We recommend that HUD require the City to since the property updates have been completed for the 24 program participants that did not receive the green infrastructure training, provide documentation that any subsequent program participants completed the green infrastructure training workshop before the grant agreement is signed and construction begins.

We recommend that HUD require the City to provide supporting documentation for the 4 program participants that did not have adequate income documentation. If the supporting documentation cannot be provided, repay, from nonfederal funds, $99,347.

We recommend that HUD require the City to support or repay, from nonfederal funds, $5,078 in the square footage overcharge for work not completed, according to the project design and invoice documentation.

We recommend that HUD require the City to analyze the effectiveness of the Retrofit program and identify what improvements are needed to better benefit program participants and lessen their burden, to include obtaining input from program participants, and implement those improvements.

We recommend that HUD require the City to develop and implement a plan for how to review the condition of the property updates and determine where repairs are needed.

We recommend that HUD require the City to develop and implement a methodology for NORA to conduct periodic evaluations at appropriate points during the construction process to assess the quality of the work on all new properties and correct any issues identified.

We recommend that HUD require the City to provide monitoring reports and supporting documentation to show that it conducted periodic monitoring of NORA’ s performance and compliance with program rules and regulations and ensured that NORA promptly remedies any findings or concerns. This includes, but is not limited to, ensuring that NORA (1) provides adequate oversight of the contractors providing service under the program and (2) maintains documentation to support eligibility for program participants.

We recommend that HUD require the City to develop a plan for how the City will continue to fulfill the required monitoring and oversight responsibilities of the National Disaster Resilience programs and projects if it runs out of planning and administration funds before it completes these programs and projects.

We recommend that HUD require the City to review misallocated planning and administration funds and reallocate any mistakenly allocated funds to the correct National Disaster Resilience project or grant activity. This measure could make available additional funds for program oversight.

We recommend that HUD require the City to analyze the method used to charge planning and administration costs to ensure that all costs are applied to the correct costs category and are valid charges to the National Disaster Resilience grant.