Ensure that the Authority’s board of commissioners and staff receive HUD-approved training on conflicts of interest.

Monitor the Authority to ensure that initial tenant certifications and annual recertifications with an actual or potential conflict of interest are appropriately handled.

Require the Authority to develop and implement detailed policies and procedures to address collections, tracking, and use of its laundry machine revenue.

Require the Authority to determine how much laundry machine revenue was not deposited into its accounts and used for eligible purposes and reimburse its program from non-Federal funds.

Monitor the Authority to ensure compliance with its new laundry machine revenue policies.

Provide documentation to show that $793,101 paid to the City for legal services was cost beneficial. Based on the documentation, it should reimburse its Housing Choice Voucher Program from non-Federal funds for any amount that exceeded the cost savings.

Follow the terms of the agreement, HUD requirements, and its own policies and procedures to ensure that any intergovernmental agreements for goods and services are in compliance.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to update its policies and procedures to ensure that any additional payments made under interagency agreements are adequately supported before payment is made and that the services are provided in accordance with applicable requirements. These requirements include but are not limited to HUD, Federal, and Authority requirements related to procurement, allocation of costs, and review and approval of payments.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that $36,508 disbursed1 was for authorized and approved costs or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support.

We recommend that the Director of HUD’s Newark Office of Public Housing provide technical assistance to the Authority to help ensure that 1) future interagency agreements, including the renewal of its agreement with Long Branch clearly outline the expectations and documentation required to show that work was performed, (2) its board provides adequate oversight of work performed under interagency agreements, and 3) it complies with HUD, Federal, and Authority procurement requirements when purchasing goods and services.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to show that the $583,920 paid to two vendors for purchase orders below the Authority’s micropurchase limit was for prices that were reasonable or reimburse its Operating Fund from non-Federal funds for any amount that it cannot support or is not considered reasonable.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to show that $842,931 paid under five contracts was for prices that were reasonable or reimburse its Operating Fund for any amount that it cannot support or is not considered reasonable.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls over purchases to ensure compliance with HUD, Federal, and Authority procurement requirements. This includes, but is not limited to, controls to ensure that it (1) maintains records sufficient to detail the significant history of procurements, (2) complies with requirements for each type of procurement, (3) obtains independent cost estimates and performs cost or price analyses when required, and (4) prevents and detects conflict-of-interest situations.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to its staff to ensure compliance with HUD and Federal procurement requirements.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify the $372,695 in unsupported Operating Fund subsidies received or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide documentation to justify $8,564 in excessive property management fees charged by the COCC or reimburse its Operating Fund from non-Federal funds for any amount it cannot support.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to reimburse its Operating Fund from non-Federal funds $82,907 for 16 document management services contract payments that should have been paid with COCC funds.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to strengthen its controls to ensure that operating funds are requested, received, and used in accordance with HUD, Federal, and Authority requirements.

We recommend that the Acting Director of HUD’s Buffalo Office of Public Housing require the Authority to provide training to employees involved in the funding and expenditure processes to ensure compliance with HUD, Federal, and Authority requirements

Transfer $78,786 ($22,601 $56,185) from its Family Self-Sufficiency account to its Housing Choice Voucher Program account for the overfunded and forfeited escrows.