We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to support that subrecipient 3 met a national objective, environmental requirements, and client eligibility or repay $304,975 to its CDBG line of credit from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $565 in ineligible costs for its failure to provide subrecipient oversight, which should have identified that the subrecipient had incorrectly applied eligibility requirements for homeless clients served. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to reimburse its CDBG line of credit for $1,400 in ineligible costs for its failure to provide subrecipient oversight, which should have identified the ineligibility of clients whose income exceed the threshold as reported. Reimbursement must be from non-Federal funds.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development require the City of Albuquerque’s Department of Family and Community Services to develop and implement written CDBG policies and procedures, which detail the requirements, including but not limited to (1) meeting Federal procurement requirements, (2) executing written agreements for all subrecipients and contractors that meet minimum requirements, (3) documenting all conflicts of interest, (4) complying with HUD environmental review requirements, (5) maintaining documentation to support that its CDBG-funded projects met one or more national objectives, (6) properly and accurately monitoring subrecipients for compliance with all requirements, and (7) consistently and accurately reporting activities in IDIS.

We recommend that the Director of HUD’s Albuquerque Office of Community Planning and Development continue to classify the City of Albuquerque as a high risk grantee until such time as HUD has determined the City has implemented an effective program in compliance with all requirements.

Repay HUD from non-Federal funds for the $987,500 disbursed to 21 home buyers who did not meet all of the program eligibility requirements.

Implement adequate procedures and controls to ensure that it properly monitors the listing brokers to ensure compliance with its contract. The procedures and controls should include but not limited to performing quality control reviews and supervisory review of its brokers, and maintaining documentation of its quality control reviews and corrective actions.

Update its quality control plan to include the performance of physical inspections of the properties in its inventory.

Support the eligibility of $6,529,500 in code enforcement costs, including meeting code enforcement requirements, preparing time distribution reports, and supporting vehicle costs, or repay the program from non-Federal funds (appendix D).

Suspend funding to its code enforcement program until it can show that it has implemented controls, addressed its capacity issues, and understands and abides by HUD requirements.

Repay the program $4,565 from non-Federal funds for ineligible code enforcement program costs.

Repay the program $139,071 from non-Federal funds for ineligible tire team code enforcement program costs.

Repay the program $19,919 from non-Federal funds for ineligible antigraffiti program salary costs.

Support the eligibility of the $1,107,000 in after school program costs, including meeting the limited clientele national objective, or repay the program from non-Federal funds.

Support the eligibility of the $218,028 in antigraffiti costs or repay the program from non-Federal funds.

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.