We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to set performance and financial milestones, including approval of Harris County’s projects and obligation and expenditure of funds, for all programs and activities funded under the Harris County subrecipient agreement through the remainder of the contract and deadlines for Harris County to achieve those milestones.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to continuously monitor Harris County’s pace and performance in its remaining Hurricane Harvey CDBG-DR program and take appropriate action to ensure that program goals are met.

Develop and provide training for applicable program staff, grantees, and PHAs on radon testing and mitigation requirements.

Develop and issue a departmentwide policy that notes that radon is a radioactive substance and outlines HUD's requirements to test for and mitigate excessive radon levels in accordance with 24 CFR 50.3(i)(1) and 58.5(i)(2)(i).

Corrective Action Taken

None Given.

Develop and implement additional procedures and controls to ensure that HUD procurement requirements are followed.

Support the reasonableness of the South Gate contract or repay NSP2 $856,692 from non-Federal funds.

Obtain training to ensure that it understands NSP2 regulations and requirements related to payroll allocation for its administrative and project delivery costs and program income calculation methodology to ensure it properly computes the amount it is allowed to charge for administrative costs.

Establish written payroll policies and procedures in accordance with program requirements for the tracking, recording, and maintenance of direct costs to ensure that time distribution records are in place to support the allocation of charges.

Develop and implement a HUD-approved cost allocation plan to properly account for indirect program costs.

Provide supporting documentation to show whether the outstanding liability of $324,478 is correctly classified as an NSP2 liability. If not, HUD should ensure that NHSLA corrects its NSP2 cost reimbursement summary for the 12 months ending June 30, 2018, to reclassify the expenses to a non-NSP2 program. Such funds would be considered funds to be put to better use.