Create a plan and timeline that outlines OFO’s proposal to make necessary improvements to the EBLL tracker, such as moving it to a different platform.

Provide field office staff access to historical data in the EBLL tracker to be readily available as needed, with adequate protection of PII.

Update the EBLL tracker to show whether one or multiple children have an EBLL and whether the unit, building, or development previously had an EBLL reported.

Update the EBLL tracker by including which data fields are required, establishing what type of information can be entered into each data field, and disallowing case closure if required information is missing.

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. OFO had not received confirmation that the data had been uploaded.

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.

Create a plan and timeline that outlines OFO’s proposal to move the LBPR tracker to a different platform.

Develop a timeliness standard in the LBPR tracker to establish expectations for how often field office staff must reach out to PHAs on the LBPR tracker to discuss measures that will resolve cases in a timely manner.

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

On November 22, 2024, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) informed HUD OIG that the final Federal Register Notice was published for its request for information from Lead Safe Housing Rule stakeholders and the general public on its proposal to adopt the CDC's BLRV of 3.5 µg/dL as its EBLL under the rule. The public comment period ended on October 11, 2024, and as of October 15, 2024, all 25 comments submitted have been posted to https://www.regulations.gov/docket/HUD-2024-0069/comments. OLHCHH is reviewing the public comments in preparing to decide whether to change the rule's current level, and if so, to what level.

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 BLRV of 3.5 ug/dL. Alternatively, OLHCHH must establish that its research led it to determine that environmental interventions in cases of children with EBLLs between 3.5 and 4.9 µg/dL were ineffective in reducing the children’s blood lead levels and that lowering HUD’s EBLL regulation to 3.5 µg/dL is unnecessary.

Implementation of this recommendation will help ensure children living in public housing with EBLLs 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.

Implement a quality control review to ensure that successive below-60 REAC inspection score flags are entered into APPS.

Update APPS to automatically flag a property that receives successive below-60 REAC inspection scores.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to clearly communicate that homeowners who had not previously requested forbearance by September 30, 2021, are eligible to request forbearance from their servicer through the end of the COVID-19 National Emergency.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to include information on the various COVID-19 loss mitigation options servicers may offer homeowners with FHA-insured forward mortgages who are exiting COVID-19 forbearance.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to include details about the protections and loss mitigation options available for homeowners with FHA-insured reverse mortgages. This information could include (1) instructions for requesting an extension, (2) a statement notifying homeowners that they should not be charged late fees or penalties, (3) a chart showing the extension periods and related deadlines, and (4) information on the various loss mitigation options available for homeowners with FHA-insured reverse mortgages who are exiting a COVID-19 HECM extension.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to include relevant information on the U.S. Department of the Treasury’s Homeowner Assistance Fund.

We recommend that the Deputy Assistant Secretary for Single Family Housing work with the Office of Public Affairs, Office of Housing Counseling, and other offices within HUD to develop a detailed communication strategy for how and when it plans to use websites, letters, and other methods to proactively notify homeowners about relief programs, protections, and loss mitigation options during disasters and national emergencies. The strategy could include processes to ensure that (1) key information is provided or made available in a timely manner and kept up-to-date, (2) information is communicated clearly and consistently across mediums, and is linked together when possible, and (3) letters are mailed to struggling homeowners when needed. It could also articulate the methods HUD will use to reach homeowners without internet access.

Research, evaluate, and implement technical or alternative solutions to deploy essential computer software updates using appropriate secure methods to ensure that computer security updates occur in a timely manner to minimize risk to HUD’s systems and operations