We also recommend that the Director of the Philadelphia Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training to the Authority’s staff involved with managing lead-based paint and technical assistance in developing and implementing new procedures and controls.

We also recommend that the Director of the Philadelphia Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to assess the quality of the lead-based paint inspections and risk assessments performed by the Authority’s contractors to determine whether they are sufficient to fulfill HUD’s requirements.

We recommend that the Deputy Assistant Secretary for Public Housing and Voucher Programs enhance SEMAP or develop a new performance measurement process that would identify PHAs with underperforming HCV Programs, which should include an assessment of PHAs’ ability to maximize assistance to house families.

We recommend that the Deputy Assistant Secretary for Field Operations Provide additional training and guidance to field office program staff on SEMAP scoring, rating, and verification procedures, including confirmatory reviews, quality control reviews, and adjustments to the SEMAP process.

We recommend that the Deputy Assistant Secretary for Field Operations provide training and guidance to field office program staff on SEMAP scoring, rating, and verification procedures, including confirmatory reviews, quality control reviews, and adjustments, as appropriate, for the revised SEMAP process.

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.

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

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.

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.

Corrective Action Taken

On September 10, 2025, HUD took action to close priority recommendation 6 from HUD OIG Evaluation Report 2021-OE-0011b, Improvements are Needed to HUD’s Processes for Monitoring Elevated Blood Lead Levels and Lead-Based Paint Hazards in Public Housing, issued February 28, 2023.  HUD’s Office of Public and Indian Housing, Office of Field Operations (OFO), conducted research and comparative analysis of nine identified field offices and PHAs with unreported elevated blood lead levels (EBLL) and obtained the missing documentation and entered it into the EBLL tracker.  Additionally, OFO revised the EBLL tracker job aid, published new EBLL guidance, held office hours and group and individual trainings for OFO staff, and developed a PowerBI dashboard to accompany the EBLL tracker to allow for the visual monitoring of EBLL cases with outstanding or nearing deadlines.  These corrective actions have increased the effectiveness of the EBLL tracker and enhanced the accuracy of HUD records.  HUD can now ensure that EBLL cases are both reported and recorded in the EBLL tracker appropriately so that it can track progress towards addressing EBLLs and close EBLL cases in a timely manner.

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.

Consider conducting an analysis of staffing resources needed to manage the REO and notes sales on tribal trust properties program and adjust staffing accordingly.

In conjunction with corrective actions being taken on previous audits, revise ONAP’s internal policy and procedures to include detailed written policies and procedures for the marketing, preservation, and sale of defaulted loan notes and REO properties on tribal trust and other restricted lands.

Work with the Office of the Chief Information Officer to develop an electronic solution, such as a new module in Native Advantage or one similar to FHA’s P260 tracking system, to track the sale of defaulted loan notes and REO properties on tribal trust and other restricted lands. While the solution is being developed, HUD should put controls into place to ensure that manual systems used to track defaulted loans and REO properties are complete and accurate.

We recommend that the General Deputy Assistant Secretary for Public and Indian Housing require the Real Estate Assessment Center in coordination with the Office of Field Operations to develop and implement a plan to manage lead-based paint and lead-based paint hazards in public housing.

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.

We recommend that the General Deputy Assistant Secretary for Public and Indian Housing require the Real Estate Assessment Center in coordination with the Office of Field Operations to determine the cost to eliminate or control the lead-based paint and lead based paint hazards in public housing and the timeframe to complete such work based on the existing funding levels and strategies that could accelerate the timeframe.

We recommend that the General Deputy Assistant Secretary for Public and Indian Housing require the Real Estate Assessment Center in coordination with the Office of Field Operations to implement adequate procedures and controls to ensure that public housing agencies appropriately identify and control lead-based paint and eliminate lead-based paint hazards in public housing.

We recommend that the General Deputy Assistant Secretary for Public and Indian Housing require the Real Estate Assessment Center in coordination with the Office of Field Operations to determine whether the public housing agencies identified as having lead-based paint hazards in their housing developments maintain and implement a plan for managing lead-based paint. For any public housing agency that does not have a plan for the management of lead-based paint in its public housing developments, as appropriate, HUD should inform the public housing agency that it should develop and implement its own plan.