Implement a quality control process for monitoring its contracted inspectors to ensure that units meet HUD’s requirements to prevent nearly $36 million in program funds from being spent on units that do not meet HQS over the next year.

Implement procedures and controls regarding its quality control inspections to ensure that the results of those inspections are appropriately used to evaluate and monitor the performance of the Authority’s contracted inspectors and documentation is maintained on communications with the contractor on corrective actions taken to address recurring inspection deficiencies.

Pursue collection from the applicable owner or reimburse its HCV Program $5,194 from non-Federal funds for HAP that was not properly stopped for two units with outstanding HQS deficiencies.

Provide support showing whether HAP was appropriately stopped for the four units cited in the finding or reimburse or pursue collection of $10,233 from non-Federal funds for HAP to owners with outstanding HQS deficiencies.

Implement procedures and controls regarding its stop payment process to ensure that it consistently (1) stops payments as required by its HCV Program administrative plan and HUD requirements, (2) verifies and documents the correction of deficiencies, and (3) maintains sufficient documentation to support the stop payment for each unit.

Implement controls over its inspection processes and procedures to ensure that emergency failures are properly identified, reinspected, and corrected within 24 hours in accordance with its HCV Program administrative plan or the housing assistance to the owner is stopped.

Work with its contractor to ensure that the contractor’s inspectors receive training on how to properly identify and categorize life-threatening deficiencies.

Develop and implement policies and procedures that align with HUD’s requirements and controls to ensure that owners follow the requirements of the LSHR.

Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide technical assistance to the Authority’s staff to develop and implement policies, procedures, and controls for managing cases of children with EBLLs to ensure compliance with the LSHR, including attempts to collaborate with public health departments to identify cases of EBLL in children under 6 years of age under its HCV Program and updating its policies and procedures accordingly.

Work with PRDOH to determine whether its current method of measuring how many applicants purchased their home through the program is the best way to measure the HBA program’s impact.

Based on the results of recommendation 1A, update the HBA guidelines and the Puerto Rico disaster recovery action plan.

Instruct PRDOH and PRHFA to develop and implement clear and consistent guidelines and procedures that establish a verifiable methodology for determining the amount of financial awards granted to eligible HBA participants.

Include, as part of the revised procedures, a requirement to document within each case in SSP a detailed (1) calculation of the household income and (2) the analysis and computations conducted by the PRHFA underwriter for determining the amount of the financial assistance award.

Instruct PRDOH and PRHFA to provide training and guidance to participating lending institutions related to the updated guidelines and procedures for determining the financial award granted to HBA participants to ensure that program funds are distributed in an equitable manner.

We recommend that HUD require the City to reassess the eight infrastructure projects still in the design or planning phase to determine whether the City can complete the projects or how the remaining funds could be best used within the 6 years remaining for the grant period to ensure that the City is protected from future storm and rain events.

We recommend that HUD require the City to for the $14,683,335 originally budgeted for the Milneburg and Microgrid projects, work with HUD to (1) determine whether its planned action plan amendment would constitute the need to submit a substantial action plan amendment, (2) ensure that any modifications in its action plan amendment would lessen the susceptibility of rain and flood events within the Gentilly area, and (3) require that any activities pursued under the action plan amendment could reasonably be expected to be completed by the September 30, 2029, deadline.

We recommend that HUD require the City to review the number and type of positions for its National Disaster Resilience staff that are responsible for the oversight and completion of infrastructure projects and ensure that it has the appropriate staffing levels to complete adequate monitoring and oversight of the projects.

We recommend that HUD require the City to revise its risk assessment plan and process to ensure that monitoring is regularly conducted for its infrastructure projects through project completion, including establishing a monitoring schedule to ensure the progression and completion of the infrastructure projects.

We recommend that HUD require the City to develop and submit to HUD for approval an updated planning and administration budget and staffing plan, after reassessing the infrastructure projects in recommendation 1A, to complete the National Disaster Resilience projects with the funds and within the timeframe remaining.

We recommend that HUD require the City to analyze the method used to charge planning and administration costs to ensure that all costs are applied to the correct costs category and are valid charges to the National Disaster Resilience grant.