Provide mandatory training on the revised Notice to the local field offices and to grantees that use CDBG funds for the code enforcement program to ensure compliance with requirements.

Ensure that the updated and revised notice is issued with the appropriate clearance.

Obtain HUD approval of policies and procedures before executing its subrecipient agreements and ensure that its finalized policies and procedures include but not limited to financial management, procurement, duplication of benefits, and monitoring.

Establish adequate financial controls to ensure that its disaster funds are properly classified and allocated to the correct grant and ensure that DRGR drawdowns are conducted in a timely manner.

Provide adequate training to staff on the appropriate classification of disaster recovery activities to ensure costs are accurately allocated and recorded.

Continue to establish a data sharing agreement with FEMA for Hurricanes Hermine and Matthew to ensure that all sources of funding are included in its disaster policies and procedures to prevent duplication of benefits and ensure that the term of the agreement is sufficient.

Continue to negotiate with SBA to extend its data-sharing agreements for the term of the expenditure requirements set forth in public laws or the Federal Register.

Continue to fill its vacancy and assess staffing resources as it prepares for additional disaster funds.

Repay from non-Federal funds the $1,190,977 in ineligible costs charged to the program.

Repay from non-Federal funds the $434,970 in unreasonable costs charged to the program

Support $249,015 in program costs spent on a 2014 grant for which the grantee was unable to provide a tier one environmental review record or repay from non-Federal funds any amount that cannot be supported

Support $676,922 for contracts that were improperly procured or repay from non-Federal funds any amount that cannot be supported.

Support $422,600 in program income that was not used before additional grant fund drawdowns or repay from non-Federal funds any amount that cannot be supported

Strengthen controls over program oversight to ensure that grantees comply with their agreements and program requirements, including tier two environmental reviews, contract procurements, and homeowner and project eligibility, to ensure that (1) all income, including rental income, is considered; (2) loan-to-value ratios do not exceed 90 percent without State approval; and (3) projects do not exceed the program limits without State approval.

Strengthen controls over monitoring to ensure that onsite monitoring and monitoring letters are completed in a timely manner and sufficient supporting documentation is required and reviewed by those responsible for grant oversight.

Develop and implement policies and procedures to assess the validity of all program complaints to ensure that they are addressed and resolved in a timely manner.

Provide additional guidance to its grantees regarding its policy stating that the repair or replacement of paved surfaces should be minimal in cost and incidental to the rehabilitation of the dwelling, including whether grantees are required to consult with the State before starting the work.

Support that the 59 contracts awarded for the emergency repair program were fair and reasonable or repay its program $272,569 from non-Federal funds.

Obtain technical assistance from HUD to revise its Emergency Repair Program to meet CDBG requirements.

Support that the contract awarded for the food incubator study was fair and reasonable and met a final cost objective or repay its program $50,000 from non-Federal funds.