Refer regulatory agreement violations to the Departmental Enforcement Center within 30 days of HUD having identified it and work with the Departmental Enforcement Center to develop a plan for resolving the violation. Any revisions to the plan must be accepted by the Departmental Enforcement Center.

Review and revise the policies and procedures for making partial payments of claims to check that each decision to make a partial payment of claim ensures that the payment restores the subject nursing home to financial viability to avoid a repeat of the situation that led to the loss on Hebrew Home.

Require Jamaica Hospital Nursing Home to provide support for $8,974,000 paid to its related company. Any amount that the owner cannot support as reasonable in price and necessary to the nursing home should be repaid to the nursing home.

Require Jamaica Hospital Nursing Home to provide support for $44,483,000 in accounts payable. Any amount that the owner cannot support as reasonable in price and necessary to the nursing home should be removed from the accounts payable

Require the owners of Bishop Wicke Health and Rehabilitation Center, Plaza Village Senior Living, Golden Hill Health Care Center, Immanuel Campus of Care, and their related companies to reimburse the nursing homes for the ineligible expenses of $7,027,289.

Require Shawnee Christian Nursing Center to return 27 beds to operation or pay down the mortgage by $815,973

Define the troubled and potentially troubled classifications for nursing homes and develop specific measures to identify when and how nursing homes are classified.

Develop and implement policies and procedures to revisit the classifications at least annually.

Develop and implement computerized controls to flag blank data fields and illogical financial data.

Develop and implement procedures to require owners, operators, and lenders to submit accurate and complete financial data.

We recommend that the Director of HUD’s Detroit Office of Public Housing require the Commission to reimburse its operating fund $107,692 from non-Federal funds for ineligible payments cited in this finding.

Determine the eligibility of the $2,399,428 disbursed for four projects with signs of slow progress and reevaluate the feasibility of the activities. Total disbursements of $3,483,086 were adjusted to consider $713,008 questioned in recommendation 2C and $370,650 in recommendation 2A. The Municipality must reimburse its HOME program from non-Federal funds for activities that HUD determines to have been terminated.

Require the Municipality to reimburse its HOME program from non-Federal funds $766,480 for disbursements associated with terminated activities that did not meet HOME objectives.

Require the Municipality to submit supporting documentation showing the allocability of $39,338 and any additional payroll costs charged to the HOME program between July 1, 2009, and June 30, 2011, associated with the three employees performing other functions not related to the program, or reimburse the program from non-Federal funds.

Require the Municipality to reimburse the HOME program from non-Federal funds $2,263,799 paid for ineligible costs.

Require the Municipality to put to better use $2,854,395 associated with unexpended funds maintained in its local bank account.

Require the Municipality to update its accounting records and ensure that receipts and expenditures are properly accounted for, are reconciled with HUD’s information system, and comply with HUD requirements.

Require the Municipality to develop and implement a financial management system in accordance with HUD requirements, including that HOME funds can be traced to a level which ensures that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes and that funds are disbursed in a timely manner.

We recommend that the Director of HUD’s New York City Office of Community Planning and Development instruct City officials to reimburse from non-Federal funds $93,436 for ineligible costs charged to HPRP; specifically, $59,430 related to payments for rental arrears over the 6-month eligibility requirement and $34,006 for payments issued directly to participants.

We recommend that the Director of HUD’s New York City Office of Community Planning and Development instruct City officials to provide documentation to justify the $329,937 in unsupported salary costs incurred between June and September 2010. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.