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.

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.

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

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.

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

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.