We audited the Boston Housing Authority’s Housing Choice Voucher (HCV) Program. We initiated this audit based upon our assessment of risks associated with public housing agencies' HCV Program units, as well as recent media attention and public concern about the conditions of subsidized housing properties. Our objective was to determine whether the physical conditions of the Authority’s HCV units complied with both the U.S. Department of Housing and Urban Development’s (HUD) and the Authority’s requirements.
The Authority did not always ensure that its HCV Program units met HUD’s housing quality standards (HQS). Specifically, we reviewed a sample of 87 units that had passed a recent HQS inspection and determined that 50 units had 193 deficiencies. Of the 50 units, 15 units had 53 deficiencies that existed at the time of the Authority’s last inspection. In addition, the Authority did not (1) consistently stop housing assistance payments (HAP) to owners for uncorrected unit deficiencies and (2) comply with HUD’s monitoring and data collection requirements of the Lead Safe Housing Rule (LSHR) for cases of children with elevated blood lead levels (EBLL).
These conditions occurred because the Authority's inspectors did not thoroughly inspect housing units in a consistent manner and the Authority’s quality control process for HQS inspections had weaknesses. Further, (1) the Authority’s information system did not have controls in place to stop payments properly and (2) the Authority did not consistently follow its own established procedures to take appropriate actions to address unit deficiencies. Additionally, although the Authority was aware of HUD’s EBLL requirements, it (1) was uncertain about its authority to require owners to comply with those requirements and (2) believed that coordinating with the vast number of local health departments would have been challenging. As a result, families participating in the Authority’s HCV Program resided in housing units that were not always decent, safe, and sanitary. Based on our statistical sample, we estimate that over the next year, the Authority will pay owners more than $34 million in housing assistance for units that do not meet HQS. Further, (1) the Authority paid $180,309 in housing assistance to owners for units with uncorrected deficiencies and (2) HUD lacked assurance that the Authority and owners appropriately addressed their responsibilities under the LSHR for cases of children with EBLLs in a timely manner.
We recommend that the Director of HUD’s Boston Office of Public Housing require the Authority to (1) ensure that the owners correct the outstanding unit deficiencies; (2) recover or repay from non-Federal funds $106,477 for HAP that were not properly stopped; (3) review its records to confirm whether it had cases of children with EBLLs during our audit period and work with the owner(s) of the HCV Program units to provide required documentation to HUD; (4) update publications and educational materials to owners to ensure that they understand their reporting responsibilities to HUD regarding confirmed cases of children with EBLLs; (5) develop and implement procedures and controls for coordinating with public health departments and monitoring owners for compliance with the requirements of the LSHR; and (6) improve controls over its inspections, stop payments for uncorrected deficiencies, and monitor owners for compliance with the requirements of the LSHR. Additionally, we recommend that the Director of HUD’s Boston Office of Public Housing work with the Office of Lead Hazard Control and Healthy Homes to provide training to the Authority’s staff involved with managing lead‐based paint and technical assistance in developing and implementing new procedures and controls.
Recommendations
Public and Indian Housing
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Status2024-CH-1004-001-AOpenClosed
Provide evidence to support that the owners corrected the 46 deficiencies for the 20 units with outstanding deficiencies. If the owners fail to provide evidence that they made the required corrections, HUD should require the Authority to implement its HAP enforcement procedures and provide supporting documentation to HUD evidencing that it did so.
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Status2024-CH-1004-001-BOpenClosed$34,487,989.00Funds Put to Better Use
Recommendations 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.
Improve its quality control process for monitoring its inspectors to enhance the effectiveness of its unit inspections and ensure that all units meet HUD’s and its own requirements to prevent more than $34 million in Program funds from being spent on units that do not meet HQS over the next year. This process should include but not be limited to procedures (1) requiring its staff to use the quality control inspection results to evaluate and monitor the performance of the Authority’s inspectors, along with maintaining adequate supporting documentation on feedback provided to the inspectors for recurring inspection deficiencies and (2) for evaluating the training provided to its inspectors to determine what improvements are needed to ensure that unit deficiencies are detected.
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Status2024-CH-1004-002-AOpenClosed$106,477.00Questioned Costs
Recommendations 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.
Pursue collection from the applicable owners or reimburse its HCV Program from non-Federal funds $106,477 ($180,309 - $73,832) in inappropriate HAP
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Status2024-CH-1004-002-BOpenClosed
Provide evidence to HUD that it has improved its controls and procedures for its stop payment process to ensure that (1) payments to owners comply with its HCV Program administrative plan and HUD requirements and (2) it maintains documentation to support stop payments and resumption of those payments for each unit as applicable.
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Status2024-CH-1004-002-COpenClosed
Provide documentation to support that HAP was appropriately paid to the owners for the 66 units that had more than one stop payment. If additional HAP was inappropriately paid, the Authority should pursue collection from the applicable owners or reimburse its HCV Program from non-Federal funds.
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Status2024-CH-1004-003-AOpenClosed
Review its records to confirm whether it had cases of children with EBLLs during our audit period and work with the owner(s) of the HCV Program units to provide required documentation to HUD.
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Status2024-CH-1004-003-BOpenClosed
Update publications and educational materials to owners to ensure that they understand their reporting responsibilities to HUD regarding confirmed cases of children with EBLLs.
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Status2024-CH-1004-003-COpenClosed
Develop and implement procedures and controls for coordinating with public health departments and managing cases of children with EBLLs, including monitoring owners for compliance with the requirements of the LSHR.
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Status2024-CH-1004-003-DOpenClosed
Work with HUD’s OLHCHH to provide technical assistance to the Authority’s staff to develop and implement procedures and controls for monitoring owners for compliance with HUD’s EBLL requirements and attempting to collaborate with local health departments to identify cases of EBLL in children under 6 years of age under its HCV Program.