Monitor environmental reviews of PIH-funded properties with potential contamination.

Ensure that OCFO has the data it needs to record a reasonable PIH prepayment estimate related to supplemental pandemic funding in fiscal year 2021 and beyond if additional funding is provided.

Prepare a white paper regarding the accounting treatment for each type of funding disbursed under the HCVP, to include a comparison of the qualities the funding embodies against the qualities that are necessary for it to be considered a prepayment versus an expense according to generally accepted accounting principles. The Chief Financial Officer should work with PIH to gather the information necessary to complete this analysis and have PIH review it to ensure the accuracy of the program information used.

Develop and implement a policy that requires OCFO to review all new program notices, new regulations, and new types of funding and evaluate each against the accounting standards and current accounting treatment (as documented in white papers or other forms) to determine whether OCFO’s treatment complies with generally accepted accounting principles and if not, propose changes. The policy should include formal designation of roles and responsibilities as well as internal controls to ensure proper review and approval of conclusions.

Once additional data are available, and at least quarterly, reduce the CARES Act PIH prepayment by the amount actually spent by PHAs or an estimated amount with a low level of estimation uncertainty.

As part of the validation process for CPD’s accrued grant liabilities, review CPD’s accrued grant liabilities estimation methodology to ensure that it is based on verifiable grantee supporting documentation and all assumptions and variables used for the grant accrual estimate were properly established, supported, and documented.

Research the survey responses that resulted in a positive cash on hand balance to determine whether a cash advance exists. If so, the Chief Financial Officer should coordinate with CPD to (1) determine whether the grantees have proper documentation and approvals allowing for cash advances and (2) develop and implement procedures to estimate and account for cash advances for financial reporting purposes.

Investigate other methods for validating CPD’s accrued grant liabilities estimate, including the use of other sampling units, which could provide additional relevant information that can be used to produce more reasonable results and reduce estimation uncertainty to a low level.

Work with the Director of the Office of Multifamily Asset Management and Portfolio Oversight to ensure that all debt owed to HUD is identified, accurately reported in HUD’s financial records, and properly monitored to ensure compliance with applicable laws and regulations.

Require the Authority to reimburse the six tenants who overpaid rent totaling $1,550 using non-Federal funds.

Require the Authority to develop and implement internal control procedures that support its policy and ensure a proper tenant selection process when selecting tenants for housing.

Ensure that the Authority follows all applicable HUD requirements related to accessing, use, and safeguarding credentials of HUD systems.

Conduct a nationwide assessment of the impact of portability and determine whether technical assistance is necessary for certain public housing agencies. Consider seeking input from public housing agencies and industry groups to evaluate the potential impact of portability and (1) determine whether improvements to the portability aspect of the program are warranted, and (2) if deemed warranted, determine how the improvements will be implemented for public housing agencies portable vouchers (both port-in and port-out).

Pursue collection or recapture $248,514 ($115,335 $133,179) from the applicable public housing agencies for the overpayment of category 2b portability set-aside funds and special administrative fees cited in this finding.

Distribute $35,189 to the applicable public housing agencies for the underpayment of special administrative fees for portability cited in this finding.

Review the calculations and distributions of funds for the 2019 category 2b portability set-aside and special administrative fees for portability to ensure that the spreadsheet errors did not carry forward from the previous calculations.

Request indemnification for the 7 of the 11 loans that had material underwriting deficiencies (appendix D). The unpaid balance for these loans is $1.3 million and the estimated potential loss to HUD is $607,598.

Require the lender to develop and implement enhanced policies and procedures to ensure electronic signatures from borrowers are properly supported.

Require the lender to fully implement its quality control plan with respect to reverifications and provide HUD with periodic reports for 12 months to ensure that it conducts its quality control reviews in accordance with the requirements.

Put $256,824 to better use by cancelling the project-based voucher housing assistance payments contract resulting from the RAD conversion. The Authority should work with HUD and the owner to protect the tenancy of the affected tenants at the time of contract cancellation.