Develop and implement procurement policies and procedures for monitoring subrecipients to ensure that the scope of work developed by its subrecipients is sufficiently detailed to allow contractors to submit informed bids, reducing the number of change orders after the contract, and that its subrecipients do an independent cost analysis before all procurement transactions, including change orders, to ensure that it receives a reasonable price and allows for full and open competition.

Develop and implement policies and procedures that ensure labor wage interviews are completed and documented.

Provide training to its staff on CDBG program rules and requirements to ensure that its staff adequately implements policies and procedures.

Identify the national objective met for the park project or repay the program $2,000,000 from non-Federal funds.

Develop monitoring practices to ensure that all projects that use limited clientele criteria exclusively serve the specific population claimed.

Repay $48,323 to the program from non-Federal funds for non-program-related payroll costs.

Determine the allocable amount of CDBG payroll costs for the employees who worked on CDBG and non-CDBG activities and adjust the funding amount as necessary or repay the program $573,064 from non-Federal funds.

Repay $71,397 to the program from non-Federal funds for the use of CDBG funds for code enforcement costs related to general government expenses.

Revise its code enforcement program to meet CDBG requirements for the remaining $33,603 budgeted or amend the use of the funding to another CDBG-eligible activity.

Determine the CDBG proportional benefit of the $329 charged for indirect automotive costs and repay the program any unsupported charges using non-Federal funds.

Obtain training or technical assistance from HUD concerning CDBG code enforcement, allocation of payroll, and indirect administrative costs.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to develop and implement a HUD approved written plan and checklists; and take actions that will correct and prevent the deficiencies outlined in the finding, improve program administration effectiveness, ensure compliance with HUD regulations and the policies and procedures it submitted and certified to HUD, and ensure it has the continuing capacity to carry out its activities, as required. Implementing this recommendation should ensure that the remaining $8,679,994 allocated in disaster funding is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support the cost reasonableness or repay its program from non-Federal funds $362,319 paid to its consultant contractor without an independent cost estimate.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support the cost reasonableness or repay its program from non-Federal funds $30,702 paid to its construction contractor for cost increases without adequate cost analyses.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support the cost reasonableness or repay its program from non-Federal funds $58,873 paid to its surveyor contractor for the sole-sourced contract without an adequate cost analysis.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to maintain program files with all required documentation for each activity.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to implement an internal audit function that satisfies program requirements.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to revise its monitoring policy to include the role of the internal auditor once implemented, and finalize and fully implement or revise its fraud, waste, and abuse detection policy to reflect current procedures.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to update its Web site to include current quarterly performance, budget, and progress reports.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to obtain technical assistance concerning the disaster recovery program requirements, including related Federal Register requirements. Specifically, the technical assistance should include guidance on how to satisfy the requirement regarding maintaining an internal audit function and Web site maintenance.