We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to support or reimburse its program $425,193 ($19,924 $384,755 in housing assistance payments $46 in utility allowances $20,468 in associated administrative fees) from non-Federal funds for the unsupported overpayment of housing assistance and utility allowances due to unsupported calculations, missing eligibility documentations, and discrepancies in the housing assistance payments register.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to provide documentation to justify the $189,322 in unsupported administrative and planning costs that was disbursed for employee salaries and fringe benefits. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to reimburse from non-Federal funds $78,530 for ineligible home-buyer rehabilitation and demolition costs charged to the HOME program.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to terminate the contract between the County and the Village of Freeport to rehabilitate and construct single-family public housing units to be sold to low-income residents. The remaining contract balance of $31,470 should be put to better use by reprogramming it for other eligible purposes.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to provide documentation to justify the $1,264 in unsupported project delivery costs. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to document their application review committee membership and provide evidence of the committee meetings and their evaluation and rating of subrecipients to fully support their funding recommendations.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to develop controls to ensure that the County’s recently established debarment verification procedures are implemented for all future procurement activity.

We recommend that the Director of HUD’s New York Office of Community Planning and Development instruct County officials to develop controls that will ensure that the County’s decentralized record-keeping system is centralized for ready access to HOME documents.

Require the Municipality to reimburse from non-federal funds $552,658 in unallowable and unallocated costs associated with the disbursement of salaries and fringe benefits of employees who did not perform duties directly related to carrying out activities charged with the program delivery costs.

Require the Municipality to provide support showing the allocability and eligibility of $1,077,577 spent on salaries and fringe benefits for employees who performed local government duties and multiple federally funded activities without properly allocating the costs directly related to carrying out each activity. Any amounts determined ineligible must be reimbursed to the Block Grant program from non-federal funds.

Implement control policies or procedures to at least annually coordinate with HUD’s Office of Public Housing to match data in the Single Family Data Warehouse to data in the Public Housing Information Center to prevent or mitigate instances of borrowers violating Program residency requirements by renting their properties to Section 8 voucher participants.

Develop and implement a financial management system in accordance with HUD requirements.

Reimburse its business development loan program $5,999,894 from non-Federal funds for the ineligible expenditures related to the Hotel Sterling project.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to reimburse its program $21,650 form non-Federal funds for the overpayment of escrow funds to the participants cited in this finding.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to provide supporting documentation or reimburse its program $17,008 from non-Federal funds for the unsupported payments cited in this finding.

Require the Municipality to develop and implement a financial management system in accordance with HUD requirements and ensure that $3,213,572 in HOME funds drawn from HUD between July 1, 2009, and December 31, 2011, can be traced to a level which ensures that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes or reimburse the HOME program from non-Federal funds.(Footnote 2) Total disbursements of $3,523,723 were adjusted to consider $173,978 questioned in recommendation 1B, $86,567 questioned in recommendation 1D, and $49,606 questioned in recommendation 2B.

Require the Municipality to submit supporting documentation showing the allocability and eligibility of $114,139 charged to the HOME program for project delivery costs or reimburse the program from non-Federal funds.

Determine the eligibility of the $537,773 disbursed for the Ciudad de Ensueño project and reevaluate the feasibility of the activity. (Footnote 9) Total disbursements of $538,973 were adjusted to consider $1,200 questioned in recommendation 1F. The Municipality must reimburse its HOME program from non-Federal funds if HUD determines the activity to have been terminated.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to reimburse $11,289 (the difference between the contract paid price of $33,638 and the lesser calculated cost of $ 22,349) from non-Federal funds to HUD for transmission to the U.S. Treasury for the cost savings cited in this finding.

Establish and implement procedures to reassess the safe harbor percentage and rates periodically to ensure that they are reasonable. HUD should retain the documentation justifying the calculation of those percentages and rates. In addition, HUD should assess the feasibility of requiring the agencies to periodically justify and retain documentation showing the reasonableness of using the maximum rates, or lower them as appropriate.