Develop and implement additional procedures and controls to ensure that City employees properly calculate administrative fees for portability HAP related to the Authority.

Update its intergovernmental agreements for supplemental law enforcement services to include the current HUD requirements at 2 CFR Part 200 to comply with its procurement bulletin and HUD Notice SD-2015-01. By doing so, the Authority will ensure that current and future intergovernmental agreements include the current HUD requirements and focus Federal resources toward improving program performance and outcomes.

Issue guidance to PHAs to ensure any applicant for or tenant of public or assisted housing whose name appears on the SAM excluded parties list are reviewed by PHAs to determine eligibility in a manner consistent with the regulations in 2 CFR 180 and 2424 so that ineligible applicants or tenants are not admitted or recertified to put up to $13.7 million to better use.

Take corrective actions for the 729 tenants reported as deceased to put $6.1 million to better use.

Establish a method to provide information in the Do Not Pay system to PHAs and require its use.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to support or repay its HUD program accounts from non-Federal funds $97,170 paid for unsupported legal services, of which $29,111 was paid with Housing Choice Voucher Program funds and $68,059 was paid with operating funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to support or repay its HUD program accounts from non-Federal funds $21,000 paid for unreasonable and unnecessary retainer fees for those months when the Authority did not hold a regular meeting, of which $7,112 was paid with Housing Choice Voucher Program funds and $13,888 was paid with operating funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to revise its procurement policies to include, either in their entirety or by reference, the current Federal cost principles.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to provide training to commissioners and employees on Federal procurement and cost principles requirements and have them certify that they understand and will comply with the requirements.

Repay to the public housing program from non-Federal funds the $32,620 in ineligible housing assistance it received from HUD.

Repay to the Treasury from non-Federal funds the $3,402 in ineligible administrative fees it received from HUD.

Establish effective procedures and controls to verify that it receives correct products from its vendors and ensures the proper completion of renovation work by its contractors.

Repay from non-Federal sources the $1,864,914 in ineligible costs related to environmental deficiencies

Repay from non-Federal sources the $85,204 in ineligible costs related to payments made beyond the contract terms.

Support that the $101,052 spent for one activity followed Federal environmental review requirements or repay this amount from non-Federal funds.

Support that the $1,325,967 spent for activities was fair and reasonable in accordance with Federal procurement requirements or repay from non-Federal funds any amounts that cannot be supported

Deobligate $113,710 in funds not yet spent on ineligible activities with environmental review deficiencies and work with HUD to determine whether these funds can be reobligated to eligible activities.

Deobligate $11,781 in funds not yet spent on ineligible activities related to activities that exceeded contract terms and work with HUD to determine whether these funds can be reobligated to eligible activities

Develop and implement adequate policies and procedures to address the environmental deficiencies identified.

Strengthen their policies and procedures to address the procurement and contract administration deficiencies identified.