Develop and implement a policy that clearly defines roles and responsibilities for Office of Multifamily Housing Programs’ staff for EBLL-related requirements, including the oversight of property owners’ compliance with these requirements.

Establish processes to track reported EBLLs for the Office of Multifamily Housing Programs to easily identify the status of owners’ remediation efforts for units that were the source of the confirmed EBLL.

Develop and implement uniform procedures for the FSM desk monitoring review, including a second level review for the FSM monitoring reviews and process for each inspection type.

Update the FSM monitoring plan and FSM qualitative monitoring database to: (a) clearly define the monitoring questions, (b) include a section for Q7 New Not Ready to Show (NRTS) properties, (c) define which routine inspection reports will be reviewed to conduct the routine inspection monitoring reviews and (d) develop a monitoring question to evaluate photo date stamps.

Ensure that program officials periodically provide all FSM CORs and staff involved in the monitoring process uniform property inspection training.

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.

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.

Develop a standard operating procedure to ensure that the OCFO is 1) monitoring the DNP Computer Matching agreement to ensure continuity, 2) reporting accurately on its DNP matching, and 3) working with program offices to adjudicate any payments that are identified as potentially improper during the computer matching process.

Work with Multifamily Housing to investigate the 11 of 24 entities with expired SAM.gov registrations to determine if those entities should have received payments totaling $212,208,450 and perform the required follow-up actions once a determination is made.