Implement adequate procedures and controls to ensure that it does not provide the corporation Block Grant funds for excessive labor costs.

Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that the cost of materials and services acquired for the program is reasonable.

Reimburse its Block Grant program from non-Federal funds for the $182 it provided to the corporation for a 4 percent surcharge that was inappropriately included on all materials.

Support or reimburse its Block Grant program from non-Federal funds for the $6,140 it provided to the corporation for indirect costs for which the corporation lacked sufficient documentation to support whether the indirect costs included lobbying-related expenses.

Support or reimburse its Block Grant program from non-Federal funds for the $1,541 it provided to the corporation for jobs for which the corporation lacked sufficient income documentation to support that the households were eligible for assistance.

Implement adequate procedures and controls to ensure that sufficient income documentation is maintained to ensure that households are eligible for assistance under the program and income is verified in accordance with HUD’s requirements and the subrecipient agreement.

Implement adequate procedures and controls to ensure that it properly documents compliance with HUD’s environmental review procedures before the start of each job.

Implement adequate procedures and controls to ensure that third emergency repairs are documented in writing and reported to the County before completion of assistance in accordance with the subrecipient agreement.

Support or reimburse its Block Grant program from non-Federal funds for the $4,953 it provided to the corporation for one job for which the corporation lacked sufficient documentation to support that a member of the household was physically disabled.

Implement adequate procedures and controls to ensure that sufficient documentation is maintained to support that accessibility modifications are provided only to households with at least one member who is physically disabled.

Reimburse its Block Grant program from non-Federal funds for the $4,127 it inappropriately provided to the corporation due to not ensuring that the corporation reduced all of its program income from its invoices for housing repair services.

Support or reimburse its Block Grant program from non-Federal funds for the $107 it provided to the corporation for the January 2016 invoice that the corporation generally could not explain.

Implement adequate procedures and controls to ensure that the corporation reduces program income from its invoices for housing repair services.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $594,012 disbursed due to the use of multipliers was for eligible, reasonable, necessary, and supported costs or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $2,689 disbursed due to a higher than required overtime rate was supported by documentation from the trade unions or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to reimburse its program $1,198 from non-Federal funds for overpaid wages due to billing and payroll errors.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to pay $544 in unpaid wages to the subcontractors of the affected employees and submit evidence that these employees have been paid.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide training to its staff to help ensure compliance with applicable cost principle, procurement, and Davis-Bacon requirements.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that it has strengthened its invoice review process to ensure that costs are eligible and supported before disbursing Disaster Recovery funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that payments made under the Rockaway Boardwalk construction management services contract complied with Davis-Bacon and Related Acts requirements and that restitution is made to affected workers for any underpayments identified.