Develop and execute a detailed plan and timeline for both testing and reporting estimates of improper payments in the PIH-TBRA and PBRA programs in compliance with Federal law and OMB guidance.

Status

As of January 30, 2026, HUD has not provided a management decision, detailed plan, or timeline as to how HUD will respond to the recommendation.  When OIG inquired on the status of this recommendation, HUD reported it had completed work in this area that was reflected in its fiscal year 2025 Annual Financial Report (AFR). However, based on what HUD reported it is unclear if it addressed our recommendation. OIG recently initiated the annual Payment Integrity Information Act (PIIA) audit which reviews HUD’s payment integrity information to determine HUD’s compliance. During this audit OIG will also determine the status of HUD’s efforts in terms of this recommendation.

Analysis

For HUD to close this recommendation, it must finish testing the full life cycle of payments in these programs and publicly report estimates of the improper payments in them. Merely producing a plan with future action target dates is not sufficient to meet the spirit of this recommendation.

PBRA and PIH-TBRA are the two largest program expenditures in HUD's portfolio, totaling $55.6 billion in FY 25, or 62.5 percent of HUD's total expenditures. HUD has been challenged with developing a compliant sampling methodology that can test the full payment cycle, and, that can be executed within the required timeframes. To fully address this recommendation, the sampling methodology should test the full payment cycle, and the associated sample testing and statistical estimation must be completed in time to be included in the Annual Financial Report.
Implementation of this recommendation will result in HUD better-safeguarding taxpayer dollars and decrease improper payments.

Update HUD regulations, policies, and procedures following the regulatory process required by the amended Lead Safe Housing Rule, in consideration of CDC's lowered BLRV of 3.5 ug/dL.

Status

As of January 30, 2026, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) informed HUD OIG that HUD has circulated for comment a joint notice for HUD offices impacted by the modified elevated blood lead level (EBLL) threshold.  These offices include OLHCHH, the Office of Community Planning and Development (CPD), the Office of Multifamily Housing Programs (MF), and the Office of Public and Indian Housing (PIH).  The OLHCHH's estimated completion date is February 2026.

Analysis

To fully address this recommendation, OLHCHH must provide evidence that HUD has updated its regulations, policies, and procedures so that they are consistent with CDC’s lowered BLRV of 3.5 ug/dL.

Implementation of this recommendation will help ensure children living in public housing with EBLLs receive effective environmental interventions.

Update applicable requirements to require assisted property owners, including PHAs, to maintain adequate documentation to support their determinations that maintenance and hazard reduction activities that disturb surfaces with lead-based paint qualify for the de minimis exemption from the lead-safe work practices under the Lead Safe Housing Rule.

Status

To address this recommendation, The Office of Lead Hazard Control and Healthy Homes (OLHCHH) agreed to:                                                                                                                      
1. Issue a notice to assisted target housing owners and public housing agencies on the de minimis exception citing the correct application of the de minimis threshold; describing appropriate documentation methods for the application of the de minimis threshold; and recommendations of best practices for documenting applications.
2. Collect additional data regarding the use of the de minimis threshold, including information on how private and public housing owners: (a) determine how much paint in target housing will be disturbed during a maintenance or rehabilitation project; (b) use the paint disturbance area information; (c) monitor the amount of paint disturbed in projects that are designed to disturb de minimis amounts of paint in target housing.
3. Design and conduct webinars, including at least one for each program office’s major categories of stakeholders on requirements and best practices pertaining to the de minimis exception under the Lead Safe Housing Rule and its implementation; record the webinars on the HUD website (e.g., on HUD Exchange) for future viewing by stakeholders; and conduct outreach promoting the webinars. 
The OLHCHH had drafted guidance on the de minimis exception to the Lead Safe Housing Rule for PIH, Multifamily Housing, and CPD and submitted it through the clearance process in September 2024.  As of January 2026, OLHCHH continues to revise the draft guidance in consideration of the comments it received during the clearance review process.  However, HUD has not provided an updated target date to complete the agreed upon actions, which was January 31, 2024.

Analysis

To implement this recommendation, HUD needs to provide evidence that it has implemented the three actions OLHCHH agreed to complete.

Implementation of this recommendation and associated corrective actions will ensure assisted property owners are sufficiently informed regarding the requirements to support their determinations that maintenance and hazard reduction activities that disturb surfaces with lead-based paint qualify for the de minimis exemption from the lead-safe work practices under the Lead Safe Housing Rule and that assisted property owners are conducting this work safely, thereby ensuring households are residing in safe and healthy HUD-assisted housing.