We recommend that the General Deputy Assistant Secretary for Community Planning and Development develop and implement a quality review process at the headquarters level to ensure consistent compliance with its policy for risk analysis, to include but not be limited to reviewing supporting documentation for conclusions drawn.

Obtain training or technical assistance on CDBG program requirements.

Implement additional procedures and controls to ensure that documentation is obtained to support that the limited clientele national objective was met.

Implement additional policies and procedures to ensure that salaries and wages and cost allocations are charged in compliance with HUD requirements.

Support the reasonableness of the $95,736 in cost allocations charged as CDBG administrative (activity 522) costs or repay the costs from non-Federal funds.

Support the $31,186 After School program (activity 501) costs, including the reasonableness of the contract costs and meeting the limited clientele national objective, or repay the program from non-Federal funds.

Support the reasonableness of the $110,000 Graffiti Removal program (activities 504 and 520) cost allocations or repay the program from non-Federal funds.

Implement revised code enforcement program policies and procedures to meet CDBG requirements. This will help ensure that the remaining $328,918 budgeted for code enforcement activity 531 is put to better use.

Support the $576,997 in code enforcement costs (activities 499, 512, and 531), including meeting code enforcement and cost allocation requirements, or repay the program from non-Federal funds.

Repay the program $7,323 from non-Federal funds for ineligible code enforcement costs.