Reimburse the project $296,787 from nonproject funds for the ineligible legal expenses.

Reimburse HUD $3,892 from nonproject funds for the overpayment of housing assistance.

Correct the errors in the tenant files identified during the audit.

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.

Develop and implement controls to minimize instances of overpayment and underpayment of housing assistance.

Ensure that all payments to Federal employees are included in HUD’s periodic risk assessment cycle.

Establish and implement procedures and controls, in coordination with FHA, to ensure that FHA information reported in the AFR is accurate and consistent with supporting documents.

Develop and implement steps to ensure that the description of corrective actions highlights current efforts and key milestones for ongoing efforts and explain in the AFR how it specifically tailored its corrective actions to better reflect the unique processes, procedures, and risks involved with RHAP as required by OMB.

Develop and implement steps to ensure that adequate disclosures are made when future-year reduction targets for improper payments reported in the AFR are higher than the current-year improper payment estimates.

Disclose in the AFR the results of HUD’s review concerning its current performance against program-specific improper payment reduction targets to promote transparency.

Reimburse NSP2 from non-Federal funds for the $59,523 in ineligible disbursements on the five vouchers.

Provide documentation to support that the $224,868 in NSP2 funds drawn down from the four vouchers was eligible or repay the program from non-Federal funds.