Implement adequate policies and procedures to ensure that payments to subrecipients are issued in accordance with HUD’s requirements.

Provide adequate training to staff associated with the administration of the ESG program to ensure compliance with HUD’s requirements, including timely drawdowns.

Implement adequate policies and procedures for conducting complete and consistent monitoring of subrecipients’ matching requirements, including confirming eligibility and existence of matching funds to ensure compliance with HUD’s requirements.

Support that grant administration services paid were cost reasonable or reimburse its Program $387,443 from non-Federal funds.

Reimburse its Program $102,069 from non-Federal funds for the duplicate payments made to its subcontractor for lead-based paint and other health hazard control activities.

Coordinate with HUD’s Office of Lead Hazard Control and Healthy Homes to determine whether $88,258 in Program funds ($77,597 $10,661) may be drawn down and used to reimburse its subcontractor if the lead-based paint and other health hazard control activities are determined to be eligible.

Determine whether the subcontractor is owed payment for 21 units, which the Department’s records showed were assisted under the Program but were not identified as assisted units according to documentation maintained by the Department to support its drawdowns from HUD’s LOCCS. If the Department Read More

Determine whether appropriate reimbursements were made to the subcontractor for the remaining 166 assisted units that were not a part of our review. If the Department determines that appropriate reimbursements were not made, it should provide support that the lead-based paint and other health Read More

Support that the four households residing in assisted units were income eligible or reimburse its Program $59,883 from non-Federal funds for the lead-based paint and other health hazard control activities completed in the assisted units.

Support that landlords gave preference in renting six vacant units to families with children under 6 years of age or reimburse its Program $41,240 from non-Federal funds for the lead-based paint and other health hazard control activities completed at these assisted units.

Support that lead-based paint hazard control activities were necessary at 13 assisted units or reimburse its Program $23,857 from non-Federal funds for the unsupported lead-based paint hazard control activities completed at these assisted units.

Reimburse its Program $2,900 from non-Federal funds for the two units in which the seven windows were not installed.

Transfer $17,507 in non-Federal funds to its Childhood Lead Poisoning Prevention Program and use the funds in accordance with the program grant requirements since these funds were not recaptured after the four assisted units were sold within 3 years.

Execute agreements with owners of the assisted units detailing the Department’s recapture policy and determine whether liens should be filed with the appropriate government office to ensure that Program funds used to assist the units are properly protected and able to be recaptured if assisted Read More

Implement adequate procedures and controls to ensure that (1) contracts are properly procured in accordance with HUD’s requirements, (2) annual income is properly calculated for households residing in assisted units, (3) the appropriate reimbursement payments are made to the subcontractor for lead Read More

Develop and implement adequate procedures and controls to ensure that assisted rental units are prioritized for families with children under 6 years of age.

Implement its procurement controls to ensure that it is able to locate and maintain the complete procurement documents for at least 3 years after the closeout of NSP1 and NSP3 in compliance with its own procedures and HUD regulations.

Provide the required documents to support $161,131 in NSP1 and $109,525 in NSP3 funds for expenses for acquisition, rehabilitation, and administration. If the City cannot provide the required documents, it should repay the U.S. Treasury from non-Federal funds.

Repay the U.S. Treasury from non-Federal funds for the $1,550 overpaid to acquire a foreclosed NSP3 property.

Obtain technical assistance from HUD to ensure that it is able to manage the programs and comply with program regulations before processing future expenses related to NSP1 and NSP3 projects and activities.