Emergency Rental Assistance (ERA1) Program Notice of Recoupment — City of Houston, Texas (OIG-CA-26-025)

Summary

Department of the Treasury Office of Inspector General document OIG-CA-26-025, March 1 2, 2026, Emergency Rental Assistance (ERA 1) Program Notice of Recoupment - City of Houston, Texas. The summary states that during desk reviews of Houston and Harris County, OIG identified 21,123 potential duplicative ERA1 payments, sampled 50 beneficiaries and found payment errors relating to 21 of the 50 beneficiaries, totaling $110,928 of overpayments. It states that OIG determined Houston's ERA1 program paid $30,981 in violation of the ERA1 statute because funds were disbursed to ineligible households, and that Treasury's Bureau of the Fiscal Service issued an invoice for $30,981 on March 11, 2026. The attached Notice of Recoupment is dated February 27, 2026.

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Issuer: Inspector general and oversight reports
Document type: Oig Ca 26 025 Emergency Rental Assistance Era1 Program Notice Of Recoupment City Of
Case: Oig Ca 26 025 Emergency Rental Assistance Era1 Program Notice Of Recoupment City Of

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“Emergency Rental Assistance (ERA1) Program Notice of Recoupment — City of Houston, Texas (OIG-CA-26-025).” Original at oig.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/oig-ca-26-025-emergency-rental-assistance-era1-program-notice-of-recoupment-city-of/, SHA-256 bf9ea401c730dc00db4e686119336fa455204857c315876f687cdd8c73a53e84.

Full text

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

OFFICE OF
INSPECTOR GENERAL

OIG-CA-26-025
March 1 2, 2026

Emergency Rental Assistance (ERA 1) Program
Notice of Recoupment - City of Houston, Texas
Summary
The ERA1 statute (codified at 15 USC § 9058a) directs the Department of the
Treasury (Treasury) to make allocations and payments to eligible grantees such as
States and local governments, who in turn, make funding available in the form of
rental assistance to eligible households. The statute also directs the Treasury
Office of Inspector General (OIG) to conduct monitoring and oversight of the
receipt, disbursement, and use of funds made available to grantees. As part of
this oversight authority, if OIG determines that a grantee failed to comply with the
use of funds requirements in the statute, the amount equal to the amount of
funds used in violation shall be booked as a debt of such entity owed to the
Federal Government.
The City of Houston, Texas (Houston) is a recipient of funds under the ERA1
statute. During our desk reviews of Houston and Harris County, Texas, we
identified 21,123 potential duplicative ERA1 payments in grantee-submitted data
through December 2021 . We then selected a non-statistical sample of
50 beneficiaries from those payments for further review. We identified duplicative
assistance, assistance exceeding 15 months, payments for ineligible expenses, or
other payment errors relating to 21 of the 50 beneficiaries, totaling $110,928 of
overpayments in violation of the requirements included in the ERA1 statute codified
at 15 U.S.C. § 9058a (c), Use of Funds. Based on our review, we determined that
Houston's ERA1 program paid ERA 1 funds totaling $30,981 in violation of the
ERA1 statute because the funds were disbursed to ineligible households as
discussed in the attached OIG Notice of Recoupment (Notice). The Notice
established a debt to the Federal Government for which Treasury's Bureau of the
Fiscal Service issued an invoice for $30,981 to Houston on March 11, 2026.
We provided Houston an opportunity to comment on a draft of the Notice and its
written response and our evaluation of that response is also included in the
Notice.

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
We conducted our review from May 2022 to August 2025. We inquired of the
grantee and other relevant parties, reviewed related documentation, and
performed other appropriate procedures. During our review of one case, we noted
certain matters that we have referred to the OIG Office of Investigations. We
believe the evidence obtained is sufficient and appropriate to provide a reasonable
basis for our determination in this Notice.
In conducting our review, we followed the OIG’s system of quality management
to ensure that the information in this report is accurate. We also followed the
Council of the Inspectors General on Integrity and Efficiency Quality Standards for
Federal Offices of Inspector General which require that our work adheres to its
general standards for integrity to include objectivity, independence, professional
judgment, and confidentiality as well as its general standard for receiving and
reviewing allegations.
Distribution
Department of the Treasury
Jeffrey W. Stout, Acting Chief Operating Officer, Office of Capital
Access
Danielle Christensen, Deputy Chief Program Officer for State & Local
Programs, Office of Capital Access
Kendra N. Young-Freeman, Director, Housing Programs, Office of Capital
Access
Michelle Dickerman, Deputy Assistant General Counsel, Office of the
General Counsel
Carolyn Appel, Attorney-Advisor, Office of the General Counsel
Blossom Butcher-Sumner, Attorney-Advisor, Office of the General
Counsel
City of Houston, Texas
Assistant Director Compliance Grant Administration
Deputy Director Planning and Grants Reporting
Division Manager Grant Reporting
Deputy Assistant Director
Management Analyst IV Compliance and Grants Administration Division
Administration Manager Public Service

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

OFFICE OF
INSPECTOR GENERAL

Notice of Recoupment
Emergency Rental Assistance
Division N, Title V, Subtitle A, § 501 of the Consolidated Appropriations Act, 2021
(Pub. L. No. 116-260), Dec. 27, 2020, and codified at 15 USC § 9058a (ERA1)

February 27, 2026
Grantee: City of Houston, TX
Points of Contact: Tandra Johnson, ERA Reporting
tandra.shropshire@houstontx.gov
(832) 394-6242

Derek Sellers, Deputy Director
Derek.Sellers@houstontx.gov
(832) 394-6239
Mailing Address: 2100 Travis St, 9th Floor, Houston, TX 77002
Federal Award Identification Numbers: ERA0038
Recoupment Amount: $30,981
Background/Legal Authority

Under the ERA1 statute at 15 U.S.C. § 9058a(c), Use of Funds, an eligible grantee
shall only use ERA1 award funds to provide financial assistance and housing
stability services to eligible households. The financial assistance includes: the
payment of rent; rent arrears; utilities and home energy costs; utilities and home
energy costs arrears; and other expenses related to housing incurred due, directly
or indirectly, to the COVID-19 outbreak, as defined by the Secretary of the
Department of the Treasury (Treasury). Such assistance shall be provided for a
period not to exceed 12 months except that grantees may provide assistance for
an additional 3 months to ensure housing stability (subject to availability of funds).
The ERA1 statute at 15 U.S.C. § 9058a(c)(2)(8)(i) allows for up to 3 months (with
exceptions) for prospective rent payments within the 12 or 15 months total
assistance limitation.
The ERA1 statute at 15 U.S.C. § 9058a(k)(3)(A) defines eligible household as a
household of one or more individuals who are obligated to pay rent on a residential
dwelling and with respect to which the eligible grantee involved determines: that

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
(1) one or more individuals within the household has (a) qualified for unemployment
benefits or (b) experienced a reduction in household income, incurred significant
costs, or experienced other financial hardship due, directly or indirectly, to the
COVID-19 outbreak, which the applicant shall attest in writing; (2) one or more
individuals within the household can demonstrate a risk of experiencing
homelessness or housing instability, which may include a past due utility or rent
notice or eviction notice; unsafe or unhealthy living conditions; or any other
evidence of such risk, as determined by the eligible grantee involved; and (3) the
household has a household income that is not more than 80 percent of the area
median income for the household. The grantee must also ensure that, to the extent
feasible, any rental assistance provided to an eligible household is not duplicative of
any other federally funded rental assistance provided to such household.
Pursuant to the ERA1 statute at 15 U.S.C. § 9058a(e)(2), the last day of the
period of performance for grantees that received ERA1 reallocated funds is
December 29, 2022.
The ERA1 statute at 15 U.S.C. § 9058a(i), Inspector General Oversight;
Recoupment, directs that the Treasury Office of Inspector General (OIG) conduct
monitoring and oversight of the receipt, disbursement, and use of funds made
available under the ERA1 program. As part of this authority, if OIG determines that
a grantee failed to comply with the use of funds requirements in the ERA1
statute (15 U.S.C. § 9058a(c)), the amount equal to the amount of funds used in
violation of 15 U.S.C. § 9058a(c) shall be booked as a debt of such entity owed to
the Federal Government. Amounts recovered shall be deposited into the general
fund of the Treasury.
Facts and Analysis
As part of our desk reviews of the City of Houston (Houston) and Harris County,
TX (the grantees), 1 we identified 21,123 potential duplicative ERA1 payments in
grantee-submitted data through December 2021. We then selected a non-statistical
sample of 50 beneficiaries from those payments for further review. We identified
duplicative assistance, assistance exceeding 15 months, payments for ineligible
expenses, or other payment errors relating to 21 of the 50 beneficiaries, totaling
$110,928 of overpayments in violation of the requirements included in the ERA1
statute at 15 U.S.C. § 9058a(c), Use of Funds. We worked with the grantees to
confirm the payment exceptions and issued a report discussing that work in detail.2
We communicated our results and observations to the grantees relating to the
$110,928 in overpayments we identified. In response, grantee management

1
Houston and Harris County jointly ran their Emergency Rental Assistance Program; however, the
grantees maintained separate funding and reporting functions.
2
Treasury OIG, Emergency Rental Assistance: Desk Review of Emergency Rental Assistance
Payments Made by Houston, TX and Harris County, TX, OIG-CA-24-029 (September 26, 2024).
2

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
informed us that they are pursuing recoupment of overpayments from the payees
and initiating an internal review of supporting eligibility documentation. The
grantees also recharacterized 3 $12,686 of the $110,928. As a result, $98,242
remains as ineligible ERA1 payments from our review.
Of the $98,242, we determined that Houston issued financial assistance totaling
$30,981 in violation of the ERA1 statute at 15 U.S.C. § 9058a(c), Use of Funds. A
separate recoupment notice will be issued to Harris County for the remaining
ineligible ERA1 payments. 4 Houston’s cases 1 through 9 are summarized below.
1. Houston Case 1

-
Case number (no.): (b) (6)
Amount: $20,000
Assistance invoice nos.: (b) (6)

Use of funds violation: Ineligible payment

-
The supporting documentation for case no. (b) (6) is insufficient. The
case file includes a document titled “Applicant Rental Verification Request
Form” with which a tenant authorizes a landlord to obtain information on
the prospective tenant by asking the previous landlord questions related
to the tenant’s prior residency. This document is not an acceptable item
for proof of residence according to both Treasury and the Houston-Harris
ERA Program guidance. Treasury guidance states that if grantees are
unable to obtain a signed current lease, the grantee may accept evidence
of paying utilities, an attestation by a landlord, or other reasonable
documentation. Houston-Harris further refined Treasury’s guidance for
establishing proof of residence to include obtaining a current photo
identification with the address of the rental unit; a current utility bill; a
lease; or mail from a government office, financial institution, or utility
provider to the applicant at the rental unit address. Also, the document
was not an adequate substitute for documentation that establishes a

3
According to Department of the Treasury, “Emergency Rental Assistance Frequently Asked
Questions” (May 10, 2023), https://home.treasury.gov/system/files/136/FAQs-05102023.pdf
(accessed October 26, 2023), question 45, there may be cases in which a grantee discovers that
a household has received ERA assistance from multiple grantees intended to cover the same
period of rent, utilities, rental arrears, or utility arrears. In such cases, assuming certain
conditions are met, the grantee may decline to recover its payment and instead recharacterize it
as assistance covering a different period of eligible rental or utility expenses.
4
We determined $67,261 of $98,242 was subject to recoupment from Harris County. In
February 2024 and September 2025, Harris County returned $2,249 and $3,040, respectively,
to Treasury. As such, the remaining recoupment amount is $61,972.
3

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
definitive existing rental agreement or leasehold between the tenant and
the landlord or that the applicant resided at the property.
Houston paid the household $2,000 in financial assistance per month for
10 months from September 2020 through June 2021, under case

-
no. (b) (6) . We found the assistance Houston provided under case
no. (b) (6) was ineligible because Houston did not have an acceptable
proof of residence document in accordance with Houston-Harris ERA
Program guidelines. Thus, we determined the applicant was not eligible
for assistance and that Houston provided ERA1 funds for 10 months of
financial assistance in the amount of $20,000 in violation of the Use of
Funds statute.

-
2. Houston Case 2
Case no.: (b) (6)
Amount: $2,334
Assistance invoice nos.: (b) (6)
(b) (6)
, and

Use of funds violation: Duplicate assistance

-
Houston paid financial assistance to the same household twice for the
months of February, March, and April 2021, under case no. (b) (6) .
Thus, we determined that Houston provided duplicate ERA1 financial
assistance for 3 months at the monthly rate of $778 for the total amount
of $2,334 in violation of the Use of Funds statute.

-
3. Houston Case 3
Case no.: (b) (6)
Amount: $2,040
Assistance invoice nos.: (b) (6) and (b) (6)
Use of funds violation: Duplicate assistance
Houston paid financial assistance to the same household twice for the

- -
months of March and April 2021 under case no. (b) (6) for one
applicant and under case no. (b) (6) for another applicant. Thus, we
determined that Houston provided duplicate ERA1 financial assistance for
2 months at the monthly rate of $1,020 for the total amount of $2,040
in violation of the Use of Funds statute.

-
4. Houston Case 4
Case no.: (b) (6)
Amount: $1,878
Assistance invoice no.: (b) (6)
Use of funds violation: Duplicate assistance

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Houston and Harris County each paid the household 1 month of financial
assistance for March 2021. According to the grantees, Harris County
issued the first payment for one applicant under case no. (b) (6) , and
Houston issued the second payment under case no. (b) (6) for another
applicant in the same household. Houston is responsible for the payment
due to the program’s practice that the second payer will pursue
reallocation or recapture. Thus, we determined that Houston provided
duplicate ERA1 financial assistance for 1 month for the total amount of
$1,878 in violation of the Use of Funds statute.

-
5. Houston Case 5
Case no.: (b) (6)
Amount: $1,799
Assistance invoice no.: (b) (6)
Use of funds violation: Duplicate assistance
Houston and Harris County each paid the household 1 month of financial
assistance for May 2021. According to the grantees, Harris County

--
issued the first payment under case no. (b) (6) , and Houston issued the
second payment under case no. (b) (6) . Houston is responsible for the
payment due to the program’s practice that the second payer will pursue
reallocation or recapture. Thus, we determined that Houston provided
duplicate ERA1 financial assistance for 1 month in the amount of $1,799
in violation of the Use of Funds statute.

-
6. Houston Case 6
Case no.: (b) (6)
Amount: $820
Assistance invoice no.: (b) (6)
Use of funds violation: Duplicate assistance

-
Houston paid the household financial assistance twice for March 2021
under case no. (b) (6) . Thus, we determined that Houston provided
duplicate ERA1 financial assistance for 1 month in the amount of $820 in
violation of the Use of Funds statute.

-
7. Houston Case 7
Case no.: (b) (6)
Amount: $810
Assistance invoice no.: (b) (6)
Use of funds violation: Duplicate assistance

--
Houston paid the household twice for financial assistance for March 2021
under case numbers (b) (6) and (b) (6) . Thus, we determined that

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Houston provided duplicate ERA1 financial assistance for 1 month in the
amount of $810 in violation of the Use of Funds statute.

-
8. Houston Case 8
Case no.: (b) (6)
Amount: $700
Assistance invoice no.: (b) (6)
Use of funds violation: Duplicate assistance

-
Houston paid the household financial assistance twice for April 2021
under case no. (b) (6) . Thus, we determined that Houston provided
duplicate ERA1 financial assistance for 1 month in the amount of $700 in
violation of the Use of Funds statute.

-
9. Houston Case 9
Case no.: (b) (6)
Amount: $600
Assistance invoice no.: (b) (6)
Use of funds violation: Duplicate assistance

-
Houston paid the household financial assistance twice for May 2021
under case no. (b) (6) . Houston recharacterized the ineligible duplicate
payment to ERA2 5 in April 2023 with the intent to recover the funds.
However, since Houston made an ineligible payment, those funds were
not eligible for recharacterization. Thus, we determined that Houston
provided duplicate ERA1 financial assistance for 1 month in the amount
of $600 in violation of the Use of Funds statute.
We determined that Houston’s ERA1 program paid ERA1 funds totaling $30,981 in
violation of the requirements included in the ERA1 statute at 15 U.S.C. § 9058a(c),
Use of Funds. Accordingly, these funds are required to be returned to the Federal
Government. Table 1 below illustrates a breakdown of ineligible ERA1 payment by
case number.

5
The statute authorizing ERA2 is codified at 15 U.S.C. § 9058c.
6

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Table 1. Ineligible Payment by Case Number

Houston Ineligible ERA 1 Financial
Case Case No. Assistance Payments
1 $20,000
2 2,334
3 2,040
4 1,878
5 1,799
6 820
7 810
8 700
9 600
Total $30,981

Grantee ResQonse

We provided Houston an opportunity to respond to our Proposed Notice of
Recoupment. On May 5, 2025, Houston management provided a written response.
See Appendix I for the response in its entirety.

Houston management concurred with the recoupment of $9,561 (6 of 9 cases)
related to duplicate payments and stated that they have initiated recapture of the
funds. However, Houston management disagreed with our determination for the
remaining $21,420 (3 of 9 cases) and asserted that they are eligible costs, as
summarized below.

• Houston Case 1-: $20,000

Houston management stated they verified proof of residency using the
applicant's water bill and lease addendum, which meets the proof of
residency requirements. Houston management attached copies of the
applicant's water bill and lease addendum for our review.

• Houston Case 6 : $820

Houston management stated that, according to the program's records, the
landlord requested that the funds be allocated to another month but was
unable to record the change in the system due to a technical issue.

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
•
-
Houston Case 9 (b) (6) : $600
Houston management requested further clarification on how the
recharacterization constitutes a violation of the Use of Funds statute.

OIG Evaluation
We considered Houston management’s response in finalizing this notice. We
commend the Houston-Harris ERA program for its efforts to minimize duplicate
payments. We acknowledge Houston management’s concurrence with the
recoupment in the amount of $9,561 for cases 2 to 5 and 7 to 8. We disagree
with Houston management’s assertion that cases 1, 6, and 9, in the total amount
of $21,420, are eligible costs, as discussed in detail below. Accordingly, Houston
is required to return $30,981 to the Federal Government.
Specifically:

•
-
Houston Case 1 (b) (6) : $20,000
We determined Houston did not provide sufficient evidence to demonstrate
the tenant’s residency or that the assistance provided was an eligible
payment.
o The additional documentation (copies of water bill and lease renewal
addendum) Houston management provided on May 5, 2025, are
allowable documents for proof of residency; however, these
documents and other documents provided for this case, when taken
as a whole, raised concerns with eligibility requirements. The
documents for the case included contradictory information and created
an overlap in the timeline of the tenant’s residency, as described
below. In October 2023, we notified Houston and Harris County of
overlapping assistance each had provided on behalf of different
tenants at the same address. Both applications listed the same phone
number and email address, but the email address contained the
landlord’s first and last name.
o According to the documentation Houston provided, the tenant lived at
two addresses from July 2019 through December 2020.
 The tenant’s prior landlord, Landlord A, attested the tenant
leased the property from July 1, 2019, through July 1, 2020,
on an Applicant Rental Verification Request Form. Further, on
December 4, 2020, Landlord A attested the tenant continued to
lease on a month-to-month basis.

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
The lease addendum shows the current landlord (Landlord B)
extended the tenant's lease agreement at a different address
with the same lease start date of July 1, 2019. According to
the lease addendum, the agreement was extended to
July 1, 2021. This address received the rental assistance and
was listed in the application.
o The tenant's driver license supports the address listed for Landlord A
and not the address listed on the tenant’s application for Landlord B.
o The water bill is dated May 2021, which is the second-to-last-month
for which the household received financial assistance and does not
establish tenancy at the address for most of the timeframe Houston
provided assistance (September 2020 through June 2021).

As a result, Houston did not establish that it obtained sufficient
documentation that the tenant was obligated to pay rent to the address that
received rental assistance in accordance with ERA1 statute at 15 U.S.C. §
9058a(c), Use of Funds. It is also unclear where the applicant lived during
the period they received the rental assistance. Thus, we do not concur with
Houston’s position that the payment met the proof of residency
requirements.

•
-
Houston Case 6 (b) (6) : $820
Houston management has not demonstrated that it recharacterized the funds
in question to another eligible month, a requirement of Treasury
recharacterization guidance.6
The additional documentation that Houston management provided on
June 4, 2025, included correspondence dated April 27, 2023, and May 4,
2023, between Houston and the landlord. The correspondence instructed the
landlord to reapply to reallocate the duplicated payments to different eligible
months. We determined that the additional documentation provided did not
(1) establish that the landlord filed a new application for assistance, on
behalf of the applicant, (2) indicate that Houston had approved a new

6
Department of the Treasury, “Emergency Rental Assistance Frequently Asked Questions”
(December 4, 2024), https://home.treasury.gov/system/files/136/ERA-FAQs-12042024.pdf
(accessed July 10, 2025). Per Frequently Asked Question 45, the grantee may decline to recover
its payment and instead recharacterize it as assistance covering a different period of eligible rental
or utility expenses, if the grantee documents, in accordance with ERA records requirements, which
expenses its funds ultimately covered; and the grantee confirms that the household was eligible
for all assistance it received, including ensuring that the total number of months of financial
assistance received by the household does not exceed statutory limits, as described in FAQ 10.
9

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
application, and (3) show the eligible month to which the duplicate payment
credit should be reallocated.
Further, Houston identified the amount associated with the case as a “refund
requested” item, which means the amount is subject for recapture by
Houston.
Thus, we do not concur with Houston’s position that the payment was
eligible.

•
-
Houston Case 9 (b) (6) : $600
Houston provided two Federally funded rental assistance payments to the
same household for May 2021, thus, its recharacterization of an ineligible
payment to ERA2 was in violation of use of funds requirements. Specifically,
15 U.S.C. 9058a(k)(3)(B), which requires that, “an eligible grantee shall
ensure that any rental assistance provided to an eligible household pursuant
to funds made available under this section is not duplicative of any other
Federally funded rental assistance provided to such household.”
According to Treasury management, by using both ERA1 and ERA2 award
funds to cover assistance payments to the same household for the same
rental period, Houston is in violation of the ERA1 statutory requirement
outlined at 15 U.S.C. 9058a(k)(3)(B). Thus, recharacterizing the duplicative
ERA1 rental assistance paid to the household to its ERA2 award – regardless
of the intent to recover the duplicative payment – is not allowable. To
resolve this noncompliance, Houston would need to identify different months
within the allowable 18-month assistance limitation period and the ERA1
award period of performance for which ERA assistance or other federally
funded rental assistance had not already covered for the household to
recharacterize the ineligible payments as an eligible ERA2 expenditure. If the
household already received a cumulative total of 18 months of ERA financial
assistance from Houston and/or other ERA grantees that was not covered by
any other federally funded rental assistance, the ineligible payments would
have to be returned out of Houston’s own funds to the Federal Government.
As noted in our prior desk review report (see footnote 2), we coordinated with
Houston and determined the duplicate payment was not eligible for ERA2
recharacterization.
We appreciate the courtesy and assistance provided by your staff. Should you have
any questions, please contact Julie Wong, Acting Deputy Assistant Inspector
General for Audit, at (202) 439-6354 or John Tomasetti, Audit Director, at
(202) 277-3210.
10

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Appendix I
Grantee Response
Docusign E,,lope ID:

C1TY0FH0 TO John Whitmire
Housing & Community De elopment Department Mayor

C.N:.:hols
Dff.cior
2100Tra. 9 "' Floo<
1-Jcuslon. T...._as 77002

T. (832} 394-6200
F. (832) 395-QatJ.2
www.hcustontx.QOVJhoos,ng

May 5, 2025

John Tomasetti. Housing Assistance Audit Director
Department of the Treasury I Office of Inspector General
875 15 111. treet m • . Washington, D _ooos

Re: EmergCDcy Rental .istance Proposed. Recoupment RespoDSe- ERA.0038

Dear Mr. Tomaselti:

The City of Houston (..City'') acknowledges receipt of the Draft otice of Proposed OIG
Re:coupmeru letter dared April 22. _025_ The City appre.cia1es the opportunity to review an.d
respond to the proposed recoupment re.suUing from the Depanment of the Treasury Office of
r
Inspector Genera. s ('OIG' desk reviev.r of the Ho on - Harris County Rental Assistance
Progr.1111 ('"Program'').

Below, the City has provided a response indicating concurrence or non-concurrence for each of
fue identified cases, along with the actions taken since the initial inquiry. Addition.any. the
accompanying supportin documentation subsr:anriat the City"s basis for any cases of non
concurrcnce.

ummat")·: The OIG has detemrined that the City issued fina.nci.al assistance totaling 30,981.00
in violation of the ER.Al statute 15 .S. . §9058a(c), se of Funds.

Ciry·s Response: Toe City concurs with the recoupment of.$9.561.00 associated with six (6) of the
identified ms.es due ro duplicate payments. However based on the City's review, Ille remaining
21.420.00 oflhe proposed recoupment- related to three (3) cases - are eligible costs.

l. Houston Cas:e 1
Case mm1ber no.):
Amount: $_0.000.00

The City does not agree with the OIG's. detennination. The program confinned that
proof of residency w-as verified using the applicant's water bill and lease addendum
Coad Menber,;: Am, Ped< T""3llJacksco Ab!,,,, KlYnn Evans-Shabazz F....:t F1ic:b,g Trflany D. l'1¥JnDs Ma.), N311 Mano C--..
Joaq. Matinez Ect,,,ardPcll.w M311ha1ex-T311.m JimiR.rnre,z: e °""'5 T 'laCaner leliGPlJmner Sall:eAlcam
Co,molls: Ctn; Holhru.

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Appendix I
Grantee Response
Docusign En ._.1ope ID:

which mee the proof of r, idency requirements. Copi of the water bill and )ease
addenchm1 are attached for the Treasury's revie'. •.

Houston Case 2
Case number (no.):
Amount: .$_,334.00
Assistance in: ·oice numbers:
Use of funds ·olation: Ineligible payment

The City agrees with OIG·s determination of duplicate paymenr. Toe Program initiated
recoupmmt on May S 2023.

3. Houston Case 3
Case number no.):
Amount: $ 04-0.00
Assistance invoice numbers:
se of funds violation: Ineligible payment

Toe ity agrees with DIG' determination of duplicate payment. Toe Program initiated
recoupme:nt on May S. 2023.

4. Houston Case 4
Case number (no. :
.Amotmt: $1.878.00
Assistance in oice numbers: -
Use ofmnds violation: Ineligiole payment

Toe City agrees ,vith OIG's detemlillation of duplicate payment. The Program initia ed
recoupment on June 1. 2023

5. Houston Case 5
Case number no. :
Amount: $1. 799.00
Assistance \.'Oice nwib-ers: -
Use of funds violation: Ineligible payment

The City agrees with OIG's determination of duplicate payment. Toe. Program initiated
recoupment on April 6, -023.

6. Houston Case 6
Casenumber(no. :
Amount: $S._O
Assistance invoice mwiliers: -
Use offtlnds violation: Ineligible payment

Toe City does no agree with the OIG s determination. According to the Program's
records. the landlord requested that th fun be allocated to another month but was
unable to record tbe change in the system due to a tedmica1 issu . The file con ains
correspondenc documenting the reallocation request

7. Houston Case 7
Ca.se number no.):

This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Appendix I
Grantee Response
Docusign Envelope JO:

Amount: $810
Assistance invoice numbers:
Use of funds violation: Ineligible payment

The City agrees with OIG's detennination of duplicate payment. The Program initiated
recoupment on June 23. 2023.

8. Houston Case 8
Case number (no.): -
Amount: $700
Assistance invoice numbers:
Use of funds violation: Ineligible payment

The City agrees \\ith OIG·s determination of duplicate payment. The Program initiated
recoupme:nt on April 21, 1023.

9. Houston Case 9
Case number (no.):
Amount: $600
Assistance invoice numbers: -
Use of funds violation: Ineligible payment

The City does not agree with the OIG's determination and respectfully requests further
clarification on how the recharacterization constitutes a violation of the Use of Funds
stalUte.

If you have any additional questions please contact Kennisha London., Compliance and Gram
Administration Division Deputy Director, Kennisha.London@houstontx..gov or (832) 394-6197.

'Az:
Very truly yours.

L ·;Ju(s
n--1i.1m;J1.11r
l'vlichacl C. Nichols, Director

OIG NOTE:

The attachments referenced in the Grantee Response are not included in this
Appendix due to the inclusion of sensitive personal information. To maintain
transparency and completeness of the record, the attachments are summarized
in the "Grantee Response" section, beginning on page 7 of the Notice of
Recoupment. Where applicable, OIG's evaluation of the referenced materials is
provided.

This Notice may contain information protected under the Privacy Act, 5 USC 552a.

File and source

File: OIG-CA-26-025-emergency-rental-assistance-era1-program-notice-of-recoupment-city-of.pdf
Size: 1,153,641 bytes
SHA-256: bf9ea401c730dc00db4e686119336fa455204857c315876f687cdd8c73a53e84
Our copy: OIG-CA-26-025-emergency-rental-assistance-era1-program-notice-of-recoupment-city-of.pdf
Original: oig.treasury.gov