Establish a centralized acquisition tracking system that allows for input and monitoring by all offices involved with the IT acquisition process by: a. Developing a plan with detailed implementation milestones; b. Obtaining appropriate approvals and funding; and c. Implementing a centralized acquisition tracking system, based on the implementation plan and approvals from 4a and 4b.

Develop a plan for clearly defining, communicating, and enforcing IT acquisition process standards, including acquisition process roles and responsibilities.

We recommend that HUD’s Chief Administrative Officer implement the corrective actions and internal process improvements in internal control developed as a result of the Chief Financial Officer’s investigation addressed in recommendation 1A.

We recommend that HUD’s Chief Administrative Officer provide training to responsible staff and officials to ensure that those that may be involved with negotiating any GSA rent credits, like the credits addressed in this report, identify such potential rent credit transactions and follow the corrective actions and process improvements implemented to resolve recommendation 1B.

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.

Designate a Senior Agency Official for Records Management at the Assistant Secretary level or its equivalent.

Update and issue agency formal records policy, including detailed procedures and requirements for completing and maintaining program office and agencywide inventories of systems, records, and PII.

Update and obtain final NARA approval of all HUD records retention schedules, including the Capstone email schedule, to comply with Federal requirements, including OMB M-19-21.

Develop and approve an enterprise strategy to meet all M-19-21 electronic transition requirements.

Issue a formal policy and requirements for managing CUI.

Establish and disseminate a policy on safeguarding or prohibiting the transportation of PII records out of the office for telework purposes.

Complete the development of performance measures and establish a formal records evaluation process to measure the effectiveness and progress of the records management program.

Standardize processes and duties for all RMLOs.

Conduct a staffing resource assessment for the HUD records program and identify any skills gaps or resource needs.

Assign independent, contract officers to review and certify the initiating contract buyer’s compliance with policies for initiating and authorizing interagency agreements and later modifications for all amounts in accordance with Acquisition Instruction 13-07, HUD Contracting Officers.

Ensure that contracting officers and OCPO field offices review and follow the records management policies and procedures, including completing and signing Forms 7600A and 7600B, to ensure consistency among contract officers approving interagency agreements in the procurement system of record.

Implement a process to periodically audit or reconcile ARC’s records.

Implement a process to periodically review approving officials’ span of control to ensure that the requirement is not exceeded.

Implement a process with ARC to ensure that cardholders and approving officials are notified before purchase card training is due to allow training to be completed in a timely manner.

Implement a process to ensure that purchase cards are suspended when a cardholder or approving official fails to complete training.