We recommend that the Director for HUD’s Office of Disaster Recovery develop and implement controls to ensure that program income balance discrepancies are identified and corrected.

We recommend that the Director for HUD’s Office of Disaster Recovery develop and implement controls to ensure that untimely FFRs are identified and corrected.

We recommend that the Director for HUD’s Office of Disaster Recovery implement quality control procedures to ensure that HUD staff completes the action plan and QPR checklists.

For any of the 3,024 loans found to be subject to the temporary policy or otherwise ineligible for insurance, require the lenders to execute indemnification agreements covering a period of at least 5 years or reimburse HUD for any claims to put up to $26,840,071 to better use by protecting HUD against potential losses. For any indemnification agreements executed, HUD should properly store the agreements and record the agreement data.

We recommend that the Chief Procurement Officer update HUD’s field service manager contract monitoring plan and FSM qualitative monitoring databases used to monitor contractor performance to align with the QASP and contractual requirements as noted in recommendation 1G below.

Develop and implement an agencywide crisis readiness plan addressing likely hazards arising from a crisis. This guidance should include all key elements that meet CIGFO crisis guidance.

We recommend that the Deputy Assistant Secretary for Public Housing and Voucher Programs enhance SEMAP or develop a new performance measurement process that would identify PHAs with underperforming HCV Programs, which should include an assessment of PHAs’ ability to maximize assistance to house families.

We recommend that the Deputy Assistant Secretary for Field Operations provide training and guidance to field office program staff on SEMAP scoring, rating, and verification procedures, including confirmatory reviews, quality control reviews, and adjustments, as appropriate, for the revised SEMAP process.

We recommend that the Director of CPD’s Office of Disaster Recovery adopt LMI benchmarking to ensure that grantees budget adequate funds to LMI at significant milestones in the grant lifecycle.

We recommend that the Director of CPD’s Office of Disaster Recovery make changes to the action plan process so that the action plan calculates an overall LMI percentage.

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 13, 2024, the PIH Office of Field Operations (OFO) had completed its outreach data collection and identified 9 public housing authorities that had not completed the required EBLL reporting actions and that OFO informed the field office directors overseeing the appropriate PHAs that they had until November 6, 2024, to upload the proper information to the trackers. As of January 29, 2025, OFO field office directors and their staff were still updating and inputting EBLL cases and relevant documentation into the EBLL tracker due to delays in responses from PHAs. The estimated completion date is February 28, 2025.

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 demonstrate 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.

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:

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

Status

On January 17, 2025, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) informed HUD OIG that the Office of the Federal Register published a notice, Modifying HUD’s Elevated Blood Lead Level Threshold for Children Under Age 6 Who Are Living in Certain HUD-Assisted Target Housing Covered by the Lead Safe Housing Rule. The notice announced that HUD is lowering its EBLL threshold from 5 to 3.5 µg/dL for a child under the age of 6, consistent with the CDC’s current blood lead reference value of 3.5 µg/dL, effective January 17, 2025. Next, OLHCHH will assist the Office of Community Planning and Development, the Office of Multifamily Housing Programs, and the Office of Public and Indian Housing to draft, circulate, and publish EBLL notices. The estimated completion date is June 30, 2025.

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.

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

Identify short- and long-term plans for the RPA program that align its capabilities, staffing needs, funding projections, and mission needs.

Implement procedures to capture and monitor centralized logs to maintain appropriate visibility into bot activities and provide for auditability of bot actions.

Implement procedures to periodically review RPA system access and remove access for users that are not authorized or no longer have a need to use the system.

Implement procedures to ensure that attended bots use the security rights and credentials of the attending user.

Assess its help desk system against other technical solutions and ensure that the help desk solution used captures complete data on technical support requests. This measure includes but is not limited to ensuring that sequence gaps are properly documented or do not occur, valid transactions are accepted by the help desk system, rejected transactions are identified, and the history of each transaction is retained.

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 has made steady progress in building its Fraud Risk Management program. In FY 2024, HUD received Congressional approval to establish the Office of the Chief Risk Officer (OCRO). With its Fraud Risk Management Policy in place since 2022, OCRO worked with the HUD Risk Management Council to develop the Department’s approach and establish a cross-functional approach for Fraud Risk Management program accountability. The CRO also completed a fraud risk exposure assessment method that enables the Department to provide a risk-based approach to prioritize program fraud risk assessments and a department-level Fraud Risk Management Playbook to align HUD’s cross-functional activities and accountability to the GAO Fraud Risk Framework and CFO Council practices. The CRO is also working on tools and templates that are being customized for HUD program offices to help them complete their fraud risk assessments. Priority program offices are targeted to complete fraud risk assessments in 2025.

Analysis

While HUD has made progress in the area of fraud risk management, there is still work to be done for HUD to complete an entity-wide fraud risk assessment. HUD's exposure analysis will help it to determine where to focus its efforts. The Department still needs to conduct program-specific fraud risk assessments. Based on the demonstration by Multifamily Housing (MFH), we believe that MFH has made great progress in its fraud risk assessment, and we are encouraged that it has identified areas of weakness that it plans to target. However, Public and Indian Housing (PIH) and Community Planning and Development (CPD) have not been able to demonstrate progress in this area. We believe that the tools and templates the OCRO is developing, along with the continued support, will help PIH and CPD to complete these assessments.

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.

Develop and implement a strategy for collecting and analyzing agency-wide data, to include subrecipient and beneficiary data, to identify trends and potential indicators of fraud across programs.

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.