oversight

HUD's Oversight of the Alexander County Housing Authority

Published by the Department of Housing and Urban Development, Office of Inspector General on 2018-07-24.

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

                                      MEMORANDUM
                                           July 24, 2018



To:      Dominique Blom
         General Deputy Assistant Secretary, Office of Public and Indian Housing, P


From:    Brian T. Pattison
         Assistant Inspector General for Evaluation, G

Subject: Final Evaluation Report – HUD’s Oversight of the Alexander County Housing
         Authority, 2017-OE-0014


Please see the attached final report on our evaluation of the U.S. Department of Housing and
Urban Development’s (HUD) oversight of the Alexander County Housing Authority in Cairo,
IL. It contains three findings and four recommendations. The report will be posted to our
website within 3 days.

In your response to our draft report, you agreed with our findings and recommendations. Your
response, along with our comments to it, are included in our report. Based on your response, we
consider recommendations 1, 2, 3, and 4 “unresolved-open.” We will contact your office within
90 days to begin discussing your proposed management decisions.

I appreciate the assistance you, your staff, and staff throughout HUD provided throughout the
evaluation. If you have any questions, please contact Director Paul Bergstrand at (202) 402-
2728.

Attachment

cc
Unabyrd Wadhams, Former Deputy Assistant Secretary for Field Operations, PQ
Donald Lavoy, Deputy Assistant Secretary for the Real Estate Assessment Center, PX
Kelley Lyons, Regional Public Housing Director for Chicago Hub, Office of Public and Indian
Housing, 5FPH
Daniel Sherrod, Director, Chicago Hub, Office of Public and Indian Housing, 5APH
Peter Schmiedel, Financial Management Specialist, Office of Public and Indian Housing, PCE
Rochelle Katz, Assessment Manager, Office of Public and Indian Housing, PG
James Cunningham, Deputy Regional Administrator, Office of Field Policy and Management,
5AMA
Bryan Greene, General Deputy Assistant Secretary, Office of Fair Housing and Equal
Opportunity, E1
Terri L. Wanzer, Management Analyst, Office of Fair Housing and Equal Opportunity, EGP
Charles M. Montgomery III, Director, Office of Fair Housing and Equal Opportunity, EGP
Craig T. Clemmensen, Director, Departmental Enforcement Center, CACB

                                       Office of Inspector General
                                           Office of Evaluation
                                      th
                                 451 7 Street SW, Washington, DC 20410
                                 Phone (202) 708-0430, Fax (202) 401-2505
                                             www.hudoig.gov
                                         HUD’s Oversight of the Alexander County Housing Authority
                                                                                     July 24, 2018

Frieda Edwards, Director, Office of General Counsel, CAGB
Patrice Mitchell, Management Analyst, Office of General Counsel, CAGB
     U.S. Department of Housing and Urban Development

                 Office of Inspector General
                       Office of Evaluation




      HUD’s Oversight of the Alexander
         County Housing Authority




                     Program Evaluations Division

Washington, DC       Report Number: 2017-OE-0014    July 24, 2018
                                                                        Executive Summary
                     HUD’s Oversight of the Alexander County Housing Authority


Report Number: 2017-OE-0014                                                                        July 24, 2018

Why We Did This                Results of Evaluation
Evaluation
                               HUD had been aware of negative conditions at ACHA since at least 2010. HUD
The Office of Public and       identified issues with ACHA’s governance, including the misuse of funds,
Indian Housing (PIH) is        conflicts of interest, and a failure to comply with HUD policies and Federal civil
responsible for (1)            rights laws. Further, about 200 children and their families lived in units with
monitoring public housing      peeling paint; graffiti; pest infestations; and other health and safety hazards, such
agencies’ (PHA)                as inoperable appliances and obstructed accessibility routes.
compliance with program
                               Despite HUD’s attempts to bring ACHA into compliance, its efforts did not
requirements and (2)
                               resolve the negative conditions at ACHA. Residents continued to live in
ensuring that effective
                               deplorable conditions as ACHA languished, and ACHA officials were generally
controls are in place to
                               uncooperative in addressing the negative conditions HUD identified. Since
prevent potential problems.
                               2010, PIH had used several oversight tools to identify issues at the ACHA, but
PHAs are responsible for
                               major enforcement action against ACHA occurred only after HUD assembled a
providing safe, decent, and
                               cross-programmatic team. HUD hesitated to take ACHA into possession in part
affordable rental housing
                               because PIH officials believed that they had to allow ACHA an opportunity to
for eligible low-income
                               improve instead of declaring it in substantial default. Additionally, HUD
families, the elderly, and
                               guidance and expertise on receiverships were limited.
persons with disabilities.
                               On February 19, 2016, HUD declared ACHA in substantial default of its
We initiated this review in    contract with HUD, removed its board, and took possession of it. At that time,
response to a request for an   HUD assumed the role of administrative receiver of ACHA.
evaluation from Senators
Richard (Dick) Durbin and      Recommendations
Tammy Duckworth of
Illinois and interest from     Conditions at ACHA had deteriorated over a decade or more, and two housing
other members of               developments there, Elmwood and McBride, are scheduled for demolition.
Congress. In the formal        Since we concluded our fieldwork, HUD decided that two additional ACHA
request, the Senators noted    housing developments (Sunset Terrace and Mary Alice Meadows in Thebes, IL)
the deteriorating housing      will also be closed as necessary repairs there are too expensive, further reducing
conditions and overall         available affordable housing stock for low-income residents. While local
mismanagement at the           officials are responsible for the daily administration of ACHA, HUD could and
Alexander County Housing       should have done more to oversee it. Although it may to be too late to save
Authority (ACHA). In           ACHA, as of June 2018, 50 other PHAs were designated as troubled. Therefore,
response to this request, we   we offer four recommendations to improve PIH’s administration and oversight of
assessed the U.S.              troubled PHAs. PIH agreed with each of our recommendations. The status of
Department of Housing and      each recommendation will remain “unresolved-open” until we receive further
Urban Development’s            documentation outlining PIH’s proposed management decision to address each
(HUD) oversight of ACHA        recommendation.
to determine whether HUD
met program requirements.
Table of Contents
Introduction ........................................................................................................................... 2
  Objective ............................................................................................................................ 2
  Background........................................................................................................................ 2
  Scope and Methodology .................................................................................................... 4
A Primer: HUD’s Oversight of ACHA ................................................................................... 5
Findings ................................................................................................................................ 6
  PIH Used Several Oversight Tools To Identify Issues at ACHA, but Negative Conditions
  Persisted ............................................................................................................................ 6
  Only After HUD Assembled a Cross-Programmatic Team Did It Take Major Enforcement
  Action Against ACHA ......................................................................................................... 9
  HUD Hesitated To Exercise Its Authority To Take ACHA Into Receivership .................... 12
Recommendations .............................................................................................................. 17
  1. Create Agreements and Strategies With Other Program Offices That Describe When
  Cross-Programmatic Reviews and Enforcement Actions Against PHAs Are Required .... 17
  2. Train PIH Officials on the Authority and Processes for Declaring PHAs in Substantial
  Default and for Taking PHAs Into HUD Possession ......................................................... 17
  3.     Update and Strengthen the Training Program for HUD Receivers of PHAs ............. 18
  4. Update Procedures for Receiverships To Include Specific Guidance on When
  Initiating a Receivership May Be Appropriate .................................................................. 18
Agency Comments and OIG Response .............................................................................. 19
  Summary of PIH’s Comments .......................................................................................... 19
  OIG Response to PIH’s Comments ................................................................................. 19
  PIH Comments to the Draft Report .................................................................................. 20
Appendixes ......................................................................................................................... 22
  Appendix A – Acknowledgements.................................................................................... 22
  Appendix B – Acronyms................................................................................................... 23


List of Figures
Figure 1 – Timeline of HUD’s oversight of ACHA.................................................................. 5
Figure 2 – ACHA housing developments’ physical conditions scores from FY 2012 to 2013 9
Figure 3 – FHEO findings of racially segregated housing developments at ACHA ............. 10
Figure 4 – ACHA’s overall PHAS scores from FY 2010 to 2016 ......................................... 14
Introduction
Objective
To assess the U.S. Department of Housing and Urban Development’s (HUD) oversight of the
Alexander County Housing Authority (ACHA).

Background
Overview of the Public Housing Program and Public Housing Agencies

The Office of Public and Indian Housing (PIH) operates HUD’s public housing programs.
Public housing’s mission is to provide safe, decent, and affordable rental housing for eligible
low-income families, the elderly, and persons with disabilities. Nationwide, approximately 1.2
million families reside in public housing developments that are owned and operated by about
3,300 local public housing agencies (PHA). HUD provides Federal aid to PHAs, which in turn
manage public housing for eligible residents at rents they can afford. Additionally, HUD
furnishes technical and professional assistance to PHAs for planning, development, and
management. Each year, HUD provides approximately $4 billion in operating subsidies to assist
PHAs in running their public housing programs. HUD also awards approximately $2 billion to
PHAs annually to develop, modernize, and maintain public housing properties.

A PHA is a legal entity authorized by a State to develop or administer low-rent public housing.
PHAs are the “caretakers” of public housing funds and must ensure that the funds are properly
managed. The PHA’s executive director, board, or commission operates and manages the PHA.
PHAs are responsible for operating their housing developments to ensure that the PHA complies
with its annual contributions contract. This contract is an agreement between the PHA and
HUD, which outlines the applicable regulations and procedural requirements that PHAs must
abide by to receive Federal funding. The contract also outlines HUD funds available for a
PHA’s use for that year. ACHA is a moderate-size PHA in Cairo, IL, with nearly 500 units in its
inventory.

HUD’s Oversight of PHAs

The Housing Act of 1937 requires that HUD establish rules and provide funding for PHAs to
manage their own housing programs. The intent of the Act is to give as much flexibility and
responsibility to the State and its units of local government as possible. In turn, HUD is to
ensure that PHAs meet performance requirements and provide technical assistance, with the goal
of safeguarding both public investment and resident quality of life.

HUD’s objective is to identify endangered funds and assist PHAs in correcting deficiencies it
identifies while monitoring PHAs. Field offices monitor PHAs remotely from the field office or
onsite at the PHA. A field office generally does not perform onsite monitoring of a PHA unless
it knows of performance or compliance problems. Field offices may focus efforts on PHAs that
are determined to be in the greatest need of attention. To identify those in greatest need of
attention, PIH uses a risk-based monitoring approach that accounts for a PHA’s risk in five areas.
These five areas are (1) organization, management, and personnel; (2) facilities management; (3)

                                                2
finance and budget; (4) marketing, leasing, and management; and (5) community relations and
involvement.

In addition to the field offices’ monitoring activities, PIH’s Real Estate Assessment Center
(REAC) inspects HUD properties to ensure that units are decent, safe, sanitary, and in good
repair. REAC uses a uniform physical inspection protocol with an intent to ensure that the
inspections of HUD properties are as uniform and objective as possible. REAC examines four
indicators about the PHA: its physical condition, financial condition, management operations,
and Public Housing Capital Fund program. Inspectors submit inspection data to REAC, which
REAC checks and analyzes. A PHA’s physical conditions indicator score affects the frequency
of its inspection cycle, with poorly performing PHAs requiring inspection more frequently.
REAC compiles each of the four indicators into an overall score using a scale of 0 to 100. This
score helps HUD identify PHAs with performance issues using its Public Housing Assessment
System (PHAS). Using this PHAS score, PIH designates the PHA as a high, standard,
substandard, or troubled performer. A PHA that achieves an overall PHAS score of less than 60
percent would be designated as a troubled performer.

PIH policy requires that the field office initiate the PHA Recovery and Sustainability (PHARS)
protocol for PHAs designated as troubled. 1 In 2011, PIH launched the PHARS protocol as a
four-phased approach to recover PHAs. HUD created this protocol as a holistic approach to
solving and remediating systemic issues at PHAs. When a PHA is found to be troubled, the
regional director usually assigns a PHARS team to lead in the recovery effort of that PHA. This
team is composed of staff from the Office of Field Policy and Management (FPM), PIH, and the
Departmental Enforcement Center (DEC). The PHARS team performs a preliminary financial
management and governance assessment of the PHA. The PHARS team (1) works with troubled
PHAs to assess the underlying systemic issues causing the PHA’s troubled status, (2) creates
recovery agreements, and (3) implements action plans that will ensure the sustainability of
successful PHA performance. It also continues to monitor the PHA and provide support during
the implementation and cure period.

Although HUD generally follows the PHARS protocol to remedy negative conditions at PHAs,
HUD also has the authority to declare a PHA in substantial default in emergency situations. In
these cases, the PHA is not provided an opportunity to respond or cure negative conditions when
HUD determines that conditions exist that pose an imminent threat to the life, health, or safety of
public housing residents or residents of the surrounding neighborhood or (2) the events or
conditions precipitating the default are determined to be the result of criminal or fraudulent
activity. 2 HUD may also determine that PHAs with serious financial, physical, management, or
ethical problems that cannot be remedied through the PHARS protocol are in substantial default
of their contract with HUD. When a PHA is found in substantial default, HUD temporarily takes
possession of the PHA to correct identified problems through a process known as administrative
receivership. 3 HUD views administrative receivership as a last resort for assisting PHAs with the
most severe problems. In extreme cases, HUD may also suspend or debar PHA officials as an
administrative remedy to address longstanding performance issues at the PHA. PIH’s Office of

1
  During fieldwork, a HUD official told us that the procedures had changed and HUD may now initiate this process
for substandard performer PHAs as well.
2
  24 CFR (Code of Federal Regulations) 907.5(d)
3
  Administrative receiverships may include PHAs under settlement agreements, PHAs under cooperative endeavor
agreements, possession and control of PHA projects, and HUD “Secretary in possession” of PHAs.

                                                       3
Receivership Oversight is responsible for providing day-to-day oversight and direction for
receiverships. If the PHA’s improvement is sustained, the PHA may be returned to local control,
and PIH’s local field office resumes oversight and monitoring of the PHA. Otherwise, HUD
maintains control of the PHA through the receivership process.

Scope and Methodology
We completed this evaluation under the authority of the Inspector General Act of 1978 as
amended and in accordance with the Quality Standards for Inspection and Evaluation, issued by
the Council of the Inspectors General on Integrity and Efficiency (January 2012).

Scope

We performed fieldwork for this evaluation between August and December 2017. This
evaluation covered operations within six HUD programs offices – PIH, DEC, the Office of Fair
Housing and Equal Opportunity (FHEO), FPM, the Office of General Counsel (OGC), and the
Office of Davis-Bacon and Labor Standards (Labor Standards). We assessed HUD’s oversight
of ACHA since 2010 to determine what HUD knew about ACHA, when it knew those facts, and
what steps it took to correct identified deficiencies. We did not assess ACHA, except as it
related to interactions with the above-named HUD program offices. We did not include in our
scope a comparison of ACHA to other PHAs and their receiverships.

Methodology

To address our objective, we conducted 24 interviews with current and former HUD officials
identified in our scope. Through these interviews and other documentation collected during our
evaluation, we learned what actions HUD took in an attempt to identify and address deficiencies
at ACHA. We also identified the roles and responsibilities of personnel involved in the
monitoring and oversight of ACHA. We reviewed relevant statutes, regulations, and other
documentation to determine criteria for the monitoring and oversight of PHAs.

Limitations

On November 22, 2017, we sent HUD a request for several HUD officials’ emails to determine
what they knew and communicated about ACHA at the time the issues occurred. HUD produced
the requested emails and provided them to us in June 2018. 4 We received nearly 50 gigabytes of
email data, which we will review following the release of this report. If our findings or
recommendations are substantially affected by new information, we will communicate that
information in an appropriate format.




4
 In December 2017, we issued a report finding that OGC’s collection of electronically stored information, including
emails, does not meet customer demand because processing these requests takes too long to meet each program
office’s needs.

                                                        4
A Primer: HUD’s Oversight of ACHA
On February 19, 2016, HUD declared ACHA in substantial default of its contract with HUD,
removed its board, and took possession of it. In April 2017, HUD announced its plan to relocate
about 400 residents, including 200 children, from two ACHA housing developments, Elmwood
and McBride. 5 Those developments will be demolished. According to news reports, residents
remain angry and frustrated with HUD’s decision. The city of Cairo has insufficient housing
stock for these displaced families, so almost 200 families will have to move out of the city. A
HUD spokesperson said that HUD was “stunned … at what we saw, not just in terms of the
deplorable living conditions that we encountered but at the poor, even absent record keeping, the
staggering backlog of critical repairs, all of this going to the very health and safety of the
residents living there.” However, the deplorable conditions at ACHA did not occur overnight.
HUD had been aware of negative conditions at ACHA since at least 2010. Over the span of 6
years, HUD performed multiple assessments and reviews of ACHA. Figure 1 below outlines the
steps HUD had taken since 2010 in an attempt to address the negative conditions.

                          Figure 1 – Timeline of HUD’s oversight of ACHA

         2010                 2013              2014                2015                2016              2017

• PIH conducted       • Due to the        • HUD conducted   • FHEO issued a • HUD took the        • HUD began the
  an onsite review      Authority's FY* a cross-              voluntary          Authority into     process of
  of the Authority,     2012                programmatic      compliance         receivership.      relocating
  which produced        substandard         review, which     agreement to the                      residents from
  negative              physical            produced          Authority to                          two Authority
  findings.             conditions score, negative            address its civil                     housing
                        PIH conducted       findings.         rights violations.                    developments
                        an onsite review                                                            scheduled for
                        of the Authority,                                                           demolition.
                        which produced                                                            • HUD debarred
                        negative                                                                    some Authority
                        findings.                                                                   executives.
* FY = fiscal year

HUD had failed ACHA in every physical condition indicator since fiscal year (FY) 2012 and
identified weaknesses with its financial condition as early as FY 2013. ACHA was generally
uncooperative in addressing the negative conditions identified by HUD’s assessments and
reviews. Despite HUD’s attempts to bring ACHA into compliance, the negative conditions
remained. In June 2017, DEC and OGC issued an indefinite debarment from participating in
government programs for two former ACHA executives and a 3-year debarment for a board
member. This action resulted from many violations of HUD regulations and the contract, such
as deplorable physical conditions, severe misuse of Federal funds, civil rights violations, lead-
based paint violations, and other issues.



5
 Since we concluded our fieldwork, HUD decided that two additional ACHA housing developments (Sunset
Terrace and Mary Alice Meadows in Thebes, IL) will also be closed as necessary repairs there are too expensive for
ACHA to cover. Some of the residents relocated from the Elmwood and McBride developments ended up at the
Thebes developments, so they will have to relocate again.

                                                            5
Findings
PIH Used Several Oversight Tools To Identify Issues at ACHA, but
Negative Conditions Persisted
Since 2010, HUD 6 had performed multiple assessments and reviews of ACHA, which
highlighted issues with its governance, including the misuse of funds, conflicts of interest, and a
failure to comply with HUD policies and Federal civil rights laws. Despite HUD’s attempts to
bring ACHA into compliance, the negative conditions remained. ACHA was generally
uncooperative in addressing the negative conditions HUD identified during its assessments and
reviews. On February 19, 2016, HUD removed ACHA’s board and took possession of ACHA,
declaring it in substantial default of its contract with HUD.

PIH Identified Issues at ACHA During a Review in 2010, but Closed the Findings

In keeping with routine oversight practices, the Chicago field office assigned a team to monitor
and oversee ACHA. This team was assigned to ensure that ACHA complied with HUD rules
and regulations and to provide technical assistance to ACHA as needed. The team was
composed of an engineer, a financial analyst, and a public housing revitalization specialist. In
March 2010, this team completed a review of ACHA, which identified improper payments and
other high-risk elements. 7 During this review, the team conducted tenant file reviews to
determine whether ACHA calculated rents accurately and reviewed its compliance with HUD
policies.

The team made nine findings and four observations, one of which indicated that there was a
conflict of interest among the board of commissioners, the president of the resident council, and
ACHA. PIH records and the team leader of the review confirmed that the field office closed the
findings.

The Field Office Conducted Onsite and Remote Assessments of ACHA in 2012 and 2013,
but ACHA Did Not Correct Identified Negative Conditions

For FY 2012, REAC scored ACHA as a substandard physical performer due to the poor physical
conditions of its buildings. A team member assigned to ACHA told us that the substandard score
required the field office to conduct an onsite review. Before the onsite review, this team member
performed a remote assessment of ACHA. He said that during the remote assessment, he
identified several issues unrelated to ACHA’s physical conditions score, such as inappropriate
procurement practices and nepotism, stating that ACHA’s organization chart looked like a
“family tree.” After completing the remote assessment, he issued a letter to ACHA, stating his
findings, and asked for a response and for ACHA’s plans to address the findings before the
upcoming onsite review. In response, ACHA provided an action plan, which the team member
believed did not sufficiently address the concerns in the findings letter. Accordingly, this

6
  When “HUD” is used, officials or actions from more than one program office are being cited. When PIH is used,
we are referring only to PIH officials or actions.
7
  HUD completed a Consolidated Tier II review. Consolidated Tier I or Tier II reviews were a type of onsite review
of PHAs, which PIH no longer performs.

                                                        6
response required the field office to continue its onsite review of ACHA. In May 2013, the
National Association for the Advancement of Colored People also sent HUD a letter alleging
discriminatory conditions at ACHA, which reinforced the need for the onsite review.

The field office conducted the onsite review of ACHA from September 4 through 13, 2013. A
team member who participated in the review told us that ACHA personnel were very
uncooperative during the visit. For example, one team member told us that several members of
the ACHA staff attempted a “sick-out” to avoid being interviewed. Team members also
observed serious civil rights violations during the review, such as segregated housing and
segregated staffing. One team member said the team conducted physical inspections of all of the
ACHA housing developments, during which it reviewed the building interiors and exteriors and
inspected a sample of units. He said, in total, these physical inspections took about a half day.
This team member also said that the poor physical condition of the properties was obvious, even
from the outside. However, when the team members went inside the properties, one team
member said that he observed broken and outdated appliances and pest infestations in housing
developments occupied by African-Americans.

On November 1, 2013, following the onsite review, the field office issued a letter to ACHA,
which detailed concerns related to its finances, operations, and procurement practices. In total,
the field office made 9 findings related to the physical condition of ACHA’s properties and 20
findings related to its overall management. Major findings included that

   •   The McBride and Elmwood housing developments had ongoing security issues.
   •   The plumbing at the McBride housing development was deteriorated and in need of
       rehabilitation.
   •   The former executive director improperly procured a consultant services contract for
       himself.
   •   ACHA awarded retirement packages and offered part-time employment to specific
       employees with no documented or defined formula or eligibility requirements.
   •   ACHA’s nepotism policy was inadequate.
   •   An ACHA board member had a nephew and grandson employed by the PHA.
   •   The executive director’s son-in-law and the assistant executive director’s husband were
       maintenance workers at ACHA.

In December 2013, ACHA provided an action plan to address the issues identified during the
onsite review, in which it generally disagreed with the field office’s findings and observations.
Field office staff members told us and documentation confirms that they found ACHA’s
response insufficient. Field office staff members also told us that they informed regional PIH
leadership about issues pertaining to ACHA. Around this time, the field office staff also
approached HUD’s Region V Administrator. The Administrator is responsible for engaging with
local officials and acting as a liaison for HUD field offices and programs. As such, he was
positioned to engage with ACHA and Cairo, IL, officials.




                                                 7
REAC Routinely Inspected ACHA, but Physical Inspection Scores Did Not Always
Accurately Reflect ACHA’s Conditions

As discussed earlier, REAC scored ACHA as a substandard physical performer for FY 2012 due
to the physical conditions of the Elmwood and McBride housing developments. 8 The FY 2012
inspection report continuously indicated the presence of peeling paint; graffiti; deteriorated caulk
and sealants; and the presence of insects, such as bed bug and live roach infestations, among
other issues. It also noted health and safety hazards, such as inoperable electrical breakers and
appliances and obstructed accessibility routes.

Despite these findings, in FY 2013, ACHA’s REAC scores indicated that the physical conditions
had improved dramatically. Field office staff members were concerned that the FY 2013
physical condition scores did not reflect the actual conditions at ACHA. One remarked that he
was shocked by the inflated score. At this time, ACHA’s budget showed that only two major
capital improvements had been undertaken. PIH’s practice was to wait to initiate the PHARS
protocol until it had designated a PHA as troubled. Without a score low enough to consider
ACHA troubled, PIH was unable to initiate the PHARS protocol, which aims to recover PHAs
by solving and remediating systemic issues. 9 As a result, in April 2014, field office staff
requested that REAC rescore the housing developments off cycle and immediately release the
scores. The field office staff continued to request updates on the status of the rescore request,
and in August 2014, REAC confirmed that ACHA would be reinspected.

REAC began the FY 2013 rescore for the housing developments in November 2014 and
completed it by February 2015. According to a REAC official, a number of factors can delay
REAC inspections of PHAs and 95 to 99 percent of the time those delays are related to procuring
contract inspectors to perform the inspections. Further, documents showed that holidays and
HUD staffs’ use of “use or lose leave” contributed to delays as well.

REAC’s revised scores showed that conditions had deteriorated since FY 2012 and not improved
as the original FY 2013 score indicated. For two housing developments, the score was lowered
by more than 50 points. The score for the Elmwood and McBride housing developments, which
are now scheduled for demolition, were lowered by 54 points. Figure 2 below provides the
physical conditions scores in FYs 2012 and 2013 and the rescores for FY 2013.




8
  ACHA has several housing developments that receive individual physical conditions scores during the inspection
process.
9
  During the interim period, PIH field offices also have the ability to implement a zero threshold review of capital
fund grants. However, this is not a sanction. This action requires PIH field office staff to review and approve all
draws a PHA wants to make from its Capital Fund.

                                                          8
     Figure 2 – ACHA housing developments’ physical conditions scores from FY
                                   2012 to 2013
Development                 FY 2012 physical           FY 2013 original physical             FY 2013 physical
name                        conditions score               conditions score                 conditions rescore
Elmwood and
                                     42                              82                                28
McBride
Scattered sites                      76                              73                                71
Connell F. Smith
                                     74                              92                                34
Building

The revised FY 2013 inspection report for the Elmwood and McBride housing developments
showed that there were 112 health and safety deficiencies and concluded that if all buildings and
units were inspected, 1,134 health and safety deficiencies would be found. 10 REAC decertified
and dismissed the contract inspectors who performed the initial FY 2013 inspections for not
following REAC’s inspection protocol. 11,12

Only After HUD Assembled a Cross-Programmatic Team Did It Take
Major Enforcement Action Against ACHA
After PIH field office staff approached him with concerns about ACHA, the Region V
Administrator assembled a cross-programmatic review team in early 2014 to review ACHA.
The Administrator, who is part of FPM, served as the lead on this team. The team consisted of
Region V staff from the following HUD program offices: PIH, FHEO, DEC, and Labor
Standards. Each participating program office focused on its respective programmatic
jurisdiction.

HUD Conducted a Cross-Programmatic Review of ACHA in 2014, Which Resulted in
Negative Findings Against ACHA

Several cross-programmatic review team members stated that this type of review was uncommon
and that they had not seen so many program offices work collectively to review a single PHA.
The onsite portion of the cross-programmatic review occurred from June 24 through 26, 2014.
Participating team members reviewed ACHA documents, conducted interviews, and inspected
low-rent housing properties. Unlike its response to PIH’s 2013 reviews, HUD staff told us that
ACHA was relatively cooperative as the team carried out its cross-programmatic review.



10
   The inspections examine a sample of units at a given PHA and not every unit.
11
   This protocol refers to the standard set of rules and procedures for inspectors to follow on all inspections. The
purpose of the physical inspection process is to provide HUD with the ability to assess whether its properties are in a
safe, decent, and sanitary condition and in good repair.
12
   In response to a congressional mandate, REAC released a report, entitled “Efforts and Progress Made to Improve
Inspection Processes and Protocols,” on February 23, 2018. Within the report, REAC stated that its physical
inspection process has declined over time due to a number of reasons, including competing demands of Federal
inspection staff, a shifting quality environment, and external pressures. However, most notably, REAC stated that it
also faced challenges in acquiring contract inspectors that met HUD’s quality inspection standards in the
performance of duties. To address issues highlighted in the report, REAC stated that, as of June 2017, it had
identified and implemented 86 process improvements in an effort to enhance its inspection process.


                                                          9
PIH, DEC, and Labor Standards made several significant findings on ACHA’s noncompliance
with several HUD rules and regulations, which included mismanagement of ACHA, misuse of
Federal funds, misadministration of contracts subject to Davis-Bacon and related acts, and
governance issues. In July 2014, ahead of releasing its official findings, PIH field office staff
issued a memorandum to ACHA which placed its Capital Fund under zero threshold review,
which required PIH field office staff to review and approve all draws ACHA wanted to make
from its Capital Fund. In November 2014, PIH issued a memorandum to ACHA, which
documented its official cross-programmatic review findings of ACHA noncompliance with
several Federal, State housing, and labor laws.

During this review, DEC also identified an issue that inappropriately benefited ACHA’s
financial condition score used for PHAS. DEC found a significant deficiency in ACHA’s
internal control over financial reporting and compliance when it borrowed funds in a manner not
permissible under the HUD Financial Management Handbook or Office of Management and
Budget Circular A-133. ACHA borrowed more than $400,000 from the Elmwood and McBride
operating fund to cover the central office cost center’s deficit, which resulted from the cost
center’s failure to charge fees to any of ACHA’s three housing developments. ACHA’s method
for recording the transaction made the financial condition appear better than it was and, hence,
inappropriately benefited its financial condition score. A DEC official stated that had ACHA
recorded the transaction properly, the PHAS financial condition score would have declined from
“satisfactory” to “unsatisfactory.” As a result of this issue, the original financial condition score
was reduced from 18 to 10. This score revision and the revised physical conditions scores
(released in 2015) resulted in HUD’s changing ACHA’s overall performance designation for FY
2013 to troubled.

However, FHEO made the most significant findings of the cross-programmatic review. FHEO
issued its findings to ACHA in a separate memorandum, dated September 30, 2014. FHEO
found that ACHA violated rules under Title VI of the Civil Rights Act 13 for its racial segregation
of public housing and employment discrimination on the basis of race. Additionally, FHEO
found that the Elmwood and McBride housing developments, where heads of household were
96.8 percent African-American, were older and more poorly maintained than other ACHA
housing developments. Figure 3 below provides a summary of FHEO findings of racially
segregated housing in the housing developments at ACHA.

 Figure 3 – FHEO findings of racially segregated housing developments at ACHA

                                                                  Percentage of units occupied by
     Development name(s)           Number of units
                                                               African-American heads of household
     Elmwood and McBride                   247                                     96.8%
     Connell F. Smith
     Building and scattered                188                                     57.4%
     sites

In its findings, FHEO also noted that ACHA had a documented history of discriminating against
African-American employees. FHEO found that the highest paid ACHA maintenance

13
  Title VI of the Civil Rights Act states, “No person in the United States shall, on the ground of race, color or
national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under
any program or activity receiving Federal financial assistance” (42 U.S.C. (United States Code) 2000d).

                                                          10
technicians were what FHEO referred to as white employees and that those employees’ seniority
had no direct correlation to their pay rates compared to their African-American peers. For
example, ACHA contracted two white retirees for part-time work at a pay rate of more than $20
per hour, whereas a part-time African-American retiree, not under contract, received a pay rate
of just under $16 per hour for the same position. In another example, ACHA employed four full-
time maintenance employees in September 2013. Two were white and two were African-
American. The white employees had 8 and 4 years of job experience, respectively, and earned
an equal or higher rate of pay compared to the two African-American employees who had 28 and
4 years of job experience, respectively. FHEO also found that African-Americans typically
serviced the Elmwood and McBride housing developments (identified as racially segregated)
instead of other ACHA housing developments.

FHEO and other HUD officials said that PIH senior officials were reluctant to move quickly
against ACHA on the cross-programmatic findings. 14 Some officials attributed this delay to
different causes, such as the disagreement over programmatic jurisdiction (FHEO’s versus
PIH’s). When asked about their reaction to the cross-programmatic review, some PIH senior
officials, including the PIH Region V Director at the time, said that they were unaware of it or its
findings. However, field office staff and the Region V Administrator claimed that they met with
the PIH Region V Director and discussed this topic in August 2014.

Following the Cross-Programmatic Review Findings, FHEO Entered Into an Agreement
With ACHA, Which ACHA Violated

FHEO officials said that FHEO’s authorities enable it to act more quickly than other HUD
program offices. Therefore, FHEO could act as the “tip of the spear” to get ACHA to comply
with public housing rules and regulations. Once FHEO makes a finding of noncompliance at a
PHA, the PHA is required to review the finding within a 30-day window and enter into a
voluntary compliance agreement to remedy the identified negative conditions. Additionally,
FHEO officials said that PIH generally requires a much more lengthy remedial process for PHAs
and that PIH’s remedial process, the PHARS protocol, could take up to 1 year or more.

ACHA entered into the agreement with HUD in August 2015. It required ACHA to comply with
provisions related fair housing, security of housing, and equal employment opportunity. For
example, to ensure fair hiring practices, the agreement required ACHA to obtain prior HUD
review and approval before hiring a new executive director. Among other things, it also required
that ACHA develop a public housing waiting list to provide residents in the Elmwood and
McBride housing developments the opportunity to relocate to a more racially integrated housing
development.

FHEO officials said that ACHA officials violated the agreement and the violations were
deliberate and serious. For example, ACHA unilaterally hired a new executive director, and
FHEO officials considered this violation to also be a breach of its contract with HUD. FHEO
and PIH officials disagreed about the extent to which this provision of the agreement was
permissible and enforceable. In January 2016, the Region V Director of FHEO issued a
memorandum to the PIH field office director formally challenging ACHA’s compliance with the
14
  The term PIH “senior officials” refers to PIH staff at the regional public housing director level and above. We
choose to refer to this group as “PIH senior officials” because of the many staffing changes that occurred within PIH
from 2010 to the present, with some individuals occupying more than one senior position at different times.

                                                        11
contract. FHEO officials said that this memorandum forced PIH to take action on ACHA. The
violation of the agreement became the basis for finding ACHA in substantial default of its
contract with HUD. On February 19, 2016, HUD removed ACHA’s board and took possession
of ACHA, declaring it in substantial default of the contract.

Despite ACHA’s limited cooperation in addressing PIH-identified deficiencies over time, PIH
did not feel that it could take more aggressive action against ACHA. Without a score low
enough to consider ACHA troubled, PIH was unable to initiate the PHARS protocol, which aims
to recover PHAs by solving and remediating systemic issues. However, the cross-programmatic
approach, led by FPM, empowered HUD to use alternative means of enforcement against
ACHA. Specifically, FHEO’s involvement enabled HUD to leverage different authorities that
would have required ACHA to remedy issues more quickly. When ACHA did not remedy the
deficiencies within this period, HUD was empowered to take swifter action against it. Without
FHEO’s involvement, negative conditions at ACHA may have persisted longer before HUD took
it into receivership. Involving several parts of HUD, such as FHEO or DEC, may improve PIH’s
oversight of uncooperative PHAs like ACHA.

HUD Hesitated To Exercise Its Authority To Take ACHA Into
Receivership
HUD temporarily takes possession of a PHA to correct identified problems through a process
known as administrative receivership. HUD views administrative receivership as a last resort for
assisting PHAs with the most severe problems. Residents at ACHA continued living in
deplorable conditions as ACHA languished, and HUD hesitated to take ACHA into receivership.
Despite negative conditions at ACHA, HUD did not take it into receivership earlier for several
reasons; namely,

   •   PIH officials initially allowed ACHA several opportunities to improve instead of using
       HUD’s authority to declare it in substantial default and take possession of it. In our
       discussions with PIH officials, they did not seem to be aware of HUD’s authority to take
       possession of ACHA without first offering it an opportunity to cure deficiencies.
   •   ACHA’s official performance scores were not initially low enough to initiate the PHARS
       protocol.
   •   PIH officials disagreed about the extent to which ACHA’s actions and existing
       documentation were sufficient to place it into receivership.
   •   HUD officials claimed that receiverships were costly to administer and could attract
       negative attention to the agency.
   •   HUD guidance and expertise on receiverships were limited at the time.

PIH Officials May Not Have Been Aware of HUD’s Authority To Declare PHAs in
Substantial Default

HUD has the authority to declare a PHA in substantial default of its contract with HUD in
emergency situations. In these cases, HUD is not required to provide the PHA with an
opportunity to respond to or cure negative conditions when (1) HUD determines that conditions
exist that pose an imminent threat to the life, health, or safety of public housing residents or
residents of the surrounding neighborhood or (2) the events or conditions precipitating the

                                               12
default are determined to be the result of criminal or fraudulent activity. 15 Although this
authority allows PIH to declare a PHA in default of its contract before the maximum 2-year cure
period ends, PIH headquarters and field officials emphasized during interviews the necessity to
use the PHARS protocol and allow PHAs the full 2 years to cure negative conditions. The living
conditions at ACHA posed an immediate threat to its residents and we believe PIH should have
exercised this authority sooner. We are concerned that the PIH officials we spoke with may not
have been aware of HUD’s authority to declare substantial default and take PHAs into
possession in emergency situations. If PIH officials are not aware of this authority or prepared to
use it, uncooperative PHAs with similar issues may languish without adequate corrective action
at the expense of housing development residents, as ACHA did.

ACHA’s Official Performance Scores Were Not Initially Low Enough To Trigger the
PHARS Protocol

As discussed earlier, HUD designates PHAs as high, standard, substandard, or troubled
performers based on their performance. Once a PHA is designated as troubled, HUD initiates
the PHARS protocol. A troubled PHA is given a maximum of 2 years to cure negative
conditions. 16 If the PHA cannot cure its issues within 2 years, this condition should trigger a
referral for administrative receivership. 17 However, PIH has not enforced this referral procedure
uniformly. Given this lack of uniformity, the Office of Receivership Oversight has begun
developing protocols and a standardized process for assessing PHAs that have not met their 1- or
2-year recovery goals and for making referrals. At the conclusion of our fieldwork, this process
had not been completed or implemented.

ACHA’s performance scores were not initially low enough to trigger the PHARS protocol,
which is a process of enhanced oversight meant to help a PHA solve and remediate systemic
issues or later receivership action. Until FY 2013, ACHA scored substandard or better on all of
its PHAS assessments. As discussed earlier, REAC did not revise ACHA’s FY 2013 physical
conditions score or its financial conditions score until much later, which resulted in HUD’s
changing ACHA’s overall performance designation to troubled for FY 2013. PIH’s practice was
to wait to initiate the PHARS protocol until it designated a PHA as troubled. One HUD official
told us that at the time, there was no formal remedial process for substandard PHAs (such as
ACHA) as there was for troubled ones. A PIH employee told us that he suggested placing
ACHA into the PHARS protocol in 2013, although it was not yet officially designated troubled,
but that management opposed this approach. A PIH senior official said that if a substandard
PHA remained uncooperative about addressing identified issues, it would continue to decline
until it reached troubled status. Conditions at ACHA continued to decline this way over time.
Figure 4 below lists ACHA’s performance scores from FY 2010 to 2016.




15
   24 CFR 907.5(d)
16
   During this period, the PHA has 1 year to raise its PHAS score to at least 50 percent of the difference between its
poor PHAS score and the current score and a maximum of 2 years to raise it to at least 60 percent overall. HUD
takes incremental steps to work with the PHA to cure the conditions during that 2-year period.
17
   However, the recovery process is not limited to administrative receivership. There are two basic types of
receiverships: administrative and judicial. Judicial receiverships are established, monitored, and supervised by
Federal courts.

                                                          13
            Figure 4 – ACHA’s overall PHAS scores from FY 2010 to 2016

                   FY                       Total score                  Designation status
                  2010                        No score                      No score released
                  2011                           78                             Standard
                  2012                           67                       Substandard physical
                 2013*                           52                             Troubled
                  2014                           52                             Troubled
                  2015                           29                             Troubled
                  2016                           27                             Troubled
        *Indicates the revised FY 2013 scores that REAC released in February 2015

PIH Officials Disagreed About the Extent to Which ACHA’s Actions and Existing
Documentation Were Sufficient To Place It Into Receivership

HUD officials told us that there was a major emphasis on developing an action plan and
continuing to work with ACHA officials to remedy the negative conditions there. Records
showed that field office staff began working to develop an action plan as early as October 2013.
ACHA submitted its action plan to PIH in December 2013. The action plan refuted PIH’s results
and determinations and stated that ACHA personnel were not willing to cooperate to remedy the
negative conditions PIH had identified. Several field office staff members also told us that
ACHA personnel were uncooperative. However, we were told that PIH senior officials
encouraged the field office to continue to work with ACHA officials to remedy the conditions at
the local level despite their lack of cooperation.

Once HUD has decided to take a PHA into receivership, HUD gathers substantial documentation
to show the necessity for the receivership. PIH senior officials were generally unsatisfied with
the existing administrative record and encouraged field office staff to document the negative
conditions at ACHA. PIH senior officials also told us that there was a major emphasis on
gathering documentation to substantiate the need for taking the PHA into receivership, which
resulted in delays. We heard that this documentation was critical for establishing a clear
administrative record of the negative conditions. This record could be necessary if ACHA
attempted to challenge a receivership decision in court.

Personnel disagreed about the extent to which the existing action plan and corresponding
documentation were sufficient to warrant receivership. Field office staff members told us that
they requested that PIH senior officials take action against ACHA and they were frustrated with
senior leadership’s inaction. They argued that such action would help ensure that the decision to
take ACHA into receivership was sound and defensible if ACHA appealed. PIH senior officials
consulted OGC staff about the sufficiency of the administrative record. According to OGC staff,
consultations began on February 4, 2016, approximately 2 weeks before HUD issued the
substantial default letter to take ACHA into receivership.




                                                      14
HUD Officials Claimed That Receiverships Were Costly To Administer and Could Attract
Negative Attention

During interviews, HUD officials told us that taking a PHA into receivership was very costly, so
HUD was not inclined to initiate receiverships. PIH’s Deputy to the Deputy Assistant Secretary
for the Office of Field Operations stated that a receivership can take many years to execute,
require the labor of four to five full-time employees, and cost more than $5 million. Other HUD
officials said that there were concerns about not having the necessary funding for executing a
receivership of ACHA. Field office staff told us that the Region V Director commented in 2014
that there were no funds available to take ACHA into possession.

HUD officials added that the agency must consider the political repercussions from taking a
PHA into receivership. These concerns contributed to HUD’s hesitation to take ACHA into
receivership.

HUD Guidance and Expertise on Receivership, Due in Part to a Lack of Training, Were
Initially Limited and Could Still Be Improved

HUD officials told us that an administrative record to justify receivership must include an onsite
review of a PHA, its results, and follow-up activity with the PHA. One of the officials told us
that it takes years to build such a record. However, that official also said that the receivership
process “isn’t too mapped out,” and another told us that he was unsure of what precisely triggers
a receivership.

From 1985 to 2015, HUD initiated administrative receiverships of 20 PHAs without a
receivership manual. 18 At the time HUD took ACHA into receivership in 2016, HUD was in the
process of creating such a manual. As a result, there was no systematic process for executing
receiverships when HUD initiated the receivership of ACHA or the 20 other PHAs taken into
administrative receivership before that.

HUD developed a PowerPoint training presentation for receivers in March 2013. However, two
PIH staff members who served as receivers, including the one assigned to ACHA, told us that
they did not attend formal training on receivership. One of the receivers told us that he relied on
his institutional knowledge from previously working at PHAs. Multiple officials told us that a
limited number of HUD staff members had the expertise to fulfill this role.

HUD did not publish its Internal Procedures Manual for HUD Receiverships until April 2017,
approximately 14 months after HUD took ACHA into receivership. HUD has also not updated
its PowerPoint training for receivers to align with the Internal Procedures Manual released in
2017. Although the Internal Procedures Manual for HUD Receiverships outlines post
receivership actions HUD officials should take when executing an administrative receivership, it
does not provide guidance to HUD officials or circumstances in which initiating a receivership
may be appropriate.

The small pool of experienced receivers, inadequate guidance, and outdated training pose

18
  HUD has taken the Lafayette Housing Authority in Layfette, LA, into administrative receivership twice since
1995.

                                                       15
organizational risks that could negatively affect HUD’s oversight of PHAs over time. Without
these elements, HUD may avoid taking PHAs into receivership when it is necessary and may
oversee PHAs in receivership improperly or inadequately.




                                             16
Recommendations
Conditions at ACHA had deteriorated over a decade or more, and two housing developments
there, Elmwood and McBride, are scheduled for demolition. Since we concluded our fieldwork,
HUD decided that two additional ACHA housing developments (Sunset Terrace and Mary Alice
Meadows in Thebes, IL) will also be closed as necessary repairs there are too expensive, 19 further
reducing available, affordable housing stock for low-income residents. While local officials are
responsible for the daily administration of ACHA, HUD could and should have done more to
oversee it. Although it may be too late to save ACHA, as of June 2018, 50 other PHAs were
designated as troubled. Therefore, we recommend that the General Deputy Assistant Secretary
of Public and Indian Housing:

1. Create Agreements and Strategies With Other Program Offices
   That Describe When Cross-Programmatic Reviews and
   Enforcement Actions Against PHAs Are Required
Considering ACHA’s limited cooperation in addressing PIH-identified deficiencies over time,
we are concerned that the PHARS protocol does not enable PIH to address issues at
uncooperative PHAs in a timely manner. Although PIH has strategies to engage some HUD
offices, such as DEC, when it encounters serious performance issues at PHAs, the cross-
programmatic approach led by FPM empowered HUD to use alternative means of enforcement
against ACHA. Specifically, FHEO’s involvement enabled HUD to leverage different
authorities that required ACHA to remedy issues more quickly. Involving several parts of HUD,
such as FHEO or Labor Standards, may improve PIH’s oversight of uncooperative PHAs like
ACHA so that conditions can be improved more quickly.

2. Train PIH Officials on the Authority and Processes for Declaring
   PHAs in Substantial Default and for Taking PHAs Into HUD
   Possession
The living conditions at ACHA posed an immediate threat to its residents, and we believe PIH
should have exercised its authority to declare it in substantial default sooner. PIH headquarters
and field officials emphasized during interviews the necessity to use the PHARS protocol and
allow troubled PHAs the full 2 years to cure negative conditions. This interpretation of HUD’s
authority and process may enable uncooperative PHAs like ACHA to languish at the expense of
housing development residents. PIH should train its officials at all levels to identify when a cure
period is not appropriate. This includes emergency situations in which conditions exist that pose
an imminent threat to the life, health, or safety of public housing residents or residents of the
surrounding neighborhood. PIH should also train PIH officials at all levels about the process for
expediently exercising the authority to declare a substantial default without a cure period.




19
  The housing developments will be removed from public housing inventory. However, HUD has not decided how
the housing developments will be removed. They will be either demolished or sold.

                                                   17
3. Update and Strengthen the Training Program for HUD Receivers of
   PHAs
PIH’s expertise on receiverships was limited at the time of ACHA’s receivership and could still
be improved. PIH should update its training for receivers to align with the Internal Procedures
Manual released in 2017.

4. Update Procedures for Receiverships To Include Specific Guidance
   on When Initiating a Receivership May Be Appropriate
While PIH has released its Internal Procedures Manual for HUD Receiverships, guidance and
policy on when initiating receivership may be appropriate are not included. The limited HUD
guidance and expertise on receiverships present organizational risks that could negatively affect
HUD’s oversight of PHAs over time.




                                               18
Agency Comments and OIG Response
Summary of PIH’s Comments
PIH agreed with each of our four recommendations. However, PIH stated that although it agreed
in concept with recommendation 1 and that requiring cross-programmatic reviews was
inappropriate, it requested that the recommendation be reworded. In its comments, PIH stated
that PHAs face “varying circumstances and challenges,” which requires PIH to have flexibility in
addressing issues at PHAs. PIH further stated that agreements and strategies should outline
when cross-programmatic reviews are appropriate. For recommendations 2, 3, and 4, PIH stated
that it would address the recommendations when it submitted its proposed management decision
for each recommendation within 120 days of final report issuance.

OIG Response to PIH’s Comments
Based on PIH’s response, we consider recommendations 1, 2, 3, and 4 “unresolved-open.” With
regard to recommendation 1 and PIH’s request to reword the recommendation, we agree that
cross-programmatic reviews and enforcement actions may not be required in every instance.
Therefore, we changed the language to make it clear that the agreements and strategies with
other program offices should describe when cross-programmatic reviews and enforcement
actions are required. We will reevaluate the status of recommendations 2, 3, and 4 upon receipt
of documentation detailing PIH’s proposed management decision, along with target dates for
completing corrective actions to address our recommendations.




                                              19
PIH Comments to the Draft Report




                               20
21
Appendixes
Appendix A – Acknowledgements
This report was prepared under the direction of Brian T. Pattison, Assistant Inspector General for
Evaluation, Paul H. Bergstrand, Director of the Program Evaluations Division, and Lindsay K.
Clarke Brubaker, Supervisory Evaluator. The Office of Evaluation staff members who
contributed are recognized below.

Major Contributors

Josh Rowell, Senior Evaluator (team lead)
Christa Kidd, Senior Evaluator
Sonia Pena, Senior Forensic Auditor

Other Contributors

Angelina Johnston, Senior Evaluator




                                               22
Appendix B – Acronyms
           ACRONYM                           DEFINITION
             ACHA        Alexander County Housing Authority
             DEC         Departmental Enforcement Center
             FHEO        Office of Fair Housing and Equal Opportunity
             FPM         Office of Field Policy and Management
              FY         fiscal year
             HUD         U.S. Department of Housing and Urban Development
             OGC         Office of General Counsel
             PHA         public housing agency
            PHARS        PHA Recovery and Sustainability
             PHAS        Public Housing Assessment System
             PIH         Office of Public and Indian Housing
             REAC        Real Estate Assessment Center




                        23
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  agency within the U.S. Department of Housing and Urban Development.
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   Report fraud, waste, and mismanagement in HUD programs and operations by
          Completing this online form: https://www.hudoig.gov/report-fraud
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             Program Evaluations Division