oversight

Records Management in the Office of Hospital Facilities Needs Improvement

Published by the Department of Housing and Urban Development, Office of Inspector General on 2016-09-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 Records Management in the
                  Office of Hospital Facilities
                     Needs Improvement




                       Program Evaluations Division

Washington, DC       Report Number: 2016-OE-0001      September 23, 2016
                                      MEMORANDUM
                                        September 23, 2016


To:      Geoffrey Papsco
         Director, Office of Hospital Facilities, HP

         Carmelita Bridges
         Departmental Records Officer, AHDCB

         Dr. Sheila Wright
         Chief Learning Officer, AHC

From:    Kathryn Saylor
         Assistant Inspector General for Evaluation, GAH

Subject: Records Management in the Office of Hospital Facilities Needs Improvement, 2016-
         OE-0001


Please see the attached final report on our evaluation of records management practices within the
Office of Hospital Facilities (OHF). We identified areas in which OHF can improve its records
management and the U.S. Department of Housing and Urban Development (HUD) can improve
records management training. We made three recommendations designed to help OHF and HUD
address these areas.

We have included comments on our draft report from the Offices of Healthcare Programs (OHP)
and Digital Enterprise (ODE) in appendix B. OHP agreed with the two recommendations
directed toward them and provided proposed actions to be taken to satisfy the recommendations.
The Office of the Chief Human Capital Officer (OCHCO) did not provide comments on our draft
report but agreed with recommendation 3 during discussions of the draft report. ODE also
agreed with recommendation 3. We concur with OHP’s and ODE’s proposed actions and look
forward to receiving additional information on their plans. Within 90 days, OHP, OCHCO, and
ODE should provide us with details on their proposed management decision for their respective
recommendations as well as target dates for implementing corrective actions.

Attachment

cc:
Roger Lukoff, Deputy Assistant Secretary for Healthcare Programs (Acting), HP
Dr. Dolores Cole, Director (Acting), Office of Digital Enterprise, AHD
Rafael C. Diaz, Chief Information Officer
Henry Hensley, Director, Office of Strategic Planning and Management, X
Christopher Walsh, Deputy Performance Improvement Officer, Office of Strategic Planning and
  Management, X
Michael C. Adams, Program Analysis Officer, Office of Strategic Planning and Management, X
Diane A. Stewart, Audit Liaison, HROA

                                        Office of Inspector General
                                             Office of Evaluation
                                  451 7th Street SW, Washington DC 20024
                                 Phone (202) 708-0430, Fax (202) - 401-2505
                                               www.hudoig.gov
                                                                            Executive Summary
                              Records Management in the Office of Hospital Facilities
                                                               Needs Improvement

Report Number: 2016-OE-0001                                                                    September 23, 2016


Why We Did This                     Results of Evaluation
Evaluation
                                    OHF relied on its employees’ personal judgement of which records to retain for its
The Office of Hospital Facilities   business needs or to document the legitimacy of an underwriting decision. While
(OHF) provides mortgage             OHF may have retained many required records with its current practices, we are
insurance for acute care            concerned that records collected or generated by OHF could be misplaced or
hospitals. The insurance it         improperly destroyed because it did not actively apply a records disposition
provides reduces risk to lenders    schedule, it lacked internal policies, and its employees received insufficient
and lowers borrowing costs for      training. Additionally, we learned that OHF did not treat emails as records as
hospitals. As of May 2016, the      required by National Archives and Records Administration and U.S. Department
unpaid principal balance for its    of Housing and Urban Development (HUD) policies. Finally, OHF could not
105 insured mortgages was           provide some documents we requested as part of our evaluation. OHF risks not
approximately $7 billion.           being able to retrieve all records needed for legal or administrative procedures if it
                                    does not address these issues.
OHF collects and generates
many records to support its         We also observed that HUD’s records management training content was vague
mission. These records include      and did not cover Federal records requirements. After taking the training, an
application materials, internal     employee would not have learned how to properly identify, maintain, and archive
reports, and correspondence.        Federal records.
Robust records management
practices can help OHF protect      Recommendations
the financial, legal, and other
rights of the Government and        We recommend that the Director of OHF (1) develop internal written procedures
the public.                         for records management and (2) ensure that personnel preparing records for
                                    archiving are trained to perform this function and aware of all relevant records
Well-managed records can be         disposition schedules and policies.
used to assess the impact of
programs, improve business          We also recommend that the chief learning officer, in consultation with the Office
processes, share knowledge          of Digital Enterprise, offer records management training that incorporates Federal
across the Government, and          and departmental records management policies and employee records
hold officials accountable for      management responsibilities.
their actions.

While researching OHF’s
underwriting process, we found
evidence of potential
weaknesses in the storage of
paper and electronic materials.
We evaluated records
management procedures to
determine whether (1) OHF
maintained a records retention
system that complied with
applicable policies and (2) staff
received required records
training.
Table of Contents
Background ..................................................................................................................... 1
   The Office of Hospital Facilities .................................................................................... 1
   Records Management .................................................................................................. 1
OHF Risks the Loss of Records Due to Its Records Management Practices .................. 2
   OHF Did Not Follow a Records Schedule .................................................................... 2
   OHF Did Not Treat Emails as Records ........................................................................ 3
   OHF Could Not Produce Some Documents ................................................................. 4
   HUD Planned Records Management Changes............................................................ 5
   Recommendations ....................................................................................................... 5
HUD’s Records Management Training Was Not Specific Enough To Be Useful............. 6
   Recommendation ......................................................................................................... 6
Appendixes ..................................................................................................................... 7
   Appendix A – Objectives, Scope, and Methodology .................................................... 7
   Appendix B – Agency Comments and OIG Response ................................................. 8
      Office of Healthcare Programs’ Comments .................................................................... 8
      OIG’s Response to the Office of Healthcare Programs’ Comments ................................. 10
      Office of the Chief Human Capital Officer – No Comment ............................................ 11
      Office of Digital Enterprise’s Comments ..................................................................... 12
      OIG’s Response to the Office of Digital Enterprise’s Comments .................................... 13
   Appendix C – List of Acronyms .................................................................................. 14



List of Figures
Figure 1 – The records life cycle ..................................................................................... 1
Figure 2 – Was OHF able to supply records requested by OIG? .................................... 4
                                                                            Report number: 2016-OE-0001




Background
The Office of Hospital Facilities
The U.S. Department of Housing and Urban Development (HUD), Office of Hospital Facilities
(OHF), part of the Office of Healthcare Programs within the Office of Housing (Housing),
administers the Section 242 program. Section 242 of the National Housing Act authorizes
mortgage insurance for acute care hospital facilities, ranging from large teaching institutions to
small rural critical access hospitals. HUD provides this mortgage insurance to private lenders to
ensure that adequate mortgage capital is available for hospitals. OHF’s insurance reduces risk to
lenders and lowers borrowing costs for hospitals. OHF has insured hospital mortgages, ranging
from $2 million to $755 million. As of May 2016, the unpaid principal balance for its 105
insured hospital mortgages was approximately $7 billion.

OHF collects and generates many records to support its decision on whether to insure a
hospital’s mortgage. These documents include application materials, internal reports, and
correspondence. For example, lenders applying for mortgage insurance must submit 3 volumes
containing 43 documents, which may total hundreds of pages.

Records Management
Records are the foundation of open
government, supporting the principles of              Figure 1 – The records life cycle
transparency, participation, and
collaboration. Well-managed records can
be used to assess the impact of programs,
                                                  Creation or receipt
improve business processes, and share
knowledge across the Government.
Additionally, records protect the rights and          Maintenance and use
interests of people and hold officials
accountable for their actions. Federal law
defines records as all recorded information,              Disposition
regardless of form or characteristics, made               • Destroy or transfer to NARA
or received by a Federal agency as evidence
of the organization, functions, policies,
decisions, procedures, operations, or other activities of the United States Government or because
of the informational value of data in them. 1 Figure 1 lists the three stages of the records life
cycle.

The National Archives and Records Administration (NARA) is the Federal agency that oversees
the management of all Federal records. Federal law requires the head of each agency to make
and preserve records containing adequate and proper documentation of the organization,
functions, policies, decisions, procedures, and essential transactions of the agency. 2 These


1
    See 44 U.S.C. (United States Code) 3301 for the full definition.
2
    44 U.S.C. 3101

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records include records created or received on electronic mail systems. 3 All Federal records
must be governed by a schedule, which provides mandatory instructions for the disposition of the
records (including the transfer of permanent records to NARA and disposal of temporary
records) when they are no longer needed by an agency. Record disposition schedules are created
by agencies and must be approved by NARA.

HUD’s departmental records officer is located in Office of Digital Enterprise, Electronic Records
Management Division (ERMD). ERMD’s role is to ensure that records are properly documented
and preserved and records no longer needed are properly destroyed or archived. ERMD also
maintains and enforces records disposition schedules. During our evaluation, ERMD was
revising all HUD records schedules, including OHF’s, and anticipated submitting its draft for
NARA’s approval by the end of fiscal year 2016. It might take up to a year to obtain NARA’s
approval.

Until a new schedule is approved, OHF’s records are governed by Records Disposition Schedule
10: Records Relating to Multifamily Insured Programs. Schedule 10 requires OHF to preserve
records for periods ranging from 3 years from the creation of the material to 6 years after HUD
ceases to have liability in the project.


OHF Risks the Loss of Records Due to Its
Records Management Practices
OHF relied on its employees’ personal judgement of which records to retain for its business
needs or to document the legitimacy of an underwriting decision. While OHF may have retained
many required records with its current practices, records collected or generated by OHF could
have been misplaced or improperly destroyed because its staff did not knowingly apply Schedule
10, it lacked internal policies, and its employees received insufficient training. For example, we
learned that OHF did not treat emails as records as required by NARA and HUD policies.
Finally, OHF could not provide some records we requested as part of our evaluation. OHF risks
not being able to retrieve all necessary records needed for legal or administrative procedures if it
does not address these issues.

OHF Did Not Follow a Records Schedule
For day-to-day activities, OHF employees stored materials on their computers’ hard drives, a
shared network drive, or a SharePoint site or as personal hardcopy files. Once OHF completed
the underwriting process, employees placed documents on a shared network drive or a
SharePoint site or gave them to the underwriting director. Also, the lead underwriter may have
kept documents. OHF did not have internal guidance identifying the specific records to be
maintained. In general, the focus for records management was on documents generated for the
closing process, and those records created during underwriting were not always considered for
archiving.


3
    36 CFR (Code of Federal Regulations) 1222.24(a)

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A financial analyst acted as an ad hoc records custodian. He prepared OHF’s records for
archiving after a project closed. This role evolved over time and was not officially designated.
At times, other individuals placed underwriting and closing documents into boxes for archiving.
For example, the analyst was not aware of all underwriting documents or whether others had put
documents into boxes for storage.

More recently, an OHF manager asked the analyst to review paper files and send them to
Housing’s archives. The financial analyst informed us that he did not apply a records schedule
to his archiving efforts. He was initially unaware that a records schedule existed for OHF, telling
us that an office manager should be hired to develop and follow a records schedule. When we
showed him Schedule 10, he said he used it for labeling files. He also believed the Freedom of
Information Act controlled how emails were retained and was not aware of the relevant NARA
or HUD policies governing email retention. 4

Documents the analyst said he included for archiving were (1) the application for mortgage
insurance, (2) approval letters, (3) architecture documents, (4) the certification of project costs,
(5) final closing documents, and (6) financial transaction records. The financial analyst’s goal
was to maintain documents, which showed that the underwriting was legitimate. After
organizing records, the analyst sent them to Housing’s chief records officer for long-term storage
and eventual transmittal to NARA. While OHF may have retained many required records by its
practices, it could have misplaced or improperly destroyed records because it did not apply
Schedule 10.

OHF leadership believed the only records management training its staff received was from HUD
Virtual University, an e-training site that offers records management training to all HUD
employees. OHF staff members we talked with did not describe records management guidance
or training provided by HUD or Housing beyond HUD Virtual University and the HUD
handbook. According to Housing’s chief records officer, HUD Virtual University training was
not tailored to HUD components, nor was it complete. She said Housing was developing a new
training course on records management, which would have modules that were more specific.
The target date for completing the development of the training course is September 30, 2016.

OHF Did Not Treat Emails as Records
Most communication among OHF, lenders, and hospitals was done via email. However, OHF
did not consistently maintain these emails as required by NARA and HUD policies because it did
not enforce the policies throughout the office. According to an OHF manager, email messages
that contained questions and answers among OHF, the hospital, and the lender were not archived
because he did not believe there was formal guidance that required the memorialization of major
issues or their resolution. Additionally, the financial analyst who maintained OHF’s records and
prepared them for archiving was not sure whether an email retention policy existed and did not
think training on this topic was available in HUD Virtual University. 5 One OHF team member
said emails were all in one email system but was not sure how the system was archived. Another

4
 See the next subsection for more information on email retention.
5
 As discussed in the next section, we reviewed HUD’s records training content and found that it did not include
Federal records management requirements.

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employee stated that he printed out important emails and maintained them. When we asked
Housing’s chief records officer why OHF employees were not aware of email retention
requirements, she said HUD personnel overall were not aware of the email policies.
According to NARA, all agency-administered email accounts are likely to contain Federal
records. 6 Therefore, NARA requires agencies to have record-keeping requirements for records
created or received on electronic mail systems. 7 Further, HUD’s email retention policy requires
that records created or received on electronic mail systems be managed in accordance with
NARA regulations. 8 Additionally, Schedule 10 states that correspondence pertaining to the
production phase (underwriting) must be retained for 3 years after creation. 9 Without properly
identifying which emails are records and determining how long to retain them, OHF risks not
being able to retrieve records needed for legal or administrative procedures.

OHF Could Not Produce Some Documents
OHF could not produce some records we requested as part of our evaluation. We chose a
judgmental sample of eight hospitals. For each hospital, we asked for four types of documents
that OHF collected or created during the underwriting process—credit memorandum, feasibility
study, financial spreadsheet, and annual financial statements. As shown in figure 2, OHF could
not produce one credit memorandum, seven financial spreadsheets, and one set of financial
statements.

            Figure 2 – Was OHF able to supply records requested by OIG?

                                     Credit   Feasibility Financial    Financial
                                   memorandum   study     spreadsheet statements
            St. Francis (original)    Yes        Yes          No          Yes
            St. Francis (increase)    Yes        Yes          Yes         Yes
                                                                          Not
            New Orleans               Yes        Yes          No
                                                                      applicable
            St. John’s                Yes        Yes          Yes         Yes
                                                                          Not
            Lakeway                   Yes        Yes          Yes
                                                                      applicable
            Capital Health            Yes        Yes          No          Yes
            Bucyrus (original)        Yes        Yes          No          No
            Bucyrus (increase)        Yes       No  10
                                                              No          Yes
            Baptist                   No         Yes          No          Yes
            New York Hospital
                                      Yes        Yes          No          Yes
            - Queens

Because OHF did not identify how documents it generated or collected were governed by a
specific records schedule, we could not determine whether the schedule was followed. However,

6
  NARA Bulletin 2014-06 – Guidance on Email Management
7
  36 CFR 1222.24(a)
8
  2400.1, REV-1, CHG-3, HUD Electronic Mail Policy, paragraph 7.4b
9
  2225.6, REV-1, Records Disposition Schedule 10, item 1
10
   According to OHF, a feasibility study was not required in this instance.

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our review of HUD’s Schedule 10 related to hospitals led us to believe that documents, such as
the credit memorandum and financial statements, were required to be maintained for 6 years past
the life of the mortgage. 11 We were less certain about the requirements for financial
spreadsheets, which were either to be maintained for 3 years after creation or for 6 years past the
life of the mortgage. 12 When OHF could not produce all of the financial spreadsheets we
requested, a manager noted that some of the requested financial spreadsheets were more than 10
years old and could not be located. While this was true, because OHF did not apply Schedule
10, it is unclear whether the financial spreadsheets were maintained for 3 years after creation and
then destroyed or were, instead, misplaced at some unknown time. Additionally, these records
may have been required to be maintained for 6 years past the life of the mortgage.

HUD Planned Records Management Changes
In August 2012, the Office of Management and Budget (OMB) directed agencies to require
electronic record keeping and demonstrate compliance with Federal records management statutes
and regulations. 13 To meet this requirement, the departmental records officer, located in ERMD,
was revising HUD’s records management policies. Additionally, Housing was transitioning to
an electronic records management system. The Office of Residential Care Facilities, another
office within the Office of Hospital Programs, led the effort to transition records management to
an electronic system. OHF intended to start this transition in June 2016. While the transition to
an electronic system may help OHF more easily organize and retrieve documents, the office
needs to first determine which records it generates or collects and must be maintained. Until this
is done, OHF risks not digitizing and storing all relevant records.

Recommendations
We recommend that the Director of the Office of Hospital Facilities

        1. Develop internal written procedures for records management that
              a. Identify materials OHF collects or generates, which meet the regulatory
                 definition of a record;
              b. Comply with Federal and departmental records management policies, to
                 include appropriate records disposition schedules; and
              c. Inform all personnel of their records management responsibilities.

        2. Ensure that personnel preparing records for archiving are trained to perform this
           function and aware of all relevant records disposition schedules and policies.




11
   2225.6, REV-1, Records Disposition Schedule 10, item 7
12
   2225.6, REV-1, Records Disposition Schedule 10, either item 2 or 4a
13
   OMB Memorandum M-12-8: Managing Government Records Directive

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                                                                                          Report number: 2016-OE-0001




HUD’s Records Management Training Was Not
Specific Enough To Be Useful
NARA regulations require that agencies give guidance and training to all agency personnel on
their records management responsibilities, including identification of Federal records, in all
formats and media. 14 The Office of the Chief Human Capital Officer (OCHCO) offers records
management training through HUD Virtual University. OCHCO records showed that 25 of the
26 OHF staff members attended records management training during fiscal years 2014 and 2015.
We reviewed the training content and found that it did not include Federal records management
requirements. After taking the training, an employee would not have learned how to properly
identify, maintain, and archive Federal records. For instance, the first section of the training,
entitled “Record Retention Policies Overview,” did not mention HUD or Federal requirements
and referred to the organization as a “company” with “corporate records.” When listing legal
considerations, the training stated that the employee should be aware of laws and regulations,
court decisions, and contract provisions, but the training did not list or explain laws or
regulations. For example, it did not include the definition of a “record.” Finally, instead of
giving instruction on HUD records management policies, the training asked employees to
conduct research to learn which records should be retained and for how long. The training did
not provide contact information or links to resources that would help employees research HUD
records management policies.

Recommendation
We recommend that the chief learning officer, in consultation with the Office of Digital
Enterprise,

     3. Offer records management training that incorporates
           a. Federal and departmental records management policies, to include HUD’s
                safeguards against the removal or loss of records and the penalties provided by
                law for the unlawful removal or destruction of records, and
           b. Employee records management responsibilities, to include identification and
                maintenance of Federal records in all formats and media. 15




14
  36 CFR 1220.34(f)
15
  Based on conversations about the draft report with HUD, we revised the language of recommendation 3 to include
“in consultation with the Office of Digital Enterprise.” We also changed the action official from the Director of the
Employee Development Division to the chief learning officer.

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                                                                           Report number: 2016-OE-0001




Appendixes
Appendix A – Objectives, Scope, and Methodology
While researching OHF’s underwriting process, we found sufficient evidence of potential
weaknesses in the storage of paper and electronic materials to warrant an evaluation of records
management policies and practices within OHF. Our objectives were to determine whether (1)
OHF maintained a records retention system that complied with applicable policies and (2) staff
received required records training. We did not attempt to test the extent to which OHF records
management practices resulted in the appropriate identification and retention or destruction of
records.

To answer our objectives, we chose a judgmental sample of eight hospitals—based on the size
and timeframe of their applications for mortgage insurance—to review the documents related to
OHF’s underwriting decisions. From the judgmental sample, we interviewed eight OHF
employees who were involved in the underwriting portion of one or more of the hospital
applications. We reviewed OHF’s records management training content and records for fiscal
years 2014 and 2015. Additionally, we interviewed

   •   HUD’s departmental records officer,
   •   Housing’s chief records officer, and
   •   OHF’s financial analyst, who acted as a records custodian on an ad hoc basis.

We reviewed applicable laws, regulations, and policies pertaining to records management,
including those from NARA, OMB, and HUD. These documents included

   •   44 U.S.C. 3101 – Records management by agency heads; general duties;
   •   44 U.S.C. 3301 – Definition of records;
   •   36 CFR 1220.1-1220.34 – Federal Records; General;
   •   36 CFR 1222.1-1222.34 – Creation and Maintenance of Federal Records;
   •   NARA Bulletin 2014-06 – Guidance on Email Management;
   •   OMB Memorandum M-12-8: Managing Government Records Directive;
   •   HUD Handbook 2200.01, Chapter 11: Records and Files Management;
   •   HUD Records Disposition Schedules Handbook 2225.6, REV-1, Records Disposition;
       Schedule 10: Records Relating to Multifamily Insured Programs; and
   •   HUD Handbook 2400.1, REV-1, CHG-3, HUD Electronic Mail Policy, paragraph 7.4b

We conducted fieldwork from March to June 2016. We conducted this evaluation under the
authority of the Inspector General Act of 1978, as amended, and in accordance with the Council
of the Inspectors General on Integrity and Efficiency’s Quality Standards for Inspection and
Evaluation (January 2012).




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Appendix B – Agency Comments and OIG Response
Office of Healthcare Programs’ Comments




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     Office of Healthcare Programs’ Comments – Continued


Reference
to OIG
Response




Comment 1




Comment 2




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OIG’s Response to the Office of Healthcare Programs’ Comments


Comment 1   The Office of Healthcare Programs (OHP) agreed with recommendation 1. OHF
            intends to draft procedures that will specify what materials it collects and
            generates that meet the definition of a record, comply with Federal and
            departmental records management policies, and inform all personnel of their
            records management responsibilities. OHF will seek guidance from HUD’s
            departmental records officer and develop a plan to comply with this
            recommendation and share it with us 90 days after the publication of this report.
            These actions, once implemented, should comply with our recommendation. We
            look forward to reading OHF’s action plan, which should include specific dates
            for completing these actions. Please provide the plan to us 90 days from the
            issuance of this report to your office.

Comment 2   OHP agreed with recommendation 2. OHF intends to train all staff members on
            records management policies and procedures after they are developed. OHF will
            seek guidance from HUD’s departmental records officer and develop a plan to
            comply with this recommendation and share it with us 90 days after the
            publication of this report. These actions, once implemented, should comply with
            our recommendation. We look forward to reading OHF’s action plan, which
            should include specific dates for completing these actions. Please provide the
            plan to us 90 days from the issuance of this report to your office.




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Office of the Chief Human Capital Officer – No Comment

OCHCO did not comment on the draft report but informed us that that it accepts
recommendation 3 and will support the Office of Administration as it revises records
management training. Within 90 days, please provide us with details on your proposed
management decision as well as target dates for implementing corrective action.




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      Office of Digital Enterprise’s Comments

Reference
to OIG
Response




Comment 1




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OIG’s Response to the Office of Digital Enterprise’s Comments


Comment 1    The Office of Administration will revise records management training to
             incorporate Federal records management policies and employee responsibilities
             that include identification and maintenance of Federal records in all formats and
             media. The training will also address safeguards against the removal or loss of
             records and the penalties applicable to unlawful removal or destruction of records.
             The Office of Administration will gain the assistance of OCHCO to place the
             revised records management training on HUD Virtual University. These actions,
             once implemented, should comply with our recommendation. Within 90 days,
             please provide us with details on your proposed management decision as well as
             target dates for implementing corrective action.




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Appendix C – List of Acronyms
  Acronym                                     Definition
    CFR       Code of Federal Regulations
   ERMD       Electronic Records Management Division
    HUD       U.S. Department of Housing and Urban Development
    NARA      National Archives and Records Administration
   OCHCO      Office of the Chief Human Capital Officer
    OHF       Office of Hospital Facilities
    OMB       Office of Management and Budget
    U.S.C.    United States Code




                                        14
The Office of Inspector General is an independent and objective oversight
 agency within the U.S. Department of Housing and Urban Development.
We conduct and supervise audits, evaluations, and investigations relating
to HUD’s programs and operations. Our mission is to promote economy,
   efficiency, and effectiveness in these programs while preventing and
                detecting fraud, abuse, and mismanagement.

  Report fraud, waste, and mismanagement in HUD programs and operations by

                    Faxing the OIG hotline: 202-708-4829
                 Emailing the OIG hotline: hotline@hudoig.gov


                       Sending written information to
              Department of Housing and Urban Development
                      Inspector General Hotline (GFI)
                       451 7th Street, SW Room 8254
                          Washington, DC 20410

                                 Internet
                  http://www.hudoig.gov/hotline/index.php




   INFORMATION IS CONFIDENTIAL, AND YOU MAY REMAIN ANONYMOUS




             Program Evaluations Division




Report number: 2016-OE-0001