Develop and implement written policies and procedures for the management of the project, including but not limited to financial policies for cash disbursements, cash receipts, and documentation requirements.

Create and implement policies and procedures or change program regulations to prevent multifamily housing properties from charging more for Section 8 units than for comparable non-Section 8 units. For the 25 properties reviewed, this measure would prevent as much as $3,144,894 of Section 8 funds from subsidizing non-Section 8 units in the next year.

Deobligate $542,289 in fiscal year 2015 capital funds in HUD’s system until binding agreements are executed for eligible and reasonable purposes, or coordinate with HUD for terminating its funding.

Reclassify $398,022 in fiscal year 2016 capital funds as authorized in HUD’s system to an eligible and reasonable activity, or coordinate with HUD for terminating its funding.

Coordinate with HUD for terminating the allocation of the remaining $217,553 funds given the Authority’s current intentions to not build or purchase public housing units.

Develop and implement adequate procedures and controls to ensure that the reporting of allocated capital funds in HUD’s system is accurate.

Provide adequate training to staff responsible for making entries into HUD’s system to ensure accurate reporting on allocated funds. The training should include but not be limited to ensuring that its staff understands all of HUD’s reporting requirements for obligations and authorizations.

Confirm the replacement of program units was appropriate for the number of units demolished at Johnson Ferry East, and submit a development proposal to construct new public housing units, transfer public housing assistance to another public housing agency, or terminate its annual contributions contract and return all unobligated and unexpended capital funds to HUD.

Certify, along with the owners of the 11 units cited in this finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $9,715 from non-Federal funds ($9,660 for housing assistance payments and $55 in associated administrative fees) for the unit that materially failed to meet HUD’s housing quality standards.

Provide training to its inspectors on conducting housing quality standards inspections.

Develop improved procedures and provide training to appropriate staff regarding the departmental clearance process requirements, including • Determining which guidance is considered to be a directive, including public communications, and • Ensuring that HUD program participants have clear, instructive, and helpful information to comply with the applicable requirements and procedures for HUD programs.

Pursue departmental clearance for the July 25, 2013, guidance that did not go through required departmental clearance. For any items that cannot be appropriately cleared, HUD should take appropriate action to recall the document or policy.

Develop guidance that helps the public understand its options for assistance between CDBG-DR and SBA and how to comply with Federal requirements.

Develop and implement a written methodology for employees’ time allocations for its HUD grant programs in accordance with program requirements.

Provide training on compensation for personal services grant program requirements to employees working on HUD grants.

Support $142,181 spent on payroll allocated to HUD grants or repay the program from non-Federal funds.

Provide supporting documentation or reimburse its Program $81,654 from non-Federal funds for unsupported on-the-job training costs incurred under project FL0220L4D001407.

Provide supporting documentation or reimburse its Program $1,023 from non-Federal funds for unsupported personal cell phone costs incurred under project FL0220L4D001407.

Provide guidance to subrecipients to ensure that (1) on-the-job training hours are supported by source documents, such as signed attendance or time sheets, and (2) personal goods and services are supported by documents that show the allocation between business and personal use.