Issue guidance to PHAs clarifying the timing of unit inspections and lead-based paint visual assessments to address the misinterpretation caused by the terms “annual” and “every 12 months.”

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.

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.

Pursue collection from the applicable owners or reimburse its HCV Program from non-Federal funds $106,477 ($180,309 - $73,832) in inappropriate HAP

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.

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.

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.

Update publications and educational materials to owners to ensure that they understand their reporting responsibilities to HUD regarding confirmed cases of children with EBLLs.

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.

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.

Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training for the Authority’s staff on the appropriate testing methodology for confirming that a child has an EBLL and to provide technical assistance on procedures and controls to address the issues cited in this finding.

Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training for the Authority’s staff on the management of lead-based paint, including technical assistance with developing and implementing procedures and controls to address the issues cited in this finding.

Pursue collection from the applicable owner or reimburse its HCV Program $5,194 from non-Federal funds for HAP that was not properly stopped for two units with outstanding HQS deficiencies.

Provide support showing whether HAP was appropriately stopped for the four units cited in the finding or reimburse or pursue collection of $10,233 from non-Federal funds for HAP to owners with outstanding HQS deficiencies.

Consider grantee feedback on the challenges they faced as part of ONAP’s planning for technical assistance and training of ONAP COVID-19 recovery program grantees.

Develop and implement a nationwide inspection review protocol, which includes but is not limited to (1) whether field office staff should mark verification of PHA corrections of life-threatening deficiencies in PASS or any future tracking systems, (2) acceptable documentation for offsite verifications, and (3) whether field office staff should discuss or verify corrections of non-life-threatening deficiencies.

Corrective Action Taken

HUD's Office of Field Operations (OFO) created a protocol describing how it would perform quality control reviews of field office oversight of PHAs’ corrections of life-threatening deficiencies. The implementation of this recommendation resulted in HUD creating a protocol that established consistency in the way HUD field office staff monitored public housing agencies’ corrections of life-threatening deficiencies.

Develop and implement training for field offices that addresses reviewing or following up with PHAs about the correction of life-threatening and non-life-threatening deficiencies and how (1) to review physical inspection reports to effectively ensure that PHAs correct physical deficiencies, (2) PHAs should address or correct each type of deficiency observed in the REAC physical inspection report, and (3) to use PASS or any future tracking system.

Corrective Action Taken

HUD developed and provided training to the field offices on their roles and responsibilities for following up with PHAs on the correction of life-threatening and non-life-threatening deficiencies observed during REAC inspections, the NSPIRE system and standards, protocols, and timelines for deficiency correction and verification. Implementation of the recommendation will help HUD to ensure that field office staff are clear on their roles and responsibilities to communicate with PHAs on how deficiencies should be addressed and verify that PHAs’ inspection deficiencies have been corrected.

Implement a system to track field office inspection review activities and create a repository for the support documentation collected to verify the correction of life-threatening deficiencies.

Corrective Action Taken

HUD’s Office of Field Operations (OFO) had created a quality assurance tracker as well as a life-threatening deficiency tracker, which contained data specific to the inspections selected by OFO HQs, for quality assurance reviews. The documentation (photographs, work orders, etc.) of the life-threatening deficiency correction was maintained in HUD’s NSPIRE Salesforce system.

Implementation of the recommendation resulted in HUD creating a system to track HUD field offices’ verifications of PHAs’ corrections of life-threatening deficiencies.

We recommend that the Deputy Assistant Secretary for REAC determine whether PHAs are required to perform annual inspections on 100 percent of their public housing units annually and issue clarifying guidance to all PHAs.

If REAC determines that 100 percent annual self-inspections are required, establish specific guidance to address the number of units and frequency of PHA self-inspections. If not required, REAC should evaluate whether HUD’s rationale for inspecting a statistical sample rather than 100 percent of public housing units remains appropriate.