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The most significant management and performance challenges facing HUD.
| Oversight Area | Priority Recommendations | Open Recommendations |
|---|---|---|
| Housing Assistance | 75 | 100 |
| Community Development | 3 | 75 |
| Disaster Recovery | 3 | 82 |
| Financial Risk and Accountability | 6 | 130 |
| Technology and Cybersecurity | 4 | 88 |
| Health and Safety | 1 | 53 |
| HUD's Operations | 4 | 100 |
| Total | 96 | 628 |
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Implement adequate policies, procedures, and controls to ensure that public housing properties will be inspected within required timeframes.
Status
As of July 2025, according to HUD, all development and enhancement of the NSPIRE software system are presently on hold pending Administrative guidance on HUD funded software system improvements. Additionally, the required software changes recommended under this finding depend on the final Public Housing Assessment System (PHAS) rule, but most regulatory work has been paused for review per Executive Order from the Administration. Pending the required resources and funding approval, HUD cannot move forward at this time. According to HUD, it has planned for and proposed the needed improvements to meet this recommendation and will provide updates when available. The current final action target date is September 30, 2025.
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 the required timeframes.
Implementation of this recommendation will result in HUD accurately tracking the dates on which public housing properties should be inspected and that they are timely completed.
Due to the uncertainty of when software changes to NSPIRE can take place to enforce the timing of inspections, REAC cannot enforce the requirements of inspection timing.
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:
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 July 2025, OLHCHH continues to revise the draft guidance in consideration of the comments it received during the clearance review process. HUD did not provide an updated target date to complete the agreed upon actions, which had been 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.
Require 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. As of November 2024, PIH reported that inspections have had a slow start due to procurement delays. Additionally, the NSPIRE system did not get the requested functionality to collect lead inspections. As of July 2025, HUD is conducting an inventory of the properties that are missing lead-based paint inspections. Once all the inspections have been received and uploaded into the NSPIRE system, it will use the information to estimate the number of public housing developments and associated units that contain lead-based paint and lead-based paint hazards. Among other factors, based on current legislative requirements of unit inspection cycle, HUD estimates that it will collect the lead-based paint inspection reports for final properties by December 31, 2028. Therefore, with OIG concurrence, HUD has revised the final action target date to February 2, 2029, to fully implement the recommendation.
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.
The CDO should coordinate with HUD’s Records Office, Privacy Office, and program offices to develop data policies and procedures for data inventory, categorization, and labeling in support of zero trust architecture.
Status
HUD provided a corrective action plan for this recommendation in May 2025. The planned corrective action requires the agency to acquire a data management system, develop cataloging standards, and coordinate with the program offices stated in the recommendation to ensure data is handled in a secure manner. The procurement process has not yet begun, yet in their initial plans, HUD will require vendor support to develop this tool. The estimated completion date of this recommendation is September 2027.
Analysis
By addressing the recommendation, HUD will be positioned better to protect and prioritize protection for data in its IT systems. This will allow HUD to have a better understanding of the specifics of the most sensitive data as well as allow recommendation 2024-OE-0002a-03 to be addressed by HUD.
HUD maintains billions of records of PII and sensitive data within IT systems and the IT environment. Knowing more specifics about the data is essential in the ability to protect and recover from attempted exfiltration attempts.
Determine the appropriate timeframe for when initial management and occupancy reviews (MORs) should be completed for all properties that convert under the Rental Assistance Demonstration and issue updated guidance that includes a system to track the timeliness of initial MORs.
Status
Given current resource constraints, HUD will create guidance based on risk-based Management and Occupancy Review (MOR) parameters to ensure that field staff and leadership perform the initial MOR for PBRA RAD-converted properties. This guidance will specify which assessments can be done on-site or remotely (such as desk reviews). Furthermore, the guidance will require that the existing MOR tracking tools (e.g., PowerApps) be used to monitor planning for the MORs and progress throughout, until final closing of the review. As of July 2025, HUD has completed 233 MORs for the 834 RAD-converted properties. The tool allows HUD staff to filter by the type of conversion (e.g. RAD PIH, RAD PRAC, etc.) as well as other risk indicators (e.g., troubled status), location and servicer (e.g. Account Executive, Senior Account Executive, Resolution Specialist). OIG has concurred with HUD's corrective action plan that it will create guidance to allow for a risk-based approach for completing MORs, which HUD anticipates completing by September 30, 2025.
Analysis
To implement this recommendation, HUD needs to provide evidence that it has updated guidance with appropriate timeframe for conducting MORs and a system to track the timeliness of initial MORs. Failure to determine the timing of the initial MORs could delay HUD's performance of them, which may result in property owners' untimely corrective actions, and thus potentially impact the health and safety of families.
The implementation of this recommendation has the potential to directly impact the health and safety of families.
Complete the initial management and occupancy reviews (MORs) for the Rental Assistance Demonstration properties that have not had an initial MOR.
Status
Given current resource constraints, HUD will create guidance based on risk-based Management and Occupancy Review (MOR) parameters to ensure that field staff and leadership perform the initial MOR for PBRA RAD-converted properties. This guidance will specify which assessments can be done on-site or remotely (such as desk reviews). The guidance will outline the timing requirements for when the initial MOR should be completed. To date, HUD staff have completed 233 MORs for the 834 RAD-converted properties. HUD anticipates completing the initial MORs for the remaining 501 properties by the end of 2027. HUD HQ and field staff will use the Power BI MOR tool to track the MOR through the stages: scheduling, review, issuance of report and finally the closing of the report. As of July 2025, OIG has concurred with HUD's corrective action plan that HUD will begin completing the initial MORs using a risk-based approach. The target completion date for HUD to demonstrate it is taking corrective action is set for December 31, 2025.
Analysis
Completing initial MORs would assist HUD in holding property owners accountable for maintaining the conditions of their properties and sufficient reserve for replacement accounts balances, which could impact property owners' ability to make needed capital repairs.
The recommended corrective action has the potential to directly impact the health and safety of families.
Develop and implement a plan to determine how to implement the risk-based approach to review the Rental Assistance Demonstration properties that have not had subsequent management and occupancy reviews (MORs) in more than 3 years and to require periodic MORs going forward.
Status
Given the current resource constraints, HUD will create guidance based on risk-based Management and Occupancy Review (MOR) parameters to ensure that field staff and leadership perform MORs using a risk-based model for PBRA RAD-converted properties. This guidance will specify which assessments can be done on-site or remotely (such as desk reviews) and the timing requirements for when ongoing MORs should be scheduled once the initial MOR is completed. As of July 2025, 641 MORs need to be scheduled for the Office of Asset Management's portfolio of 834 RAD-converted properties. Of those, 85 properties are managed by Performance-Based Contract Administrators (PBCA). Depending on risk indicators for each property, MORs will be scheduled accordingly. HUD reported that its staff resources are limited in comparison to the PBCAs and will therefore take a risk-based approach for prioritizing the MORs that HUD staff must complete. The Office of Asset Management will develop a plan to address the backlog of RAD-converted MORs using the current risk factors which include the physical condition, last MOR score, financial health of the property and other indicators. The target completion date is December 31, 2025.
Analysis
Developing a plan to implement the risk-based approach would establish the criteria for identifying properties that are at a higher risk of noncompliance.
The recommended corrective action would help HUD to monitor property owners' compliance with its requirements and thus, potentially protect families from living in unsafe units.
Determine an appropriate timeframe in which non-FHA-insured Project-Based Rental Assistance (PBRA) properties converted under the Rental Assistance Demonstration should be initially inspected, work with HUD’s Real Estate Assessment Center (REAC) to ensure that inspections are ordered and completed within that timeframe, and update HUD’s publicly available and internal guidance to ensure consistent messaging in accordance with HUD’s determination.
Status
As of July 2025, Multifamily Housing planned to develop and implement adequate policies, procedures, and controls to ensure non-FHA insured PBRA properties under RAD are inspected within 90 days after the original date of the HAP contract, unless the property has been approved for inspection delay during major rehabilitation, then within 90 days after the end of the approved inspection delay. Further, Multifamily Housing will provide appropriate updated guidance to both internal and external partners relative to non-FHA-insured PBRA properties converted under RAD. The target completion date is September 30, 2025.
Analysis
Determining the appropriate timeframe for initial inspections would result in the timely identification and correction of life-threatening and non-life-threatening deficiencies.
The recommended corrective action has the potential to directly impact the health and safety of families.
Develop a comprehensive process to ensure that complaints received by HUD’s Multifamily Housing Clearinghouse are resolved in a timely manner.
Status
In October 2023, the Office of Multifamily Housing reported that it had sought funding for system enhancements to coordinate tenant complaints. HUD is transitioning the Multifamily Clearinghouse responsibilities to the Federal Housing Administration (FHA) Resource Center. The FHA Resource Center has a system that will allow tracking and monitoring of customer calls. As of July 11, 2025, the Office of Multifamily Housing requested the closure of this recommendation because it did not receive the requested funding from Congress for system enhancements, and it believes there is no prospect of future funding. Further, its alternative action of using the FHA Resource Center to track and monitor customer calls did not work. Developing a comprehensive process for intaking, monitoring, and tracking health and safety complaints would require a system enhancement or creation of a new system, and HUD has repeatedly attempted to obtain funding from Congress to no avail. OIG is in the process of collaborating with HUD on finding a potential corrective action to resolve the recommendation.
Analysis
To fully address this recommendation, HUD needs to develop a comprehensive process to ensure that complaints received by HUD are resolved in a timely manner.
Implementation of this recommendation will result in a timelier resolution of complaints submitted by those living in multifamily member housing units.
Develop agencywide policies and procedures for the intake, monitoring, and tracking of health and safety complaints.
Status
In October 2023, HUD stated that it will develop policies and procedures for Multifamily properties for the intake, monitoring, and tracking of health and safety complaints it receives. The Office of Multifamily Housing has not yet updated its policies and procedures. With no comprehensive, automated, real-time system in place, there was no direction to give the field staff, Multifamily Clearinghouse, or the Performance Based Contract Administrators other than what they were already doing. HUD was in the process of developing an automated monitoring system in the FHA resource center to allow tracking of individual calls and the call’s subject, such as health and safety. HUD missed the final action target date of December 31, 2022, and a new completion goal was set for February 2025. As of July 14, 2025, HUD is seeking closure for this recommendation due to unavailability of funds. HUD stated that its issuance of policies and procedures for a comprehensive process was contingent on the development of a tracking system for the complaint process, for which it has repeatedly requested funding from Congress to no avail. OIG is in the process of collaborating with HUD on finding a potential corrective action to resolve outstanding concerns.
Analysis
To fully address this recommendation, HUD must provide evidence that it has developed and implemented policies and procedures for the Multifamily properties for the intake, monitoring, and tracking of health and safety complaints it receives when using the FHA’s automated monitoring system.
Implementation of this recommendation will result in HUD having a more efficient process for taking in, monitoring, and tracking health and safety complaints and aid HUD in more efficiently addressing those complaints.
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
In November 2024, OCPO submitted an IT Acquisition Workflow Report and a document outlining responsibilities as evidence for closure. Although these documents clarified existing roles and documented one sample workflow, they did not propose or implement revised IT-acquisition policies or procedures producing measurable improvements. As of July 2025, OIG received no further information that identifies improvements in the IT acquisition process.
Analysis
To fully address this recommendation, HUD must provide evidence that it has published its standard operating procedures resulting from its evaluation of workflows and efforts to simplify processes and facilitate more effective coordination.
Implementation of this recommendation will result in defined IT acquisition process workflow procedures to increase efficiency and ensure coordination across program offices.
Define and communicate policies and procedures to ensure that its products, system components, systems, and services comply with its cybersecurity and supply chain risk management (SCRM) requirements. This recommendation includes (a) identification and prioritization of externally provided systems (new and legacy), components, and services; (b) how HUD maintains awareness of its upstream suppliers; (c) the integration of acquisition processes, tools, and techniques to use the acquisition process to protect the supply chain; and (d) contract tools or procurement methods to confirm that contractors are meeting their obligations.
Corrective Action
HUD finalized its Supply Chain Risk Management (SCRM) policy in April 2025, which utilizes a SCRM questionnaire to assess each vendor’s supply chain risk, and identifies and prioritizes risks accordingly. HUD’s SCRM program team manages a supply chain risk register which records prior and current vendors, and those that have undergone risk assessments to maintain visibility into its upstream suppliers and track changes over time. HUD also used multiple tools such as supply chain risk criteria and sourcing research and market analysis to evaluate vendors and strengthen protection of the supply chain during acquisition. By implementing these procedures, as well as, having HUD’s program management team conducting annual and quarterly performance reviews for all vendors, HUD ensures contractors are meeting their contractual obligations.
Update HUD Handbook 1900.40, Do Not Pay policy, to clearly define the responsibilities for all parties and align it with current laws, processes, and procedures. This should include defining responsibilities for preaward and prepayment verification, and developing a process and governance structure to ensure that preaward and prepayment verification are consistently performed across HUD’s programs.
Status
HUD has until August 25, 2025, to provide its corrective action plan to OIG for review.
Analysis
Updating the HUD Handbook 1900.40 will define responsible parties for ensuring compliance with the Do Not Pay Initiative (DNP).
The implementation of this recommendation will result in consistent use of DNP, allowing for instant verification of eligibility across the billions in payments that HUD processes, resulting in the reduction of future improper payments.
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