The Boston Housing Authority Did Not Always Comply With HUD’s Requirements for Its Housing Choice Voucher Program Units

We audited the Boston Housing Authority’s Housing Choice Voucher (HCV) Program. We initiated this audit based upon our assessment of risks associated with public housing agencies' HCV Program units, as well as recent media attention and public concern about the conditions of subsidized housing properties. Our objective was to determine whether the physical conditions of the Authority’s HCV units complied with both the U.S. Department of Housing and Urban Development’s (HUD) and the Authority’s requirements. The Authority did not always ensure that its HCV Program units met HUD’s housing quality standards (HQS). Specifically, we reviewed a sample of 87 units that had passed a recent HQS inspection and determined that 50 units had 193 deficiencies. Of the 50 units, 15 units had 53 deficiencies that existed at the time of the Authority’s last inspection. In addition, the Authority did not (1) consistently stop housing assistance payments (HAP) to owners for uncorrected unit deficiencies and (2) comply with HUD’s monitoring and data collection requirements of the Lead Safe Housing Rule (LSHR) for cases of children with elevated blood lead levels (EBLL). These conditions occurred because the Authority's inspectors did not thoroughly inspect housing units in a consistent manner and the Authority’s quality control process for HQS inspections had weaknesses. Further, (1) the Authority’s information system did not have controls in place to stop payments properly and (2) the Authority did not consistently follow its own established procedures to take appropriate actions to address unit deficiencies. Additionally, although the Authority was aware of HUD’s EBLL requirements, it (1) was uncertain about its authority to require owners to comply with those requirements and (2) believed that coordinating with the vast number of local health departments would have been challenging. As a result, families participating in the Authority’s HCV Program resided in housing units that were not always decent, safe, and sanitary. Based on our statistical sample, we estimate that over the next year, the Authority will pay owners more than $34 million in housing assistance for units that do not meet HQS. Further, (1) the Authority paid $180,309 in housing assistance to owners for units with uncorrected deficiencies and (2) HUD lacked assurance that the Authority and owners appropriately addressed their responsibilities under the LSHR for cases of children with EBLLs in a timely manner. We recommend that the Director of HUD’s Boston Office of Public Housing require the Authority to (1) ensure that the owners correct the outstanding unit deficiencies; (2) recover or repay from non-Federal funds $106,477 for HAP that were not properly stopped; (3) review its records to confirm whether it had cases of children with EBLLs during our audit period and work with the owner(s) of the HCV Program units to provide required documentation to HUD; (4) update publications and educational materials to owners to ensure that they understand their reporting responsibilities to HUD regarding confirmed cases of children with EBLLs; (5) develop and implement procedures and controls for coordinating with public health departments and monitoring owners for compliance with the requirements of the LSHR; and (6) improve controls over its inspections, stop payments for uncorrected deficiencies, and monitor owners for compliance with the requirements of the LSHR. Additionally, we recommend that the Director of HUD’s Boston Office of Public Housing work with the 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.