Confirm the replacement of program units was appropriate for the number of units demolished at Johnson Ferry East, and submit a development proposal to construct new public housing units, transfer public housing assistance to another public housing agency, or terminate its annual contributions contract and return all unobligated and unexpended capital funds to HUD.

Certify, along with the owners of the 11 units cited in this finding, that the applicable housing quality standards violations have been corrected.

Reimburse its program $9,715 from non-Federal funds ($9,660 for housing assistance payments and $55 in associated administrative fees) for the unit that materially failed to meet HUD’s housing quality standards.

Provide training to its inspectors on conducting housing quality standards inspections.

Pursue departmental clearance for the July 25, 2013, guidance that did not go through required departmental clearance. For any items that cannot be appropriately cleared, HUD should take appropriate action to recall the document or policy.

Develop guidance that helps the public understand its options for assistance between CDBG-DR and SBA and how to comply with Federal requirements.

Develop and implement a written methodology for employees’ time allocations for its HUD grant programs in accordance with program requirements.

Provide training on compensation for personal services grant program requirements to employees working on HUD grants.

Support $142,181 spent on payroll allocated to HUD grants or repay the program from non-Federal funds.

Provide supporting documentation or reimburse its Program $81,654 from non-Federal funds for unsupported on-the-job training costs incurred under project FL0220L4D001407.

Provide supporting documentation or reimburse its Program $1,023 from non-Federal funds for unsupported personal cell phone costs incurred under project FL0220L4D001407.

Provide guidance to subrecipients to ensure that (1) on-the-job training hours are supported by source documents, such as signed attendance or time sheets, and (2) personal goods and services are supported by documents that show the allocation between business and personal use.

Report Program income of $31,724 for FL0199L4D001407 to HUD.

Provide supporting documentation to show that participant 87487 from FL0431L4D001403 was chronically homeless or reimburse its Program $15,756.

Perform onsite monitoring of the subrecipient that administered project FL0431L4D001403 to ensure that participants are eligible and annual income re-certifications are performed.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing Investments direct staff to determine whether the nine PHAs that were classified as troubled or physically substandard have public housing developments that are subject to the required conversion requirements to support whether potentially distressed projects should be converted to tenant-based rental assistance. If conversion is required, ensure that it is accomplished timely, thereby ensuring that up to $75,540,916 is used effectively for other projects that are cost effective and have long term viability and ensuring that residents receive other rental assistance. Footnote: The $75 million cited as funds to be put to better use is based on an analysis of available data. We recognize that the 131 PHAs cited in this report, including the 9 PHAs that comprise the $75 million figure, may not have projects with at least 250 units on one or more contiguous sites that have vacancy rates of 12 percent or more. However, the data did not allow us to calculate vacancy rates for each group of contiguous units, and HUD could not provide a reasonable, supported method to identify projects subject to required conversion. To address this recommendation, HUD will need to determine whether these PHAs have projects that are subject to required conversion.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing Investments direct staff to develop and implement policies and procedures with the Office of Field Operations regarding identification of potentially distressed projects and monitoring and enforcement of the required conversion program.

We recommend that the Program Center Coordinator, Office of Public Housing, Oklahoma City, OK, require the Authority to repay $12,739 from non-Federal funds to its Section 8 program for ineligible payments based on incorrect housing assistance payment calculations, incorrect payment standards and utility allowances, and unreported income.

We recommend that the Program Center Coordinator, Office of Public Housing, Oklahoma City, OK, require the Authority to support or repay $28,574 from non-Federal funds to its Section 8 program for unsupported payments based on questionable income calculations.

We recommend that the Program Center Coordinator, Office of Public Housing, Oklahoma City, OK, require the Authority to strengthen its compliance with requirements by implementing a quality control system that would require management to review a sample number of income calculations, ensure staff follow-up on income discrepancies and document their analysis.