We audited the U.S. Department of Housing and Urban Development’s (HUD) Office of Community Planning and Development’s (CPD) monitoring of grantees’ compliance with civil rights requirements. Our audit focused on the Community Development Block Grant (CDBG) and the HOME Investment Partnerships Program (HOME). Our audit objective was to assess the extent to which CPD monitored civil rights compliance in its program activities.

CPD could improve its civil rights compliance monitoring reviews. Specifically, CPD performed civil rights monitoring reviews for 2 percent of the CDBG and HOME grantees it monitored in fiscal year 2023. CPD suspended its limited civil rights monitoring in fiscal years 2021 and 2022 pending the Affirmatively Furthering Fair Housing (AFFH) rules. In fiscal year 2023, it resumed its limited civil rights monitoring. However, guidance issued by management did not instruct staff to conduct civil rights monitoring, which led to confusion among field staff. In addition, CPD could improve its monitoring by requiring its field staff to fully complete the CPD Handbook 6509.2, chapter 22, civil rights monitoring checklists while conducting remote monitoring. Without clear guidance and in depth monitoring reviews, CPD could miss opportunities to identify errors in grantees’ policies, procedures, and practices related to nondiscriminatory responsibilities in CPD programs, thus overlooking the potential to communicate fair housing concerns to HUD’s Office of Fair Housing and Equal Opportunity (FHEO) for resolution.

We recommend that HUD’s General Deputy Assistant Secretary for Community Planning and Development coordinate with FHEO to implement training for civil rights monitoring reviews. Additionally, CPD should (1) ensure that training on civil rights monitoring reviews is regularly provided to CPD staff (such as quarterly, semiannually, etc.); (2) implement updated guidance or protocols for monitoring civil rights compliance and require CPD staff to incorporate civil rights monitoring into the risk analysis process; and (3) develop guidance clarifying the use of the exhibit for on-site, hybrid, and remote monitoring to ensure a full review  of grantees’ compliance with civil rights requirements, and incorporate this guidance into training developed as a result of the first recommendation. HUD took steps during the audit to implement the second recommendation.