Flag all principals of the borrowers with unreimbursed and unauthorized distributions in the Active Partners Performance System (APPS) to ensure that HUD appropriately evaluates the risks associated with doing business with these principals.

Require PRDOH to submit supporting documentation so HUD can evaluate the basis of the contract amendments and determine the eligibility of more than $31 million in disaster recovery funds. If HUD determines that the contract amendments were not supported, PRDOH must reimburse HUD from non-Federal funds.

Instruct PRDOH to remediate all outside installations that are directly exposed to sunlight and the elements or repay HUD $19,185,244 from non-Federal funds.

Require PRDOH to implement a review process to better structure its future contracts to ensure that the scope of work is clearly defined so that all parties understand the agreement. This includes, but is not limited to, ensuring that the basic subtasks needed to complete projects are considered and included only as necessary in future contracts.

Work with borrowers and lenders to develop a plan to address the issues for each of the 58 defaulted loans within a reasonable time frame and implement corrective actions for the 58 loans; thereby protecting HUD’s investment of $329,541,272.

Instruct PRDOH to re-evaluate its use of the IRS Form 1040 AGI calculation methodology to assess participants’ income compared to the income calculation methodology defined under Section 8 program at 24 CFR § 5.609 and determine whether it ensures consistent eligibility determination for the program.

Require grantees to include in their DRGR system’s reports their non-Federal match costs in a manner that documents that they have met FEMA’s set match percentage requirements and issue a template to grantees to ensure consistency of reporting in their systems of records.

Instruct PRDOH to enforce its contract terms and conditions, which requires installers to install batteries and inverters outside of direct sunlight and exposure to the elements.

Instruct PRDOH to address and correct all the deficiencies noted for the properties inspected.

We recommend that the Deputy Assistant Secretary for Operations of Community Planning and Development enhance CPDs existing Grant Accrual Standard Operating Procedures to strengthen governance within CPD and to effectively work within the framework established by the OCFO in recommendation 1A. The updated procedures should include increased ownership and oversight over the reviews, authorizations, approvals, and changes to the CPD grant…

Implement procedures and controls regarding its quality control inspections to ensure that the results of those inspections are appropriately used to evaluate and monitor the performance of the Authority’s contracted inspectors and documentation is maintained on communications with the contractor on corrective actions taken to address recurring inspection deficiencies.

Implement procedures and controls regarding its stop payment process to ensure that it consistently (1) stops payments as required by its HCV Program administrative plan and HUD requirements, (2) verifies and documents the correction of deficiencies, and (3) maintains sufficient documentation to support the stop payment for each unit.

Provide evidence that the owners corrected the 248 deficiencies for the 48 units with outstanding deficiencies. If the owners fail to make corrections, the Authority should implement its stop payment procedures and provide supporting documentation to HUD.

Work with its contractor to ensure that the contractor’s inspectors receive training on how to properly identify and categorize life-threatening deficiencies.

Establish internal and financial controls to ensure that it allocates, tracks, and reports future non-Federal match costs separately from other disaster recovery costs within the DRGR system for future disasters, which will ensure that at least $1.3 million is correctly reported as other disaster recovery costs rather than as costs that Colorado is using to meet its non-Federal match requirements.

Provide documentary support in the DRGR system that it met and did not exceed the match percentage set by FEMA for its completed Public Assistance activities

Work with HUD’s Office of Lead Hazard Control and Healthy Homes to assess whether the lead-based paint inspections and risk assessments with missing elements are sufficient to support the lead-based paint status of the Authority’s properties. If it is determined that the lead-based paint and risk assessment reports are not sufficient, HUD should require the Authority to perform new assessments.

Implement controls over its inspection processes and procedures to ensure that emergency failures are properly identified, reinspected, and corrected within 24 hours in accordance with its HCV Program administrative plan or the housing assistance to the owner is stopped.

HUD OCIO should a) resolve the conflicts between its Inventory of Automated Systems (IAS) policy and web applications policy to clarify if web applications will be inventories in IAS, the web application Sharepoint site, or both; and b) implement the chosen resolution to this conflict to develop a consistent inventory of web applications (IG FISMA metric 1).

Implement policies and procedures that align with HUD’s requirements and controls to ensure that reevaluations are completed when required.