We recommend that Director of the Houston Office of Public Housing require the Authority to update and implement its policies and procedures, including creating a policy for recording expenses, a cost allocation plan, and a travel policy, to ensure that the Authority appropriately pays and accurately reports its costs.

We recommend that the Director of the Houston Office of Public Housing require the Authority’s new board to complete HUD’s “Lead the Way” online training and Texas’ Open Meetings Act training.

We recommend that the Director of the Houston Office of Public Housing require the Authority’s new board to review the board minutes during our audit period, determine which board decisions were invalid, and take action to address the invalid decisions.

We recommend that the Director of the Houston Office of Public Housing require the Authority’s new board to revise its bylaws to agree with the Texas Open Meetings Act.

Establish and implement a plan to assist public housing agencies in optimizing leasing potential to maximize the number of assisted families and prevent additional vouchers from becoming unfunded. The plan should include but not be limited to (1) addressing the circumstances that prevent public housing agencies from leasing vouchers and assessing whether legislative, policy, or funding changes are needed to optimize voucher use and (2) establishing timeframes to lease vouchers for those public housing agencies that can lease vouchers and determining appropriate corrective actions for those public housing agencies that do not increase their leasing to prevent additional vouchers from becoming unfunded.

Establish and implement a plan for the unused and unfunded vouchers to mitigate or prevent additional vouchers from becoming unused and unfunded […]

Corrective Action Taken

HUD established and implemented a plan for the unused and unfunded vouchers, aiming to mitigate or prevent additional vouchers from becoming unused and unfunded. PIH's plan included the following, among other actions:

• Determining the scope of HUD's statutory and regulatory authority to offset and reallocate vouchers.
• Issuing Office of Public and Indian Housing Notice 2020-29, titled Guidance for Running an Optimized Housing Choice Voucher Program.
• Continuing the work of HUD's landlord taskforce, engaging in listening sessions with major PHA industry groups, and conducting outreach to increase landlord participation in the HCV Program.
• Developing research by HUD's Office of Policy Development and Research on the best methods for adjusting fair market rents and addressing specific challenges in local communities to increase utilization in the HCV Program.

Establish and implement a process to ensure that CPD’s supervisory controls are effective related to its staff’s requirement to contact grantees following a disaster. This process should also integrate with other HUD program offices as appropriate to improve consistency with HUD’s overall disaster response and to ensure the effectiveness of disaster controls.

Establish and implement a process to ensure that ONAP’s policies and procedures are effective. This process should address the identification of presidentially declared disaster areas and the requirement to contact disaster-affected housing entities. This process should also integrate with other HUD program offices as appropriate to improve consistency with HUD’s overall disaster response and to ensure the effectiveness of disaster controls.

Improve the Office of Public Housing’s procedures with written guidance to ensure that its staff formally tracks outreach to PHAs.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to provide documentation, including but not limited to showing that it (1) notified and allowed a response from bidders regarding the bidding and scoring processes; and (2) awarded home repair master agreement contracts without restriction and were in line with the bid evaluation requirements, or provide a documented re-evaluation of the procurement showing that it provided the best advantage to it and HUD, thereby putting the remaining $9,736,636 award amount to better use.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to support $1,063,364 or repay its CDBG-DR program from non-Federal funds for payments made to one prequalified contractor under its home repair program without independent cost estimates and cost analyses.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to support $170,066 or repay its CDBG-DR program from non-Federal funds for payments made to the demolition contractor under its housing buyout program without independent cost estimates and cost analyses.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to support $27,250 or repay its CDBG-DR program from non-Federal funds for payments made to three appraisal contractors under its housing buyout program without cost analyses.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to develop and implement a HUD-approved written plan and checklists that will correct and prevent the deficiencies outlined in the finding.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to provide training to City staff to ensure that it understands and follows procurement requirements, such as performing independent cost estimates, cost analysis, scoring, including all contract provisions, ensuring that subrecipients understand and follow procurement requirements, and maintaining appropriate procurement documentation.

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to Update its procurement policies and procedures to ensure compliance with disaster assistance program requirements

We recommend that the Director of HUD’s Office of Community Planning and Development require the City to ensure that monitoring includes a review of its subrecipients’ (1) policies and procedures to ensure that the policies and procedures are current and comply with HUD requirements, (2) documentation supporting cost reasonableness to ensure that the documentation is sufficient, and (3) training provided regarding procurement and other program requirements to ensure that trainings are adequate.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to continuously monitor Harris County’s pace and performance in its remaining Hurricane Harvey CDBG-DR program and take appropriate action to ensure that program goals are met. The plan should include a process for repurposing additional grant funds, if necessary, to avoid potential recapture due to Harris County’s inability to meet the expenditure deadline established under its subrecipient agreement with the Texas GLO, and to allow the Texas GLO to meet the expenditure deadline for its grant award.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to set performance and financial milestones, including approval of Harris County’s projects and obligation and expenditure of funds, for all programs and activities funded under the Harris County subrecipient agreement through the remainder of the contract and deadlines for Harris County to achieve those milestones. This would include the Texas GLO (1) providing its plan to continually assess whether Harris County is meeting the established milestones within the prescribed time period; (2) taking appropriate action as outlined in the subrecipient agreement for any missed deadlines; and (3) , if necessary, determining whether additional programs need to be combined or eliminated from the subrecipient agreement.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide evidence of subrecipient monitoring of Harris County’s capacity to manage its Hurricane Harvey grant funds to address duplicative, inefficient, and cost-prohibitive processes or positions. The evidence should include any corrective actions that have been imposed and Harris County’s response.