Implement information security controls over the Section 108 loan guarantee database that prevent and detect unauthorized changes to program data (or implement an updated Section 108 loan guarantee database with information security controls that prevent and detect unauthorized changes to program data).

Develop a formal enterprise risk management policy for program offices’ risk owners, including guidance for completing the annual risk profile refresh, requirements for completing risk mitigation strategies, and reporting risk mitigation progress to the Risk Management Council

Execute system code requests, including new program-level class and code, CAM 1 codes, in accordance with internal OCFO system standard operating procedures. Specifically, the CFO system code coordinator should verify that OCFO budget officers and program budget officers provide adequate documentation showing that the new CAM1 code is covered by an approved funds control matrix or sufficient justification for not requiring a funds control…

Develop and implement policy and procedures for the incremental obligation process used for project-based Section 8 funds, including documentation for determining the incremental amounts and controls to review the amounts for accuracy.

Assign independent, contract officers to review and certify the initiating contract buyer’s compliance with policies for initiating and authorizing interagency agreements and later modifications for all amounts in accordance with Acquisition Instruction 13-07, HUD Contracting Officers.

Ensure that contracting officers and OCPO field offices review and follow the records management policies and procedures, including completing and signing Forms 7600A and 7600B, to ensure consistency among contract officers approving interagency agreements in the procurement system of record.

Update and implement the internal procedures for processing housing conversion actions to require documentation, including but not limited to expired contracts or financial documentation from HUD’s Line of Credit Control System, to show when the last payment was made for the contract to support the proposed housing conversion actions before allotment of tenant protection funds.

Update and implement internal procedures to require verification that tenant protection funds were not previously allotted for the same type of housing conversion action.

For the remaining retroactive RAD conversion not completed, to take steps, including but not limited to maintaining adequate approval documentation to ensure that it enforces its requirement that the tenant protection assistance is provided to tenants before the submission of the RAD application.

For the remaining retroactive RAD conversion not completed, to take steps including but not limited to training staff responsible for reviewing and approving RAD applications to ensure that it enforces its requirement that the tenant protection assistance is provided to tenants before the submission of the RAD application.

We recommend that the Office of Multifamily Housing Programs enforce written policies and procedures to ensure that the verification and payment of housing assistance payment subsidies for properties it subsidizes are based on accurate and supported information.

We recommend that the Office of Multifamily Housing Programs establish and implement policies to ensure effective contract administration, including providing funding approvals for project-based contract administrators in a timely manner.

We recommend that the Office of Multifamily Housing Programs develop contingency policies and procedures to ensure that the properties it subsidizes receive adequate and verifiable continuous monitoring.

Develop and implement a HUD-approved cost allocation plan(s) that appropriately represents the benefit received by the Authority from the City’s HHS department and allocates overhead and operating costs to all programs managed by the Authority.

Support the eligibility of the $1,965,990 in overhead allocations through the application of a HUD-approved allocation plan (including offsetting the amount by applicable reimbursements) or repay the Housing Choice Voucher Program from non-Federal funds.

Determine the appropriate amount of general operating costs totaling $2,544,266 that applied to the Housing Choice Voucher Program in accordance with a HUD-approved cost allocation plan (including offsetting the amount by applicable reimbursements) and repay overcharges (estimated at $50,947) to the Program from the other applicable programs as appropriate or from non-Federal funds.

Support the eligibility of the $25,827 in personnel expenses from SPC (including offsetting the amount by applicable reimbursements) or repay its Housing Choice Voucher Program from the other applicable programs as appropriate or from non-Federal funds.

Support the eligibility of the $64,150 for accounting services charged to the Housing Choice Voucher Program that applied to other Authority programs (including offsetting the amount by applicable reimbursements) or repay the Program from the other applicable programs as appropriate or from non-Federal funds.

Support the reasonableness of the $340,701 Casterline contracts or repay the Housing Choice Voucher Program any amount that cannot be supported using non-Federal funds.

Support the reasonableness of the $33,415 Genesis contract or repay any amount that cannot be supported from non-Federal funds.