Require the Authority and Majestic Management to repay any excessive annual leave that Majestic Management paid to its employees from project funds when its contract terminated in 2017.

Require the Authority to provide training on procurement requirements in public housing to all Majestic Management employees working at the projects.

Require the Authority and Majestic Management to support that the $487,422 spent on goods and services for the projects was a reasonable cost and the goods and services were procured from eligible vendors or repay the projects from non-Federal funds.

Require the Authority to review all other payments to the sampled vendors to confirm that the costs were reasonable and the goods and services were procured from eligible vendors or repay the projects from non-Federal funds.

Require the Authority to monitor Majestic Management to ensure that the recent training was effective and the new checklist is in use and effective.

Require the Authority to recompute the rents for the households noted above and as necessary for errors made by Majestic Management, reimburse tenants for overcharged rent from operating funds or rent credit, and enter into repayment agreements with tenants if they were undercharged based on nondisclosure of income.

Support that $2,533,377 in costs were reasonable and allowable program expenses in accordance with requirements or repay from non-Federal funds the appropriate programs any amounts they cannot support.

Repay the appropriate programs from non-Federal funds the $1,524,604 in ineligible funds paid when costs exceeded contract terms.

Determine the appropriateness of the remaining balance of $1,242,154 on unsupported contracts to ensure costs were reasonable, reprocure the subject contracts, or reallocate the funds to the appropriate program.

Reprocure expired service contracts to ensure estimated balances of $375,526 are used on eligible contract.

Reprocure any service contracts necessary and ensure that the contracts are properly awarded in accordance with HUD requirements.

Strengthen and implement controls and procedures over procurement, including monitoring consultants, to ensure that procurement activities meet HUD requirements.

Establish and implement an effective system to ensure that payments do not exceed approved contract values.

Establish and implement an effective system to maintain a complete and accurate contract register to ensure proper contract planning and administration.

Provide technical assistance to the Authority to ensure that responsible staff and board members receive necessary procurement training.

Finalize and implement monitoring procedures to ensure that $6,324,625 in flat rents are appropriately charged to tenants over the next year.

Follow up with the housing authorities in our sample, identified as noncompliant with flat rent requirements, to ensure that their rents are properly adjusted.

Clarify guidance to better enhance housing authority understanding of the requirement, including explaining that housing authorities must code ceiling rent tenants as flat rents and explaining what housing authorities should do when maximum rents for low-income housing tax credit properties are lower than the minimum flat rent amounts required by HUD.

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 or overstated tribal enrollment numbers.