Update the EBLL tracker by including which data fields are required, establishing what type of information can be entered into each data field, and disallowing case closure if required information is missing.

PIH in coordination with other HUD offices as necessary, research and address potential causes of the variance in the number of EBLL cases among States on the EBLL tracker and identify solutions that are within HUD's control.

Status

As of July 30, 2025, PIH’s Office of Field Operations (OFO) has coordinated with the Office of Lead Hazard Control and Healthy Homes (OLHCHH) on the EBLL data requested and obtained from PHAs.  OFO’s timeline to finish implementing the recommendation:

• Conduct and complete research and comparison by September 30, 2025.  OFO will need to ensure that any EBLL documentation received from PHAs is accurate and accounted for in its EBLL tracked.
• Complete final review and revisions by October 31, 2025.  OFO will need to contact PHAs for any necessary revisions or missing documentation.
• Stakeholder feedback and incorporation of edits by December 31, 2025.  Stakeholders include OFO leadership and PIH’s Real Estate Assessment Center (REAC).
• Final approvals and sign offs by OFO leadership by March 27, 2026.
• Final reporting and closure documentation by March 31, 2026.  OFO will develop guidance and training materials to ensure that OFO field offices are able to properly communicate EBLL guidance to PHAs.

The estimated completion date is March 31, 2026.  The original estimated completion date was June 30, 2024, and was revised to account for (1) delays in responses from various PHAs in providing current and accurate information on EBLLs to OFO and (2) stakeholder input and review from various offices across HUD.

Analysis

To fully address this recommendation, OFO must provide evidence of completion of each step in its timeline, such as research and comparisons conducted and communications with stakeholders in HUD and with PHAs.

Implementation of this recommendation will help ensure that EBLL cases are reported and recorded appropriately in the EBLL tracker.

Create a plan and timeline that outlines OFO’s proposal to move the LBPR tracker to a different platform.

Develop a timeliness standard in the LBPR tracker to establish expectations for how often field office staff must reach out to PHAs on the LBPR tracker to discuss measures that will resolve cases in a timely manner.

Update HUD regulations, policies, and procedures, following the regulatory process required by the amended LSHR, in consideration of CDC’s lowered BLRV of 3.5 µg/dL.

Status

On January 17, 2025, HUD published a Federal Register notice to modify its EBLL threshold under its Lead Safe Housing Rule from to 5 to 3.5 micrograms of lead per deciliter of blood (µg/dL) for a child under the age of 6, consistent with the Centers for Disease Control and Prevention's current blood lead reference value of 3.5 µg/dL.  

As of July 17, 2025, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) informed HUD OIG that HUD has drafted a joint notice for HUD offices impacted by the modified elevated blood lead level (EBLL) threshold.  These offices include OLHCHH, the Office of Community Planning and Development (CPD), the Office of Multifamily Housing Programs (MF), and the Office of Public and Indian Housing (PIH).

OLHCHH’s timeline to finish implementing the recommendation:

• The notice will enter the clearance process by the end of August.
• CPD, MF, PIH, and OLHCHH will publish the final joint notice by September 30, 2025.

The estimated completion date for these actions is September 30, 2025.  The original estimated completion date was June 30, 2024, and was revised to account for the time required to (1) receive and review public comments on HUD’s proposed change to the EBLL threshold and (2) coordinate the implementation of the EBLL threshold change across the impacted HUD offices.
  

Analysis

To fully address this recommendation, OLHCHH must provide evidence that HUD has updated its regulations, policies, and procedures so that they are consistent with CDC’s lowered BLRV of 3.5 ug/dL.

Implementation of this recommendation will help ensure children living in public housing with EBLLs receive effective environmental interventions.
 

Identify short- and long-term plans for the RPA program that align its capabilities, staffing needs, funding projections, and mission needs.

Implement procedures to capture and monitor centralized logs to maintain appropriate visibility into bot activities and provide for auditability of bot actions.

Implement procedures to periodically review RPA system access and remove access for users that are not authorized or no longer have a need to use the system.

Implement procedures to ensure that attended bots use the security rights and credentials of the attending user.

Implement a quality control review to ensure that successive below-60 REAC inspection score flags are entered into APPS.

Update APPS to automatically flag a property that receives successive below-60 REAC inspection scores.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to clearly communicate that homeowners who had not previously requested forbearance by September 30, 2021, are eligible to request forbearance from their servicer through the end of the COVID-19 National Emergency.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to include information on the various COVID-19 loss mitigation options servicers may offer homeowners with FHA-insured forward mortgages who are exiting COVID-19 forbearance.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to include details about the protections and loss mitigation options available for homeowners with FHA-insured reverse mortgages. This information could include (1) instructions for requesting an extension, (2) a statement notifying homeowners that they should not be charged late fees or penalties, (3) a chart showing the extension periods and related deadlines, and (4) information on the various loss mitigation options available for homeowners with FHA-insured reverse mortgages who are exiting a COVID-19 HECM extension.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to include relevant information on the U.S. Department of the Treasury’s Homeowner Assistance Fund.

We recommend that the Deputy Assistant Secretary for Single Family Housing work with the Office of Public Affairs, Office of Housing Counseling, and other offices within HUD to develop a detailed communication strategy for how and when it plans to use websites, letters, and other methods to proactively notify homeowners about relief programs, protections, and loss mitigation options during disasters and national emergencies. The strategy could include processes to ensure that (1) key information is provided or made available in a timely manner and kept up-to-date, (2) information is communicated clearly and consistently across mediums, and is linked together when possible, and (3) letters are mailed to struggling homeowners when needed. It could also articulate the methods HUD will use to reach homeowners without internet access.

Research, evaluate, and implement technical or alternative solutions to deploy essential computer software updates using appropriate secure methods to ensure that computer security updates occur in a timely manner to minimize risk to HUD’s systems and operations

Research, evaluate, and implement technical solutions to provide additional improvements to VPN and related remote working capabilities of HUD system users.

Perform routine VPN stress tests as part of its contingency planning and testing processes to regularly identify and remediate network performance issues and ensure that network capabilities are sufficient for teleworking.

Research, evaluate, and implement technical solutions to resolve the user account management issues and the underlying issue in the technical environment.