Develop and implement an indirect cost allocation plan, which ensures that indirect costs are charged to the correct program.

Provide technical assistance to the Community to ensure that its staff receives training on documentation of matching contributions and the use of program funds.

Reclassify the $28,576 as program income to the specific permanent supportive housing program that generated it and ensure these funds are used for that specific program.

Develop and implement written policies and procedures to ensure that all program income is recorded and used in accordance with HUD requirements.

Support that $2,687 in payments to the board member for legal services was allowed through a HUD-approved waiver that occurred before the legal services or repay HUD from non-Federal funds.

Suspend the travel cards for 35 employees who made 166 improper, illegal, or erroneous purchases, if warranted based on the nature of misuse, and coordinate with the related program offices, the Office of the Chief Human Capital Officer, and the Office of Employee Labor Relations to take appropriate disciplinary actions against these employees and their supervisors who did not follow up on the monitoring reports.

Ensure that ARC has properly updated the monitoring report criteria to include transaction categories that were previously missing from the monitoring reports.

Coordinate with the Office of Employee Labor Relations and the Office of the Chief Human Capital Officer to update HUD’s travel card policy with the table of penalties and disciplinary actions for travel card misuse and provide the updated policy and tiered instructions for disciplinary actions to administrative officers and approving officials.

Require program offices to report all disciplinary actions taken against employees who made improper purchases.

Generate a periodic report of travel cards for employees who do not travel and cancel the travel cards if not needed.

Inform all travel cardholders and approving officials about specific travel program requirements and repercussions for disregarding these requirements.

Verify with ARC on a regular basis that all travel cardholders have completed their training as required.

Require justification and approval for selecting a nonrefundable rate in the travel system comments section.

Generate a periodic monitoring report that would identify employees who did not use their government travel card when required and send this report to employees’ supervisors and the Assistant Secretary of related program offices for proper action.

Require justification and approval in the travel system comments section when requesting lodging expense reimbursement to the traveler’s bank account.

Update HUD’s travel card policy to require approving officials’ review of travel documents for appropriate methods of payment and work with the Office of Employee Labor Relations and the Office of the Chief Human Capital Officer to prescribe disciplinary actions for not using the government travel card when required.

Inform all HUD travel cardholders and approving officials about the mandatory use of the government travel card and disciplinary actions for not using it.

Follow up with the 19 employees identified as failing to use their government travel card and coordinate with the related program offices to ensure these employees receive training, counseling or other appropriate disciplinary action, if necessary, on the mandatory use of the government travel card.

Develop and implement adequate enforcement procedures that support its policy and ensure that housing quality standards deficiencies are corrected in a timely manner.

Work with the City of Denver Office of Economic Development to recapture $37,000 in HOME funds not properly used for the affordable housing projects.