We recommend that the Director of HUD’s New York Office of Public and Indian Housing require the Authority to provide documentation to show that $108,061 in property disposition proceeds was used for the activities outlined in its HUD-approved disposition application and modifications or reimburse its Operating Fund from non-Federal funds for any amount not supported.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require the Authority to obtain retroactive approval from HUD for the $61,545 in property disposition proceeds used for Rental Assistance Demonstration conversion costs or reimburse its Operating Fund from non-Federal funds for any amount for which it does not obtain approval.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require the Authority to reimburse its Operating Fund from non-Federal funds for $11,173 spent on ineligible activities funded by $369 in property disposition proceeds and $10,804 in tenant participation funds.

We recommend that the Director of HUD’s New York Office of Public and Indian Housing require the Authority to strengthen its controls to ensure that $1,074,979 in remaining property disposition proceeds and any outstanding loans and other funds to be repaid will be put to better use as intended to benefit the Authority’s residents. These controls include controls to ensure that proceeds are used in accordance with the HUD-approved disposition application, adequate supporting documentation is maintained, and the source and use of funds is properly recorded in the Authority’s books and records and reported to HUD.

Develop and implement an inspection process for the Section 232 program that better reflects those properties’ physical conditions and how those properties differ from other properties REAC inspects (for example, multifamily properties).

Ensure that all areas of the properties are inspected, including the roofs and all buildings located on the property that is insured by HUD.

Repay the Housing Choice Voucher program from non-Federal funds the $281,929 in ineligible retroactive housing assistance payments.

Develop and implement internal control procedures to ensure that housing assistance funds appropriated for 1 calendar year are not used to make retroactive housing assistance payments for prior years.

Repay the Housing Choice Voucher program from non-Federal funds the $32,682 in ineligible housing assistance overpayments made due to program errors.

Develop and implement internal control procedures to ensure that housing assistance payments resulting from errors of Authority officials are covered by the Authority’s administrative fees.

Develop and implement internal control procedures to ensure that housing assistance payments are not made to owners without a properly executed lease and housing assistance payments contract.

Develop and implement internal controls to ensure that housing assistance payments discontinue once a program participant is absorbed into another public housing agency’s program or leaves the program.

Provide support showing that the repayment of housing assistance overpayments found by the Authority were received.

Work with OCFO to develop a consistent and reasonable methodology for determining the PIH prepayment, which (1) allows for timely recording of financial events, (2) complies with GAAP, and (3) provides an adequate audit trail until the cash management process is automated.

Reopen recommendation 2016-FO-0003-002-D, “Develop a tracking function for the payments advanced to IHBG recipients to facilitate financial reporting and monitoring compliance with grant time restrictions.”

Review the one identified retained inactive obligation with a remaining balance totaling $765,000 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

For all 32 debts not under repayment agreement, (1) send demand letters for any debts for which a demand letter has not been sent and (2) aggressively work with the PHAs to determine appropriate repayment agreement terms.

Establish procedures to ensure that the debt file is sent to the OCFO DCCO for claim establishment if initial collection attempts prove unsuccessful.

Establish procedures to routinely send all debts (delinquent or not) to OCFO for evaluation as required by the debt collection handbook.

Finalize the repayment agreement procedures and implement training to ensure that all of PIH is aware of the procedures. The repayment agreement procedures should ensure that PIH follows HUD’s debt collection handbook.