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2023-CH-0004-002-C
Status
Open
Date Issued
May 30, 2023
OIG Component Office
Audit

Develop and implement a nationwide protocol for field offices, describing how PHA self-inspections should be reviewed, based on REAC's determination of the number and frequency of PHA self-inspections.


Status

The OFO is working on the protocol/job aid and will keep OIG updated on progress made.  The final action target date is August 15, 2024.


Analysis

To fully resolve this recommendation, HUD must provide evidence that demonstrates it developed a nationwide protocol and implemented it across all HUD field offices.

Program Office
Public and Indian Housing
Questioned Costs
$0.00
Better Funds Use
$0.00
Publication Report Number
2023-CH-0004

Related Recommendations

Recomendation Status Date Issued Summary
2023-CH-0004-001-A Closed May 30, 2023

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.

2023-CH-0004-001-B Open May 30, 2023

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.


Status

On March 27, 2024, the OFO will host its inaugural office hours to discuss the life threatening and severe deficiencies protocol with FO staff.  The agenda for the training will include the NSPIRE system and the timeliness and responsibilities for correcting life-threatening and non-life threatening deficiencies.


Analysis

To fully address this recommendation, OFO must provide evidence that the training it develops and implements addresses reviewing or following up with PHAs about the correction of life-threatening, severe,  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.

Implementation of this recommendation will result in public housing units that are decent, safe, and sanitary because it mandates oversight to ensure PHAs are addressing identified deficiencies.

2023-CH-0004-001-C Closed May 30, 2023

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.

2023-CH-0004-002-A Closed May 30, 2023 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.
2023-CH-0004-002-B Closed May 30, 2023 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.