Open Recommendations

Require the Municipality to reimburse the HOME program from non-Federal funds $2,263,799 paid for ineligible costs.

Require the Municipality to put to better use $2,854,395 associated with unexpended funds maintained in its local bank account.

Require the Municipality to update its accounting records and ensure that receipts and expenditures are properly accounted for, are reconciled with HUD's information system, and comply with HUD requirements.

Require the Municipality to develop and implement a financial management system in accordance with HUD requirements, including that HOME funds can be traced to a level which ensures that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes and that funds are disbursed in a timely manner.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse its Capital Fund $1,539,629 from non-Federal funds for the ineligible payments cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to return the $411,228 in excess capital fund draws cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to provide supporting documentation or reimburse its Capital Fund $394,683 from non-Federal funds for the unsupported costs cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse its Capital Fund $13,085 from non-Federal funds for the inappropriately earned interest cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse its appropriate programs $180,649 from non-Federal funds for the ineligible payments cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to provide supporting documentation or reimburse its appropriate programs $30,236 from non-Federal funds for the unsupported costs cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse its Capital Fund $127,050 from non-Federal funds for the ineligible payments cited in this finding.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to reimburse its operating fund $107,692 from non-Federal funds for ineligible payments cited in this finding.

The Office of Programs should work with the management control review committee to revise management control documentation to be consistent with Government Accountability Office guidance for internal controls.

Support or repay from non-Federal funds any amounts that it cannot support, including $1,568,245 to its operating fund and $973,126 to its capital fund paid for (1) contracts that were improperly procured, (2) contract overpayments, or (3) contract payments made outside of the contract effective dates.

Develop short-term, intermediate, and long-term outcome performance measures, and additional output performance measures, with appropriate targets and timeframes, to measure the progress and results of theprogram.

Develop and publish a comprehensive management plan for EDSP, including estimates of EDSP’s budget requirements, priorities, goals, andkey activities covering at least a 5-year period.

Annually review the EDSP program results, progress toward milestones, and achievement of performance measures, including explanations for any missed milestones or targets.

Rec. 2.a: The DoD OIG recommended that the Deputy Commandant, Plans, Policies, and Operations, update the small arms accountability guidance in Marine Corps Order 5530.14A consistent with Marine Corps Bulletin 4440 and the updates to Marine Corps Order 8300.1C.

We recommend that the Director of HUD's Buffalo Office of Community Planning and Development reimburse from non-Federal funds $162,923 ($134,711 $28,212) expended on ineligible costs pertaining to street improvement projects not done and a duplicate reimbursement.

We further recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct the City to provide documentation to justify the $1,982,988 in unsupported costs associated with street improvement expenditures incurred between June 2007 and October 2009. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.

We recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct the City to provide documentation to justify the $20,143,219 ($4,902,754 $15,240,465) in unsupported transactions recorded in the CDBG program income account. Any receipts determined to be unrecorded program income should be returned to the CDBG program, and any expenditures determined to be ineligible should be reimbursed from non-Federal funds.

We further recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct the City to reimburse from non-Federal funds the $304,506 related to ineligible clean and seal code enforcement costs.

We further recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct the City to provide documentation to justify the $716,622 ($545,607 $24,069 $146,946) in unsupported clean and seal costs incurred so that HUD can make an eligibility determination. Any costs determined to be ineligible should be reimbursed from non-Federal funds.

Deobligate $279,245 in available funds associated with the ineligible CHDO and reprogram the funds for other eligible HOME activities, thereby putting the funds to better use.

KPMG recommends that the CIO develop and promulgate entity-wide security policies and procedures and assume more responsibility for the coordination and oversight of Program Offices in completing certification and accreditation and other information security requirements and activities.