We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to obtain technical assistance concerning the disaster recovery program requirements, including related Federal Register requirements. Specifically, the technical assistance should include guidance on how to satisfy the requirement regarding maintaining an internal audit function and Web site maintenance.

Director for the Office of Field Management ensure that the CDBG-DR risk analysis worksheet includes risk factors that show the measurement of performance outputs to determine completed activities.

Director for the Office of Field Management update the risk analysis guidance for CDBG-DR grants to include the assessment of the likelihood of risk occurrence to help inform management which critical risks to address during monitoring.

Director for the DRSI Division ensure that monitoring strategies correlate to the high-risk areas identified during the risk analysis and are in compliance with the central risk factor categories identified in HUD’s Monitoring Desk Guide.

Ensure that CPD personnel that plan for, award, and manage grants and other forms of financial assistance receive formal risk analysis training.

Provide adequate documentation to support the $21,373,462 in unreasonable and unnecessary obligated funds.

Strengthen and implement acquisition controls to ensure that proper cost and price documentation is obtained, adequate monitoring is conducted, adequate market research is conducted and that contractors are evaluated to assess their capability to perform work, and required contract documentation is maintained in the file to ensure that $9,645,864 that is yet to be used will not be spent for unreasonable and unnecessary costs.

Seek reimbursement for $161,718 in ineligible funds disbursed for equipment and support services not specified in a scanning services contract.

Provide documentation to show that prices paid for products and services totaling $1,423,262 for three activities were fair and reasonable or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $942,636 for activity 7099 were for employees’ actual time spent benefiting the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $100,000 for activity 6865 benefited the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that seven activities with costs totaling $2,266,543 were exempt or categorically excluded from environmental reviews or repay its program from non-Federal funds for any amount that it cannot support (excluding any amount repaid as a result of recommendations 1A, 1B, and 1C).

Revise its policies and procedures to address compliance with applicable procurement regulations requiring independent cost estimates before receiving bids or proposals.

Train its staff on requirements for documenting costs funded by multiple funding sources.

Develop and implement controls to ensure that subrecipients comply with requirements for documenting costs funded by multiple funding sources.

Determine whether it has complied with environmental review requirements for all activities since October 2010 and provide a copy of its determination to HUD. If it did not comply, either provide the necessary support for the activities or repay its program from non-Federal funds for any activity costs it cannot support.

Develop and implement controls to ensure that it complies with environmental review requirements.

Review accomplishment data that it reported in IDIS for open and completed activities to ensure that accomplishments were reported accurately.

Train its staff on reporting accomplishments in IDIS and develop and implement policies and procedures for supervisory review to ensure accuracy.

Include compliance with environmental review requirements in its project-specific reviews in its next periodic monitoring of the City’s Block Grant program.