We further recommend that the Southwest Region Director of Multifamily Housing require its contract administrator for Beverly Place to verify that the owner’s recently implemented quality control program is working as designed.

We further recommend that the Southwest Region Director of Multifamily Housing ensure that the project-based contract administrator’s review process includes steps to obtain reasonable assurance that tenants being reported as subsidized at Beverly Place live in the subsidized units.

Take appropriate administrative sanctions, including suspension, limited denial of participation, or debarment, against the commissioners.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to repay from non-Federal funds $11,172 paid for ineligible travel costs of which $6,904 was Housing Choice Voucher and $4,268 was operating subsidy funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to repay from non-Federal funds $2,946 paid for excessive lodging rates, extra trip days, and car rental costs of which $1,214 was Housing Choice Voucher and $1,732 was operating subsidy funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to support or repay its HUD programs from non-Federal funds $9,020 for unsupported meals, incidental expenses, lodging costs, and travel for training of which $2,978 was Housing Choice Voucher and $6,041 was operating subsidy funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to adopt policies and procedures that contain current Federal and State guidance.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to provide training to commissioners and employees on travel requirements and their responsibilities and duties.

Acknowledge that the attached settlement agreement for $10,000 represents an amount due HUD.

Repay the program $7,323 from non-Federal funds for ineligible code enforcement costs.

Support the $576,997 in code enforcement costs (activities 499, 512, and 531), including meeting code enforcement and cost allocation requirements, or repay the program from non-Federal funds.

Implement revised code enforcement program policies and procedures to meet CDBG requirements. This will help ensure that the remaining $328,918 budgeted for code enforcement activity 531 is put to better use.

Support the reasonableness of the $110,000 Graffiti Removal program (activities 504 and 520) cost allocations or repay the program from non-Federal funds.

Support the $31,186 After School program (activity 501) costs, including the reasonableness of the contract costs and meeting the limited clientele national objective, or repay the program from non-Federal funds.

Support the reasonableness of the $95,736 in cost allocations charged as CDBG administrative (activity 522) costs or repay the costs from non-Federal funds.

Implement additional policies and procedures to ensure that salaries and wages and cost allocations are charged in compliance with HUD requirements.

Implement additional procedures and controls to ensure that documentation is obtained to support that the limited clientele national objective was met.

Obtain training or technical assistance on CDBG program requirements.

Determine legal sufficiency and if legally sufficient, pursue civil and administrative remedies against Cypress Meadows, LLC; Skyline Crest Enterprises, LLC; the project’s owner; or all three for inappropriately disbursing funds in violation of the project’s regulatory agreement, operating lease agreement, and HUD requirements.

Pursue appropriate civil money penalties and administrative actions, up to and including debarment, against Cypress Meadows LLC; Skyline Crest Enterprises LLC; the project’s owner; or all three for violating the project’s regulatory agreement, operating lease agreement, and HUD requirements.