Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $588,694 in 12 administrative obligations marked for deobligation as of September 30, 2018.

Review the three identified retained inactive obligations with remaining balances totaling $78,069 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

Ensure that $1,385,791 ($1,229,684 in housing assistance payments and $156,107 in associated administrative fees) used by the Lexington-Fayette Urban County Housing Authority is supported through a valid and retroactive exemption from HUD’s third-party requirements. If a retroactive exemption cannot be issued, HUD should follow recovery procedures prescribed in HUD Handbook 2000.06, REV-4.

Revise the standard MTW agreement for all existing 39 MTW housing agencies to clearly and specifically support which provision(s) waive the third-party inspection requirements.

Issue clarifying guidance to all existing 39 MTW housing agencies advising that HUD intended to waive the third-party inspection requirements via attachment C to the standard agreement.

Ensure that reviews of MTW annual plans are thorough by verifying that the MTW plan accurately identifies the appropriate exemptions as authorized in the MTW agreements.

Verify that the Office of Public Housing Investments’ approvals of all MTW public housing agencies’ MTW plans’ exemptions from HUD’s third-party requirements were valid and appropriate.

Require the Authority to reimburse its Public Housing Capital Fund program $38,411 from nonproject funds for the inappropriate use of funds for the Section 8 Project-Based Voucher Program units.

Ensure that the Louisville, KY, PIH field office sends to the Office of Recapitalization any requests it receives for approving capital funds expenditures after the RAD conversion is complete.

Require the Authority to ensure that capital funds are used in accordance with the program requirements for any future RAD conversions.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to certify, along with the owners of the 25 units cited in the finding, that the applicable housing quality standards violations have been corrected.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to reimburse its program $111,651 from non-Federal funds ($110,943 for housing assistance payments and $708 in associated inspection service fees) for the 23 units that materially failed to meet HUD’s housing quality standards.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to improve controls over its inspection program to ensure compliance with HUD guidelines and that the results of those inspections are used to enhance the effectiveness of its housing quality standards inspections.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to reimburse its program $4,459 from non-Federal funds for housing assistance payments that should have been abated for units that did not meet housing quality standards.

We recommend that the Director of HUD’s Newark Office of Public and Indian Housing require the Authority to improve controls to ensure that its staff accurately calculates housing assistance payment abatements.

Provide adequate documentation to support that the $71,034 spent for improperly procured goods and services was spent at the most competitive prices. For any amounts not supported, it should reimburse its program from non-Federal funds.

Provide adequate documentation to support $15,280 spent for maintenance activities. For any amounts not supported, it should reimburse its program from non-Federal funds.

Develop and implement detailed operating procedures, including checklists, which fully implement its procurement policy and HUD requirements.

Ensure that its executive director obtains appropriate procurement training.

Work with the Authority to develop a formalized process, such as a checklist, to use when conducting initial certifications and annual recertifications, which would help to ensure that it follows HUD requirements for its public housing program.