Lead Paint in Housing:

HUD Should Strengthen Grant Processes, Compliance Monitoring, and Performance Assessment

GAO-18-394: Published: Jun 19, 2018. Publicly Released: Jun 19, 2018.

Multimedia:

  • GAO Interactive Graphic
    INTERACTIVE GRAPHIC: Lead Paint Hazard Risk and Locations of HUD's Lead Grant Awards, 2013-2017

Additional Materials:

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Daniel Garcia-Diaz
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garciadiazd@gao.gov

 

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What GAO Found

The Department of Housing and Urban Development’s (HUD) lead grant and rental assistance programs have taken steps to address lead paint hazards, but opportunities exist for improvement. For example, in 2016, HUD began using new tools to monitor how public housing agencies comply with lead paint regulations. However, HUD could further improve efforts in the following areas:
  • Lead grant programs. While its recent grant award processes incorporate statutory requirements on applicant eligibility and selection criteria, HUD has not fully documented or evaluated these processes. For example, HUD’s guidance is not sufficiently detailed to ensure consistent and appropriate grant award decisions. Better documentation and evaluation of HUD’s grant program processes could help ensure that lead grants reach areas at risk of lead paint hazards. Further, HUD has not developed specific time frames for using available local-level data to better identify areas of the country at risk for lead paint hazards, which could help HUD target its limited resources.
  • Oversight. HUD does not have a plan to mitigate and address risks related to noncompliance with lead paint regulations by public housing agencies. We identified several limitations with HUD’s monitoring efforts, including reliance on public housing agencies’ self-certifying compliance with lead paint regulations and challenges identifying children with elevated blood lead levels. Additionally, HUD lacks detailed procedures for addressing noncompliance consistently and in a timely manner. Developing a plan and detailed procedures to address noncompliance with lead paint regulations could strengthen HUD’s oversight of public housing agencies.
  • Inspections. The lead inspection standard for the Housing Choice Voucher program is less strict than that of the public housing program. By requesting and obtaining statutory authority to amend the standard for the voucher program, HUD would be positioned to take steps to better protect children in voucher units from lead exposure as indicated by analysis of benefits and costs.
  • Performance assessment and reporting. HUD lacks comprehensive goals and performance measures for its lead reduction efforts. In addition, it has not complied with annual statutory reporting requirements, last reporting as required on its lead efforts in 1997. Without better performance assessment and reporting, HUD cannot fully assess the effectiveness of its lead efforts.

Examples of Homes with Lead Paint Hazards

Why GAO Did This Study

Lead paint in housing is the most common source of lead exposure for U.S. children. HUD awards grants to state and local governments to reduce lead paint hazards in housing and oversees compliance with lead paint regulations in its rental assistance programs. The 2017 Consolidated Appropriations Act, Joint Explanatory Statement, includes a provision that GAO review HUD’s efforts to address lead paint hazards. This report examines HUD’s efforts to (1) incorporate statutory requirements and other relevant federal standards in its lead grant programs, (2) monitor and enforce compliance with lead paint regulations in its rental assistance programs, (3) adopt federal health guidelines and environmental standards for its lead grant and rental assistance programs, and (4) measure and report on the performance of its lead efforts. GAO reviewed HUD documents and data related to its grant programs, compliance efforts, performance measures, and reporting. GAO also interviewed HUD staff and some grantees.

What GAO Recommends

GAO makes nine recommendations to HUD including to improve lead grant program and compliance monitoring processes, request authority to amend its lead inspection standard in the voucher program, and take additional steps to report on progress. HUD generally agreed with eight of the recommendations. HUD disagreed that it should request authority to use a specific, stricter inspection standard. GAO revised this recommendation to allow HUD greater flexibility to amend its current inspection standard as indicated by analysis of the benefits and costs.

For more information, contact Daniel Garcia-Diaz at (202) 512-8678 or garciadiazd@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: As of November 2019, HUD's Lead Office had taken steps to implement this recommendation. For example, they updated the 2018 Application Review Guide with some criteria that could be used to score grant applications. However, the 2019 Application Review Guide did not contain similar criteria. To fully implement this recommendation, the agency will need to follow through and adopt criteria to score grant applications on a consistent basis.

    Recommendation: The Director of HUD's Lead Office should ensure that the office more fully documents its processes for scoring and awarding lead grants and its rationale for award decisions. (Recommendation 1)

    Agency Affected: Department of Housing and Urban Development

  2. Status: Open

    Comments: As of November 2019, HUD's Lead Office began to take steps to implement this recommendation. For example, in the upcoming weeks and months, the Lead Office staff plan to meet to review the most recent round of grant applications and determine whether any changes need to be made to the scoring criteria for future years. To fully implement this recommendation, HUD's Lead Office staff will need to provide evidence the office is periodically evaluating and changing processes to score and award grants, as appropriate.

    Recommendation: The Director of HUD's Lead Office should ensure that the office periodically evaluates its processes for scoring and awarding lead grants. (Recommendation 2)

    Agency Affected: Department of Housing and Urban Development

  3. Status: Closed - Implemented

    Comments: As of November 2019, HUD's Lead Office and PD&R have taken steps to address this recommendation. For example, PD&R completed an analysis to determine high impact neighborhoods and high abatement needs jurisdictions. The analysis is referenced within HUD's fiscal year 2019 Notice of Funding Availability (released in June 2019) and available on HUD's website.

    Recommendation: The Director of HUD's Lead Office, in collaboration with the Office of Policy Development and Research (PD&R), should set time frames for incorporating relevant data on lead paint hazard risks into the lead grant programs' processes. (Recommendation 3)

    Agency Affected: Department of Housing and Urban Development

  4. Status: Open

    Priority recommendation

    Comments: As of November 2019, HUD officials told us the agency had taken steps to implement the recommendation, including requiring PHAs to submit appropriate documentation regarding public housing units' compliance with lead paint regulations and updating an internal checklist for on-site compliance reviews that HUD staff conduct. We will continue to monitor HUD's progress in response to our recommendation.

    Recommendation: The Director of HUD's Lead Office and the Assistant Secretary for the Office of Public and Indian Housing (PIH) should collaborate to establish a plan to mitigate and address risks within HUD's lead paint compliance monitoring processes. (Recommendation 4)

    Agency Affected: Department of Housing and Urban Development

  5. Status: Open

    Priority recommendation

    Comments: As of November 2019, HUD officials told us procedures were in draft form and under internal review and were not expected to be finalized until spring 2020.

    Recommendation: The Director of HUD's Lead Office and the Assistant Secretary for PIH should collaborate to develop and document procedures to ensure that HUD staff take consistent and timely steps to address issues of public housing agency noncompliance with lead paint regulations. (Recommendation 5)

    Agency Affected: Department of Housing and Urban Development

  6. Status: Open

    Priority recommendation

    Comments: In response to this recommendation, HUD's fiscal year 2021 budget justification requested funds to test an alternative lead paint testing method in HUD's Housing Choice Voucher program. To fully implement our recommendation, HUD needs to continue to take steps to analyze potential effects of alternative lead paint testing methods, and use the results to inform its decisions about requesting new authority from Congress.

    Recommendation: The Secretary of HUD should request authority from Congress to amend the inspection standard to identify lead paint hazards in the Housing Choice Voucher program as indicated by analysis of health effects for children, the impact on landlord participation in the program, and other relevant factors. (Recommendation 6)

    Agency Affected: Department of Housing and Urban Development

  7. Status: Open

    Comments: As of November 2019, HUD officials told us they still were exploring whether current data systems could be used to count the number of lead-safe housing units in HUD's rental assistance programs. We will continue to monitor HUD's effort to implement this recommendation.

    Recommendation: The Director of the Lead Office should develop performance goals and measures to cover the full range of HUD's lead efforts, including its efforts to ensure that housing units in its rental assistance programs are lead-safe. (Recommendation 7)

    Agency Affected: Department of Housing and Urban Development

  8. Status: Open

    Comments: In November 2019, HUD officials told us they planned to use data from the forthcoming update to the American Healthy Homes Survey to better estimate the prevalence of lead paint hazards in federally assisted housing which would provide an indication of the effectiveness of the lead paint rules. However, officials told us the findings from the updated survey likely would not be available until summer 2020.

    Recommendation: The Director of the Lead Office, in conjunction with PD&R, should finalize plans and develop a time frame for evaluating the effectiveness of the Lead Safe Housing and Lead Disclosure Rules, including an evaluation of the long-term cost effectiveness of the lead remediation methods required by the Lead Safe Housing Rule. (Recommendation 8)

    Agency Affected: Department of Housing and Urban Development

  9. Status: Open

    Comments: In November 2019, HUD officials told us they planned to issue a report to Congress on the agency's lead efforts in early 2020.

    Recommendation: The Director of the Lead Office should complete statutory reporting requirements, including but not limited to its efforts to make housing lead-safe through its lead grant programs and rental-assistance programs, and make the report publicly available. (Recommendation 9)

    Agency Affected: Department of Housing and Urban Development

 

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