Provide evidence to support that the Authority corrected the 11 unit deficiencies for the 5 units and 7 building deficiencies for 4 buildings with outstanding deficiencies.

Determine the frequency of its quality control reviews of its inspections and work orders and update its quality control policy, training materials, and other resources as appropriate to ensure that its quality control process is consistently implemented.

Support that it has implemented its quality control policy for (1) monitoring the effectiveness of its unit and building inspections to ensure compliance with HUD’s and its own requirements and (2) reviewing work orders to ensure that cited deficiencies are corrected in accordance with HUD’s and its own requirements.

Provide evidence to support that the Authority corrected the four non-life-threatening deficiencies for the three units with outstanding deficiencies.

Implement adequate procedures and controls to ensure that the deficiencies identified during annual self-inspections are properly categorized and corrected in a timely manner.

Develop and implement a plan to manage and reduce its backlog of work orders. This plan should include but not be limited to (1) assessing and addressing staffing needs; (2) creating a timeline for completion of the work orders to ensure that its properties are maintained in decent, safe, and sanitary condition and in good repair; and (3) providing documentation showing that it is on track to meet the completion timeframe.

Implement adequate procedures and controls to ensure that inspection reports are uploaded to the Authority’s electronic filing system and work orders are created in a timely manner. This process should include but not be limited to providing training to its staff on the Authority’s systems, establishing timeframes for the creation of work orders, and monitoring the work order process.

Provide evidence to support that the Authority corrected the 3 non-life-threatening health and safety, and 19 non-health and safety deficiencies.

Develop and implement adequate procedures and controls to ensure that (1) the deficiencies identified during REAC inspections are corrected in a timely manner and (2) documentation is maintained to support that repairs were made.

Implement adequate controls to ensure that the Authority’s information system properly tracks the completion of work orders.

Implement adequate controls to ensure that the correction of life-threatening deficiencies is reported to HUD accurately and in a timely manner.

Review whether potential violations of the Antideficiency Act took place because of implementing or enforcing any nondisclosure policies, forms, or agreements that do not include the anti-gag provision as required by law. If it is determined that a violation occurred, the Chief Financial Officer should take disciplinary actions as appropriate and report the identified violations to the oversight authorities, including the HUD Secretary, the President, the Office of Management and Budget, Congress, and the Comptroller General.

We recommend that the Chief Financial Officer enhance existing policies to establish a formal grant accrual risk management framework to help ensure consistent standards across HUD with regard to the development, review, and execution of the grant accrual and validation. This framework should include 1) identifying grant accrual estimation risk, assessing the magnitude of this risk, and managing the risks that arise when using certain quantitative estimation methods, 2) a governance structure that includes estimation ownership, oversight, and framework assessment, 3) the creation of a committee that is responsible for establishing a holistic approach to estimation risk management, including key stakeholders from OCFO and program offices, such as CPD, and 4) a requirement for documentation of committee meeting agendas, minutes, and key decisions and discussion points which impacts the various grant accrual methodologies across the Department.

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.