Submit supporting documentation showing that contracts and purchase orders complied with Federal and its own procurement requirements and that these were reasonable and necessary costs or reimburse the CDBG-DR program $55,010 from non-Federal funds.

Submit supporting documentation showing that contracts and purchase orders complied with Federal and its own procurement requirements and that these were reasonable and necessary costs or cancel the $361,501 in unpaid obligations related to CDBG-DR funds.

Revise and finalize the procurement procedures to ensure compliance with applicable Federal requirements, including but not limited to procedures to ensure full and open competition, supporting independent cost estimates, properly documenting the procurement history, and including required clauses in contracts, among other issues.

Continue testing the financial and credit history variables, including default data, and include the appropriate reliable and sufficient variables for the cash flow model used to estimate and reestimate the credit subsidy for the cohorts of mortgages within the Section 232 program.

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…

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…

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.

Ensure that the remaining 244 developments’ exemption status is properly supported.

Ensure that the 382 potentially noncompliant developments are reported in its response tracking system and reviewed for compliance with the Lead Safe Housing Rule.

Implement 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.

Develop a framework for taking administrative actions against public housing agencies that do not comply with HUD’s Lead Safe Rule.

Continue its efforts to identify and train staff on how to use the response tracker.

Continue its efforts to resolve technical issues that prevented the addition of new cases into the response tracker.

Establish 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.

Support that $916,132 spent on contracts was fair and reasonable in accordance with Federal requirements or repay the Operating Fund or Capital Fund program from non-Federal funds any amount that cannot be supported.

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.

Reprocure any contracts for which cost reasonableness cannot be supported and contracts were not properly awarded to ensure compliance with HUD requirements.

Ensure that all Authority staff members working with procurements and contract administration receive Federal procurement training.

Establish 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.

Ensure that all architectural and engineering contracts or task orders awarded during our audit period are reviewed for cost reasonableness.