Reimburse its program $156,675 from non-Federal funds for the ineligible payments it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to ensure that it obtains waivers from HUD before entering into agreements that create conflict-of-interest situations.

Provide training and technical assistance to the Authority to ensure that it understands the proper use of intergovernmental agreements in accordance with HUD requirements.

Support the Child Crisis of Arizona campus creation project phase one met a national objective and was necessary and reasonable or repay its program $300,000 from non-Federal funds.

Improve and implement stronger policies and procedures for reviewing potential activities for funding, which include ensuring that they are necessary and reasonable, that the service area for the low- and moderate-income area benefit national objective includes the entire area served by the activity, and that the City has addressed concerns from those reviewing the application.

Support that the Eagles Park activity met an eligible CDBG national objective or repay its program $1,150,000 from non-Federal funds.

Support that the Save the Family Community Conference Center activity met a national objective or repay its program $981,779 from non-Federal funds.

Support that the Kleinman Park activity met a national objective or repay its program $249,300 from non-Federal funds and correct the installation of the playground fossils or repay the program from non-Federal funds.

Support that the West Mesa CDC special economic development activities for fiscal years 2016 and 2017 met a national objective and that expenses were adequately supported and for eligible activities or repay its program $175,975 from non-Federal funds.

Ensure that the $65,000 microenterprise activity awarded to West Mesa CDC for fiscal year 2019 meets CDBG requirements or amend the use of funding to another CDBG-eligible activity.

Support that the Ability360 Mesa Home Accessibility activity for fiscal years 2015, 2016, and 2017 followed HUD requirements and its subrecipient agreement or repay its program $192,563 from non-Federal funds. This includes supporting that all activities met the national objective requirements and were for rental properties, contracts were properly procured, the 10 percent match subrecipient agreement requirement was met ($4,293) and properly accounted for, and contract expenses were adequately supported ($228).

Ensure that the $6,809 allocated for the Mesa Home Accessibility activity for fiscal year 2017 meets HUD requirements or amend the use of funding to another CDBG-eligible activity.

Implement and reinforce its policies and procedures that require the City and its subrecipients to maintain adequate documentation to support the City’s CDBG program activities and maintain adequate documentation of subrecipient monitoring reviews. This includes tracking the status of monitoring reviews, communicating findings to subrecipients, and adequately resolving findings in a timely manner.

Support that the findings for the fiscal years 2011 and 2014 NEDCO activity were adequately resolved or repay its program $105,688 from non-Federal funds.

Ensure that the remaining $153,191 budgeted for the 2010 NEDCO activity meets HUD requirements or amend the use of funds to another CDBG-eligible activity.

Develop and implement procedures to ensure that City employees responsible for desk and onsite monitoring reviews and its subrecipients are aware of HUD and subrecipient requirements for each type of activity funded.

Improve and implement its desk and onsite monitoring policies and procedures to strengthen its capacity to perform effective desk and onsite monitoring reviews of subrecipients and for using a risk assessment to schedule monitoring visits.

Develop and implement policies and procedures for reviewing expenses charged to CDBG from other City departments.

Develop and implement a recurring training plan for City CDBG staff to ensure knowledge of HUD regulations and requirements.

Document and submit all activities to HUD for written approval to ensure that they are eligible activities that meet the CDBG national objective requirements before funding until recommendations 1B, 1J, and 1M to 1P are adequately implemented. This should include documenting all correspondence with HUD, including review and approval.