Develop and implement procedures for executing Section 8 Project-Based Voucher Program housing assistance payments contracts related to RAD conversions.

Require lenders to obtain the borrowers’ consent to verify the existence of delinquent Federal taxes with the IRS during loan origination and deny any applicant with delinquent Federal tax debt and no payment plan or a noncompliant payment plan or an applicant refusing to provide consent from receiving FHA insurance to put at least $6.1 billion to better use by avoiding potential future costs to the FHA insurance fund.

Status

To fully address this recommendation, HUD will need to provide evidence that it established a method of borrower consent to verify the existence of delinquent federal taxes including, but not limited to one of the options OIG provided, which were (1) lenders obtaining the borrowers' consent to obtain their tax records directly from the IRS or (2) borrowers accessing their own tax information and submitting it to the lenders.

Implementation of this rule should result in HUD putting $6.1 billion to better use.

Analysis

To fully address this recommendation, HUD will need to provide evidence that it established a method of borrower consent to verify the existence of delinquent federal taxes including, but not limited to one of the options OIG provided, which were (1) lenders obtaining the borrowers' consent to obtain their tax records directly from the IRS or (2) borrowers accessing their own tax information and submitting it to the lenders.

Implementation of this rule should result in HUD putting $6.1 billion to better use.

Develop and implement an action plan that includes sufficient policies, procedures, and controls that address households living in assisted units having a sufficient supply of safe drinking water. Such policies, procedures, and controls should include but not be limited to (1) developing and implementing internal procedures to be notified, and share with public housing agencies, when the public water systems’ water exceeds the Environmental Protection Agency’s lead action level and (2) revising HUD’s applicable regulations, providing guidance to public housing agencies and Housing Choice Voucher Program landlords, and taking appropriate actions so that households living in assisted units have a sufficient supply of safe drinking water.

Evaluate the risk that employee benefit contributions expensed at PHAs may be unreasonable and, if determined necessary, establish and implement controls to reduce or eliminate the evaluated risk.

Develop and implement additional guidance to ensure that PHAs enter accurate employee benefit data into FASS-PH.

Require the Englewood Apartments’ owner to repay HUD from non-project funds the projected $377,108 in housing assistance payments for tenants who were not eligible for assistance.

Require Englewood Apartments to support that $24,295 in unsupported housing assistance payments was eligible and accurate. Englewood Apartments’ owner should repay any subsidy overpayments to HUD from non-project sources. Further, the owner should reimburse tenants for overcharged rents or enter into a repayment agreement with tenants who were undercharged due to nondisclosure of income.

Require the Englewood Apartments’ owner to implement appropriate controls, including a formalized process, to use when conducting initial certifications and interim and annual recertifications to ensure that tenants are eligible, housing assistance payments are accurate, and tenant files contain all required documentation to comply with HUD’s and its own requirements. In addition, the updated controls should ensure a layer of management oversight to review all certifications before final approval until such time as onsite management is trained and has been proven to follow HUD’s and its own requirements.

Ensure that the owner, management agent, and staff complete training to ensure that they understand their duties, including HUD’s and local tenant eligibility and certification requirements.

Monitor Englewood Apartments to ensure that its staff properly maintains tenant files and completes required certifications in accordance with HUD’s and its own requirements.

Ensure that Englewood Apartments’ owner and its identity-of-interest management agent provide necessary oversight to its onsite staff.

Require Englewood Apartments’ owner to further develop a formalized process to use when running and reviewing EIV reports.

Require Englewood Apartments’ owner to ensure that the management agent and staff complete EIV training to ensure that staff members understand their duties and both HUD’s and Englewood Apartments’ own requirements.

Monitor Englewood Apartments to ensure that it properly runs and reviews the EIV reports.

Ensure that Englewood Apartments’ owner and its identity-of-interest management agent provide necessary oversight to its onsite staff.

Provide documentation to show that the proposal of the vendor that it selected and paid $860,132 was the most advantageous or reimburse its program from non-Federal funds for any amounts that it cannot support.

Develop and implement controls to monitor its agent to ensure that it procures products and services in accordance with applicable Federal procurement requirements.

Reimburse its program $156,675 from non-Federal funds for the ineligible payments it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to ensure that it obtains waivers from HUD before entering into agreements that create conflict-of-interest situations.

Provide training and technical assistance to the Authority to ensure that it understands the proper use of intergovernmental agreements in accordance with HUD requirements.