Reimburse its program $111,568 from non-Federal funds for the ineligible payments it made due to the conflict-of-interest situations identified by the audit.

Submit a retroactive request for a waiver to the conflict-of-interest requirements to support payments totaling $1,499,137 or reimburse the appropriate fund from non-Federal funds for any amount not covered by a waiver.

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

Provide documentation to show that products and services totaling $171,822 were purchased at fair and reasonable prices. For any amounts determined to be unreasonable and not supported, the Authority should reimburse the program from non-Federal funds.

Reimburse its program $170,784 from non-Federal funds for the ineligible salary payments and ongoing security payments.

Develop and implement controls over its procurement actions to ensure that prices paid for goods and services are reasonable.

Develop and implement controls to ensure that program funds are used for eligible activities only.

Reimburse its program $279 from non-Federal funds for the ineligible payment it made due to the conflict-of-interest situation identified by the audit.

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

Provide documentation to show that indirect payroll expenses totaling $225,182 charged to the program were reasonable and necessary or repay its program from non-Federal funds for any amount that it cannot support.

Develop and implement a cost allocation plan to use as a basis for charging indirect payroll expenses to the program.

Provide documentation to show that administrative fees totaling $47,376 were used to perform administrative duties for the program or repay its program from non-Federal funds for any amount that it cannot support.

Develop and implement controls to ensure that administrative fees are used to perform administrative duties for the program.

Certify, along with the owners of the 10 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Provide training to its inspector on conducting housing quality standards inspections.

Develop and implement controls to ensure that an independent entity performs housing quality standards inspections of units that it substantially controls.

Submit a request for approval of an independent entity to perform rent reasonableness determinations for program units that it substantially controls.

Develop and implement controls to ensure that the independent entity approved in recommendation 1J performs rent reasonableness determinations for program units that it substantially controls.

Procure appropriate HUD-approved investment accounts and move all Federal funds from the STAR Ohio investment accounts to HUD-approved accounts to ensure that $20,706,862 or the current balance of the STAR Ohio accounts is properly protected.

Implement adequate procedures and controls to ensure that the Authority complies with HUD’s requirements for its investments of Federal funds.