Provide documentation to show that $793,101 paid to the City for legal services was cost beneficial. Based on the documentation, it should reimburse its Housing Choice Voucher Program from non-Federal funds for any amount that exceeded the cost savings.

Follow the terms of the agreement, HUD requirements, and its own policies and procedures to ensure that any intergovernmental agreements for goods and services are in compliance.

Review the 17 travel cardholders with purchases that occurred without a travel authorization and the 6 travel cardholders with purchases that were not supported to determine whether the purchases were allowable, proper, and paid in full by the cardholder, taking appropriate administrative actions as necessary. These unsupported purchases totaled $6,407. However, a total of $5,780 remains after deducting the duplicate amount of $627 addressed in Recommendation 1C.

Perform an analysis of the 3,045 travel card purchases with indications that they were unauthorized or ineligible to identify potential violations and to address any unauthorized purchases identified. OCFO should perform a review of identified transactions to determine whether they were allowable, proper, and paid in full by the cardholder, taking appropriate administrative actions as necessary.

Refer the 15 ineligible travel card transactions totaling $5,393 to the appropriate program office and obtain a response regarding what administrative actions were taken to resolve the violations. If no actions were taken, OCFO should request support to show why no corrective actions were taken.

Strengthen internal monitoring efforts regarding government travel card use to identify potentially improper, illegal, or erroneous transactions. Such efforts should include data mining to detect instances of delinquency, fraud, and misuse.

We also recommend that the Director of HUD’s Departmental Enforcement Center evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to show that the $583,920 paid to two vendors for purchase orders below the Authority’s micropurchase limit was for prices that were reasonable or reimburse its Operating Fund from non-Federal funds for any amount that it cannot support or is not considered reasonable.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to show that $842,931 paid under five contracts was for prices that were reasonable or reimburse its Operating Fund for any amount that it cannot support or is not considered reasonable.

Follow up on the 15 properties in our sample to ensure that the code enforcement violations have been corrected, that the necessary documentation has been gathered and retained in the code enforcement file for the property, and that the code enforcement process has been completed.

Provide documentation to support $671,838 in code enforcement costs or repay the program from non-Federal funds for any amount that it cannot support.

Develop and implement policies and procedures to ensure that its Block Grant-funded code enforcement activities comply with HUD requirements, including documentation requirements, thereby ensuring that funds totaling $301,866 can be put to better use.

Provide documentation to support $1 million in community policing salary costs or repay the program from non-Federal funds for any amount that it cannot support.

Develop and implement policies and procedures to ensure that Block Grant-funded community policing salaries and benefits comply with HUD requirements, including documentation requirements, thereby ensuring that funds totaling $295,935 are put to better use.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that the $252,000 paid to the Long Branch Housing Authority was for eligible, reasonable, necessary, and allocable costs or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support or that is not considered reasonable.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to update its policies and procedures to ensure that any additional payments made under interagency agreements are adequately supported before payment is made and that the services are provided in accordance with applicable requirements. These requirements include but are not limited to HUD, Federal, and Authority requirements related to procurement, allocation of costs, and review and approval of payments.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that the $161,600 paid for legal, fee accounting, and auditing services was for prices that were reasonable and that the costs were properly allocated among the Authority’s programs or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support or is not considered reasonable

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that $172,538 paid for goods and services was reasonable or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support or that is not considered reasonable.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that $36,508 disbursed1 was for authorized and approved costs or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support.

We recommend that the Director of HUD’s Newark Office of Public Housing provide technical assistance to the Authority to help ensure that 1) future interagency agreements, including the renewal of its agreement with Long Branch clearly outline the expectations and documentation required to show that work was performed, (2) its board provides adequate oversight of work performed under interagency agreements, and 3) it complies with HUD, Federal, and Authority procurement requirements when purchasing goods and services.