oversight

The Orange County Housing Authority, Santa Ana, CA, Did Not Always Ensure That Housing Units Met HUD's Housing Quality Standards

Published by the Department of Housing and Urban Development, Office of Inspector General on 2016-04-21.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

     Orange County Housing Authority,
             Santa Ana, CA
     Housing Choice Voucher Program Housing Quality
                       Standards




Office of Audit, Region 9     Audit Report Number: 2016-LA-1003
Los Angeles, CA                                    April 21, 2016
To:            Marcie P. Chavez, Director, Los Angeles Office of Public Housing, 9DPH

               //SIGNED//
From:          Tanya E. Schulze, Regional Inspector General for Audit, Region IX, 9DGA
Subject:       The Orange County Housing Authority, Santa Ana, CA, Did Not Always Ensure
               That Housing Units Met HUD’s Housing Quality Standards




Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our review of the Orange County Housing Authority’s housing
quality standards inspections of Housing Choice Voucher program-funded housing units.
HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on
recommended corrective actions. For each recommendation without a management decision,
please respond and provide status reports in accordance with the HUD Handbook. Please furnish
us copies of any correspondence or directives issued because of the audit.
The Inspector General Act, Title 5 United States Code, section 8M, requires that OIG post its
publicly available reports on the OIG Web site. Accordingly, this report will be posted at
http://www.hudoig.gov.
If you have any questions or comments about this report, please do not hesitate to call me at 213-
534-2471.
                    Audit Report Number: 2016-LA-1003
                    Date: April 21, 2016

                    The Orange County Housing Authority, Santa Ana, CA, Did Not Always
                    Ensure That Housing Units Met HUD’s Housing Quality Standards




Highlights

What We Audited and Why
We audited the Orange County Housing Authority’s Housing Choice Voucher program’s
housing quality standards primarily due to the Orange County district attorney’s investigation
into allegations that Authority inspectors conducted personal business during the work day.
These allegations resulted in concerns that inspections may not have been thorough to ensure
housing units met HUD standards. Our objective was to determine whether the Authority
conducted its inspections in accordance with U.S. Department of Housing and Urban
Development (HUD) rules and requirements.

What We Found
The Authority’s inspections did not adequately enforce HUD’s housing quality standards. Of the
80 housing units inspected, 42 were in material noncompliance with HUD standards. For those
units, the Authority’s inspectors failed to report 229 deficiencies that existed when they
conducted their last inspections. This condition occurred because the inspectors did not have
current and consistent training to ensure that housing units complied with housing quality
standards. In addition, it did not have a complete quality control review process in place to
ensure inspections of units met HUD standards. As a result, some tenants lived in housing that
was not up to HUD standards, and the Authority disbursed $217,916 in housing assistance
payments for these 42 units. Unless the Authority provides training to its inspectors and ensures
that all of its housing units materially meet minimum housing quality standards, we estimate that
over the next year, HUD will pay more than $48.6 million in housing assistance for units that are
materially noncompliant with HUD standards.

What We Recommend
We recommend that the Director of HUD’s Los Angeles Office of Public Housing require the
Authority to (1) reimburse its program $217,916 from non-Federal funds for the 42 units that
materially failed to meet HUD standards; (2) certify that the identified deficiencies have been
corrected for the units cited; (3) ensure that its inspectors are provided up-to-date and consistent
training on conducting inspections, which will prevent more than $48.6 million in program funds
from being spent on housing that does not meet HUD standards over the next year; and (4)
develop and implement quality controls, which ensure that housing complies with HUD
standards.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................4
         Finding: The Authority Did Not Always Ensure That Housing Units Met Housing
         Quality Standards ............................................................................................................. 4

Scope and Methodology .........................................................................................12

Internal Controls ....................................................................................................14

Appendixes ..............................................................................................................15
         A. Schedule of Questioned Costs and Funds To Be Put to Better Use ...................... 15
         B. Auditee Comments and OIG’s Evaluation ............................................................. 16
         C. Criteria ....................................................................................................................... 22
         D. Schedule of Questioned Costs for Materially Noncompliant Housing Units....... 26




                                                                     2
Background and Objective
The U.S. Department of Housing and Urban Development (HUD) designated the Orange County
Housing Authority as a public agency in 1971 and authorized it to provide housing assistance for
low-income families, which include families with children, the elderly, and people with disabilities,
residing within the 31 cities and unincorporated areas of Orange County, CA, excluding the cities of
Santa Ana, Garden Grove, and Anaheim. The Authority’s mission is to provide safe, decent, and
sanitary housing conditions for very low-income families and to manage resources efficiently.

The goal of the Housing Choice Voucher program is to provide safe, decent, and sanitary housing at
an affordable cost to low-income families. To accomplish this goal, program regulations set forth
basic housing quality standards, which all housing units must meet before assistance can be paid on
behalf of a family and at least annually throughout the term of the assisted tenancy. These standards
define standard housing and establish the minimum criteria necessary for the health and safety of
program participants (appendix C).

HUD is moving from housing quality standards to uniform physical condition standards for public
housing agencies to use when inspecting program-funded housing units.

The Authority is a division within Orange County Community Services that administers federally
funded programs to provide monthly rental assistance to qualified tenants in privately owned rental
housing. It is divided into three sections under the direction of a division manager:

   1. Occupancy and Residency Section

   2. Rental Assistance Section

   3. Special Housing Programs Section

In 2015, the Authority administered about 10,622 program-funded housing units and disbursed
more than $114 million in funding to provide housing assistance to eligible participants.

The objective of the audit was to determine whether the Authority conducted its housing quality
standards inspections in accordance with HUD rules and requirements.




                                                  3
Results of Audit

Finding: The Authority Did Not Always Ensure That Housing Units
Met Housing Quality Standards
The Authority did not always ensure that its program-funded housing units met HUD’s housing
quality standards. Of 80 units inspected, 69 failed to meet HUD’s minimum standards, and 42 1
were in material noncompliance with the standards. For the 42 units in material noncompliance,
the Authority’s inspectors failed to report 229 deficiencies that existed when they conducted
their last inspections. These deficiencies occurred because the Authority did not provide current
and consistent training to its inspectors to ensure that program-funded housing units complied
with housing quality standards. In addition, the Authority did not maintain a complete quality
control inspection process that ensured inspections of units complied with HUD standards. As a
result, some tenants lived in units that did not meet HUD standards, and the Authority disbursed
$217,916 in housing assistance payments for the 42 units in material noncompliance with HUD
standards. Unless the Authority provides training to its inspectors and ensures that all of its
housing units materially meet minimum housing quality standards, we estimate that over the next
year, HUD will pay more than $48.6 million in housing assistance for units in material
noncompliance with the standards.

Housing Quality Standards Not Met
We statistically selected 80 2 housing units from a universe of 1,154 program-funded units that
had passed an Authority housing quality standards inspection between May 1 and July 31, 2015.
The 80 units were selected to determine whether the Authority ensured that its program-funded
units met minimum housing quality standards. We inspected the units from October 20 to
December 14, 2015. We performed the inspections within 3 to 7 months after the Authority
performed its inspections.

Contrary to 24 CFR (Code of Federal Regulations) 982.401(a)(3) (appendix C), 42 of the 80
units inspected (53 percent) failed and were in material noncompliance with housing quality
standards. These units were in material noncompliance for having at least three deficiencies,
which created living conditions that were not decent, safe, and sanitary for tenants. We
determined some of these deficiencies were caused by the tenants; however, these units still
failed HUD housing standards. The 42 units had a total of 229 deficiencies (appendix D).

Contrary to the Authority’s 2015 administrative plan (appendix C), the units identified had
deficiencies, such as (1) conditions that jeopardized the security of the housing unit, including



1
  An additional 27 of 80 units failed but were not materially deficient. The remaining 11 units passed with no
  deficiencies.
2
  Our methodology for the statistical sample is explained in the Scope and Methodology section of this audit report.



                                                          4
windows and doors on the first floor that do not lock; (2) electrical problems or conditions that
could result in shock or fire; and (3) conditions that presented an imminent possibility of injury.

The following table lists the top 5 deficiencies identified among the 42 units that were materially
noncompliant with HUD standards.

                                                                   Number of        Number of
                       Type of deficiency
                                                                   deficiencies    housing units
              Interior debris and unsafe storage                        51               32
       Kitchen sinks, cabinets, stoves, duct systems, and
                                                                        33               23
                          countertops
           Exterior, foundation, and site conditions                    31               14
                     Doors and door locks                               24               18
                 Windows and window locks                               22               14

Types of Deficiencies
The following photographs illustrate some of the deficiencies noted during housing quality
standards inspections of the 42 units that materially failed to meet HUD standards. Most of the
deficiencies were categorized as interior debris and unsafe storage; kitchen sinks, cabinets,
stoves, duct systems, and countertops; exterior, foundation, and site conditions; door and door
locks; and windows and window locks.

Interior Debris and Unsafe Storage
A total of 51 deficiencies were found in the 32 housing units that materially failed to meet
HUD’s housing quality standards.




                                                  5
The picture above shows a housing unit with personal items that restricted access to the window.
In addition, the tenant’s personal items surrounded oxygen tanks, which created a safety issue for
the tenant and others in the building. The Authority’s own inspection checklist states that the
inside and outside of the housing unit must be free from accumulated clutter. If the tenant’s
personal items blocked access to the window, emergency crews would not be able to rescue
tenants from potential emergencies. Two weeks before OIG’s inspections, the fire department
inspected and failed the housing unit for the same deficiencies.

Kitchen Sinks, Cabinets, Stoves, Duct Systems, and Countertops
A total of 33 deficiencies were found in the 23 housing units that materially failed to meet
housing quality standards.




                                                 6
The picture above shows a stove vent system that was not properly sealed. The Authority’s
administrative plan states that this issue would be considered life threatening as it presents an
imminent possibility of injury to the tenant. The lack of a properly sealed stove vent is a safety
issue that could result in a fire.

Exterior, Foundation, and Site Conditions
A total of 31 deficiencies were found in the 14 housing units that materially failed to meet
HUD’s housing quality standards.




                                                 7
The picture above shows a housing unit yard that the owner used as a personal storage space for
debris. The Authority’s own inspection checklist states the inside and outside of the unit must be
free of accumulated garbage, debris, and clutter. The Authority’s administrative plan states that
this issue would be considered life threatening as it presents an imminent possibility of injury to
the tenant. The owner’s use of the yard for debris posed a health and safety concern for the
tenant and family. Further, the tenant did not have full access to the unit.

Doors and Door Locks
A total of 24 deficiencies were found in the 18 housing units that materially failed to meet
HUD’s housing quality standards.




                                                 8
The picture above shows an exterior door to a housing unit with a bottom lock that did not work.
The Authority’s administrative plan; HUD Handbook 7420.10G, chapter 10; and 24 CFR
982.401(d)(2)(iv) state that the exterior doors of a housing unit must be lockable. Specifically,
HUD Handbook 7420.10G Chapter 10.3 Performance Requirements and Acceptability Standards
for space and security acceptability criteria state that door surfaces must be in sufficient
condition to support the installation and proper operation of door locks. In addition, the Housing
Choice Voucher Housing Quality Standards Master Book Chapter 3: Electricity and Security
Section 2: Space and Security used by the Authority states all locks should be operable and
fastened securely for exterior doors . The administrative plan states that this issue would be
considered life threatening as it would jeopardize the security of the housing unit. In this case, a
bottom lock to an exterior door that does not work would result in a failed inspection of the unit.

Windows and Window Locks
A total of 22 deficiencies were found in the 14 housing units that materially failed to meet
HUD’s housing quality standards.




                                                 9
The picture above shows a window without a locking device. Regulations at 24 CFR
982.401(d)(2)(iii) and HUD Handbook 7420.10G, chapter 10, require that housing unit windows
that are accessible from the outside be lockable. In addition, the training manual states that
windows must be lockable. The Authority’s administrative plan states that this issue would be
considered life threatening as it would jeopardize the security of the housing unit. If a window
does not have the required lock, there is a safety concern for the tenant and family.

Lack of Current and Consistent Training
The Authority did not provide current and consistent training to its inspectors to ensure that
inspections conducted on its program-funded units complied with HUD standards. The
Authority had not provided its inspectors training on HUD standards since 2007. Subsequent
training courses did not provide specific information on HUD’s housing quality standards. In
August and December 2010, the Authority sent 6 of its 16 inspectors to a housing quality
standards training course presented by an outside vendor. In June 2014, it provided inspectors an
online refresher course on HUD standards. The inspectors had completed other training courses
in the areas of mobility process, bed bugs, and lead-based paint. In 2015, there was no record of
the Authority providing its inspectors with housing quality standards training. As a result,
Authority inspectors incorrectly passed units that did not meet the required standards.




                                                10
Inadequate Quality Control Process
The Authority did not maintain a complete quality control process that ensured inspections of
housing units met HUD standards. A quality control inspection is a reinspection of randomly
selected housing units by a supervisor or other qualified individual to ensure that housing quality
standards inspections were conducted correctly and uniformly. The Authority is required to
inspect a specific number of units within the year. In this case, it randomly selected 94 units for
quality control reviews. We found that 43 of these quality control inspections lacked the
required information, such as whether the unit passed or failed the quality control review. We
also found that 40 of the inspection reports did not have the required signatures to certify that the
inspector had completed the quality control inspection. As a result, inspectors were not provided
with complete and accurate feedback about their performance to ensure that housing units met
HUD’s housing quality standards.

Conclusion
The deficiencies described above occurred because the Authority failed to provide current and
consistent training and a complete quality control review to its inspectors. The lack of current
and consistent training and a complete quality control review did not ensure that program-funded
housing units met housing quality standards. In addition, these causes allowed tenants to live in
units that were not safe and decent conditions. As a result, the Authority spent $217,916 in
housing assistance payments on 42 housing units (appendix D) that were in material
noncompliance.

Unless the Authority improves its inspection program to ensure compliance with HUD standards,
HUD will spend more than $48.6 million in housing assistance on units in material
noncompliance with the standards over the next year.

Recommendations
We recommend that the Director of the Los Angeles Office of Public Housing require the
Authority to

       1A.     Reimburse its program from non-Federal funds $217,916 for the 42 units that
               materially failed to meet HUD’s housing quality standards

       1B.     Certify that the identified failed housing quality standards items have been
               corrected for the units cited in this report or take appropriate administrative
               action.

       1C.     Ensure that its inspectors are provided up-to-date and consistent training on
               conducting inspections, which will prevent $48,665,810 in program funds from
               being spent on units that are in material noncompliance with HUD standards over
               the next year.

       1D.     Develop and implement quality controls to ensure that its Housing Choice
               Voucher program-funded units comply with HUD standards.




                                                  11
Scope and Methodology
We performed our audit work at the Authority’s office in Santa Ana, CA, from September 21,
2015, to February 19, 2016. Our review covered the period July 1, 2014, to July 31, 2015, and
was expanded as necessary.

To accomplish our objective, we

   •   Reviewed and analyzed the Authority’s policies, procedures, internal controls, and
       financial records relating to the program;

   •   Reviewed applicable HUD regulations and requirements;

   •   Reviewed HUD’s monitoring reports, annual plan, and consolidated annual contributions
       contract;

   •   Reviewed files, such as housing quality standards inspection reports, housing assistance
       payment registers, quality control inspection reports, and tenant files and data;

   •   Interviewed Authority staff; and

   •   Conducted on-site inspections of statistically sampled housing units.

We inspected a statistical sample of 80 housing units. The units were selected from a universe of
1,154 Housing Choice Voucher program-funded rental units that passed the Authority’s
inspections from May 1 through July 31, 2015. We selected recently completed inspections to
determine whether the Authority’s inspection staff adequately inspected and correctly passed
program-funded units. We used statistical sampling because each sampling unit was selected
without bias from the audit population, thereby allowing the results to be projected to the
population.

Based on the statistical sample of 80, we found that 42 of the units had material housing quality
standards deficiencies but passed an Authority inspection. Using a confidence interval of 95
percent, we projected that at least 43.6 percent of the units had material deficiencies. Extending
this amount to the monthly count of 8,902 occupied units on the Authority’s program, we can say
that at least 3,884 units would have material housing quality standards deficiencies, despite
having passed Authority inspections.

Based on the average housing assistance paid for the 80 units, less a deduction to account for a
statistical margin of error, we can say with a confidence interval of 95 percent that the average
amount of monthly housing assistance spent on units that did not meet HUD standards was




                                                 12
$455.57 per unit. Extending this amount to the 8,902 units over 12 months yields at least $48.6
million in housing assistance paid per year for substandard housing.

We relied in part on data maintained by the Authority. We performed an assessment of the
reliability of the data and found the data to be reasonably reliable for our audit objective.

We conducted the audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objective(s). We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.




                                                 13
Internal Controls
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the achievement of the organization’s mission,
goals, and objectives with regard to

•   Effectiveness and efficiency of operations,
•   Reliability of financial reporting, and
•   Compliance with applicable laws and regulations.
Internal controls comprise the plans, policies, methods, and procedures used to meet the
organization’s mission, goals, and objectives. Internal controls include the processes and
procedures for planning, organizing, directing, and controlling program operations as well as the
systems for measuring, reporting, and monitoring program performance.

Relevant Internal Controls
We determined that the following internal controls were relevant to our audit objective:

•   Effectiveness and efficiency of program operations – Policies and procedures implemented to
    ensure effective and efficient operations of the Authority’s housing quality standards
    inspections.

•   Reliability of financial information – Policies and procedures implemented to reasonably
    ensure that valid and reliable information is obtained, maintained, and fairly disclosed in its
    housing quality standards inspection reports, and

•   Compliance with applicable laws and regulations – Policies and procedures implemented to
    ensure that housing quality standards inspections are consistent with applicable HUD
    requirements.
We assessed the relevant controls identified above.
A deficiency in internal control exists when the design or operation of a control does not allow
management or employees, in the normal course of performing their assigned functions, the
reasonable opportunity to prevent, detect, or correct (1) impairments to effectiveness or
efficiency of operations, (2) misstatements in financial or performance information, or (3)
violations of laws and regulations on a timely basis.
Significant Deficiency
Based on our review, we believe that the following item is a significant deficiency:

•   The Authority did not provide current and consistent training to ensure that program-funded
    housing units complied with HUD’s housing quality standards (finding).



                                                  14
Appendixes

Appendix A


           Schedule of Questioned Costs and Funds To Be Put to Better Use
                Recommendation                     Funds to be put
                                    Ineligible 1/
                     number                        to better use 2/
                         1A            $217,916
                         1C                              $48,665,810
                       Totals          $217,916          $48,665,810


1/   Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity
     that the auditor believes are not allowable by law; contract; or Federal, State, or local
     policies or regulations.
2/   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, 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 stop incurring program costs for housing units that are not
     decent, safe, and sanitary. Instead, it will put more than $48.6 million on housing units
     that meet HUD’s standards. (See the Scope and Methodology section of the report for
     the calculation.) Once the Authority improves its training and controls, this will be a
     recurring benefit. Our estimate reflects only the initial year of this benefit.




                                             15
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 1




Comment 2




                               16
Ref to OIG
Evaluation




Comment 3




Comment 4




             17
Ref to OIG
Evaluation




Comment 5




Comment 6




             18
Ref to OIG
Evaluation




Comment 7




Comment 8




             19
                         OIG Evaluation of Auditee Comments


Comment 1   We acknowledge the Authority’s commitment to providing safety to its program
            participants. However, we disagree that the identified deficiencies deviate from
            housing quality standards. Our inspections followed the requirements stated in
            the Authority’s Housing Choice Voucher Program Administrative Plan. The
            Authority’s administrative plan section on housing quality standards is based on
            HUD rules and requirements such as those included in appendix C. As a result,
            the identified deficiencies are within HUD standards.

            We acknowledge the challenges that the Authority faced with staffing shortage
            that affected its ability to conduct inspections of program-funded units. However,
            the Authority can take the appropriate actions to ensure that units meet HUD
            standards.

Comment 2   The CGI Federal report was part of HUD’s move from housing quality standards
            inspections to uniform physical condition standards for public housing agencies to
            use when inspecting program-funded housing units. As a result, the mentioned
            checklist from the report does not pertain to the current use of housing quality
            standards inspections by the Authority. As a result, we based our inspection of
            the units using the Authority’s own 2015 Housing Choice Voucher Program
            Administrative Plan. According to the administrative plan, the Authority
            established the criteria for deficiencies that are considered life threatening and
            need correction within 24 hours of being identified by the inspector. In addition,
            we used HUD rules and requirements to determine whether the deficiencies were
            considered life-threatening conditions that must be corrected within 24 hours of
            the inspection. Throughout our review, we informed the Authority of the
            deficiencies identified as life threatening that needed to be corrected within 24
            hours of the inspections.

Comment 3   We disagree with the Authority’s assessment that the cited exterior door met
            HUD requirements with only a functional deadbolt upper lock. The Authority’s
            administrative plan states that the door must be lockable and does not give
            exceptions. Further, HUD Handbook 7420.10G Chapter 10.3 Performance
            Requirements and Acceptability Standards for space and security states that door
            surfaces must be in sufficient condition to support the installation and proper
            operation of door locks. In addition, the Housing Choice Voucher Housing
            Quality Standards Master Book Chapter 3: Electricity and Security Section 2:
            Space and Security for lock for exterior doors specified that all locks should be
            operable and fastened securely to the door. Since the bottom lock to the exterior
            door of the unit was not lockable, it was considered a deficiency that contributed
            to that unit failing HUD standards.




                                             20
Comment 4   We understand that there were tenant-caused deficiencies that factored into the
            units failing HUD standards and have added that acknowledgement in the report.
            However, the Authority is responsible for ensuring that units meet HUD
            standards. In addition, the cited tenant-caused deficiencies were not the only
            determining factor that made the units in question materially deficient. During
            our inspections, there were identified owner-caused deficiencies that factored into
            our determination of whether the units materially failed HUD standards.

Comment 5   While families in the program have preferences to reside at the units, the
            Authority must ensure that units meet HUD standards. In accordance with the
            Authority’s administrative plan, the inspector identified deficiencies at the units
            with conditions that present imminent possibility of injury were considered life
            threatening. In addition, the Housing Choice Voucher Program Guidebook
            Chapter 10.3 Performance Requirements and Acceptability Standards for
            structure and materials acceptability criteria state that “the condition and
            equipment of interior and exterior stairs, halls, porches, and walkways must not
            present the danger of tripping and falling.” Further, the site and neighborhood
            acceptability criteria state that “the site and neighborhood may not be subject to
            serious adverse natural or manmade environmental conditions, such as dangerous
            walks or steps…” Based on these HUD requirements, we determined that
            deficiencies such as uneven cement and iron stairwell and entry walkway with a 7
            ½ step drop at two units presented imminent possibilities of injury that would be
            considered life threatening to the participants.

Comment 6   We appreciate and commend the Authority for being proactive in addressing the
            failed housing quality standard items identified during the review.

Comment 7   We commend the Authority for being proactive in ensuring that its inspectors are
            provided up-to-date and consistent training on conducting inspections.

Comment 8   We appreciate and commend the Authority for taking action to ensure that it
            develops and implements a quality control inspection plan. By developing and
            implementing this plan, the Authority will ensure that inspections of program-
            funded units meet HUD standards.




                                             21
Appendix C
                                             Criteria

The following sections of 24 CFR Part 982, HUD Handbook 7420.10G, the consolidated annual
contributions contract, the Authority’s administrative plan, Housing Choice Voucher Housing
Quality Standards Master Book, and the Authority’s checklist were relevant to our review of the
Authority’s housing quality standards inspections of program-funded housing units.

24 CFR Part 982 – Section 8, Tenant Based Assistance Housing: Housing Choice Voucher
Program
24 CFR 982.305(a), Program requirements. The PHA [public housing agency] may not give
approval for the family of the assisted tenancy, or execute a HAP [housing assistance payments]
contract, until the PHA has determined that all the following meet program requirements:

   (1) The unit is eligible;

   (2) The unit has been inspected by the PHA and passes HQS [housing quality standards];

24 CFR 982.401(a)(3). All program housing must meet the HQS performance requirements both
at commencement of assisted occupancy, and throughout the assisted tenancy.

24 CFR 982.401(a)(4)(i). In addition to meeting HQS performance requirements, the housing
must meet the acceptability criteria stated in this section, unless variations are approved by HUD.

24 CFR 982.404(a), Owner obligation.

   (1) The owner must maintain the unit in accordance with HQS.

   (2) If the owner fails to maintain the dwelling unit in accordance with HQS, the PHA must
       take prompt and vigorous action to enforce the owner obligations. PHA remedies for
       such breach of the HQS include termination, suspension or reduction of housing
       assistance payments and termination of the HAP contract.

   (3) The PHA must not make any housing assistance payments for a dwelling unit that fails to
       meet the HQS, unless the owner corrects the defect within the period specified by the
       PHA and the PHA verifies the correction. If a defect is life threatening, the owner must
       correct the defect within no more than 24 hours. For other defects, the owner must
       correct the defect within no more than 30 calendar days (or any PHA-approved
       extension).

24 CFR 982.401(d)(2)(iii). Dwelling unit windows that are accessible from the outside, such as
basement, first floor, and fire escape windows, must be lockable (such as window units with sash
pins or sash locks, and combination windows with latches). Windows that are nailed shut are




                                                 22
acceptable only if these windows are not needed for ventilation or as an alternate exit in case of
fire.

24 CFR 982.401(d)(2)(iv). The exterior doors of the dwelling unit must be lockable. Exterior
doors are doors by which someone can enter or exit the dwelling unit.

Consolidated Annual Contributions Contract
10. HUD Requirements

   a. The HA [housing agency] must comply, and must require owners to comply, with the
      requirements of the U.S. Housing Act of 1937 and all HUD regulations and other
      requirements, including any amendments or changes in the law or HUD requirements.

   b. The HA must comply with its HUD-approved administrative plan, and HUD-approved
      program funding applications.

   c. The HA must use the program forms required by HUD.

   d. The HA must proceed expeditiously with the programs under this consolidated ACC
      [annual contributions contract].

11. Use of Program Receipts

   a. The HA must use program receipts to provide decent, safe, and sanitary housing for
      eligible families in compliance with the U.S. Housing Act of 1937 and all HUD
      requirements. Program receipts may only be used to pay program expenditures.

Orange County Housing Authority Administrative Plan, Housing Choice Voucher
Program, Adopted 1-27-2015
Chapter 8, Housing Quality Standards and Rent Reasonableness Determinations
8-I.B. Additional Local Requirements

Clarifications of HUD Requirements
As permitted by HUD, OCHA [the Authority] has adopted the following specific requirements
that elaborate on HUD standards.

Windows
Windows shall be operational and clear of obstructions that would prevent ingress and egress.

Doors
All exterior doors must be weather-tight to avoid any air or water infiltration, be lockable with
no interior key lock, have no holes, have all trim intact, and have a threshold.

8.I.C. Life Threatening Conditions [24 CFR 982.404(A)]




                                                 23
   •    Any condition that jeopardizes the security of the unit including locking windows and
        doors on the first floor.

   •    Electrical problems or conditions that could result in shock or fire.

   •    Conditions that present the imminent possibility of injury.

Orange County Housing Authority Checklist, Most Common Reasons a Unit Fails
Inspection
Orange County Housing Authority will not make housing assistance payments on a unit that fails
Housing Quality Standards inspections. To help you continue to receive rental assistance and to
avoid interruption of payments to the landlord, we have provided a list of the most common
items that fail a unit at inspection but it is not a complete list. It is to your benefit to take the
time to go through the list and check each item before the Inspector comes out for the inspection
appointment.

Checklist

   •    Keyed locks on interior doors are not acceptable.

   •    The unit must be free of accumulation of garbage, debris and clutter both inside and
        outside the unit.

   •    If you reside in a house the yard must be maintained.

HUD Handbook 7420.10, Housing Choice Voucher Program Guidebook, Chapter 10,
Housing Quality Standards
10.3 Performance Requirements and Acceptability Standards
Space and Security
Acceptability Criteria

    •   Dwelling unit windows that are accessible from the outside must be lockable.

    •   Exterior doors to the unit must be lockable.

Unit windows located on the first floor, at the basement level, on a fire escape, porch, or other
outside space that can be reached from the ground and that are designed to be opened must have
a locking device.

Doors leading to the outside and common hallways, fire escapes, and porches or otherwise
accessible from the ground must have locks. No specific type of lock is required.

Window and door surfaces (including the door frame) must be in sufficient condition to support
the installation and proper operation of window and door locks.



                                                  24
Structure and Materials
Acceptability Criteria

   •   The condition and equipment of interior and exterior stairs, halls, porches, and walkways
       must not present the danger of tripping and falling.

Site and Neighborhood
Acceptability Criteria

   •   The site and neighborhood may not be subject to serious adverse natural or manmade
       environmental conditions, such as dangerous walks or steps, instability, flooding, poor
       drainage, septic tank back-ups or sewer hazards, mudslides, abnormal air pollution,
       smoke or dust, excessive noise, vibration, or vehicular traffic, excessive accumulations of
       trash, vermin, or rodent infestation, or fire hazards.

Housing Choice Voucher Housing Quality Standards Master Book, April 1, 2015
Chapter 3 Electricity and Security, Section 2: Space and Security
GENERAL SECURITY REQUIREMENTS

   •   These areas must be lockable:

          -   Unit’s windows which are accessible from the outside (HUD states that a lockable
              combination storm/screen window with a non-lockable inside window is
              acceptable)

          -   Unit’s exterior doors that provide access to or egress from the unit.


Lock for Exterior Doors

   •   The requirements are:
          - All locks should be operable and fastened securely to the door.




                                                25
Appendix D
             Schedule of Questioned Costs for Materially Noncompliant Housing Units


                           Housing unit         Number of deficiencies            Total 3

                                 A                            6                   $5,752
                                 B                            4                   $7,292
                                 C                           12                   $3,132
                                 D                            3                   $3,328
                                 F                           16                   $1,964
                                 G                            3                   $2,070
                                  I                           6                   $5,208
                                  J                           5                   $4,795
                                 K                            3                   $3,644
                                 L                            4                   $3,512
                                 M                           10                   $6,312
                                 N                            4                   $7,084
                                 O                            6                   $5,255
                                 P                            5                   $1,032
                                 Q                            4                    $192
                                 S                            8                  $10,230
                                 T                            4                   $6,515
                                 V                            6                   $6,345
                                 W                            7                   $3,336
                                 Z                            3                   $8,874
                                 I2                           3                    $840
                                 J2                          11                   $5,760
                                 K2                           3                   $4,236
                                 L2                           3                   $4,836
                                 M2                           3                   $5,850
                                 N2                           4                   $4,975
                                 O2                           6                   $4,860




3
    The total questioned amount for each housing unit is based on months between the Authority’s inspection and our
    inspection, multiplied by the monthly housing assistance payment.



                                                           26
Housing unit   Number of deficiencies    Total

    P2                   3               $6,090
    Q2                   6              $12,901
    R2                   4               $8,610
    T2                   8               $3,504
    W2                   3              $12,018
    A3                   3               $3,925
    B3                   3               $3,270
    D3                   3               $3,996
    E3                   3               $4,599
    G3                   7               $2,090
    L3                   8               $4,730
    M3                   6               $6,185
    N3                   4               $5,275
    P3                   6               $6,168
    Q3                  10               $7,326
   Totals               229             $217,916




                       27