Review all administration drawdown vouchers and provide documentation to support that the drawdowns for estimated payroll costs are reconciled with the actual payroll costs for the pay periods. Any calculated overpayment by NSP should be returned to the program to meet program purposes.

Provide clearer guidance and instruction to PL 113-2 disaster grantees to assist them in establishing an effective internal audit activity.

Establish a recurring training and discussion forum among the PL 113-2 grantees and CPD that enables grantees to share ideas and receive guidance and information about CPD’s expectations regarding the internal audit requirement.

Reevaluate the feasibility of the two Section 108 activities that failed to meet a national objective and determine the eligibility of the $15,814,000 already invested. Any amount determined ineligible must be reimbursed to the program from non-Federal funds.

Require the borrowers to submit a plan for how they will proceed and use the $8,694,000 million in unused commitments to provide the intended benefits and meet program objectives.

Require the borrower to provide all supporting documentation and evaluate the allowability and eligibility of $75,000 used for the unauthorized activity. Any amount determined ineligible must be reimbursed to the program from non-Federal funds.

Develop procedures directing field offices to include the review of Section 108-funded activities when performing the annual reviews of Block Grant recipients.

Develop procedures to ensure that the information necessary to monitor program performance and compliance with program requirements is promptly provided to the field offices.

Implement procedures to ensure that borrowers comply with all loan contract provisions and that required documents are submitted, including bank agreements, monthly statements, and security documents. If a borrower does not provide evidence that it has complied with all program requirements, HUD must initiate appropriate remedial actions under paragraph 12 of the contract.

Develop and implement a tracking system for monitoring reviews of Section 108 loans.

Support the reasonableness of the amount paid for the food facility consolidation and expansion project or repay the program $1,663,758 from non-Federal funds.

Correct any citations from the Southern Nevada Health District at the Pettiti public pool before May 2017 using non-Federal funds or repay the entire project cost of $596,126 from non-Federal funds and support the reasonableness of the change orders for the Pettiti pool project or repay the program from non-Federal funds.

Support the cost reasonableness of $2,809 in change orders for the ADA pool improvement project or repay the program from non-Federal funds.

Provide supporting documentation for $4,955 in unsupported costs or repay the program from non-Federal funds.

Provide support showing that the ADA pool improvement project allows equal and independent access for people with disabilities through a third party or correct the access issue.

Develop and implement procurement policies and procedures for monitoring subrecipients to ensure that the scope of work developed by its subrecipients is sufficiently detailed to allow contractors to submit informed bids, reducing the number of change orders after the contract, and that its subrecipients do an independent cost analysis before all procurement transactions, including change orders, to ensure that it receives a reasonable price and allows for full and open competition.

Develop and implement policies and procedures that ensure labor wage interviews are completed and documented.

Provide training to its staff on CDBG program rules and requirements to ensure that its staff adequately implements policies and procedures.

Identify the national objective met for the park project or repay the program $2,000,000 from non-Federal funds.

Develop monitoring practices to ensure that all projects that use limited clientele criteria exclusively serve the specific population claimed.