We recommend that the Director of CPD’s Office of Disaster Recovery develop and implement internal controls to ensure that grantees completely and accurately report non-Federal match activities in DRGR.

Provide evidence to support that the Authority corrected the 11 unit deficiencies for the 5 units and 7 building deficiencies for 4 buildings with outstanding deficiencies.

Determine the frequency of its quality control reviews of its inspections and work orders and update its quality control policy, training materials, and other resources as appropriate to ensure that its quality control process is consistently implemented.

Support that it has implemented its quality control policy for (1) monitoring the effectiveness of its unit and building inspections to ensure compliance with HUD’s and its own requirements and (2) reviewing work orders to ensure that cited deficiencies are corrected in accordance with HUD’s and its own requirements.

Provide evidence to support that the Authority corrected the four non-life-threatening deficiencies for the three units with outstanding deficiencies.

Implement adequate procedures and controls to ensure that the deficiencies identified during annual self-inspections are properly categorized and corrected in a timely manner.

Develop and implement a plan to manage and reduce its backlog of work orders. This plan should include but not be limited to (1) assessing and addressing staffing needs; (2) creating a timeline for completion of the work orders to ensure that its properties are maintained in decent, safe, and sanitary condition and in good repair; and (3) providing documentation showing that it is on track to meet the completion timeframe.

Implement adequate procedures and controls to ensure that inspection reports are uploaded to the Authority’s electronic filing system and work orders are created in a timely manner. This process should include but not be limited to providing training to its staff on the Authority’s systems, establishing timeframes for the creation of work orders, and monitoring the work order process.

Provide evidence to support that the Authority corrected the 3 non-life-threatening health and safety, and 19 non-health and safety deficiencies.

Develop and implement adequate procedures and controls to ensure that (1) the deficiencies identified during REAC inspections are corrected in a timely manner and (2) documentation is maintained to support that repairs were made.

Implement adequate controls to ensure that the Authority’s information system properly tracks the completion of work orders.

Implement adequate controls to ensure that the correction of life-threatening deficiencies is reported to HUD accurately and in a timely manner.

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.

Issue guidance to PHAs clarifying the timing of unit inspections and lead-based paint visual assessments to address the misinterpretation caused by the terms “annual” and “every 12 months.”

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.