The Quality Control Plan (QCP) must include periodic reports that
identify for senior management areas of deficiency, including fraud
or violations of HUD regulations and the non-profit agencies own
policies and procedures, errors and omissions, and unacceptable
patterns or trends. The QCP must describe in detail the non-profit
agencies review procedures, record keeping procedures and outline
the corrective actions to be initiated immediately when discrepancies
are found.
The QCP should assure:
A) Records of Quality Control (QC) findings and actions
taken are maintained.
B) Periodic reports that identify deficiencies are provided
to senior management.
C) Prompt, effective corrective measures are taken by senior
management and documented when deficiencies are identified.
D) The non-profit has a procedure to report any violation
of law or regulation, any known false statement, fraud or program
abuse to HUD, the HUD-Office of the Inspector General or the appropriate
Federal, State or Local law enforcement agency.
In addition, the following elements represent components of a QCP,
but none of them are specifically required by HUD. However, non-profit
agencies are encouraged to include the following elements in their
QCP.
E) Have an impartial third party entity conduct the QC reviews
on the non-profit agencies activities.
F) Identify the procedures for expanding the scope of the
QC review when fraud or patterns of deficiency may exist.
G) Procedures to identify revisions in HUD guidelines are
established, and non-profit personnel are informed of the revisions
as they arise.
H) Non-profit employees are held accountable for performance
failures or errors.
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