Open Recommendations

We recommend that the Director of HUD's Detroit Office of Multifamily Housing Programs require the Authority to reimburse the U.S. Treasury $12,830 from non-Federal funds for the lost interest.

We recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct City officials to expend or reprogram to other eligible program activities the $2,451,645 in CDBG program income maintained in the City's community development bank accounts as of June 30, 2013, so the City can assure HUD that these funds have been put to better use.

We recommend that the Director of HUD's Buffalo Office of Community Planning and Development instruct City officials to Provide documentation to justify the $177,923 unsupported difference between the City's CDBG program income balance in IDIS and its bank account balances as of June 30, 2013. Any portion of the unsupported difference determined to be ineligible should be reimbursed from non-Federal funds.

Provide adequate supporting documentation for the $1,628,130 in unsupported salary and benefit costs or repay the CDBG program from non-Federal funds.

Reimburse its HOME program $1,595,113 from non-Federal funds for HOME funds that were inappropriately used on Section 8 housing assistance payments.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to support or reimburse its program $425,193 ($19,924 $384,755 in housing assistance payments $46 in utility allowances $20,468 in associated administrative fees) from non-Federal funds for the unsupported overpayment of housing assistance and utility allowances due to unsupported calculations, missing eligibility documentations, and discrepancies in the housing assistance payments register.

We recommend that the Director of HUD's New York Office of Community Planning and Development instruct County officials to provide documentation to justify the $189,322 in unsupported administrative and planning costs that was disbursed for employee salaries and fringe benefits. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.

We recommend that the Director of HUD's New York Office of Community Planning and Development instruct County officials to reimburse from non-Federal funds $78,530 for ineligible home-buyer rehabilitation and demolition costs charged to the HOME program.

We recommend that the Director of HUD's New York Office of Community Planning and Development instruct County officials to terminate the contract between the County and the Village of Freeport to rehabilitate and construct single-family public housing units to be sold to low-income residents. The remaining contract balance of $31,470 should be put to better use by reprogramming it for other eligible purposes.

We recommend that the Director of HUD's New York Office of Community Planning and Development instruct County officials to provide documentation to justify the $1,264 in unsupported project delivery costs. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.

We recommend that the Director of HUD's New York Office of Community Planning and Development instruct County officials to document their application review committee membership and provide evidence of the committee meetings and their evaluation and rating of subrecipients to fully support their funding recommendations.

We recommend that the Director of HUD's New York Office of Community Planning and Development instruct County officials to develop controls to ensure that the County's recently established debarment verification procedures are implemented for all future procurement activity.

We recommend that the Director of HUD's New York Office of Community Planning and Development instruct County officials to develop controls that will ensure that the County's decentralized record-keeping system is centralized for ready access to HOME documents.

Require the Municipality to reimburse from non-federal funds $552,658 in unallowable and unallocated costs associated with the disbursement of salaries and fringe benefits of employees who did not perform duties directly related to carrying out activities charged with the program delivery costs.

Require the Municipality to provide support showing the allocability and eligibility of $1,077,577 spent on salaries and fringe benefits for employees who performed local government duties and multiple federally funded activities without properly allocating the costs directly related to carrying out each activity. Any amounts determined ineligible must be reimbursed to the Block Grant program from non-federal funds.

Reimburse its business development loan program $5,999,894 from non-Federal funds for the ineligible expenditures related to the Hotel Sterling project.

We recommend that the Director of HUD's Detroit Office of Public Housing require the Commission to provide supporting documentation or reimburse its program $17,008 from non-Federal funds for the unsupported payments cited in this finding.

Require the Municipality to develop and implement a financial management system in accordance with HUD requirements and ensure that $3,213,572 in HOME funds drawn from HUD between July 1, 2009, and December 31, 2011, 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 or reimburse the HOME program from non-Federal funds.(Footnote 2) Total disbursements of $3,523,723 were adjusted to consider $173,978 questioned in recommendation 1B, $86,567 questioned in recommendation 1D, and $49,606

Determine the eligibility of the $537,773 disbursed for the Ciudad de Ensueo project and reevaluate the feasibility of the activity. (Footnote 9) Total disbursements of $538,973 were adjusted to consider $1,200 questioned in recommendation 1F. The Municipality must reimburse its HOME program from non-Federal funds if HUD determines the activity to have been terminated.

Establish and implement procedures to reassess the safe harbor percentage and rates periodically to ensure that they are reasonable. HUD should retain the documentation justifying the calculation of those percentages and rates. In addition, HUD should assess the feasibility of requiring the agencies to periodically justify and retain documentation showing the reasonableness of using the maximum rates, or lower them as appropriate.

Direct responsible grantees to justify the use of $66,849,658 that it disbursed for cancelled Block Grant program activities or repay HUD from non-Federal funds.

We recommend that the Director of HUD's New York City Office of Community Planning and Development instruct City officials to reimburse from non-Federal funds $93,436 for ineligible costs charged to HPRP; specifically, $59,430 related to payments for rental arrears over the 6-month eligibility requirement and $34,006 for payments issued directly to participants.

We recommend that the Director of HUD's New York City Office of Community Planning and Development instruct City officials to provide documentation to justify the $329,937 in unsupported salary costs incurred between June and September 2010. Any unsupported costs determined to be ineligible should be reimbursed from non-Federal funds.

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.