Reimburse its program $37,508 ($33,085 in housing assistance payments and $4,423 in associated administrative fees) from non-Federal funds for failing to perform unit inspections in a timely manner.

Develop and implement procedures, including but not limited to software upgrades, and staff training to ensure that unit inspections are conducted in a timely manner.

Develop and implement adequate oversight to ensure that unit inspections are conducted in a timely manner.

Reimburse its program $6,084 ($5,553 in housing assistance payments and $531 in associated administrative fees) from non-Federal funds for the units that materially failed to meet HUD’s housing quality standards.

Certify, along with the owners of the 26 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Perform all required quality control housing quality standards inspections in compliance with its HUD-approved MTW plan, thus helping to ensure that its inspectors perform housing quality standards inspections in accordance with HUD’s requirements.

Reimburse its Section 8 Project-Based Voucher program $443,204 ($394,190 in housing assistance payments and $49,014 in associated administrative fees) from nonproject funds for the payments related to the 206 Authority-owned units’ inspections not conducted by a HUD-approved independent entity and for compliance with housing quality standards for the period January 1, 2016, through August 5, 2016.

Ensure that HUD-approved independent third parties complete the unit inspections and determine the rent reasonableness for units it owns or seek an appropriate exemption of program requirements from the HUD Secretary.

Ensure that in future RAD conversions, if any, unit inspections are conducted for compliance with HUD’s housing quality standards after rehabilitation and construction is completed and before tenants move in.

Provide adequate training to its staff to ensure compliance with Section 8 Project-Based Voucher program requirements for unit inspections and rent reasonableness determinations.

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

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.

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.

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.

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

Update and implement policies and procedures to ensure that all procurements are conducted in a manner that promotes full and open competition and avoids any arbitrary action in the procurement process, including ensuring that contractors are given sufficient time to respond to solicitations.

Repay from non-Federal funds $257,737 from voucher 6035061 for the duplicate draw.

Support that $45,304 drawn in advance met eligibility and procurement requirements and costs were reasonable or repay the unsupported amount from non-Federal funds.

Update its policies and procedures to ensure that the City issues payments to vendors and obtains reimbursement from HUD only after the City’s Community and Economic Development Department has verified that work is complete.

Support that $323,563 spent on rehabilitation administration charged in program year 2015 costs was reasonable and benefited the City’s rehabilitation program or repay the program from non-Federal funds any amount determined to be unreasonable or ineligible.