Work with the owners, lenders, operators, and management agents (as applicable) to develop and implement an action plan for potentially troubled and troubled nursing homes. Each plan should include an analysis of the root causes of that nursing home’s challenges and define specific and measureable steps that address the root causes. Each step should have a defined completion date.

Implement the action plan for the four defaulted nursing homes to protect HUD’s investment of $41,435,357. This amount represents the collective funds put to better use for these nursing homes. Appendix E lists the funds to be put to better use by nursing home

Develop and implement policies and procedures to address delinquent or defaulted mortgages that would not benefit from refinancing.

Refer regulatory agreement violations to the Departmental Enforcement Center within 30 days of HUD having identified it and work with the Departmental Enforcement Center to develop a plan for resolving the violation. Any revisions to the plan must be accepted by the Departmental Enforcement Center.

Review and revise the policies and procedures for making partial payments of claims to check that each decision to make a partial payment of claim ensures that the payment restores the subject nursing home to financial viability to avoid a repeat of the situation that led to the loss on Hebrew Home.

Require Jamaica Hospital Nursing Home to provide support for $8,974,000 paid to its related company. Any amount that the owner cannot support as reasonable in price and necessary to the nursing home should be repaid to the nursing home.

Require Jamaica Hospital Nursing Home to provide support for $44,483,000 in accounts payable. Any amount that the owner cannot support as reasonable in price and necessary to the nursing home should be removed from the accounts payable

Require the owners of Bishop Wicke Health and Rehabilitation Center, Plaza Village Senior Living, Golden Hill Health Care Center, Immanuel Campus of Care, and their related companies to reimburse the nursing homes for the ineligible expenses of $7,027,289.

Require Shawnee Christian Nursing Center to return 27 beds to operation or pay down the mortgage by $815,973

Define the troubled and potentially troubled classifications for nursing homes and develop specific measures to identify when and how nursing homes are classified.

Develop and implement policies and procedures to revisit the classifications at least annually.

Develop and implement computerized controls to flag blank data fields and illogical financial data.

Develop and implement procedures to require owners, operators, and lenders to submit accurate and complete financial data.

Develop and implement internal controls to routinely compare financial data on mortgage payments to Multifamily Delinquency and Default Reporting System data on mortgage payments and follow up on any conflicting data.

Develop and implement procedures for referring operators who fail to provide required financial statements to the Departmental Enforcement Center.

Develop and implement metrics to evaluate each nursing home’s financial data for changes in utilization, payments, profitability, and solvency (debt service credit ratios).

Require the 12 grantees to correct their action plans to ensure that they comply with program requirements and submit the corrected plans to HUD for review or require the grantees to repay HUD from non-Federal funds for any amount of the $7,779,450 they received that they cannot support.

Require the Housing Authority of Brevard County to repay $1,520 in ineligible escrow funds to HUD from non-Federal funds for the program participant that exceeded allowable contract terms of the FSS program.

Monitor the grantees’ efforts to improve the accuracy and completeness of the PIC program data to ensure that program outcomes reported to Congress are accurately supported.

Develop and implement a plan to monitor grantee FSS programs, including to ensure that escrow accounts are calculated correctly.