Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training for the Authority’s staff on the appropriate testing methodology for confirming that a child has an EBLL and to provide technical assistance on procedures and controls to address the issues cited in this finding.

Perform a search for historical documentation to support the lead-free status of the 15 units and the associated developments. If adequate documentation is not found to support that all lead-based paint was identified and abated and clearance was achieved as required, the Authority should complete a lead-based paint inspection of the developments to determine whether they are lead free.

Develop a quality control process to ensure that records for the remaining 1,385 units49 contain evidence of lead-free status. If adequate documentation is not found to support that all lead-based paint was identified and abated and clearance was achieved as required, the Authority should complete a lead-based paint inspection of the developments to determine whether they are lead free.

Implement procedures that align with HUD’s requirements and controls to ensure that visual assessments for lead-based paint are completed at least every 12 months.

Implement policies and procedures that align with HUD’s requirements and controls to ensure that reevaluations are completed when required.

Implement controls to ensure that accurate lead disclosures are provided to prospective and current tenants.

Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training for the Authority’s staff on the management of lead-based paint, including technical assistance with developing and implementing procedures and controls to address the issues cited in this finding.

Work with HUD’s Office of Lead Hazard Control and Healthy Homes to 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. If it is determined that the lead-based paint and risk assessment reports are not sufficient, HUD should require the Authority to perform new assessments.

Provide evidence that the owners corrected the 248 deficiencies for the 48 units with outstanding deficiencies. If the owners fail to make corrections, the Authority should implement its stop payment procedures and provide supporting documentation to HUD.

Implement a quality control process for monitoring its contracted inspectors to ensure that units meet HUD’s requirements to prevent nearly $36 million in program funds from being spent on units that do not meet HQS over the next year.

Implement procedures and controls regarding its quality control inspections to ensure that the results of those inspections are appropriately used to evaluate and monitor the performance of the Authority’s contracted inspectors and documentation is maintained on communications with the contractor on corrective actions taken to address recurring inspection deficiencies.

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.

Implement procedures and controls regarding its stop payment process to ensure that it consistently (1) stops payments as required by its HCV Program administrative plan and HUD requirements, (2) verifies and documents the correction of deficiencies, and (3) maintains sufficient documentation to support the stop payment for each unit.

Implement controls over its inspection processes and procedures to ensure that emergency failures are properly identified, reinspected, and corrected within 24 hours in accordance with its HCV Program administrative plan or the housing assistance to the owner is stopped.

Work with its contractor to ensure that the contractor’s inspectors receive training on how to properly identify and categorize life-threatening deficiencies.

Develop and implement policies and procedures that align with HUD’s requirements and controls to ensure that owners follow the requirements of the LSHR.

Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide technical assistance to the Authority’s staff to develop and implement policies, procedures, and controls for managing cases of children with EBLLs to ensure compliance with the LSHR, including attempts to collaborate with public health departments to identify cases of EBLL in children under 6 years of age under its HCV Program and updating its policies and procedures accordingly.

Update Handbook 4000.1 to require servicers to share information regarding foreclosure moratoriums with borrowers.

Review the two loans in our sample that did not receive appropriate servicing and take administrative actions if appropriate.