We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to update its policies and procedures to ensure that any additional payments made under interagency agreements for technical, administrative, maintenance, and redevelopment services are adequately supported prior to making payment and that these services are provided in accordance with applicable requirements.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that the $326,096 paid for goods and services was reasonable or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support or that is not considered reasonable.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to show that it had valid contracts in place before disbursing $125,589 to three vendors or reimburse its Operating and Capital Fund programs from non-Federal funds for any amount that it cannot support.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to update its procurement policies and procedures to ensure compliance with HUD and Federal procurement requirements.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to support $100,496 in 2015 Capital Fund grant obligations that have already been disbursed or reimburse HUD from non-Federal funds for any amount it cannot support.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to provide documentation to support $18,913 in 2015 Capital Fund grant obligations that have not yet been disbursed or request that HUD recapture the funds in accordance with regulations at 24 CFR 905.306.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to improve its policies and procedures to ensure that capital funds are obligated in a timely manner and adequately supported.

We recommend that the Director of HUD’s Newark Office of Public Housing require the Authority to reimburse its Operating Fund from non-Federal funds for the $75,722 settlement payment made to the State of New Jersey.

We also recommend that the Director of the HUD Departmental Enforcement Center consider whether administrative action against the appropriate owner(s) is warranted.

We recommend that the Southwest Region Director of Multifamily Housing require Villa Main Apartments owner to repay HUD $534,741 for 39 subsidized units with ineligible “ghost” tenants.

We recommend that the Southwest Region Director of Multifamily Housing require Villa Main Apartments owner to provide support that the subsidized 43 units without annual physical inspections, without required EIV reports, or with missing files were eligible or repay HUD $1,095,364 for those subsidies.

We recommend that the Southwest Region Director of Multifamily Housing require Villa Main Apartments owner to implement appropriate controls to ensure tenants are eligible, housing assistance subsidies are accurate, and that units are inspected as required.

We further recommend that the Southwest Region Director of Multifamily Housing verify that the owner is providing oversight to its onsite staff and its recently implemented quality control program is working as designed and in accordance with HUD requirements.

We further recommend that the Southwest Region Director of Multifamily Housing ensure that the project-based contract administrator’s review process includes steps to obtain reasonable assurance that tenants being reported as subsidized at Villa Main qualify for the program and live in the subsidized units.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to develop and implement a HUD-approved written plan and procedures and take actions that will correct and prevent the deficiencies noted in the finding, improve program administration effectiveness, strengthen the control environment, ensure compliance with HUD regulations and its own policies and procedures, and ensure that it has the continuing capacity to carry out its HOME program activities as required. Implementing this recommendation should ensure that the $216,663 in HOME funding allocated for the Parish’s property rehabilitation program is better used.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to Repay its program from non-Federal funds for $9,849 in payments made to contractors for duplicate payments and overpayments.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to support or repay its program from non-Federal funds $1,020,121 for payments made (1) for work that the contractor(s) did not perform and excessive material costs; (2) that lacked adequate supporting documentation for change orders, independent cost estimates, and invoice documentation; or (3) for the 10 HOME-funded rehabilitated homes not brought up to code.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to establish and implement desk and onsite monitoring policies and procedures to ensure that documentation is maintained to support that (1) adequate supporting documentation for payments is filed, tracked, and maintained; (2) the necessity for all change orders is verified and reasonableness of the costs is assessed; (3) cost estimates are completed before the bidding process; (4) work is completed before pay requests are approved and payments are made to the contractor; and (5) contractors are properly monitored throughout the rehabilitation process, including progress and final inspections.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to correct the property deficiencies identified during the onsite inspections related to the 20 contracts as applicable.

We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require the Parish to inspect the remaining 33 homes for compliance with the contract specifications and HUD requirements and correct deficiencies as applicable.