We recommend that the Deputy Assistant Secretary instruct the Virgin Islands Housing Finance Authority to revise its policies and procedures to include requirements to document its basis for activities’ meeting the national objective, including the rationale for the service area used and a list of acceptable documents to support that the area was primarily residential for the low- and moderate- income area benefit national objective.

We recommend that the Deputy Assistant Secretary instruct the Virgin Islands Housing Finance Authority to conduct training for Authority staff on the newly developed or revised policies and procedures

We recommend that the Deputy Assistant Secretary require HUD program staff to provide technical assistance to the Authority to address deficiencies noted throughout the audit report.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement monitoring policies and detailed procedures to guide the Authority’s CMU staff in assessing activity performance to meet the subrecipient monitoring requirements and establish written performance metrics to progressively achieve the performance outcome for those activities the Authority administers.

We recommend that the Deputy Assistant Secretary instruct the Authority to revise subrecipient agreements to include performance metrics and milestones tailored to the activity in sufficient detail to enable the Authority to collect information to effectively assess the activity’s performance.

We recommend that the Deputy Assistant Secretary instruct the Authority to revise the monthly status report template to allow the subrecipient to report its current progress against the established performance metrics.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop a tracking process to ensure that the Authority issues monitoring reports and receives responses to these reports within the timeframe required by its policy. This process should also include a referral to management when the timeframe requirements are not met.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop detailed procedures to ensure that the corrective action tracking process is consistently followed to ensure proper resolution.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement policies and detailed procedures to establish the CMU’s responsibilities related to verifying that the CDBG-DR activity meets the stated national objective.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement policies and detailed procedures to identify the risk analysis process for monitoring all CDBG-DR-funded activities during the course of the activity and require that the monitoring files document the basis for why an activity is or is not monitored.

We recommend that the Deputy Assistant Secretary instruct the Authority to train the CMU staff on the newly developed policies and procedures and obtain technical assistance from HUD as needed.

We recommend that the Director for HUD’s Office of Disaster Recovery establish a mechanism to train grantees and HUD staff on existing guidance regarding supporting documentation for expenditures, FFRs, and program income balances on a recurring basis. Additionally, provide guidance and establish recurring training for HUD staff to monitor grantees for program income and submission of the FFRs..

We recommend that the Director for HUD’s Office of Disaster Recovery develop and implement controls to ensure that grantees’ policies and procedures related to program income are adequate.

We recommend that the Director for HUD’s Office of Disaster Recovery provide training to grantees regarding the reporting, tracking, and expenditure of program income.

Provide technical assistance to the State and the staff to ensure that they understand the requirements for conducting a monitoring review in accordance with regulations.

Instruct the State to update and implement the CDBG-DR standard operating procedures, which clearly outline what activities, including the frequency, will be reviewed by its monitoring and internal audit function.

Instruct the State to conduct monitoring reviews of its CDBG-DR HIM activities and subrecipients that satisfy monitoring requirements.

Work with the State to develop and implement policies and procedures to ensure that monitoring is conducted remotely in the event that it cannot be conducted onsite.

Instruct the State to update and implement policies and procedures to ensure that the results of the CDBG-DR internal audits are shared by the State’s Commissioner with CDBG-DR program staff to allow for the resolution of any findings and required corrective actions.

Monitor the State’s CDBG-DR program to ensure that performance expectations are achieved.