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.

Implement procedures and controls to ensure that visual assessments for lead-based paint are completed at least every 12 months.

Implement procedures and controls to ensure that risk assessments and reevaluations are conducted in accordance with HUD’s requirements.

Obtain lead-based paint risk assessments for the five developments for which hazard reduction work was completed and perform the required reevaluations.

Determine whether the remaining five developments (Imperial Courts, Mar Vista Gardens, Nickerson Gardens, Ramona Gardens, and Rancho San Pedro) have deteriorated paint and if so, obtain lead-based paint risk assessments and reevaluations when applicable.

Coordinate with HUD’s Office of Lead Hazard Control and Healthy Homes to obtain training for the Authority’s employees responsible for managing lead-based paint on the management of lead-based paint, including the requirements for visual assessments, risk assessments, reevaluations, and hazard reduction.

Require that the PLUS system for receiving, processing, and assigning applications tracks applications and captures application intake, screening, and status, including key dates; captures data on the type of underwriter used; includes a portal for receiving documents and communicating with lenders; and generates FHA loan numbers. This will allow HUD to identify, monitor, and address processing delays and issues on a continuous basis; evaluate its performance and processes; and manage future challenges.

Update policies and procedures to include methods that will be used when applications exceed underwriter capacity, align intake and screening processes, and explain when timeframes will be enforced, including in PLUS.

Issue an industry wide letter to reinforce how intake, screening, and enforcement of timeframes will be handled.

Update relevant policies and procedures for appraiser roster management so that they align with each other and with regulations and reflect HUD practice. At a minimum, the policies and procedures should clearly cover appraiser roster status, license expiration, disciplinary actions, removals, data accuracy, and documentation.

Maintain historical data for each appraiser record, including history on expiration dates, when appraisers are moved on or off the appraiser roster and when they are and are not allowed to be assigned to conduct appraisals.

Improve quality assurance processes by adding steps to verify that the appraiser roster is accurate and reliable over time through testing of its logic-based system controls and data fields.

Develop and implement adequate procedures to ensure that confirmed EBLL cases, unconfirmed EBLL cases, and environmental investigations are reported to HUD.

Develop and implement adequate procedures and controls to ensure that environmental investigations are completed when required.

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.

Perform a search for historical documentation to support the lead-free status of the 15 units and the associated developments. If adequate documentation is not found to support that all lead-based paint was identified and abated and clearance was achieved as required, the Authority should complete a lead-based paint inspection of the developments to determine whether they are lead free.

Develop a quality control process to ensure that records for the remaining 1,385 units contain evidence of lead-free status. If adequate documentation is not found to support that all lead-based paint was identified and abated and clearance was achieved as required, the Authority should complete a lead-based paint inspection of the developments to determine whether they are lead free.

Implement procedures that align with HUD’s requirements and controls to ensure that visual assessments for lead-based paint are completed at least every 12 months.

Implement policies and procedures that align with HUD’s requirements and controls to ensure that reevaluations are completed when required.

Implement controls to ensure that accurate lead disclosures are provided to prospective and current tenants.