Verify with ARC on a regular basis that all travel cardholders have completed their training as required.

Require justification and approval for selecting a nonrefundable rate in the travel system comments section.

Generate a periodic monitoring report that would identify employees who did not use their government travel card when required and send this report to employees’ supervisors and the Assistant Secretary of related program offices for proper action.

Require justification and approval in the travel system comments section when requesting lodging expense reimbursement to the traveler’s bank account.

Update HUD’s travel card policy to require approving officials’ review of travel documents for appropriate methods of payment and work with the Office of Employee Labor Relations and the Office of the Chief Human Capital Officer to prescribe disciplinary actions for not using the government travel card when required.

Inform all HUD travel cardholders and approving officials about the mandatory use of the government travel card and disciplinary actions for not using it.

Follow up with the 19 employees identified as failing to use their government travel card and coordinate with the related program offices to ensure these employees receive training, counseling or other appropriate disciplinary action, if necessary, on the mandatory use of the government travel card.

Develop and implement adequate enforcement procedures that support its policy and ensure that housing quality standards deficiencies are corrected in a timely manner.

Work with the City of Denver Office of Economic Development to recapture $37,000 in HOME funds not properly used for the affordable housing projects.

Require Del Norte to develop policies and procedures to prevent ineligible affordability period transfers.

Ensure that the HECM cash flow model assumptions capture all valid assignments or provide an analysis showing that the model results are not biased due to the exclusion of valid HECM assignments.

Document and implement policies and procedures to ensure that data observations for key assumptions that are inconsistent with FHA’s understanding of program operations are researched and further analyzed and that all results are concurrently documented and included in the model documentation.

Update the posting models to ensure that refunds relating to payments made in prior years are properly recorded in accordance with OMB Circular A-11.

Correct the programming error in the HERMIT system to ensure that the correct insurance-in-force balances are reported on the note disclosures.

Develop policies and procedures to ensure that the line items in the required note disclosures are understood, properly calculated, and properly disclosed in the financial statements in accordance with OMB Circular A-136.

Implement adequate procedures and controls to ensure that all required data are complete, accurate, and reported in a timely manner. These procedures and controls should include but not be limited to ensuring that all transactions are recorded and reported within the proper period and listing the source of each of the data elements, including how to obtain the source documentation from HUD’s various program offices or systems.

Implement adequate procedures and controls to ensure that all data elements are traceable to the source documentation.

Revise internal DATA Act policy and procedure documents to resolve inconsistencies to ensure full, appropriate, and consistent implementation of the DATA Act.

Take appropriate enforcement actions against the responsible parties and pursue civil action against the owner for improperly certifying to the eligibility of the project residents.

Pursue administrative actions, as appropriate, against the responsible parties for the improper certification included in form HUD-50059 and the Section 8 project-based voucher housing assistance payments contract.