For each youth referred, require PHAs to obtain PCWA certification that the PCWA will provide or secure access to supportive services.

Include FYI in its voucher risk assessment and develop and implement monitoring policies, procedures, and controls.

Establish and implement methods to regularly assess the effectiveness of the program in preventing and ending youth homelessness and improving participants’ self-sufficiency, which could include performance metrics and periodic studies performed by the Office of Policy Development and Research (PD&R).

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to establish and implement procedures and controls to ensure that lead-based paint visual assessments are performed within the required timeframe.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to implement adequate procedures and controls to ensure that lead-based paint hazard reduction work is performed within the required timeframe and that all identified hazards are abated or treated with interim controls.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to maintain lead-based paint documentation for its properties in a manner that it is readily available for review by HUD and the Authority’s tenants if requested.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to perform a search for historical lead based paint documentation and if any documents are found, compare the results from the historical documents with the results of the recent testing to identify any potential issues or inconsistencies and maintain all lead-based paint documentation related to the Authority’s properties according to HUD’s requirements.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to Implement adequate procedures and controls to ensure that accurate lead disclosures are provided to current and prospective tenants.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to implement adequate controls to ensure that contracted inspectors’ deliverables comply with HUD’s and EPA’s requirements.

We also recommend that the Director of the Philadelphia Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training to the Authority’s staff involved with managing lead-based paint and technical assistance in developing and implementing new procedures and controls.

We also recommend that the Director of the Philadelphia Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to assess the quality of the lead-based paint inspections and risk assessments performed by the Authority’s contractors to determine whether they are sufficient to fulfill HUD’s requirements.

We recommend that the Deputy Assistant Secretary for Public Housing and Voucher Programs enhance SEMAP or develop a new performance measurement process that would identify PHAs with underperforming HCV Programs, which should include an assessment of PHAs’ ability to maximize assistance to house families.

We recommend that the Deputy Assistant Secretary for Field Operations Provide additional training and guidance to field office program staff on SEMAP scoring, rating, and verification procedures, including confirmatory reviews, quality control reviews, and adjustments to the SEMAP process.

We recommend that the Deputy Assistant Secretary for Field Operations provide training and guidance to field office program staff on SEMAP scoring, rating, and verification procedures, including confirmatory reviews, quality control reviews, and adjustments, as appropriate, for the revised SEMAP process.

Consider conducting an analysis of staffing resources needed to manage the REO and notes sales on tribal trust properties program and adjust staffing accordingly.

In conjunction with corrective actions being taken on previous audits, revise ONAP’s internal policy and procedures to include detailed written policies and procedures for the marketing, preservation, and sale of defaulted loan notes and REO properties on tribal trust and other restricted lands.

Work with the Office of the Chief Information Officer to develop an electronic solution, such as a new module in Native Advantage or one similar to FHA’s P260 tracking system, to track the sale of defaulted loan notes and REO properties on tribal trust and other restricted lands. While the solution is being developed, HUD should put controls into place to ensure that manual systems used to track defaulted loans and REO properties are complete and accurate.

We recommend that the General Deputy Assistant Secretary for Public and Indian Housing require the Real Estate Assessment Center in coordination with the Office of Field Operations to develop and implement a plan to manage lead-based paint and lead-based paint hazards in public housing.

Requires the REAC in coordination with OFO to determine the number of developments and associated units that contain lead-based paint and lead-based paint hazards.

Status

In May 2023, HUD published a final rule establishing a new approach to defining and assessing housing quality: The National Standards for the Physical Inspection of Real Estate. Public Housing regulations were amended, and Public Housing program participants were required to comply with this final rule and use the NSPIRE standards starting July 1, 2023. The Real Estate Assessment Center and Office of Field Operations will collaborate with the Office of Lead Hazard Control and Healthy Homes, the Office of Policy Development and Research, and a statistician to evaluate data collected under the NSPIRE inspection program to estimate the number of public housing developments and associated units that contain lead-based paint and lead-based paint hazards. As of November 2024, PIH reported that inspections have had a slow start due to procurement delays. Additionally, the NSPIRE system did not get the requested functionality to collect lead inspections. The final action target date is March 31, 2025.

Analysis

To address this recommendation, HUD will need to provide evidence that it collected and evaluated data under NSPIRE and estimated the number of public housing developments and associated units that contain lead-based paint and lead-based paint hazards.

Implementation of this recommendation will assist HUD in working with PHAs to address the public housing units that contain lead-based paint and lead-based paint hazards and help HUD’s oversight of units in need of hazard reduction.

We recommend that the General Deputy Assistant Secretary for Public and Indian Housing require the Real Estate Assessment Center in coordination with the Office of Field Operations to determine the cost to eliminate or control the lead-based paint and lead based paint hazards in public housing and the timeframe to complete such work based on the existing funding levels and strategies that could accelerate the timeframe.