Provide technical assistance to the State and the staff to ensure that they understand the requirements for conducting a monitoring review in accordance with regulations.

Instruct the State to update and implement the CDBG-DR standard operating procedures, which clearly outline what activities, including the frequency, will be reviewed by its monitoring and internal audit function.

Instruct the State to conduct monitoring reviews of its CDBG-DR HIM activities and subrecipients that satisfy monitoring requirements.

Work with the State to develop and implement policies and procedures to ensure that monitoring is conducted remotely in the event that it cannot be conducted onsite.

Instruct the State to update and implement policies and procedures to ensure that the results of the CDBG-DR internal audits are shared by the State’s Commissioner with CDBG-DR program staff to allow for the resolution of any findings and required corrective actions.

Monitor the State’s CDBG-DR program to ensure that performance expectations are achieved.

Complete and update the system security plans for GMP and DRGR and issue an SSN justification memorandum.

Identify and provide additional role-based training, guidance, and instructions to CPD employees on how to appropriately handle and safeguard PII encountered during monitoring.

Reinforce the use and admissibility of photographs and videos for evidence collection while remote monitoring.

Identify strategic opportunities to use remote monitoring early in the FY to maximize its responsibility to oversee and monitor its grantees and then use remote monitoring when those opportunities arise.

We recommend that the Director of CPD’s Office of Disaster Recovery review the one grantee with a grant totaling $666,666 that did not meet the overall LMI requirement and address the noncompliance.

We recommend that the Director of CPD’s Office of Disaster Recovery update DRGR’s QPR to include information on the progress towards compliance with the overall LMI benefit based on the total amount of the grant.

We recommend that the Director of CPD’s Office of Disaster Recovery adopt LMI benchmarking to ensure that grantees budget adequate funds to LMI at significant milestones in the grant lifecycle.

We recommend that the Director of CPD’s Office of Disaster Recovery make changes to the action plan process so that the action plan calculates an overall LMI percentage.

Develop and document internal procedures to ensure that they will address the Program Office’s responsibilities within the departmental grant accrual validation policy.

Re-evaluate and adequately document justification for the establishment of the percentages and other key assumptions used to determine the accrual amount for each program in CPD’s accrued grant liabilities estimate.

Implement written procedures to ensure consistency among field offices in reviewing spending issues, potentially preventing up to an estimated $47 million in annual CoC recaptures.

Design and implement a training program and other development tools to help grantees. The goal of such training would be to provide ideas and other development tools to help the CoCs better provide assistance with implementation of their grants and monitoring of their grantees, including assistance with developing outreach strategies, partnering with community providers, financial budgeting, and best practices. The training should focus on the needs of first-year grantees and CPD should take steps to encourage participation.

Use the fraud risk inventory to enhance program-specific fraud risk assessments for the HOME program.

Consider allowing grantees additional time to spend the program funding on eligible activities to meet the 80 percent spending deadline.