Develop and implement adequate procedures and controls to ensure that (1) staff issues notices of violation and default within 15 calendar days of the inspection report release date and (2) the Office of Multifamily Asset Management and Portfolio Oversight is made aware when notices are not issued within 15 calendar days after the inspection report release date and takes action as appropriate to ensure that future notices are issued in a timely manner. 

Corrective Action

HUD’s Office of Multifamily Housing created procedures to identify failed inspections and notify the appropriate field office that a property in their portfolio had recently failed inspection. The procedures included a timeline for issuing a Notice of Violation/Notice of Default to the owner of the property. Implementation of the recommendation ensures that multifamily property owners are notified of deficiencies in a timely manner to take corrective actions.

Include language in future notices of violation and default clearly stating that owners are required to inspect all units (including vacant units), common areas, grounds, building systems, and sites as part of the owner survey and require owners to include sufficient detail in the surveys to show (1) when the survey was conducted and (2) that the survey was a complete survey of the project.

Corrective Action

HUD’s Office of Multifamily Housing updated the language in the template document to be used in future notices of violation and default, clearly stating that owners are required to inspect all units (including vacant units), common areas, grounds, building systems, and sites as part of the owner survey and require owners to include sufficient detail in the surveys to show (1) when the survey was conducted and (2) that the survey was a complete survey of the project. Specifically, HUD notified all Asset Management Division Directors informing them of the updates to the templates and instructed them to use the templates. The implementation of this recommendation has the potential to positively and directly impact the health and safety of families.

Develop and implement adequate policies, procedures, and controls to ensure that owner certifications and surveys and other relevant documents related to properties that fail inspections or are noted as having EHS deficiencies are maintained and retrievable from an easily accessible location.

Develop and implement adequate controls to ensure that HUD staff with the appropriate level of authority approves extensions to the notices of violation and default cure periods in writing and that documentation is maintained to support such approvals.

Modify the queries used to generate the schedules of properties that accompany the reports to Congress to consider a larger range of dates to ensure that properties that failed consecutive inspections are appropriately identified on all applicable schedules.

Assess and streamline the processes for preparing, reviewing, and approving the reports as appropriate to ensure that the reports are submitted to Congress on or before the required due date.

Implement adequate procedures and controls to ensure that documentation is maintained to support that the reports were submitted to Congress.

Determine whether the funds that were drawn in error need to be repaid to HUD and whether other remediation actions are appropriate.

HUD’s Office of Administration, in coordination with OCIO, should update and communicate its PII minimization plan. The plan should include detailed procedures to regularly review and remove unnecessary PII collections in accordance with OMB Circular A-130 (IG FISMA metric 35).

HUD OCIO should implement a process to consistently update and maintain its inventory of hardware assets and ensure that the inventory is consistent with the automated discovery scans used to perform vulnerability, configurations, and continuous diagnostics and mitigation scans and use this inventory to consistently remove unauthorized hardware assets from the HUD network (IG FISMA metrics 2, 20, and 21).

HUD OCIO should report at least 80 percent of its government-furnished equipment through the DHS CDM program (IG FISMA metric 2).

HUD OCIO should implement procedures to ensure that digital identity risk assessments have been performed and documented in accordance with HUD’s defined procedures and Federal guidelines (IG FISMA metrics 30 and 31).

HUD OCIO should develop and implement processes to monitor and analyze qualitative and quantitative performance measures for the effectiveness of its ISCM program (IG FISMA metric 47).

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.

We recommend that HUD’s Deputy Assistant Secretary for Single Family Housing update policies and procedures regarding discrimination complaints to ensure consistency among customer service representatives in rerouting these complaints to FHEO.

We recommend that HUD’s Deputy Assistant Secretary for Single Family Housing ensure that the FHA Resource Center updates its training program to ensure that refresher training on housing discrimination is regularly provided to staff (such as monthly, quarterly, semiannually, etc.).