Pursue the collection of the $5,690,000 in surplus proceeds that HUD was entitled to receive from 2017 loan terminations.

Implement a policy to require servicers to send surplus proceeds notifications to the HUD Secretary-held assets servicing contractor and establish procedures to improve HUD’s surplus proceeds collection efforts.

Redesign the partial claim program to eliminate its weaknesses and ensure that partial claims benefit from a stronger lien position to put $6,770,000 to better use.

Implement adequate procedures and controls to ensure that borrowers’ delinquent and default information is accurately reported.

Provide verification to HUD that it has taken the appropriate action to correct its delinquent or default status code reporting for the borrowers affected as a result of its system change.

Ensure that staff responsible for making entries into its servicing system is properly trained and understands HUD’s reporting requirements.

Work with the owners, lenders, operators, and management agents (as applicable) to develop and implement an action plan for potentially troubled and troubled nursing homes. Each plan should include an analysis of the root causes of that nursing home’s challenges and define specific and measureable steps that address the root causes. Each step should have a defined completion date.

Implement the action plan for the four defaulted nursing homes to protect HUD’s investment of $41,435,357. This amount represents the collective funds put to better use for these nursing homes. Appendix E lists the funds to be put to better use by nursing home

Develop and implement policies and procedures to address delinquent or defaulted mortgages that would not benefit from refinancing.

Refer regulatory agreement violations to the Departmental Enforcement Center within 30 days of HUD having identified it and work with the Departmental Enforcement Center to develop a plan for resolving the violation. Any revisions to the plan must be accepted by the Departmental Enforcement Center.

Review and revise the policies and procedures for making partial payments of claims to check that each decision to make a partial payment of claim ensures that the payment restores the subject nursing home to financial viability to avoid a repeat of the situation that led to the loss on Hebrew Home.

Require Jamaica Hospital Nursing Home to provide support for $8,974,000 paid to its related company. Any amount that the owner cannot support as reasonable in price and necessary to the nursing home should be repaid to the nursing home.

Require Jamaica Hospital Nursing Home to provide support for $44,483,000 in accounts payable. Any amount that the owner cannot support as reasonable in price and necessary to the nursing home should be removed from the accounts payable

Require the owners of Bishop Wicke Health and Rehabilitation Center, Plaza Village Senior Living, Golden Hill Health Care Center, Immanuel Campus of Care, and their related companies to reimburse the nursing homes for the ineligible expenses of $7,027,289.

Require Shawnee Christian Nursing Center to return 27 beds to operation or pay down the mortgage by $815,973

Define the troubled and potentially troubled classifications for nursing homes and develop specific measures to identify when and how nursing homes are classified.

Develop and implement policies and procedures to revisit the classifications at least annually.

Develop and implement computerized controls to flag blank data fields and illogical financial data.

Develop and implement procedures to require owners, operators, and lenders to submit accurate and complete financial data.

Develop and implement internal controls to routinely compare financial data on mortgage payments to Multifamily Delinquency and Default Reporting System data on mortgage payments and follow up on any conflicting data.