Provide adequate documentation to support the $21,373,462 in unreasonable and unnecessary obligated funds.

Strengthen and implement acquisition controls to ensure that proper cost and price documentation is obtained, adequate monitoring is conducted, adequate market research is conducted and that contractors are evaluated to assess their capability to perform work, and required contract documentation is maintained in the file to ensure that $9,645,864 that is yet to be used will not be spent for unreasonable and unnecessary costs.

Seek reimbursement for $161,718 in ineligible funds disbursed for equipment and support services not specified in a scanning services contract.

Provide documentation to show that prices paid for products and services totaling $1,423,262 for three activities were fair and reasonable or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $942,636 for activity 7099 were for employees’ actual time spent benefiting the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $100,000 for activity 6865 benefited the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that seven activities with costs totaling $2,266,543 were exempt or categorically excluded from environmental reviews or repay its program from non-Federal funds for any amount that it cannot support (excluding any amount repaid as a result of recommendations 1A, 1B, and 1C).

Revise its policies and procedures to address compliance with applicable procurement regulations requiring independent cost estimates before receiving bids or proposals.

Train its staff on requirements for documenting costs funded by multiple funding sources.

Develop and implement controls to ensure that subrecipients comply with requirements for documenting costs funded by multiple funding sources.

Determine whether it has complied with environmental review requirements for all activities since October 2010 and provide a copy of its determination to HUD. If it did not comply, either provide the necessary support for the activities or repay its program from non-Federal funds for any activity costs it cannot support.

Develop and implement controls to ensure that it complies with environmental review requirements.

Review accomplishment data that it reported in IDIS for open and completed activities to ensure that accomplishments were reported accurately.

Train its staff on reporting accomplishments in IDIS and develop and implement policies and procedures for supervisory review to ensure accuracy.

Include compliance with environmental review requirements in its project-specific reviews in its next periodic monitoring of the City’s Block Grant program.

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.