We recommend that the Director of the Office of Block Grant Assistance require the Texas General Land Office to implement appropriate cost controls, including limits for reconstruction and rehabilitation costs, to ensure that it uses limited government resources in a more economical and efficient manner. Those costs should not exceed the costs that would be incurred by a prudent person under similar circumstances.

We recommend that the Director of the Office of Block Grant Assistance require the Texas General Land Office to evaluate whether its programs would benefit from a longer affordability period and take appropriate actions to ensure that low- and moderate-income communities have access to affordable homes for an adequate period.

We recommend that the Director of the Office of Block Grant Assistance require the Texas General Land Office to ensure that the tax burden implications are a part of the determination of whether to spend significantly more than the damaged home’s appraised value to replace the home. This measure would include ensuring that participants are fully informed of the substantial and material property tax consequences that they could incur based on the increased values of their reconstructed homes (appendix B).

Develop and implement a financial management system in accordance with HUD requirements, including but not limited to permitting the disbursement of funds in a timely manner.

Ensure that $1,045,085 in CDBG funds drawn from HUD between July 1, 2015, and October 31, 2018, can be traced to a level, which ensures that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes, or reimburse the CDBG program from non-Federal funds. Footnote 2: Total drawdowns of more than $1.5 million were adjusted to consider $106 questioned in recommendation 1D and $469,974 in recommendation 2A.

Require the Municipality to return to its line of credit and put to better use $1,641 associated with the unspent program funds that have been carried over since December 2017.

Reimburse the CDBG program from non-Federal funds the $106 paid for ineligible bank penalties.

Establish and implement adequate controls and procedures to permit proper accountability for all CDBG funds to ensure that they are used solely for authorized purposes and properly safeguarded.

Submit supporting documentation showing how $469,974 in CDBG funds disbursed for street improvements was properly used and in accordance with HUD requirements or reimburse the CDBG program from non-Federal funds.

Determine the amount spent for the resurfacing of the 16 private properties identified and reimburse the CDBG program from non-Federal funds.

Establish and implement adequate policies and procedures, including project inspection protocols, to ensure that CDBG funds are used for activities that meet a national objective, are used for eligible purposes, and are properly supported.

Repay from non-Federal funds the $665,920 in ineligible costs charged to the program

Support that 14 projects, with $494,517 in construction costs, met the environmental review requirements and repay from non-Federal funds any amounts attributed to projects that cannot be certified.

Provide additional guidance to their grantees and strengthen controls to ensure that tier two environmental reviews are performed and properly conducted and signed by the responsible entity before committing program funds.

Support $401,870 for contracts that were awarded without an independent cost estimate or repay from non-Federal funds any amount that cannot be supported.

Provide additional guidance to their grantees and strengthen controls over procurement to ensure that grantees follow applicable State and Federal procurement requirements, including obtaining independent cost estimates and ensuring full and open competition.

Define which expenses should be considered program delivery costs and strengthen controls over program costs to ensure that costs are properly charged.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement a HUD-approved written plan and procedures and take actions that will correct and prevent the monitoring deficiencies in the finding, improve program administration effectiveness, and ensure compliance with HUD regulations and its own policies and procedures as required. This plan and written procedures should include controls to ensure that Northlake complies with HUD’s and its own requirements for monitoring recipients annually as well as documenting and maintaining the monitoring results. Implementing this recommendation should ensure that the $2,092,545 in HUD funds, allocated to Northlake’s four partners for program execution, is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to support $81,013 or repay its program from non-Federal funds for disbursements made without adequate supporting documentation.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement additional policies and controls and procedures, including but not limited to a disbursement file checklist, to ensure that adequate supporting documentation for disbursement is maintained in the files.