We audited the Columbus Metropolitan Housing Authority’s Housing Choice Voucher (HCV) Program. The audit was initiated based on our assessment of risks associated with public housing agencies’ HCV Program units and recent media attention and public concern about the conditions of subsidized housing properties. Our objective was to determine whether the physical condition of the Authority’s HCV Program units complied with the U.S. Department of Housing and Urban Development’s (HUD) and its own requirements.
The Authority did not always ensure that its HCV Program units met HUD’s housing quality standards (HQS). Specifically, we reviewed a sample of 84 units that had passed a recent HQS inspection and determined that 48 units had 248 deficiencies. More than 56 percent of the 48 units had 67 deficiencies that existed before the Authority’s last inspection. In addition, the Authority did not consistently stop housing assistance payments (HAP) to owners for uncorrected unit deficiencies. It also did not ensure that its contractors (1) categorized deficiencies as life threatening, requiring corrective actions within 24 hours and (2) conducted the required number of quality control inspections in 2022. Further, the Authority did not comply with HUD’s reporting and data collection requirements of the Lead Safe Housing Rule (LSHR) for cases of children with elevated blood lead levels (EBLL).
These conditions occurred because the Authority’s current contractor did not thoroughly inspect units in a consistent manner. Additionally, the Authority relied on its contractor to perform both HQS and quality control inspections of its program units without effectively overseeing the contractor’s performance. Further, the Authority did not ensure that its (1) current contractor’s information system properly transferred data to the Authority’s information system regarding stop payments and (2) former and current contractors complied with the Authority’s policies and procedures for stopping HAP. The Authority also lacked adequate oversight to ensure that its (1) former and current contractors properly categorized 24-hour life-threatening deficiencies and (2) current contractor performed the appropriate number of quality control inspections. In addition, the Authority did not update its policies and procedures to align with HUD’s EBLL requirements and relied on the State health department to initiate contact and facilitate the sharing of information for cases of children with EBLLs. As a result, families participating in the Authority’s HCV Program resided in housing units that were not always decent, safe, and sanitary. Based on our statistical sample, we estimate that over the next year, the Authority will pay owners nearly $36 million in housing assistance for units that do not meet HQS. Further, (1) the Authority paid ineligible or unsupported HAP totaling $15,427 to owners for units with uncorrected deficiencies and (2) HUD and the Authority lacked assurance that owners appropriately addressed their responsibilities under the LSHR for cases of children with EBLLs in a timely manner.
We recommend that the Director of HUD’s Cleveland Office of Public Housing require the Authority to (1) provide evidence that the owners corrected the outstanding unit deficiencies; (2) support that HAP was appropriately stopped or recover or repay from non-Federal funds $15,427 in housing assistance that was not properly stopped; (3) implement controls over its inspections, stop payments for uncorrected deficiencies, and quality control reviews; (4) work with its contractor to ensure that the contractor’s inspectors receive training on how to properly identify and categorize life-threatening deficiencies; and (5) develop and implement policies and procedures to ensure that owners follow the requirements of the LSHR. Additionally, we recommend that the Director of HUD’s Cleveland Office of Public Housing work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide technical assistance to the Authority’s staff to develop and implement procedures and controls for managing cases of children with EBLLs to ensure compliance with the LSHR, including collaborating with public health departments to identify cases of EBLL in children under 6 years of age under its HCV Program and updating its policies and procedures accordingly.
Recommendations
Public and Indian Housing
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Status2024-CH-1001-001-AOpenClosed
Provide evidence that the owners corrected the 248 deficiencies for the 48 units with outstanding deficiencies. If the owners fail to make corrections, the Authority should implement its stop payment procedures and provide supporting documentation to HUD.
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Status2024-CH-1001-001-BOpenClosed$35,651,526.00Funds Put to Better Use
Recommendations that funds be put to better use estimate funds that could be used more efficiently. For example, recommendations that funds be put to better use could result in reductions in spending, deobligation of funds, or avoidance of unnecessary spending.
Implement a quality control process for monitoring its contracted inspectors to ensure that units meet HUD’s requirements to prevent nearly $36 million in program funds from being spent on units that do not meet HQS over the next year.
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Status2024-CH-1001-001-COpenClosed
Implement procedures and controls regarding its quality control inspections to ensure that the results of those inspections are appropriately used to evaluate and monitor the performance of the Authority’s contracted inspectors and documentation is maintained on communications with the contractor on corrective actions taken to address recurring inspection deficiencies.
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Status2024-CH-1001-002-AOpenClosed$5,194.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Pursue collection from the applicable owner or reimburse its HCV Program $5,194 from non-Federal funds for HAP that was not properly stopped for two units with outstanding HQS deficiencies.
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Status2024-CH-1001-002-BOpenClosed$10,233.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Provide support showing whether HAP was appropriately stopped for the four units cited in the finding or reimburse or pursue collection of $10,233 from non-Federal funds for HAP to owners with outstanding HQS deficiencies.
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Status2024-CH-1001-002-COpenClosed
Implement procedures and controls regarding its stop payment process to ensure that it consistently (1) stops payments as required by its HCV Program administrative plan and HUD requirements, (2) verifies and documents the correction of deficiencies, and (3) maintains sufficient documentation to support the stop payment for each unit.
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Status2024-CH-1001-002-DOpenClosed
Implement controls over its inspection processes and procedures to ensure that emergency failures are properly identified, reinspected, and corrected within 24 hours in accordance with its HCV Program administrative plan or the housing assistance to the owner is stopped.
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Status2024-CH-1001-002-EOpenClosed
Work with its contractor to ensure that the contractor’s inspectors receive training on how to properly identify and categorize life-threatening deficiencies.
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Status2024-CH-1001-003-AOpenClosed
Develop and implement policies and procedures that align with HUD’s requirements and controls to ensure that owners follow the requirements of the LSHR.
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Status2024-CH-1001-003-BOpenClosed
Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide technical assistance to the Authority’s staff to develop and implement policies, procedures, and controls for managing cases of children with EBLLs to ensure compliance with the LSHR, including attempts to collaborate with public health departments to identify cases of EBLL in children under 6 years of age under its HCV Program and updating its policies and procedures accordingly.