HUD develop and implement controls to ensure that the provisions of Section 4712 are included in all contracts.
2023-IG-002 | Mayo 31, 2023
Management Alert: HUD Should Take Additional Steps to Protect Contractor Employees Who Disclose Wrongdoing
Other
- Status2023-IG-002-5OpenClosed
2023-CH-0004 | Mayo 30, 2023
HUD Can Improve Its Oversight of the Physical Condition of Public Housing Developments
Public and Indian Housing
- Status2023-CH-0004-001-AOpenClosedClosed on Marzo 26, 2024PrioridadPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
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.
- Status2023-CH-0004-001-BOpenClosedClosed on Abril 02, 2024PrioridadPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
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
As part of the agreed upon management decision, HUD stated that it would provide dates of office hours and specific training related to NSPIRE and the expectations for all types of defects as evidence to close this recommendation. These events will cover: 1) reviewing physical inspection reports to effectively ensure that PHAs correct physical deficiencies, (2) how PHAs should address or correct each type of deficiency observed in the REAC physical inspection report, including life-threatening and severe defects (formerly known as EHS under UPCS) as well as the non-life threatening type, and (3) to use PASS or any future tracking system. Additionally, HUD would provide evidence that training occurred such as logs, sign in sheets, screenshots of total Teams meeting attendees, etc., and copies of the training materials used such as power point slides or meeting handouts.
However, to close the recommendation, HUD provided only a screen print showing that 257 attendees participated in a one-hour training session, held via TEAMs. It did not provide copies of training materials, handouts, or power point slides. Additionally, HUD also did not provide evidence that it has scheduled or held office hours allowing staff to join and ask questions related to life-threatening deficiencies. Therefore, OA objects to the closure of this recommendation.
- Status2023-CH-0004-001-COpenClosedClosed on Marzo 26, 2024PrioridadPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
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.
- Status2023-CH-0004-002-AOpenClosedClosed on Septiembre 20, 2023
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.
- Status2023-CH-0004-002-BOpenClosedClosed on Septiembre 20, 2023
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.
- Status2023-CH-0004-002-COpenClosedClosed on Agosto 22, 2024PrioridadPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
Develop and implement a nationwide protocol for field offices, describing how PHA self-inspections should be reviewed, based on REAC's determination of the number and frequency of PHA self-inspections.
Status
The Office of Field Operations will develop and implement a nationwide protocol for field offices, describing how Public Housing Agency (PHA) self inspections should be reviewed, based on Real Estate Assessment Center’s determination of the number and frequency of PHA self-Inspections. Enforcing the requirements of inspection timing are dependent upon software changes to NSPIRE.
The final action target date is August 15, 2024.
Analysis
To fully address this recommendation, HUD must provide evidence demonstrating that it has implemented control activities to ensure that public housing properties are inspected within required timeframes. Implementation of this recommendation will result in HUD accurately tracking the dates in which public housing properties should be inspected and that they are timely completed.
2023-CH-1002 | Mayo 24, 2023
The Stark Metropolitan Housing Authority, Canton, OH, Did Not Always Comply With Federal and Its Own Procurement Requirements
Public and Indian Housing
- Status2023-CH-1002-001-AOpenClosedClosed on Junio 13, 2024$80,685Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
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.
- Status2023-CH-1002-001-BOpenClosedClosed on Mayo 10, 2024
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.
- Status2023-CH-1002-001-COpenClosedClosed on Septiembre 30, 2024$48,310Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
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.
- Status2023-CH-1002-001-DOpenClosed$57,902Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to support the reasonableness of $57,902 paid to three vendors 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.
- Status2023-CH-1002-001-EOpenClosed
For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to support the reasonableness of the change orders that increased the price of the contract (0216) by more than $1.1 million or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable.
- Status2023-CH-1002-001-FOpenClosed
For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to support the contract modifications and the reasonableness of the increased costs for four contracts (0824, 0505, 1023 and 0731) or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable.
- Status2023-CH-1002-001-GOpenClosedClosed on Febrero 02, 2024
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.
- Status2023-CH-1002-001-HOpenClosed
For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to implement adequate procedures and controls, including but not limited to ensuring that (1) proper documentation is maintained, (2) contracts are procured in accordance with Federal and the Authority’s procurement requirements, (3) procurement staff complies with Federal procurement requirements, and (4) payments are appropriately reconciled.
- Status2023-CH-1002-001-IOpenClosedClosed on Septiembre 06, 2023
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.
2023-CH-0003 | Mayo 23, 2023
Improvements Are Needed To Ensure That Public Housing Properties Are Inspected in a Timely Manner
Public and Indian Housing
- Status2023-CH-0003-001-AOpenClosed
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.
- Status2023-CH-0003-001-BOpenClosedPrioridadPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
Implement adequate policies, procedures, and controls to ensure that public housing properties will be inspected within required timeframes.
Status
While the NSPIRE regulations on inspection timing are completed, the Real Estate Assessment Center is not able to make the required modifications in the NSPIRE system to enforce the regulatory guidelines as this time. HUD is uncertain whether the vendor can make the needed modifications or if additional funding is needed. As of June 2024, PIH was not able to provide an expected time of when HUD will be able to make that determination.
Analysis
To fully address this recommendation, HUD must provide evidence demonstrating that it has implemented control activities to ensure that public housing properties are inspected within required timeframes. Implementation of this recommendation will result in HUD accurately tracking the dates in which public housing properties should be inspected and that they are timely completed. Due to the uncertainty of when software changes to NSPIRE can take place to enforce the timing of inspections, REAC cannot enforce the requirements of inspection timing.
2023-FO-0009 | Mayo 22, 2023
HUD Did Not Comply with the Payment Integrity Information Act of 2019
Chief Financial Officer
- Status2023-FO-0009-001-AOpenClosed
Establish an improper payment council within HUD that consists of senior accountable officials from across the Department with a role in the effort that would work to identify risks and challenges to compliance and identify solutions as a collaborative group.
- Status2023-FO-0009-001-BOpenClosedClosed on Marzo 12, 2024
Develop and complete a detailed plan and timeline for completing compliant PIH-TBRA and PBRA program estimates and ensure that the improper payment council prioritizes completion of the plan in time for fiscal year 2023 reporting.