We recommend that HUD’s Acting Deputy Assistant Secretary for Grant Programs coordinate with the Office of Healthy Homes and Lead Hazard Control to provide technical assistance and instruct City officials to provide supporting documentation that lead-based paint testing was performed, identified hazards were removed, and clearance was achieved for the 41 properties for which homeowners received $833,199 in CDBG-DR assistance. If supporting documentation is not provided, City officials should repay the $833,199 from non-Federal funds.

We recommend that HUD’s Acting Deputy Assistant Secretary for Grant Programs coordinate with the Office of Healthy Homes and Lead Hazard Control to provide technical assistance and instruct City officials to advise homeowners of their obligation under the terms of the reimbursement grant agreement to allow the Program to perform lead-based paint testing or hazard removal. Homeowners who refuse to allow the Program to complete lead hazard work or provide evidence that the property achieved clearance must repay the grant.

Issue a change to regulations at 24 CFR Part 203, which would avoid unnecessary costs to the FHA insurance fund, allowing an estimated $2.23 billion to be put to better use. These changes include (1) a maximum period for filing insurance claims and (2) disallowance of expenses incurred beyond established timeframes.

Status

This audit recommendations cannot be closed out without the publication of the Federal Housing Administration (FHA): Maximum Claim Rule. The proposed changes have been on HUD’s regulatory agenda since Spring 2020 but, as of June 2024, the Office of Single Family Housing does not have an estimated publication date.

Analysis

To fully address this recommendation, HUD must publish the FHA Maximum Claim Rule.

Implementation of this rule should result in HUD putting $2.23 billion to better use.

Acknowledge that the attached settlement agreement for $510,000 represents an amount due HUD.

We recommend that the Acting Deputy Assistant Secretary for Grant Programs require the State to develop and implement policies and procedures to document and perform detailed review and testing to establish eligibility, existence, disaster event qualifications, reasonableness of cost estimates, prioritization, and fund allocation, both retroactively and prospectively, which would put $81,982,712 to better use.

We recommend that the Acting Deputy Assistant Secretary for Grant Programs require the State to support or properly obligate $11,717,288 in unsupported obligations.

Reimburse its program $28,199 ($19,771 $7,793 $635) from non-Federal funds for the overpayment of housing assistance and ineligible administrative fees it received for the deficiencies cited in this report.

We recommend that the Director of the Public Housing Financial Management Division determine whether any of the overpayment of $3,630,286 was ineligible and take appropriate actions to recoup the ineligible payments.

We recommend that the Director of the Public Housing Financial Management Division validate the $1,191,767 in underpayments and determine if any corrections should be made.

We recommend that the Director of the Public Housing Financial Management Division recapture the overpayment of $116,218 disbursed for the units, which exceeded the PHAs’ Faircloth limit.

Provide documentation to support program accomplishment data related to disbursements totaling $292,611 or repay HUD from non-Federal funds for any amount that it cannot support.

Complete the implementation of the new accounting system and ensure it tracks program funds to a level that supports compliance with HUD requirements.

Provide support that $944,687 (Footnote 2: Emergency funds of more than $1.1 million drawn between July 1, 2011, and December 31, 2015, were adjusted to consider $158,800 questioned in recommendation 1C and $38,164 questioned in recommendation 1D.) in Emergency funds drawn from HUD is reconciled with the accounting records and that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes or reimburse the Emergency programs from non-Federal funds.

Reimburse $189,227 to the Emergency programs from non-Federal funds for ineligible charges made to the programs.

Submit supporting documentation showing the eligibility, reasonableness, and allocability of $38,164 charged to the Emergency programs for unsupported drawdowns and equipment cost allocations or reimburse the programs from non-Federal funds.

Direct the New Orleans, LA, field office to enforce its monitoring findings and require the grantee to provide documentation to support costs totaling $4,959,911 or the grantee must reimburse its program from non-Federal funds for any costs that it cannot support.

Enforce the Miami, FL, field office’s monitoring findings and require the grantee to provide documentation to support costs totaling $1,161,616 or the grantee must reimburse its program from non-Federal funds for any costs that it cannot support.

Direct the Washington, DC, field office to require the grantee to provide documentation to support the $1,766,778 in unsupported payments identified or the grantee must reimburse its program from non-Federal funds for any costs that it cannot support.

Direct the Washington, DC, field office to require the grantee to repay its program $4,214 from non-Federal funds for the ineligible costs associated with activity 1515.

Direct field offices to include property acquisition and disposition activities as an area of special emphasis when assessing grantee risk and establishing their monitoring plans and grantee monitoring strategies.