Support that $173,508 spent on homeowner rehabilitation project expenses was reasonable or repay the program from non-Federal funds.

Update policies and procedures to ensure that costs are reasonable, including preparing an independent cost estimate and a detailed scope of work for each project.

Develop and implement policies to safeguard HUD funds by ensuring that its projects meet national objectives, have a completed environmental review, and have executed agreements for all projects and verify that work is complete before approving payment, including its rental rehabilitation projects.

Support that the $401,614 spent on STANCO rental rehabilitation projects was reasonable and met one of HUD’s national objectives and that it completed an environmental review or repay the program from non-Federal funds.

Support that the $592,266 spent on the HACS rental rehabilitation projects was reasonable or repay the program from non-Federal funds.

We recommend that the Deputy Assistant Secretary for Operations establish a monitoring tracking system, organized on a CPD field office basis, to incorporate and track internal and external data and provide an immediate, multiyear quantification of grantees, grants, and dollar value for both monitored and not monitored grantees, allowing immediate assessment of monitoring findings, resolutions, and coverage individually and in total.

We recommend that the Deputy Assistant Secretary for Operations develop and implement policies to require CPD headquarters’ substantive involvement and responsibility in the risk assessment and monitoring function, including (1) oversight of risk assessment, including ensuring that all required grantees have a risk assessment performed; (2) review of annual work plans; (3) evaluation of monitoring performance and findings; (4) institution of functional supervisory controls; and (5) enforcement of field office compliance with risk analysis and monitoring requirements.

Provide technical assistance to the City to ensure that City officials responsible for administering the HOME program receive necessary HOME program training.

Request that HUD headquarters recalculate the City’s commitment shortfall for program year 2013 based on the lack of the amendment with the City’s subrecipient and for the projects that were not properly committed.

Develop and implement tools to improve record-keeping practices to support the eligibility, necessity, and reasonableness of the HOME activities.