U.S. Department of the Treasury

Introduction

Program Integrity is vital for participants of the Homeowner Assistance Fund (HAF) to ensure efficiency and effective distribution of assistance. The U.S. Department of the Treasury (Treasury) requires participants to implement policies and procedures that include robust compliance and risk-management controls, while also making certain that eligible households can receive timely assistance that supports housing stability.

HAF participants implementing HAF programs across the country operate in a wide variety of environments, with circumstances varying across population density, geography, the interconnectivity of the community, and many other localized considerations. Accordingly, HAF participants have identified a variety of program integrity measures that meet the particular needs for their community.^[1]

The strategies highlighted below support the integrity of the HAF participants’ programs which includes ensuring that HAF award funds are expediently directed toward providing eligible homeowners with assistance for qualified expenses related to mortgages and housing such as mortgage payments, utilities and home energy costs, other expenses related to homeownership, and foreclosure prevention purposes. Robust and thoughtful controls may also limit participants’ risks of having audit findings, being noncompliant with the requirements of their HAF Financial Assistance Agreement, and having issues with fraud, waste, and abuse. Combining standard program management practices with operational agility can help HAF participants find efficiencies for both administrators and homeowners while remaining compliant with the requirements of their HAF award.

Advantages to Enhancing Program Integrity Measures

• Optimizes effective operations
• Encourages robust servicer engagement and community partnerships
• Supports program reputation
• Limits program and operational risks
• Increases probability of distribution to those in most need of assistance
• Standardizes quality of service and enhances communication

Strategies to Consider

HAF participants’ program integrity policies and procedures are likely to vary in accordance with local needs and experiences, as well as with the structure of participants’ HAF programs. Nonetheless, administrators of emergency assistance programs may wish to consider some of the following in designing controls.

• “High touch” versus “scaled-up” controls: How participants determine appropriate processes and procedures for internal controls will depend on the geography and/or population of their area, as well as various partnerships and access to technology. Participants with lower application volume or more locally-focused application processing may benefit from a hands-on approach to application review, leveraging firsthand staff knowledge of the community and application trends to identify possible issues. Meanwhile, participants processing high volumes of applications may find it helpful to use technology or other scaled-up solutions that flag potentially problematic applications or patterns using risk scores, data analytics, or other tools. Partnering with vendors offering fraud or risk management tools and platforms may also promote program integrity while still allowing for quick and efficient deployment of emergency assistance. Vendors can provide technological solutions and platforms, as well as useful data on previous applicant activities gathered from third-party resources. 
• Staffing up: A workforce with experience in fraud detection, disaster recovery, and quality control for other programs funded with federal financial assistance awards can help strengthen HAF participants’ program integrity policies and procedures. Applying lessons, best practices, and tools from comparable contexts—especially contexts that require timely processing—can strengthen risk management.
• Application intake channels: HAF participants’ may consider implementing different eligibility documentation requirements or risk tiering strategies for their programs depending on the application intake channel. For instance, applicants that come to a HAF program for assistance through a trusted social services program may have different application processing and risk mitigation procedures compared to an applicant that comes to a HAF program through an online application—especially if that intake channel has similar eligibility requirements to the HAF program. HAF participants can use available documentation and relevant proxies to process applications that come through trusted intake channels to ensure applicants meet basic eligibility requirements. The rationale for these types of alternative documentation based on intake channel should be documented in the HAF participants’ program policies and procedures. 
• “Screening in” versus “screening out”: “Screen-in” approaches seek out a pathway to responsibly approve an applicant based on relevant available documentation. This may include widening the net of permissible documents that an applicant may provide to verify that he or she meets the eligibility requirements to receive HAF assistance. Screening-in practices must be paired with robust controls, and such an approach can help ensure that program integrity systems don’t erect barriers for eligible applicants.
• Communications with stakeholders: Building strong and transparent communication channels with homeowners, servicers, and utility companies can ease uncertainty, support stronger cooperation with HAF participants’ programs, and allow space for more successful risk mitigation strategies. For example, strong cooperation with servicers and utility companies can often facilitate access to supporting documentation about applicants and provide additional information about a community to help a HAF participant develop informed strategies. Regular communications to stakeholders can include the status of an application and/or access to up-to-date information about the applicant’s status.

Steps to take for future assistance programs

1. Identify strategies that make sense for the needs of your community, program capabilities, and integrate quality control strategies into your program policies and procedures.
2. Partner with networks and organizations that can help in the effort to maintain program integrity.
3. Build strong servicer, utility company, court system, and homeowner engagement strategies, which can help enhance cooperation, documentation intake, and support strategic risk mitigation efforts. 
4. Consistently reevaluate program policies and procedures and adjust as necessary.

Examples of maintaining program integrity

“High touch” versus “Scaled-Up” Controls

• One small state had developed proxies where some applicants (based on data and factual circumstances, as well as with verification of identity that they lived on their property) had more streamlined intake processes—so it could use more of its operation capacity more efficiently. For instance, homeowners living in mobile homes or coming through certain housing stability service referral channels had more streamlined back-end review of income documentation than applications that came through other channels.
• One larger state used a third-party verification process to confirm eligibility, identity, and income using in-state data.
• One state used vendor services to cross-reference applicant data with multiple data sources to identify inconsistencies. They also used randomized quality control mechanisms to track application review outcomes and develop internal systems of learning and iterative staff learning.
• One Tribally Designated Housing Entity (TDHE) provided a wide range of support for homeowners applying for HAF assistance to remove barriers to their online application system. While the online application interface removed the barrier to in-person processing and helped track data, Tribal employees also met in person with individuals who either identified themselves as needing assistance or were known to the Tribe for needing assistance to complete the application and verified their identity. The Tribe also visited properties in person to ensure the requested home repairs were necessary. To verify ownership of properties, the Tribe reviewed land leases and communicated with the land title records office.

Screening in versus screening out

• One state developed control structures that required certain documentation, but worked hard to help homeowners meet those requirements and provided flexibilities to help applicants meet these criteria. This involved identifying opportunities to responsibly pivot from paper-based documentation to electronic documentation. They also developed flexibilities to work with homeowners in order to get them through the application process when documentation was a challenge for homeowners due to unique situations. This was particularly important when working with documentation for survivors of domestic abuse, couples going through divorce, bankruptcy cases, etc.

Communications with homeowner, servicers, and utilitY Providers

• Staff from one state noticed a disconnect between departments within the servicer organization created a servicer-side delay in determining which homeowner’s account should receive the HAF assistance payment. To help expedite support for homeowners, the HAF participant developed a secure standard remittance list with detailed payment information to ensure the correct HAF assistance payment amounts were quickly applied to the appropriate homeowners’ account, while also maintaining security of sensitive information.
• Another state developed “hub-and-spoke” communication networks with housing programs implementing the program across the state. These networks helped the state’s HAF program address more local needs, while also supporting ongoing problem-solving that helped the HAF participant to maintain consistent program implementation across the state.

What’s next

• Review program integrity practices and data: Consider conducting regular reviews of program integrity policies and practices—how can they be strengthened, added to, or streamlined for your current program or future assistance programs? Tracking and assessing key program integrity metrics will facilitate these analyses and highlight areas for growth.
• Learn from other participants: Participants may find it helpful to consult with other participants, particularly neighboring participants or those sharing important features, like strategies to manage applicant volume or budget. Sharing experiences can help participants identify best practices or areas for growth in their current program or future assistance programs.
• Consider your long-term strategy for program integrity infrastructure: Identify other programs that can be beneficiaries of the knowledge gained from the implementation of a HAF program. Have you implemented an application process and distribution of innovations that might help other HAF participants implement successful program integrity measures?
   

To report fraud, waste, or abuse related to the HAF programs, please visit the Treasury Office of Inspector General (OIG) website.

Report Fraud, Waste and Abuse to Treasury (OIG)

_[1] Treasury recognizes that HAF participants’ programs vary according to local circumstances; these examples are intended to help HAF participants identify opportunities to enhance the effectiveness of their own programs but may not be universally applicable to all HAF participants. The program information provided herein is intended solely to illuminate “promising practices” that HAF participants might consider when developing their jurisdiction’s program policies and infrastructure. All such policy development must be in accordance with the applicable requirements of the HAF Financial Assistance Agreement, HAF authorizing statute, and other applicable laws, regulations, and Treasury’s HAF guidance. Nothing herein should be construed as (i) altering these requirements or (ii) confirming that any specific HAF participant’s program policies or administrative practices have been fully reviewed and found compliant.