Implement adequate procedures and controls to ensure that the Authority complies with HUD’s requirements for its investments of Federal funds.

Ensure that its staff is properly trained and familiar with HUD’s requirements to ensure that it properly procures and invests Federal funds in HUD-approved investment accounts.

Ensure that the proceeds from the sale of Bollinger Tower proceeds are moved into a separate HUD-approved restricted investment account and appropriately recorded in a restricted account in the general ledger.

Implement adequate policies and procedures to ensure that future proceeds from the disposition or sale of public housing are appropriately recorded and reported in the Authority’s books of record and annual audited financial statements and HUD’s Financial Data Schedule system.

Ensure that its staff is appropriately trained and familiar with HUD’s requirements to ensure that proceeds from future dispositions or sales of public housing property or other HUD assets are appropriately recorded and reported.

Determine the source of funds for the Waggoner Senior Housing note to ensure that the funds were loaned appropriately and that when payments are received, the payments are applied to the appropriate account. If the source of funds cannot be determined, the Authority should reimburse its program $261,990 from non-Federal funds.

Ensure that the newly developed procedures are sufficient and fully implemented to ensure that the source of funds loaned is properly tracked and that payments received are applied to the appropriate accounts.

Support the reasonableness of the $258,412 paid for contract M-1449 or reimburse its Capital Fund program from non-Federal funds.

Support that the contract modification totaling $4,899 for contract number M-1449 was reasonable. The amount that cannot be shown to be reasonable should be reimbursed to its Capital Fund program from non-Federal funds.

Implement adequate procedures and controls to ensure that it complies with HUD’s procurement requirements.

Ensure that its staff is properly trained and familiar with HUD’s requirements to ensure that documentation necessary to support the reasonableness of contract costs is obtained and maintained.

Implement adequate procedures and controls to ensure that capital funds are drawn down and disbursed in accordance with HUD’s requirements.

Implement adequate procedures and controls to ensure that it properly reports its expenditures and disbursements in LOCCS in accordance with HUD’s requirements.

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