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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

On February 23, 2024, the Office of Field Operations (OFO) provided the following update based on a reported exchange with OLHCHH:

Because health care providers typically test children and adults who are at a high risk for lead exposure, the individuals tested are not representative of the entire U.S. population. Moreover, state requirements for blood lead testing and reporting vary based on local conditions, making these data incomparable across different locations or generalizable at the national, state, or local level. Another significant issue is the use of the term “screening.” Many health care providers do not test the blood unless a verbal screening indicates that a child is at risk. This means that in some areas of the country, blood testing is not performed because parents have not identified conditions that would prompt a physician to test the child through capillary or venous.

Therefore, implementing the recommendation falls outside the purview of OFO and OFO requested closure of this recommendation.


Analysis

We do not agree with the recommendation closure request. On February 23, 2024, we responded to OFO that to close this recommendation, we would need the evidence and information that OIG and OFO had previously agreed upon. We had previously agreed that to close this recommendation, OFO would need to provide evidence of meetings held and summaries of the research it conducted. Our request to OFO was as follows:

For example, what was the exchange with OLHCHH, did OFO coordinate with any other offices, and what research was conducted? The evidence should ensure that our recommendation for finding EBLL Cases Were Primarily Located in Only Two States (see report pages 15-16) is fully addressed. In an August 2022 meeting with us, HUD officials suggested several potential causes for the disproportionate number of EBLL cases on the EBLL tracker. This recommendation asks OFO to research those potential causes (and any other causes identified) for the variances and then determine what HUD could do to address it.

On March 7, 2024, we offered to meet with OFO to discuss the recommendation. On March 8, 2024, OFO responded that it would continue to provide monthly updates on the recommendation. Therefore, we will continue to follow up with OFO monthly on this recommendation.

Publication Report

2021-OE-0011b | February 28, 2023

Improvements are Needed to the U.S. Department of Housing and Urban Development's Processes for Monitoring Elevated Blood Lead Levels and Lead-Based Paint Hazards in Public Housing

According to the Centers for Disease Control and Prevention (CDC), lead-based paint and lead-contaminated dust are some of the most widespread and hazardous sources of lead exposure for young children in the United States.  There is no safe … more

Related Recommendations

Lead Hazard Control

  •   2021-OE-0011b-01
    Priority

    Update HUD regulations, policies, and procedures following the regulatory process required by the amended Lead Safe Housing Rule, in consideration of CDC’s lowered BLRV of 3.5 ug/dL.


    Status

    On March 4, 2024, the Office of Lead Hazards Control and Healthy Homes (OLHCHH) informed us that it has drafted the Federal Register notice of its request for information from Lead Safe Housing Rule stakeholders and the general public on its proposal to adopt the Centers for Disease Control and Prevention's (CDC) blood lead reference value (BLRV) of 3.5 µg/dL as its elevated blood lead level (EBLL) under the rule. The current EBLL is 5 µg/dL. OLHCHH will be obtaining clearance of the notice, publishing the cleared version, and reviewing public comments in preparing to decide whether to change the rule's current level, and if so, to what level. OLHCHH plans on publishing the Federal Register notice by June 30, 2024, with a 60-day comment period.


    Analysis

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

    Alternatively, OLHCHH must establish that its research led it to determine that environmental interventions in cases of children with EBLLs between 3.5 and 4.9 µg/dL were ineffective in reducing the children’s blood lead levels and that lowering HUD’s EBLL regulation to 3.5 µg/dL is unnecessary.

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

Public and Indian Housing

  • Closed on November 13, 2023

    Create a plan and timeline that outlines OFO’s proposal to make necessary improvements to the EBLL tracker, such as moving it to a different platform.

  • Closed on August 25, 2023

    Provide field office staff access to historical data in the EBLL tracker to be readily available as needed, with adequate protection of PII.

  • Closed on December 08, 2023

    Update the EBLL tracker to show whether one or multiple children have an EBLL and whether the unit, building, or development previously had an EBLL reported.

  • Closed on December 08, 2023

    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.

  • Closed on February 28, 2023

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

  • Closed on March 07, 2024

    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.