Develop and implement controls to ensure that administrative fees are used to perform administrative duties for the program.

Provide training to its inspector on conducting housing quality standards inspections.

Submit a request for approval of an independent entity to perform rent reasonableness determinations for program units that it substantially controls.

Reimburse its program $279 from non-Federal funds for the ineligible payment it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to prevent and detect conflict-of-interest situations.

Develop and implement controls to ensure that the independent entity approved in recommendation 1J performs rent reasonableness determinations for program units that it substantially controls.

Develop and implement controls to ensure that an independent entity performs housing quality standards inspections of units that it substantially controls.

Certify, along with the owners of the 10 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Develop and implement a cost allocation plan to use as a basis for charging indirect payroll expenses to the program.

Provide documentation to show that indirect payroll expenses totaling $225,182 charged to the program were reasonable and necessary or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that administrative fees totaling $47,376 were used to perform administrative duties for the program or repay its program from non-Federal funds for any amount that it cannot support.

Reopen recommendation 2016-FO-0003-002-B, “Work with the Office of Native American Programs to calculate the amounts advanced to grantees and restate HUD’s financial statements to recognize the prepayments on the financial statements.”

Develop standard operating procedures for implementing accounting changes, including steps to assess the appropriate impact on each treasury account symbol.

Reopen recommendation 2016-FO-0003-002-A, “Evaluate the IHBG investment process and implement a proper accounting treatment in accordance with Federal GAAP.”

Ensure that the budget execution procedures executed internally by OCFO Budget are consistent with those established by ARC.

Ensure that PIH’s automation of its cash management process complies with Federal financial management requirements.

Review the cash management process to identify all financial events to be recognized in accordance with GAAP. Establish procedures to account for the cash management activity in a timely manner in compliance with GAAP.

Implement a cost-effective method for automating the cash management process to include an electronic interface of transactions to the standard general ledger.

Develop and implement procedures to ensure that the methodology is reevaluated by PIH and OCFO annually and any changes do not compromise (1) the audit trial, (2) compliance with GAAP, or (3) the accuracy of the balance.

Reopen recommendation 2016-FO-0003-002-D, “Develop a tracking function for the payments advanced to IHBG recipients to facilitate financial reporting and monitoring compliance with grant time restrictions.”