We recommend that the General Deputy Assistant Secretary for Public and Indian Housing require the Real Estate Assessment Center in coordination with the Office of Field Operations to determine whether the public housing agencies identified as having lead-based paint hazards in their housing developments maintain and implement a plan for managing lead-based paint. For any public housing agency that does not have a plan for the management of lead-based paint in its public housing developments, as appropriate, HUD should inform the public housing agency that it should develop and implement its own plan.

We recommend that the General Deputy Assistant Secretary for Public and Indian Housing require the Real Estate Assessment Center in coordination with the Office of Field Operations to assess the lead-based paint hazard reduction activities performed at the 19 developments associated with 18 public housing agencies reviewed that did not implement interim controls and ongoing maintenance and reevaluation activities or adequately document that previously identified lead-based paint had been abated or treated with interim controls and subjected to ongoing maintenance and reevaluation activities. If those reduction activities did not fully abate the lead-based paint, HUD should ensure that the public housing agencies implement interim controls and ongoing maintenance and reevaluation programs and maintain required documentation.

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, The 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 the 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 had drafted guidance on the de minimis exception to the Lead Safe Housing Rule for PIH, Multifamily Housing, and CPD and submitted it through the clearance process in September 2024.  As of January 2026, OLHCHH continues to revise the draft guidance in consideration of the comments it received during the clearance review process.  However, HUD has not provided an updated target date to complete the agreed upon actions, which was 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.

Ensure there are resources available for further development of geocoding services that fulfill HUD’s responsibilities stated in 43 U.S.C. § 2808(a)(5) and 43 U.S.C. § 2808(a)(12) through the reactivation of the lapsed Geocode Service Center contract.

HUD OCIO should implement procedures to ensure that information in cybersecurity risk registers is obtained accurately, consistently, and in a reproducible format and is used to a. quantify and aggregate security risks, b. normalize cybersecurity risk information across organizational units, and c. prioritize operational risk response (derived from metric 5).

HUD OCIO and the HUD Chief Risk Officer should coordinate to implement procedures to monitor the effectiveness of cybersecurity risk responses to ensure that risk tolerances are maintained at an appropriate level (derived from metric 5).

HUD OCIO and the Office of Administration should implement procedures to ensure proper validation of media sanitization in accordance with HUD Media Protection Procedures 2.0 (February 2022) and form HUD 1067A, Certification of Sanitization (derived from metric 36).

The OIG has determined that the contents of this recommendation would not be appropriate for public disclosure and has therefore limited its distribution to selected officials.

HUD OCIO should ensure that system owners and information system security officers consistently test their ISCPs and upload the test results to CSAM in accordance with HUD’s defined ISCP testing policy (derived from metric 63).

Use the fraud risk inventory to enhance program-specific fraud risk assessments for the HOME program.

Use the fraud risk inventory to enhance program-specific fraud risk assessments for the PBRA program.

Use the fraud risk inventory to enhance program-specific fraud risk assessments for the TBRA and Operating Fund programs.

Consider allowing grantees additional time to spend the program funding on eligible activities to meet the 80 percent spending deadline.

Consider streamlining program requirements to help grantees promptly use program funds to assist those impacted by the pandemic or for activities that prepare for, prevent, or respond to the coronavirus.

Provide adequate documentation to support that the $2,588,362 in CDBG-DR funds for three unsupported project and program management services expenditures cited in this report was spent for supported, necessary, and reasonable costs. Any amount for which adequate support cannot be provided should be repaid from non-Federal funds.

Update its procurement policy to clearly define the process, which includes timing and the procurement types, for conducting an independent cost estimate and a price analysis.

Provide training to State staff to ensure that it understands and follows (1) requirements to maintain adequate documentation to support that program disbursements are eligible and reasonable and (2) procurement requirements, including independent cost estimates, cost analyses, proposal scoring, and the timely checking of the SAM data for contractors’ eligibility.

We recommend that the Director of HUD’s Newark Office of Public Housing make a determination regarding outstanding agreement income, including whether those unspent funds should be returned to the public housing agencies, thereby putting up to $697,912 to better use, including $478,165 related to Asbury Park and $219,747 related to Red Bank.

We recommend that the Director of HUD’s Newark Office of Public Housing provide technical assistance to Long Branch and require updates to its procedures to ensure that it properly classifies income received under any future agreements or activities.

We recommend that the Director of HUD’s Newark Office of Public Housing require Long Branch to prepare and provide support for a reasonable estimate of the amount of employee time used to perform services for Asbury Park and Red Bank and the amount of Long Branch program funds used to pay for that time. This estimate should include all employees known or believed to have provided services under the agreements based on language in the agreements, incentive payments, after-the-fact documentation provided, and any other applicable knowledge or documentation, which would show that the employees performed work under the agreements.