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 responsibilities of HUD’s headquarters and field office level staff in ensuring PHAs’ compliance with the Lead Safe Housing Rule (LSHR). The protocol provides that the OFO field office staff work directly with PHAs to resolve issues of noncompliance with the LSHR and other Lead-based paint (LBP) guidance by responding to or escalating questions/issues to the headquarters team, directing PHAs to available training and resources on HUD.gov or HUD Exchange, and working with PHAs to obtain sufficient documentation to close an LBP case in the LBP tracker promptly. In regards to a child under 6 years of age residing in an exempted development, staff from the field offices must upload supporting documentation determining whether a pregnant lady or child six years old or younger lives in the development, collect missing information, if applicable, coordinate with OFO team to close cases in the LBP response tracker, indicate in the LBP response tracker if the PHA has provided the documents or if the property is exempt and upload supporting documents.

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.

Develop adequate procedures outlining steps for tracking monthly grant expenditures, reprogramming funds for stalled activities, managing program income, and allocating costs as required by Federal Register Notice 83 FR 5844 and the grant agreement with HUD.

Ensure that the financial management system for the 2017 CDBG-DR grant is capable of providing information by activity type and grant number.

Develop and implement a financial management system for its 2008 CDBG-DR grant and ensure that it tracks program funds to a level that supports compliance with HUD requirements. At a minimum, the accounting system must reflect disbursements by grant, activity, and activity type and properly account for assets, liabilities, and program income.

Review and update its 2017 CDBG-DR policies and procedures to prevent duplication of benefits and ensure that these are comprehensive and all applicable activities are included, including but not limited to the Small Business Financing Program and the Construction and Commercial Revolving Loan program.

Negotiate with the SBA, within 30 days of the issuance of this audit report, to extend its data-sharing agreements for the term of the expenditure requirements set forth in public laws or the Federal Register in relation to the 2017 and 2008 disasters.

Negotiate with Puerto Rico’s Insurance Commissioner and with other CDBG-DR grantees, within 30 days of the issuance of this audit report, to establish data-sharing agreements for the 2017 CDBG-DR grant disaster, any open disaster recovery grants, and future disasters.

Complete, within 30 days of the issuance of this audit report, the review for preventing duplication of benefits associated with its 2008 CDBG-DR grant and pursue appropriate remedies for any instances of noncompliance found.

Review and update its procurement policy for the 2017 CDBG-DR grant to address weaknesses identified, including but not limited to required contract clauses, processes for soliciting and accepting noncompetitive proposals, and performing cost or price analyses before receiving bids or quotations, among other issues.

Ensure that the 2017 CDBG-DR procurement policy addresses the establishment of a contract register that, at a minimum, contains the procurement information specified in section 3.8 of HUD’s Buying Right Guide regarding the PRDOH’s acquisitions of goods and services, as well as of its subrecipients and partners.

Establish procurement policies and procedures for the 2008 CDBG-DR grant to ensure compliance with 2 CFR 200.318-326, 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 to fill its vacancies with qualified and trained staff, thus ensuring that staffing levels remain adequate to administer the 2017 and 2008 CDBG-DR grant funds.