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.

HUD seek legislative authority to expeditiously include Section 4712 protections within contracts for which HUD believes it must otherwise wait until there is a major modification.

HUD develop and implement controls to ensure that the provisions of Section 4712 are included in all contracts.

Develop improved procedures and provide training to appropriate staff regarding the departmental clearance process requirements, including • Determining which guidance is considered to be a directive, including public communications, and • Ensuring that HUD program participants have clear, instructive, and helpful information to comply with the applicable requirements and procedures for HUD programs.

Review the Clearance Calendar and ensure that appropriate form HUD-22 concurrence forms were obtained and documented for directives issued by other HUD offices.

Implement controls to ensure that future directives are reviewed and documented in the Clearance Calendar tracking system as required.

Update policies and procedures for the directives process, including responsibilities for process oversight and clear guidance defining when clearance is required.

Develop and provide training to appropriate staff and required reviewing offices regarding the departmental clearance process requirements.