Determine whether the subcontractor is owed payment for 21 units, which the Department’s records showed were assisted under the Program but were not identified as assisted units according to documentation maintained by the Department to support its drawdowns from HUD’s LOCCS. If the Department determines that the subcontractor is owed payment for the lead-based paint and other health hazard control activities, it should provide support that the lead-based paint and other health hazard control activities were eligible and that the subcontractor was not reimbursed for these activities from non-Program funds. If these conditions have been met, the Department should reimburse the subcontractor from Program funds.

Determine whether appropriate reimbursements were made to the subcontractor for the remaining 166 assisted units that were not a part of our review. If the Department determines that appropriate reimbursements were not made, it should provide support that the lead-based paint and other health hazard control activities are Program eligible and the subcontractor was not reimbursed for these activities from non-Program funds. If these conditions have been met, the Department should reimburse the subcontractor from Program funds.

Support that the four households residing in assisted units were income eligible or reimburse its Program $59,883 from non-Federal funds for the lead-based paint and other health hazard control activities completed in the assisted units.

Support that landlords gave preference in renting six vacant units to families with children under 6 years of age or reimburse its Program $41,240 from non-Federal funds for the lead-based paint and other health hazard control activities completed at these assisted units.

Support that lead-based paint hazard control activities were necessary at 13 assisted units or reimburse its Program $23,857 from non-Federal funds for the unsupported lead-based paint hazard control activities completed at these assisted units.

Reimburse its Program $2,900 from non-Federal funds for the two units in which the seven windows were not installed.

Transfer $17,507 in non-Federal funds to its Childhood Lead Poisoning Prevention Program and use the funds in accordance with the program grant requirements since these funds were not recaptured after the four assisted units were sold within 3 years.

Execute agreements with owners of the assisted units detailing the Department’s recapture policy and determine whether liens should be filed with the appropriate government office to ensure that Program funds used to assist the units are properly protected and able to be recaptured if assisted units are resold within 3 years. These protections should ensure that $297,924 in Program funds is adequately protected.

Implement adequate procedures and controls to ensure that (1) contracts are properly procured in accordance with HUD’s requirements, (2) annual income is properly calculated for households residing in assisted units, (3) the appropriate reimbursement payments are made to the subcontractor for lead-based paint and other health hazard control activities, (4) lead inspection results properly support lead-based paint hazard control activities, (5) it complies with its work plan regarding executing agreements with property owners and determining whether other mechanisms are needed to enforce the agreements. This measure would ensure that future Program funds are protected, and (6) accurate and complete information regarding assisted units is reported to HUD.

Develop and implement adequate procedures and controls to ensure that assisted rental units are prioritized for families with children under 6 years of age.

Review the 17 travel cardholders with purchases that occurred without a travel authorization and the 6 travel cardholders with purchases that were not supported to determine whether the purchases were allowable, proper, and paid in full by the cardholder, taking appropriate administrative actions as necessary. These unsupported purchases totaled $6,407. However, a total of $5,780 remains after deducting the duplicate amount of $627 addressed in Recommendation 1C.

Perform an analysis of the 3,045 travel card purchases with indications that they were unauthorized or ineligible to identify potential violations and to address any unauthorized purchases identified. OCFO should perform a review of identified transactions to determine whether they were allowable, proper, and paid in full by the cardholder, taking appropriate administrative actions as necessary.

Refer the 15 ineligible travel card transactions totaling $5,393 to the appropriate program office and obtain a response regarding what administrative actions were taken to resolve the violations. If no actions were taken, OCFO should request support to show why no corrective actions were taken.

Strengthen internal monitoring efforts regarding government travel card use to identify potentially improper, illegal, or erroneous transactions. Such efforts should include data mining to detect instances of delinquency, fraud, and misuse.

Designate an unclaimed asset recovery official as required by the Treasury Financial Manual.

Work with Treasury to identify and obtain reimbursement for FHA’s and Ginnie Mae’s portion of the $1.9 million in HUD funds that Treasury collected.

Establish and implement policies and procedures to ensure that all of its unclaimed funds are claimed and the money is appropriately routed to put $2.2 million to better use. At a minimum, these policies and procedures should address what constitutes FHA and Ginnie Mae funds, ensure that these funds are returned to FHA or Ginnie Mae as appropriate, and include policies to claim co-owned funds with any appropriate thresholds or limitations.

We recommend that the Chief Financial Officer determine whether the summary expenditures totaling $160,360,714, which exceeded the grant round obligations for the two grantees, were ADA violations. If the transactions were violations, action should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed detail transactions totaling to $435,263,268, which occurred before and after grant rounds obligation and expenditure dates, were ADA violations. If the transactions were violations, actions should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed transactions totaling $496,913,235 and made more than a year after the original voucher entry were GAAP violations. If the transactions were violations, appropriate actions should be taken, including but not limited to adjusting the transactions in LOCCS and HUD’s financial statements.