Support that $1,253,596 in funds not yet expended was reasonable, supported, and allowable or reallocate the funds, thus ensuring that they will be put to their intended use.

Develop and implement adequate underwriting policies and procedures for their affordable housing activities and for the downpayment assistance program to ensure that HOME activities are consistent and meet Federal requirements. Further, they should include the downpayment underwriting policies and procedures in the written agreement with the City’s subrecipient.

Cancel activities in IDIS that have had no construction in more than 12 months.

Develop and implement adequate environmental policies and procedures to ensure that HOME activities are properly classified, the environmental review is documented and supported, and that HUD and Federal environmental requirements have been followed before committing HOME funds to an activity

Determine the total supported development costs for the completed HOME activities and calculate and obtain any program income due to the HOME program.

Support that City officials properly administered the HOME program and earned $338,665 in HOME administrative fees or repay from non-Federal funds any amount that cannot be supported.

Develop and implement tools to improve record-keeping practices to support the eligibility, necessity, and reasonableness of the HOME activities.

Request that HUD headquarters recalculate the City’s commitment shortfall for program year 2013 based on the lack of the amendment with the City’s subrecipient and for the projects that were not properly committed.

Provide technical assistance to the City to ensure that City officials responsible for administering the HOME program receive necessary HOME program training.

Obtain documentation from the remaining 55 potential cases (34 cases in the public housing program 21 cases in the Housing Choice Voucher program) reported by the public housing agencies that failed to provide supporting documentation to determine compliance with HUD’s requirements.

Obtain documentation from the remaining 195 potential cases involving children with EIBLLs reported by the public housing agencies (35 reported cases in the public housing program 160 reported cases in the Housing Choice Voucher program) that we did not review during the audit to determine whether the public housing agencies and owners, as applicable, complied with HUD’s requirements or whether action is required under the requirements.

Require the public housing agencies to support that the lead hazards were appropriately abated for the 11 cases (3 public housing program 8 Housing Choice Voucher program) that lacked adequate clearance reports or lacked documentation showing that the identified lead hazards had been corrected.

Ensure that the owners for the two Housing Choice Voucher program units, in which the families were relocated and abatement was not performed, do not provide housing for families with children under 6 years of age until the lead hazards are abated.

Obtain documentation of a lead-based paint inspection or exemption for the 222 public housing developments that failed to provide evidence of compliance with HUD’s lead-based paint inspection requirements.

Work with the Office of Lead Hazard Control and Healthy Homes to update HUD’s regulations to expand the inspection and abatement requirements of 24 CFR Part 35 to housing completed after 1977 in cases in which a child with an elevated blood lead level is reported.

Implement adequate procedures and controls at HUD’s field offices to ensure that requirements of 24 CFR Part 35 are followed by public housing agencies, including monitoring the public housing agencies to ensure that required actions are appropriately completed and performed in a timely manner.

Update the occupant emergency plan so that it lists the ways occupants are to report fires or other emergencies

Periodically provide training on the occupant emergency plan once it is updated

Create a process to help ensure that fire drills for the Weaver Building occur every year

Reimburse its program $13,605 from non-Federal funds ($8,735 in overpayments of housing assistance and utility allowances $4,870 in administrative fees) due to inappropriate calculations.