Housing should include zero trust requirements as part of the Housing Strategic Roadmap for Housing Modernization.

Housing should refine access controls within the FHA Catalyst modules that are dynamic, are tailored to user actions, and require continuous reauthentication to ensure that users have access only to information needed.

Housing should coordinate with HUD’s SOC to a. Ensure that FHA Catalyst user behavior monitoring logs are regularly captured and adequately reviewed for discrepancies in user activities. b. Establish program office responsibility for the log review process.  

Issue guidance to PHAs clarifying the timing of unit inspections and lead-based paint visual assessments to address the misinterpretation caused by the terms “annual” and “every 12 months.”

Provide evidence to support that the owners corrected the 46 deficiencies for the 20 units with outstanding deficiencies. If the owners fail to provide evidence that they made the required corrections, HUD should require the Authority to implement its HAP enforcement procedures and provide supporting documentation to HUD evidencing that it did so.

Improve its quality control process for monitoring its inspectors to enhance the effectiveness of its unit inspections and ensure that all units meet HUD’s and its own requirements to prevent more than $34 million in Program funds from being spent on units that do not meet HQS over the next year. This process should include but not be limited to procedures (1) requiring its staff to use the quality control inspection results to evaluate and monitor the performance of the Authority’s inspectors, along with maintaining adequate supporting documentation on feedback provided to the inspectors for recurring inspection deficiencies and (2) for evaluating the training provided to its inspectors to determine what improvements are needed to ensure that unit deficiencies are detected.

Pursue collection from the applicable owners or reimburse its HCV Program from non-Federal funds $106,477 ($180,309 - $73,832) in inappropriate HAP

Provide evidence to HUD that it has improved its controls and procedures for its stop payment process to ensure that (1) payments to owners comply with its HCV Program administrative plan and HUD requirements and (2) it maintains documentation to support stop payments and resumption of those payments for each unit as applicable.

Provide documentation to support that HAP was appropriately paid to the owners for the 66 units that had more than one stop payment. If additional HAP was inappropriately paid, the Authority should pursue collection from the applicable owners or reimburse its HCV Program from non-Federal funds.

Review its records to confirm whether it had cases of children with EBLLs during our audit period and work with the owner(s) of the HCV Program units to provide required documentation to HUD.

Update publications and educational materials to owners to ensure that they understand their reporting responsibilities to HUD regarding confirmed cases of children with EBLLs.

Develop and implement procedures and controls for coordinating with public health departments and managing cases of children with EBLLs, including monitoring owners for compliance with the requirements of the LSHR.

Work with HUD’s OLHCHH to provide technical assistance to the Authority’s staff to develop and implement procedures and controls for monitoring owners for compliance with HUD’s EBLL requirements and attempting to collaborate with local health departments to identify cases of EBLL in children under 6 years of age under its HCV Program.

Implement procedures and controls to ensure that visual assessments for lead-based paint are completed at least every 12 months.

Implement procedures and controls to ensure that risk assessments and reevaluations are conducted in accordance with HUD’s requirements.

Obtain lead-based paint risk assessments for the five developments for which hazard reduction work was completed and perform the required reevaluations.

Determine whether the remaining five developments (Imperial Courts, Mar Vista Gardens, Nickerson Gardens, Ramona Gardens, and Rancho San Pedro) have deteriorated paint and if so, obtain lead-based paint risk assessments and reevaluations when applicable.

Coordinate with HUD’s Office of Lead Hazard Control and Healthy Homes to obtain training for the Authority’s employees responsible for managing lead-based paint on the management of lead-based paint, including the requirements for visual assessments, risk assessments, reevaluations, and hazard reduction.

Require that the PLUS system for receiving, processing, and assigning applications tracks applications and captures application intake, screening, and status, including key dates; captures data on the type of underwriter used; includes a portal for receiving documents and communicating with lenders; and generates FHA loan numbers. This will allow HUD to identify, monitor, and address processing delays and issues on a continuous basis; evaluate its performance and processes; and manage future challenges.

Update policies and procedures to include methods that will be used when applications exceed underwriter capacity, align intake and screening processes, and explain when timeframes will be enforced, including in PLUS.