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Key Details
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  Open
  Closed
Funds Put to Better Use
Funds Put to Better Use

Recommendations that funds be put to better use estimate funds that could be used more efficiently. For example, recommendations that funds be put to better use could result in reductions in spending, deobligation of funds, or avoidance of unnecessary spending.

Questioned Costs
Questioned Costs

Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.

Sensitive
Sensitive

Sensitive information refers to information that could have a damaging import if released to the public and, therefore, must be restricted from public disclosure.

Priority
Priority

We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.

Export Search
Date Issued

Special Inquiry

  •   2023-IG-002-1
    Priority

    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.


    Status

    As of January 2024, OIG has not yet reached agreement with HUD regarding how the Department will address this recommendation.


    Analysis

    To fully address this recommendation, HUD must (a) identify all contracts related to its programs that pre-date July 1, 20213 and that have not yet been modified to include Section 4712 whistleblower protections; and (b) review all contracts entered on or after July 1, 20213, to ensure they include a clause that requires contractors to comply with Section 4712.

    Implementation of this recommendation will ensure that Section 4712 whistleblower protections will apply to all individuals working for HUD contractors.

  •   2023-IG-002-2
    Priority

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


    Status

    As of January 2024, OIG has not yet reached agreement with HUD regarding how the Department will address this recommendation.


    Analysis

    To fully address this recommendation, HUD must provide evidence that it has sought voluntary cooperation from program participants to proactively modify pre-2013 contracts for the purpose of including a clause requiring compliance with Section 4712.

    Implementation of this recommendation will ensure that Section 4712 whistleblower protections will apply to all individuals working for HUD contractors.

  •   2023-IG-002-3
    Priority

    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.


    Status

    As of January 2024, OIG has not yet reached agreement with HUD regarding how the Department will address this recommendation.


    Analysis

    To fully address this recommendation, HUD must provide evidence that it has taken steps to ensure that it is including 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.

    Implementation of this recommendation will ensure that Section 4712 whistleblower protections will apply to all individuals working for HUD contractors.

Public and Indian Housing

  •   2023-CH-0004-001-A
    Priority

    Develop and implement a nationwide inspection review protocol, which includes but is not limited to (1) whether field office staff should mark verification of PHA corrections of life-threatening deficiencies in PASS or any future tracking systems, (2) acceptable documentation for offsite verifications, and (3) whether field office staff should discuss or verify corrections of non-life-threatening deficiencies.


    Status

    The Office of Field Operations (OFO) will develop and implement a nationwide inspection review protocol for life-threatening deficiencies. Field offices will be required to ensure PHAs are timely certifying the correction of all life- threatening deficiencies. Included in the protocol, staff will be instructed to mark verification of a sample of these deficiencies. For the non-life-threatening deficiencies, OFO will implement a protocol for deficiencies with developments with physical inspection scores below 60 percent that are designated as standard performers, in compliance with 24 CFR 902.73. The final action target date is August 15, 2024.


    Analysis

    To fully address this recommendation, HUD must develop and implement a nationwide review protocol that includes (1) PHA timely certification of correction of all life-threatening deficiencies, and (2) field office verification of PHA corrections of life-threatening deficiencies in PASS or any future tracking systems.

    Further, HUD must provide evidence of the protocol implemented for non-life-threatening deficiencies.

    Implementation of this recommendation will ensure PHAs will correct life-threatening deficiencies within required timeframes.

  •   2023-CH-0004-001-B
    Priority

    Develop and implement training for field offices that addresses reviewing or following up with PHAs about the correction of life-threatening and non-life-threatening deficiencies and how (1) to review physical inspection reports to effectively ensure that PHAs correct physical deficiencies, (2) PHAs should address or correct each type of deficiency observed in the REAC physical inspection report, and (3) to use PASS or any future tracking system.


    Status

    The Office of Field Operations (OFO) plans to provide dates of office hours and specific training related to NSPIRE and the expectations for all types of defects. The final action target date to complete these actions is August 15, 2024.


    Analysis

    To fully address this recommendation, OFO must provide evidence that the training it develops and implements addresses reviewing or following up with PHAs about the correction of life-threatening and non-life-threatening deficiencies and how (1) to review physical inspection reports to effectively ensure that PHAs correct physical deficiencies, (2) PHAs should address or correct each type of deficiency observed in the REAC physical inspection report, and (3) to use PASS or any future tracking system.

    Implementation of this recommendation will result in public housing units that are decent, safe, and sanitary because it mandates oversight to ensure PHAs are addressing identified deficiencies.

  •   2023-CH-0004-001-C
    Priority

    Implement a system to track field office inspection review activities and create a repository for the support documentation collected to verify the correction of life-threatening deficiencies.


    Status

    The Office of Field Operations (OFO) will implement a system to track field office inspection review activities and create a repository for the support documentation collected to verify the correction of life-threatening deficiencies. OFO will continue to work on the corrective actions to ensure closure by the final action target date of August 15, 2024.


    Analysis

    To fully resolve this recommendation, HUD must provide evidence to demonstrate the implementation of a system that tracks office inspection review activities and includes a mechanism to collect support documentation collected to verify the correction of life-threatening deficiencies, and that is fully operational and in use.

    Implementation of this recommendation will result in public housing units that are decent, safe, and sanitary because it mandates oversight to ensure PHAs are addressing identified deficiencies.

  •   2023-CH-0004-002-C
    Priority

    Develop and implement a nationwide protocol for field offices, describing how PHA self-inspections should be reviewed, based on REAC's determination of the number and frequency of PHA self-inspections.


    Status

    The Office of Field Operations will develop and implement a nationwide protocol for field offices, describing how Public Housing Agency (PHA) self-inspections should be reviewed, based on Real Estate Assessment Center’s determination of the number and frequency of PHA self-Inspections. The final action target date is August 15, 2024.


    Analysis

    To fully resolve this recommendation, HUD must provide evidence that demonstrates it developed a nationwide protocol and implemented it across all HUD field offices.

    Implementation of this recommendation will result in public housing units that are decent, safe, and sanitary because it mandates oversight to ensure PHAs are addressing identified deficiencies.

Public and Indian Housing

  •   2023-CH-0003-001-B
    Priority

    Implement adequate policies, procedures, and controls to ensure that public housing properties will be inspected within required timeframes.


    Status

    NSPIRE regulations clarified/modified the timing for which inspections should occur. The date for inspection of each public housing property must then be programmed into HUD's system to ensure that inspections occur within required timeframes. The Real Estate Assessment Center (REAC) continues to work with its management and system support contractors on the list of public housing properties to inspect and the date the inspections should be completed by under the new NSPIRE regulations. REAC is in the process of adjusting the list based on information relating to small, rural public housing. REAC believes that it is on track to meet the final action target date of May 31, 2024.


    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 required timeframes.

    Implementation of this recommendation will result in HUD accurately tracking the dates in which public housing properties should be inspected and that they are timely completed.

Chief Financial Officer

  •   2023-FO-0009-001-A
    Priority

    Establish an improper payment council within HUD that consists of senior accountable officials from across the Department with a role in the effort that would work to identify risks and challenges to compliance and identify solutions as a collaborative group.


    Status

    HUD agreed to capture and monitor the risks related to improper payment compliance through the Risk Management Council (RMC), chaired by the HUD Deputy Secretary, which meets quarterly. Consistent with guidance issued by the GAO in June 2023 (GAO-23-106585), HUD will assign Senior Accountable Officials at the Program Office level. While we are generally agreeable to this being handled through the Risk Management Council, we informed HUD that we needed assurance that the Risk Management Council will accept this as a risk and work on it in the immediate future. We communicated our position to OCFO who agreed to update the proposed language and include as evidence deliverables from the Chief Risk Officer showing that this risk is being worked on. However, OCFO has not yet updated they’re corrective action plan to reflect our agreement. As of January 2, 2024, we do not have official agreement on HUD’s corrective actions, and therefore do not have a final action target date.


    Analysis

    To fully address this recommendation, HUD must provide evidence that it has established a process by which the Risk Management Counsel (RMC) has accepted that improper payment compliance as a risk, identifies sub-risks and challenges to achieving compliance, identifies solutions to those risks and challenges, and provide evidence that the RMC is implementing the solutions that will position HUD towards compliance.

    Implementation of this recommendation will result in HUD better safeguarding taxpayer dollars and decrease improper payments.

Government National Mortgage Association

  •   2023-KC-0003-001-B
    Priority

    Update its policy and procedures to define what type of information Ginnie Mae may disclose and how it will handle protected information before extinguishment.


    Status

    As of October 2023, Ginnie Mae planned to incorporate the existing Ginnie Mae Confidential Information Policy into its Default Playbook and identify and log information that can be selectively shared in rapid relocation execution. The final action target date is May 30, 2024.


    Analysis

    To fully address this recommendation, Ginnie Mae must provide evidence that it has updated its policies and procedures to define what type of information it may disclose and how it will handle protected information before extinguishment. Ginnie Mae stated that it is currently on track to fully address the recommendation on time.

    Implementation of this recommendation will result in Ginnie Mae more effectively protecting its portfolio.

  •   2023-KC-0003-001-C
    Priority

    Update its Policies and procedures to define how Ginnie Mae will determine the portfolio value and price before Sale.


    Status

    As of October 2023, Ginnie Mae planned to update its valuation models, timing, and pricing strategies within its rapid relocation procedure. The final action target date is May 30, 2024.


    Analysis

    To fully address this recommendation, Ginnie Mae must provide evidence that it has updated its policies and procedures to define how it will determine the portfolio value and price before sale. Ginnie Mae stated that it is currently on track to fully address the recommendation on time.

    Implementation of this recommendation will result in Ginnie Mae more effectively protecting its portfolio.

  •   2023-KC-0003-001-D
    Priority

    Update its policies and procedures to define how Ginnie Mae intends to identify and evaluate prospective buyers to ensure its ability to absorb the extinguished portfolio before executing the purchase and sale agreement.


    Status

    As of October 2023, Ginnie Mae planned to incorporate impact analysis evaluation of each prospective buyer to confirm compliance post-transfer. This will include key portfolio indicators and will mirror similar activities currently performed on select standard pool transfer participants. The final action target date is May 30, 2024.


    Analysis

    To fully address this recommendation, Ginnie Mae must provide evidence that it has updated its policies and procedures to define how it intends to identify and evaluate prospective buyers to ensure its ability to absorb the extinguished portfolio before executing the purchase and sale agreement. Ginnie Mae stated that it is currently on track to fully address the recommendation on time.

    Implementation of this recommendation will result in Ginnie Mae more effectively protecting its portfolio.

Lead Hazard Control

  •   2021-OE-0011b-01
    Priority

    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 December 12, 2023, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) is considering lowering HUD’s elevated blood lead level to 3.5 µg/dL. OLHCHH is researching the scientific literature of the efficacy of environmental interventions at the CDC’s current blood lead reference value and is preparing to issue a contract for a more intensive study into the efficacy. OLHCHH plans to publish a notice in the Federal Register for a 60-day public comment period by June 30, 2024.


    Analysis

    To fully address this recommendation, OLHCHH must provide evidence that it has updated its regulations, policies, and procedures so that they are consistent with CDC’s lowered blood lead reference value of 3.5 ug/dL. Alternatively, OLHCHH must establish that its research led it to determine that environmental interventions in cases of children with elevated blood lead levels between 3.5 and 4.9 µg/dL were ineffective in reducing the children’s blood lead levels and that lowering HUD’s elevated blood lead level regulation to 3.5 µg/dL is unnecessary.

    Implementation of this recommendation will help ensure children living in public housing with elevated blood lead levels receive effective environmental interventions.

Public and Indian Housing

  •   2021-OE-0011b-06
    Priority

    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.


    Status

    As of November 29, 2023, the Office of Field Operations (OFO) was coordinating with other HUD offices as necessary to determine causes of the variance in the number of elevated blood lead level (EBLL) cases among States on the EBLL tracker and identify solutions that are within HUD’s control. If no determination occurs, OFO will request closure of this recommendation. The estimated completion date is June 30, 2024.


    Analysis

    To fully address this recommendation, OFO must provide evidence that it coordinated with other HUD offices and identified the causes of the variances in the number of EBLL cases among states on the EBLL tracker. OFO must also provide evidence that it fully remedied the causes of the variances.

    Alternatively, OFO must provide an explanation sufficient to support a claim that it could not identify the causes of the variances or develop and implement solutions for problems it identified in its research.

    Implementation of this recommendation will result in improved HUD data of EBLL cases of children living in public housing across the country. Accurate reporting of EBLL cases to HUD is essential so that HUD can ensure PHAs take effective environmental interventions that help prevent additional lead exposure.

Chief Financial Officer

  •   2023-FO-0001-001-A
    Priority

    Perform a complete agency-wide fraud risk assessment (which incorporates the fraud risk assessments performed at the program level) and use the results to develop and implement an agency-wide plan to move HUD’s fraud risk management program out of the ad hoc phase.


    Status

    HUD had initiated several responsive actions to resolve this recommendation to include: developing a fraud risk assessment program departmental policy, compiling program level oversight reports, establishing a fraud risk working group to strengthen HUD’s fraud risk culture, and supporting program offices with establishing risk programs within their offices to draw more direct attention to their risk management activities. HUD reported that all of these are ongoing activities working in an integrated manner towards achievement of this recommendation. Further, Congress approved HUD’s reorganization proposal to establish the Office of the Chief Risk Officer, allowing HUD to dedicate full time employees to focus on Enterprise and Fraud Risk Management. The final action target date is September 30, 2024.


    Analysis

    To fully address this recommendation, HUD must provide evidence that it has performed an agency-wide fraud risk assessment performed at the program level, adopted and implemented its fraud risk assessment program departmental policy and that each HUD program office has established office-specific risk programs.

    Implementation of this recommendation will result in HUD better safeguarding taxpayer dollars and decrease improper payments.

Public and Indian Housing

  •   2023-CH-0001-001-B
    Priority

    Requires 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. The final action target date is March 31, 2025.


    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.

Lead Hazard Control

  •   2023-IG-0001-001-A
    Priority

    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 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 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 stated that they planned to complete the work for the corrective action by September 20, 2023. However, as of January 2, 2024, the recommendation is still open. The final action target date for the recommendation is 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.

Chief Financial Officer

  •   2022-FO-0005-001-A
    Priority
    Closed on October 03, 2023

    We recommend that the Deputy Chief Financial Officer…In collaboration with all involved program offices, develop and implement a sampling methodology that allows for a sample size that reasonably allows for the testing of the complete payment cycle within the PIIA reporting timeframe.


    Status

    As of October 2023, the Office of the Chief Financial Officer believed it has taken sufficient action to close this recommendation because it provided sampling and estimation plans developed for 2023 testing of improper payments. However, the sampling plans have not produced statistically valid samples in time for HUD to complete testing of its payment cycle within the PIIA reporting timeframe. OIG will continue to identify this as a priority open recommendation.


    Analysis

    HUD has been challenged with developing a compliant sampling methodology that can test the full payment cycle and that can be executed within the required timeframe. HUD’s sampling methodology, associated sample testing, and statistical estimation of improper payments could not be completed in time for the required annual reporting of improper payment estimates in the Agency Financial Report (AFR), normally issued in November. To fully address this recommendation, HUD must use a sampling methodology that tests the full payment cycle, and the associated sample testing and statistical estimation must be completed in time to include in the AFR.

    Implementation of this recommendation will result in HUD better safeguarding taxpayer dollars and decrease improper payments.

Chief Information Officer

  •   2021-OE-0001-08
    Sensitive
    Priority

    Define and communicate policies and procedures to ensure that its products, system components, systems, and services comply with its cybersecurity and SCRM requirements. This recommendation includes:

    1. Identification and prioritization of externally provided systems (new and legacy), components, and services.
    2. How HUD maintains awareness of its upstream suppliers.
    3. The integration of acquisition processes tools, and techniques to use the acquisition process to protect the supply chain.
    4. Contract tools or procurement methods to confirm that contractors are meeting their obligations (derived from OIG FISMA metric 14).

    Status

    The Office of the Chief Information Officer (OCIO) estimated it would complete corrective action for this recommendation by August 2023. However, as of December 2023, HUD has not provided a complete corrective action or evidence sufficient to close this recommendation.

    HUD OIG previously consolidated three related recommendations focused on HUD implementing foundational supply chain risk management (SCRM) processes as one Priority Open Recommendation. HUD made progress on implementing those recommendations, including by implementing an SCRM strategy and communicating it to stakeholders. In part because of that progress, OIG is no longer consolidating the three recommendations to focus on establishing core processes to advance HUD’s SCRM program.


    Analysis

    To fully address this recommendation, HUD must establish that it has defined and communicated policies and procedures to ensure that its products, system components, systems, and services comply with its cybersecurity and SCRM requirements.

    Implementation of this recommendation will result in HUD continuing to mature in supply chain risk management, establishing and defining the policies and procedures of SCRM requirements as it relates to systems and system components.

2020-OE-0004 | November 17, 2021

HUD’s Processes for Managing IT Acquisitions

Chief Procurement Officer

  •   2020-OE-0004-03
    Priority

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


    Status

    HUD agreed to an estimated completion date of March 2024. As of October 2023, HUD is currently working on this recommendation and is within the agreed-upon completion date.


    Analysis

    To fully address this recommendation, HUD must provide evidence that it has published its standard operating procedures (SOP). During a meeting with HUD in October 2023, HUD OCPO stated that it will publish the SOPs by March 2024.

    Implementation of this recommendation will result in a defined IT acquisition process workflow standard operation procedure to ensure coordination across program offices.