Update HUD Handbook 1900.40, Do Not Pay policy, to clearly define the responsibilities for all parties and align it with current laws, processes, and procedures. This should include defining responsibilities for preaward and prepayment verification, and developing a process and governance structure to ensure that preaward and prepayment verification are consistently performed across HUD’s programs.

Status

As of January 2026, HUD has not provided a management decision for this recommendation. While HUD reestablished its computer matching agreement with the Department of Treasury through the Treasury Do Not Pay verification portal, HUD has not developed a policy to define responsibilities going forward.

HUD OIG recently initiated  the annual Payment Integrity Information Act (PIIA) audit for fiscal year 2025. During this audit we will work with HUD to determine the status of this recommendation.

Analysis

Updating the HUD Handbook 1900.40 will define responsible parties for ensuring compliance with the Do Not Pay Initiative (DNP).    

The implementation of this recommendation will result in consistent use of DNP, allowing for instant verification of eligibility across the billions in payments that HUD processes, resulting in the reduction of future improper payments.

Perform a complete agency-wide fraud risk assessment (which incorporates the fraud risk assessments performed at the program level) and use the results to develop and implement an agency-wide plan to move HUD’s fraud risk management program out of the ad hoc phase.

Status

As of July 2025, HUD cancelled its fraud risk management contracts and the Chief Risk Officer position was vacated under the Deferred Resignation Program. HUD is currently working to realign its business process and determining how it will address fraud risk management. As of January 2026, HUD has not provided an updated plan on how it will address the recommendation. However, HUD reported to HUD OIG that it is currently working on reducing fraud through a Task Force and other new initiatives. The final action target date for this recommendation was September 30, 2024.

Analysis

To fully address this recommendation, HUD must provide evidence that it has performed an agency-wide fraud risk assessment performed at the program level, adopted and implemented its fraud risk assessment program departmental policy, and that each HUD program office has established office-specific risk programs.