Support the $797,222 in code enforcement costs, including meeting code enforcement and salary and benefits requirements, or repay its program from non-Federal funds.

Develop and implement written policies and procedures to define deteriorated or deteriorating areas, which would apply to its CDBG-eligible target areas, and establish a written plan for using the program, in conjunction with public or private improvements, rehabilitation, or services, that may be expected to arrest the decline in CDBG-eligible target areas.

Develop and implement written procedures and controls to properly track and charge code enforcement officers’ costs among different CDBG activities and other funding sources.

Provide training to code enforcement staff on HUD CDBG regulations and requirements.

Amend its 2015 annual action plan to include the Main Street Revitalization program.

Implement controls and procedures to ensure that all future action plans include all methods of distributing grant funds or amend the plan as required if programs are added after approval.

Provide documentation to support the $811,325 in code enforcement costs (activities 591, 619, and 645), including meeting code enforcement and salary and benefit requirements,4 or repay the program from non-Federal funds.

Develop and implement a targeted code enforcement strategy that specifies deteriorating or deteriorated areas where code enforcement would be expected to arrest decline. The strategy should include a description of public or private improvements, rehabilitation, or services that would help facilitate code enforcement and also include performance metrics to track progress.

Develop and implement policies and procedures to ensure that code enforcement salaries and benefits are charged and documented in accordance with program requirements.

Provide documentation to support $285,496 in graffiti abatement expenditures or repay the program from non-Federal funds (appendix D).

Develop and implement procedures and controls to ensure that graffiti abatement expenditures, including salaries and benefits, are accurately charged to CDBG grants and properly supported.

Support the unsupported amount of match for its subgrantee or repay HUD $54,473 from non-Federal funds (appendix D).

Implement written procedures to include the confirmation of match funds as part of its annual monitoring reviews of each subgrantee.

Develop and implement a written plan for its subgrantees to provide and submit supporting documentation for match funds at the end of each grant term.

Support sampled retroactive payroll costs totaling $12,109, which correspond to the actual time attributed to grants CA0689L9D011502, CA0880L9D011501, CA0881L9D011501, and CA0945L9D011506, or reimburse HUD from non-Federal funds.

Identify retroactive payroll for remaining grants (CA1162L9D011504, CA1024L9D011501, CA0694L9D011508, and CA0693L9D011508) and provide adequate documentation to support the cost or repay HUD from non-Federal funds.

Develop and implement additional procedures and controls to ensure that payroll costs charged to the grant reconcile to actual hours worked on the grants.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to develop and implement a HUD-approved written plan and procedures and take actions that will correct and prevent the deficiencies noted in the finding, improve program administration effectiveness, strengthen the control environment, ensure compliance with HUD regulations and its own policies and procedures, and ensure that it has the continuing capacity to carry out its HOME program activities as required. Implementing this recommendation should ensure that the $216,663 in HOME funding allocated for the Parish’s property rehabilitation program is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to Repay its program from non-Federal funds for $9,849 in payments made to contractors for duplicate payments and overpayments.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support or repay its program from non-Federal funds $1,020,121 for payments made (1) for work that the contractor(s) did not perform and excessive material costs; (2) that lacked adequate supporting documentation for change orders, independent cost estimates, and invoice documentation; or (3) for the 10 HOME-funded rehabilitated homes not brought up to code.