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.

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.

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

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.

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.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to establish and implement desk and onsite monitoring policies and procedures to ensure that documentation is maintained to support that (1) adequate supporting documentation for payments is filed, tracked, and maintained; (2) the necessity for all change orders is verified and reasonableness of the costs is assessed; (3) cost estimates are completed before the bidding process; (4) work is completed before pay requests are approved and payments are made to the contractor; and (5) contractors are properly monitored throughout the rehabilitation process, including progress and final inspections.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to correct the property deficiencies identified during the onsite inspections related to the 20 contracts as applicable.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to inspect the remaining 33 homes for compliance with the contract specifications and HUD requirements and correct deficiencies as applicable.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to establish and implement complaint policies and procedures and ensure that its staff is aware of the procedures to ensure that participant complaints are properly handled in a timely manner.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to review and adjust staffing levels as needed to ensure adequate coverage.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to provide training to staff members to ensure that they are aware of policies and procedures and their responsibilities related to expenditures, monitoring, and addressing participant complaints.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development require the County to strengthen its policies and procedures to ensure that environmental reviews and environmental review exemptions are completed and documented before HOME funds are committed.

We recommend that the Director of HUD’s Newark, NJ, Office of Community Planning and Development require the County to strengthen its policies and procedures to ensure that activity address information in IDIS is current as required.

Submit all supporting documentation showing the eligibility and propriety of the $47,720 in unsupported matching contributions towards the ESG program or reimburse the ESG program from non-Federal funds.

Reconcile the data included in its CAPER with the data in its financial management system and correct any inaccurate information reported to HUD.

Develop and implement policies and procedures to ensure that its required matching contributions are properly supported.