Review all executed repayment agreements in HUD’s Tenant Rental Assistance Certification System (TRACS) to determine which repayment agreements have not been fully repaid and represent an amount owed to HUD and work with OCFO to record these receivables.

Include a field in TRACS to identify which repayment agreements represent an amount owed to HUD and implement controls to ensure the accuracy of the listing in TRACS.

Develop and implement controls to track and enforce repayments owed to HUD to ensure that owners are not delinquent on their repayment agreements.

Adequately notify homeowners that, due to COVID-19, all FHA refund applications and supporting documents should be sent electronically to avoid delay in processing. This process should include (1) developing and expediting implementation of correspondence sent to homeowners with the application, (2) a notice of operational changes on HUD’s FHA refunds websites, (3) ensuring that HUD’s Does HUD Owe You a Refund website is updated to the most recent FHA Homeowners Fact Sheet, (4) an updated voice message from the call center including an accurate email, and (5) developing an updated script for call center agents for the initial contact with the homeowner, follow up, and contact with homeowners who already submitted their application by mail.

Conduct a privacy impact assessment for accepting homeowner FHA refund applications and supporting documentation that contain PII electronically to identify potential risks and develop and implement plans to mitigate those risks.

Develop and implement written policies and procedures for SFIOD to quickly respond to emergency situations when staff cannot return to the office. Procedures should include steps to quickly notify homeowners of any changes made to the FHA refund process.

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.

Conduct and make available internal HEROS training for all multifamily HEROS users on how to document the environmental review mitigation measures.

Establish and implement written procedures specifying which multifamily employees are required to upload mitigation resolutions after construction completion and at final endorsement.

Upload the 17 missing mitigation resolutions and the 1 missing radon testing document into HEROS for the projects in this finding.

Strengthen HEROS or internal procedures to add an additional requirement confirming that the mitigation resolutions have been uploaded at final endorsement.

Strengthen HEROS by adding a column on the dashboard to show the progress of the overall mitigation status.

Develop and implement an action plan that includes sufficient policies, procedures, and controls that address households living in multifamily housing units having a sufficient supply of safe drinking water […]

Status

In April 2022, HUD created draft standard operating procedures to address lead in the water of its multifamily housing units. On May 11, 2023, HUD published its National Standards for the Physical Inspection of Real Estate (NSPIRE) regulations that addressed lead in the water. Further, on June 30, 2023, HUD published its Implementation of National Standards for the Physical Inspection of Real Estate Administrative Procedures, which requires property owners and agents to provide information about water supply providers and water safety alerts, if applicable, prior to the commencement of a Real Estate Assessment Center (REAC) inspection. As a result, the Office of Multifamily Housing is revising its procedures and consulting with the Office of Lead Hazard Control and Healthy Homes (OLHCHH). As of February 2025, the OIG was waiting for additional information from the Office of Multifamily Housing demonstrating whether it has addressed the recommendation.

Analysis

To fully address this recommendation, the Office of Multifamily Housing must provide evidence of an action plan that includes its procedures that address households living in multifamily units to ensure that they have a sufficient supply of safe drinking water.

Implementation of this recommendation will enable HUD to have sufficient oversight and control activities in place to ensure households living in multifamily housing have a sufficient supply of safe drinking water.

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.