We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to review and update its internal controls throughout the grant cycle to ensure that the procurement and expenditure policies and procedures are implemented and working as designed, including the Federal prohibition of cost plus percentage of cost contracts.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to fill vacancies, ensuring that staffing levels remain adequate to administer Hurricane Harvey disaster grant funds.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to negotiate with SBA to extend its data-sharing agreements for the term of the expenditure requirements set forth in public laws or the Federal Register.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to initiate negotiations with the Texas Department of Insurance to establish data-sharing agreements for the Hurricane Harvey disaster, any open disaster recovery grants, and future disasters.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to ensure that false statement and false claim warnings are included in all of its contract-related forms.

Update the program’s information reporting requirements on form HUD-4117 to ensure that grantees report tribal enrollment numbers annually regardless of whether there are changes or corrections.

Revise form HUD-4117 to include certification and false claim statements that hold grantees responsible for reporting accurate tribal enrollment numbers to HUD annually.

Develop and implement policies and procedures to assist in formal challenging of grantees’ reporting tribal enrollment numbers in accordance with applicable requirements.

Issue guidance to grantees on procedures to ensure accurate reporting of tribal enrollment numbers.

Develop and implement procedures to ensure that it maintains documentation to show that it selected participants from its waiting list in accordance with applicable requirements.

Develop and implement procedures to ensure that it maintains criminal background checks in separate, secure files.

Support the $797,222 in code enforcement costs, including meeting code enforcement and salary and benefits requirements, or repay its program from non-Federal funds.

Develop and implement written policies and procedures to define deteriorated or deteriorating areas, which would apply to its CDBG-eligible target areas, and establish a written plan for using the program, in conjunction with public or private improvements, rehabilitation, or services, that may be expected to arrest the decline in CDBG-eligible target areas.

Develop and implement written procedures and controls to properly track and charge code enforcement officers’ costs among different CDBG activities and other funding sources.

Provide training to code enforcement staff on HUD CDBG regulations and requirements.

Require the Authority to design and implement controls to ensure that employees comply with RAD relocation requirements and that its RAD conversion plans submitted to HUD accurately address any tenant relocations.

Monitor the Authority to ensure that it does not improperly relocate tenants during its planned conversion of the remaining public housing units.

Conduct a compliance review of relocation and pursue corrective action as necessary on behalf of the permanently relocated tenants.

Amend its 2015 annual action plan to include the Main Street Revitalization program.

Implement controls and procedures to ensure that all future action plans include all methods of distributing grant funds or amend the plan as required if programs are added after approval.