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Develop and document internal procedures to ensure that they will address the Program Office’s responsibilities within the departmental grant accrual validation policy.
Design and implement a training program and other development tools to help grantees. The goal of such training would be to provide ideas and other development tools to help the CoCs better provide assistance with implementation of their grants and monitoring of their grantees, including assistance with developing outreach strategies, partnering with community providers, financial budgeting, and best practices. The training should focus on the needs of first-year grantees and CPD should take steps to encourage participation.
Implement written procedures to ensure consistency among field offices in reviewing spending issues, potentially preventing up to an estimated $47 million in annual CoC recaptures.
Use the fraud risk inventory to enhance program-specific fraud risk assessments for the HOME program.
Consider streamlining program requirements to help grantees promptly use program funds to assist those impacted by the pandemic or for activities that prepare for, prevent, or respond to the coronavirus.
Consider allowing grantees additional time to spend the program funding on eligible activities to meet the 80 percent spending deadline.
Provide training to State staff to ensure that it understands and follows (1) requirements to maintain adequate documentation to support that program disbursements are eligible and reasonable and (2) procurement requirements, including independent cost estimates, cost analyses, proposal scoring, and the timely checking of the SAM data for contractors’ eligibility.
Update its procurement policy to clearly define the process, which includes timing and the procurement types, for conducting an independent cost estimate and a price analysis.
Provide adequate documentation to support that the $2,588,362 in CDBG-DR funds for three unsupported project and program management services expenditures cited in this report was spent for supported, necessary, and reasonable costs. Any amount for which adequate support cannot be provided should be repaid from non-Federal funds.
Consider grant recipients’ feedback on challenges with (1) capacity, (2) multiple other sources of funding, and (3) subrecipient monitoring as part of CPD’s risk assessments.
