Issue Date
November 17, 2008
Audit Report Number
2009-LA-1002
TO: K. J. Brockington, Director, Los Angeles Office of Public Housing, 9DPH
FROM: Joan S. Hobbs, Regional Inspector General for Audit, Region IX, 9DGA
SUBJECT: The Housing Authority of the City of Los Angeles, Los Angeles, California, Did
Not Adequately Conduct Housing Quality Standards Inspections
HIGHLIGHTS
What We Audited and Why
We reviewed the Housing Authority of the City of Los Angeles’ (Authority) housing
quality standards policies and procedures for its Section 8 Housing Choice Voucher
program based on the Authority’s prior notification to the U.S. Department of Housing
and Urban Development’s (HUD) Office of Inspector General (OIG) for Audit of
problems with some of its inspectors. Furthermore, the Authority’s having received poor
scores on two of five housing quality standards indicators for 2006 under HUD’s Section
Eight Management Assessment Program further warranted review.
The objective of the audit was to determine whether the Authority adequately enforced
HUD’s housing quality standards.
What We Found
The Authority did not adequately enforce HUD’s housing quality standards. Of 68
program units statistically selected for inspection, 43 did not meet minimum housing
quality standards, of which 19 were in material noncompliance with housing quality
standards. Based on our statistical sample, we estimate that over the next year, HUD will
pay more than $65.6 million in housing assistance on units with material housing quality
standards deficiencies.
What We Recommend
We recommend that the Director of HUD’s Los Angeles Office of Public Housing (1)
require the Authority to implement adequate procedures and controls regarding its
inspection process to ensure that all units meet HUD’s housing quality standards to
prevent $65.6 million in program funds from being spent on units that are in material
noncompliance with the standards and (2) verify and certify that the applicable owners
have taken appropriate corrective action regarding the housing quality standards
deficiencies identified during our inspections or take enforcement action.
For each recommendation without a management decision, please respond and provide
status reports in accordance with HUD Handbook 2000.06, REV-3. Please furnish us
copies of any correspondence or directives issued because of the audit.
Auditee’s Response
We provided the Authority the draft report on October 9, 2008, and held an exit
conference with the Authority on October 22, 2008. The Authority generally disagreed
with our report.
We received the Authority’s response on November 7, 2008. The complete text of the
auditee’s response, along with our evaluation of that response, can be found in appendix
B of this report.
2
TABLE OF CONTENTS
Background and Objectives 4
Results of Audit 5
Finding: The Authority’s Section 8 Units Did Not Meet Housing Quality
Standards
Scope and Methodology 12
Internal Controls 14
Appendixes
A. Schedule of Funds to Be Put to Better Use 16
B. Auditee Comments and OIG’s Evaluation 17
C. Schedule of Units in Noncompliance with Housing Quality Standards 25
D. Criteria 27
3
BACKGROUND AND OBJECTIVES
The Housing Authority of the City of Los Angeles (Authority) was organized as a public housing
authority in 1938 to provide low-cost housing to individuals meeting established criteria. The
Authority is a state-chartered public agency that provides the largest stock of affordable housing
in the Los Angeles area. The Authority gets the majority of its funding from the U.S.
Department of Housing and Urban Development (HUD). Additionally, it has built a number of
key partnerships with city and state agencies, nonprofit foundations, and community-based
organizations, as well as private developers.
In 1975, the Authority implemented the Section 8 program to provide rent subsidies in the form
of housing assistance payments to private landlords on behalf of eligible families. The Section 8
program, funded by HUD, provides housing assistance to extremely low- and very low-income
families, senior citizens, and disabled or handicapped persons. Its objective is to provide
affordable, decent, and safe housing for eligible families, while increasing a family’s residential
mobility and choice. The Authority administers the second largest Section 8 program in the
country.
The Authority has two different types of rental subsidies—tenant-based and project-based
programs. Both programs have similar income-based admission requirements set by HUD.
Households with a tenant-based subsidy have a voucher that allows them to move from one place
to another. Those in the project-based programs live in a building in which the units are
subsidized. Households in the Housing Choice Voucher tenant-based program (program) come
from the Housing Authority’s waiting list of applicants.
HUD’s approved budget authority for the Authority’s program for fiscal years 2005, 2006, and
2007 was $364.7 million, $383.9 million, and $368.6 million, respectively.
The Los Angeles HUD OIG for Audit initiated an audit of the Authority’s program based on the
Authority’s prior notification to the OIG Office of Audit of problems with some of its inspectors.
In addition, the Authority had received a zero for Section Eight Management Assessment
Program indicators #11 – precontract housing quality standards inspections and #12 – annual
housing quality standards inspections for 2006, which indicate prior problems with the
Authority’s meeting HUD’s housing quality standards requirements.
The objective of the audit was to determine whether the Authority adequately enforced HUD’s
housing quality standards.
4
RESULTS OF AUDIT
Finding: The Authority’s Section 8 Units Did Not Meet Housing
Quality Standards
The Authority did not adequately enforce HUD’s housing quality standards. Of 68 program
units statistically selected for inspection, 43 units did not meet minimum housing quality
standards, and inspectors did not identify 130 deficiencies during the Authority’s latest
inspection. The Authority inspectors did not identify these deficiencies because it did not
implement adequate controls to ensure that all housing quality standards deficiencies were
detected during its inspections. As a result, it did not properly use its program funds, and
program tenants lived in units that were not decent, safe, and sanitary. Based on our statistical
sample, we estimate that over the next year, HUD will pay more than $65.6 million in housing
assistance on units with material housing quality standards deficiencies if inspection procedures
do not improve.
HUD’s Housing Quality
Standards Not Met
From the 36,626 active program units in the Authority’s housing inventory as of January 1,
2008, we statistically selected 68 units for inspection. The 68 program units were inspected
to determine whether the Authority ensured that its program units met HUD’s housing
quality standards. The inspections took place between March 17 and March 28, 2008.
Of the 68 units inspected, 43 (63 percent) had 318 housing quality standards deficiencies,
including one unit with 39 deficiencies. Of the 318 deficiencies, 134 deficiencies (42
percent) in 33 units predated the Authority’s latest inspection, but only four (3 percent) of
those 134 deficiencies were included in the Authority’s latest inspection report. This means
that inspectors did not identify 130 deficiencies during the Authority’s latest inspection.
The following table categorizes the 318 housing quality standards deficiencies in the 43
units.
5
Categories of deficiencies Number of deficiencies Number of units affected
Security 43 20
Window 42 20
Tub or shower in unit 41 22
Electrical 26 15
Wall 24 13
Sink 18 13
Fire exits 15 11
Ceiling 13 10
Floor 13 9
Range/refrigerator 13 11
Ventilation/plumbing 11 7
Garbage and debris 9 5
Smoke detectors 9 6
Chimney/heating equipment 8 5
Water heater 8 5
Space for preparation, storage, 6 6
and serving of food
Crawl vents 4 4
Other interior hazards 4 4
Roof/gutters 4 4
Flush toilet in enclosed space 3 3
Stairs, rails, and porches 2 2
Exterior surface 1 1
Foundation 1 1
Total number of deficiencies 318
In addition, we considered 19 (28 percent) of the 68 units to be in material noncompliance
with HUD requirements.1 The materially deficient units had multiple deficiencies per unit
that predated the Authority’s last inspection (i.e., had existed for an extended period) or
contained any deficiency noted in a prior inspection that was not corrected, creating unsafe
living conditions. Overall, we identified 115 deficiencies that predated the Authority’s last
inspection2 among all 19 units that we deemed materially deficient, including corrosion,
wood rot, advanced mildew, fixed break away bars on windows, badly worn carpet, and
peeling paint. By contrast, those units that were not considered to be materially deficient
had deficiencies such as missing screens on vents, doors off hinges, or missing outlet covers.
In addition, 2 of the 19 materially deficient units had four deficiencies between them that
were noted in a prior Authority inspection report but had not been corrected, despite having
been cited as ―passed‖ on the followup inspections that the Authority conducted four and
seven months before our OIG inspection.
1
Our use of the term, ―material noncompliance,‖ primarily refers to deficiencies in the Authority’s prior inspections
and/or inspection process leading to the unit’s unacceptable condition at the time of our inspection.
2
When the Authority’s inspections were overdue at the time of our inspection, we included deficiencies that the
Authority should have identified before our inspection. This was the case in 2 of the 19 materially deficient units.
6
We provided our inspection results to the Authority’s Section 8 inspections manager.
Appendix C details the deficiencies found in each of the 43 failed units, with an asterisk
denoting which of the units were determined to be materially deficient.
Types of Violations
Our inspector identified 41 tub/shower deficiencies in 22 of the program units inspected.
The following items are examples of tub/shower deficiencies listed in the table:
advanced mildew around tub/shower, water controls separated from wall by one-fourth to
one-half inch, glass enclosure off track, missing hot/cold water controls, and missing
tiles. The following picture is an example of the tub/shower deficiencies identified in the
program units inspected.
Tubs were missing the water control knobs and overflow drain covers, and the water
spouts were separated from the wall.
In addition, our inspector identified 43 security deficiencies in 20 of the program units
inspected. The security deficiencies identified included missing strikers, defective or
missing locks/latches/dead bolts, split doors, door dragging, cracked door glass,
unauthorized dead bolts, air infiltration, unfit closure, defective door handle, and wood
rot. The following picture is an example of the security deficiencies identified in the
program units inspected.
7
Doors were split, allowed air infiltration, and had unfit closures; and door strikers did not
work properly.
Further, our inspector identified 42 window deficiencies in 20 of the program units
inspected. The window deficiencies identified included missing or inoperative
latch/locks, window sill damage, water wood rot, air and/or water infiltration, and
cracked and/or broken glass panes. The following pictures are examples of the window
deficiencies identified in the program units inspected.
Windows were loose/missing, had cracked glass, and allowed air infiltration.
Our inspector identified other deficiencies, including electrical deficiencies such as
exposed electrical wiring, insecure wiring, inoperative sockets, inoperative ground fault
interrupters, main service panel missing safety shields, and missing faceplates; wall
deficiencies such as holes, cracks, exposed framing, peeling paint, water stains, and
defective repairs; inoperable smoke detectors; garbage and debris in and around program
units; loose handrails on stairways; missing screens on outside vents; loose toilet base;
and inoperative ventilation systems both in the kitchen and bathroom. The following
pictures are examples of other deficiencies identified in the program units inspected.
8
Main service panels were missing the interior safety panels, exposing electrical wiring.
Units had evidence of roach infestations.
9
Garbage, debris, and safety hazards were in and around program units.
Inadequate Controls
The Authority inspectors did not identify the deficiencies noted above because it did not
implement adequate controls to ensure that its program units met HUD’s housing quality
standards. Although the Authority’s written procedures and controls required it to ensure
that its program units met housing quality standards, it failed to fully implement those
procedures. The Authority’s Section 8 administrative plan states that the Authority uses
HUD standards described in the Code of Federal Regulations, HUD inspection manuals,
and HUD handbooks during its inspections. In addition, the Authority publishes housing
quality standards training bulletins as needed to establish and clarify policy and
procedure regarding inspection standards. Our review of the Authority’s training
bulletins determined that they were sufficient to comply with HUD rules and regulations
regarding housing quality standards; however, inspectors did not identify a number of
deficiencies of housing quality standards because they did not follow the Authority’s
(and, therefore, HUD’s) guidance.
We noted the Authority is conducting more quality control inspections than HUD
requires, and its quality control inspector has identified additional deficiencies during his
quality control review that the inspectors missed during their inspection. However, we
noted instances where the inspection supervisors who are also responsible for conducting
quality control reviews may not be adequately noting inspector oversights during their
quality control reviews. Although there is no indication this is an intentional disregard of
deficiencies, this may undermine the Authority’s quality control efforts.
10
Conclusion
The Authority’s tenants were subjected to health- and safety-related deficiencies, and the
Authority did not properly use its program funds when it failed to ensure that units
complied with HUD’s housing quality standards. If the Authority implements adequate
procedures and controls regarding its unit inspections to ensure compliance with HUD’s
housing quality standards, we estimate that more than $65.6 million in future housing
assistance payments will be spent on units that are decent, safe, and sanitary. The
complete explanation of our calculations can be found in the scope and methodology
section of this report.
Recommendations
We recommend that the Director of HUD’s Los Angeles Office of Public Housing require
the Authority to
1A. Implement adequate procedures and controls to ensure that all units meet HUD’s
housing quality standards to prevent $65.6 million in program funds from being
spent on units that are in material noncompliance with HUD’s standards.
1B. Verify and certify that the owners have taken appropriate corrective actions for all
applicable housing quality standards deficiencies identified during our
inspections. If appropriate actions have not been taken, the Authority should
abate the rents or terminate the housing assistance payments contracts.
11
SCOPE AND METHODOLOGY
We performed our on-site audit work from February through August 2008 at the Authority’s
office in Los Angeles, California. The audit generally covered the period February 1, 2007,
through January 31, 2008. We expanded our audit period as needed to accomplish our
objectives. We reviewed guidance applicable to Section 8 housing quality standards, performed
on-site inspections with a qualified HUD OIG inspector, and interviewed applicable Authority
supervisors and staff.
To accomplish our audit objectives, we
Reviewed applicable HUD regulations, including 24 CFR Part 982 and Housing Choice
Voucher Guidebook 7420.10G.
Reviewed the Authority’s administrative plan for 2007, financial independent public
audit reports for 2006, quality control procedures and sampling methods, and staff
listing and organizational chart.
Interviewed personnel from the HUD Office of Public Housing, Los Angeles field
office, to obtain background information on the Authority’s housing quality standards
performance.
Interviewed Authority supervisors and staff to determine their job responsibilities and
their understanding of housing quality standards.
Reviewed Authority data from HUD’s Public Housing Information Center system.
Analyzed databases provided by the Authority to obtain a random sample of units.
Conducted inspections of 68 randomly selected units with a qualified HUD OIG
inspector and recorded and summarized the inspection results provided.
We statistically selected a sample of 68 of the program units to determine whether the Authority
ensured that its units met housing quality standards. The sample was based on the Authority’s
housing assistance payment register for one month as of January 2008. The universe contained
36,626 units that received regular housing assistance payments from the Authority as of January
2008. We obtained the sample based on a confidence level of 90 percent, a precision level of 10
percent, and an assumed error rate of 50 percent. Fifty-seven additional sample units were
selected to be used as replacements if necessary.
We initially surveyed 13 of the 68 units in our statistical sample in order to determine if the
Authority was completing timely inspections, and we determined the Authority did complete
annual inspections in a timely manner for the most part. We noted two instances of late annual
inspections for the 13 units we reviewed for timeliness for fiscal years 2006 and 2007, although
none of the 13 units were overdue at the time of our review. We determined this was not a
material issue to proceed with and eliminated that objective from our audit.
12
We reviewed the sample of 68 units and determined that 19 of 43 failed units were materially
deficient and in noncompliance with housing quality standards. We determined that the 19 units
were in material noncompliance because they had 115 deficiencies that predated the Authority’s
latest inspection and created unsafe living conditions. Two of the units had deficiencies that
were noted in a prior Authority inspection report but had not been corrected.
Projecting the results of the 19 units that were in material noncompliance with housing quality
standards to the population of 36,626 Section 8 voucher program units indicates that 10,234 or
27.94 percent of these units contain deficiencies that predated the Authority’s latest inspection
and created unsafe living conditions. The sampling error is plus or minus 8.92 percent. In other
words, we are 90 percent confident that the number of units in unacceptable condition lies
between 19.03 and 36.86 percent of the population. This equates to an occurrence of between
6,968 and 13,499 units of the 36,626 units of the population.
The lower limit is 19.03 percent x 36,626 units = 6,968 units in noncompliance with
minimum housing quality standards.
The point estimate is 27.94 percent x 36,626 units = 10,234 units in noncompliance with
minimum housing quality standards.
The upper limit is 36.86 percent x 36,626 units = 13,499 units in noncompliance with
minimum housing quality standards.
Using the lower limit and the average annual housing assistance payments for the population
based on the Authority’s housing assistance payment register, dated February 1, 2007, through
January 31, 2008, we estimate that the Authority will spend at least $65,565,605 (6,968 units x
$9,409 average annual housing assistance payment) for units that are in material noncompliance
with housing quality standards. This estimate is presented solely to demonstrate the annual
amount of Section 8 program funds that could be put to better use on decent, safe, and sanitary
housing if the Authority implements our recommendations.
We performed our review in accordance with generally accepted government auditing standards.
13
INTERNAL CONTROLS
Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following objectives are being achieved:
Effectiveness and efficiency of operations,
Reliability of financial reporting, and
Compliance with applicable laws and regulations.
Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. Internal controls include the processes and procedures for
planning, organizing, directing, and controlling program operations. They include the systems
for measuring, reporting, and monitoring program performance.
Relevant Internal Controls
We determined the following internal controls were relevant to our audit objectives:
Program operations - Policies and procedures that management has
implemented to reasonably ensure that a program meets its objectives.
Validity and reliability of data - Policies and procedures that management has
implemented to reasonably ensure that valid and reliable data are obtained,
maintained, and fairly disclosed in reports.
Compliance with laws and regulations - Policies and procedures that
management has implemented to reasonably ensure that resource use is
consistent with laws and regulations.
Safeguarding resources - Policies and procedures that management has
implemented to reasonably ensure that resources are safeguarded against
waste, loss, and misuse.
We assessed the relevant controls identified above.
A significant weakness exists if internal controls do not provide reasonable assurance that
the process for planning, organizing, directing, and controlling program operations will meet
the organization’s objectives.
14
Significant Weaknesses
Based on our review, we believe the following item is a significant weakness:
The Authority did not fully implement adequate controls to ensure that
inspections of Section 8 units detected all deficiencies of housing quality
standards.
15
APPENDIXES
Appendix A
SCHEDULE OF FUNDS
TO BE PUT TO BETTER USE
Recommendation Funds to be put
number to better use 1/
1A $65,565,605
1/ Recommendations that funds be put to better use are estimates of amounts that could be
used more efficiently if an Office of Inspector General (OIG) recommendation is
implemented. These amounts include reductions in outlays, deobligation of funds,
withdrawal of interest subsidy costs not incurred by implementing recommended
improvements, avoidance of unnecessary expenditures noted in preaward reviews, and
any other savings that are specifically identified. In this instance, if the Authority
implements our recommendations, it will cease to incur program costs for units that are
not decent, safe, and sanitary. Instead, it will expend those funds for units that meet
HUD’s standards. Once the Authority successfully improves its controls, this will be a
recurring benefit. To be conservative, our estimate reflects only the initial year of this
benefit.
16
Appendix B
AUDITEE COMMENTS AND OIG’S EVALUATION
Ref to OIG Evaluation Auditee Comments
Comment 1
17
18
19
Comment 2
Comment 3
20
Comment 4
21
22
OIG Evaluation of Auditee Comments
Comment 1 Since 2005, OIG has issued 5 independent audit reports for the Authority.
Following each report, the Authority has worked with HUD to implement our
recommendations and gain compliance with HUD rules and regulations.
Comment 2 We acknowledge that housing quality standards violations can occur after the last
annual inspection conducted by the Authority. However, federal regulations
require that all program housing must meet housing quality standards
performance requirements at commencement of assisted occupancy and
throughout the assisted tenancy. Therefore, we reported all violations identified
at the time of our inspection so that HUD and the Authority could ensure they
were corrected.
We did not hold the Authority to ―an impossible standard‖, as we did not identify
all 43 failed units as material, and we did not project funds to be put to better use
using all 43 failed units. In order to avoid calling into question routine
maintenance issues, our report determined the number of units that were in
material noncompliance with housing quality standards. We cited units that had
failing deficiencies that were present at the time of the previous inspection, and
were therefore missed by the Authority’s inspectors and remained uncorrected.
Thus, we were very conservative when determining a unit as materially deficient,
so as not to hold the Authority to an unrealistic expectation.
Comment 3 The Authority’s objections to our audit methodology, process, and protocol are
without merit as we performed the audit in accordance with generally accepted
government auditing standards. We agree the Section 8 Management Assessment
Program requires the Authority’s sample to be no older than three months.
However, our audit was designed to determine whether HUD requirements have
been followed with respect to housing quality standards as stated at 24 CFR 982
and was not intended to follow the Section 8 Management Assessment Program
self-assessment process.
In conjunction with our inspections, we performed tenant interviews, consulted
with our certified inspector/appraiser, and reviewed the Authority’s latest
inspection reports to help us to determine whether a housing quality standards
violation existed prior to the last inspection conducted by the Authority or had
been identified by the Authority but not adequately corrected. Deficiencies were
determined to have existed at the time of the Authority’s last inspection as they
could not have reasonably deteriorated to such an extent within the time period
between the Authority’s last inspection and our HUD OIG inspection. In the
event we could not reasonably make that determination, we did not include the
violation in our assessment of funds to be put to better use, and as such, we were
very conservative in our determination of pre-existing conditions.
23
Furthermore, while we understand the City of Los Angeles has ―aging housing
stock‖ with ―maintenance issues‖, Public Housing Authorities are held to the
same housing quality standards nationwide, and the tenants living in the
jurisdiction of the Housing Authority of the City of Los Angeles, deserve and are
entitled to housing that meets the same housing quality standards as anywhere
else in the nation.
Comment 4 We performed our inspections accurately and appropriately applied HUD’s
housing quality standards in the same manner as we have done in audits
throughout the country. In no instance did we apply a higher standard than is
required by HUD’s housing quality standards. The form we used to perform our
inspections accurately and appropriately applied HUD’s housing quality
standards, and our inspector has years of experience conducting numerous
housing quality standards inspections across the country. Among our inspector’s
many inspection and appraisal certifications, there is one that shows that he is a
certified Section 8 Housing Choice Voucher Housing Quality Standards
specialist. Additionally, audit staff accompanied our inspector on each
inspection, along with a housing authority inspection supervisor; and we
evaluated the inspection results and compared the deficiencies to HUD’s housing
quality standards.
With respect to the Authority’s statement that ―HUD OIG has conceded that
several deficiencies initially identified by the auditor were erroneous and the audit
results reflect this adjustment‖, while we did agree to remove several deficiencies
we initially identified, we did so in order to give the Authority the benefit of the
doubt in cases where we could not be as certain as to the length of time a
condition existed or the severity of the deficiency based on the photographic
evidence and inspection notes – not because we deemed the deficiencies as
―erroneous‖ or in error. We scrutinized and reviewed conditions at the units
where the Authority questioned our interpretation of housing quality standards in
an effort to be as fair and conservative as possible in our estimates, and we
eliminated some deficiencies from the audit report if we determined a more
lenient interpretation of the housing quality standards could be reasonably
accepted. We agree HQS inspections involve ―individual judgment on the part of
inspectors‖, and the Housing Choice Voucher guidebook states as much,
contributing to our decision to remove some violations. However, we could not
reasonably remove several violations questioned by the Authority considering the
photographic evidence, HQS requirements, and less than convincing arguments
from the Authority’s staff. As a result, we are confident that this final audit report
accurately and fairly depicts the conditions we found in the Authority’s units
when we conducted our inspections.
24
Appendix C
SCHEDULE OF UNITS IN NONCOMPLIANCE
WITH HOUSING QUALITY STANDARDS
Item Number of deficiencies per lettered category
Totals
number A B C D E F G H I J K L M N O P Q R S T U V W
1 2 2
2 * 2 1 2 1 2 1 9
3 1 1
4 * 2 1 1 1 1 1 7
5 * 4 2 1 2 3 1 1 1 15
6 * 9 1 5 3 2 2 1 4 1 2 1 1 1 1 1 1 36
7 1 1 2
8 * 2 1 3
9 1 1
10 1 1 2
11 * 1 5 2 2 1 1 1 2 3 4 1 23
12 * 1 1 1 1 2 6
13 1 1
14 2 1 3
15 3 1 1 5
16 * 1 3 1 1 1 7
17 2 2 1 1 1 7
18 2 1 3
19 1 1 1 1 1 5
20 * 3 1 1 2 1 8
Category of deficiencies legend
A – Security M – Smoke detectors
B – Window N – Chimney/heating equipment
C – Tub or shower in unit O – Water heater
D – Electrical P – Space for preparation, storage, and serving of food
E – Wall Q – Crawl vents
F – Sink R – Other interior hazards
G – Fire exits S – Roof/gutters
H – Ceiling T – Flush toilet in enclosed space
I – Floor U – Stairs, rails, and porches
J – Range/refrigerator V – Exterior surface
K – Ventilation/plumbing W – Foundation
L – Garbage and debris * – Denotes unit determined to be materially deficient
25
Item Number of deficiencies per lettered category
Totals
number A B C D E F G H I J K L M N O P Q R S T U V W
21 1 1 1 1 1 1 1 1 1 9
22 * 2 2 3 1 8
23 1 1 2
24 * 7 9 3 8 3 1 2 3 1 1 1 39
25 1 1 2
26 * 1 2 2 1 6
27 * 1 3 1 1 1 7
28 2 2 1 1 1 1 1 9
29 1 1
30 * 4 1 3 1 1 1 1 1 1 14
31 1 1 2
32 2 1 1 4
33 * 1 2 2 3 1 9
34 1 1
35 * 4 1 5
36 1 1 2 1 1 6
37 1 1 1 1 2 6
38 * 1 1 1 1 4
39 1 1 2
40 * 2 5 2 1 2 1 1 2 1 2 1 1 21
41 * 1 1 1 1 2 1 2 1 10
42 1 1 2
43 1 1 1 3
Totals 43 42 41 26 24 18 15 13 13 13 11 9 9 8 8 6 4 4 4 3 2 1 1 318
Category of deficiencies legend
A – Security M – Smoke detectors
B – Window N – Chimney/heating equipment
C – Tub or shower in unit O – Water heater
D – Electrical P – Space for preparation, storage, and serving of food
E – Wall Q – Crawl vents
F – Sink R – Other interior hazards
G – Fire exits S – Roof/gutters
H – Ceiling T – Flush toilet in enclosed space
I – Floor U – Stairs, rails, and porches
J – Range/refrigerator V – Exterior surface
K – Ventilation/plumbing W – Foundation
L – Garbage and debris * – Denotes unit determined to be materially deficient
26
Appendix D
CRITERIA
The following sections of the Code of Federal Regulations apply to housing quality
standards inspections:
24 CFR 982.54(d)(22) states that the public housing authority administrative
plan must cover policies, procedural guidelines, and performance standards
for conducting required housing quality standards inspections.
24 CFR 982.305(a) states that the public housing authority may not give
approval for the family of the assisted tenancy or execute a housing
assistance payments contract until the authority has determined that the unit
is eligible and has been inspected by the authority and meets HUD’s housing
quality standards.
24 CFR 982.401(a) identifies the housing quality standards for assisted
housing, including performance and acceptability criteria for key aspects of
housing quality.
24 CFR 982.401(a)(3) requires that all program housing meet housing quality
standards performance requirements, both at commencement of assisted
occupancy and throughout the assisted tenancy.
24 CFR 982.404(a)(1) requires the owners of program units to maintain the
units in accordance with HUD’s housing quality standards.
24 CFR 982.404(a)(2) states that if the owner of the program unit fails to
maintain the dwelling unit in accordance with HUD’s housing quality
standards, the authority must take prompt and vigorous action to enforce the
owner’s obligations. The authority’s remedies for such a breach of the
housing quality standards include termination, suspension, or reduction of
housing assistance payments and termination of the housing assistance
payments contract.
24 CFR 982.405(a) requires public housing authorities to perform unit
inspections before the initial term of the lease, at least annually during
assisted occupancy, and at other times as needed to determine whether the
unit meets the housing quality standards.
27
The Housing Authority of the City of Los Angeles, Los Angeles, California, Did Not Adequately Conduct Housing Quality Standards Inspections
Published by the Department of Housing and Urban Development, Office of Inspector General on 2008-11-17.
Below is a raw (and likely hideous) rendition of the original report. (PDF)