We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to reimburse its program $28,303 from non-Federal funds ($26,044 for housing assistance payments and $2,259 in associated administrative fees) for the six units that materially failed to meet HUD’s housing quality standards.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to improve controls over its inspection process to ensure that program units meet housing quality standards and that the results of inspections are used to enhance the effectiveness of its housing quality standards inspections, thereby ensuring that an estimated $760,363 in future program funds is spent for units that meet HUD’s housing quality standards. These controls include but are not limited to controls to ensure that (1) inspectors apply their training to thoroughly inspect units and consistently categorize failure items, (2) inspectors use a form that includes the key aspects of housing quality standards performance and acceptability criteria, and (3) results data are accurate and comply with applicable requirements.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to improve controls over the housing quality standards quality control inspections to ensure that quality control inspections meet HUD’s minimum sample size and that the sample is drawn from recently completed housing quality standards inspections.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require HPD to improve controls over its abatement process to ensure that it consistently (1) starts abatement when required, (2) verifies and documents the correction of violations, (3) resumes housing assistance payments after the end of the abatement period, and (4) maintains sufficient documentation to support the abatement and reinstatement for each unit.

Provide documentation to show that it purchased products and services totaling $728,516 at fair and reasonable prices or reimburse either its Operating or Capital Fund from non-Federal funds for any amounts that it cannot support.

Provide documentation to show that it had contracts for dumpster rentals and pest control services, and if it cannot provide the contracts, re-procure these services.

Obtain written agreements with the originating public bodies for its ongoing awards that were procured through intergovernmental agreements, including dumpster rentals, maintenance supplies, and consulting services, and if it cannot provide the agreements, re-procure these services.

Develop and implement controls to ensure that it complies with all applicable procurement requirements.

Provide technical assistance to the Authority to ensure that it understands Federal procurement requirements, including the proper use of intergovernmental agreements.

Update its administrative plan to ensure compliance with applicable regulations. Minimally, the administrative plan should clearly define the weights and rankings of the preference system and ensure that the residency preference complies with regulations.

Reevaluate the cases of the 131 applicants to whom it did not award residency points and award points as appropriate.

Update its waiting list as needed after completing corrective action for recommendation 1B.

Develop and implement policies and procedures to ensure that it administers its waiting list according to the requirements in its administrative plan, including maintaining documentation to show that it properly selected applicants from the waiting list.

Develop and implement procedures for performing quarterly interim recertifications for families reporting zero income.

Develop and implement controls to ensure that it follows the procedures it develops and implements to resolve recommendation 1E.

Provide documentation to show that the family that received the benefit of the $2,463 overpayment in housing assistance reimbursed the program or repay its program from non-Federal funds for any amount not reimbursed by the family.

Provide technical assistance to the Authority to ensure that it properly manages its waiting list, properly uses its preference point system, and selects applicants in accordance with applicable requirements.

As part of reopened recommendation 1B, correct the deficiencies within applicable PTD reports, including missing or inaccurate records for the 10 grants identified in this CAV.

Provide support of eligibility or require lender repayment of $5,115,079 for the 822 identified claims with a reported partial claim or loan modification within the prior 24 months.

Further revise and implement Single Family Insurance System – Claims Subsystem controls to address deficiencies that allowed payment for a limited number of claims that were ineligible due to prior loan modification or FHA-HAMP option within 24 months.