Implement adequate procedures and controls to ensure that it properly documents compliance with HUD’s environmental review procedures before the start of each job.

Implement adequate procedures and controls to ensure that third emergency repairs are documented in writing and reported to the County before completion of assistance in accordance with the subrecipient agreement.

Support or reimburse its Block Grant program from non-Federal funds for the $4,953 it provided to the corporation for one job for which the corporation lacked sufficient documentation to support that a member of the household was physically disabled.

Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that accessibility modifications are provided only to households with at least one member who is physically disabled.

Reimburse its Block Grant program from non-Federal funds for the $4,127 it inappropriately provided to the corporation due to not ensuring that the corporation reduced all of its program income from its invoices for housing repair services.

Support or reimburse its Block Grant program from non-Federal funds for the $107 it provided to the corporation for the January 2016 invoice that the corporation generally could not explain.

Implement adequate procedures and controls to ensure that the corporation reduces program income from its invoices for housing repair services.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide training to its staff to help ensure compliance with applicable cost principle, procurement, and Davis-Bacon requirements.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that it has strengthened its invoice review process to ensure that costs are eligible and supported before disbursing Disaster Recovery funds.

Require that the current or future lender ensure that the project uses a contractor that is proven to be qualified and capable of completing the project.

Provide adequate documentation to support that the $71,034 spent for improperly procured goods and services was spent at the most competitive prices. For any amounts not supported, it should reimburse its program from non-Federal funds.

Provide adequate documentation to support $15,280 spent for maintenance activities. For any amounts not supported, it should reimburse its program from non-Federal funds.

Develop and implement detailed operating procedures, including checklists, which fully implement its procurement policy and HUD requirements.

Ensure that its executive director obtains appropriate procurement training.

Work with the Authority to develop a formalized process, such as a checklist, to use when conducting initial certifications and annual recertifications, which would help to ensure that it follows HUD requirements for its public housing program.

Require the Authority’s executive director to obtain appropriate training regarding public housing occupancy requirements.

Require the Authority to conduct a 100 percent review of its tenant files to ensure that tenants’ rents are accurate and the proper income, asset, and medical expenses are complete and documented in the tenant files.

Monitor the Authority after the recommended training and tenant file reviews are complete to ensure that the executive director understands and properly implements public housing occupancy requirements.

Require the Authority to address actual or potential conflict-of-interest relationships in its Admissions and Continued Occupancy Policy.

Work with the Authority to develop a plan to ensure that a third party reviews the initial tenant certifications and annual recertifications with an actual or potential conflict of interest.