Update and obtain final NARA approval of all HUD records retention schedules, including the Capstone email schedule, to comply with Federal requirements, including OMB M-19-21.

Develop and approve an enterprise strategy to meet all M-19-21 electronic transition requirements.

Issue a formal policy and requirements for managing CUI.

Establish and disseminate a policy on safeguarding or prohibiting the transportation of PII records out of the office for telework purposes.

Complete the development of performance measures and establish a formal records evaluation process to measure the effectiveness and progress of the records management program.

Standardize processes and duties for all RMLOs.

Conduct a staffing resource assessment for the HUD records program and identify any skills gaps or resource needs.

Provide documentation to show that the proposal of the vendor that it selected and paid $860,132 was the most advantageous or reimburse its program from non-Federal funds for any amounts that it cannot support.

Develop and implement controls to monitor its agent to ensure that it procures products and services in accordance with applicable Federal procurement requirements.

Reimburse its program $156,675 from non-Federal funds for the ineligible payments it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to ensure that it obtains waivers from HUD before entering into agreements that create conflict-of-interest situations.

Provide training and technical assistance to the Authority to ensure that it understands the proper use of intergovernmental agreements in accordance with HUD requirements.

Support that $916,132 spent on contracts was fair and reasonable in accordance with Federal requirements or repay the Operating Fund or Capital Fund program from non-Federal funds any amount that cannot be supported.

Support that $408,968 in funds not yet spent on contracts would be fair and reasonable or reallocate the funds to ensure that they will be put to their intended use.

Reprocure any contracts for which cost reasonableness cannot be supported and contracts were not properly awarded to ensure compliance with HUD requirements.

Ensure that all Authority staff members working with procurements and contract administration receive Federal procurement training.

Establish and implement adequate record-keeping procedures to comply with Federal procurement requirements, including a checklist for the file to ensure that they complete all procurement requirements and receive all required documents.

Ensure that all architectural and engineering contracts or task orders awarded during our audit period are reviewed for cost reasonableness.

Repay the Operating Fund program from non-Federal funds for the $37,941 in ineligible costs when the amount paid exceeded the contract value.

Establish and implement adequate controls so the Authority does not exceed the contract amount without appropriate contract amendments and written approvals.