Develop and implement procurement policies and procedures that comply with Federal, State, and local laws.

Develop and implement controls to ensure that contracts are in place when applicable.

Develop and enforce written conflict-of-interest requirements in compliance with Federal rules and regulations.

Develop and maintain a contract management system, including a contract register for all procurements.

Evaluate the training of West Warwick’s board of commissioners and determine whether additional training is required or other changes are appropriate.

.Develop and implement written policies and procedures to ensure that each Housing Choice Voucher program tenant file has an appropriately documented rent reasonableness determination.

Develop and implement written policies and procedures to ensure that each public housing unit has an annual inspection, which is appropriately documented in the tenant file.

Determine whether tenants were underpaid for utility allowances and if so, reimburse the tenants from non-Federal funds.

Evaluate the training of West Warwick employees and determine what additional training is necessary..

Provide documentation to support that $18,501 in credit card charges was spent for reasonable and necessary costs. Any amount that cannot be supported should be repaid from non-Federal funds and returned to the Housing Choice Voucher and public housing programs.

Provide documentation to support that $4,530 in petty cash funds was spent for reasonable and necessary costs. Any amount that cannot be supported should be repaid from non-Federal funds and returned to the Housing Choice Voucher and public housing programs.

Develop and maintain property records and conduct an inventory in accordance with Federal regulations.

Track and ensure that Volunteers returns to the Treasury any funds recovered through the ongoing litigation pertaining to the Yabucoa housing project.

Deobligate and recapture $1,440,165 in undrawn Section 202 funds assigned to the project.

Require Volunteers to reimburse to the United States Treasury $140,000 from non-Federal funds for ineligible project construction costs charged to the Section 202 project.

Return to the Puerto Rico Department of Housing $1,057,467, plus any interest earned, for the duplicate special escrow fund payments it received.

Provide documentation to show that prices paid for purchases of products and services totaling $970,381 were fair and reasonable or reimburse the project from nonproject funds for any amounts that were not fair and reasonable.

Provide documentation to show that payments for work totaling $716,693 complied with applicable building codes or reimburse the project from nonproject funds for payments that did not comply with the codes and take action to bring the work up to code.

Provide documentation to support payments totaling $163,885 or reimburse the project from nonproject funds for payments that it cannot support.

Develop and implement written procedures to ensure that it obtains written cost estimates as required and maintains complete documentation to support expenditures and that contractors performing or managing construction, removal, repair, or improvement work are properly licensed as required.