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. Footnote 2: Total drawdowns of more than $1.5 million were adjusted to consider $106 questioned in recommendation 1D and $469,974 in recommendation 2A.

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.

Define which expenses should be considered program delivery costs and strengthen controls over program costs to ensure that costs are properly charged.

Provide additional guidance to their grantees and strengthen controls over procurement to ensure that grantees follow applicable State and Federal procurement requirements, including obtaining independent cost estimates and ensuring full and open competition.

Support $401,870 for contracts that were awarded without an independent cost estimate or repay from non-Federal funds any amount that cannot be supported.

Provide additional guidance to their grantees and strengthen controls to ensure that tier two environmental reviews are performed and properly conducted and signed by the responsible entity before committing program funds.

Support that 14 projects, with $494,517 in construction costs, met the environmental review requirements and repay from non-Federal funds any amounts attributed to projects that cannot be certified.

Repay from non-Federal funds the $665,920 in ineligible costs charged to the program

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to obtain technical assistance from HUD to evaluate the staff’s training needs and to ensure that responsible staff receives the appropriate training for effective program administration.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to evaluate its staffing level and determine if it should hire additional staff to carry out program activities.