We recommend that the Director of CPD’s Office of Disaster Recovery make changes to the action plan process so that the action plan calculates an overall LMI percentage.

Provide documentation to show that it purchased products and services totaling $728,516 at fair and reasonable prices or reimburse either its Operating or Capital Fund from non-Federal funds for any amounts that it cannot support.

Provide documentation to show that it had contracts for dumpster rentals and pest control services, and if it cannot provide the contracts, re-procure these services.

Obtain written agreements with the originating public bodies for its ongoing awards that were procured through intergovernmental agreements, including dumpster rentals, maintenance supplies, and consulting services, and if it cannot provide the agreements, re-procure these services.

Develop and implement controls to ensure that it complies with all applicable procurement requirements.

Provide technical assistance to the Authority to ensure that it understands Federal procurement requirements, including the proper use of intergovernmental agreements.

Certify, along with the owners of the 61 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $46,605 from non-Federal funds ($44,214 for housing assistance payments and $2,391 in associated administrative fees) for the 22 units that materially failed to meet HUD’s housing quality standards.

Develop and implement procedures and controls to monitor the inspection process to ensure that program units meet housing quality standards, thereby ensuring that an estimated $2,668,680 in program funds is spent for units that are decent, safe, and sanitary.

Cancel the Section 8 Project-Based Voucher Program housing assistance payments contract for 90 units improperly converted under RAD. The owner should work with HUD and the Authority to protect the tenancy of the affected tenants at the time of contract cancellation.

Reimburse HUD’s Section 8 program administered by the Authority $485,475 in housing assistance payments from nonproject funds for the improper issuance of tenant protection assistance and an improper RAD conversion to the Project-Based Voucher Program for the 90 units.

Develop and implement procedures to ensure that when tenant protection assistance is requested as a result of a housing conversion action, the forms HUD-50059 and or tenant profiles is generated only based on a completed action and that the forms or profiles are provided to HUD instead of the Read More

Provide adequate training to staff associated with administering tenant protection and project-based assistance to help ensure compliance with program requirements.

Take appropriate enforcement actions against the responsible parties and pursue civil action against the owner for improperly certifying to the eligibility of the project residents.

Pursue administrative actions, as appropriate, against the responsible parties for the improper certification included in form HUD-50059 and the Section 8 project-based voucher housing assistance payments contract.

Recapture the $248,222 in excess program funds from the Authority and allocate in the pool for other tribes to use in meeting program objectives.

Require the Authority to provide source documentation to determine the accuracy of the tribal enrollment numbers reported in 2015 and 2016. Based on those supported numbers, HUD should recapture or offset the unsupported amounts from the awarded $1,746,658 in program funds that resulted from under Read More

Require the Authority to establish and implement controls and formal written policies and procedures to ensure that accurate tribal enrollment numbers are reported to the Formula Service Center and HUD for future grant years.

Support the eligibility of the reported $548 in unsupported program costs or repay its program using non-Federal funds.

Implement controls to ensure that all future check request forms are complete for proper tracking in its accounting records and authorized approver verifies source documentation is attached prior to check issuance for future program expenses as required by its own policies and procedures.