We recommend that the Deputy Assistant Secretary for Field Operations provide training and guidance to field office program staff on SEMAP scoring, rating, and verification procedures, including confirmatory reviews, quality control reviews, and adjustments, as appropriate, for the revised SEMAP process.

We recommend that the Director of CPD’s Office of Disaster Recovery review the one grantee with a grant totaling $666,666 that did not meet the overall LMI requirement and address the noncompliance.

We recommend that the Director of CPD’s Office of Disaster Recovery update DRGR’s QPR to include information on the progress towards compliance with the overall LMI benefit based on the total amount of the grant.

We recommend that the Director of CPD’s Office of Disaster Recovery adopt LMI benchmarking to ensure that grantees budget adequate funds to LMI at significant milestones in the grant lifecycle.

We recommend that the Director of CPD’s Office of Disaster Recovery make changes to the action plan process so that the action plan calculates an overall LMI percentage.

Create a plan and timeline that outlines OFO’s proposal to make necessary improvements to the EBLL tracker, such as moving it to a different platform.

Provide field office staff access to historical data in the EBLL tracker to be readily available as needed, with adequate protection of PII.

Update the EBLL tracker to show whether one or multiple children have an EBLL and whether the unit, building, or development previously had an EBLL reported.

Update the EBLL tracker by including which data fields are required, establishing what type of information can be entered into each data field, and disallowing case closure if required information is missing.

PIH in coordination with other HUD offices as necessary, research and address potential causes of the variance in the number of EBLL cases among States on the EBLL tracker and identify solutions that are within HUD's control.

Corrective Action Taken

On September 10, 2025, HUD took action to close priority recommendation 6 from HUD OIG Evaluation Report 2021-OE-0011b, Improvements are Needed to HUD’s Processes for Monitoring Elevated Blood Lead Levels and Lead-Based Paint Hazards in Public Housing, issued February 28, 2023.  HUD’s Office of Public and Indian Housing, Office of Field Operations (OFO), conducted research and comparative analysis of nine identified field offices and PHAs with unreported elevated blood lead levels (EBLL) and obtained the missing documentation and entered it into the EBLL tracker.  Additionally, OFO revised the EBLL tracker job aid, published new EBLL guidance, held office hours and group and individual trainings for OFO staff, and developed a PowerBI dashboard to accompany the EBLL tracker to allow for the visual monitoring of EBLL cases with outstanding or nearing deadlines.  These corrective actions have increased the effectiveness of the EBLL tracker and enhanced the accuracy of HUD records.  HUD can now ensure that EBLL cases are both reported and recorded in the EBLL tracker appropriately so that it can track progress towards addressing EBLLs and close EBLL cases in a timely manner.

Create a plan and timeline that outlines OFO’s proposal to move the LBPR tracker to a different platform.

Develop a timeliness standard in the LBPR tracker to establish expectations for how often field office staff must reach out to PHAs on the LBPR tracker to discuss measures that will resolve cases in a timely manner.

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

On January 17, 2025, HUD published a Federal Register notice to modify its EBLL threshold under its Lead Safe Housing Rule from to 5 to 3.5 micrograms of lead per deciliter of blood (µg/dL) for a child under the age of 6, consistent with the Centers for Disease Control and Prevention's current blood lead reference value of 3.5 µg/dL.

As of July 17, 2025, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) informed HUD OIG that HUD has drafted 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).

OLHCHH’s timeline to finish implementing the recommendation:

• The notice will enter the clearance process by the end of August.
• CPD, MF, PIH, and OLHCHH will publish the final joint notice by September 30, 2025.

The estimated completion date for these actions is September 30, 2025. The original estimated completion date was June 30, 2024, and was revised to account for the time required to (1) receive and review public comments on HUD’s proposed change to the EBLL threshold and (2) coordinate the implementation of the EBLL threshold change across the impacted HUD offices.

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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.

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.

Implement a quality control review to ensure that successive below-60 REAC inspection score flags are entered into APPS.

Update APPS to automatically flag a property that receives successive below-60 REAC inspection scores.

We recommend that the Deputy Assistant Secretary for Single Family Housing update its COVID-19 Resources for Homeowners webpage to clearly communicate that homeowners who had not previously requested forbearance by September 30, 2021, are eligible to request forbearance from their servicer through the end of the COVID-19 National Emergency.