Develop a retention strategy for its subrecipients to ensure that documentation is readily available for review.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $11,463,971 in 189 program obligations and $13,640 in 10 administrative obligations marked for deobligation as of September 30, 2017.

Review the 1,110 identified inactive retained obligations with remaining balances totaling $229,327,332 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

Close out and deobligate the remaining balances on 2,741 expired homeless assistance contracts of $159,437,069.

The County does not reimburse itself with program funds for the $452,444 in County bond proceeds originally budgeted for the Armstrong Park project and used to pay for flood protection improvements in the Graue Mill subdivision in Hinsdale.

The $7,677 ($460,121 - $452,444) in remaining County bond proceeds originally budgeted for the Armstrong Park project are used for eligible program activities.

Deobligate the $109,270 in program funds obligated for ineligible activities in its construction contracts for the West Branch DuPage River Flood Control and Springbrook Culvert projects.

Support or reimburse its program from non-Federal funds $98,507 for the program funds used for project management services without sufficient documentation to support that the use of the funds was reasonable.

Improve its procedures and controls to ensure that the County administers the program in accordance with Federal requirements.

Recalculate the commitment requirement as a result of the City improperly committing HOME funds for activities 5455, 5456, 5058, 5059, 5173, 5174, and 4652 and determine the cumulative effect on the City’s overall commitment requirement. Any overpayments should be recaptured or reduced in the HOME Investment Trust Fund account.

Require the City to establish and implement controls and procedures to ensure compliance with requirements for commitments entered into HUD’s information system. This includes but is not limited to controls and procedures to ensure that valid commitment entries and all HOME contracts and agreements are properly executed.

We recommend that the Deputy Assistant Secretary for Grant Programs issue guidance reminding grantees of the requirement to properly report the addresses of assisted properties in IDIS and properly calculate and report program income from the disposition of these properties.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Newark, NJ, field office to require Jersey City to provide documentation to show that a notice was provided to affected citizens as required or take action to advise affected citizens that they disposed of the property.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Los Angeles, CA, field office to require the County of Los Angeles to reclassify program income to the activity ID in IDIS that generated the income, ensuring that the $300,330 in program income is properly accounted for.

We recommend that the Deputy Assistant Secretary for Grant Programs instruct the Milwaukee, WI, field office to document that no portion of the four State of Wisconsin’s activities reviewed is currently subject to the change of use requirements or remind the State of Wisconsin that the portions of the activities related to the voluntary grant reductions are still subject to the change of use requirements.

Support or reimburse its ESG program participants $705 from non-Federal funds for the inadequately supported pay request.

Support or reimburse HUD $13,058 from non-Federal funds for the drawdowns after program grant expiration.

Implement adequate policies and procedures to ensure that payments to subrecipients are issued in accordance with HUD’s requirements.

Provide adequate training to staff associated with the administration of the ESG program to ensure compliance with HUD’s requirements, including timely drawdowns.

Implement adequate policies and procedures for conducting complete and consistent monitoring of subrecipients’ matching requirements, including confirming eligibility and existence of matching funds to ensure compliance with HUD’s requirements.