Support the reasonableness of the $110,000 Graffiti Removal program (activities 504 and 520) cost allocations or repay the program from non-Federal funds.

Support the $31,186 After School program (activity 501) costs, including the reasonableness of the contract costs and meeting the limited clientele national objective, or repay the program from non-Federal funds.

Support the reasonableness of the $95,736 in cost allocations charged as CDBG administrative (activity 522) costs or repay the costs from non-Federal funds.

Implement additional policies and procedures to ensure that salaries and wages and cost allocations are charged in compliance with HUD requirements.

Implement additional procedures and controls to ensure that documentation is obtained to support that the limited clientele national objective was met.

Obtain training or technical assistance on CDBG program requirements.

Develop improved procedures and provide training to appropriate staff regarding the departmental clearance process requirements, including • Determining which guidance is considered to be a directive, including public communications, and • Ensuring that HUD program participants have clear, instructive, and helpful information to comply with the applicable requirements and procedures for HUD programs.

Pursue departmental clearance for the July 25, 2013, guidance that did not go through required departmental clearance. For any items that cannot be appropriately cleared, HUD should take appropriate action to recall the document or policy.

Develop guidance that helps the public understand its options for assistance between CDBG-DR and SBA and how to comply with Federal requirements.

Develop and implement a written methodology for employees’ time allocations for its HUD grant programs in accordance with program requirements.

Provide training on compensation for personal services grant program requirements to employees working on HUD grants.

Support $142,181 spent on payroll allocated to HUD grants or repay the program from non-Federal funds.

Provide supporting documentation or reimburse its Program $81,654 from non-Federal funds for unsupported on-the-job training costs incurred under project FL0220L4D001407.

Provide supporting documentation or reimburse its Program $1,023 from non-Federal funds for unsupported personal cell phone costs incurred under project FL0220L4D001407.

Provide guidance to subrecipients to ensure that (1) on-the-job training hours are supported by source documents, such as signed attendance or time sheets, and (2) personal goods and services are supported by documents that show the allocation between business and personal use.

Report Program income of $31,724 for FL0199L4D001407 to HUD.

Provide supporting documentation to show that participant 87487 from FL0431L4D001403 was chronically homeless or reimburse its Program $15,756.

Perform onsite monitoring of the subrecipient that administered project FL0431L4D001403 to ensure that participants are eligible and annual income re-certifications are performed.

Reimburse NSP2 from non-Federal funds for the $59,523 in ineligible disbursements on the five vouchers.

Provide documentation to support that the $224,868 in NSP2 funds drawn down from the four vouchers was eligible or repay the program from non-Federal funds.