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We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of the physical condition of public housing developments.  Our audit objective was to assess HUD’s oversight of the physical condition of public housing developments; specifically, whether HUD had adequate oversight of public housing agencies’ (PHA) (1) corrective actions in response to periodic Real Estate Assessment Center (REAC) inspections and (2) annual self-inspections to ensure that units were maintained in decent, safe, and sanitary condition.

Properties receiving assistance through HUD’s public housing program are periodically inspected by a HUD contractor using standards established by REAC.  These “REAC inspections” evaluate five areas of a public housing development:  site, building exterior, building systems, common areas, and dwelling units.  If deficiencies in these areas are identified, the inspector records their severity within one of the following four categories: (1) no health and safety hazards, (2) non-life-threatening health and safety, (3) life-threatening exigent health and safety, or (4) fire safety.  HUD requires public housing agencies (PHA) to address life-threatening exigent health and safety and fire safety smoke detector deficiencies identified during REAC inspections within 24-hours.  HUD monitors PHAs’ corrections of life-threatening deficiencies.

We found that HUD field offices were inconsistent in overseeing whether PHAs corrected life-threatening deficiencies identified during REAC inspections.  In addition, HUD does not track PHAs’ corrections of non-life-threatening health and safety deficiencies identified during REAC inspections.  These conditions occurred because HUD did not have a standardized policy or a nationwide protocol to guide its field offices’ oversight of PHAs to ensure that all health and safety deficiencies were corrected after a REAC inspection.  Instead, HUD relied on its field offices to maintain their own policies and procedures for monitoring PHAs’ unit conditions.  However, the field offices generally did not maintain their own written policies and procedures, resulting in inconsistencies regarding what should be done.  As a result, HUD lacked assurance that PHAs corrected identified life-threatening and non-life-threatening deficiencies.  If HUD implements a nationwide protocol for monitoring and tracking PHAs’ efforts to address inspection results, it could have greater assurance that tenants residing in public housing are living in units that are decent, safe, and sanitary.

In addition to the REAC inspection, HUD requires PHAs to perform routine self-inspections of public housing properties.  These self-inspections include an annual visual assessment of the property to look for all deficiencies, and to determine the maintenance and modernization needs of the properties.  We found that HUD staff had varying interpretations of its requirements regarding the number of public housing units PHAs should self-inspect annually.  Further, HUD’s field office staff generally did not monitor PHAs for compliance with HUD’s requirements for self-inspections.  These conditions occurred because HUD’s guidance was not clear regarding (1) the number of units PHAs should inspect annually and (2) how its field office staff should monitor PHAs to ensure that self-inspections of public housing units were conducted.  Without clear guidance regarding its requirements for self-inspections, HUD lacked assurance that PHAs properly performed self-inspections of public housing units to determine maintenance and modernization needs.  HUD could also miss opportunities to provide technical assistance to PHAs through early intervention when self-inspections identify systemic deficiencies.  Further, because REAC’s inspection sampling methodology to select between 1 and 27 public housing units is based on the expectation that PHAs are completing self-inspections of 100 percent of their public housing units, REACs’ sampling methodology may no longer be appropriate.

We recommend that HUD develop and implement a nationwide inspection review protocol and associated training for its field office staff; determine whether PHAs are required to perform inspections on 100 percent of their public housing units annually; and if so, develop clear, specific guidance on the number and frequency of the self-inspections.  If 100 percent annual self-inspections are not required, we recommend that HUD determine whether the rationale for REAC to inspect a sample of public housing units, rather than 100 percent, remains appropriate. 

Recommendation Status Date Issued Summary
2023-CH-0004-001-A Closed May 30, 2023

Develop and implement a nationwide inspection review protocol, which includes but is not limited to (1) whether field office staff should mark verification of PHA corrections of life-threatening deficiencies in PASS or any future tracking systems, (2) acceptable documentation for offsite verifications, and (3) whether field office staff should discuss or verify corrections of non-life-threatening deficiencies.


Corrective Action Taken

HUD's Office of Field Operations (OFO) created a protocol describing how it would perform quality control reviews of field office oversight of PHAs’ corrections of life-threatening deficiencies. The implementation of this recommendation resulted in HUD creating a protocol that established consistency in the way HUD field office staff monitored public housing agencies’ corrections of life-threatening deficiencies.

2023-CH-0004-001-B Open May 30, 2023

Develop and implement training for field offices that addresses reviewing or following up with PHAs about the correction of life-threatening and non-life-threatening deficiencies and how (1) to review physical inspection reports to effectively ensure that PHAs correct physical deficiencies, (2) PHAs should address or correct each type of deficiency observed in the REAC physical inspection report, and (3) to use PASS or any future tracking system.


Status

On March 27, 2024, the OFO will host its inaugural office hours to discuss the life threatening and severe deficiencies protocol with FO staff. The agenda for the training will include the NSPIRE system and the timeliness and responsibilities for correcting life-threatening and non-life threatening deficiencies.


Analysis

To fully address this recommendation, OFO must provide evidence that the training it develops and implements addresses reviewing or following up with PHAs about the correction of life-threatening, severe, and non-life-threatening deficiencies and how (1) to review physical inspection reports to effectively ensure that PHAs correct physical deficiencies, (2) PHAs should address or correct each type of deficiency observed in the REAC physical inspection report, and (3) to use PASS or any future tracking system.

Implementation of this recommendation will result in public housing units that are decent, safe, and sanitary because it mandates oversight to ensure PHAs are addressing identified deficiencies.

2023-CH-0004-001-C Closed May 30, 2023

Implement a system to track field office inspection review activities and create a repository for the support documentation collected to verify the correction of life-threatening deficiencies.


Corrective Action Taken

HUD’s Office of Field Operations (OFO) had created a quality assurance tracker as well as a life-threatening deficiency tracker, which contained data specific to the inspections selected by OFO HQs, for quality assurance reviews. The documentation (photographs, work orders, etc.) of the life-threatening deficiency correction was maintained in HUD’s NSPIRE Salesforce system.

Implementation of the recommendation resulted in HUD creating a system to track HUD field offices’ verifications of PHAs’ corrections of life-threatening deficiencies.

2023-CH-0004-002-A Closed May 30, 2023 We recommend that the Deputy Assistant Secretary for REAC determine whether PHAs are required to perform annual inspections on 100 percent of their public housing units annually and issue clarifying guidance to all PHAs.
2023-CH-0004-002-B Closed May 30, 2023 If REAC determines that 100 percent annual self-inspections are required, establish specific guidance to address the number of units and frequency of PHA self-inspections. If not required, REAC should evaluate whether HUD’s rationale for inspecting a statistical sample rather than 100 percent of public housing units remains appropriate.
2023-CH-0004-002-C Open May 30, 2023

Develop and implement a nationwide protocol for field offices, describing how PHA self-inspections should be reviewed, based on REAC's determination of the number and frequency of PHA self-inspections.


Status

The OFO is working on the protocol/job aid and will keep OIG updated on progress made. The final action target date is August 15, 2024.


Analysis

To fully resolve this recommendation, HUD must provide evidence that demonstrates it developed a nationwide protocol and implemented it across all HUD field offices.