Support or reimburse its Block Grant program from non-Federal funds for the $107 it provided to the corporation for the January 2016 invoice that the corporation generally could not explain.

Implement adequate procedures and controls to ensure that the corporation reduces program income from its invoices for housing repair services.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $594,012 disbursed due to the use of multipliers was for eligible, reasonable, necessary, and supported costs or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation to show that the $2,689 disbursed due to a higher than required overtime rate was supported by documentation from the trade unions or reimburse its program from non-Federal funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to reimburse its program $1,198 from non-Federal funds for overpaid wages due to billing and payroll errors.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to pay $544 in unpaid wages to the subcontractors of the affected employees and submit evidence that these employees have been paid.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide training to its staff to help ensure compliance with applicable cost principle, procurement, and Davis-Bacon requirements.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that it has strengthened its invoice review process to ensure that costs are eligible and supported before disbursing Disaster Recovery funds.

We recommend that HUD’s Deputy Assistant Secretary for Grant Programs require the City to provide documentation showing that payments made under the Rockaway Boardwalk construction management services contract complied with Davis-Bacon and Related Acts requirements and that restitution is made to affected workers for any underpayments identified.

Require that the current or future lender ensure that the project uses a contractor that is proven to be qualified and capable of completing the project.

Implement a change to regulations at 24 CFR Part 203 to require curtailment of preforeclosure interest and other costs that are caused by lender servicing delays, resulting in $413,513,975 in funds to be put to better use. This should include updating or seeking statutory authority to update HUD’s regulations as necessary and coordinating with HUD’s Office of Finance and Budget, well before any changes go through departmental clearance, to ensure that planned curtailment requirements can be consistently enforced through the claims process.

Status

This audit recommendations cannot be closed out without the publication of the Federal Housing Administration (FHA): Maximum Claim Rule. The proposed changes have been on HUD’s regulatory agenda since Spring 2020 but, as of June 2024, the Office of Single Family Housing does not have an estimated publication date.

Analysis

To fully address this recommendation, HUD must publish the FHA Maximum Claim Rule.

Implementation of this rule should result in HUD putting $413 million to better use.

Provide adequate documentation to support that the $71,034 spent for improperly procured goods and services was spent at the most competitive prices. For any amounts not supported, it should reimburse its program from non-Federal funds.

Provide adequate documentation to support $15,280 spent for maintenance activities. For any amounts not supported, it should reimburse its program from non-Federal funds.

Develop and implement detailed operating procedures, including checklists, which fully implement its procurement policy and HUD requirements.

Ensure that its executive director obtains appropriate procurement training.

Work with the Authority to develop a formalized process, such as a checklist, to use when conducting initial certifications and annual recertifications, which would help to ensure that it follows HUD requirements for its public housing program.

Require the Authority’s executive director to obtain appropriate training regarding public housing occupancy requirements.

Require the Authority to conduct a 100 percent review of its tenant files to ensure that tenants’ rents are accurate and the proper income, asset, and medical expenses are complete and documented in the tenant files.

Monitor the Authority after the recommended training and tenant file reviews are complete to ensure that the executive director understands and properly implements public housing occupancy requirements.

Require the Authority to address actual or potential conflict-of-interest relationships in its Admissions and Continued Occupancy Policy.