We recommend that the Director of the San Antonio Office of Public Housing require the Authority to adopt policies and procedures that contain current Federal and State guidance.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to provide training to commissioners and employees on travel requirements and their responsibilities and duties.

Deobligate $542,289 in fiscal year 2015 capital funds in HUD’s system until binding agreements are executed for eligible and reasonable purposes, or coordinate with HUD for terminating its funding.

Reclassify $398,022 in fiscal year 2016 capital funds as authorized in HUD’s system to an eligible and reasonable activity, or coordinate with HUD for terminating its funding.

Coordinate with HUD for terminating the allocation of the remaining $217,553 funds given the Authority’s current intentions to not build or purchase public housing units.

Develop and implement adequate procedures and controls to ensure that the reporting of allocated capital funds in HUD’s system is accurate.

Provide adequate training to staff responsible for making entries into HUD’s system to ensure accurate reporting on allocated funds. The training should include but not be limited to ensuring that its staff understands all of HUD’s reporting requirements for obligations and authorizations.

Confirm the replacement of program units was appropriate for the number of units demolished at Johnson Ferry East, and submit a development proposal to construct new public housing units, transfer public housing assistance to another public housing agency, or terminate its annual contributions contract and return all unobligated and unexpended capital funds to HUD.

Certify, along with the owners of the 11 units cited in this finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $9,715 from non-Federal funds ($9,660 for housing assistance payments and $55 in associated administrative fees) for the unit that materially failed to meet HUD’s housing quality standards.

Provide training to its inspectors on conducting housing quality standards inspections.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing Investments direct staff to determine whether the nine PHAs that were classified as troubled or physically substandard have public housing developments that are subject to the required conversion requirements to support whether potentially distressed projects should be converted to tenant-based rental assistance. If conversion is required, ensure that it is accomplished timely, thereby ensuring that up to $75,540,916 is used effectively for other projects that are cost effective and have long term viability and ensuring that residents receive other rental assistance. Footnote: The $75 million cited as funds to be put to better use is based on an analysis of available data. We recognize that the 131 PHAs cited in this report, including the 9 PHAs that comprise the $75 million figure, may not have projects with at least 250 units on one or more contiguous sites that have vacancy rates of 12 percent or more. However, the data did not allow us to calculate vacancy rates for each group of contiguous units, and HUD could not provide a reasonable, supported method to identify projects subject to required conversion. To address this recommendation, HUD will need to determine whether these PHAs have projects that are subject to required conversion.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing Investments direct staff to develop and implement policies and procedures with the Office of Field Operations regarding identification of potentially distressed projects and monitoring and enforcement of the required conversion program.

We recommend that the Program Center Coordinator, Office of Public Housing, Oklahoma City, OK, require the Authority to repay $12,739 from non-Federal funds to its Section 8 program for ineligible payments based on incorrect housing assistance payment calculations, incorrect payment standards and utility allowances, and unreported income.

We recommend that the Program Center Coordinator, Office of Public Housing, Oklahoma City, OK, require the Authority to support or repay $28,574 from non-Federal funds to its Section 8 program for unsupported payments based on questionable income calculations.

We recommend that the Program Center Coordinator, Office of Public Housing, Oklahoma City, OK, require the Authority to strengthen its compliance with requirements by implementing a quality control system that would require management to review a sample number of income calculations, ensure staff follow-up on income discrepancies and document their analysis.

We recommend that the Program Center Coordinator, Office of Public Housing, Oklahoma City, OK, require the Authority to implement policies and procedures to monitor the EIV income discrepancy reports each quarter to minimize subsidy payment errors.

Reimburse its program $648 from non-Federal funds and use its internal control procedures to ensure that housing assistance payments are correctly calculated during the certification process to ensure that a $648 overpayment in program funds is appropriately used for future payments.

Reimburse the participants $84 from non-Federal funds for the underpayment of housing assistance.

Develop and implement an internal policy and procedure related to interim certifications to ensure that it obtains EIV reports and maintains those reports in participant files.