Take appropriate administrative action, up to and including debarment, against the owner for the violations cited in this report including, amongst others, failure to perform the required inspections to ensure that the units the owner were billing for assistance were decent, safe, and sanitary.

Require the Englewood Apartments’ owner to repay HUD from non-project funds the projected $377,108 in housing assistance payments for tenants who were not eligible for assistance.

Require Englewood Apartments to support that $24,295 in unsupported housing assistance payments was eligible and accurate. Englewood Apartments’ owner should repay any subsidy overpayments to HUD from non-project sources. Further, the owner should reimburse tenants for overcharged rents or enter into a repayment agreement with tenants who were undercharged due to nondisclosure of income.

Require the Englewood Apartments’ owner to implement appropriate controls, including a formalized process, to use when conducting initial certifications and interim and annual recertifications to ensure that tenants are eligible, housing assistance payments are accurate, and tenant files contain all required documentation to comply with HUD’s and its own requirements. In addition, the updated controls should ensure a layer of management oversight to review all certifications before final approval until such time as onsite management is trained and has been proven to follow HUD’s and its own requirements.

Ensure that the owner, management agent, and staff complete training to ensure that they understand their duties, including HUD’s and local tenant eligibility and certification requirements.

Monitor Englewood Apartments to ensure that its staff properly maintains tenant files and completes required certifications in accordance with HUD’s and its own requirements.

Ensure that Englewood Apartments’ owner and its identity-of-interest management agent provide necessary oversight to its onsite staff.

Require Englewood Apartments’ owner to further develop a formalized process to use when running and reviewing EIV reports.

Require Englewood Apartments’ owner to ensure that the management agent and staff complete EIV training to ensure that staff members understand their duties and both HUD’s and Englewood Apartments’ own requirements.

Monitor Englewood Apartments to ensure that it properly runs and reviews the EIV reports.

Ensure that Englewood Apartments’ owner and its identity-of-interest management agent provide necessary oversight to its onsite staff.

Provide documentation to show that the proposal of the vendor that it selected and paid $860,132 was the most advantageous or reimburse its program from non-Federal funds for any amounts that it cannot support.

Develop and implement controls to monitor its agent to ensure that it procures products and services in accordance with applicable Federal procurement requirements.

Reimburse its program $156,675 from non-Federal funds for the ineligible payments it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to ensure that it obtains waivers from HUD before entering into agreements that create conflict-of-interest situations.

Provide training and technical assistance to the Authority to ensure that it understands the proper use of intergovernmental agreements in accordance with HUD requirements.

Support the Child Crisis of Arizona campus creation project phase one met a national objective and was necessary and reasonable or repay its program $300,000 from non-Federal funds.

Improve and implement stronger policies and procedures for reviewing potential activities for funding, which include ensuring that they are necessary and reasonable, that the service area for the low- and moderate-income area benefit national objective includes the entire area served by the activity, and that the City has addressed concerns from those reviewing the application.

Support that the Eagles Park activity met an eligible CDBG national objective or repay its program $1,150,000 from non-Federal funds.

Support that the Save the Family Community Conference Center activity met a national objective or repay its program $981,779 from non-Federal funds.