We recommend that HUD’s Deputy Assistant Secretary for Fair Housing and Equal Opportunity update protocols to promote consistent expectations for timely supervisory, legal, and headquarters reviews of complex cases.

We recommend that HUD’s Deputy Assistant Secretary for Fair Housing and Equal Opportunity review and update the MOUs with OGC for each region to identify and remove inefficiencies that can lead to longer FHEO investigation times and OGC review times and identify best practices that can be implemented across all regions.

We recommend that HUD’s Deputy Assistant Secretary for Fair Housing and Equal Opportunity review and update investigative processes followed by each regional office to identify best practices that can be implemented across all regions and identify and remove inefficiencies that can lead to longer investigation times.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to update its intake policy and procedure to clarify which inquiries are to be recorded in HEMS.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to develop an internal agency intake training guide, distribute it to all agency housing staff members, and ensure that all intake staff members participate in HUD-approved training related to intake.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to implement a record retention policy to ensure that decisions on inquiries are sufficiently supported.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to implement a plan to ensure that it has sufficient staff to meet its obligations under FHAP cooperative agreement.

We recommend that HUD’s Deputy Assistant Secretary for Enforcement require the Commission to implement a system to better track the intake and processing of potential fair housing inquiries.

Provide more detailed guidance to HUD reviewers on benchmarks for each performance standard.

Update the PAR template to ensure that HUD reviewers include required information.

Assess HUD reviewers’ skills and readiness to determine the appropriate frequency of training.

Provide more detailed guidance to HUD reviewers and FHEO regional directors on when and under what circumstances to recommend or issue a PIP.

Update HUD Handbook 8024.01, REV-2, and regional intake policies and procedures as necessary to include (1) minimum requirements that all regions follow for documenting in HEMS attempts to reach out to claimants when additional information is needed before closing inquiries; (2) policies and procedures for collecting, recording, and documenting all relevant electronic intake information in HEMS; and (3) clarifying that communications with claimants regarding inquiry closure, requests for additional information, and notices of jurisdiction information clearly inform the claimant of the ability to provide additional information within the statute of limitations.

Develop a process to oversee housing discrimination allegations that FHAP agencies close and do not submit to HUD for dual-filing to ensure that the closure and jurisdictional determinations are consistent with the Fair Housing Act. To help address this recommendation, HUD should consider requiring FHAP agencies to enter data on closed inquiries in HEMS and make updates to FHAP agreements as necessary.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $168,198 in 29 obligations marked for deobligation as of September 30, 2018.

Review the five identified retained inactive obligations with remaining balances totaling $110,224 and close out and deobligate amounts tied to obligations that are no longer valid or needed.

Deobligate all obligations marked for deobligation during the departmentwide OOR, including as much as $559,569 in 53 administrative and $641,110 in 9 program obligations marked for deobligation as of September 30, 2017.

Review the seven identified retained inactive obligations with remaining balances totaling $143,344 and close out and deobligate amounts tied to obligations that are no longer valid or needed.