Develop and implement a review and verification process to ensure that data provided by MTW PHAs as support for compliance with the statutory requirements, that is not reported in HUD systems is accurate, complete, and supported.

Develop and implement a process to ensure that corrections or updates to PHA information are reflected in either restated or subsequent MTW annual reports.

Require PHAs to retain supporting documentation for all data elements reported in their annual reports and program data not captured in HUD systems.

Develop and implement a process to ensure that appropriate outcomes are assessed for each PHA’s local MTW program.

Conduct an analysis to determine whether the changes to form HUD-50900 allow PHAs and HUD to appropriately measure the benefits and impacts of PHAs’ MTW program to include whether additional changes to the form are warranted to appropriately evaluate results of the MTW program.

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.

Systematically evaluate whether control deficiencies identified by the AIR program have affected the accuracy or completeness of HUD’s financial statements. This assessment should include: 
a) Review relevant financial statement line items, disclosure, and account balances for misstatements attributable to ineffective controls;
b) Document the evaluation results, including the rationale for conclusions regarding the presence or absence of misstatements;
c) Make correcting entries to September 30, 2025 balances, as appropriate;
d) Retain supporting analysis for both internal and external review; and
e) Leverage test of balances results to inform remediation efforts.

Work with program offices through remediation activities to determine the underlying causes of the control deficiencies identified by the AIR program.
 

Based on the causes identified, coordinate with the program offices through remediation activities to develop corrective action plans with defined milestones, responsible parties, and timelines. Progress should be tracked, documented, and periodically reported to senior management.