HUD Can Improve Its Oversight of the Physical Condition of Public Housing Developments

We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of the physical condition of public housing developments. Our audit objective was to assess HUD’s oversight of the physical condition of public housing developments; specifically, whether HUD had adequate oversight of public housing agencies’ (PHA) (1) corrective actions in response to periodic Real Estate Assessment Center (REAC) inspections and (2) annual self-inspections to ensure that units were maintained in decent, safe, and sanitary condition. Properties receiving assistance through HUD’s public housing program are periodically inspected by a HUD contractor using standards established by REAC. These “REAC inspections” evaluate five areas of a public housing development: site, building exterior, building systems, common areas, and dwelling units. If deficiencies in these areas are identified, the inspector records their severity within one of the following four categories: (1) no health and safety hazards, (2) non-life-threatening health and safety, (3) life-threatening exigent health and safety, or (4) fire safety. HUD requires public housing agencies (PHA) to address life-threatening exigent health and safety and fire safety smoke detector deficiencies identified during REAC inspections within 24-hours. HUD monitors PHAs’ corrections of life-threatening deficiencies. We found that HUD field offices were inconsistent in overseeing whether PHAs corrected life-threatening deficiencies identified during REAC inspections. In addition, HUD does not track PHAs’ corrections of non-life-threatening health and safety deficiencies identified during REAC inspections. These conditions occurred because HUD did not have a standardized policy or a nationwide protocol to guide its field offices’ oversight of PHAs to ensure that all health and safety deficiencies were corrected after a REAC inspection. Instead, HUD relied on its field offices to maintain their own policies and procedures for monitoring PHAs’ unit conditions. However, the field offices generally did not maintain their own written policies and procedures, resulting in inconsistencies regarding what should be done. As a result, HUD lacked assurance that PHAs corrected identified life-threatening and non-life-threatening deficiencies. If HUD implements a nationwide protocol for monitoring and tracking PHAs’ efforts to address inspection results, it could have greater assurance that tenants residing in public housing are living in units that are decent, safe, and sanitary. In addition to the REAC inspection, HUD requires PHAs to perform routine self-inspections of public housing properties. These self-inspections include an annual visual assessment of the property to look for all deficiencies, and to determine the maintenance and modernization needs of the properties. We found that HUD staff had varying interpretations of its requirements regarding the number of public housing units PHAs should self-inspect annually. Further, HUD’s field office staff generally did not monitor PHAs for compliance with HUD’s requirements for self-inspections. These conditions occurred because HUD’s guidance was not clear regarding (1) the number of units PHAs should inspect annually and (2) how its field office staff should monitor PHAs to ensure that self-inspections of public housing units were conducted. Without clear guidance regarding its requirements for self-inspections, HUD lacked assurance that PHAs properly performed self-inspections of public housing units to determine maintenance and modernization needs. HUD could also miss opportunities to provide technical assistance to PHAs through early intervention when self-inspections identify systemic deficiencies. Further, because REAC’s inspection sampling methodology to select between 1 and 27 public housing units is based on the expectation that PHAs are completing self-inspections of 100 percent of their public housing units, REACs’ sampling methodology may no longer be appropriate. We recommend that HUD develop and implement a nationwide inspection review protocol and associated training for its field office staff; determine whether PHAs are required to perform inspections on 100 percent of their public housing units annually; and if so, develop clear, specific guidance on the number and frequency of the self-inspections. If 100 percent annual self-inspections are not required, we recommend that HUD determine whether the rationale for REAC to inspect a sample of public housing units, rather than 100 percent, remains appropriate.