Update policies and procedures to include methods that will be used when applications exceed underwriter capacity, align intake and screening processes, and explain when timeframes will be enforced, including in PLUS.

Issue an industry wide letter to reinforce how intake, screening, and enforcement of timeframes will be handled.

Improve or enhance its antifraud efforts for the ESG program and incorporate fraud risk management practices that are consistent with the best practices identified in the Government Accountability Office’s A Framework for Managing Fraud Risks in Federal Programs and Chief Financial Officers Council and Treasury Bureau of the Fiscal Services’ Antifraud Playbook.

Obtain training or technical assistance as needed on the implementation of fraud risk management practices.

Establish a separate fraud risk management framework or evaluate and build upon its ERM framework by incorporating fraud risk management practices that are consistent with the principles of GAO’s Standards for Internal Control in the Federal Government (Green Book), including developing a fraud risk management framework in alignment with best practices identified in GAO’s A Framework for Managing Fraud Risks in Federal Programs and the Chief Financial Officers Council’s Antifraud Playbook.

Obtain training or technical assistance on the implementation of fraud risk management practices consistent with the principles of GAO’s Standards for Internal Control in the Federal Government (Green Book).

Update relevant policies and procedures for appraiser roster management so that they align with each other and with regulations and reflect HUD practice. At a minimum, the policies and procedures should clearly cover appraiser roster status, license expiration, disciplinary actions, removals, data accuracy, and documentation.

Maintain historical data for each appraiser record, including history on expiration dates, when appraisers are moved on or off the appraiser roster and when they are and are not allowed to be assigned to conduct appraisals.

Improve quality assurance processes by adding steps to verify that the appraiser roster is accurate and reliable over time through testing of its logic-based system controls and data fields.

Develop and implement adequate procedures to ensure that confirmed EBLL cases, unconfirmed EBLL cases, and environmental investigations are reported to HUD.

Develop and implement adequate procedures and controls to ensure that environmental investigations are completed when required.

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.