Support the cost reasonableness of $2,809 in change orders for the ADA pool improvement project or repay the program from non-Federal funds.

Provide supporting documentation for $4,955 in unsupported costs or repay the program from non-Federal funds.

Provide support showing that the ADA pool improvement project allows equal and independent access for people with disabilities through a third party or correct the access issue.

Develop and implement procurement policies and procedures for monitoring subrecipients to ensure that the scope of work developed by its subrecipients is sufficiently detailed to allow contractors to submit informed bids, reducing the number of change orders after the contract, and that its Read More

Develop and implement policies and procedures that ensure labor wage interviews are completed and documented.

Provide training to its staff on CDBG program rules and requirements to ensure that its staff adequately implements policies and procedures.

Identify the national objective met for the park project or repay the program $2,000,000 from non-Federal funds.

Develop monitoring practices to ensure that all projects that use limited clientele criteria exclusively serve the specific population claimed.

Repay $48,323 to the program from non-Federal funds for non-program-related payroll costs.

Determine the allocable amount of CDBG payroll costs for the employees who worked on CDBG and non-CDBG activities and adjust the funding amount as necessary or repay the program $573,064 from non-Federal funds.

Repay $71,397 to the program from non-Federal funds for the use of CDBG funds for code enforcement costs related to general government expenses.

Revise its code enforcement program to meet CDBG requirements for the remaining $33,603 budgeted or amend the use of the funding to another CDBG-eligible activity.

Determine the CDBG proportional benefit of the $329 charged for indirect automotive costs and repay the program any unsupported charges using non-Federal funds.

Obtain training or technical assistance from HUD concerning CDBG code enforcement, allocation of payroll, and indirect administrative costs.

Support the $126,824 in total incentive payments. For any amount it cannot support, HUD should require the project development group, LP, to pay the equivalent, from any of its reserves other than reserve for replacement, toward the project mortgage principle.

Develop and implement controls over its incentives program, including record-keeping requirements; defined processes, such as a detailed checklist of available incentives, including monetary limits; and supervisory review requirements.

Require the Authority to support the $9,608 payment with the required 2 years of average annual net earnings. For any amount that cannot be supported, HUD should require the Oak Towers Housing Development Group, LP, to pay the equivalent, from any of its reserves other than reserve for Read More

Take appropriate administrative actions against Authority staff for noncompliance.

Procure appropriate HUD-approved investment accounts and move all Federal funds from the STAR Ohio investment accounts to HUD-approved accounts to ensure that $20,706,862 or the current balance of the STAR Ohio accounts is properly protected.

Implement adequate procedures and controls to ensure that the Authority complies with HUD’s requirements for its investments of Federal funds.