We recommend that HUD require the City to provide supporting documentation for the 4 program participants that did not have adequate income documentation. If the supporting documentation cannot be provided, repay, from nonfederal funds, $99,347.

We recommend that HUD require the City to since the property updates have been completed for the 24 program participants that did not receive the green infrastructure training, provide documentation that any subsequent program participants completed the green infrastructure training workshop before the grant agreement is signed and construction begins.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to update its intake policy and procedure to clarify which inquiries are to be recorded in HEMS.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to develop an internal agency intake training guide, distribute it to all agency housing staff members, and ensure that all intake staff members participate in HUD-approved training related to intake.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to implement a record retention policy to ensure that decisions on inquiries are sufficiently supported.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to implement a plan to ensure that it has sufficient staff to meet its obligations under FHAP cooperative agreement.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to implement a system to better track the intake and processing of potential fair housing inquiries.

Determine how to measure the impact of recruitment efforts related to individuals who identiy as Hispanic or Latino.

Implement a process to measure the impact of recruitment efforts related to individuals who identify as Hispanic or Latino.

Implement a process to collect and maintain information about recruitment efforts related to indiviuals who identify as Hispanic or Latino from all HUD program offices and their respective field offices.

Develop and implement adequate procedures and controls to ensure that (1) staff issues notices of violation and default within 15 calendar days of the inspection report release date and (2) the Office of Multifamily Asset Management and Portfolio Oversight is made aware when notices are not issued within 15 calendar days after the inspection report release date and takes action as appropriate to ensure that future notices are issued in a timely manner. 

Corrective Action

HUD’s Office of Multifamily Housing created procedures to identify failed inspections and notify the appropriate field office that a property in their portfolio had recently failed inspection. The procedures included a timeline for issuing a Notice of Violation/Notice of Default to the owner of the property. Implementation of the recommendation ensures that multifamily property owners are notified of deficiencies in a timely manner to take corrective actions.

Include language in future notices of violation and default clearly stating that owners are required to inspect all units (including vacant units), common areas, grounds, building systems, and sites as part of the owner survey and require owners to include sufficient detail in the surveys to show (1) when the survey was conducted and (2) that the survey was a complete survey of the project.

Corrective Action

HUD’s Office of Multifamily Housing updated the language in the template document to be used in future notices of violation and default, clearly stating that owners are required to inspect all units (including vacant units), common areas, grounds, building systems, and sites as part of the owner survey and require owners to include sufficient detail in the surveys to show (1) when the survey was conducted and (2) that the survey was a complete survey of the project. Specifically, HUD notified all Asset Management Division Directors informing them of the updates to the templates and instructed them to use the templates. The implementation of this recommendation has the potential to positively and directly impact the health and safety of families.

Develop and implement adequate policies, procedures, and controls to ensure that owner certifications and surveys and other relevant documents related to properties that fail inspections or are noted as having EHS deficiencies are maintained and retrievable from an easily accessible location.

Develop and implement adequate controls to ensure that HUD staff with the appropriate level of authority approves extensions to the notices of violation and default cure periods in writing and that documentation is maintained to support such approvals.

Modify the queries used to generate the schedules of properties that accompany the reports to Congress to consider a larger range of dates to ensure that properties that failed consecutive inspections are appropriately identified on all applicable schedules.

Assess and streamline the processes for preparing, reviewing, and approving the reports as appropriate to ensure that the reports are submitted to Congress on or before the required due date.

Implement adequate procedures and controls to ensure that documentation is maintained to support that the reports were submitted to Congress.

Develop comprehensive guidance and training for grantees on how to prepare the PR 29 report to ensure that the information collected is reliable, accurate, timely, and in compliance with the Uniform Administrative Guidance for Grants and Cooperative Agreements, specifically 2 CFR 200.302(a)(b) and 2 CFR 200.303

Determine whether the funds that were drawn in error need to be repaid to HUD and whether other remediation actions are appropriate.

Follow up with the four grantees without adequate supporting documentation and assess their compliance with the financial management requirements in 2 CFR 200.302(b)(3), which require the financial management system of each non-Federal entity to provide for records that adequately identify the source and application of funds for federally funded activities.