Develop and implement policies and procedures to ensure that code enforcement salaries and benefits are charged and documented in accordance with program requirements.

Provide documentation to support $285,496 in graffiti abatement expenditures or repay the program from non-Federal funds (appendix D).

Develop and implement procedures and controls to ensure that graffiti abatement expenditures, including salaries and benefits, are accurately charged to CDBG grants and properly supported.

Support the unsupported amount of match for its subgrantee or repay HUD $54,473 from non-Federal funds (appendix D).

Implement written procedures to include the confirmation of match funds as part of its annual monitoring reviews of each subgrantee.

Develop and implement a written plan for its subgrantees to provide and submit supporting documentation for match funds at the end of each grant term.

Support sampled retroactive payroll costs totaling $12,109, which correspond to the actual time attributed to grants CA0689L9D011502, CA0880L9D011501, CA0881L9D011501, and CA0945L9D011506, or reimburse HUD from non-Federal funds.

Identify retroactive payroll for remaining grants (CA1162L9D011504, CA1024L9D011501, CA0694L9D011508, and CA0693L9D011508) and provide adequate documentation to support the cost or repay HUD from non-Federal funds.

Develop and implement additional procedures and controls to ensure that payroll costs charged to the grant reconcile to actual hours worked on the grants.

Certify, along with the owners of the 63 units cited in this finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $29,226 from non-Federal funds ($27,737 for housing assistance payments and $1,489 in associated administrative fees) for the 22 units that materially failed to meet HUD’s housing quality standards.

Develop and implement procedures and controls to ensure that program units meet housing quality standards and inspectors are adequately trained to perform inspections, thereby ensuring that an estimated $1,241,550 in program funds is spent for units that are decent, safe and sanitary.

Reimburse its program $3,822 from non-Federal funds for housing assistance payments that should have been abated.

Reimburse five owners $267 for the excess housing assistance payments it abated.

Develop and implement policies and procedures to ensure that extensions granted to owners to make repairs after failed inspections comply with HUD regulations.

Develop and implement controls to ensure that abatements are properly calculated and procedures in its administrative plan are followed.

Train its staff on the proper abatement of housing assistance payments.

Conduct criminal record background checks in accordance with its policies and procedures to ensure that adult members of households for whom the Authority made housing assistance payments totaling $4,920,685 were eligible to participate in the program or repay its program from non-Federal funds for any amount that it cannot support. If the participants are deemed ineligible, the Authority should follow applicable regulations to terminate or modify assistance.

Develop and implement controls to ensure that criminal records checks are conducted, according to policy, at application and when family composition changes.

Repay its program $19,520 from non-Federal funds for the ineligible housing assistance payments made.