Immediately conduct an internal audit of the CDBG-DR grant funds.

Update, finalize, and implement its procurement policies to comply with 2 CFR 200.317-326.

Adequately support or reimburse its HOPWA program $31,157 from non-Federal funds for the inappropriate disbursements.

Reimburse its HOPWA program $14,017 from non-Federal funds for the inappropriate disbursements.

Provide adequate training to staff responsible for reviewing and approving the expenditures to ensure compliance with HUD’s and Louisville Metro’s requirements for the administration of the HOPWA program, including processing program disbursements and monitoring project sponsors’ cash management.

Implement adequate procedures for sufficiently monitoring its project sponsors’ cash management.

Reimburse the program $70,992 ($63,312 $7,680) from non-Federal funds for housing assistance payments made and administrative fees received for the units that materially failed to meet HUD’s housing quality standards.

Certify, along with the owners of the 103 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Develop and implement adequate policies and procedures for conducting quality control inspections in accordance with HUD’s requirements.

Develop and implement adequate procedures and controls to ensure that its quality control inspection program functions properly to include adequately monitoring the inspection contractor to prevent $20,566,345 in program funds from being spent over the next year on units that do not materially comply with requirements.

Reimburse the program $2,492 ($2,286 in housing assistance payments and $206 in administrative fees received) from non-Federal funds for rental subsidies not abated on four units.

Complete a review of rental subsidy abatements for all current units for which a retroactive abatement was not conducted. The Authority should reimburse the program from non-Federal funds for any overpaid rental subsidy.

Develop and implement written procedures and a process for retroactively abating housing assistance payments.

Complete a rent reasonableness determination for all current units for which a determination was required but not completed. The Authority should reimburse the program from non-Federal funds for any overpaid rental subsidy.

Develop and implement written procedures to ensure that a rent reasonableness determination is performed before rent increases are approved.

Complete a review that owners of current assisted units are not debarred, suspended, or subject to a limited denial of participation.

Develop and implement written procedures for conducting a complete owner eligibility determination.

Provide adequate training to its staff to ensure compliance with HUD’s requirements for program units.

Support the eligibility of $6,529,500 in code enforcement costs, including meeting code enforcement requirements, preparing time distribution reports, and supporting vehicle costs, or repay the program from non-Federal funds (appendix D).

Suspend funding to its code enforcement program until it can show that it has implemented controls, addressed its capacity issues, and understands and abides by HUD requirements.