Deobligate the 835 administrative obligations totaling $38,525,836.88 identified for deobligation during the fiscal year 2024 OOR that had not been deobligated as of February 28, 2025.

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.

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).

Develop a standard operating procedure for the monthly transaction review that aligns with the HUD policy and includes specific procedures on how to (1) identify and review common transactions that raise the level of risk in the program (for example, personal use purchases, other prohibited purchases, unauthorized purchases or services, split purchases, fraudulent purchases, FAR violation purchases, etc.), (2) methodically select transactions for investigation, and (3) follow up on identified potential improper transactions, including record-keeping requirements.

HUD’s Office of Administration, in coordination with OCIO, should update and communicate its PII minimization plan. The plan should include detailed procedures to regularly review and remove unnecessary PII collections in accordance with OMB Circular A-130 (IG FISMA metric 35).

We recommend that the Chief Procurement Officer update HUD’s field service manager contract monitoring plan and FSM qualitative monitoring databases used to monitor contractor performance to align with the QASP and contractual requirements as noted in recommendation 1G below.

We recommend that the Chief Procurement Officer direct the contracting officers to review the current FSM contracts’ QASP and update accordingly to ensure that all minimum contract requirements are included.

We recommend that the Chief Procurement Officer direct the contracting officers to oversee the implementation of the current FSM contracts’ QASP.

We recommend that the Chief Procurement Officer require the contracting officers to implement the policies and procedures in the HUD Acquisition Policy and Procedure Handbook for completion of HUD’s FSM contractor performance assessment reports in CPARS to ensure that Government past performance is documented properly and in a timely manner, at least annually, for use by all Federal agencies and maintained in the contract files.

We recommend that the Chief Procurement Officer require all staff involved in the oversight of FSM contracts to maintain the required documentation in the official contract file identified by HUD policy to support the contracts.

We recommend that the Chief Procurement Officer require the contracting officers to formally designate CORs in a timely manner and maintain the required documentation in the proper location identified in the relevant HUD policies and procedures, which fully supports the CORs’ oversight of the FSM contract.

Ensure that future policies and guidance developed to return HUD’s offices to normal operations include the specific criteria, metrics, and defined geographic area to be used by all offices as applicable.

Develop and implement sufficient policies and controls to ensure that (1) applicable criteria in any future guidance are met and all safety measures are sufficiently completed before returning HUD’s offices to normal operations and (2) sufficient documentation is maintained to support that the applicable criteria were met.

Conduct a departmentwide comprehensive staff capacity assessment to identify resource and skills gaps of staff involved in IT acquisitions.

Develop a departmentwide human capital plan or evaluate and revise existing plans to guide the recruitment, retention, and skill development of staff involved in IT acquisitions. The plan should include related metrics to measure plan implementation and effectiveness.

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

The Office of the Chief Procurement Officer (OCPO) had agreed to an estimated completion date of March 2024. In November 2024, OCPO submitted additional evidence for closure; however, the evidence did not identify how the revisions to the process will address efficiency issues. The OIG requested 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.