Develop and implement a financial management system in accordance with HUD requirements, including but not limited to permitting the disbursement of funds in a timely manner.

Require the Municipality to return to its line of credit and put to better use $1,641 associated with the unspent program funds that have been carried over since December 2017.

Reimburse the CDBG program from non-Federal funds the $106 paid for ineligible bank penalties.

Establish and implement adequate controls and procedures to permit proper accountability for all CDBG funds to ensure that they are used solely for authorized purposes and properly safeguarded.

Submit supporting documentation showing how $469,974 in CDBG funds disbursed for street improvements was properly used and in accordance with HUD requirements or reimburse the CDBG program from non-Federal funds.

Determine the amount spent for the resurfacing of the 16 private properties identified and reimburse the CDBG program from non-Federal funds.

Establish and implement adequate policies and procedures, including project inspection protocols, to ensure that CDBG funds are used for activities that meet a national objective, are used for eligible purposes, and are properly supported.

Repay from non-Federal funds the $665,920 in ineligible costs charged to the program

Support that 14 projects, with $494,517 in construction costs, met the environmental review requirements and repay from non-Federal funds any amounts attributed to projects that cannot be certified.

Provide additional guidance to their grantees and strengthen controls to ensure that tier two environmental reviews are performed and properly conducted and signed by the responsible entity before committing program funds.

Support $401,870 for contracts that were awarded without an independent cost estimate or repay from non-Federal funds any amount that cannot be supported.

Provide additional guidance to their grantees and strengthen controls over procurement to ensure that grantees follow applicable State and Federal procurement requirements, including obtaining independent cost estimates and ensuring full and open competition.

Define which expenses should be considered program delivery costs and strengthen controls over program costs to ensure that costs are properly charged.

Provide documentation to support housing assistance payments the projects received totaling $497,762 or reimburse HUD from nonproject funds for any amount that it cannot support.

Implement controls to ensure that it maintains adequate documentation in the tenant files to show that tenants were eligible for assistance and that the housing assistance payments were supported.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to certify, along with the owners of the 52 units cited in the finding, that the applicable housing quality standards violations have been corrected.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to reimburse its program $28,303 from non-Federal funds ($26,044 for housing assistance payments and $2,259 in associated administrative fees) for the six units that materially failed to meet HUD’s housing quality standards.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to improve controls over its inspection process to ensure that program units meet housing quality standards and that the results of inspections are used to enhance the effectiveness of its housing quality standards inspections, thereby ensuring that an estimated $760,363 in future program funds is spent for units that meet HUD’s housing quality standards. These controls include but are not limited to controls to ensure that (1) inspectors apply their training to thoroughly inspect units and consistently categorize failure items, (2) inspectors use a form that includes the key aspects of housing quality standards performance and acceptability criteria, and (3) results data are accurate and comply with applicable requirements.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to improve controls over the housing quality standards quality control inspections to ensure that quality control inspections meet HUD’s minimum sample size and that the sample is drawn from recently completed housing quality standards inspections.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to improve controls over its abatement process to ensure that it consistently (1) starts abatement when required, (2) verifies and documents the correction of violations, (3) resumes housing assistance payments after the end of the abatement period, and (4) maintains sufficient documentation to support the abatement and reinstatement for each unit.