs.