Consider suggestions made by grantees to assist with the progress of spending funds and provide support for the guidance it plans to share with grantees based on these suggestions. (See bullets under Grantees Generally Considered CPD’s Assistance With the Progress of Their Grants Helpful.)

Develop and implement written policies and procedures and controls for the FHA refund process to address the deficiencies identified in the audit report. These should include (1) controls to ensure that the website for the public listing of all unpaid refunds is complete, (2) controls to ensure that refund applications are sent only to the homeowners who requested them, (3) controls to ensure that refund applications are sent to all homeowners…

Develop and implement written policies and procedures (1) for locating homeowners who have unpaid refunds (for both existing and new refunds), (2) to establish a standard timeframe for mailing refund applications to homeowners after they are requested, and (3) to establish requirements for verifying the termination date based on supporting documents provided by homeowners.

Research, develop, and implement policies and procedures to reduce the number of refunds that have remained unclaimed for an extended period, including consideration of a statute of limitations.

Develop and implement written policies and procedures regarding the designation of legal representation for applicants.

Obtain the required approvals under the Paperwork Reduction Act for the insert document mailed with the refund application and the Tracer Found Case form.

Work with the Authority to determine whether the buildings represent an imminent threat to public safety from physical deterioration and whether activities to control the situation would be exempt under the Part 58 environmental review process or excluded under the Part 50 environmental review process. If it qualifies, require the Authority to immediately take actions necessary to control the imminent threat to public safety before the full…

Determine whether it would be beneficial for HUD to conduct a Part 50 environmental review of the development or if the Authority should conduct a Part 58 environmental review, and implement the decision to ensure that the environmental review is conducted as soon as possible as required under the action plan.

Continue to provide training and technical assistance to ensure that the Authority understands relevant requirements for the various asset repositioning options, including milestone and disposition requirements.

Provide certifications and supporting documentation to show that it has identified and addressed urgent health and safety issues at the development, such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors.

Develop and implement a plan to routinely identify and address recurring urgent health and safety issues such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors while the property remains vacant and throughout future asset repositioning efforts.

Develop and implement a plan to use available asset repositioning options for the remaining 284 public housing units at the Commodore Perry Homes development, including 274 dwelling units and 10 nondwelling units.

Develop and implement a plan for the original property related to the 46 units converted under the RAD transfer of assistance option to ensure that the property and proceeds from its disposition are used in accordance with requirements.

If the Authority does not follow through on its asset repositioning plans, misses deadlines, or it otherwise becomes clear that the plan is no longer feasible, work with the HUD’s Special Applications Center, Office of Recapitalization, and other offices as appropriate, to consider and use available remedies such as revoking approval and enforcing required conversion.

Develop and implement policies and procedures to ensure that subgrantee agreements are executed in a timely manner, effective monitoring is performed, and subgrantees maintain an emphasis on using their CoC funds, thereby preventing similar occurrences of $3.5 million (see appendix D) in CoC funding going unused.

Develop and implement strategies to address capacity and organizational problems or obtain technical assistance to address these issues.

Develop and implement procedures and controls to clearly define and update point-of-contact staff for subgrantees.

Work with HUD and subgrantees to reevaluate its CoC program’s performance goals and set targets that help to ensure that funds for future CoC grants are fully and effectively used to advance the goal of ending homelessness.

Adequately support the eligibility of payroll costs or repay its CoC grants $824,302 from non-Federal funds.

Adequately support the eligibility of rent costs or repay its CoC grants $55,545 from non-Federal funds.