Provide additional training and technical assistance to the PRDOH on the development of policies and procedures to ensure that procedures comply with applicable Federal and grant requirements.

Submit supporting documentation showing that contracts and purchase orders complied with Federal and its own procurement requirements and that these were reasonable and necessary costs or reimburse the CDBG-DR program $55,010 from non-Federal funds.

Submit supporting documentation showing that contracts and purchase orders complied with Federal and its own procurement requirements and that these were reasonable and necessary costs or cancel the $361,501 in unpaid obligations related to CDBG-DR funds.

Revise and finalize the procurement procedures to ensure compliance with applicable Federal requirements, including but not limited to procedures to ensure full and open competition, supporting independent cost estimates, properly documenting the procurement history, and including required clauses in contracts, among other issues.

Collaborate with OCFO to review methodologies used to produce grant accrual estimates, to include testing and verification of the resulting accrual estimates.

Implement information security controls over the Section 108 loan guarantee database that prevent and detect unauthorized changes to program data (or implement an updated Section 108 loan guarantee database with information security controls that prevent and detect unauthorized changes to program data).

Support that it met its $161,957 matching contribution required for the $647,827 it drew down for expenses related to its four HUD-funded programs. If the Community cannot provide support, it should reimburse HUD $577,6707 from non-Federal funds.

Develop and implement written policies and procedures to ensure that it maintains documentation to support matching contributions received in compliance with HUD requirements.

Repay HUD $15,163 from non-Federal funds for the rental assistance provided to five ineligible individuals.

Support the eligibility of the 11 individuals who received rental assistance through its rapid rehousing program or repay HUD $26,676 from non-Federal funds.

Work with HUD to determine the eligibility of current permanent supportive housing residents and if residents are determined ineligible, take appropriate action.

Implement its written policies and procedures to ensure that only eligible individuals receive rapid rehousing assistance.

Implement its written policies and procedures to ensure that individuals entering its permanent supportive housing are eligible.

Support or repay HUD $17,025 from non-Federal funds for the questioned payroll costs charged to the programs.

Develop and implement written policies and procedures to ensure accurate and complete reporting of staff hours charged to each program.

Support the validity of its indirect cost allocations or repay HUD $8,605 from non-Federal funds.

Develop and implement an indirect cost allocation plan, which ensures that indirect costs are charged to the correct program.

Provide technical assistance to the Community to ensure that its staff receives training on documentation of matching contributions and the use of program funds.

Reclassify the $28,576 as program income to the specific permanent supportive housing program that generated it and ensure these funds are used for that specific program.

Develop and implement written policies and procedures to ensure that all program income is recorded and used in accordance with HUD requirements.