Recalculate annual income for participants assisted with the 2014 lead hazard control grant to support the $1,803,705 spent. For any assistance the Health Department cannot support with complete income calculations, it should repay the U.S. Treasury from non-Federal funds, less any amount repaid as a result of recommendations 1B and 2A.

Develop and implement policies and procedures that clarify the definition of annual income to be used, calculation components, and the documentation required to calculate income.

Develop and implement procedures for quality control reviews to ensure that annual income is properly calculated.

Provide training on HUD’s income requirements to employees responsible for calculating income.

Provide support showing the $79,738 spent on window replacement qualified or repay the U.S. Treasury from non-Federal funds.

Develop and implement policies and procedures to ensure that all windows replaced meet lead hazard qualifications.

Develop and implement quality control procedures to ensure that all bid specifications are reviewed for qualified items based on the risk assessment results.

Update the Health Department’s work plan to include policies and procedures for defining, determining, and documenting relocation hardship for all participants.

Develop and implement policies and procedures to ensure that the property owners receive the required information concerning lead-based paint disclosure requirements, risk assessment results, summaries of treatments and clearances, and ongoing maintenance activities, including how to report paint deterioration.

Acknowledge that $40,000 in the attached settlement represents an amount due HUD.

Evaluate the apparent conflict-of-interest situation in this report and pursue administrative sanctions if warranted.

Provide documentation to support $280,561 (housing assistance and utility allowance payments totaling $237,809 for families that did not meet eligibility requirements and $42,752 in administrative fees) or reimburse its program from non-Federal funds for any amounts it cannot support.

Reimburse its program $17,101 from non-Federal funds for the overpayment of housing assistance and utility allowances to 14 families.

Reimburse five households $984 from program funds for the underpayment of housing assistance and utility reimbursements due to incorrect calculations.

Develop and implement procedures and controls to ensure that housing assistance and utility allowance payments are correctly calculated, including the use of the Enterprise Income Verification system to verify household income, and that they are adequately supported.

Correct the errors in the files identified in this report.

Develop and implement procedures and controls to ensure that required eligibility documentation is obtained and maintained to support households’ selection from its waiting list and admission to and continued assistance on the program.

Develop and implement controls to ensure that employees comply with its computer, internet, and email use policy and use only official business email accounts to transmit confidential information.

Develop and implement controls to ensure that its Section 8 coordinator is adequately trained and supervised to ensure that the program operates in accordance with requirements.

Follow its administrative plan to ensure that program requirements are met.