Implement its procurement controls to ensure that it is able to locate and maintain the complete procurement documents for at least 3 years after the closeout of NSP1 and NSP3 in compliance with its own procedures and HUD regulations.

Provide the required documents to support $161,131 in NSP1 and $109,525 in NSP3 funds for expenses for acquisition, rehabilitation, and administration. If the City cannot provide the required documents, it should repay the U.S. Treasury from non-Federal funds.

Repay the U.S. Treasury from non-Federal funds for the $1,550 overpaid to acquire a foreclosed NSP3 property.

Obtain technical assistance from HUD to ensure that it is able to manage the programs and comply with program regulations before processing future expenses related to NSP1 and NSP3 projects and activities.

Follow its NSP procedures and HUD regulations to complete and submit its future NSP1 and NSP3 HUD quarterly performance reports and annual single audit reports within the required timeframes until the closeout of the respective programs or until HUD is assured that these reports are consistently submitted on time.

Follow its own procedures and HUD regulations to post the missing 21 NSP1 and 22 NSP3 HUD quarterly performance reports, as of June 30, 2019, on its official website; and, post the future NSP1 and NSP3 HUD quarterly performance reports on its website until the closeout of the respective programs or until HUD is assured that these reports are consistently posted on its website.

Obtain technical assistance from HUD to ensure that the City is able to submit its quarterly performance reports and annual single audit reports on time and post the performance reports on its website to comply with program regulations.

Support the Child Crisis of Arizona campus creation project phase one met a national objective and was necessary and reasonable or repay its program $300,000 from non-Federal funds.

Improve and implement stronger policies and procedures for reviewing potential activities for funding, which include ensuring that they are necessary and reasonable, that the service area for the low- and moderate-income area benefit national objective includes the entire area served by the activity, and that the City has addressed concerns from those reviewing the application.

Support that the Eagles Park activity met an eligible CDBG national objective or repay its program $1,150,000 from non-Federal funds.

Support that the Save the Family Community Conference Center activity met a national objective or repay its program $981,779 from non-Federal funds.

Support that the Kleinman Park activity met a national objective or repay its program $249,300 from non-Federal funds and correct the installation of the playground fossils or repay the program from non-Federal funds.

Support that the West Mesa CDC special economic development activities for fiscal years 2016 and 2017 met a national objective and that expenses were adequately supported and for eligible activities or repay its program $175,975 from non-Federal funds.

Ensure that the $65,000 microenterprise activity awarded to West Mesa CDC for fiscal year 2019 meets CDBG requirements or amend the use of funding to another CDBG-eligible activity.

Support that the Ability360 Mesa Home Accessibility activity for fiscal years 2015, 2016, and 2017 followed HUD requirements and its subrecipient agreement or repay its program $192,563 from non-Federal funds. This includes supporting that all activities met the national objective requirements and were for rental properties, contracts were properly procured, the 10 percent match subrecipient agreement requirement was met ($4,293) and properly accounted for, and contract expenses were adequately supported ($228).

Ensure that the $6,809 allocated for the Mesa Home Accessibility activity for fiscal year 2017 meets HUD requirements or amend the use of funding to another CDBG-eligible activity.

Implement and reinforce its policies and procedures that require the City and its subrecipients to maintain adequate documentation to support the City’s CDBG program activities and maintain adequate documentation of subrecipient monitoring reviews. This includes tracking the status of monitoring reviews, communicating findings to subrecipients, and adequately resolving findings in a timely manner.

Support that the findings for the fiscal years 2011 and 2014 NEDCO activity were adequately resolved or repay its program $105,688 from non-Federal funds.

Ensure that the remaining $153,191 budgeted for the 2010 NEDCO activity meets HUD requirements or amend the use of funds to another CDBG-eligible activity.

Develop and implement procedures to ensure that City employees responsible for desk and onsite monitoring reviews and its subrecipients are aware of HUD and subrecipient requirements for each type of activity funded.