HUD (a) identify all contracts related to its programs that pre-date July 1, 2013 and that have not yet been modified to include Section 4712 whistleblower protections; and (b) review all contracts entered into on or after July 1, 2013, to ensure they include a clause that requires contractors to comply with Section 4712.

Seek voluntary cooperation from program participants to proactively modify pre-2013 contracts for the purpose of including a clause requiring compliance with Section 4712.

Use its best efforts to include a clause requiring compliance with Section 4712 at the time of major modifications to contracts with program participants with whom HUD is unable to gain voluntary cooperation.

HUD seek legislative authority to expeditiously include Section 4712 protections within contracts for which HUD believes it must otherwise wait until there is a major modification.

HUD develop and implement controls to ensure that the provisions of Section 4712 are included in all contracts.

Identify short- and long-term plans for the RPA program that align its capabilities, staffing needs, funding projections, and mission needs.

Implement procedures to capture and monitor centralized logs to maintain appropriate visibility into bot activities and provide for auditability of bot actions.

Implement procedures to periodically review RPA system access and remove access for users that are not authorized or no longer have a need to use the system.

Implement procedures to ensure that attended bots use the security rights and credentials of the attending user.

Research, evaluate, and implement technical or alternative solutions to deploy essential computer software updates using appropriate secure methods to ensure that computer security updates occur in a timely manner to minimize risk to HUD’s systems and operations

Research, evaluate, and implement technical solutions to provide additional improvements to VPN and related remote working capabilities of HUD system users.

Perform routine VPN stress tests as part of its contingency planning and testing processes to regularly identify and remediate network performance issues and ensure that network capabilities are sufficient for teleworking.

Research, evaluate, and implement technical solutions to resolve the user account management issues and the underlying issue in the technical environment.

Assess its help desk system against other technical solutions and ensure that the help desk solution used captures complete data on technical support requests. This measure includes but is not limited to ensuring that sequence gaps are properly documented or do not occur, valid transactions are accepted by the help desk system, rejected transactions are identified, and the history of each transaction is retained.

HUD OCIO should implement procedures to ensure that information in cybersecurity risk registers is obtained accurately, consistently, and in a reproducible format and is used to a. quantify and aggregate security risks, b. normalize cybersecurity risk information across organizational units, and c. prioritize operational risk response (derived from metric 5).

HUD OCIO and the HUD Chief Risk Officer should coordinate to implement procedures to monitor the effectiveness of cybersecurity risk responses to ensure that risk tolerances are maintained at an appropriate level (derived from metric 5).

HUD OCIO and the Office of Administration should implement procedures to ensure proper validation of media sanitization in accordance with HUD Media Protection Procedures 2.0 (February 2022) and form HUD 1067A, Certification of Sanitization (derived from metric 36).

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.

HUD OCIO should ensure that system owners and information system security officers consistently test their ISCPs and upload the test results to CSAM in accordance with HUD’s defined ISCP testing policy (derived from metric 63).

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.