Ensure that its newly created policies and procedures include a process for ensuring that (1) escrow balances are correctly calculated and disbursed, (2) escrow accounts and disbursements are fully supported, and (3) forfeited escrow account funds are returned to the Housing Choice Voucher Program as required.

Ensure that its staff is appropriately trained and familiar with HUD’s requirements and its program action plan regarding the administration of its program to ensure that (1) participants’ individual training and services plans are complete and contain appropriate goals to assist the family in achieving self-sufficiency, (2) participants are notified of their escrow account balances at least annually, and (3) contracts of participation are complete and accurate.

Implement procedures and controls to ensure that documentation required by HUD and the Authority’s own action plan is correctly completed, documented, and updated.

Reimburse one participant, $547 from its Family Self-Sufficiency program for the underpaid graduation payment.

Transfer $3,801 from its Housing Choice Voucher Program account to its Family Self-Sufficiency account for the underfunded escrows.

Reimburse its Housing Choice Voucher Program $12,460 from non-Federal funds for the ineligible disbursements.

Support or reimburse its Housing Choice Voucher Program $120,067 from non-Federal funds for unsupported graduation disbursements.

Transfer $78,786 ($22,601 $56,185) from its Family Self-Sufficiency account to its Housing Choice Voucher Program account for the overfunded and forfeited escrows.

Develop and implement controls to ensure that the independent entity approved in recommendation 1J performs rent reasonableness determinations for program units that it substantially controls.

Submit a request for approval of an independent entity to perform rent reasonableness determinations for program units that it substantially controls.