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.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify the $372,695 in unsupported Operating Fund subsidies received or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify $8,564 in excessive property management fees charged by the COCC or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to reimburse its Operating Fund from non-Federal funds $82,907 for 16 document management services contract payments that should have been paid with COCC funds.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls to ensure that operating funds are requested, received, and used in accordance with HUD, Federal, and Authority requirements.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to employees involved in the funding and expenditure processes to ensure compliance with HUD, Federal, and Authority requirements

Follow up on the 15 properties in our sample to ensure that the code enforcement violations have been corrected, that the necessary documentation has been gathered and retained in the code enforcement file for the property, and that the code enforcement process has been completed.

Provide documentation to support $671,838 in code enforcement costs or repay the program from non-Federal funds for any amount that it cannot support.

Develop and implement policies and procedures to ensure that its Block Grant-funded code enforcement activities comply with HUD requirements, including documentation requirements, thereby ensuring that funds totaling $301,866 can be put to better use.

Provide documentation to support $1 million in community policing salary costs or repay the program from non-Federal funds for any amount that it cannot support.

Develop and implement policies and procedures to ensure that Block Grant-funded community policing salaries and benefits comply with HUD requirements, including documentation requirements, thereby ensuring that funds totaling $295,935 are put to better use.

Implement adequate procedures and controls to ensure that it obtains and reviews source documentation, such as invoices and time sheets, to support that expenses are eligible before providing Block Grant funds to the corporation for housing repair services.

Reimburse its Block Grant program from non-Federal funds for the $5,810 it provided to the corporation for labor that exceeded actual labor costs (more than $4,800) and indirect costs associated with the excessive labor costs (nearly $1,000).

Review the labor costs associated with the remaining 1,645 (1,668 - 23 reviewed) jobs that we did not review to determine whether the Block Grant funds it provided the corporation for labor exceeded the actual labor costs for each job. If the labor exceeded the actual labor cost for a job, the County should reimburse its Block Grant program from non-Federal funds for the excessive labor costs and the indirect costs associated with the…

Implement adequate procedures and controls to ensure that it does not provide the corporation Block Grant funds for excessive labor costs.

Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that the cost of materials and services acquired for the program is reasonable.

Reimburse its Block Grant program from non-Federal funds for the $182 it provided to the corporation for a 4 percent surcharge that was inappropriately included on all materials.

Support or reimburse its Block Grant program from non-Federal funds for the $6,140 it provided to the corporation for indirect costs for which the corporation lacked sufficient documentation to support whether the indirect costs included lobbying-related expenses.

Support or reimburse its Block Grant program from non-Federal funds for the $1,541 it provided to the corporation for jobs for which the corporation lacked sufficient income documentation to support that the households were eligible for assistance.

Implement adequate procedures and controls to ensure that sufficient income documentation is maintained to ensure that households are eligible for assistance under the program and income is verified in accordance with HUD’s requirements and the subrecipient agreement.