We audited the Cuyahoga Metropolitan Housing Authority’s management of lead‐based paint in its public housing program based on our assessment of the risks of lead‐based paint in public housing.  The risk factors assessed included the age of buildings, the number of units, household demographics, and reported cases of childhood lead poisoning.  Our audit objectives were to determine whether the Authority (1) complied with HUD’s requirements for children with elevated blood lead levels (EBLL) and (2) adequately managed lead‐based paint and lead‐based paint hazards in its public housing units.

The Authority did not comply with HUD’s reporting and verification requirements for cases of children with EBLLs.  Specifically, it did not report all 10 confirmed cases of children with an EBLL to HUD or notify HUD that it was unable to verify 4 additional cases.  Further, for 6 of 10 of the confirmed cases (60 percent), the Authority did not complete adequate environmental investigations to appropriately determine the source of each child’s lead poisoning.  The Authority also did not adequately manage lead-based paint and lead-based paint hazards in its public housing.  Specifically, of our sample of 24 units that the Authority managed as lead free, we determined that the Authority did not maintain sufficient documentation to support that 15 units (nearly 63 percent) and their associated developments did not contain lead-based paint.  Further, for our sample of 66 units that contained lead-based paint, we determined that the Authority did not ensure that the lead-based paint inspection and risk assessment reports for 31 units (nearly 47 percent) included required information.  Additionally, we reviewed a sample of 77 units, consisting of 67 units with lead-based paint and 10 units that had a child with a confirmed EBLL, and determined that the Authority did not (1) perform visual assessments for 59 units (nearly 77 percent) within the required timeframe, including 9 units that had a child under 6 years of age with a reported EBLL and (2) provide accurate lead disclosures to tenants for 38 units (nearly 50 percent), including 5 units that later had a child with a reported EBLL.  Lastly, we reviewed three units for which a reevaluation was required, since the lead-based paint inspection for those units identified deteriorated paint and, thus, required hazard reduction, and determined that the Authority did not reevaluate those three units every 2 years as required.

The issues related to reporting and notifying HUD of children with EBLLs and the associated environmental investigations occurred because the Authority (1) disregarded HUD’s requirement for reporting EBLL cases to HUD and (2) stated that it was not aware of certain HUD’s requirements for managing cases of children with EBLLs, even though HUD had published the LSHR and issued Office of Public and Indian Housing notices regarding PHAs’ requirements for managing children with EBLLs.  Therefore, the Authority should have been aware of and implemented those requirements.  The Authority also (1) painted over deteriorated paint in the units that contained children with EBLLs before the environmental investigations were performed; thereby compromising the results and (2) believed that an environmental investigation was not needed if the household with a child with an EBLL no longer resided in an Authority unit.  Further, the Authority lacked adequate policies, procedures, and controls to ensure that it complied with the LSHR requirements for managing housing units that contain lead-based paint.  Additionally, the Authority lacked oversight of (1) the lead-based paint inspection and risk assessment reports to ensure that they contained required elements; (2) the timeliness of its visual assessments, which it combined with the performance of annual physical inspections; and (3) its property managers to ensure that accurate lead-based paint disclosures were provided to prospective tenants.

We recommend that the Director of the Cleveland Office of Public Housing require the Authority to (1) develop and implement adequate procedures to ensure that confirmed EBLL cases, unconfirmed EBLL cases, and environmental investigations are reported to HUD; (2) develop and implement adequate procedures and controls to ensure that environmental investigations are completed when required; (3) perform a search for historical lead-based paint documentation to support the lead-free status of its units and the associated developments and if adequate documentation is not found, complete a lead-based paint inspection of the developments to determine whether they are lead free; and (4) implement adequate procedures and controls to ensure that visual assessments for lead-based paint are completed at least every 12 months, reevaluations are completed when required, and accurate lead disclosures are provided to prospective and current tenants.  We also recommend that the Director of the Cleveland Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to (1) provide training to the Authority’s staff on the appropriate testing methodology for confirming that a child has an EBLL and for managing lead‐based paint, (2) provide technical assistance to the Authority in developing and implementing procedures and controls to address the issues cited in this report, and (3) assess whether the lead-based paint inspections and risk assessments with missing elements are sufficient to support the lead-based paint status of the Authority’s properties.