Implement controls to ensure that project distributions are made from surplus cash and comply with the regulatory agreement and HUD requirements.

Develop and implement procedures to ensure that it maintains documentation to show that it selected participants from its waiting list in accordance with applicable requirements.

Develop and implement procedures to ensure that it maintains criminal background checks in separate, secure files.

Repay the U.S. Treasury $19,173 spent on ineligible assistance from non-Federal funds.

Complete a cost breakdown to support the $10,731 spent on a rental property, which included assistance to an ineligible unit, and repay the ineligible assistance to the U.S. Treasury from non-Federal funds.

Recalculate annual income for participants assisted with the 2014 lead hazard control grant to support the $1,803,705 spent. For any assistance the Health Department cannot support with complete income calculations, it should repay the U.S. Treasury from non-Federal funds, less any amount repaid as a result of recommendations 1B and 2A.

Develop and implement policies and procedures that clarify the definition of annual income to be used, calculation components, and the documentation required to calculate income.

Develop and implement procedures for quality control reviews to ensure that annual income is properly calculated.

Provide training on HUD’s income requirements to employees responsible for calculating income.

Provide support showing the $79,738 spent on window replacement qualified or repay the U.S. Treasury from non-Federal funds.

Develop and implement policies and procedures to ensure that all windows replaced meet lead hazard qualifications.

Develop and implement quality control procedures to ensure that all bid specifications are reviewed for qualified items based on the risk assessment results.

Update the Health Department’s work plan to include policies and procedures for defining, determining, and documenting relocation hardship for all participants.

Develop and implement policies and procedures to ensure that the property owners receive the required information concerning lead-based paint disclosure requirements, risk assessment results, summaries of treatments and clearances, and ongoing maintenance activities, including how to report paint deterioration.

Develop a method for using the Do Not Pay portal during the underwriting process to identify delinquent child support and delinquent Federal debt to prevent future FHA loans to ineligible borrowers to put $1.9 billion to better use.

Status

The Office of Housing has approved prioritization of funding for Integration between the Treasury’s Do Not Pay portal and HUD’s Computerized Homes Underwriting Reporting System (CHUMS). Funding was allocated to the CHUMS IT contractor on January 26, 2024, to integrate Treasury’s Do Not Pay system with CHUMS, and the IT development project was kicked off the week of February 5, 2024. As of July 2025, the CHUMS Memorandum of Understanding (MOU) and Interconnection Security Agreement (ISA) with DNP is fully signed. However, the System of Records Notice (SORN) is under review with OMB. HUD's Office of Privacy is in the process of reaching out to OMB to request comments or permission to publish. The anticipated completion date of the CHUMS interface with DNP is December 31, 2025.

Analysis

To fully address this recommendation, HUD must provide evidence that it has implemented applicant screening against the Do Not Pay portal to identify delinquent child support and delinquent federal debt to prevent future FHA loans from going to ineligible borrowers.

Implementation of this rule should result in HUD putting $1.9 billion to better use.

Revise the single-family handbook to comply with regulations that prevent loans to borrowers with delinquent child support subject to Federal offset.

Schedule the timely renewal of data-sharing agreements to prevent data loss in CAIVRS or discontinue use of the system if implementation of 1A makes CAIVRS unnecessary.

Strengthen current written policies on occupancy requirements for subsidized multifamily housing programs to ensure that prospective tenants do not improperly bypass waiting lists.

Repay HUD for improperly filed partial claims and incentive fees totaling $1,053,688.

Work with HUD to ensure the release of the liens on the 66 properties with improper partial claims.