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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