Conduct risk assessments in public housing without adequate lead-based paint inspection documentation to ascertain the existence of lead-based paint hazards.

Conduct lead-based paint inspections at public housing abated through removal methods where an abatement report is unavailable to ensure that units are “lead-free.”

Abate or implement interim control measures to reduce the risk of exposure to lead-based paint hazards identified through risk assessments.

Implement an ongoing maintenance program for lead-based paint to ensure unabated and “lead-safe” units remain hazard free.

Implement adequate policies and procedures regarding the management of lead-based paint in its public housing, including maintaining adequate records, completing interim controls, and conducting ongoing maintenance for lead-based paint hazards.

Ensure that it provides appropriate and accurate lead-based paint disclosures to prospective and current tenants.

Revise and update the Authority’s policies to ensure that environmental investigations are completed for EBLL cases and ensure that HUD and residents are notified of the results of environmental investigations in a timely manner.

Coordinate with HUD to provide training for the Authority’s employees on managing of lead-based paint hazards and to provide technical assistance such as developing written procedures, improving internal controls, or contracting with subject matter experts to address the issues cited in this report.

Provide evidence that it abated lead-based paint hazards in one EBLL case where the Authority did not abate the hazards identified in an environmental investigation.

Use the fraud risks and fraud schemes HUD OIG identified and involve relevant stakeholders to create a program-specific fraud risk inventory to support HUD’s anti-fraud efforts and enhance oversight of the Capital Fund program.

Communicate Capital Fund program fraud risks and schemes to all its stakeholders, including PHAs, to increase program effectiveness.

Determine whether data currently collected from PHAs can be leveraged to identify and mitigate fraud risks and consider whether any additional data needs to be collected or systems enhanced to mitigate fraud risks.

Implement procedures and controls for targeting non-FHA-insured RAD PBV projects to monitor the physical conditions and reserve for replacement accounts.

Implement procedures for monitoring property owners’ reserve for replacement accounts for compliance with HUD’s requirements, using reserve for replacement account data collected on projects from PHAs.

Provide inspection reports for the units identified in this report that failed to meet HQS showing that the units and associated buildings meet HUD’s current physical condition standards.

Implement a policy to ensure that monitoring of RAD PBV projects includes, at a minimum, a review of the accuracy of the reserve for replacement account balances and compliance with HUD’s physical condition and inspection requirements.

Review the reserve for replacement accounts for the 12 underfunded projects to ensure that the account balances are maintained in accordance with the applicable HUD requirements and executed HUD business documents and require owners to fully fund any underfunded reserves, as applicable.

Review the reserve for replacement accounts for the 14 project owners that did not make annual adjustments for inflation, as identified in the capital needs assessment, to determine whether the account balances are sufficient to meet anticipated capital needs. If the account balances are not sufficient, HUD should require the owners to appropriately fund the accounts.

Implement a plan to review the reserve for replacement accounts for all RAD PBV projects to ensure that reserve for replacement accounts are appropriately funded.

Obtain documentation from the PHAs to support that more than $1 million in withdrawals from the eight reserve accounts complied with HUD’s requirements or require the project owners to reimburse the reserve accounts for the unsupported withdrawals.