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.

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.

Consider grantee feedback on the challenges they faced as part of ONAP’s planning for technical assistance and training of ONAP COVID-19 recovery program grantees.

Develop and implement a nationwide inspection review protocol, which includes but is not limited to (1) whether field office staff should mark verification of PHA corrections of life-threatening deficiencies in PASS or any future tracking systems, (2) acceptable documentation for offsite verifications, and (3) whether field office staff should discuss or verify corrections of non-life-threatening deficiencies.

Corrective Action Taken

HUD's Office of Field Operations (OFO) created a protocol describing how it would perform quality control reviews of field office oversight of PHAs’ corrections of life-threatening deficiencies. The implementation of this recommendation resulted in HUD creating a protocol that established consistency in the way HUD field office staff monitored public housing agencies’ corrections of life-threatening deficiencies.

Develop and implement training for field offices that addresses reviewing or following up with PHAs about the correction of life-threatening and non-life-threatening deficiencies and how (1) to review physical inspection reports to effectively ensure that PHAs correct physical deficiencies, (2) PHAs should address or correct each type of deficiency observed in the REAC physical inspection report, and (3) to use PASS or any future tracking system.

Corrective Action Taken

HUD developed and provided training to the field offices on their roles and responsibilities for following up with PHAs on the correction of life-threatening and non-life-threatening deficiencies observed during REAC inspections, the NSPIRE system and standards, protocols, and timelines for deficiency correction and verification. Implementation of the recommendation will help HUD to ensure that field office staff are clear on their roles and responsibilities to communicate with PHAs on how deficiencies should be addressed and verify that PHAs’ inspection deficiencies have been corrected.

Implement a system to track field office inspection review activities and create a repository for the support documentation collected to verify the correction of life-threatening deficiencies.

Corrective Action Taken

HUD’s Office of Field Operations (OFO) had created a quality assurance tracker as well as a life-threatening deficiency tracker, which contained data specific to the inspections selected by OFO HQs, for quality assurance reviews. The documentation (photographs, work orders, etc.) of the life-threatening deficiency correction was maintained in HUD’s NSPIRE Salesforce system.

Implementation of the recommendation resulted in HUD creating a system to track HUD field offices’ verifications of PHAs’ corrections of life-threatening deficiencies.

We recommend that the Deputy Assistant Secretary for REAC determine whether PHAs are required to perform annual inspections on 100 percent of their public housing units annually and issue clarifying guidance to all PHAs.

If REAC determines that 100 percent annual self-inspections are required, establish specific guidance to address the number of units and frequency of PHA self-inspections. If not required, REAC should evaluate whether HUD’s rationale for inspecting a statistical sample rather than 100 percent of public housing units remains appropriate.

We recommend that the Director of HUD’s Cleveland Office of Public Housing require the Authority to Support the reasonableness of $80,685 paid to a vendor for pest control services without a valid contract or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable.

We recommend that the Director of HUD’s Cleveland Office of Public Housing require the Authority to Support the reasonableness of the amounts paid for the two noncompetitively awarded contracts (0917 and 1125) that lacked adequate support for the independent cost estimate and price analysis or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable.

We recommend that the Director of HUD’s Cleveland Office of Public Housing require the Authority to support the $48,310 in excess costs paid for landscaping services or reimburse its program from non-Federal funds.

For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to ensure that its staff is appropriately trained and familiar with Federal procurement requirements regarding cost estimates and cost analyses.

We also recommend that the Director of HUD’s Cleveland Office of Public Housing determine whether the Authority qualifies for an exemption from preaward review.

Prioritize the inspection of public housing properties that were (1) not included in the NSPIRE demonstration but were identified as high priority under the Center’s Big Inspection Plan and (2) approved to participate under the NSPIRE demonstration that the Center was unable to inspect by March 31, 2023.

Develop and implement a plan to assist PHAs in improving voucher utilization, including providing additional guidance to PHAs to improve coordination between PHAs and PCWAs to improve voucher utilization and limit barriers to leasing.

Require PHAs to document that they informed FYI participants at program entry of their eligibility for supportive services and the availability of those services for the duration of the program.

For each youth referred, require PHAs to obtain PCWA certification that the PCWA will provide or secure access to supportive services.

Include FYI in its voucher risk assessment and develop and implement monitoring policies, procedures, and controls.

Establish and implement methods to regularly assess the effectiveness of the program in preventing and ending youth homelessness and improving participants’ self-sufficiency, which could include performance metrics and periodic studies performed by the Office of Policy Development and Research (PD&R).

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to establish and implement procedures and controls to ensure that lead-based paint visual assessments are performed within the required timeframe.