Complete and implement policies and procedures to ensure that APRs are submitted by the closeout deadline.

Develop and implement policies and procedures to ensure that relevant personnel are routinely and regularly trained on the grant closeout process.

Work with the Authority to determine whether the buildings represent an imminent threat to public safety from physical deterioration and whether activities to control the situation would be exempt under the Part 58 environmental review process or excluded under the Part 50 environmental review process. If it qualifies, require the Authority to immediately take actions necessary to control the imminent threat to public safety before the full environmental review is done.

Determine whether it would be beneficial for HUD to conduct a Part 50 environmental review of the development or if the Authority should conduct a Part 58 environmental review, and implement the decision to ensure that the environmental review is conducted as soon as possible as required under the action plan.

Continue to provide training and technical assistance to ensure that the Authority understands relevant requirements for the various asset repositioning options, including milestone and disposition requirements.

Provide certifications and supporting documentation to show that it has identified and addressed urgent health and safety issues at the development, such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors.

Develop and implement a plan to routinely identify and address recurring urgent health and safety issues such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors while the property remains vacant and throughout future asset repositioning efforts.

Develop and implement a plan to use available asset repositioning options for the remaining 284 public housing units at the Commodore Perry Homes development, including 274 dwelling units and 10 nondwelling units.

Develop and implement a plan for the original property related to the 46 units converted under the RAD transfer of assistance option to ensure that the property and proceeds from its disposition are used in accordance with requirements.

If the Authority does not follow through on its asset repositioning plans, misses deadlines, or it otherwise becomes clear that the plan is no longer feasible, work with the HUD’s Special Applications Center, Office of Recapitalization, and other offices as appropriate, to consider and use available remedies such as revoking approval and enforcing required conversion.

Develop and implement written policies and procedures and controls for the FHA refund process to address the deficiencies identified in the audit report. These should include (1) controls to ensure that the website for the public listing of all unpaid refunds is complete, (2) controls to ensure that refund applications are sent only to the homeowners who requested them, (3) controls to ensure that refund applications are sent to all homeowners on the loan after loan termination, and (4) a formal monitoring framework for tracking the status of refunds.

Develop and implement written policies and procedures (1) for locating homeowners who have unpaid refunds (for both existing and new refunds), (2) to establish a standard timeframe for mailing refund applications to homeowners after they are requested, and (3) to establish requirements for verifying the termination date based on supporting documents provided by homeowners.

Research, develop, and implement policies and procedures to reduce the number of refunds that have remained unclaimed for an extended period, including consideration of a statute of limitations.

Develop and implement written policies and procedures regarding the designation of legal representation for applicants.

Obtain the required approvals under the Paperwork Reduction Act for the insert document mailed with the refund application and the Tracer Found Case form.

Revise its methodology to identify slow spenders, including appropriate baselines and the definition of slow spenders.

Update its policies and procedures for tracking expenditures related to slow-spending grantees, including steps for assisting the grantees to expedite spending (including the grantee’s steps or actions to address slow spending), identifying the reasons for the delays with the grant, and documenting the outcome of its efforts.

Corrective Action Taken

CPD updated guidance addressing grantee slow spending through technical assistance, including actions grant managers can take when grantee expenditures do not appear to be “on pace” to meet the expenditure deadlines, and demonstrated it is providing technical assistance to grantees during monitoring. CPD also issued an additional Standard Monitoring Findings and Corrective Actions Guide for its staff to promote a consistent framework for crafting monitoring findings and the corrective actions needed to resolve identified deficiencies and prevent future occurrences. This new resource provides general guidance and examples for presenting Finding components in monitoring reports for fourteen topics including, “Failure to Meet Timeliness of Expenditures Requirements.

Establish a reasonable timeframe for grantees to resolve DRGR flags or at a minimum, if a flag cannot be resolved within the established timeframe, have the grantee provide a remediating comment explaining why the flag could not be resolved and a proposed timeline for resolution.

Resolve or remediate outstanding flags for grants B-12-MT-01-0001, B-13-MS-36-0002, B-16-MH-48-0001, and B-16-DL-12-0001 in DRGR.

Require updated projections for grants B-12-MT-01-0001, B-13-MS-36-0002, and B-16-DL-12-0001 and provide assistance to the grantees to ensure that the expenditure deadlines will be met.