For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to support the reasonableness of $57,902 paid to three vendors for pest control services without a valid contract or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable.

For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to support the reasonableness of the change orders that increased the price of the contract (0216) by more than $1.1 million or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable.

For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to support the contract modifications and the reasonableness of the increased costs for four contracts (0824, 0505, 1023 and 0731) or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable.

For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to ensure that its staff is appropriately trained and familiar with Federal procurement requirements regarding cost estimates and cost analyses.

For the contract activities during the period of January 1, 2020, through April 2022, the Director should require the Authority to implement adequate procedures and controls, including but not limited to ensuring that (1) proper documentation is maintained, (2) contracts are procured in accordance with Federal and the Authority’s procurement requirements, (3) procurement staff complies with Federal procurement requirements, and (4) payments are appropriately reconciled.

We also recommend that the Director of HUD’s Cleveland Office of Public Housing determine whether the Authority qualifies for an exemption from preaward review.

Prioritize the inspection of public housing properties that were (1) not included in the NSPIRE demonstration but were identified as high priority under the Center’s Big Inspection Plan and (2) approved to participate under the NSPIRE demonstration that the Center was unable to inspect by March 31, 2023.

Implement adequate policies, procedures, and controls to ensure that public housing properties will be inspected within required timeframes.

Status

NSPIRE regulations clarified and modified the timing for which inspections should occur. The date for inspection of each public housing property must then be programmed into HUD's system to ensure that inspections occur within the required timeframes. The Real Estate Assessment Center (REAC) continues to work with its management and system support contractors on the list of public housing properties to inspect and the date the inspections should be completed under the new NSPIRE regulations. REAC is in the process of adjusting the list based on information relating to small, rural public housing. As of November 2024, the NSPIRE regulations on inspection timing are completed. However, REAC is not able to make the required modifications in the NSPIRE system to enforce the regulatory guidelines. REAC previously indicated that new IT funding is needed to make the system modifications but had not provided information about whether additional funding has been allocated. The final action target date was revised from May 31, 2024, to September 30, 2025.

Analysis

To fully address this recommendation, HUD must provide evidence demonstrating that it has implemented control activities that ensure public housing properties are inspected within the required timeframes.

Implementation of this recommendation will result in HUD accurately tracking the dates on which public housing properties should be inspected and that they are timely completed. Due to the uncertainty of when software changes to NSPIRE can take place to enforce the timing of inspections, REAC cannot enforce the requirements of inspection timing.

Develop and implement a plan to assist PHAs in improving voucher utilization, including providing additional guidance to PHAs to improve coordination between PHAs and PCWAs to improve voucher utilization and limit barriers to leasing.

Require PHAs to document that they informed FYI participants at program entry of their eligibility for supportive services and the availability of those services for the duration of the program.

For each youth referred, require PHAs to obtain PCWA certification that the PCWA will provide or secure access to supportive services.

Include FYI in its voucher risk assessment and develop and implement monitoring policies, procedures, and controls.

Establish and implement methods to regularly assess the effectiveness of the program in preventing and ending youth homelessness and improving participants’ self-sufficiency, which could include performance metrics and periodic studies performed by the Office of Policy Development and Research (PD&R).

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to establish and implement procedures and controls to ensure that lead-based paint visual assessments are performed within the required timeframe.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to implement adequate procedures and controls to ensure that lead-based paint hazard reduction work is performed within the required timeframe and that all identified hazards are abated or treated with interim controls.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to maintain lead-based paint documentation for its properties in a manner that it is readily available for review by HUD and the Authority’s tenants if requested.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to perform a search for historical lead based paint documentation and if any documents are found, compare the results from the historical documents with the results of the recent testing to identify any potential issues or inconsistencies and maintain all lead-based paint documentation related to the Authority’s properties according to HUD’s requirements.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to Implement adequate procedures and controls to ensure that accurate lead disclosures are provided to current and prospective tenants.

We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to implement adequate controls to ensure that contracted inspectors’ deliverables comply with HUD’s and EPA’s requirements.

We also recommend that the Director of the Philadelphia Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training to the Authority’s staff involved with managing lead-based paint and technical assistance in developing and implementing new procedures and controls.