We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to review and update its internal controls throughout the grant cycle to ensure that the procurement and expenditure policies and procedures are implemented and working as designed, including the Federal prohibition of cost plus percentage of cost contracts.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to fill vacancies, ensuring that staffing levels remain adequate to administer Hurricane Harvey disaster grant funds.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to negotiate with SBA to extend its data-sharing agreements for the term of the expenditure requirements set forth in public laws or the Federal Register.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to initiate negotiations with the Texas Department of Insurance to establish data-sharing agreements for the Hurricane Harvey disaster, any open disaster recovery grants, and future disasters.

We recommend that HUD’s Acting Director for the Office of Block Grant Assistance require the Texas General Land Office to ensure that false statement and false claim warnings are included in all of its contract-related forms.

Support the $797,222 in code enforcement costs, including meeting code enforcement and salary and benefits requirements, or repay its program from non-Federal funds.

Develop and implement written policies and procedures to define deteriorated or deteriorating areas, which would apply to its CDBG-eligible target areas, and establish a written plan for using the program, in conjunction with public or private improvements, rehabilitation, or services, that may be expected to arrest the decline in CDBG-eligible target areas.

Develop and implement written procedures and controls to properly track and charge code enforcement officers’ costs among different CDBG activities and other funding sources.

Provide training to code enforcement staff on HUD CDBG regulations and requirements.

Amend its 2015 annual action plan to include the Main Street Revitalization program.

Implement controls and procedures to ensure that all future action plans include all methods of distributing grant funds or amend the plan as required if programs are added after approval.

Develop and implement a targeted code enforcement strategy that specifies deteriorating or deteriorated areas where code enforcement would be expected to arrest decline. The strategy should include a description of public or private improvements, rehabilitation, or services that would help facilitate code enforcement and also include performance metrics to track progress.

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

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

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.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to develop and implement a HUD-approved written plan and procedures and take actions that will correct and prevent the deficiencies noted in the finding, improve program administration effectiveness, strengthen the control environment, ensure compliance with HUD regulations and its own policies and procedures, and ensure that it has the continuing capacity to carry out its HOME program activities as required. Implementing this recommendation should ensure that the $216,663 in HOME funding allocated for the Parish’s property rehabilitation program is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to Repay its program from non-Federal funds for $9,849 in payments made to contractors for duplicate payments and overpayments.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support or repay its program from non-Federal funds $1,020,121 for payments made (1) for work that the contractor(s) did not perform and excessive material costs; (2) that lacked adequate supporting documentation for change orders, independent cost estimates, and invoice documentation; or (3) for the 10 HOME-funded rehabilitated homes not brought up to code.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to establish and implement desk and onsite monitoring policies and procedures to ensure that documentation is maintained to support that (1) adequate supporting documentation for payments is filed, tracked, and maintained; (2) the necessity for all change orders is verified and reasonableness of the costs is assessed; (3) cost estimates are completed before the bidding process; (4) work is completed before pay requests are approved and payments are made to the contractor; and (5) contractors are properly monitored throughout the rehabilitation process, including progress and final inspections.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to correct the property deficiencies identified during the onsite inspections related to the 20 contracts as applicable.