Ensure that it obtains a separate interest-bearing depository account for its program participants’ escrow funds in accordance with HUD’s requirements.

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’ contracts of participation and individual training and services plans are properly updated and contain the necessary signatures; (2) changes in participants’ files are properly identified and notated; and (3) participants are notified of changes in their monthly escrow deposits, total escrow balances, or both.

Develop and implement procedures and controls to ensure that (1) documentation required by HUD and its own action plan is correctly completed, documented, and updated; (2) escrow account balances are correctly calculated and disbursed; and (3) escrow accounts and disbursements are fully supported to ensure that $127,544 in coordinator grant funds is appropriately used over the next year.

Determine the amount of the $387,507 in coordinator grant funds that was appropriately earned by the Authority for meeting requirements. The funds that are determined to be unearned should be reimbursed to HUD from non-Federal funds.

Review the Authority’s graduate documentation and adjust the Authority’s minimum program size as necessary.

Review the Authority’s Section Eight Management Assessment Program scores for the Family Self-Sufficiency program and adjust as necessary.

Provide technical assistance and guidance to the Authority to ensure that it properly administers its Family Self-Sufficiency program.

Reimburse its program $34,666 from non-Federal funds ($21,990 $12,676 in administrative fees) for the overpayment of housing assistance due to inappropriate calculations of housing assistance.

Reimburse the appropriate households $1,265 from program funds for the underpayment of housing assistance due to inappropriate calculations.

Pursue collection from the applicable households or reimburse its program $9,644 from non-Federal funds for the overpayment of housing assistance due to unreported or underreported income.

Support or reimburse its program $1,666 from non-Federal funds for the unsupported payments of housing assistance cited in this finding.

Implement adequate procedures and controls to ensure that (1) housing assistance payments are appropriately calculated and supported, (2) repayment agreements are created to recover overpaid housing assistance when unreported income is discovered during the examination process, and (3) annual reexaminations are completed in a timely manner to ensure that $322,550 in program funds is appropriately used for future payments.

We recommend that the Southwest Region Director of Multifamily Housing require Beverly Place’s owner to repay HUD $574,930 for subsidized units that were not occupied by qualified tenants. Repayment must be from non-Federal funds.

We recommend that the Southwest Region Director of Multifamily Housing require Beverly Place’s owner to provide support to show that the subsidies for 11 tenants with falsified income were accurate or repay HUD $150,082 for those subsidies. Repayment must be from non-Federal funds.

We recommend that the Southwest Region Director of Multifamily Housing require Beverly Place’s owner to provide support to show that the subsidies for 18 tenants without files or without adequate income documentation in their files were accurate or repay HUD $77,621 for those subsidies. Repayment must be from non-Federal funds.

We further recommend that the Southwest Region Director of Multifamily Housing require its contract administrator for Beverly Place to verify that the owner’s recently implemented quality control program is working as designed.

We further recommend that the Southwest Region Director of Multifamily Housing ensure that the project-based contract administrator’s review process includes steps to obtain reasonable assurance that tenants being reported as subsidized at Beverly Place live in the subsidized units.

Take appropriate administrative sanctions, including suspension, limited denial of participation, or debarment, against the commissioners.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to repay from non-Federal funds $11,172 paid for ineligible travel costs of which $6,904 was Housing Choice Voucher and $4,268 was operating subsidy funds.

Acknowledge that the attached settlement agreement for $10,000 represents an amount due HUD.