Evaluate the owner’s capability to effectively manage the project and consider whether independent professional management services are needed.

Pursue civil money penalties and administrative sanctions, as appropriate, against the owner and its parent company and their principals for their part in the violations cited in this report.

Develop and implement adequate written policies to ensure that cardholders obtain appropriate authorizations to support charges to their government travel cards and establish a process for submitting a written request to OCFO for a merchant code unblock.

Develop and implement written policies to ensure that program offices adequately follow up on identified questionable charges and inform OCFO of significant travel card violations when they are identified.

Review the identified 3,160 transactions totaling $555,337 to determine whether they were for official government travel. If they were not for official travel, OCFO should determine whether the cardholders paid the credit bill for the improper charges, request reimbursement when applicable, and take all other appropriate actions.

Strengthen current purchase card controls to ensure that purchases are supported by all required approvals before the purchase is made.

Acknowledge that $41 million of the $89,274,944 in the attached settlement represents an amount due HUD, less DOJ’s civil debt collection fees.

Recapture the $248,222 in excess program funds from the Authority and allocate in the pool for other tribes to use in meeting program objectives.

Require the Authority to provide source documentation to determine the accuracy of the tribal enrollment numbers reported in 2015 and 2016. Based on those supported numbers, HUD should recapture or offset the unsupported amounts from the awarded $1,746,658 in program funds that resulted from under or overstated tribal enrollment numbers.

Require the Authority to establish and implement controls and formal written policies and procedures to ensure that accurate tribal enrollment numbers are reported to the Formula Service Center and HUD for future grant years.

Support the eligibility of the reported $548 in unsupported program costs or repay its program using non-Federal funds.

Implement controls to ensure that all future check request forms are complete for proper tracking in its accounting records and authorized approver verifies source documentation is attached prior to check issuance for future program expenses as required by its own policies and procedures.

Reimburse HUD $52,932 from non-project funds for the overpayment of housing assistance and utility allowances due to incorrect calculations.

Reimburse the appropriate households $566 from non-project funds for the underpayment of housing assistance due to incorrect calculations.

Reimburse HUD $32,334 for the overpayment of housing assistance due to unreported, and underreported income, or income reported late. This reimbursement is either from non-project funds or collections from applicable households.

Support or reimburse HUD $6,444 from non-project funds for the unsupported payments of housing assistance cited in the finding.

Implement adequate quality control procedures to ensure that housing assistance payments are appropriately calculated and supported. These procedures and controls should ensure that $76,107 in program funds are appropriately used for future payments.

Document the implementation of the quality control plan and the completed reviews of the tenant certification process.

Revise its occupancy standards to include policies and procedures to prevent underuse of the project’s units.

Review and update the project’s internal transfer waiting list to include the applicants’ move-in dates, and the project’s external waiting list to include notations showing the reasons why applicants were not admitted into the project’s program and why applicants were bypassed.