We recommend that HUD’s Associate Deputy Assistant Secretary for Single Family Housing assess BLM’s performance under the area 1D contract at least quarterly to determine whether it has improved its performance. If its performance does not improve, coordinate with the Office of the Chief Procurement Officer to determine whether BLM was in default of its contract and take appropriate action.

Reimburse HUD $52,932 from non-project funds for the overpayment of housing assistance and utility allowances due to incorrect calculations.

Reimburse the appropriate households $566 from non-project funds for the underpayment of housing assistance due to incorrect calculations.

Reimburse HUD $32,334 for the overpayment of housing assistance due to unreported, and underreported income, or income reported late. This reimbursement is either from non-project funds or collections from applicable households.

Support or reimburse HUD $6,444 from non-project funds for the unsupported payments of housing assistance cited in the finding.

Implement adequate quality control procedures to ensure that housing assistance payments are appropriately calculated and supported. These procedures and controls should ensure that $76,107 in program funds are appropriately used for future payments.

Document the implementation of the quality control plan and the completed reviews of the tenant certification process.

Revise its occupancy standards to include policies and procedures to prevent underuse of the project’s units.

Review and update the project’s internal transfer waiting list to include the applicants’ move-in dates, and the project’s external waiting list to include notations showing the reasons why applicants were not admitted into the project’s program and why applicants were bypassed.

Develop and implement adequate procedures and controls to ensure that the project complies with HUD’s requirements and its own policies regarding the management of its waiting list.

Recapture the $248,222 in excess program funds from the Authority and allocate in the pool for other tribes to use in meeting program objectives.

Require the Authority to provide source documentation to determine the accuracy of the tribal enrollment numbers reported in 2015 and 2016. Based on those supported numbers, HUD should recapture or offset the unsupported amounts from the awarded $1,746,658 in program funds that resulted from under or overstated tribal enrollment numbers.

Require the Authority to establish and implement controls and formal written policies and procedures to ensure that accurate tribal enrollment numbers are reported to the Formula Service Center and HUD for future grant years.

Support the eligibility of the reported $548 in unsupported program costs or repay its program using non-Federal funds.

Implement controls to ensure that all future check request forms are complete for proper tracking in its accounting records and authorized approver verifies source documentation is attached prior to check issuance for future program expenses as required by its own policies and procedures.

Acknowledge that $2.93 million in the attached settlement agreement represents an amount due HUD, less DOJ’s civil debt collection fees. (Footnote 2 - DOJ’s 1994 Appropriation Act (Public Law 103-121) authorized DOJ to retain up to 3 percent of all amounts collected as the result of its civil debt collection litigation activities.)

Acknowledge that $41 million of the $89,274,944 in the attached settlement represents an amount due HUD, less DOJ’s civil debt collection fees.

Clarify whether assistance provided under its community development programs, such as HOPWA, are considered “Federal public benefits” and are, therefore, subject to PRWORA’s noncitizen eligibility restrictions.

Consult with the Office of the Attorney General to establish whether HOPWA and other homeless assistance programs are a Federal public benefit that meets the definition of “providing assistance for the protection of life or safety” and are, therefore, exempt from PRWORA noncitizen eligibility restrictions.

Provide adequate supporting documentation for the amount of Public Housing Capital Fund loan to verify the loan source. If another source of Federal funds is determined, repay the amount to the appropriate program from non-Federal funds.