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Office of Capital Access management should require Houston's and Harris County's management to take appropriate and timely corrective actions to (a) determine if payments related to the total population of 1,797'ERA1 household address groupings with potential duplicative assistance totaling approximately $20'million as of December 31, 2021, from which TOIG identified $98,242 in questioned costs from a sample, were made to eligible beneficiaries in the correct amounts, (b)'identify whether additional ERA1 ineligible and duplicate payments occurred after December 31, 2021 and, if applicable, provide the amount of such payments, and (c)'identify whether ineligible and duplicate payments were made during the entire ERA2 award period of performance and, if applicable, provide the amount of such payments. OCA should require corrected ERA1 and ERA2 reports from Houston and Harris County based on the results of the review. For any ERA1 payments determined to be ineligible or duplicative, OCA should ensure that the grantees return funds to Treasury. For any ERA2 payments determined to be ineligible or duplicative, OCA should ensure that the grantees return funds to Treasury or reimburse the grantees' ERA2 programs with non-Federal funds, as appropriate.

Office of Capital Access management should develop, document, and communicate to TOIG OCA's processes to monitor grantees for overpayments and duplicate payments, track grantees' recharacterizations, and ensure data quality for household addresses provided by grantees.

Office of Capital Access management should provide technical advice and counsel to all grantees and TOIG about the use of funds in circumstances where a landlord and a tenant are related. While OCA concurred with our recommendations and its planned corrective actions meet the intent of our recommendations, management did not provide an implementation date for its planned corrective action for our third recommendation regarding familial tenant/landlord relationships.