Initiate appropriate administrative actions and debarments against parties, including the former grants manager and contractors, who contributed to the mismanagement of program funds.

We recommend that HUD’s Office of General Counsel, Office of Program Enforcement, acknowledge that $30,000 in the settlement agreement represents an amount due HUD.

Update the program’s information reporting requirements on form HUD-4117 to ensure that grantees report tribal enrollment numbers annually regardless of whether there are changes or corrections.

Revise form HUD-4117 to include certification and false claim statements that hold grantees responsible for reporting accurate tribal enrollment numbers to HUD annually.

Develop and implement policies and procedures to assist in formal challenging of grantees’ reporting tribal enrollment numbers in accordance with applicable requirements.

Issue guidance to grantees on procedures to ensure accurate reporting of tribal enrollment numbers.

Require the Authority to design and implement controls to ensure that employees comply with RAD relocation requirements and that its RAD conversion plans submitted to HUD accurately address any tenant relocations.

Monitor the Authority to ensure that it does not improperly relocate tenants during its planned conversion of the remaining public housing units.

Conduct a compliance review of relocation and pursue corrective action as necessary on behalf of the permanently relocated tenants.

Acknowledge that $40,000 in the attached settlement represents an amount due HUD.

Evaluate the apparent conflict-of-interest situation in this report and pursue administrative sanctions if warranted.

Provide documentation to support $280,561 (housing assistance and utility allowance payments totaling $237,809 for families that did not meet eligibility requirements and $42,752 in administrative fees) or reimburse its program from non-Federal funds for any amounts it cannot support.

Reimburse its program $17,101 from non-Federal funds for the overpayment of housing assistance and utility allowances to 14 families.

Reimburse five households $984 from program funds for the underpayment of housing assistance and utility reimbursements due to incorrect calculations.

Develop and implement procedures and controls to ensure that housing assistance and utility allowance payments are correctly calculated, including the use of the Enterprise Income Verification system to verify household income, and that they are adequately supported.

Correct the errors in the files identified in this report.

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.