Obtain the required depository agreements for two5 grantees to ensure that they invest program funds in investment securities for use in carrying out affordable housing activities in accordance with PIH Notices 2014-21, section 4, and 2015-08, section 7.

Strengthen monitoring controls to ensure that current and future grantees maintain the required depository agreements before allowing them to invest program funds in investment securities for use toward affordable housing activities.

Update HUD’s Indian Housing Block Grant Recipient Self-Monitoring Guidebook to replace the expired requirement for investing program funds with PIH Notice 2015-08 and ensure that the Guidebook is updated with the latest requirements to ensure that grantees remain compliant with program requirements.

Direct PIH and OCIO to develop a comprehensive project plan, documenting the milestones and dates for addressing the gaps in ONAP-LOS capabilities (functionality and reports) and the 25 recommendations made during HUD OCIO's project health assessment

Direct all stakeholders to identify all viable options to securely resolve the ONAP-LOS access issues, so authorized Section 184 lenders can access the system. The best solution should not impose unacceptable risk to business processes or sensitive data. Current program offices involved are OCIO, PIH, and FHA, while others may also be identified

Direct PIH and OCIO to ensure that the Section 184 program transitions away from dependency on CHUMS.

Support that the converted units met HUD’s housing quality standards or reimburse its program $1,206,046 from non-Federal funds ($1,053,618 in housing assistance payments $152,428 in administrative fees).

Seek retroactive approval or reimburse its program $10,124 for program funds paid to the contractor not approved by HUD for the housing quality standards inspections for units owned by entities substantially controlled by the Authority.

Implement adequate procedures and controls to ensure that the Authority complies with HUD’s conflict-of-interest requirements, including but not limited to ensuring that (1) its staff is appropriately trained and familiar with HUD’s requirements for units owned by entities it substantially controls and (2) future contracts to perform housing quality standards inspections for program units owned by entities substantially controlled by the Authority are with a HUD-approved independent third party.

Implement adequate procedures and controls, including but not limited to providing guidance to its program staff on how to apply the correct contract rents and developing an effective quality control process.

Provide sufficient documentation to support that it disbursed the $199,604 in program funds, which it determined were inappropriate housing or utility assistance payments, and that it made a reasonable effort to collect the debts. If the Agency cannot provide sufficient documentation to support the disbursements and that the debts were uncollectable, it should reimburse its program from non-Federal funds as appropriate. If the Agency provides sufficient documentation to support the disbursements but cannot provide sufficient documentation to support that the debts were uncollectable, it should make a reasonable effort to collect from the debtors or reimburse its program from non-Federal funds as appropriate.

Implement adequate procedures and controls to ensure that it maintains sufficient documentation to support housing and utility assistance payments and that it makes a reasonable effort to collect debts.

Implement adequate procedures and controls to ensure that it follows its bad debt writeoff policy when it writes off accounts receivable.

Provide sufficient documentation to support that the two deleted adjustments to accounts payable and four deleted adjustments to accounts receivable were duplicate or incorrect adjustments that should have been deleted. If the Agency cannot do this, it should make the appropriate accounting entries and take the appropriate actions.

Determine whether the tenant paid the landlord nearly $1,284 for housing assistance payments that the Agency did not make to the landlord. If the tenant paid the landlord, the Agency should make the appropriate accounting entries and reimburse the tenant from program funds. If the tenant did not pay the landlord, the Agency should reinstate the adjustments to accounts payable that were inappropriately deleted and pay the landlord from program funds.

Provide sufficient documentation to support that an adjustment to accounts payable and five adjustments to accounts receivable were appropriate. If the Agency cannot do this, it should make the appropriate accounting entries and take the appropriate actions.

Implement adequate procedures and controls to ensure that it deletes adjustments to accounts payable and receivable and makes adjustments to accounts payable and receivable in accordance with HUD’s regulations and its administrative plan.

Request that HUD’s Quality Assurance Division continue reviewing the Agency’s (1) writeoff of accounts receivable, (2) deleted adjustments to accounts payable and receivable, and (3) adjustments to accounts payable and receivable as part of its financial and program management and operations review.

Create agreements and strategies with other program offices that describe when cross-programmatic reviews and enforcement actions against PHAs are required.

Train PIH officials on the authority and processes for declaring PHAs in substantial default and for taking PHAs into HUD possession.