Establish and implement policies and procedures to ensure that all of its unclaimed funds are claimed and the money is appropriately routed to put $2.2 million to better use. At a minimum, these policies and procedures should address what constitutes FHA and Ginnie Mae funds, ensure that these funds are returned to FHA or Ginnie Mae as appropriate, and include policies to claim co-owned funds with any appropriate thresholds or limitations.

We recommend that the Chief Financial Officer determine whether the summary expenditures totaling $160,360,714, which exceeded the grant round obligations for the two grantees, were ADA violations. If the transactions were violations, action should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed detail transactions totaling to $435,263,268, which occurred before and after grant rounds obligation and expenditure dates, were ADA violations. If the transactions were violations, actions should be taken as required by the ADA.

We recommend that the Chief Financial Officer determine whether the revised and completed transactions totaling $496,913,235 and made more than a year after the original voucher entry were GAAP violations. If the transactions were violations, appropriate actions should be taken, including but not limited to adjusting the transactions in LOCCS and HUD’s financial statements.

We recommend that the Chief Financial Officer enter a 24-month expiration term into LOCCS for Disaster Recovery funding provided by the 2017 Act and monitor to ensure that expenses are not entered before or after the grant period.

We recommend that the Chief Financial Officer require CPD to enter into a separate grant agreement for each grantee’s round of disaster funding for funding provided by the 2017 and 2018 Acts.

We recommend that the Chief Financial Officer require CPD to monitor the detailed voucher transactions in the DRGR system to ensure that grantees appropriately record transactions.

We recommend that the Chief Financial Officer require CPD to prohibit grantees from revising completed vouchers in the DRGR system and require adjustments to be entered as new vouchers into the DRGR system, which will ensure that LOCCS records and tracks revisions.

Repay the U.S. Treasury $19,173 spent on ineligible assistance from non-Federal funds.

Complete a cost breakdown to support the $10,731 spent on a rental property, which included assistance to an ineligible unit, and repay the ineligible assistance to the U.S. Treasury from non-Federal funds.

Recalculate annual income for participants assisted with the 2014 lead hazard control grant to support the $1,803,705 spent. For any assistance the Health Department cannot support with complete income calculations, it should repay the U.S. Treasury from non-Federal funds, less any amount repaid as a result of recommendations 1B and 2A.

Develop and implement policies and procedures that clarify the definition of annual income to be used, calculation components, and the documentation required to calculate income.

Develop and implement procedures for quality control reviews to ensure that annual income is properly calculated.

Provide training on HUD’s income requirements to employees responsible for calculating income.

Provide support showing the $79,738 spent on window replacement qualified or repay the U.S. Treasury from non-Federal funds.

Develop and implement policies and procedures to ensure that all windows replaced meet lead hazard qualifications.

Develop and implement quality control procedures to ensure that all bid specifications are reviewed for qualified items based on the risk assessment results.

Update the Health Department’s work plan to include policies and procedures for defining, determining, and documenting relocation hardship for all participants.

Develop and implement policies and procedures to ensure that the property owners receive the required information concerning lead-based paint disclosure requirements, risk assessment results, summaries of treatments and clearances, and ongoing maintenance activities, including how to report paint deterioration.

Implement a repeatable and sustainable process to prepare timely and accurate quarterly financial statement notes, including third and fourth quarter notes within the OMB required timeframe.