We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to show that $842,931 paid under five contracts was for prices that were reasonable or reimburse its Operating Fund for any amount that it cannot support or is not considered reasonable.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls over purchases to ensure compliance with HUD, Federal, and Authority procurement requirements. This includes, but is not limited to, controls to ensure that it (1) maintains records sufficient to detail the significant history of procurements, (2) complies with requirements for each type of procurement, (3) obtains independent cost estimates and performs cost or price analyses when required, and (4) prevents and detects conflict-of-interest situations.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to its staff to ensure compliance with HUD and Federal procurement requirements.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify the $372,695 in unsupported Operating Fund subsidies received or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify $8,564 in excessive property management fees charged by the COCC or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to reimburse its Operating Fund from non-Federal funds $82,907 for 16 document management services contract payments that should have been paid with COCC funds.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls to ensure that operating funds are requested, received, and used in accordance with HUD, Federal, and Authority requirements.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to employees involved in the funding and expenditure processes to ensure compliance with HUD, Federal, and Authority requirements

Evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.

Update and revise the CPD Notice to further improve the code enforcement guidance.

Provide mandatory training on the revised Notice to the local field offices and to grantees that use CDBG funds for the code enforcement program to ensure compliance with requirements.

Ensure that the updated and revised notice is issued with the appropriate clearance.

Transfer $78,786 ($22,601 $56,185) from its Family Self-Sufficiency account to its Housing Choice Voucher Program account for the overfunded and forfeited escrows.

Support or reimburse its Housing Choice Voucher Program $120,067 from non-Federal funds for unsupported graduation disbursements.

Reimburse its Housing Choice Voucher Program $12,460 from non-Federal funds for the ineligible disbursements.

Transfer $3,801 from its Housing Choice Voucher Program account to its Family Self-Sufficiency account for the underfunded escrows.

Reimburse one participant, $547 from its Family Self-Sufficiency program for the underpaid graduation payment.

Implement procedures and controls to ensure that documentation required by HUD and the Authority’s own action plan is correctly completed, documented, and updated.

Ensure that its staff is appropriately trained and familiar with HUD’s requirements and its program action plan regarding the administration of its program to ensure that (1) participants’ individual training and services plans are complete and contain appropriate goals to assist the family in achieving self-sufficiency, (2) participants are notified of their escrow account balances at least annually, and (3) contracts of participation are complete and accurate.

Ensure that its newly created policies and procedures include a process for ensuring that (1) escrow balances are correctly calculated and disbursed, (2) escrow accounts and disbursements are fully supported, and (3) forfeited escrow account funds are returned to the Housing Choice Voucher Program as required.