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

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

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.

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.

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.

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

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

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