Provide support to show that the performance history element was factored as part of the grantees’ capacity to manage the grants awarded through the 2025 NOFO.

Recapture $3,775,916 in undisbursed grant funds not used to meet agreed-upon performance benchmarks for the two identified ‘High Risk’ grantees whose period of performance ended in June and July 2025, respectively. In addition, identify those grantees that received 2020 through 2022 LBPHC and LHRD grants with a period of performance that ended on or before December 31, 2025, to determine whether agreed-upon performance benchmarks were met by that date, and take appropriate actions that include recapturing undisbursed grant funds.

Update HUD regulations, policies, and procedures following the regulatory process required by the amended Lead Safe Housing Rule, in consideration of CDC's lowered BLRV of 3.5 ug/dL.

Provide the MOU with EPA designed to address radon contamination.

Support that healthy homes assessment and data collection services were cost reasonable or reimburse its Program $361,850 from non-Federal funds.

Support that landlords gave preference in renting eight vacant units to families with children under 6 years of age or reimburse its Program $112,917 from non-Federal funds for the lead-based paint hazard control activities completed at these assisted units.

Support that lead-based paint hazard control activities were necessary at 19 assisted units or reimburse its Program $70,266 from non-Federal funds for the unsupported lead-based paint hazard control activities completed at these assisted units

Coordinate with HUD’s Office of Lead Hazard Control and Healthy Homes to determine whether $51,930 in healthy homes supplemental funds used for four units in excess of $5,000 per unit was for eligible activities. If the activities are deemed ineligible, the Department should reimburse its Program the appropriate amount from non-Federal funds.

Support that one household residing in an assisted unit was income eligible or reimburse its Program $19,500 from non-Federal funds for the lead-based paint hazard control activities completed in the assisted unit.

Implement adequate procedures and controls to ensure that (1) documentation is maintained to support that contracted services are cost reasonable, (2) landlords give preference in renting assisted vacant units to families with children under 6 years of age, (3) lead inspection documentation properly supports lead-based paint hazard control activities, (4) HUD approval is obtained when more than $5,000 per unit in healthy homes supplemental funds is budgeted to assist units, and (5) its staff is fully knowledgeable of the Program requirements.

Review the one identified retained inactive obligation with a remaining balance totaling $60,395 and deobligate amounts that are no longer valid or needed.

Support that grant administration services paid were cost reasonable or reimburse its Program $387,443 from non-Federal funds.

Reimburse its Program $102,069 from non-Federal funds for the duplicate payments made to its subcontractor for lead-based paint and other health hazard control activities.

Coordinate with HUD’s Office of Lead Hazard Control and Healthy Homes to determine whether $88,258 in Program funds ($77,597 $10,661) may be drawn down and used to reimburse its subcontractor if the lead-based paint and other health hazard control activities are determined to be eligible.

Determine whether the subcontractor is owed payment for 21 units, which the Department’s records showed were assisted under the Program but were not identified as assisted units according to documentation maintained by the Department to support its drawdowns from HUD’s LOCCS. If the Department determines that the subcontractor is owed payment for the lead-based paint and other health hazard control activities, it should provide support that the lead-based paint and other health hazard control activities were eligible and that the subcontractor was not reimbursed for these activities from non-Program funds. If these conditions have been met, the Department should reimburse the subcontractor from Program funds.

Determine whether appropriate reimbursements were made to the subcontractor for the remaining 166 assisted units that were not a part of our review. If the Department determines that appropriate reimbursements were not made, it should provide support that the lead-based paint and other health hazard control activities are Program eligible and the subcontractor was not reimbursed for these activities from non-Program funds. If these conditions have been met, the Department should reimburse the subcontractor from Program funds.

Support that the four households residing in assisted units were income eligible or reimburse its Program $59,883 from non-Federal funds for the lead-based paint and other health hazard control activities completed in the assisted units.

Support that landlords gave preference in renting six vacant units to families with children under 6 years of age or reimburse its Program $41,240 from non-Federal funds for the lead-based paint and other health hazard control activities completed at these assisted units.

Support that lead-based paint hazard control activities were necessary at 13 assisted units or reimburse its Program $23,857 from non-Federal funds for the unsupported lead-based paint hazard control activities completed at these assisted units.

Reimburse its Program $2,900 from non-Federal funds for the two units in which the seven windows were not installed.