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.

We also recommend that the Director of HUD’s Departmental Enforcement Center evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.

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

Acknowledge the settlement amount of $149,500,000 and that $115,000,000 of the settlement represents restitution due HUD less DOJ’s civil debt collection fees.

We recommend that HUD’s Office of General Counsel, Office of Program Enforcement, acknowledge that the $40,000 in the settlement agreement represents an amount due HUD.

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.

Repay the U.S. Treasury $19,173 spent on ineligible assistance from non-Federal funds.

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.