We recommend that the Director of HUD’s Office of Davis-Bacon and Labor Standards seek guidance from the Department of Labor to correct the wage determinations where applicable for the five projects addressed in this report.

We recommend that the Director of HUD’s Office of Davis-Bacon and Labor Standards based on the outcome of recommendation 1A, determine the correct wages to be paid to workers and ensure that appropriate actions are taken to pay the workers.

We recommend that the Director of HUD’s Office of Davis-Bacon and Labor Standards update HUD Handbook 1344.1, REV-2, CHG-2, and Labor Relations Letter No. LR-96-03 to comply with the Department of Labor’s policies and guidance on the application of wage determinations for construction projects.

We recommend that the Director of HUD’s Office of Davis-Bacon and Labor Standards develop and implement controls to ensure that the appropriate Davis-Bacon wage rate determinations are implemented in the contracts of FHA-insured multifamily construction projects that require multiple wage determinations, including the requirement that contract specifications clearly identify the portions of the contract subject to each assigned wage determination, and that adequate documentation to support wage determinations is maintained.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $78,021 in two administrative obligations marked for deobligation as of September 30, 2017.

Develop improved procedures and provide training to appropriate staff regarding the departmental clearance process requirements, including • Determining which guidance is considered to be a directive, including public communications, and • Ensuring that HUD program participants have clear, instructive, and helpful information to comply with the applicable requirements and procedures for HUD programs.

Complete all steps necessary for an effective evaluation effort.

Work with grant program offices to overcome reporting challenges. Ensure that grant program offices report OMB-requested data. Learn from and leverage results of participating grant programs.

Work with PD&R on an evaluation approach and design for the Promise Zone initiative. Ensure that OFPM has the appropriate resources for its new Communications and Data Analysis Division.

Review the Clearance Calendar and ensure that appropriate form HUD-22 concurrence forms were obtained and documented for directives issued by other HUD offices.

Implement controls to ensure that future directives are reviewed and documented in the Clearance Calendar tracking system as required.

Update policies and procedures for the directives process, including responsibilities for process oversight and clear guidance defining when clearance is required.

Develop and provide training to appropriate staff and required reviewing offices regarding the departmental clearance process requirements.