Establish internal and financial controls to ensure that it allocates, tracks, and reports future non-Federal match costs separately from other disaster recovery costs within the DRGR system for future disasters, which will ensure that at least $1.3 million is correctly reported as other disaster recovery costs rather than as costs that Colorado is using to meet its non-Federal match requirements.

Provide documentary support in the DRGR system that it met and did not exceed the match percentage set by FEMA for its completed Public Assistance activities

Require grantees to include in their DRGR system’s reports their non-Federal match costs in a manner that documents that they have met FEMA’s set match percentage requirements and issue a template to grantees to ensure consistency of reporting in their systems of records.

Instruct PRDOH to remediate all outside installations that are directly exposed to sunlight and the elements or repay HUD $19,185,244 from non-Federal funds.

Instruct PRDOH to enforce its contract terms and conditions, which requires installers to install batteries and inverters outside of direct sunlight and exposure to the elements.

Instruct PRDOH to address and correct all the deficiencies noted for the properties inspected.

Require PRDOH to implement a review process to better structure its future contracts to ensure that the scope of work is clearly defined so that all parties understand the agreement. This includes, but is not limited to, ensuring that the basic subtasks needed to complete projects are considered and included only as necessary in future contracts.

Instruct PRDOH to re-evaluate its use of the IRS Form 1040 AGI calculation methodology to assess participants’ income compared to the income calculation methodology defined under Section 8 program at 24 CFR § 5.609 and determine whether it ensures consistent eligibility determination for the program.

Develop and implement a fraud risk management program with an emphasis on obtaining high-level management buy-in to ensure commitment from the board and senior management and subsequently, to ensure involvement of all levels of the program in setting an anti-fraud culture and tone to effectively combat fraud. This would include ensuring the program includes specific procedures to effectively manage fraud disclosures from employees and emphasis on reporting fraud to the HUD OIG Hotline.

Establish a dedicated anti-fraud component to design and oversee risk management activities within the organization and its subrecipients.

Implement fraud risk assessment processes tailored to all levels of the program to identify and assess risks to determine VIHFA’s disaster recovery and mitigation program’s risk profile.

Evaluate its program’s fraud risk profile and fraud risk assessment outcomes to (1) design risk responses and specific actions for responding to fraud, and (2) develop, document, and communicate an anti-fraud strategy for employees and stakeholders that contain all key elements described in GAO’s “A Framework for Managing Fraud Risks in Federal Program” (3) monitor and evaluate fraud risk management activities to improve the organization’s fraud risk management.

Implement fraud awareness initiatives, such as official anti-fraud training for staff and stakeholders, including subrecipients. This could include developing frequent formal communication containing newsletters or bulletins and post physical visual displays to ensure staff’s fraud awareness when conducting day-to-day activities.

Upon completion of recommendations 1A – 1E, assess whether VIHFA has established and implemented mature fraud risk management practices within its disaster recovery and mitigation programs.

Repay ineligible landlord holding fees of $964,952 drawn from ESG CARES Act funds to HUD from non-federal funds.

Determine if the $58,878 drawn for 18 signing bonuses or additional security deposits from ESG CARES Act funds were reasonable under the program participant’s particular circumstances, and not more than necessary to house the program participants or repay HUD from non-federal funds.

Repay risk mitigation overpayments of $6,549 drawn from ESG CARES Act funds to HUD from non-federal funds.

Determine if the remaining risk mitigation expenses of $185,731 drawn from ESG CARES Act funds were reasonable and necessary in accordance with program requirements or repay HUD from non-federal funds.

Support the cost reasonableness of $96,561 drawn from ESG CARES Act funds for the kitchen services contractor or repay HUD from non-federal funds.

Develop and implement additional written procedures and internal controls for the annual ESG program to ensure that it, and its subrecipients, do not charge holding fees and risk mitigation costs as expenses to the program, and that contracts are properly executed and maintained.