Seek retroactive approval or reimburse its program $10,124 for program funds paid to the contractor not approved by HUD for the housing quality standards inspections for units owned by entities substantially controlled by the Authority.

Implement adequate procedures and controls to ensure that the Authority complies with HUD’s conflict-of-interest requirements, including but not limited to ensuring that (1) its staff is appropriately trained and familiar with HUD’s requirements for units owned by entities it substantially controls and (2) future contracts to perform housing quality standards inspections for program units owned by entities substantially controlled by the Authority are with a HUD-approved independent third party.

Implement adequate procedures and controls, including but not limited to providing guidance to its program staff on how to apply the correct contract rents and developing an effective quality control process.

Provide sufficient documentation to support that it disbursed the $199,604 in program funds, which it determined were inappropriate housing or utility assistance payments, and that it made a reasonable effort to collect the debts. If the Agency cannot provide sufficient documentation to support the disbursements and that the debts were uncollectable, it should reimburse its program from non-Federal funds as appropriate. If the Agency provides sufficient documentation to support the disbursements but cannot provide sufficient documentation to support that the debts were uncollectable, it should make a reasonable effort to collect from the debtors or reimburse its program from non-Federal funds as appropriate.

Implement adequate procedures and controls to ensure that it maintains sufficient documentation to support housing and utility assistance payments and that it makes a reasonable effort to collect debts.

Implement adequate procedures and controls to ensure that it follows its bad debt writeoff policy when it writes off accounts receivable.

Provide sufficient documentation to support that the two deleted adjustments to accounts payable and four deleted adjustments to accounts receivable were duplicate or incorrect adjustments that should have been deleted. If the Agency cannot do this, it should make the appropriate accounting entries and take the appropriate actions.

Determine whether the tenant paid the landlord nearly $1,284 for housing assistance payments that the Agency did not make to the landlord. If the tenant paid the landlord, the Agency should make the appropriate accounting entries and reimburse the tenant from program funds. If the tenant did not pay the landlord, the Agency should reinstate the adjustments to accounts payable that were inappropriately deleted and pay the landlord from program funds.

Provide sufficient documentation to support that an adjustment to accounts payable and five adjustments to accounts receivable were appropriate. If the Agency cannot do this, it should make the appropriate accounting entries and take the appropriate actions.

Implement adequate procedures and controls to ensure that it deletes adjustments to accounts payable and receivable and makes adjustments to accounts payable and receivable in accordance with HUD’s regulations and its administrative plan.

Request that HUD’s Quality Assurance Division continue reviewing the Agency’s (1) writeoff of accounts receivable, (2) deleted adjustments to accounts payable and receivable, and (3) adjustments to accounts payable and receivable as part of its financial and program management and operations review.

Create agreements and strategies with other program offices that describe when cross-programmatic reviews and enforcement actions against PHAs are required.

Train PIH officials on the authority and processes for declaring PHAs in substantial default and for taking PHAs into HUD possession.

Update and strengthen the training program for HUD receivers of PHAs.

Update procedures for receiverships to include specific guidance on when initiating a receivership may be appropriate.

The Pell City Housing Authority to reimburse its public housing fund from non-Federal funds $1,188 for payments made for ineligible credit card expenditures.

The Pell City Housing Authority to support or reimburse its public housing fund $12,874 ($4,709 $8,165) for unsupported disbursements.

The Pell City Housing Authority to fully implement adequate internal controls over its credit card purchases and disbursements to ensure that it complies with Federal requirements and its own policies and procedures.

The Pell City Housing Authority to revise its policies and procedures for its review of expenditures to ensure that its board of commissioners documents its enforcement of and the Authority’s compliance with the requirements during its review process to ensure that the Authority’s disbursements are supported and used for eligible expenditures.

The Pell City Housing Authority’s board of commissioners to receive training to ensure the proper review and approval of expenditures and to understand the requirements relevant to the Authority’s financial operations.