Support the eligibility of the $55,000 subrecipient drawdown or repay the program from non-Federal funds.

Develop and implement written code enforcement policies and procedures to meet CDBG requirements or amend the funding for another CDBG-eligible project. Improving code enforcement controls will result in $428,373 in funds to be put to better use.

Execute contractual agreements with each CDBG recipient department to ensure compliance with all Federal guidelines.

Develop and implement written policies and procedures for specific departments, update and implement CDBG-specific written policies and procedures, and provide formal training and technical assistance to the Development and Resource Management Department employees to ensure that they understand and follow CDBG requirements.

Develop and implement a monitoring program within the City’s Development and Resource Management Department to ensure that it periodically monitors and provides guidance to its subrecipient(s) and City departments on how to administer CDBG funds.

Reimburse the program $70,992 ($63,312 $7,680) from non-Federal funds for housing assistance payments made and administrative fees received for the units that materially failed to meet HUD’s housing quality standards.

Certify, along with the owners of the 103 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Develop and implement adequate policies and procedures for conducting quality control inspections in accordance with HUD’s requirements.

Develop and implement adequate procedures and controls to ensure that its quality control inspection program functions properly to include adequately monitoring the inspection contractor to prevent $20,566,345 in program funds from being spent over the next year on units that do not materially comply with requirements.

Reimburse the program $2,492 ($2,286 in housing assistance payments and $206 in administrative fees received) from non-Federal funds for rental subsidies not abated on four units.

Complete a review of rental subsidy abatements for all current units for which a retroactive abatement was not conducted. The Authority should reimburse the program from non-Federal funds for any overpaid rental subsidy.

Develop and implement written procedures and a process for retroactively abating housing assistance payments.

Complete a rent reasonableness determination for all current units for which a determination was required but not completed. The Authority should reimburse the program from non-Federal funds for any overpaid rental subsidy.

Develop and implement written procedures to ensure that a rent reasonableness determination is performed before rent increases are approved.

Complete a review that owners of current assisted units are not debarred, suspended, or subject to a limited denial of participation.

Develop and implement written procedures for conducting a complete owner eligibility determination.

Provide adequate training to its staff to ensure compliance with HUD’s requirements for program units.

Develop and implement HUD-approved policies and procedures to ensure that the process for conducting an internal audit complies with HUD regulations and the policies and procedures are submitted and certified to HUD.

Immediately conduct an internal audit of the CDBG-DR grant funds.

Update, finalize, and implement its procurement policies to comply with 2 CFR 200.317-326.