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.

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 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.

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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.

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

In May 2023, HUD published a final rule establishing a new approach to defining and assessing housing quality: The National Standards for the Physical Inspection of Real Estate (NSPIRE). Public Housing regulations were amended, and Public Housing program participants were required to comply with this final rule and use the NSPIRE standards starting July 1, 2023. The Real Estate Assessment Center and Office of Field Operations will collaborate with the Office of Lead Hazard Control and Healthy Homes, the Office of Policy Development and Research, and a statistician to evaluate data collected under the NSPIRE inspection program to estimate the number of public housing developments and associated units that contain lead-based paint and lead-based paint hazards. As of November 2024, PIH reported that inspections have had a slow start due to procurement delays. Additionally, the NSPIRE system did not get the requested functionality to collect lead inspections. As of July 2025, HUD is conducting an inventory of the properties that are missing lead-based paint inspections. Once all the inspections have been received and uploaded into the NSPIRE system, it will use the information to estimate the number of public housing developments and associated units that contain lead-based paint and lead-based paint hazards. Among other factors, based on current legislative requirements of unit inspection cycle, HUD estimates that it will collect the lead-based paint inspection reports for final properties by December 31, 2028. Therefore, with OIG concurrence, HUD has revised the final action target date to February 2, 2029, to fully implement the recommendation.

Analysis

To address this recommendation, HUD will need to provide evidence that it collected and evaluated data under NSPIRE and estimated the number of public housing developments and associated units that contain lead-based paint and lead-based paint hazards.

Implementation of this recommendation will assist HUD in working with PHAs to address the public housing units that contain lead-based paint and lead-based paint hazards and help HUD’s oversight of units in need of hazard reduction.

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.

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 assess the lead-based paint hazard reduction activities performed at the 19 developments associated with 18 public housing agencies reviewed that did not implement interim controls and ongoing maintenance and reevaluation activities or adequately document that previously identified lead-based paint had been abated or treated with interim controls and subjected to ongoing maintenance and reevaluation activities. If those reduction activities did not fully abate the lead-based paint, HUD should ensure that the public housing agencies implement interim controls and ongoing maintenance and reevaluation programs and maintain required documentation.

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 July 2025, OLHCHH continues to revise the draft guidance in consideration of the comments it received during the clearance review process. HUD did not provide an updated target date to complete the agreed upon actions, which had been 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.

Use the fraud risk inventory to enhance program-specific fraud risk assessments for the TBRA and Operating Fund programs.

We recommend that the Director of HUD’s Newark Office of Public Housing make a determination regarding outstanding agreement income, including whether those unspent funds should be returned to the public housing agencies, thereby putting up to $697,912 to better use, including $478,165 related to Asbury Park and $219,747 related to Red Bank.

We recommend that the Director of HUD’s Newark Office of Public Housing provide technical assistance to Long Branch and require updates to its procedures to ensure that it properly classifies income received under any future agreements or activities.

We recommend that the Director of HUD’s Newark Office of Public Housing require Long Branch to prepare and provide support for a reasonable estimate of the amount of employee time used to perform services for Asbury Park and Red Bank and the amount of Long Branch program funds used to pay for that time. This estimate should include all employees known or believed to have provided services under the agreements based on language in the agreements, incentive payments, after-the-fact documentation provided, and any other applicable knowledge or documentation, which would show that the employees performed work under the agreements.

We recommend that the Director of HUD’s Newark Office of Public Housing require Long Branch to reimburse Long Branch’s program from non-Federal funds for any Long Branch program funds used for payroll expenses related to services provided to Asbury Park and Red Bank as established in recommendation 2A, estimated to be $1,014,660.

We recommend that the Director of HUD’s Newark Office of Public Housing require Long Branch to prepare and provide support to show the reasonableness and eligibility of the $1,583,652 in employee incentive payments related to services performed for Asbury Park and Red Bank, which was paid from agreement income, or reimburse its program from non-Federal funds for any amount it cannot support.