We recommend that the Director of the HUD's Buffalo Office of Community Planning and Development instruct City officials to reprogram unexpended funds of $2,516 on a subgrantee agreement that expired June 30, 2015, for use by other eligible CDBG activities so that these funds are put to better Read More

We recommend that the Director of the HUD's Buffalo Office of Community Planning and Development instruct City officials to strengthen monitoring procedures for CDBG-funded subgrantees to ensure compliance with program requirements.

We recommend that the Director of the HUD's Buffalo Office of Community Planning and Development instruct City officials to provide documentation to adequately support that $70,538 disbursed and $150,000 obligated were for eligible costs. Any costs determined to be ineligible should be reimbursed Read More

Include compliance with environmental review requirements in its project-specific reviews in its next periodic monitoring of the City’s Block Grant program.

Train its staff on reporting accomplishments in IDIS and develop and implement policies and procedures for supervisory review to ensure accuracy.

Train its staff on requirements for documenting costs funded by multiple funding sources.

Develop and implement controls to ensure that subrecipients comply with requirements for documenting costs funded by multiple funding sources.

Determine whether it has complied with environmental review requirements for all activities since October 2010 and provide a copy of its determination to HUD. If it did not comply, either provide the necessary support for the activities or repay its program from non-Federal funds for any activity Read More

Develop and implement controls to ensure that it complies with environmental review requirements.

Review accomplishment data that it reported in IDIS for open and completed activities to ensure that accomplishments were reported accurately.

Provide documentation to show that seven activities with costs totaling $2,266,543 were exempt or categorically excluded from environmental reviews or repay its program from non-Federal funds for any amount that it cannot support (excluding any amount repaid as a result of recommendations 1A, 1B Read More

Provide documentation to show that costs totaling $100,000 for activity 6865 benefited the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $942,636 for activity 7099 were for employees’ actual time spent benefiting the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that prices paid for products and services totaling $1,423,262 for three activities were fair and reasonable or repay its program from non-Federal funds for any amount that it cannot support.

Revise its policies and procedures to address compliance with applicable procurement regulations requiring independent cost estimates before receiving bids or proposals.

Develop and implement adequate environmental policies and procedures to ensure that HOME activities are properly classified, the environmental review is documented and supported, and that HUD and Federal environmental requirements have been followed before committing HOME funds to an activity

Cancel activities in IDIS that have had no construction in more than 12 months.

Develop and implement adequate underwriting policies and procedures for their affordable housing activities and for the downpayment assistance program to ensure that HOME activities are consistent and meet Federal requirements. Further, they should include the downpayment underwriting policies and Read More

Support that $1,253,596 in funds not yet expended was reasonable, supported, and allowable or reallocate the funds, thus ensuring that they will be put to their intended use.

Support that $1,559,908 in HOME funds disbursed was reasonable, supported, and allowable in accordance with Federal requirements or repay from non-Federal funds any amount that cannot be supported.