Assign and communicate the responsibility of FERA policy implementation and oversight to ensure that program offices are performing FERAs on a routine and timely basis to ensure effectiveness and efficiency of operations at the HUD program level and compliance with HUD internal policy and procedure.

Assign and communicate the responsibility of the MCR program policy, implementation, and oversight to ensure that program offices routinely conduct reviews to support a compliant internal control framework.

Conduct the OOR more frequently than annually to ensure that all obligations are adequately reviewed and deobligations are processed by the end of the fiscal year

Develop departmental policy that outlines the open obligation review process, to include (1) internal controls, (2) timeframes, and (3) roles and responsibilities of OCFO, OCPO, and program offices. These policies must outline sufficient internal controls in place to ensure that the Secretary can certify that all of HUD’s obligations are valid as of the end of the fiscal year.

Update standard operating procedures on the departmentwide unliquidated obligations review to conduct a routine review of justifications provided by the program offices for retained obligations, while ensuring that they are for a bonafide need and to support the annual certification made by the Secretary on open obligations.

As part of the OOR process, conduct monitoring activities of obligations sent to OCPO for deobligation by developing a mechanism to routinely track the status, to include key information, such as but not limited to the owner (program), date transmitted to OCPO, point of contact, last contact date, and current status. OCFO should use this information to ensure that all information has been communicated among all parties involved to enable timely deobligation.

Implement a process to ensure that ongoing ADA violation investigations are properly documented as the investigation progresses to enable timely review of open cases.

Ensure that $1,385,791 ($1,229,684 in housing assistance payments and $156,107 in associated administrative fees) used by the Lexington-Fayette Urban County Housing Authority is supported through a valid and retroactive exemption from HUD’s third-party requirements. If a retroactive exemption cannot be issued, HUD should follow recovery procedures prescribed in HUD Handbook 2000.06, REV-4.

Revise the standard MTW agreement for all existing 39 MTW housing agencies to clearly and specifically support which provision(s) waive the third-party inspection requirements.

Issue clarifying guidance to all existing 39 MTW housing agencies advising that HUD intended to waive the third-party inspection requirements via attachment C to the standard agreement.

Ensure that reviews of MTW annual plans are thorough by verifying that the MTW plan accurately identifies the appropriate exemptions as authorized in the MTW agreements.

Verify that the Office of Public Housing Investments’ approvals of all MTW public housing agencies’ MTW plans’ exemptions from HUD’s third-party requirements were valid and appropriate.

Require the Authority to reimburse its Public Housing Capital Fund program $38,411 from nonproject funds for the inappropriate use of funds for the Section 8 Project-Based Voucher Program units.

Ensure that the Louisville, KY, PIH field office sends to the Office of Recapitalization any requests it receives for approving capital funds expenditures after the RAD conversion is complete.

Require the Authority to ensure that capital funds are used in accordance with the program requirements for any future RAD conversions.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to certify, along with the owners of the 25 units cited in the finding, that the applicable housing quality standards violations have been corrected.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to reimburse its program $111,651 from non-Federal funds ($110,943 for housing assistance payments and $708 in associated inspection service fees) for the 23 units that materially failed to meet HUD’s housing quality standards.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to improve controls over its inspection program to ensure compliance with HUD guidelines and that the results of those inspections are used to enhance the effectiveness of its housing quality standards inspections.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to reimburse its program $4,459 from non-Federal funds for housing assistance payments that should have been abated for units that did not meet housing quality standards.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to improve controls to ensure that its staff accurately calculates housing assistance payment abatements.