Recommendations

Transparency to stakeholders is a key priority within HUD OIG. The Recommendation Dashboard provides stakeholders and the public with data on open and closed recommendations for HUD programs and funding recipients. Through the dashboard, users can identify the total number of open recommendations, review the costs associated with specific recommendations, and visualize key data elements through graphs and charts. For additional information visit recommendations FAQs.

Open Recommendations by Oversight Area

Housing Assistance

Community Development

Disaster Recovery

Financial Risk and Accountability

Technology and Cybersecurity

Health and Safety

HUD's Operations

Priority Recommendations
Open Recommendations

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Open Recommendations by Oversight Area
Oversight Area	Priority Recommendations	Open Recommendations
Housing Assistance	75	100
Community Development	3	75
Disaster Recovery	3	82
Financial Risk and Accountability	6	130
Technology and Cybersecurity	4	88
Health and Safety	1	53
HUD's Operations	4	100
Total	96	628

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We audited the Housing Authority of the City Long Beach’s Housing Choice Voucher Program based on a referral from the U.S. Department of Housing and Urban Development’s (HUD) Los Angeles Office of Public Housing due to concerns regarding its financial activity control weaknesses. The objective of…

Audit #: 2020-LA-1002 Oversight Area: Rental Assistance Date Published: March 10, 2020

Develop and implement a HUD-approved cost allocation plan(s) that appropriately represents the benefit received by the Authority from the City’s HHS department and allocates overhead and operating costs to all programs managed by the Authority.

Support the eligibility of the $1,965,990 in overhead allocations through the application of a HUD-approved allocation plan (including offsetting the amount by applicable reimbursements) or repay the Housing Choice Voucher Program from non-Federal funds.

Determine the appropriate amount of general operating costs totaling $2,544,266 that applied to the Housing Choice Voucher Program in accordance with a HUD-approved cost allocation plan (including offsetting the amount by applicable reimbursements) and repay overcharges (estimated at $50,947) to the Program from the other applicable programs as appropriate or from non-Federal funds.

Support the eligibility of the $25,827 in personnel expenses from SPC (including offsetting the amount by applicable reimbursements) or repay its Housing Choice Voucher Program from the other applicable programs as appropriate or from non-Federal funds.

Support the eligibility of the $64,150 for accounting services charged to the Housing Choice Voucher Program that applied to other Authority programs (including offsetting the amount by applicable reimbursements) or repay the Program from the other applicable programs as appropriate or from non-Federal funds.

Support the reasonableness of the $340,701 Casterline contracts or repay the Housing Choice Voucher Program any amount that cannot be supported using non-Federal funds.

Support the reasonableness of the $33,415 Genesis contract or repay any amount that cannot be supported from non-Federal funds.

Establish and implement additional procedures and controls to ensure that City personnel responsible for administering procurement on the Authority’s behalf follow procurement and contracting requirements and maintain applicable supporting documentation in accordance with HUD requirements.

Repay the Housing Choice Voucher Program $5,648 from non-Federal funds for the unallowable expenses.

Develop and implement procedures and controls to ensure that ineligible food costs are not charged to the Program.

We audited the Springfield Housing Authority’s Public Housing Operating Fund and Capital Fund programs because the Authority ranked fifth highest on our risk assessment of Massachusetts public housing agencies and is the third largest in the State. In addition, we had not audited the Authority in…

Audit #: 2020-BO-1002 Oversight Area: Rental Assistance Date Published: March 19, 2020

Support that $916,132 spent on contracts was fair and reasonable in accordance with Federal requirements or repay the Operating Fund or Capital Fund program from non-Federal funds any amount that cannot be supported.

Support that $408,968 in funds not yet spent on contracts would be fair and reasonable or reallocate the funds to ensure that they will be put to their intended use.

Reprocure any contracts for which cost reasonableness cannot be supported and contracts were not properly awarded to ensure compliance with HUD requirements.

Ensure that all Authority staff members working with procurements and contract administration receive Federal procurement training.

Establish and implement adequate record-keeping procedures to comply with Federal procurement requirements, including a checklist for the file to ensure that they complete all procurement requirements and receive all required documents.

Ensure that all architectural and engineering contracts or task orders awarded during our audit period are reviewed for cost reasonableness.

Repay the Operating Fund program from non-Federal funds for the $37,941 in ineligible costs when the amount paid exceeded the contract value.

Establish and implement adequate controls so the Authority does not exceed the contract amount without appropriate contract amendments and written approvals.

Establish and implement adequate controls to obtain all of the required project completion documentation prior to final payment.

We audited the Philadelphia, PA, Housing Authority’s use of public housing program operating funds because we received a complaint alleging that the Authority misused U.S. Department of Housing and Urban Development (HUD) funds. Our objective was to determine whether allegations from the complaint…

Audit #: 2020-PH-1001 Oversight Area: Rental Assistance Date Published: April 20, 2020

Provide documentation to show that the proposal of the vendor that it selected and paid $860,132 was the most advantageous or reimburse its program from non-Federal funds for any amounts that it cannot support.

Develop and implement controls to monitor its agent to ensure that it procures products and services in accordance with applicable Federal procurement requirements.

Reimburse its program $156,675 from non-Federal funds for the ineligible payments it made due to the conflict-of-interest situation identified by the audit.

Develop and implement controls to ensure that it obtains waivers from HUD before entering into agreements that create conflict-of-interest situations.

Provide training and technical assistance to the Authority to ensure that it understands the proper use of intergovernmental agreements in accordance with HUD requirements.

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General, audited Englewood Apartments’ Project-Based Section 8 Rental Assistance program based on a request from HUD’s Region 7 Office of Multifamily Housing Programs. HUD conducted a management and occupancy review in…

Audit #: 2020-KC-1001 Oversight Area: Rental Assistance Date Published: June 8, 2020

Require the Englewood Apartments’ owner to repay HUD from non-project funds the projected $377,108 in housing assistance payments for tenants who were not eligible for assistance.

Require Englewood Apartments to support that $24,295 in unsupported housing assistance payments was eligible and accurate. Englewood Apartments’ owner should repay any subsidy overpayments to HUD from non-project sources. Further, the owner should reimburse tenants for overcharged rents or enter into a repayment agreement with tenants who were undercharged due to nondisclosure of income.

Require the Englewood Apartments’ owner to implement appropriate controls, including a formalized process, to use when conducting initial certifications and interim and annual recertifications to ensure that tenants are eligible, housing assistance payments are accurate, and tenant files contain all required documentation to comply with HUD’s and its own requirements. In addition, the updated controls should ensure a layer of management oversight to review all certifications before final approval until such time as onsite management is trained and has been proven to follow HUD’s and its own requirements.

Ensure that the owner, management agent, and staff complete training to ensure that they understand their duties, including HUD’s and local tenant eligibility and certification requirements.

Monitor Englewood Apartments to ensure that its staff properly maintains tenant files and completes required certifications in accordance with HUD’s and its own requirements.

Ensure that Englewood Apartments’ owner and its identity-of-interest management agent provide necessary oversight to its onsite staff.

Take appropriate administrative action, up to and including debarment, against the owner for the violations cited in this report including, amongst others, failure to perform the required inspections to ensure that the units the owner were billing for assistance were decent, safe, and sanitary.

Require Englewood Apartments’ owner to further develop a formalized process to use when running and reviewing EIV reports.

Require Englewood Apartments’ owner to ensure that the management agent and staff complete EIV training to ensure that staff members understand their duties and both HUD’s and Englewood Apartments’ own requirements.

Monitor Englewood Apartments to ensure that it properly runs and reviews the EIV reports.

Ensure that Englewood Apartments’ owner and its identity-of-interest management agent provide necessary oversight to its onsite staff.

We audited Vineville Christian Towers’ (project) Rental Assistance Demonstration Program (RAD) conversion in accordance with our annual audit plan. Our audit objective was to determine whether the project’s RAD conversion to the Section 8 Project-Based Voucher Program was completed in accordance…

Audit #: 2020-AT-1003 Oversight Area: Rental Assistance Date Published: August 31, 2020

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.

Reimburse its Section 8 program $138,925 in associated administrative fees from non-Federal funds for the improper issuance of tenant protection assistance and an improper conversion to the project-based voucher program.

Develop and implement procedures to ensure that forms HUD-50059 and or tenant profiles is received from HUD before providing tenant protection assistance resulting from a completed housing conversion action.

Provide adequate training to staff associated with administering tenant protection and project-based vouchers to help address its lack of familiarity with requirements and ensure compliance with program requirements.

Develop and implement procedures for executing Section 8 Project-Based Voucher Program housing assistance payments contracts related to RAD conversions.

We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of portability in the Housing Choice Voucher Program based on a congressional inquiry from Senator Grassley’s office. Our audit objective was to determine whether HUD had adequate oversight of portability in the…

Audit #: 2020-CH-0006 Oversight Area: Rental Assistance Date Published: September 9, 2020

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.

We audited the Buffalo Municipal Housing Authority’s management of its Commodore Perry Homes development. We selected the Authority based on congressional interest. Half of the development’s buildings were demolished more than 20 years ago, and the majority of the remaining buildings and units…

Audit #: 2022-NY-1001 Oversight Area: Rental Assistance Date Published: January 11, 2022

Work with the Authority to determine whether the buildings represent an imminent threat to public safety from physical deterioration and whether activities to control the situation would be exempt under the Part 58 environmental review process or excluded under the Part 50 environmental review process. If it qualifies, require the Authority to immediately take actions necessary to control the imminent threat to public safety before the full environmental review is done.

Determine whether it would be beneficial for HUD to conduct a Part 50 environmental review of the development or if the Authority should conduct a Part 58 environmental review, and implement the decision to ensure that the environmental review is conducted as soon as possible as required under the action plan.

Continue to provide training and technical assistance to ensure that the Authority understands relevant requirements for the various asset repositioning options, including milestone and disposition requirements.

Provide certifications and supporting documentation to show that it has identified and addressed urgent health and safety issues at the development, such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors.

Develop and implement a plan to routinely identify and address recurring urgent health and safety issues such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors while the property remains vacant and throughout future asset repositioning efforts.

Develop and implement a plan to use available asset repositioning options for the remaining 284 public housing units at the Commodore Perry Homes development, including 274 dwelling units and 10 nondwelling units.

Develop and implement a plan for the original property related to the 46 units converted under the RAD transfer of assistance option to ensure that the property and proceeds from its disposition are used in accordance with requirements.

If the Authority does not follow through on its asset repositioning plans, misses deadlines, or it otherwise becomes clear that the plan is no longer feasible, work with the HUD’s Special Applications Center, Office of Recapitalization, and other offices as appropriate, to consider and use available remedies such as revoking approval and enforcing required conversion.

We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of its public housing agencies’ (PHA) reasonable accommodation policies and procedures. We initiated this audit because we identified an increase in housing discrimination complaints based on a failure to provide a…

Audit #: 2022-BO-0001 Oversight Area: Rental Assistance Date Published: February 7, 2022

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs update its compliance monitoring guidance to include a requirement for personnel to review PHAs reasonable accommodations policies and procedures.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs update and consolidate requests for reasonable accommodation policies and procedures to ensure that there is centralized guidance available for the field offices and PHAs.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs conduct additional outreach efforts to educate tenants and PHAs on their rights and responsibilities related to requests for reasonable accommodation, including technical assistance, webinars, and external communications to inform PHAs about their responsibilities and how to evaluate requests for reasonable accommodation, and help families understand their rights.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs require that PHAs track requests for reasonable accommodation, including the date of the request, the type of request, and the disposition and date of any action taken that should be made available to HUD at its request.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs review the joint agreement between HUD PIH and FHEO, including the Section 504 checklist, and modify, update, or recommit to it to ensure that the role of PIH and the responsibility for conducting civil rights front-end reviews is clearly defined.

We recommend that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs ensure that personnel receive training on how to conduct the civil rights front-end reviews, including a review of PHAs reasonable accommodation policies and procedures.

We audited the Housing Authority of Plainfield, NJ’s administration of its public housing programs. We selected the Authority based on a risk analysis of public housing agencies in New Jersey that considered the size of the agency, the amount of operating and capital funds received, and previous…

Audit #: 2022-NY-1002 Oversight Area: Rental Assistance Date Published: March 30, 2022

Terminate the current lease and pay for any fees needed to terminate the lease from non-Federal funds.

Execute and record the release of the current lease with the third party and ensure that the declaration of trust is returned to the first priority position.

Correct the reporting and use of proceeds received from the current lease, thereby putting $1,278,260 to better use. This requirement includes properly recording the proceeds as restricted nonrental program income on its financial data schedule, placing any unspent funds into an account subject to a general depository agreement until spent, providing a detailed accounting of the use of the proceeds, reporting the use of any proceeds used for demolition or other expenses in a revised 5-year annual plan, and making any other updates needed to ensure that funds are properly recorded and used.

Repay from non-Federal funds any proceeds used for unallowable expenses identified in recommendation 1C.

Submit a Section 18 application to obtain HUD approval of any proposed new lease agreement prior to its execution, in compliance with the United States Housing Act of 1937 and 24 CFR Part 970.

Improve controls over the proper execution and recording of all declaration of trust documents.

Implement controls to ensure that it does not enter into future third-party agreements unless the Authority follows applicable requirements in Notice PIH 2017-24 (HA), the annual contributions contract, 24 CFR Part 970, and the United States Housing Act of 1937.

Implement controls to ensure that future disposition proceeds are properly accounted for and used only for planned, approved purposes.

Place the Authority onto a zero threshold review process, requiring that all draws for funds go through field office review until the Authority completes all actions needed to close recommendations 1A through 1H.

Consider and take additional action if the Authority does not complete recommendations 1A and 1B before submitting its next annual plan, including withholding further awards for its program, conditioning future grant funds, and other remedies that may be legally available until the Authority completes recommendations 1A and 1B.

Provide technical assistance to the Authority regarding the deficiencies identified with the rooftop lease and related proceeds, and Federal requirements for property disposition.

Support that $2,870,374 paid for goods and services was reasonable in accordance with applicable requirements or repay its Public Housing Operating Fund or Capital Fund programs from non-Federal funds for any amount that it cannot support or that is not considered reasonable.

Support that $1,236,210 in funds not yet spent on the contracts reviewed, along with any new procurements, would be reasonable or reallocate the funds to ensure that they will be put to their intended use

Review any ongoing time-and-materials contracts and if requirements were not followed, remedy the noncompliance or reprocure the contracts to ensure compliance with HUD requirements.

Ensure that all Authority staff members working with procurements and contract administration receive procurement training on applicable requirements, including the requirements related to cost reasonableness, contract types, the number of bids or quotations, contract provisions, and maintaining documentation to show the history of procurements.

Establish and implement adequate record-keeping procedures to comply with applicable procurement requirements, including a register of all contracts with key information and a checklist for each procurement action, to ensure that it completes required steps and receives all required documentation.

We audited the Long Branch Housing Authority based on the results of our previous audits of the Asbury Park and Red Bank Housing Authorities, which received management services and technical assistance from Long Branch for several years. The objective of the audit was to determine whether Long…

Audit #: 2022-NY-1003 Oversight Area: Rental Assistance Date Published: August 24, 2022

We recommend that the Director of HUD’s Newark Office of Public Housing make a determination regarding outstanding agreement income, including whether those unspent funds should be returned to the public housing agencies, thereby putting up to $697,912 to better use, including $478,165 related to Asbury Park and $219,747 related to Red Bank.

We recommend that the Director of HUD’s Newark Office of Public Housing provide technical assistance to Long Branch and require updates to its procedures to ensure that it properly classifies income received under any future agreements or activities.

We recommend that the Director of HUD’s Newark Office of Public Housing require Long Branch to prepare and provide support for a reasonable estimate of the amount of employee time used to perform services for Asbury Park and Red Bank and the amount of Long Branch program funds used to pay for that time. This estimate should include all employees known or believed to have provided services under the agreements based on language in the agreements, incentive payments, after-the-fact documentation provided, and any other applicable knowledge or documentation, which would show that the employees performed work under the agreements.

We recommend that the Director of HUD’s Newark Office of Public Housing require Long Branch to reimburse Long Branch’s program from non-Federal funds for any Long Branch program funds used for payroll expenses related to services provided to Asbury Park and Red Bank as established in recommendation 2A, estimated to be $1,014,660.

We recommend that the Director of HUD’s Newark Office of Public Housing require Long Branch to prepare and provide support to show the reasonableness and eligibility of the $1,583,652 in employee incentive payments related to services performed for Asbury Park and Red Bank, which was paid from agreement income, or reimburse its program from non-Federal funds for any amount it cannot support.

We recommend that the Director of HUD’s Newark Office of Public Housing require Long Branch to implement adequate controls to ensure compliance with applicable cost principle requirements for employees, including those covering compensation for personal services, such as wages, salaries, and incentive payments, at 2 CFR 200.430. Records should reasonably reflect the total activity for which Long Branch’s employees are compensated by the non-Federal entity and support the distribution of compensation among specific activities and cost objectives.

Open Recommendations by Oversight Area

Oversight Area

Topic

Status

Reports with Priority

The Housing Authority of the City of Long Beach, CA, Did Not Administer Its Housing Choice Voucher Program in Accordance With HUD Requirements

The Housing Authority of the City of Springfield, MA, Did Not Always Comply With Procurement and Contract Administration Requirements

The Philadelphia Housing Authority, Philadelphia, PA, Did Not Comply With Procurement and Conflict-of-Interest Requirements

Englewood Apartments Did Not Comply With Tenant Eligibility and Recertification Requirements

The Housing Authority of the City of Macon-Bibb County, GA, Improperly Executed the HAP Contract for Vineville Christian Towers’ RAD Conversion

HUD Could Improve Its Oversight of Portability in the Housing Choice Voucher Program

The Buffalo Municipal Housing Authority, Buffalo, NY, Needs To Improve Its Management of the Commodore Perry Homes Development To Address Longstanding Concerns

HUD Did Not Have Adequate Policies and Procedures for Ensuring That Public Housing Agencies Properly Processed Requests for Reasonable Accommodation

The Housing Authority of Plainfield, NJ, Did Not Always Comply With Requirements When Administering Its Public Housing Programs

Long Branch Housing Authority, Long Branch, NJ, Did Not Properly Handle Income and Expenses Related to Agreements With Other Housing Agencies

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