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.

Ensure the privacy program is staffed with experienced personnel (such as a Chief Privacy Officer) to manage the operational aspects of the program.

Issue a notice at the Secretary level delegating and clarifying the authority and responsibilities of the SAOP and Privacy Office

A. Document the roles and specific responsibilities of all positions assigned privacy responsibilities. B. Communicate these responsibilities on a recurring basis, at least annually, to individuals holding these positions.

Implement thorough human capital processes to ensure execution of the HUD privacy program and all its requirements

Finalize and approve the draft privacy program strategic plan

Ensure the privacy program is integrated with the enterprise risk program and that privacy risks are incorporated into the agency risk management process

Establish an executive leadership dashboard to communicate continuous monitoring of key program risks and issues

A. Develop an internal privacy program communication plan to describe how privacy issues will be disseminated and best practices will be shared. B. Implement the communication plan

Develop a dedicated budget to address Privacy Office training needs and initiatives

Update all privacy guidance to reflect current Federal requirements and processes.

Implement a formal process for the Privacy Office to issue and communicate privacy guidance, requirements, and deadlines.

Update and continue to maintain a central collaboration area to include all current privacy program policies, procedures, and guidance

Establish standard processes to ensure consistent work flow and communications between program office and Privacy Office personnel

Ensure role-based privacy training is provided to all personnel with privacy responsibilities

Ensure privacy awareness training is provided to all contractor and third party personnel