Establish and implement additional procedures and controls to ensure that City personnel responsible for administering procurement on the Authority’s behalf follow procurement and contracting requirements and maintain applicable supporting documentation in accordance with HUD requirements.

Establish and implement additional procedures and controls to ensure that audited financial statements are prepared and submitted in accordance with HUD requirements.

Complete and submit to HUD the audited financial statements for all past-due fiscal years in accordance with HUD regulations.

Consider imposing administrative sanctions and remedies on the Authority for the nonsubmission of audited financial statements for all overdue fiscal years.

Develop and implement additional procedures and controls to ensure that City employees properly calculate administrative fees for portability HAP related to the Authority.

Update its intergovernmental agreements for supplemental law enforcement services to include the current HUD requirements at 2 CFR Part 200 to comply with its procurement bulletin and HUD Notice SD-2015-01. By doing so, the Authority will ensure that current and future intergovernmental agreements include the current HUD requirements and focus Federal resources toward improving program performance and outcomes.

Issue guidance to PHAs to ensure any applicant for or tenant of public or assisted housing whose name appears on the SAM excluded parties list are reviewed by PHAs to determine eligibility in a manner consistent with the regulations in 2 CFR 180 and 2424 so that ineligible applicants or tenants are not admitted or recertified to put up to $13.7 million to better use.

Take corrective actions for the 729 tenants reported as deceased to put $6.1 million to better use.

Establish a method to provide information in the Do Not Pay system to PHAs and require its use.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to support that the subsidies for 51 units without annual physical inspections, without required EIV reports, or missing files were eligible and accurate or repay HUD $1,054,150 for those subsidies. Repayment must be from nonproject funds.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to use correct dates for tenants who move in or out of subsidized units or transfer to other units. The move-ins, move-outs, and transfers must be adequately documented and supported.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to ensure that form HUD-50059 transactions are properly coded and adequately document and support the transactions.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to ensure that tenant income is properly verified and maintain EIV reports as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to perform and document annual inspections as required.

We recommend that the Southwest Region Director of Multifamily Housing require the Northline Point Apartments’ owner to implement appropriate controls to ensure that tenants are eligible, housing assistance subsidies are accurate, tenants are properly moved and transferred, transactions are properly coded, units are inspected as required, and tenant files contain all required documentation.

We also recommend that the Southwest Region Director of Multifamily Housing verify that the owner is providing oversight to its onsite staff and its recently implemented quality control procedures are working as designed and in accordance with HUD requirements.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to support or repay its HUD program accounts from non-Federal funds $97,170 paid for unsupported legal services, of which $29,111 was paid with Housing Choice Voucher Program funds and $68,059 was paid with operating funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to support or repay its HUD program accounts from non-Federal funds $21,000 paid for unreasonable and unnecessary retainer fees for those months when the Authority did not hold a regular meeting, of which $7,112 was paid with Housing Choice Voucher Program funds and $13,888 was paid with operating funds.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to revise its procurement policies to include, either in their entirety or by reference, the current Federal cost principles.

We recommend that the Director of the San Antonio Office of Public Housing require the Authority to provide training to commissioners and employees on Federal procurement and cost principles requirements and have them certify that they understand and will comply with the requirements.