Provide training for its staff to ensure sufficient knowledge of CDBG requirements regarding when to charge delivery costs, including when to charge payroll to rehabilitation administration, versus general administrative costs.

Reclassify $517 in miscellaneous expenses that was incorrectly prorated or repay the program from non-Federal funds.

Support that expenses were related to rehabilitation activities for $13,263 in unsupported payroll or repay the program from non-Federal funds.

Support that expenses were related to rehabilitation activities for $66,910 in payroll expenses charged to the rehabilitation delivery expenses activity for its former environmental review specialist or repay the program from non-Federal funds.

Reclassify $69,794 in employee payroll and benefits for City employees that did not work on rehabilitation-related activities or repay the program from non-Federal funds.

Support that $323,563 spent on rehabilitation administration charged in program year 2015 costs was reasonable and benefited the City’s rehabilitation program or repay the program from non-Federal funds any amount determined to be unreasonable or ineligible.

Update its policies and procedures to ensure that the City issues payments to vendors and obtains reimbursement from HUD only after the City’s Community and Economic Development Department has verified that work is complete.

Support that $45,304 drawn in advance met eligibility and procurement requirements and costs were reasonable or repay the unsupported amount from non-Federal funds.

Repay from non-Federal funds $257,737 from voucher 6035061 for the duplicate draw.

Update and implement policies and procedures to ensure that all procurements are conducted in a manner that promotes full and open competition and avoids any arbitrary action in the procurement process, including ensuring that contractors are given sufficient time to respond to solicitations.