We recommend that HUD work with Connecticut and Shelby County to fully realize the program benefits by (1) assessing whether any of the current project activities need to be replaced with more viable project activities, thereby ensuring that any modifications to the project activities will lessen the susceptibility of rain and flood events; (2) assessing whether administrative funds have been properly allocated and charged to identify any possible cost savings; (3) determining whether enough administrative funds or other available funds exist to complete the administration of the grant project activities; and (4) developing and implementing a written plan of action that will assist with expediting the project activities that could reasonably be expected to be completed by the September 30, 2029, deadline.

We recommend that HUD conduct onsite or remote monitoring for the City of Minot and Tennessee, which have not had any monitoring since grant inception, to ensure that these grantees are on track to meet their program goals.

We recommend that HUD for grantees with delayed project activities (California, Connecticut, Louisiana, Tennessee, Virginia, New York City, Minot, and Shelby County), require each grantee to provide a detailed timeline with milestone dates of when projects should be completed and provide updates to ensure that grantees stay on schedule.

We recommend that HUD for its disaster-related program wide activities, revise the action plan and quarterly performance review checklists to a format that more specifically and directly addresses the subject program.

We recommend that HUD for its disaster-related program wide activities, require grantees to provide documentation showing that they have upfront collaboration with partnering entities in executing the grant program. If the grantee plans to hire contractors, HUD should ensure that grantees have a plan to quickly onboard contractors early in the program.

We recommend that the Deputy Assistant Secretary for Operations of Community Planning and Development enhance CPDs existing Grant Accrual Standard Operating Procedures to strengthen governance within CPD and to effectively work within the framework established by the OCFO in recommendation 1A. The updated procedures should include increased ownership and oversight over the reviews, authorizations, approvals, and changes to the CPD grant accrual estimates and methodology.

Take corrective action for the subrecipient monitoring and agreement issues cited for eight of the ESG-CV grantees reviewed, and provide additional guidance and technical assistance as needed to ensure that they understand requirements.

Develop and implement additional subrecipient monitoring training and guidance for all ESG grantees.

Improve or enhance its antifraud efforts for the ESG program and incorporate fraud risk management practices that are consistent with the best practices identified in the Government Accountability Office’s A Framework for Managing Fraud Risks in Federal Programs and Chief Financial Officers Council and Treasury Bureau of the Fiscal Services’ Antifraud Playbook.

Obtain training or technical assistance as needed on the implementation of fraud risk management practices.

Establish a separate fraud risk management framework or evaluate and build upon its ERM framework by incorporating fraud risk management practices that are consistent with the principles of GAO’s Standards for Internal Control in the Federal Government (Green Book), including developing a fraud risk management framework in alignment with best practices identified in GAO’s A Framework for Managing Fraud Risks in Federal Programs and the Chief Financial Officers Council’s Antifraud Playbook.

Obtain training or technical assistance on the implementation of fraud risk management practices consistent with the principles of GAO’s Standards for Internal Control in the Federal Government (Green Book).

Work with PRDOH to determine whether its current method of measuring how many applicants purchased their home through the program is the best way to measure the HBA program’s impact.

Based on the results of recommendation 1A, update the HBA guidelines and the Puerto Rico disaster recovery action plan.

Instruct PRDOH and PRHFA to develop and implement clear and consistent guidelines and procedures that establish a verifiable methodology for determining the amount of financial awards granted to eligible HBA participants.

Include, as part of the revised procedures, a requirement to document within each case in SSP a detailed (1) calculation of the household income and (2) the analysis and computations conducted by the PRHFA underwriter for determining the amount of the financial assistance award.

Instruct PRDOH and PRHFA to provide training and guidance to participating lending institutions related to the updated guidelines and procedures for determining the financial award granted to HBA participants to ensure that program funds are distributed in an equitable manner.

We recommend that HUD require the City to reassess the eight infrastructure projects still in the design or planning phase to determine whether the City can complete the projects or how the remaining funds could be best used within the 6 years remaining for the grant period to ensure that the City is protected from future storm and rain events.

We recommend that HUD require the City to for the $14,683,335 originally budgeted for the Milneburg and Microgrid projects, work with HUD to (1) determine whether its planned action plan amendment would constitute the need to submit a substantial action plan amendment, (2) ensure that any modifications in its action plan amendment would lessen the susceptibility of rain and flood events within the Gentilly area, and (3) require that any activities pursued under the action plan amendment could reasonably be expected to be completed by the September 30, 2029, deadline.

We recommend that HUD require the City to review the number and type of positions for its National Disaster Resilience staff that are responsible for the oversight and completion of infrastructure projects and ensure that it has the appropriate staffing levels to complete adequate monitoring and oversight of the projects.