Instruct the State to update and implement the CDBG-DR standard operating procedures, which clearly outline what activities, including the frequency, will be reviewed by its monitoring and internal audit function.

Instruct the State to conduct monitoring reviews of its CDBG-DR HIM activities and subrecipients that satisfy monitoring requirements.

Work with the State to develop and implement policies and procedures to ensure that monitoring is conducted remotely in the event that it cannot be conducted onsite.

Instruct the State to update and implement policies and procedures to ensure that the results of the CDBG-DR internal audits are shared by the State’s Commissioner with CDBG-DR program staff to allow for the resolution of any findings and required corrective actions.

Monitor the State’s CDBG-DR program to ensure that performance expectations are achieved.

Complete and update the system security plans for GMP and DRGR and issue an SSN justification memorandum.

Identify and provide additional role-based training, guidance, and instructions to CPD employees on how to appropriately handle and safeguard PII encountered during monitoring.

Reinforce the use and admissibility of photographs and videos for evidence collection while remote monitoring.

Identify strategic opportunities to use remote monitoring early in the FY to maximize its responsibility to oversee and monitor its grantees and then use remote monitoring when those opportunities arise.

We recommend that the Director of CPD’s Office of Disaster Recovery review the one grantee with a grant totaling $666,666 that did not meet the overall LMI requirement and address the noncompliance.

We recommend that the Director of CPD’s Office of Disaster Recovery update DRGR’s QPR to include information on the progress towards compliance with the overall LMI benefit based on the total amount of the grant.

We recommend that the Director of CPD’s Office of Disaster Recovery adopt LMI benchmarking to ensure that grantees budget adequate funds to LMI at significant milestones in the grant lifecycle.

We recommend that the Director of CPD’s Office of Disaster Recovery make changes to the action plan process so that the action plan calculates an overall LMI percentage.

Develop and document internal procedures to ensure that they will address the Program Office’s responsibilities within the departmental grant accrual validation policy.

Re-evaluate and adequately document justification for the establishment of the percentages and other key assumptions used to determine the accrual amount for each program in CPD’s accrued grant liabilities estimate.

Provide more detailed guidance to HUD reviewers on benchmarks for each performance standard.

Update the PAR template to ensure that HUD reviewers include required information.

Assess HUD reviewers’ skills and readiness to determine the appropriate frequency of training.

Provide more detailed guidance to HUD reviewers and FHEO regional directors on when and under what circumstances to recommend or issue a PIP.

Update HUD Handbook 8024.01, REV-2, and regional intake policies and procedures as necessary to include (1) minimum requirements that all regions follow for documenting in HEMS attempts to reach out to claimants when additional information is needed before closing inquiries; (2) policies and procedures for collecting, recording, and documenting all relevant electronic intake information in HEMS; and (3) clarifying that communications with claimants regarding inquiry closure, requests for additional information, and notices of jurisdiction information clearly inform the claimant of the ability to provide additional information within the statute of limitations.