Determine the CDBG proportional benefit of the $329 charged for indirect automotive costs and repay the program any unsupported charges using non-Federal funds.

Obtain training or technical assistance from HUD concerning CDBG code enforcement, allocation of payroll, and indirect administrative costs.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to develop and implement a HUD approved written plan and checklists; and take actions that will correct and prevent the deficiencies outlined in the finding, improve program administration effectiveness, ensure compliance with HUD regulations and the policies and procedures it submitted and certified to HUD, and ensure it has the continuing capacity to carry out its activities, as required. Implementing this recommendation should ensure that the remaining $8,679,994 allocated in disaster funding is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support the cost reasonableness or repay its program from non-Federal funds $362,319 paid to its consultant contractor without an independent cost estimate.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support the cost reasonableness or repay its program from non-Federal funds $30,702 paid to its construction contractor for cost increases without adequate cost analyses.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support the cost reasonableness or repay its program from non-Federal funds $58,873 paid to its surveyor contractor for the sole-sourced contract without an adequate cost analysis.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to maintain program files with all required documentation for each activity.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to implement an internal audit function that satisfies program requirements.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to revise its monitoring policy to include the role of the internal auditor once implemented, and finalize and fully implement or revise its fraud, waste, and abuse detection policy to reflect current procedures.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to update its Web site to include current quarterly performance, budget, and progress reports.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to obtain technical assistance concerning the disaster recovery program requirements, including related Federal Register requirements. Specifically, the technical assistance should include guidance on how to satisfy the requirement regarding maintaining an internal audit function and Web site maintenance.

Director for the Office of Field Management ensure that the CDBG-DR risk analysis worksheet includes risk factors that show the measurement of performance outputs to determine completed activities.

Director for the Office of Field Management update the risk analysis guidance for CDBG-DR grants to include the assessment of the likelihood of risk occurrence to help inform management which critical risks to address during monitoring.

Director for the DRSI Division ensure that monitoring strategies correlate to the high-risk areas identified during the risk analysis and are in compliance with the central risk factor categories identified in HUD’s Monitoring Desk Guide.

Ensure that CPD personnel that plan for, award, and manage grants and other forms of financial assistance receive formal risk analysis training.

Provide documentation to show that prices paid for products and services totaling $1,423,262 for three activities were fair and reasonable or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $942,636 for activity 7099 were for employees’ actual time spent benefiting the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that costs totaling $100,000 for activity 6865 benefited the activity or repay its program from non-Federal funds for any amount that it cannot support.

Provide documentation to show that seven activities with costs totaling $2,266,543 were exempt or categorically excluded from environmental reviews or repay its program from non-Federal funds for any amount that it cannot support (excluding any amount repaid as a result of recommendations 1A, 1B, and 1C).

Revise its policies and procedures to address compliance with applicable procurement regulations requiring independent cost estimates before receiving bids or proposals.