Provide support to show that the performance history element was factored as part of the grantees’ capacity to manage the grants awarded through the 2025 NOFO.

Reevaluate ‘High Risk’ designation criteria as part of the SOP update and reimplement its updated ‘High Risk’ criteria to reflect how grantees will be designated as ‘High Risk’ within the program. In addition, train OLHCHH staff on the new ‘High Risk’ designation criteria stated in the SOP.

Notify grantees of HUD’s updated ‘High Risk’ designation criteria and HUD’s expectations when designated as ‘High Risk.’

Provide assistance to the nine identified ‘High Risk’ grantees that will help meet established performance benchmarks to be completed by the end of the respective grants in 2026.

Recapture $3,775,916 in undisbursed grant funds not used to meet agreed-upon performance benchmarks for the two identified ‘High Risk’ grantees whose period of performance ended in June and July 2025, respectively. In addition, identify those grantees that received 2020 through 2022 LBPHC and LHRD grants with a period of performance that ended on or before December 31, 2025, to determine whether agreed-upon performance benchmarks were met by that date, and take appropriate actions that include recapturing undisbursed grant funds.

Consider grantees’ suggestions to improve training sessions, technical assistance, and communication of information that grantees can use to help meet agreed-upon performance benchmarks. In addition, provide documentation to support the guidance OLHCHH plans to share with grantees to ensure agreed-upon performance benchmarks are met.

Reassess, establish, and incorporate a maximum review period of grantee-submitted QPRs into an SOP. Inform staff of the review period to ensure consistency and understanding of HUD’s expectations of the time to review grantee-submitted QPRs. In addition, establish formal guidance and implement internal controls to monitor and track the timely review of QPRs.

Work with the prime award recipients that had subaward reporting deficiencies to ensure that their subaward information is reported or reported accurately.

Update and expand the guidance provided to prime award recipients by (1) updating program website(s) with comprehensive information about FFATA, (2) implementing training, (3) issuing formal communication, and (4) implementing a feedback mechanism to ensure that all prime award recipients have the opportunity to share challenges with HUD and ask questions.

Integrate FFATA reporting requirements into the program monitoring procedures for all programs and conduct regular reviews to assess compliance.

Implement a process to identify teleworkers most at risk of receiving incorrect locality payments, verify that their official duty stations are correct and they are reporting to their official duty stations as required, and if necessary, correct their locality payments.

Determine how to measure the impact of recruitment efforts related to individuals who identiy as Hispanic or Latino.

Implement a process to measure the impact of recruitment efforts related to individuals who identify as Hispanic or Latino.

Implement a process to collect and maintain information about recruitment efforts related to indiviuals who identify as Hispanic or Latino from all HUD program offices and their respective field offices.

Implement a transparent process for reviewing open-ended exit survey results and sharing those results with ODEEO, as appropriate, and program offices while still protecting former employees’ confidentiality.

Assess what departing employees mean when they indicate that organizational culture is a motivation for leaving HUD.

Develop guidance for the program offices to identify the causes behind high attrition rates in governmentwide high-risk MCOs and field offices in large cities.

Develop guidance for program offices to develop program office-specific action plans to address any causes found for high attrition rates in governmentwide high-risk MCOs and field offices in large cities.

Create a single, unified agency-specific MCO list updated to reflect current progress toward closing skills gaps.

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

As of January 30, 2026, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) informed HUD OIG that HUD has circulated for comment 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).  The OLHCHH's estimated completion date is February 2026.

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.