Revise its written policies and procedures to ensure that it administers its participant repayment agreements in compliance with requirements.

Ensure that it executes form HUD-52675 with all program participants and adult household members.

Develop written policies and procedures, to include HUD’s requirements to (1) properly report participant data in the PIC system, (2) report repayments and debts owed in the EIV system, and (3) monitor EIV reports.

Compare current participant and financial data to the EIV and PIC system data to ensure that all participant data were accurately submitted and reported.

Revise its administrative plan to ensure that it accurately reflects current HUD requirements and the Authority’s current policies and procedures.

Provide training to its staff to ensure that it is familiar with all HUD documentation and reporting requirements.

Develop and implement adequate controls over payments for services that are part of the management fee.

Amend and resubmit the management agreements and the management certifications for HUD approval and ensure that the agreements do not conflict with the management certifications.

Identify all unallowable fees and reimburse from non-project funds.

Pay the project $282,578 from non-project funds for the fair value of the commercial rent not collected from the lessees.

Request approval from HUD to lease the commercial space. If HUD approves the request, then execute a lease at fair market rent thereby increasing the project’s rent revenue by at least $36,858 per year.

Request approval from HUD for the $31,769 in project operating funds spent on building improvements or repay the project from nonproject funds for any amount not approved.

Provide documentation to show that the $39,920 paid to replace an air conditioning system was fair and reasonable or repay the project from nonproject funds any amount determined not to be fair and reasonable (excluding any amount repaid as a result of recommendation 1C).

Remove the $25,000 lien on the project property.

Repay the project $8,597 from nonproject funds for the ineligible expenses it incurred for management fee and gas utility expenses that were identified by the audit and any additional management fee and gas utility expenses improperly paid outside of our review period.

Develop and implement controls to ensure that financial statements are submitted to HUD in a timely manner, including paying the correct amount of annual payments according to the terms of the mortgage.

Develop and implement controls to ensure that the project complies with applicable HUD requirements.

Recalculate the project’s annual surplus cash balances for 2013, 2014, and 2015 after resolution of recommendations 1A, 1C, 1D, and 1F to determine whether the project should make additional payment to HUD from surplus cash toward its mortgage beyond the $13,740 that it paid during the audit.

Provide training and technical assistance to the owner and its management agent to ensure compliance with the terms of its mortgage and other applicable HUD requirements.

We recommend that the Acting Director of HUD’s Newark Office of Public Housing instruct Authority officials to provide supporting documentation to justify the $88,534 in unsupported travel and training costs related to out-of-State trainings, meetings, and conferences. Any amount determined to be ineligible should be repaid from non-Federal funds to the Operating Fund.