Develop and implement adequate environmental policies and procedures to ensure that environmental reviews are properly documented and supported and that HUD and Federal environmental requirements have been followed before committing HOME funds to an activity.

Develop and implement adequate policies and procedures to ensure that fixed HOME units are identified and adequate documentation is maintained to support tenant eligibility and compliance with HOME rental limits for the entire affordability period.

Develop and implement tools to improve record-keeping practices to support the eligibility, necessity, and reasonableness of the HOME activities.

Provide technical assistance to the City to ensure that responsible staff receives necessary environmental, underwriting, and overall program administration training.

Repay from non-Federal sources the $1,864,914 in ineligible costs related to environmental deficiencies

Repay from non-Federal sources the $85,204 in ineligible costs related to payments made beyond the contract terms.

Support that the $101,052 spent for one activity followed Federal environmental review requirements or repay this amount from non-Federal funds.

Support that the $1,325,967 spent for activities was fair and reasonable in accordance with Federal procurement requirements or repay from non-Federal funds any amounts that cannot be supported

Deobligate $113,710 in funds not yet spent on ineligible activities with environmental review deficiencies and work with HUD to determine whether these funds can be reobligated to eligible activities.

Deobligate $11,781 in funds not yet spent on ineligible activities related to activities that exceeded contract terms and work with HUD to determine whether these funds can be reobligated to eligible activities

Develop and implement adequate policies and procedures to address the environmental deficiencies identified.

Strengthen their policies and procedures to address the procurement and contract administration deficiencies identified.

Strengthen their procedures to obligate capital funds in a timely manner.

Provide technical assistance to Authority officials to ensure that responsible staff receives necessary procurement and environmental review training.

Repay to the public housing program from non-Federal funds the $32,620 in ineligible housing assistance it received from HUD.

Repay to the Treasury from non-Federal funds the $3,402 in ineligible administrative fees it received from HUD.

Establish effective procedures and controls to verify that it receives correct products from its vendors and ensures the proper completion of renovation work by its contractors.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to support or repay its HUD program accounts from non-Federal funds $97,170 paid for unsupported legal services, of which $29,111 was paid with Housing Choice Voucher Program funds and $68,059 was paid with operating funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to support or repay its HUD program accounts from non-Federal funds $21,000 paid for unreasonable and unnecessary retainer fees for those months when the Authority did not hold a regular meeting, of which $7,112 was paid with Housing Choice Voucher Program funds and $13,888 was paid with operating funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to revise its procurement policies to include, either in their entirety or by reference, the current Federal cost principles.