We recommend that the General Deputy Assistant Secretary for Community Planning and Development, require field offices to upload referenced supporting documentation into CPD’s system for findings and concerns developed during the monitoring review.

We recommend that the General Deputy Assistant Secretary for Community Planning and Development, update exhibits to require staff to document procedures performed, provide sufficient explanation to verify procedures performed and conclusions drawn, and reference appropriate supporting Read More

Provide mandatory training on the revised Notice to the local field offices and to grantees that use CDBG funds for the code enforcement program to ensure compliance with requirements.

Develop and implement a financial management system in accordance with HUD requirements, including but not limited to permitting the disbursement of funds in a timely manner.

Ensure that $1,045,085 in CDBG funds drawn from HUD between July 1, 2015, and October 31, 2018, can be traced to a level, which ensures that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes, or reimburse the CDBG program from non-Federal funds Read More

Require the Municipality to return to its line of credit and put to better use $1,641 associated with the unspent program funds that have been carried over since December 2017.

Reimburse the CDBG program from non-Federal funds the $106 paid for ineligible bank penalties.

Establish and implement adequate controls and procedures to permit proper accountability for all CDBG funds to ensure that they are used solely for authorized purposes and properly safeguarded.

Submit supporting documentation showing how $469,974 in CDBG funds disbursed for street improvements was properly used and in accordance with HUD requirements or reimburse the CDBG program from non-Federal funds.

Determine the amount spent for the resurfacing of the 16 private properties identified and reimburse the CDBG program from non-Federal funds.

Establish and implement adequate policies and procedures, including project inspection protocols, to ensure that CDBG funds are used for activities that meet a national objective, are used for eligible purposes, and are properly supported.

Director for the Office of Field Management ensure that the CDBG-DR risk analysis worksheet includes risk factors that show the measurement of performance outputs to determine completed activities.

Director for the Office of Field Management update the risk analysis guidance for CDBG-DR grants to include the assessment of the likelihood of risk occurrence to help inform management which critical risks to address during monitoring.

Review and update its 2017 CDBG-DR policies and procedures to prevent duplication of benefits and ensure that these are comprehensive and all applicable activities are included, including but not limited to the Small Business Financing Program and the Construction and Commercial Revolving Loan Read More

Negotiate with Puerto Rico’s Insurance Commissioner and with other CDBG-DR grantees, within 30 days of the issuance of this audit report, to establish data-sharing agreements for the 2017 CDBG-DR grant disaster, any open disaster recovery grants, and future disasters.

Review and update its procurement policy for the 2017 CDBG-DR grant to address weaknesses identified, including but not limited to required contract clauses, processes for soliciting and accepting noncompetitive proposals, and performing cost or price analyses before receiving bids or quotations, Read More

Ensure that the 2017 CDBG-DR procurement policy addresses the establishment of a contract register that, at a minimum, contains the procurement information specified in section 3.8 of HUD’s Buying Right Guide regarding the PRDOH’s acquisitions of goods and services, as well as of its subrecipients Read More

Establish procurement policies and procedures for the 2008 CDBG-DR grant to ensure compliance with 2 CFR 200.318-326, including but not limited to procedures to ensure full and open competition, supporting independent cost estimates, properly documenting the procurement history, and including Read More

Continue to fill its vacancies with qualified and trained staff, thus ensuring that staffing levels remain adequate to administer the 2017 and 2008 CDBG-DR grant funds.

Submit supporting documentation showing that contracts and purchase orders complied with Federal and its own procurement requirements and that these were reasonable and necessary costs or reimburse the CDBG-DR program $55,010 from non-Federal funds.