Update HUD Handbook 1900.40, Do Not Pay policy, to clearly define the responsibilities for all parties and align it with current laws, processes, and procedures. This should include defining responsibilities for preaward and prepayment verification, and developing a process and governance structure to ensure that preaward and prepayment verification are consistently performed across HUD’s programs.

Status

As of January 2026, HUD has not provided a management decision for this recommendation. While HUD reestablished its computer matching agreement with the Department of Treasury through the Treasury Do Not Pay verification portal, HUD has not developed a policy to define responsibilities going forward.

HUD OIG recently initiated  the annual Payment Integrity Information Act (PIIA) audit for fiscal year 2025. During this audit we will work with HUD to determine the status of this recommendation.

Analysis

Updating the HUD Handbook 1900.40 will define responsible parties for ensuring compliance with the Do Not Pay Initiative (DNP).    

The implementation of this recommendation will result in consistent use of DNP, allowing for instant verification of eligibility across the billions in payments that HUD processes, resulting in the reduction of future improper payments.

Determine the appropriate timeframe for when initial management and occupancy reviews (MORs) should be completed for all properties that convert under the Rental Assistance Demonstration and issue updated guidance that includes a system to track the timeliness of initial MORs.

Status

Given current resource constraints, HUD agreed to create guidance based on risk-based Management and Occupancy Review (MOR) parameters to ensure that field staff and leadership perform the initial MOR for PBRA RAD-converted properties. This guidance will specify which assessments can be done on-site or remotely (such as desk reviews). Furthermore, the guidance will require that the existing MOR tracking tools (e.g., PowerApps) be used to monitor planning for the MORs and progress throughout, until final closing of the review. As of January 2026, HUD has trained its staff on performing MORs and is in the process of finalizing the policy for the timeframe for when initial MORs are due. The final target completion date is April 15, 2026.

Analysis

To implement this recommendation, HUD needs to provide evidence that it has updated guidance with appropriate timeframe for conducting MORs and a system to track the timeliness of initial MORs. Failure to determine the timing of the initial MORs could delay HUD's performance of them, which may result in property owners' untimely corrective actions, and thus potentially impact the health and safety of families.

The implementation of this recommendation has the potential to directly impact the health and safety of families.

Complete the initial management and occupancy reviews (MORs) for the Rental Assistance Demonstration properties that have not had an initial MOR.

Status

Given current resource constraints, HUD will create guidance based on risk-based Management and Occupancy Review (MOR) parameters to ensure that field staff and leadership perform the initial MOR for PBRA RAD-converted properties. This guidance will specify which assessments can be done on-site or remotely (such as desk reviews). The guidance will outline the timing requirements for when the initial MOR should be completed. To date, HUD staff have completed 233 MORs for the 834 RAD-converted properties.  HUD anticipates completing the initial MORs for the remaining 501 properties by the end of 2027.  HUD HQ and field staff will use the Power BI MOR tool to track the MOR through the stages: scheduling, review, issuance of report and finally the closing of the report. As of January 2026, due to restrictions regarding travel funds for fiscal year 2025 and HUD’s need for staff training, HUD stated it was unable to make progress in conducting additional MORs. HUD anticipates having travel funds in fiscal year 2026 that will enable it to begin working through the backlog. The target date is March 31, 2026.

Analysis

Completing initial MORs would assist HUD in holding property owners accountable for maintaining the conditions of their properties and sufficient reserve for replacement accounts balances, which could impact property owners' ability to make needed capital repairs.

The recommended corrective action has the potential to directly impact the health and safety of families.

Develop and implement a plan to determine how to implement the risk-based approach to review the Rental Assistance Demonstration properties that have not had subsequent management and occupancy reviews (MORs) in more than 3 years and to require periodic MORs going forward.

Status

Given the current resource constraints, HUD will create guidance based on risk-based MOR parameters to ensure that field staff and leadership perform MORs using a risk-based model for PBRA RAD-converted properties. This guidance will specify which assessments can be done on-site or remotely (such as desk reviews) and the timing requirements for when ongoing MORs should be scheduled once the initial MOR is completed. As of January 2026, 641 MORs need to be scheduled for the Office of Asset Management's portfolio of 834 RAD-converted properties. Of those, 85 properties are managed by Performance-Based Contract Administrators (PBCA).  Depending on risk indicators for each property, MORs will be scheduled accordingly. HUD reported that its staff resources are limited in comparison to the PBCAs and will therefore take a risk-based approach for prioritizing the MORs that HUD staff must complete. The Office of Asset Management will develop a plan to address the backlog of RAD-converted MORs using the current risk factors which include the physical condition, last MOR score, financial health of the property and other indicators. As of January 2026, HUD was unable to complete its plan due to staff training needs and the restrictions regarding travel in fiscal year 2025.  HUD anticipates having travel funds in fiscal year 2026 that will enable it to begin working through the backlog. Target completion date is March 31, 2026.

Analysis

Developing a plan to implement the risk-based approach would establish the criteria for identifying properties that are at a higher risk of noncompliance.  

The recommended corrective action would help HUD to monitor property owners' compliance with its requirements and thus, potentially protect families from living in unsafe units.

Determine an appropriate timeframe in which non-FHA-insured Project-Based Rental Assistance (PBRA) properties converted under the Rental Assistance Demonstration should be initially inspected, work with HUD’s Real Estate Assessment Center (REAC) to ensure that inspections are ordered and completed within that timeframe, and update HUD’s publicly available and internal guidance to ensure consistent messaging in accordance with HUD’s determination.

Status

As of January 2026, Multifamily Housing plans to develop and implement adequate policies, procedures, and controls to ensure non-FHA insured PBRA properties under RAD are inspected within 90 days after the original date of the HAP contract, unless the property has been approved for inspection delay during major rehabilitation, then within 90 days after the end of the approved inspection delay. Further, Multifamily Housing will provide appropriate updated guidance to both internal and external partners relative to non-FHA-insured PBRA properties converted under RAD.  The target completion date is March 31, 2026.

Analysis

Determining the appropriate timeframe for initial inspections would result in the timely identification and correction of life-threatening and non-life-threatening deficiencies.

The recommended corrective action has the potential to directly impact the health and safety of families.

The CDO should coordinate with HUD’s Records Office, Privacy Office, and program offices to develop data policies and procedures for data inventory, categorization, and labeling in support of zero trust architecture.

Status

HUD provided a corrective action plan for this recommendation in May 2025. The planned corrective action requires the agency to acquire a data management system, develop cataloging standards, and coordinate with the program offices stated in the recommendation to ensure data is handled in a secure manner. The procurement process has not yet begun, yet in their initial plans, HUD will require vendor support to develop this tool. The estimated completion date of this recommendation is September 2027.

Analysis

By addressing the recommendation, HUD will be positioned better to protect and prioritize protection for data in its IT systems. This will allow HUD to have a better understanding of the specifics of the most sensitive data as well as allow recommendation 2024-OE-0002a-03 to be addressed by HUD.

HUD maintains billions of records of PII and sensitive data within IT systems and the IT environment. Knowing more specifics about the data is essential in the ability to protect and recover from attempted exfiltration attempts.

Develop and execute a detailed plan and timeline for both testing and reporting estimates of improper payments in the PIH-TBRA and PBRA programs in compliance with Federal law and OMB guidance.

Status

As of January 30, 2026, HUD has not provided a management decision, detailed plan, or timeline as to how HUD will respond to the recommendation.  When OIG inquired on the status of this recommendation, HUD reported it had completed work in this area that was reflected in its fiscal year 2025 Annual Financial Report (AFR). However, based on what HUD reported it is unclear if it addressed our recommendation. OIG recently initiated the annual Payment Integrity Information Act (PIIA) audit which reviews HUD’s payment integrity information to determine HUD’s compliance. During this audit OIG will also determine the status of HUD’s efforts in terms of this recommendation.

Analysis

For HUD to close this recommendation, it must finish testing the full life cycle of payments in these programs and publicly report estimates of the improper payments in them. Merely producing a plan with future action target dates is not sufficient to meet the spirit of this recommendation.

PBRA and PIH-TBRA are the two largest program expenditures in HUD's portfolio, totaling $55.6 billion in FY 25, or 62.5 percent of HUD's total expenditures. HUD has been challenged with developing a compliant sampling methodology that can test the full payment cycle, and, that can be executed within the required timeframes. To fully address this recommendation, the sampling methodology should test the full payment cycle, and the associated sample testing and statistical estimation must be completed in time to be included in the Annual Financial Report.
Implementation of this recommendation will result in HUD better-safeguarding taxpayer dollars and decrease improper payments.

HUD (a) identify all contracts related to its programs that pre-date July 1, 2013 and that have not yet been modified to include Section 4712 whistleblower protections; and (b) review all contracts entered into on or after July 1, 2013, to ensure they include a clause that requires contractors to comply with Section 4712.

Status

HUD provided a Management Plan that identifies actions HUD is taking to address the recommendation. The OIG and HUD have not reached an agreement that the actions proposed will fully address the recommendation. Additionally, HUD has not completed several of the proposed actions and is evaluating what next steps are appropriate and feasible.

Analysis

To fully address this recommendation, HUD must (a) identify all contracts related to its programs that pre-date July 1, 2013, and that have not yet been modified to include Section 4712 whistleblower protections; and (b) review all contracts entered on or after July 1, 2013, to ensure they include a clause that requires contractors to comply with Section 4712. Implementation of this recommendation will ensure that Section 4712 whistleblower protections will apply to all individuals working for HUD contractors.

Seek voluntary cooperation from program participants to proactively modify pre-2013 contracts for the purpose of including a clause requiring compliance with Section 4712.

Status

HUD provided a Management Plan that identifies actions HUD is taking to address the recommendation.  The OIG and HUD have not reached an agreement that the actions proposed will fully address the recommendation. Additionally, HUD has not completed several of the proposed actions and is evaluating what next steps are appropriate and feasible.

Analysis

To fully address this recommendation, HUD must provide evidence that it has sought voluntary cooperation from program participants to proactively modify pre-2013 contracts for the purpose of including a clause requiring compliance with Section 4712. Implementation of this recommendation will ensure that Section 4712 whistleblower protections will apply to all individuals working for HUD contractors.

Use its best efforts to include a clause requiring compliance with Section 4712 at the time of major modifications to contracts with program participants with whom HUD is unable to gain voluntary cooperation.

Status

HUD provided a Management Plan that identifies actions HUD is taking to address the recommendation. The OIG and HUD have not reached an agreement that the actions proposed will fully address the recommendation. Additionally, HUD has not completed several of the proposed actions and is evaluating what next steps are appropriate and feasible. In addition, the President's fiscal year 2026 Congressional Budget Justification includes a request for new legal authority to "expeditiously include whistleblower protections of 41 U.S.C. 4712 within all contracts and grants, including outstanding project-based rental assistance contracts, rather than wait until there is a major modification."

Analysis

To fully address this recommendation, HUD must provide evidence that it has taken steps to ensure that it includes a clause requiring compliance with Section 4712 at the time of major modifications to contracts with program participants with whom HUD is unable to gain voluntary cooperation. Implementation of this recommendation will ensure that Section 4712 whistleblower protections will apply to all individuals working for HUD contractors.

Implement adequate policies, procedures, and controls to ensure that public housing properties will be inspected within required timeframes.

Status

As of July 2025, according to HUD, all development and enhancement of the NSPIRE software system are presently on hold pending Administrative guidance on HUD funded software system improvements. Additionally, the required software changes recommended under this finding depend on the final Public Housing Assessment System (PHAS) rule, but most regulatory work has been paused for review per Executive Order from the Administration. Pending the required resources and funding approval, HUD cannot move forward at this time. According to HUD, it has planned for and proposed the needed improvements to meet this recommendation and will provide updates when available. The current final action target date is September 30, 2025.

Analysis

To fully address this recommendation, HUD must provide evidence demonstrating that it has implemented control activities that ensure public housing properties are inspected within the required timeframes.

Implementation of this recommendation will result in HUD accurately tracking the dates on which public housing properties should be inspected and that they are timely completed.

Due to the uncertainty of when software changes to NSPIRE can take place to enforce the timing of inspections, REAC cannot enforce the requirements of inspection timing.

Perform a complete agency-wide fraud risk assessment (which incorporates the fraud risk assessments performed at the program level) and use the results to develop and implement an agency-wide plan to move HUD’s fraud risk management program out of the ad hoc phase.

Status

As of July 2025, HUD cancelled its fraud risk management contracts and the Chief Risk Officer position was vacated under the Deferred Resignation Program. HUD is currently working to realign its business process and determining how it will address fraud risk management. As of January 2026, HUD has not provided an updated plan on how it will address the recommendation. However, HUD reported to HUD OIG that it is currently working on reducing fraud through a Task Force and other new initiatives. The final action target date for this recommendation was September 30, 2024.

Analysis

To fully address this recommendation, HUD must provide evidence that it has performed an agency-wide fraud risk assessment performed at the program level, adopted and implemented its fraud risk assessment program departmental policy, and that each HUD program office has established office-specific risk programs.

Require the REAC in coordination with OFO to determine the number of developments and associated units that contain lead-based paint and lead-based paint hazards.

Status

As of January 30, 2026, according to HUD, all development and enhancement of the NSPIRE software system is still on hold pending administrative guidance on HUD funded software system improvements.  Additionally, the required software changes recommended under this finding depend on the final Public Housing Assessment System (PHAS) rule, but most regulatory work has been paused for review per Executive Order from the Administration.  HUD anticipates changes to the PHAS rule will be finalized in 2026; however, updates to the NSPIRE system requires funding.  Pending the required resources and funding approval, HUD cannot move forward at this time.  According to HUD, it has planned for and proposed the needed improvements to meet this recommendation and will provide updates when available.  The final action target date was revised to October 1, 2026.

Analysis

To fully address this recommendation, HUD must provide evidence demonstrating that it has implemented control activities that ensure public housing properties are inspected within the required timeframes.

Implementation of this recommendation will result in HUD accurately tracking the dates on which public housing properties should be inspected and that they are timely completed.

Due to the uncertainty of when software changes to NSPIRE can take place to enforce the timing of inspections, REAC cannot enforce the requirements of inspection timing.

Update applicable requirements to require assisted property owners, including PHAs, to maintain adequate documentation to support their determinations that maintenance and hazard reduction activities that disturb surfaces with lead-based paint qualify for the de minimis exemption from the lead-safe work practices under the Lead Safe Housing Rule.

Status

To address this recommendation, The Office of Lead Hazard Control and Healthy Homes (OLHCHH) agreed to:                                                                                                                      
1. Issue a notice to assisted target housing owners and public housing agencies on the de minimis exception citing the correct application of the de minimis threshold; describing appropriate documentation methods for the application of the de minimis threshold; and recommendations of best practices for documenting applications.
2. Collect additional data regarding the use of the de minimis threshold, including information on how private and public housing owners: (a) determine how much paint in target housing will be disturbed during a maintenance or rehabilitation project; (b) use the paint disturbance area information; (c) monitor the amount of paint disturbed in projects that are designed to disturb de minimis amounts of paint in target housing.
3. Design and conduct webinars, including at least one for each program office’s major categories of stakeholders on requirements and best practices pertaining to the de minimis exception under the Lead Safe Housing Rule and its implementation; record the webinars on the HUD website (e.g., on HUD Exchange) for future viewing by stakeholders; and conduct outreach promoting the webinars. 
The OLHCHH had drafted guidance on the de minimis exception to the Lead Safe Housing Rule for PIH, Multifamily Housing, and CPD and submitted it through the clearance process in September 2024.  As of January 2026, OLHCHH continues to revise the draft guidance in consideration of the comments it received during the clearance review process.  However, HUD has not provided an updated target date to complete the agreed upon actions, which was January 31, 2024.

Analysis

To implement this recommendation, HUD needs to provide evidence that it has implemented the three actions OLHCHH agreed to complete.

Implementation of this recommendation and associated corrective actions will ensure assisted property owners are sufficiently informed regarding the requirements to support their determinations that maintenance and hazard reduction activities that disturb surfaces with lead-based paint qualify for the de minimis exemption from the lead-safe work practices under the Lead Safe Housing Rule and that assisted property owners are conducting this work safely, thereby ensuring households are residing in safe and healthy HUD-assisted housing.

Evaluate IT acquisition process workflows and identify ways to simplify the processes, facilitate more effective stakeholder coordination across offices, and create efficiencies when possible.

Status

In September 2025, OCPO indicated that additional time was needed to implement the recommendation based on the implementation of Executive Order 14275, which initiates a governmentwide initiative to streamline federal procurement regulations and agency acquisition practices.  OCPO stated that the corrective action would be completed by March 31, 2026.

Analysis

To fully address this recommendation, HUD must provide evidence that it has published its standard operating procedures resulting from its evaluation of workflows and efforts to simplify processes and facilitate more effective coordination.

Implementation of this recommendation will result in defined IT acquisition process workflow procedures to increase efficiency and ensure coordination across program offices.

Implement a software asset management capability for software and operating systems to ensure that software executes only from the authorized software inventory and all unauthorized software is blocked from executing on HUD's network.

Status

HUD previously reported that it was implementing a software management tool with an expected implementation date of quarter 2 of FY 2025; however, between quarter 2 and 3 of FY 2025, HUD personnel has stated that the tool would not meet the agency’s needs.  Accordingly, HUD is looking at a new tool to implement this program and collaborating with the DHS continuous diagnostics and monitoring team to analyze options. As of January 2026, HUD has not provided an estimated completion date.

Analysis

To fully address this recommendation, the Office of Multifamily Housing must provide evidence of an action plan or policy that includes procedures to ensure households living in multifamily units have a sufficient supply of safe drinking water.

Implementation of this recommendation will enable HUD to have sufficient oversight and control activities in place to ensure households living in multifamily housing have a sufficient supply of safe drinking water.

Implement multifactor authentication mechanisms for all nonprivileged users who access information systems that process, store, or transmit PII.

Status

The Office of the Chief Information Officer reported that it has implemented a new software security solution to implement multifactor authentication, starting with a pilot on 15 FHA systems.  In October 2024, HUD received additional funds through the Technology Modernization Fund for this project enterprise-wide.  HUD is in the process of conducting baseline surveys for all 200+ systems to determine how to handle systems that need architectural adjustments to utilize the tool.  This is assisting HUD in developing an agency-wide implementation plan, which is expected to take several years to implement.  As of January 2026, HUD has not provided an estimated completion date.

Analysis

To fully address the recommendation, HUD must implement multifactor authentication enterprise-wide.

Implementation of this recommendation will result in an enterprise-wide identity and access management solution. Nonprivileged users will be required to use multifactor authentication methods to access HUD data, networks, and devices.

Implement multifactor authentication mechanisms for all privileged users who access information systems that process, store, or transmit PII.

Status

The Office of the Chief Information Officer reported that it has implemented a new software security solution to implement multifactor authentication, starting with a pilot on 15 FHA systems.  In October 2024, HUD received additional funds through the Technology Modernization Fund for this project enterprise-wide. HUD is in the process of conducting baseline surveys for all 200+ systems to determine how to handle systems that need architectural adjustments to utilize the tool.  This is assisting HUD in developing an agency-wide implementation plan, which is expected to take several years to implement.  As of January 2026, HUD has not provided an estimated completion date.

Analysis

To fully address this recommendation, HUD must implement multifactor authentication enterprise-wide.

Implementation of this recommendation will result in an enterprise-wide identity and access management solution.  Privileged users will be required to use multifactor authentication methods to access HUD data, networks, and devices.

Require lenders to obtain the borrowers’ consent to verify the existence of delinquent Federal taxes with the IRS during loan origination and deny any applicant with delinquent Federal tax debt and no payment plan or a noncompliant payment plan or an applicant refusing to provide consent from receiving FHA insurance to put at least $6.1 billion to better use by avoiding potential future costs to the FHA insurance fund.

Status

As of January 2026, the Office of Multifamily has developed standard operating procedures for its field office staff and plans to issue additional guidance to HUD staff and multifamily property owners on addressing lead in the water for multifamily properties.  Although the final action target date has passed, the guidance is undergoing HUD's internal review clearance process.  HUD did not provide an estimated date for issuance of the guidance to close the recommendation.

Analysis

To fully address this recommendation, the Office of Multifamily Housing must provide evidence of an action plan or policy that includes procedures to ensure households living in multifamily units have a sufficient supply of safe drinking water.

Implementation of this recommendation will enable HUD to have sufficient oversight and control activities in place to ensure households living in multifamily housing have a sufficient supply of safe drinking water.

Require lenders to obtain the borrowers’ consent to verify the existence of delinquent Federal taxes with the IRS during loan origination and deny any applicant with delinquent Federal tax debt and no payment plan or a noncompliant payment plan or an applicant refusing to provide consent from receiving FHA insurance to put at least $6.1 billion to better use by avoiding potential future costs to the FHA insurance fund.

Status

HUD's Office of Single Family Housing will need additional tax information to complete the planned action.  In July 2025, HUD was seeking closure of the recommendation, stating that the delinquent Federal tax debt information is not systematically available since the Internal Revenue Service (IRS) cannot disclose it for this non-tax administration need and use under current regulations.  HUD also maintains that without an automated solution from the IRS, it is not practical for individual borrowers and/or lenders to manually check tax status with the IRS.  OIG disagreed with HUD's request for closure and its position is that action is required since delinquent tax debtors are ineligible for FHA loans under existing FHA and Office of Management and Budget (OMB) guidelines.  HUD has other opportunities to address the recommendation, which would help put at least $6.1 billion to better use by ensuring that Federal tax delinquencies are appropriately reviewed during loan origination.  As of January 2026, no further updates have occurred.

Analysis

To fully address this recommendation, HUD will need to provide evidence that it established a method of borrower consent to verify the existence of delinquent federal taxes including, but not limited to one of the options OIG provided, which were (1) lenders obtaining the borrowers' consent to obtain their tax records directly from the IRS or (2) borrowers accessing their own tax information and submitting it to the lenders.

Implementation of this rule should result in HUD putting $6.1 billion to better use.