HUD did not comply with PIIA because it did not report compliant improper and unknown payment estimates for the Office of Public and Indian Housing’s Tenant-Based Rental Assistance (PIH-TBRA) program and the Office of Multifamily Housing Programs’ Project-Based Rental Assistance (MF-PBRA) program.   These were HUD’s two largest program expenditures, totaling more than $50 billion in fiscal year 2024.  This noncompliance is significant because this is the eighth consecutive year in which HUD has been unable to produce PIH-TBRA and MF-PBRA improper and unknown payment estimates, and that deficiency has contributed to HUD’s noncompliance with improper payment laws for 12 consecutive years.  

These programs present payment integrity challenges because they entail thousands of program administrators outside of HUD processing large volumes of payments using nonstandarized processes, and supporting documentation needed for testing is not maintained at HUD.  The lack of a detailed approach to resolve these systemic challenges, including coordination by leadership, has prevented HUD from making the progress needed to achieve compliance.  

 We also determined that HUD did not comply with the Do Not Pay Initiative (DNP) as required by the Payment Integrity Information Act of 2019 because it did not consistently use DNP for prepayment verification.  This occurred in large part because the computer matching agreement between HUD and Treasury, related to DNP, expired in 2019 and has still not been renewed.  Additionally, we found HUD’s governance of DNP implementation to be weak.  Without this computer matching process in place and because of weak governance around DNP implementation, HUD’s risk of improper payments increased.  At least $212 million of HUD funds were technically improper payments since the funds were paid to at least 11 entities that did not have an active registration on SAM.gov.