Develop ALU engagement standards and incorporate them into acquisition policies and procedures.

Update guidance to clarify the different roles and responsibilities of the ALU, CO, CS, and COR.

We recommend that the Chief Procurement Officer develop, implement, and communicate requirements for program offices to establish written minimum roles and responsibilities for their respective procurement management functions, including but not limited to CORs, PMs, and SMEs.

Revise HUD’s Controlled Unclassified Information Policy to include the anti-gag provision.

Revise HUD’s Controlled Unclassified Information Policy to state that (a) nondisclosure forms and agreements must include the anti-gag provision as required by law and (b) confidentiality clauses in personnel settlement agreements must include the anti-gag provision if the clause restricts disclosure of any other information beyond the terms and conditions of the agreement itself.

Implement a plan to annually survey all HUD program offices to identify nondisclosure policies, forms, and agreements issued and to determine whether they include the anti-gag provision as required by WPEA and, as necessary, to take corrective action to ensure that they include the anti-gag provision.

Communicate across HUD that (a) HUD employees are required to include the anti-gag provision in nondisclosure policies, forms, and agreements applicable to HUD employees and (b) program offices should consider requiring their employees to request OGC assistance when implementing and enforcing nondisclosure policies, forms, and agreements applicable to HUD employees.

Revise the Ginnie Mae Confidential Information Policy to state that in the future, (a) nondisclosure forms and agreements must include the anti-gag provision as required by law and (b) confidentiality clauses in personnel settlement agreements must include the anti-gag provision if the clause restricts disclosure of any other information beyond the terms and conditions of the agreement itself.

Review whether potential violations of the Antideficiency Act took place because of implementing or enforcing any nondisclosure policies, forms, or agreements that do not include the anti-gag provision as required by law. If it is determined that a violation occurred, the Chief Financial Officer should take disciplinary actions as appropriate and report the identified violations to the oversight authorities, including the HUD Secretary, the President, the Office of Management and Budget, Congress, and the Comptroller General.

HUD’s Privacy Office should require program offices to periodically review systems in all environments (testing, development, production) for unnecessary disclosure of personally identifiable information (PII).

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.

Housing should include zero trust requirements as part of the Housing Strategic Roadmap for Housing Modernization.

Housing should refine access controls within the FHA Catalyst modules that are dynamic, are tailored to user actions, and require continuous reauthentication to ensure that users have access only to information needed.

Housing should coordinate with HUD’s SOC to a. Ensure that FHA Catalyst user behavior monitoring logs are regularly captured and adequately reviewed for discrepancies in user activities. b. Establish program office responsibility for the log review process.  

HUD OCIO should identify needs to address Federal requirements by performing a gap analysis on its zero trust architecture strategic plan.

HUD OCIO should establish a zero trust architecture implementation plan that includes milestones and resources to address all zero trust pillars.

HUD OCIO should develop system policies and procedures for dynamic access controls that include just-in-time and just-enough access tailored to individual actions and individual resource needs.

HUD OCIO should capture risks that are associated with zero trust architecture implementation and document these risks in its risk register.

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.

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.