Verify that the remaining 14 (Footnote 5 - As detailed in the Scope and Methodology section of this report, we reviewed 23 of the 37 commitments entered into IDIS by the City.) commitments made during the period January 1, 2013, through December 31, 2017, were properly supported with written agreements and accurately entered into IDIS.

Require the City to follow its newly developed policy regarding the execution of a written agreement that is signed and dated by all parties before the commitment of any funds in IDIS.

We recommend that the Deputy Assistant Secretary for Grant Programs require the State to support that seven applicants met the ownership and occupancy requirements or repay $396,905 to its program from non-Federal funds.

We recommend that the Deputy Assistant Secretary for Grant Programs require the State to support that it complied with the elevation requirements for two applicants or repay $118,244 to its program from non-Federal funds.

We recommend that the Deputy Assistant Secretary for Grant Programs require the State to implement additional controls and revise policies and procedures to ensure that adequate documentation is maintained in its files to support (1) recapture decisions, (2) eligibility related to ownership or occupancy, (3) ineligible decisions, (4) elevation considerations, and (5) mitigation of duplication of benefits issues related to override procedures and incorrect data provided by other agencies.

We recommend that the Deputy Assistant Secretary for Grant Programs require the State to implement additional controls and revise policies and procedures to ensure that the website is maintained and updated in compliance with requirements.

Require the four Community Compass providers reviewed to reimburse HUD $13,384 from non-Federal funds for ineligible costs from overcharged labor or travel costs.

Require the four Community Compass providers reviewed to either provide documentation to support $845,497 in unsupported labor and travel costs, for personnel not on approved work plans, and for work performed that was not described on the payment request or reimburse HUD from non-Federal funds for any costs that it cannot support.

Develop and implement policies and procedures for the Community Compass program, to include postaward monitoring, that ensures that providers and provider subcontractors comply with applicable requirements to avoid incurring expenses for unapproved personnel and overcharged labor and travel costs, thereby ensuring that as much as $15,475,981 is put to better use.

Develop and implement controls for the Community Compass program to ensure that it uses procurement contracts for services that directly benefit HUD, including the development, maintenance, and operation of the HUD Exchange website and preparation of the Annual Homelessness Assessment Report, thereby ensuring that as much as $5,060,494 is put to better use.

Develop and implement controls for the Community Compass program to ensure that it consistently applies subcontractor wage rates among all providers that use a subcontractor.

Implement adequate procedures and controls to ensure that it obtains and reviews source documentation, such as invoices and time sheets, to support that expenses are eligible before providing Block Grant funds to the corporation for housing repair services.

Reimburse its Block Grant program from non-Federal funds for the $5,810 it provided to the corporation for labor that exceeded actual labor costs (more than $4,800) and indirect costs associated with the excessive labor costs (nearly $1,000).

Review the labor costs associated with the remaining 1,645 (1,668 - 23 reviewed) jobs that we did not review to determine whether the Block Grant funds it provided the corporation for labor exceeded the actual labor costs for each job. If the labor exceeded the actual labor cost for a job, the County should reimburse its Block Grant program from non-Federal funds for the excessive labor costs and the indirect costs associated with the excessive labor costs that the County provided to the corporation.

Implement adequate procedures and controls to ensure that it does not provide the corporation Block Grant funds for excessive labor costs.

Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that the cost of materials and services acquired for the program is reasonable.

Reimburse its Block Grant program from non-Federal funds for the $182 it provided to the corporation for a 4 percent surcharge that was inappropriately included on all materials.

Support or reimburse its Block Grant program from non-Federal funds for the $6,140 it provided to the corporation for indirect costs for which the corporation lacked sufficient documentation to support whether the indirect costs included lobbying-related expenses.

Support or reimburse its Block Grant program from non-Federal funds for the $1,541 it provided to the corporation for jobs for which the corporation lacked sufficient income documentation to support that the households were eligible for assistance.

Implement adequate procedures and controls to ensure that sufficient income documentation is maintained to ensure that households are eligible for assistance under the program and income is verified in accordance with HUD’s requirements and the subrecipient agreement.