Support that $408,968 in funds not yet spent on contracts would be fair and reasonable or reallocate the funds to ensure that they will be put to their intended use.
2020-BO-1002 | March 19, 2020
The Housing Authority of the City of Springfield, MA, Did Not Always Comply With Procurement and Contract Administration Requirements
Public and Indian Housing
2020-BO-1002-001-B
Closed on November 03, 2020$408,968Funds Put to Better UseRecommendations that funds be put to better use estimate funds that could be used more efficiently. For example, recommendations that funds be put to better use could result in reductions in spending, deobligation of funds, or avoidance of unnecessary spending.
2020-BO-1002-001-C
Closed on October 06, 2020Reprocure any contracts for which cost reasonableness cannot be supported and contracts were not properly awarded to ensure compliance with HUD requirements.
2020-BO-1002-001-D
Closed on June 23, 2020Ensure that all Authority staff members working with procurements and contract administration receive Federal procurement training.
2020-BO-1002-001-E
Closed on June 22, 2020Establish and implement adequate record-keeping procedures to comply with Federal procurement requirements, including a checklist for the file to ensure that they complete all procurement requirements and receive all required documents.
2020-BO-1002-001-F
Closed on November 19, 2020Ensure that all architectural and engineering contracts or task orders awarded during our audit period are reviewed for cost reasonableness.
2020-BO-1002-002-A
Closed on November 03, 2020$37,941Questioned CostsRecommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Repay the Operating Fund program from non-Federal funds for the $37,941 in ineligible costs when the amount paid exceeded the contract value.
2020-BO-1002-002-B
Closed on June 22, 2020Establish and implement adequate controls so the Authority does not exceed the contract amount without appropriate contract amendments and written approvals.
2020-BO-1002-002-C
Closed on June 22, 2020Establish and implement adequate controls to obtain all of the required project completion documentation prior to final payment.
2020-CH-0003 | March 18, 2020
HUD Lacked Adequate Oversight of Public Housing Agencies’ Compliance With the Lead Safe Housing Rule
Public and Indian Housing
2020-CH-0003-001-A
Closed on September 05, 2023PriorityPriorityWe believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
Ensure that its staff appropriately determines exemptions from the Lead Safe Housing Rule and documents support of the determinations.
Corrective Action Taken
In June 2023, HUD publicly issued Notice 2023-16, Implementation of National Standards for the Physical Inspection of Real Estate (NSPIRE) Administrative Procedures, providing guidance covering the process and operational requirements for HUD’s public housing programs that clarifies for its staff (1) actions that should be taken by the PHA and (2) documentation that must be provided to support that a housing unit is exempt from the Lead Safe Housing Rule. The guidance describes the process that a PHA or property owners and/or agents must take when a NSPIRE inspection identifies deteriorated paint in a property or housing unit. Specifically, the PHA or property owners and/or agents should first verify that the property or housing unit is considered “target housing,” and if so, determine whether it is exempt from the Lead Safe Housing Rule. If an exemption applies, documentation such as, a lease or other residency agreement that affirms that the property is designated exclusively for occupancy by the elderly or persons with disabilities must be provided to HUD. Other residency agreements could include a HUD-approved designated housing plan, property deed or charter, or occupancy restrictions approved by HUD or the PHA’s board of commissioners. The PHA or property owners and/or agency must also affirm whether children under the age of 6 years reside in the property.
2020-CH-0003-001-B
Closed on September 22, 2023PriorityPriorityWe believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
Ensure that its staff determines whether a child under 6 years of age resides in an exempted development. If a child is determined to reside in an exempted development take appropriate actions in accordance with its internal policies
Corrective Action Taken
The Office of Field Operations (OFO) updated the Lead-Based Paint Response Tracker’s Standard Protocol and Roles and Responsibilities to identify the roles and responsibilities of HUD’s headquarters and field office level staff in ensuring PHAs’ compliance with the Lead Safe Housing Rule (LSHR). The protocol provides that the OFO field office staff work directly with PHAs to resolve issues of noncompliance with the LSHR and other Lead-based paint (LBP) guidance by responding to or escalating questions/issues to the headquarters team, directing PHAs to available training and resources on HUD.gov or HUD Exchange, and working with PHAs to obtain sufficient documentation to close an LBP case in the LBP tracker promptly. In regards to a child under 6 years of age residing in an exempted development, staff from the field offices must upload supporting documentation determining whether a pregnant lady or child six years old or younger lives in the development, collect missing information, if applicable, coordinate with OFO team to close cases in the LBP response tracker, indicate in the LBP response tracker if the PHA has provided the documents or if the property is exempt and upload supporting documents.
2020-CH-0003-001-C
Ensure that the 55 developments without sufficient support for an exemption either support the exemption status or complete the required lead-based paint inspections and provide the documentation to the appropriate field office.
2020-CH-0003-001-D
Ensure that the remaining 244 developments’ exemption status is properly supported.
2020-CH-0003-001-E
Ensure that the 382 potentially noncompliant developments are reported in its response tracking system and reviewed for compliance with the Lead Safe Housing Rule.
2020-CH-0003-001-F
Closed on September 22, 2023Implement adequate procedures and controls for monitoring public housing agencies’ compliance with the Lead Safe Housing Rule. Such procedures and controls should include but not limited to establishing timeframes for reporting potentially noncompliant developments in its tracking system and implementing corrective actions and resolution.
2020-CH-0003-001-G
Closed on September 22, 2023Develop a framework for taking administrative actions against public housing agencies that do not comply with HUD’s Lead Safe Rule.
2020-CH-0003-001-H
Closed on August 24, 2022Continue its efforts to identify and train staff on how to use the response tracker.
2020-CH-0003-001-I
Closed on June 06, 2023Continue its efforts to resolve technical issues that prevented the addition of new cases into the response tracker.
2020-CH-0003-001-J
Closed on September 13, 2023Establish policies, procedures, and controls for validating and correcting construction dates of the public housing developments in IMS-PIC. If the information is determined to be inaccurate, HUD should work with public housing agencies to update the data to ensure accuracy.
2020-AT-1002 | March 16, 2020
The Puerto Rico Department of Housing, San Juan, PR, Should Strengthen Its Capacity To Administer Its Disaster Grants
Community Planning and Development
2020-AT-1002-001-A
Closed on November 06, 2020Develop adequate procedures outlining steps for tracking monthly grant expenditures, reprogramming funds for stalled activities, managing program income, and allocating costs as required by Federal Register Notice 83 FR 5844 and the grant agreement with HUD.
2020-AT-1002-001-B
Closed on November 06, 2020Ensure that the financial management system for the 2017 CDBG-DR grant is capable of providing information by activity type and grant number.