We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to show that the $583,920 paid to two vendors for purchase orders below the Authority’s micropurchase limit was for prices that were reasonable or reimburse its Operating Fund from non-Federal funds for any amount that it cannot support or is not considered reasonable.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to show that $842,931 paid under five contracts was for prices that were reasonable or reimburse its Operating Fund for any amount that it cannot support or is not considered reasonable.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls over purchases to ensure compliance with HUD, Federal, and Authority procurement requirements. This includes, but is not limited to, controls to ensure that it (1) maintains records sufficient to detail the significant history of procurements, (2) complies with requirements for each type of procurement, (3) obtains independent cost estimates and performs cost or price analyses when required, and (4) prevents and detects conflict-of-interest situations.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to its staff to ensure compliance with HUD and Federal procurement requirements.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify the $372,695 in unsupported Operating Fund subsidies received or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to reimburse its Operating Fund from non-Federal funds $82,907 for 16 document management services contract payments that should have been paid with COCC funds.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls to ensure that operating funds are requested, received, and used in accordance with HUD, Federal, and Authority requirements.

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

We also recommend that the Director of HUD’s Departmental Enforcement Center evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.