Complete a cost breakdown to support the $10,731 spent on a rental property, which included assistance to an ineligible unit, and repay the ineligible assistance to the U.S. Treasury from non-Federal funds.

Recalculate annual income for participants assisted with the 2014 lead hazard control grant to support the $1,803,705 spent. For any assistance the Health Department cannot support with complete income calculations, it should repay the U.S. Treasury from non-Federal funds, less any amount repaid as a result of recommendations 1B and 2A.

Develop and implement policies and procedures that clarify the definition of annual income to be used, calculation components, and the documentation required to calculate income.

Develop and implement procedures for quality control reviews to ensure that annual income is properly calculated.

Provide training on HUD’s income requirements to employees responsible for calculating income.

Provide support showing the $79,738 spent on window replacement qualified or repay the U.S. Treasury from non-Federal funds.

Develop and implement policies and procedures to ensure that all windows replaced meet lead hazard qualifications.

Develop and implement quality control procedures to ensure that all bid specifications are reviewed for qualified items based on the risk assessment results.

Update the Health Department’s work plan to include policies and procedures for defining, determining, and documenting relocation hardship for all participants.

Develop and implement policies and procedures to ensure that the property owners receive the required information concerning lead-based paint disclosure requirements, risk assessment results, summaries of treatments and clearances, and ongoing maintenance activities, including how to report paint deterioration.

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.