We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to employees involved in the funding and expenditure processes to ensure compliance with HUD, Federal, and Authority requirements

Work with the Authority to determine whether the buildings represent an imminent threat to public safety from physical deterioration and whether activities to control the situation would be exempt under the Part 58 environmental review process or excluded under the Part 50 environmental review Read More

Determine whether it would be beneficial for HUD to conduct a Part 50 environmental review of the development or if the Authority should conduct a Part 58 environmental review, and implement the decision to ensure that the environmental review is conducted as soon as possible as required under the Read More

Continue to provide training and technical assistance to ensure that the Authority understands relevant requirements for the various asset repositioning options, including milestone and disposition requirements.

Provide certifications and supporting documentation to show that it has identified and addressed urgent health and safety issues at the development, such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors.

Develop and implement a plan to routinely identify and address recurring urgent health and safety issues such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors while the property remains vacant and throughout future asset repositioning efforts.

Develop and implement a plan to use available asset repositioning options for the remaining 284 public housing units at the Commodore Perry Homes development, including 274 dwelling units and 10 nondwelling units.

Develop and implement a plan for the original property related to the 46 units converted under the RAD transfer of assistance option to ensure that the property and proceeds from its disposition are used in accordance with requirements.

If the Authority does not follow through on its asset repositioning plans, misses deadlines, or it otherwise becomes clear that the plan is no longer feasible, work with the HUD’s Special Applications Center, Office of Recapitalization, and other offices as appropriate, to consider and use Read More

We recommend that the Director of CPD’s Office of Disaster Recovery review the one grantee with a grant totaling $666,666 that did not meet the overall LMI requirement and address the noncompliance.

We recommend that the Director of CPD’s Office of Disaster Recovery update DRGR’s QPR to include information on the progress towards compliance with the overall LMI benefit based on the total amount of the grant.

We recommend that the Director of CPD’s Office of Disaster Recovery adopt LMI benchmarking to ensure that grantees budget adequate funds to LMI at significant milestones in the grant lifecycle.

We recommend that the Director of CPD’s Office of Disaster Recovery make changes to the action plan process so that the action plan calculates an overall LMI percentage.

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.

Certify, along with the owners of the 61 units cited in the finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $46,605 from non-Federal funds ($44,214 for housing assistance payments and $2,391 in associated administrative fees) for the 22 units that materially failed to meet HUD’s housing quality standards.