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.

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.

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 July 30, 2025, PIH’s Office of Field Operations (OFO) has coordinated with the Office of Lead Hazard Control and Healthy Homes (OLHCHH) on the EBLL data requested and obtained from PHAs.  OFO’s timeline to finish implementing the recommendation:

• Conduct and complete research and comparison by September 30, 2025.  OFO will need to ensure that any EBLL documentation received from PHAs is accurate and accounted for in its EBLL tracked.
• Complete final review and revisions by October 31, 2025.  OFO will need to contact PHAs for any necessary revisions or missing documentation.
• Stakeholder feedback and incorporation of edits by December 31, 2025.  Stakeholders include OFO leadership and PIH’s Real Estate Assessment Center (REAC).
• Final approvals and sign offs by OFO leadership by March 27, 2026.
• Final reporting and closure documentation by March 31, 2026.  OFO will develop guidance and training materials to ensure that OFO field offices are able to properly communicate EBLL guidance to PHAs.

The estimated completion date is March 31, 2026.  The original estimated completion date was June 30, 2024, and was revised to account for (1) delays in responses from various PHAs in providing current and accurate information on EBLLs to OFO and (2) stakeholder input and review from various offices across HUD.

Analysis

To fully address this recommendation, OFO must provide evidence of completion of each step in its timeline, such as research and comparisons conducted and communications with stakeholders in HUD and with PHAs.

Implementation of this recommendation will help ensure that EBLL cases are reported and recorded appropriately in the EBLL tracker.

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.