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.

Provide support to show that the performance history element was factored as part of the grantees’ capacity to manage the grants awarded through the 2025 NOFO.

Reevaluate ‘High Risk’ designation criteria as part of the SOP update and reimplement its updated ‘High Risk’ criteria to reflect how grantees will be designated as ‘High Risk’ within the program. In addition, train OLHCHH staff on the new ‘High Risk’ designation criteria stated in the SOP.

Notify grantees of HUD’s updated ‘High Risk’ designation criteria and HUD’s expectations when designated as ‘High Risk.’

Provide assistance to the nine identified ‘High Risk’ grantees that will help meet established performance benchmarks to be completed by the end of the respective grants in 2026.

Recapture $3,775,916 in undisbursed grant funds not used to meet agreed-upon performance benchmarks for the two identified ‘High Risk’ grantees whose period of performance ended in June and July 2025, respectively. In addition, identify those grantees that received 2020 through 2022 LBPHC and LHRD grants with a period of performance that ended on or before December 31, 2025, to determine whether agreed-upon performance benchmarks were met by that date, and take appropriate actions that include recapturing undisbursed grant funds.

Consider grantees’ suggestions to improve training sessions, technical assistance, and communication of information that grantees can use to help meet agreed-upon performance benchmarks. In addition, provide documentation to support the guidance OLHCHH plans to share with grantees to ensure agreed-upon performance benchmarks are met.

Reassess, establish, and incorporate a maximum review period of grantee-submitted QPRs into an SOP. Inform staff of the review period to ensure consistency and understanding of HUD’s expectations of the time to review grantee-submitted QPRs. In addition, establish formal guidance and implement internal controls to monitor and track the timely review of QPRs.

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.