Ensure that its staff is properly trained and familiar with HUD’s requirements to ensure that documentation necessary to support the reasonableness of contract costs is obtained and maintained.

Implement adequate procedures and controls to ensure that capital funds are drawn down and disbursed in accordance with HUD’s requirements.

Implement adequate procedures and controls to ensure that it properly reports its expenditures and disbursements in LOCCS in accordance with HUD’s requirements.

Repay from non-Federal funds the $1,190,977 in ineligible costs charged to the program.

Repay from non-Federal funds the $434,970 in unreasonable costs charged to the program

Support $249,015 in program costs spent on a 2014 grant for which the grantee was unable to provide a tier one environmental review record or repay from non-Federal funds any amount that cannot be supported

Support $676,922 for contracts that were improperly procured or repay from non-Federal funds any amount that cannot be supported.

Support $422,600 in program income that was not used before additional grant fund drawdowns or repay from non-Federal funds any amount that cannot be supported

Strengthen controls over program oversight to ensure that grantees comply with their agreements and program requirements, including tier two environmental reviews, contract procurements, and homeowner and project eligibility, to ensure that (1) all income, including rental income, is considered; (2) loan-to-value ratios do not exceed 90 percent without State approval; and (3) projects do not exceed the program limits without State approval.

Strengthen controls over monitoring to ensure that onsite monitoring and monitoring letters are completed in a timely manner and sufficient supporting documentation is required and reviewed by those responsible for grant oversight.

Develop and implement policies and procedures to assess the validity of all program complaints to ensure that they are addressed and resolved in a timely manner.

Provide additional guidance to its grantees regarding its policy stating that the repair or replacement of paved surfaces should be minimal in cost and incidental to the rehabilitation of the dwelling, including whether grantees are required to consult with the State before starting the work.

Reimburse its program $279 from non-Federal funds for the ineligible payment it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to prevent and detect conflict-of-interest situations.

Provide documentation to show that indirect payroll expenses totaling $225,182 charged to the program were reasonable and necessary or repay its program from non-Federal funds for any amount that it cannot support.

Develop and implement a cost allocation plan to use as a basis for charging indirect payroll expenses to the program.

Provide documentation to show that administrative fees totaling $47,376 were used to perform administrative duties for the program or repay its program from non-Federal funds for any amount that it cannot support.

Develop and implement controls to ensure that administrative fees are used to perform administrative duties for the program.

Certify, along with the owners of the 10 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Provide training to its inspector on conducting housing quality standards inspections.