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.

Provide technical assistance to the Authority to ensure that it properly administers its program and that program regulations are met.

Evaluate the Authority’s email system and its computer, internet, and email use policy to determine whether they provide sufficient safeguards for transmitting and handling confidential information.

Reimburse its program $119,023 from non-Federal funds for the ineligible housing assistance payments it made due to the conflict-of-interest situation identified by the audit and any additional ineligible housing assistance payments it made outside our review period.

Develop and implement controls to prevent and detect conflict-of-interest situations.

Provide documentation to support the $811,325 in code enforcement costs (activities 591, 619, and 645), including meeting code enforcement and salary and benefit requirements,4 or repay the program from non-Federal funds.

Develop and implement a targeted code enforcement strategy that specifies deteriorating or deteriorated areas where code enforcement would be expected to arrest decline. The strategy should include a description of public or private improvements, rehabilitation, or services that would help facilitate code enforcement and also include performance metrics to track progress.

Develop and implement policies and procedures to ensure that code enforcement salaries and benefits are charged and documented in accordance with program requirements.

Provide documentation to support $285,496 in graffiti abatement expenditures or repay the program from non-Federal funds (appendix D).

Develop and implement procedures and controls to ensure that graffiti abatement expenditures, including salaries and benefits, are accurately charged to CDBG grants and properly supported.

Support the unsupported amount of match for its subgrantee or repay HUD $54,473 from non-Federal funds (appendix D).

Implement written procedures to include the confirmation of match funds as part of its annual monitoring reviews of each subgrantee.

Develop and implement a written plan for its subgrantees to provide and submit supporting documentation for match funds at the end of each grant term.

Support sampled retroactive payroll costs totaling $12,109, which correspond to the actual time attributed to grants CA0689L9D011502, CA0880L9D011501, CA0881L9D011501, and CA0945L9D011506, or reimburse HUD from non-Federal funds.

Identify retroactive payroll for remaining grants (CA1162L9D011504, CA1024L9D011501, CA0694L9D011508, and CA0693L9D011508) and provide adequate documentation to support the cost or repay HUD from non-Federal funds.

Develop and implement additional procedures and controls to ensure that payroll costs charged to the grant reconcile to actual hours worked on the grants.

Certify, along with the owners of the 63 units cited in this finding, that the applicable housing quality standards violations have been corrected.