We conducted a review of the Philadelphia Housing Authority’s compliance with Federal lobbying disclosure requirements and restrictions based on concerns noted during our ongoing internal audit of the U.S. Department of Housing and Urban Development’s (HUD) oversight of public housing authorities’ compliance with Federal lobbying disclosure requirements and during the resolution of recommendations from our prior audit report concerning the Authority’s payments for outside legal services (report #2011-PH-1007). Our review objective was to determine whether the Authority complied with Federal lobbying disclosure requirements and restrictions.

We found that the Authority engaged in the prohibited practice of using Federal funds for lobbying and Carl R. Greene, the former executive director, certified that it did not do so. In addition, Mr. Greene falsely certified on at least five occasions that the Authority did not use non-Federal funds for lobbying activities.

We recommended that HUD’s Associate General Counsel for Program Enforcement pursue remedies under the Program Fraud Civil Remedies Act and take administrative action up to and including debarment against the Authority’s former executive director Carl R. Greene for falsely certifying to HUD that the Authority did not participate in lobbying activities. We also recommended that the Director of HUD’s Pennsylvania State Office of Public Housing ensure that responsible Authority officials are formally trained in lobbying disclosure requirements and restrictions and that all future HUD monitoring of the Authority covers compliance with Federal lobbying disclosure requirements and restrictions.