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Implement procedures that align with HUD’s requirements and controls to ensure that visual assessments for lead-based paint are completed at least every 12 months.
Develop a quality control process to ensure that records for the remaining 1,385 units contain evidence of lead-free status. If adequate documentation is not found to support that all lead-based paint was identified and abated and clearance was achieved as required, the Authority should complete a lead-based paint inspection of the developments to determine whether they are lead free.
Perform a search for historical documentation to support the lead-free status of the 15 units and the associated developments. If adequate documentation is not found to support that all lead-based paint was identified and abated and clearance was achieved as required, the Authority should complete a lead-based paint inspection of the developments to determine whether they are lead free.
Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training for the Authority’s staff on the appropriate testing methodology for confirming that a child has an EBLL and to provide technical assistance on procedures and controls to address the issues cited in this finding.
Develop and implement adequate procedures and controls to ensure that environmental investigations are completed when required.
Develop and implement adequate procedures to ensure that confirmed EBLL cases, unconfirmed EBLL cases, and environmental investigations are reported to HUD.
Work with HUD’s Office of Lead Hazard Control and Healthy Homes to provide technical assistance to the Authority’s staff to develop and implement policies, procedures, and controls for managing cases of children with EBLLs to ensure compliance with the LSHR, including attempts to collaborate with public health departments to identify cases of EBLL in children under 6 years of age under its HCV Program and updating its policies and procedures accordingly.
Develop and implement policies and procedures that align with HUD’s requirements and controls to ensure that owners follow the requirements of the LSHR.
Work with its contractor to ensure that the contractor’s inspectors receive training on how to properly identify and categorize life-threatening deficiencies.
Implement controls over its inspection processes and procedures to ensure that emergency failures are properly identified, reinspected, and corrected within 24 hours in accordance with its HCV Program administrative plan or the housing assistance to the owner is stopped.
