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Event / Action Date:Aug 20, 2026
A federal audit found that the Buffalo Municipal Housing Authority failed to report three confirmed cases involving children with elevated blood lead levels and lacked adequate controls for managing lead-based paint across its public housing portfolio.
The Department of Housing and Urban Development’s Office of Inspector General issued the audit on August 20. HUD OIG reviewed the authority’s compliance with federal requirements for children with elevated blood lead levels and its broader management of lead-based paint hazards.
The audit covered activity from January 2022 through December 2024. Its findings extend beyond the three individual cases, identifying problems with annual visual assessments, tenant disclosures, risk assessments, hazard-reduction records and documentation used to classify housing as lead-free.
HUD’s Lead Safe Housing Rule establishes a series of deadlines when a public housing agency learns that a child under 6 living in covered housing has a confirmed elevated blood lead level.
The housing authority must report the case to the appropriate HUD offices within five business days. An environmental investigation must generally be completed within 15 calendar days of notification, and identified lead-based paint hazards must be addressed within 30 calendar days after the investigation report is received unless the household is relocated.
HUD OIG found that the Buffalo authority did not report three confirmed cases or the results of the associated environmental investigations to HUD.
The audit also found lead-based paint hazards in the units occupied by two of the three affected children. According to OIG, the authority did not adequately address those hazards within the required timeframe.
In one case, OIG said the authority took approximately two years to complete hazard-reduction work despite multiple notices from the local health department. The audit also found insufficient documentation demonstrating that required clearance testing had been completed for work associated with another case.
Because the cases were not reported, HUD could not monitor the authority’s response or determine whether each required step was completed on time.
The responsibilities triggered by an elevated blood lead level can extend beyond the individual apartment.
When hazard-reduction work occurs, residents of other units in the affected building may need to receive information about the activity so they can take appropriate precautions.
HUD OIG found that the authority did not notify residents in other units within the buildings where lead-hazard reduction activities occurred. The report said this prevented those residents from receiving information they could have used to protect themselves and their families.
The auditors also examined 69 units containing lead-based paint. Those units were located across seven Buffalo housing developments.
The results pointed to problems beyond the three confirmed blood-lead cases.
For more than 94 percent of the sampled units, the authority could not support that required visual assessments had been performed consistently. HUD requires visual assessments for deteriorated paint at least every 12 months and when a unit turns over.
OIG also found that nearly 67 percent of the sampled units did not have accurate and complete lead disclosures. That group included the three units associated with the confirmed elevated blood lead cases.
Federal disclosure requirements generally require prospective tenants to receive known information about lead-based paint and related hazards, along with available reports and records.
The audit additionally found that inspection and risk-assessment reports covering the 69 units were missing required information. In some instances, records did not include complete testing results needed to determine which surfaces contained lead-based paint.
The authority classified one housing development as lead-free but could not provide enough historical documentation to support that designation, according to the audit.
HUD OIG recommended that the authority search for the missing records. If adequate documentation cannot be located, OIG said the development should receive a new lead-based paint inspection to establish its status.
The authority also did not complete a required risk assessment for another development containing lead-based paint. A risk assessment is intended to determine whether lead-based paint presents an active hazard and what controls or abatement work may be necessary.
Without complete inspection, assessment and clearance records, OIG said HUD and the authority lacked assurance that the properties’ lead status was accurate or that identified hazards had been properly addressed.
HUD OIG attributed the failures to gaps in the authority’s policies, procedures, internal controls and staff knowledge.
The audit found that the authority did not have adequate procedures for managing confirmed elevated blood lead cases, reporting those cases to HUD, tracking environmental investigations or notifying other residents about hazard-reduction work.
OIG also found inadequate controls for annual visual assessments, tenant disclosures, risk assessments and lead-related recordkeeping.
The authority’s management had not received sufficient training on HUD’s elevated blood lead requirements, according to the report, even though the authority had annually certified that it would comply with the Lead Safe Housing Rule.
In its response, Buffalo Municipal Housing Authority management said it has treated lead-based paint seriously and has implemented proactive measures intended to reduce exposure.
The authority pointed to the absence of lead-related litigation against it during the previous decade. It also explained that it relies on the local public health department to perform blood-lead testing and notify the authority when a child living in one of its properties has an elevated result.
Management acknowledged that hazards were present in two of the three units but said those hazards were not widespread throughout the apartments. It also noted that the audit did not establish that the children’s lead exposure originated inside authority-owned units.
HUD OIG agreed that it could not definitively identify the source of the children’s exposure. However, the auditors said that possibility could not be ruled out and that the uncertainty did not eliminate the authority’s reporting, investigation and hazard-reduction responsibilities.
OIG also said that even a single lead-based paint hazard can create a health risk, particularly for a child under 6.
HUD OIG recommended that HUD’s Buffalo Office of Public Housing require the authority to establish procedures for reporting confirmed cases and environmental investigations, completing hazard-reduction work within required deadlines and notifying affected residents.
Additional recommendations call for the authority to:
Perform clearance testing where remediation documentation is missing.
Verify or reassess the development classified as lead-free.
Complete visual assessments at least every 12 months.
Review existing tenant disclosures and reissue inaccurate or incomplete forms.
Complete the outstanding risk assessment and address hazards it identifies.
Improve the completeness of inspection and risk-assessment reports.
Train staff responsible for elevated blood lead cases and lead-based paint compliance.
HUD OIG also recommended that HUD determine whether existing reports with missing elements are sufficient to support the authority’s current lead classifications.
This audit is specific to Buffalo, but the compliance lesson applies to public housing agencies nationwide.
A lead program cannot be managed through maintenance work orders alone. Each confirmed case creates a documented chain of responsibilities: notification, reporting, investigation, resident communication, hazard reduction, clearance and record retention.
If one part of that chain is missing, the agency may be unable to demonstrate compliance—even if physical work was ultimately performed.
Housing authorities should be able to retrieve a complete file for every affected unit, identify the responsible staff member and show that every required action was completed by its federal deadline.
In lead compliance, the record is part of the protection.
1. Assign responsibility for each confirmed elevated blood lead case, including required HUD reporting, investigation, hazard reduction and resident notices.
2. Review case files for investigation reports, remediation evidence, clearance results and reporting confirmation. Escalate missing steps against the applicable deadlines.
3. Audit annual and turnover visual assessments, tenant disclosures and the records supporting lead status. Provide role specific training and obtain qualified review when inspection or clearance documentation is incomplete.
The audit found failures in reporting, hazard reduction, resident notification and recordkeeping involving housing occupied by children with elevated blood lead levels. Missing procedures and documentation can prevent HUD from monitoring a housing authority’s response and can leave families without timely information about potential hazards. The findings also give other public housing agencies a clear warning to test their own Lead Safe Housing Rule controls before an individual case exposes broader compliance gaps.
Buffalo Municipal Housing Authority residents, particularly families with children under 6; authority leadership and property-management staff; public housing agencies nationwide; HUD field offices; lead inspectors and risk assessors; maintenance contractors; and local public health departments responsible for coordinating elevated blood lead cases.
HUD’s inspector general found that the Buffalo Municipal Housing Authority failed to report three confirmed child blood-lead cases and identified broader problems involving hazard reduction, tenant notification, annual assessments, disclosures and lead-related documentation.
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