We recommend that the Office of Multifamily Housing Programs develop contingency policies and procedures to ensure that the properties it subsidizes receive adequate and verifiable continuous monitoring.

Develop and implement a HUD-approved cost allocation plan(s) that appropriately represents the benefit received by the Authority from the City’s HHS department and allocates overhead and operating costs to all programs managed by the Authority.

Support the eligibility of the $1,965,990 in overhead allocations through the application of a HUD-approved allocation plan (including offsetting the amount by applicable reimbursements) or repay the Housing Choice Voucher Program from non-Federal funds.

Determine the appropriate amount of general operating costs totaling $2,544,266 that applied to the Housing Choice Voucher Program in accordance with a HUD-approved cost allocation plan (including offsetting the amount by applicable reimbursements) and repay overcharges (estimated at $50,947) to the Program from the other applicable programs as appropriate or from non-Federal funds.

Support the eligibility of the $25,827 in personnel expenses from SPC (including offsetting the amount by applicable reimbursements) or repay its Housing Choice Voucher Program from the other applicable programs as appropriate or from non-Federal funds.

Support the eligibility of the $64,150 for accounting services charged to the Housing Choice Voucher Program that applied to other Authority programs (including offsetting the amount by applicable reimbursements) or repay the Program from the other applicable programs as appropriate or from non-Federal funds.

Support the reasonableness of the $340,701 Casterline contracts or repay the Housing Choice Voucher Program any amount that cannot be supported using non-Federal funds.

Support the reasonableness of the $33,415 Genesis contract or repay any amount that cannot be supported from non-Federal funds.

Establish and implement additional procedures and controls to ensure that City personnel responsible for administering procurement on the Authority’s behalf follow procurement and contracting requirements and maintain applicable supporting documentation in accordance with HUD requirements.

Repay the Housing Choice Voucher Program $5,648 from non-Federal funds for the unallowable expenses.

Develop and implement procedures and controls to ensure that ineligible food costs are not charged to the Program.

Develop adequate procedures outlining steps for tracking monthly grant expenditures, reprogramming funds for stalled activities, managing program income, and allocating costs as required by Federal Register Notice 83 FR 5844 and the grant agreement with HUD.

Ensure that the financial management system for the 2017 CDBG-DR grant is capable of providing information by activity type and grant number.

Develop and implement a financial management system for its 2008 CDBG-DR grant and ensure that it tracks program funds to a level that supports compliance with HUD requirements. At a minimum, the accounting system must reflect disbursements by grant, activity, and activity type and properly account for assets, liabilities, and program income.

Review and update its 2017 CDBG-DR policies and procedures to prevent duplication of benefits and ensure that these are comprehensive and all applicable activities are included, including but not limited to the Small Business Financing Program and the Construction and Commercial Revolving Loan program.

Negotiate with the SBA, within 30 days of the issuance of this audit report, to extend its data-sharing agreements for the term of the expenditure requirements set forth in public laws or the Federal Register in relation to the 2017 and 2008 disasters.

Negotiate with Puerto Rico’s Insurance Commissioner and with other CDBG-DR grantees, within 30 days of the issuance of this audit report, to establish data-sharing agreements for the 2017 CDBG-DR grant disaster, any open disaster recovery grants, and future disasters.

Complete, within 30 days of the issuance of this audit report, the review for preventing duplication of benefits associated with its 2008 CDBG-DR grant and pursue appropriate remedies for any instances of noncompliance found.

Review and update its procurement policy for the 2017 CDBG-DR grant to address weaknesses identified, including but not limited to required contract clauses, processes for soliciting and accepting noncompetitive proposals, and performing cost or price analyses before receiving bids or quotations, among other issues.

Ensure that the 2017 CDBG-DR procurement policy addresses the establishment of a contract register that, at a minimum, contains the procurement information specified in section 3.8 of HUD’s Buying Right Guide regarding the PRDOH’s acquisitions of goods and services, as well as of its subrecipients and partners.