We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $2,689 disbursed due to a higher than required overtime rate was supported by documentation from the trade unions or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to reimburse its program $1,198 from non-Federal funds for overpaid wages due to billing and payroll errors.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to pay $544 in unpaid wages to the subcontractors of the affected employees and submit evidence that these employees have been paid.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide training to its staff to help ensure compliance with applicable cost principle, procurement, and Davis-Bacon requirements.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that it has strengthened its invoice review process to ensure that costs are eligible and supported before disbursing Disaster Recovery funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that payments made under the Rockaway Boardwalk construction management services contract complied with Davis-Bacon and Related Acts requirements and that restitution is made to affected workers for any underpayments identified.

Provide adequate documentation to support that the $71,034 spent for improperly procured goods and services was spent at the most competitive prices. For any amounts not supported, it should reimburse its program from non-Federal funds.

Provide adequate documentation to support $15,280 spent for maintenance activities. For any amounts not supported, it should reimburse its program from non-Federal funds.

Develop and implement detailed operating procedures, including checklists, which fully implement its procurement policy and HUD requirements.

Ensure that its executive director obtains appropriate procurement training.

Work with the Authority to develop a formalized process, such as a checklist, to use when conducting initial certifications and annual recertifications, which would help to ensure that it follows HUD requirements for its public housing program.

Require the Authority’s executive director to obtain appropriate training regarding public housing occupancy requirements.

Require the Authority to conduct a 100 percent review of its tenant files to ensure that tenants’ rents are accurate and the proper income, asset, and medical expenses are complete and documented in the tenant files.

Monitor the Authority after the recommended training and tenant file reviews are complete to ensure that the executive director understands and properly implements public housing occupancy requirements.

Require the Authority to address actual or potential conflict-of-interest relationships in its Admissions and Continued Occupancy Policy.

Work with the Authority to develop a plan to ensure that a third party reviews the initial tenant certifications and annual recertifications with an actual or potential conflict of interest.

Ensure that the Authority’s board of commissioners and staff receive HUD-approved training on conflicts of interest.

Monitor the Authority to ensure that initial tenant certifications and annual recertifications with an actual or potential conflict of interest are appropriately handled.

Require the Authority to develop and implement detailed policies and procedures to address collections, tracking, and use of its laundry machine revenue.

Require the Authority to determine how much laundry machine revenue was not deposited into its accounts and used for eligible purposes and reimburse its program from non-Federal funds.