Implement adequate procedures and controls to ensure that the Authority complies with HUD’s conflict-of-interest requirements, including but not limited to ensuring that (1) its staff is appropriately trained and familiar with HUD’s requirements for units owned by entities it substantially controls and (2) future contracts to perform housing quality standards inspections for program units owned by entities substantially controlled by the Authority are with a HUD-approved independent third party.

Seek retroactive approval or reimburse its program $10,124 for program funds paid to the contractor not approved by HUD for the housing quality standards inspections for units owned by entities substantially controlled by the Authority.

Support that the converted units met HUD’s housing quality standards or reimburse its program $1,206,046 from non-Federal funds ($1,053,618 in housing assistance payments $152,428 in administrative fees).

Request that HUD’s Quality Assurance Division continue reviewing the Agency’s (1) writeoff of accounts receivable, (2) deleted adjustments to accounts payable and receivable, and (3) adjustments to accounts payable and receivable as part of its financial and program management and operations review.

Implement adequate procedures and controls to ensure that it deletes adjustments to accounts payable and receivable and makes adjustments to accounts payable and receivable in accordance with HUD’s regulations and its administrative plan.

Provide sufficient documentation to support that an adjustment to accounts payable and five adjustments to accounts receivable were appropriate. If the Agency cannot do this, it should make the appropriate accounting entries and take the appropriate actions.

Determine whether the tenant paid the landlord nearly $1,284 for housing assistance payments that the Agency did not make to the landlord. If the tenant paid the landlord, the Agency should make the appropriate accounting entries and reimburse the tenant from program funds. If the tenant did not pay the landlord, the Agency should reinstate the adjustments to accounts payable that were inappropriately deleted and pay the landlord from program funds.

Provide sufficient documentation to support that the two deleted adjustments to accounts payable and four deleted adjustments to accounts receivable were duplicate or incorrect adjustments that should have been deleted. If the Agency cannot do this, it should make the appropriate accounting entries and take the appropriate actions.

Implement adequate procedures and controls to ensure that it follows its bad debt writeoff policy when it writes off accounts receivable.

Implement adequate procedures and controls to ensure that it maintains sufficient documentation to support housing and utility assistance payments and that it makes a reasonable effort to collect debts.