Ensure that in future RAD conversions, if any, unit inspections are conducted for compliance with HUD’s housing quality standards after rehabilitation and construction is completed and before tenants move in.

Provide adequate training to its staff to ensure compliance with Section 8 Project-Based Voucher program requirements for unit inspections and rent reasonableness determinations.

Obtain documentation from the remaining 55 potential cases (34 cases in the public housing program 21 cases in the Housing Choice Voucher program) reported by the public housing agencies that failed to provide supporting documentation to determine compliance with HUD’s requirements.

Obtain documentation from the remaining 195 potential cases involving children with EIBLLs reported by the public housing agencies (35 reported cases in the public housing program 160 reported cases in the Housing Choice Voucher program) that we did not review during the audit to determine whether the public housing agencies and owners, as applicable, complied with HUD’s requirements or whether action is required under the requirements.

Require the public housing agencies to support that the lead hazards were appropriately abated for the 11 cases (3 public housing program 8 Housing Choice Voucher program) that lacked adequate clearance reports or lacked documentation showing that the identified lead hazards had been corrected.

Ensure that the owners for the two Housing Choice Voucher program units, in which the families were relocated and abatement was not performed, do not provide housing for families with children under 6 years of age until the lead hazards are abated.

Obtain documentation of a lead-based paint inspection or exemption for the 222 public housing developments that failed to provide evidence of compliance with HUD’s lead-based paint inspection requirements.

Work with the Office of Lead Hazard Control and Healthy Homes to update HUD’s regulations to expand the inspection and abatement requirements of 24 CFR Part 35 to housing completed after 1977 in cases in which a child with an elevated blood lead level is reported.

Implement adequate procedures and controls at HUD’s field offices to ensure that requirements of 24 CFR Part 35 are followed by public housing agencies, including monitoring the public housing agencies to ensure that required actions are appropriately completed and performed in a timely manner.

Reimburse its program $13,605 from non-Federal funds ($8,735 in overpayments of housing assistance and utility allowances $4,870 in administrative fees) due to inappropriate calculations.

Reimburse the appropriate households $2,663 from non-Federal funds for the underpayment of housing assistance and utility allowances due to inappropriate calculations.

Support or reimburse the appropriate households $44 from non-Federal funds for the unsupported payments of housing assistance cited in this finding.

Pursue collection from the applicable households or reimburse its program $1,877 from non-Federal funds for the overpayment of housing assistance due to unreported income.

Pursue collection from the applicable projects or reimburse its program $5,065 from non-Federal funds for the overpayment of housing assistance.

Reimburse the appropriate projects $177 from program funds for the underpayment of housing assistance.

Reimburse the appropriate households $263 from program funds for the underpayment of utility allowance reimbursements.

Review the payments for all certifications completed between December 2016 and February 2017 for the remaining Housing Choice Voucher and Project-Based Voucher program participants to ensure that adjustments were appropriately paid.

Implement adequate quality control procedures to ensure that it correctly pays housing assistance.

Ensure that the quality controls over the calculation of housing assistance payments implemented by the Commission are sufficient.

We recommend that the Chief Financial Officer determine whether the summary expenditures totaling $160,360,714, which exceeded the grant round obligations for the two grantees, were ADA violations. If the transactions were violations, action should be taken as required by the ADA.