Develop and implement guidance to communicate appropriate ways for grantees to calculate household income.

Provide guidance to field office staff to clarify the statutory requirements in 42 U.S.C. 5305(a)(24) regarding a principal reduction and a downpayment for direct home-ownership assistance activities.

Direct responsible field offices to require the grantees identified by the audit to either provide documentation to support $227,260 in unsupported payments or reimburse their programs from non-Federal funds for costs they cannot support.

Consult with the Office of the Attorney General to establish whether HOPWA and other homeless assistance programs are a Federal public benefit that meets the definition of “providing assistance for the protection of life or safety” and are, therefore, exempt from PRWORA noncitizen eligibility restrictions.

Clarify whether assistance provided under its community development programs, such as HOPWA, are considered “Federal public benefits” and are, therefore, subject to PRWORA’s noncitizen eligibility restrictions.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development continue to classify the City of Albuquerque as a high risk grantee until such time as HUD has determined the City has implemented an effective program in compliance with all requirements.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to develop and implement written CDBG policies and procedures, which detail the requirements, including but not limited to (1) meeting Federal procurement requirements, (2) executing written agreements for all subrecipients and contractors that meet minimum requirements, (3) documenting all conflicts of interest, (4) complying with HUD environmental review requirements, (5) maintaining documentation to sup

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $1,400 in ineligible costs for its failure to provide subrecipient oversight, which should have identified the ineligibility of clients whose income exceed the threshold as reported. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $565 in ineligible costs for its failure to provide subrecipient oversight, which should have identified that the subrecipient had incorrectly applied eligibility requirements for homeless clients served. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to support that subrecipient 3 met a national objective, environmental requirements, and client eligibility or repay $304,975 to its CDBG line of credit from non-Federal funds.