Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require the implementation of risk-based security and privacy controls for external entities that process, store, or share sensitive information with HUD. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require independent assessments of external entities that process, store, or share sensitive information with HUD to ensure controls are implemented. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require identifying and tracking corrective action needed by external entities that process, store, or share sensitive information with HUD. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require monitoring of progress in implementing controls/corrective actions by external entities that process, store, or share sensitive information with HUD. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to develop and maintain a comprehensive systems inventory that incorporates sufficient, reliable information about the external entities with which HUD program information is shared and the extent to which each external entity has access to PII and other sensitive information. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should establish a date to finalize its draft standard operating procedures for conducting career SES reassignments, and ensure that the final procedures include (1) obtaining a written moratorium waiver from the career SES member before making the reassignment during the new, noncareer supervisor moratorium, and (2) retaining the waiver in the member's Official Personnel Folder. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on the draft of the report, HUD said it finalized standard operating procedures for making career SES reassignments, and thus believes it has addressed our recommendation. We will follow up with the department to assess whether its actions fully address the recommendation.

Recommendation: HUD's Office of Special Needs Assistance Programs should conduct quality assurance checks on the PIT count methodology data it requires CoCs to submit and take actions as appropriate to ensure that HUD's standards for conducting valid and reliable PIT counts are met. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: HUD's Office of Special Needs Assistance Programs should provide more detailed instructions on using probability sampling techniques to complete the PIT count, such as by updating its Point-in-Time Count Methodology Guide to instruct CoCs on reporting measures of error and bias in PIT count results. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: HUD's Office of Special Needs Assistance Programs should assess and enhance the usefulness of its assistance to CoCs' data collection efforts. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should ensure that the agency fully implements each of the seven key IT workforce planning activities it did not fully implement. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of HUD should establish time frames and a plan for publication of the grant process and requirements for CDBG-DR funding available for improvements to Puerto Rico's electricity grid. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of August 2020, HUD had not published a federal notice outlining the grant process and requirements for CDBG-DR funding available for improvements to Puerto Rico's electricity grid, nor has it established time frames and a plan for issuing this notice. We continue to believe that the action we recommended is needed and will monitor HUD's efforts as part of our regular recommendation follow-up and additional work examining federal support to improve grid resilience in Puerto Rico. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should update the department's environmental justice strategic plan. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In comments on our report, the department neither agreed nor disagreed with this recommendation. We will continue to review the department's actions and update this information.

Recommendation: The Secretary of Housing and Urban Development should issue a progress report on its environmental justice efforts each year. (Recommendation 16)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In comments on our report, the department agreed with this recommendation. We will continue to review the department's actions and update this information.

Recommendation: The Secretary of Housing and Urban Developing should develop a cybersecurity risk management strategy that includes the key elements identified in this report. (Recommendation 16)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: The Department of Housing and Urban Development concurred with this recommendation. As of January 2020, the department said it planned to develop a cybersecurity risk management strategy that will determine how cybersecurity risks will be identified, framed, assessed, respond to, and monitored. The Department estimated completing this effort by August 2020. Once the department has provided evidence of these actions, we plan to verify whether implementation has occurred.

Recommendation: The Assistant Secretary for Community Planning and Development should develop additional guidance for HUD staff to use when assessing the adequacy of the capacity and unmet needs assessments that grantees develop. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In November 2019, HUD said that CPD will provide training to HUD staff regarding the standards for assessing unmet needs and grantee capacity. HUD needs to provide written guidance or other documentation outlining the standards HUD staff must consider when assessing the adequacy of grantees' capacity and unmet needs assessments.

Recommendation: The Assistant Secretary for Community Planning and Development should require staff to document the basis for their conclusions during reviews of grantees' financial controls, procurement processes, and grant management procedures and capacity and unmet needs assessments. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In November 2019, HUD stated that HUD staff are now required to indicate the basis for their conclusions in the checklist used to review financial controls and all correspondence between grantees and HUD staff regarding revisions to the financial processes will be provided as part of the certification or grant approval package. We are following up with CPD on the extent to which similar requirements have been developed for reviews of procurement processes, grant management procedures, and capacity and unmet needs assessments. In addition, CPD needs to provide documentation showing that all correspondence between grantees and HUD staff regarding revisions to financial controls, procurement processes, and grant management procedures and capacity and unmet needs assessments are to be part of the grant's approval package.

Recommendation: The Assistant Secretary for Community Planning and Development should develop and implement a comprehensive monitoring plan for the 2017 grants. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In November 2019, HUD stated CPD had modified the CDBG-DR risk analysis tool to include pre-award conditions that must be factored into the provision of the grant agreement as well as future monitoring reviews. HUD stills needs to develop a comprehensive monitoring plan for the 2017 grants based on the risk assessments conducted using this revised tool.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should conduct a comprehensive review of the physical inspection process. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should resume calculating the sampling error associated with the physical inspection score for each property, identify what changes may be needed for HUD to use sampling error results, and consider those results when determining whether more frequent inspections or enforcement actions are needed. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should develop comprehensive and organized documentation of REAC's sampling methodology and develop a process to ensure that documentation is maintained going forward. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should track on a routine basis whether REAC is conducting inspections of multifamily housing properties in accordance with federal guidelines for scheduling and coordinate with the Deputy Assistant Secretary for Multifamily Housing to minimize the number of properties that can cancel or reschedule their physical inspections. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should design and implement an evaluation plan to assess the effectiveness of the Indefinite Delivery/Indefinite Quantity pilot in ensuring timely and quality inspections for properties in hard-to-staff geographic areas. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for Multifamily Housing and the Deputy Assistant Secretary for the Real Estate Assessment Center should expedite implementation of the recommendations from the Rapid Response and Resolution Team. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should follow through on REAC's plan to create a process to verify candidate qualifications for contract inspectors—for example, by calling references and requesting documentation from candidates that supports their completion of 250 residential or commercial inspections. The plan should also consider whether certain types of inspections—such as Federal Emergency Management Agency inspections and U.S. Army Office of Housing inspections—satisfy REAC's requirements. (Recommendation 7)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should develop a process to evaluate the effectiveness of REAC's training program—for example, by reviewing the results of tests or soliciting participant feedback. (Recommendation 8)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should revise training for quality assurance inspectors to better reflect their job duties. Revised training should be documented, include expanded subject matter training, and address skills that may not be included in training for contract inspectors—for example, instructing contract inspector candidate trainings and coaching and providing feedback. (Recommendation 9)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should develop continuing education requirements for contract and quality assurance inspectors. (Recommendation 10)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should develop and implement a plan for meeting REAC's management targets for the timeliness and frequency of collaborative quality assurance reviews and quality control inspections. The plan should include consideration of resources of and demands on quality assurance inspectors, including the effect of natural disasters and other special assignments. (Recommendation 11)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should ensure that Quality Control's policies and procedures for overseeing quality assurance inspectors are implemented. (Recommendation 12)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should review quality assurance inspector performance standards and revise them to better reflect the skills and supporting behaviors that quality assurance inspectors need to effectively contribute to REAC's mission. (Recommendation 13)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Deputy Assistant Secretary for Multifamily Housing should report to Congress on why the agency has not complied with the 2017 and 2018 Consolidated Appropriations Acts requirement to issue notices to properties when the REAC score is 60 or below, including seeking any statutory flexibilities or exceptions believed appropriate. (Recommendation 14)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should develop a documented policy or clarify existing policy to implement the statutory requirement to consult with ANCs on the same basis as Indian tribes under Executive Order 13175. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 17)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: To complete the appropriate assignment of codes to their positions performing IT, cybersecurity, or cyber-related functions, in accordance with the requirements of the Federal Cybersecurity Workforce Assessment Act of 2015, the Secretary of Housing and Urban Development should take steps to review the assignment of the "000" code to any positions in the department in the 2210 IT management occupational series and assign the appropriate NICE framework work role codes. (Recommendation 10)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: The Department of Housing and Urban Development (HUD) agreed with this recommendation. In January 2020, HUD stated that it was in the process of reviewing its positions in the 2210 IT management occupational series and assigning appropriate work role codes. To fully implement this recommendation, HUD will need to correctly categorize the work roles and functions performed by IT and cyber-related personnel in order to be able to identify critical cybersecurity staffing needs.

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Community Planning and Development should develop written guidance for CPD's field offices to use when determining whether to make a referral to the Departmental Enforcement Center. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Public and Indian Housing should develop written guidance for PIH's field offices to use when determining whether to make a referral to the Departmental Enforcement Center. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Community Planning and Development should develop targets for the number of referrals that CPD should make to DEC that are based on program risk. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Public and Indian Housing should develop targets for the number of referrals that PIH should make to DEC that are based on program risk. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Departmental Enforcement Center should develop and implement performance measures that assess the outcomes, or desired results, of its enforcement activities. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Departmental Enforcement Center should develop and implement performance measures of its timeliness in completing oversight reviews. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Departmental Enforcement Center should track the implementation of the recommendations that it makes to program offices as a result of its oversight reviews. (Recommendation 7)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Departmental Enforcement Center should develop controls to ensure that analysts consistently and reliably record dates related to referral activity, corrective action taken, and other key information used to determine DEC's impact. (Recommendation 8)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Housing and Urban Development should ensure that the department's IT management policies address the role of the CIO for key responsibilities in the six areas we identified. (Recommendation 11)

Agency: Department of Housing and Urban Development
Status: Open

Comments: The department indicated that it has work underway to address this recommendation, which it plans to complete in March 2020. When we confirm those actions, we will provide updated information.

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: Department of Housing and Urban Development
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 periodically evaluates its processes for scoring and awarding lead grants. (Recommendation 2)

Agency: Department of Housing and Urban Development
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 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: Department of Housing and Urban Development
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 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: Department of Housing and Urban Development
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 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: Department of Housing and Urban Development
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 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: Department of Housing and Urban Development
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, 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: Department of Housing and Urban Development
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 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: Department of Housing and Urban Development
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 Deputy Assistant Secretary of the Department of Housing and Urban Development's Office of Native American Programs, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 10)

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of December 2019, the task force members had agreed to jointly consider the actions they have taken from the 2011 report and to discuss additional actions they could take to increase collaboration at the national level. We will evaluate HUD's actions once they are complete.

Recommendation: HUD's Assistant Secretary for Housing should improve the accuracy of RAD leverage metrics--such as better selecting inputs to the leverage ratio calculation and clearly identifying what the leverage ratio measures--and calculate a private-sector leverage ratio. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: This recommendation remains open. HUD has described an ongoing evaluation of its leverage metrics. We will continue to review HUD's progress and post updates as appropriate.

Recommendation: HUD's Assistant Secretary for Housing should determine how it can use available program-wide data from public housing and Section 8 databases, in addition to resident logs, for analysis of the use and enforcement of RAD resident protections. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

Comments: This recommendation remains open. HUD plans to develop a methodology to track residents through individual HUD systems such as Public Housing program, RAD and Section 8 program databases. We will continue to review HUD's progress in implementing this recommendation and provide updates as appropriate.

Recommendation: The Assistant Secretary for the Office of Public and Indian Housing (PIH) should complete workforce planning for the MTW demonstration to help ensure that PIH has sufficient staff with appropriate skills and competencies to manage an expanded demonstration, including reviewing reports and carrying out compliance reviews in a timely manner. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that PIH was continuing its workforce planning efforts, including assessing the knowledge, skills, and abilities needed to implement the MTW expansion.

Recommendation: The Assistant Secretary for PIH should more fully document the process for annually assessing compliance with the five demonstration requirements. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they had drafted written protocols for assessing compliance with the five demonstration requirements that would be finalized by May 2019.

Recommendation: The Assistant Secretary for PIH should develop and implement a process to track how MTW demonstration funds are being used for other allowable activities, including local, nontraditional activities. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they were still determining the most cost effective way to track MTW demonstration funds being used for local, nontraditional activities.

Recommendation: The Assistant Secretary for PIH should identify and implement changes to PIC to capture household data for households served through local, nontraditional activities. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that HUD planned to add fields for capturing data on households served through local, nontraditional activities to the next generation of PIC for expansion MTW agencies, which would be implemented in the summer of 2020. Officials said HUD is currently in the process of determining how the next generation of PIC will be rolled out for existing MTW agencies.

Recommendation: The Assistant Secretary for PIH should develop and implement a process to monitor MTW agencies' reserves. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they planned to monitor existing MTW agencies' Housing Choice Voucher reserves by revising their annual reporting requirements to require them to report their plans for and use of reserves.

Recommendation: The Assistant Secretary for PIH should clarify HUD's rent-reform definition for the MTW demonstration as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that PIH would clarify the definition of rent reform for existing MTW agencies in a document responding to frequently asked questions on the annual reporting requirements and for expansion agencies in the operations notice that it was finalizing for the expansion of the MTW program.

Recommendation: The Assistant Secretary for PIH should set parameters for HUD's definition of self-sufficiency for the demonstration, either by providing one definition or a range of options from which agencies could choose, as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 7)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they planned to provide a range of suggested options for defining self-sufficiency in a document responding to frequently asked questions about the annual reporting requirements for MTW agencies.

Recommendation: The Assistant Secretary for PIH should revise HUD's guidance to MTW agencies to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies and the information required for each element as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 8)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they planned to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies in the operations notice HUD was finalizing for the expansion of the MTW program. Further, HUD officials stated that the 2016 Appropriations Act that extended the standard agreement for the existing 39 MTW agencies limits HUD's ability to revise its guidance for these agencies to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies and the information required for each element. However, they stated that guidance related to the hardship policy and annual reevaluations has been updated to include more specific parameters for what an agency must submit to HUD. As we stated in our report, this guidance is set forth outside the standard agreement, which HUD already has revised without changes to the standard agreement. Therefore, we continue to believe that HUD could revise its guidance for the existing agencies to clarify which elements are required for these documents and the information each element should include.

Recommendation: The Assistant Secretary for PIH should develop written guidance for existing MTW agencies that requires a hardship policy for public housing time limits and encourages an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies for public housing and voucher programs as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 9)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they had updated their most recent annual reporting requirements for MTW agencies to require a hardship policy for public housing time limits and that they were working on finalizing guidance to existing MTW agencies encouraging an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies for public housing and voucher programs.

Recommendation: The Assistant Secretary for PIH should require an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies new MTW agencies adopt for their public housing and voucher programs as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 10)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that the operations notice they were finalizing for the expansion of the MTW program would require an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies new MTW agencies adopt for their public housing and voucher programs.

Recommendation: The Assistant Secretary for PIH should develop and implement a plan for analyzing the information that agencies report on the effect of rent-reform, work-requirement, and time-limit policies on tenants as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 11)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they planned to develop separate analysis plans for existing and expansion MTW agencies due to differences in the types of performance information HUD can require them to report under their MTW agreements.

Recommendation: The Secretary of Housing and Urban Development should direct the Principal Deputy Assistant Secretary for the Office of Community Planning and Development to design and implement policies and procedures for identifying and managing high-risk and recurring single audit findings using a risk-based approach.

Agency: Department of Housing and Urban Development
Status: Open

Comments: The Department of Housing and Urban Development's (HUD) Office of Community Planning and Development (CPD) stated that it did not agree with GAO's emphasis on high risk/recurring single audit findings. Nevertheless, in March 2019, HUD's CPD stated that it is working towards a redesigned model for analyzing risk as a basis for monitoring. In August 2020, HUD informed us that CPD is finalizing the beta test for the risk model. Although the risk model will be further defined and enhanced in fiscal year 2021 for fiscal year 2022, CPD plans to roll out the beta test of the risk model to develop the fiscal year 2021 risk rankings. Single audit will be one factor that is included in calculating the risk scores. CPD will validate and assess the results of the beta test and make adjustments as needed. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Secretary of Housing and Urban Development should direct the Principal Deputy Assistant Secretary for the Office of Public and Indian Housing to design and implement policies and procedures for identifying and managing high-risk and recurring single audit findings using a risk-based approach.

Agency: Department of Housing and Urban Development
Status: Open

Comments: The Department of Housing and Urban Development's (HUD) Office of Public and Indian Housing (PIH) agreed with this recommendation. On May 7, 2018, PIH stated that it had implemented a Risk Based Approach Tool designed to identify and manage high-risk and recurring single audit findings. The Risk Based Approach tool was intended to track and focus on audit findings reported as material weaknesses or significant deficiencies and was designed to determine the resources needed and available to assist in mitigating the audit findings. However, in March 2019, PIH informed us that in late 2018, PIH began to work toward repositioning goals, priorities and identification of key risk indicators. PIH stated that it is now focused on aligning risk indicators to the HUD and PIH priorities. PIH priorities for fiscal year 2019 include addressing Public Housing Authorities insolvency which may be identified through an Independent Public Accountant audit or through other means. PIH stated that it no longer uses the assessment tool that included over 100 risk indicators. PIH indicated that it has a revised risk mitigation framework proposal that will be presented to the Enterprise Risk Counsel in the near future. In fiscal year 2020, we have sent additional follow-up questions to the agency and are currently waiting for a response. We will continue to monitor agency's actions to address this recommendation.

Recommendation: To increase the likelihood that its IT investments develop reliable cost estimates, the Secretary of HUD should finalize, and ensure the implementation of, guidance that incorporates the best practices called for in the GAO Cost Estimating and Assessment Guide.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In April 2017, HUD reported that the department concurred with the recommendation and noted that the Office of the Chief Information Officer (OCIO) intended to establish cost estimation guidance for IT projects within its IT Management Framework Guide, incorporating appropriate best practices from the GAO Cost Estimating and Assessment Guide. In March 2019, HUD reported that, with contractor assistance, the department had begun to develop a standard methodology for investment lifecycle cost estimation; however, the methodology had not been fully institutionalized across all investments, and a policy for cost estimation had not been developed. Lacking an updated IT Management Framework and cost estimation policy, OCIO took additional interim action in the most recent budget cycle to reduce cost estimation risk by having the Chief Technology Officer standardize the cost estimates for IT investments. HUD continues to take action intended to address this recommendation; however, OCIO has not yet finalized a cost estimation methodology or the associated policy for IT investments or established a timeframe for implementing cost estimation practices departmentwide.

Recommendation: To improve federal agencies' efforts to rationalize their portfolio of applications, the heads of the Departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development, the Interior, Labor, State, Transportation, the Treasury, and Veterans Affairs; and heads of the Environmental Protection Agency; National Aeronautics and Space Administration; National Science Foundation; Nuclear Regulatory Commission; Office of Personnel Management; Small Business Administration; Social Security Administration; and U.S. Agency for International Development should direct their Chief Information Officers (CIOs) and other responsible officials to improve their inventories by taking steps to fully address the practices we identified as being partially met or not met.

Agency: Department of Housing and Urban Development
Status: Open

Comments: We reported that the Department of Housing and Urban Development (HUD) partially met the following three software application inventory practices, (1) includes systems from all organizational components, (2) specifies basic application attributes, and (3) is regularly updated with quality controls to ensure reliability. In June 2017, the department reported that it is working to identify applications in field offices, and planned for this effort to be completed in fiscal year 2018. In addition, the department stated it planned to update the inventory to include business functions for each system by the end of fiscal year 2017. Further, department officials stated that to ensure the accuracy and reliability of the application inventory, the department planned to conduct quarterly portfolio reviews starting in fiscal year 2018. In October 2018, HUD officials reported that CTO performed a technical assessment of HUD's IT assets, which resulted in identifying systems in the inventory that had been decommissioned and will be decommissioned. In addition, the department provided its strategy for performing the assessment. In August 2019, HUD reported that it completed an assessment of its legacy applications and the current inventory system is outdated. However, as of January 2020, HUD had not yet provided an updated inventory. We plan to continue to monitor the department's efforts to address the recommendation.

Recommendation: To better inform Congress and improve what is known about the extent to which elderly residents of Section 202 properties are assisted by service coordinators, the Assistant Secretary for Housing should develop and implement written guidance that describes how HUD staff should assess Section 202 properties' compliance with the program's supportive services requirement. Such guidance should include information on the roles and responsibilities of HUD staff for (1) identifying stand-alone Section 202 properties and (2) monitoring the supportive services requirement for Section 202 properties with grant- and budget-based service coordinators, Section 202 properties that do not have service coordinators, and stand-alone Section 202 properties.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2018, HUD noted that it is in the process of finalizing written guidance which will document the agency's expectations regarding the supportive services requirement for Section 202 properties. HUD plans to finalize the guidance and post it on its website by May 2018. In July 2019, HUD noted that it posted guidance related to service coordinators on its website in 2018. The guidance describes the roles and responsibilities of service coordinators as well is reporting policies related to budget-based service coordinators. As of October 2019, HUD noted that it is drafting guidance that includes information on identifying and monitoring stand-alone Section 202 properties. This recommendation will remain open until HUD can demonstrate providing guidance to HUD staff on (1) identifying stand-alone Section 202 properties, and (2) monitoring the supportive services requirement for various types of Section 202 properties, including properties without service coordinators and stand-alone Section 202 properties. In December 2019, we requested further information from HUD and will continue to follow up on the agency's progress toward implementing this recommendation.

Recommendation: To better inform Congress and improve what is known about the extent to which elderly residents of Section 202 properties are assisted by service coordinators, the Assistant Secretary for Housing should develop and implement policies and procedures for (1) verifying the accuracy of a sample of the performance information that Section 202 properties submit through semiannual performance reports and (2) analyzing the performance information collected.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2018, HUD noted that it had implemented a pilot program in 2017 which connected the information systems that some Section 202 properties use to record information on their service coordinator programs to a "grant reporting framework." In February 2018, HUD staff told us that all Section 202 properties with Service Coordinators would be required to use the new grant reporting framework in 2018, and that the new framework included edit checks and other mechanisms designed to improve the reliability of the data reported. In July 2019, HUD noted that they are continuing work on the pilot program and have not analyzed the data yet. They also stated that the pilot includes processes to help ensure the reliability of the data. In October 2019, HUD stated that the pilot ended in FY 2018 and the new grant reporting framework became a national reporting requirement for all Multifamily service coordinator programs (grant-funded and budget-based) in FY 2019. This recommendation will remain open until HUD develops and implements policies and procedures for (1) verifying the accuracy of a sample of performance information, and (2) analyzing the performance information collected. In December 2019, we requested further information from HUD and will continue to follow up on the agency's progress toward implementing this recommendation.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to define a high-level depiction of the IT systems anticipated in the future state, a description of the operations that must be performed and who must perform them, and an explanation of where and how the operations are to be carried out.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had collaborated through an IT technical assessment initiative, identifying four primary financial management modernization initiatives remaining from the New Core Program. In July 2020, HUD officials, including the Deputy Chief Financial Officer, provided a roadmap that defined a high-level depiction of the financial management systems anticipated in the future state. However, the department had not yet completed more detailed plans that (1) identify operations that must be performed and who must perform them and (2) explain where and how operations are to be carried out. We will continue to monitor HUD's efforts to address this recommendation.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to develop comprehensive plans for scope, schedule and cost.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization. As of July 2020, the department had begun taking action to address this recommendation. Specifically, HUD planned to integrate loan and property management into its current financial management shared service and had begun planning for how to modernize its budget formulation and cost accounting systems. For the budget formulation effort, HUD had developed high-level plans for the scope of the program, planned an implementation schedule, and estimated on the cost for implementation and operating and maintaining the system for two years. We will continue to monitor HUD's efforts to address this recommendation.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to ensure requirements are fully documented and traceable.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In March 2017, the department reported that the Chief Financial Officer and the Chief Information Officer intended to partner on future departmental financial management systems modernization efforts to fully document requirements and trace requirements to the functionality in the modernized system. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization in 4 areas previously identified for the New Core program. As of July 2020, HUD was in the early phases of planning for modernization in these areas. According to officials from the Office of the Chief Financial Officer, the department intended to address this recommendation for budget formulation modernization by developing applicable plans and artifacts for managing requirements from the department's project planning and management framework. However, that effort has not yet started. We intend to continue to follow up on HUD's actions.

Recommendation: The Secretary of HUD should also direct the Deputy Secretary to ensure that the Chief Information Officer takes action to improve IT governance control activities used for monitoring programs and identifying needed corrective actions, and strengthen investment oversight by improving coordination with stakeholders and alignment among IT modernization efforts.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. Since 2016, HUD has revised its IT governance boards, which provide oversight of all its IT investments, including financial management initiatives, several times. While the department has not yet completed those improvement efforts, HUD updated its project planning and management framework to tailor requirements and artifacts for different program types. According to an official from the Office of the Chief Financial Officer, updates to the requirements for shared services projects incorporated lessons learned from the New Core program. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization in 4 areas previously identified for the New Core program. Officials from both offices have described improvements in their coordination and collaboration on efforts to plan for modernization. We intend to continue to follow up on HUD's actions to ensure that planned improvements to governance and oversight mechanisms are effectively implemented and institutionalized.

Recommendation: In order to more fully implement key practices and meet requirements and to better institutionalize standards and practices, the Secretary of HUD should establish a process and schedule for regularly reviewing, revising, and updating HUD's human capital strategic plan, strategic workforce plan, and succession plan.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In response to our recommendation, HUD developed an internal management calendar and associated standard operating procedures. The purpose of the management calendar is to document recurring processes of program offices across the agency, assist in planning and managing the agency's deliverables to ensure that critical deadlines are met, and provide information on ongoing reporting requirements occurring across the agency. We will determine whether HUD has fully implemented our recommendation when the agency provides documentation showing how the management calendar is used for updating human capital, workforce, and succession plans.

Recommendation: In order to more fully implement key practices and meet requirements and to better institutionalize standards and practices, the Secretary of HUD should establish a process and schedule for reviewing and updating policies and procedures to help ensure that policies and procedures for key management functions remain current and complete.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In response to our recommendation, HUD developed an internal management calendar and associated standard operating procedures. The purpose of the management calendar is to document recurring processes of program offices across the agency, assist in planning and managing the agency's deliverables to ensure that critical deadlines are met, and provide information on ongoing reporting requirements occurring across the agency. We will determine whether HUD has fully implemented our recommendation when the agency provides documentation showing how the management calendar is used for updating policies and procedures for key management functions.

Recommendation: To improve the department's IT savings reinvestment plans, the Secretary of Housing and Urban Development should direct the CIO to ensure that the department's integrated data collection submission to OMB includes, for all reported initiatives, complete plans to reinvest any resulting cost savings and avoidances from OMB-directed IT reform-related efforts.

Agency: Department of Housing and Urban Development
Status: Open

Comments: The Department of Housing and Urban Development agreed with, and has taken initial steps to implement, our recommendation. Specifically, as of May 2020, the department's integrated data collection submission included reinvestment plans for one of the eight cost savings and avoidance initiatives reported. However, the seven remaining initiatives, with savings and avoidances totaling approximately $6.3 million, did not include reinvestment plans. The department expects to provide an update in June 2020. We will continue to evaluate the department's progress in implementing this recommendation.

Recommendation: To enhance the effectiveness of its preparations for conducting a retrospective review of its QM regulations, HUD should develop a plan that identifies the metrics, baselines, and analytical methods to be used. Furthermore, to account for and help mitigate the limitations of existing data and the uncertain availability of enhanced datasets, HUD should include in its plan alternate metrics, baselines, and analytical methods that could be used data were to remain unavailable.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2017, HUD noted that it does not currently collect data on the annual percentage rate (APR) for each loan that would allow for a perfect comparison to the average prime offer rate. According to HUD, its Office of Housing has on its long-term list of systems priorities to collect specific information from the Uniform Closing Data that could be used to conduct such a comparison. However, HUD stated that it has not received adequate funding to meet these systems enhancements. According to HUD, it is considering the feasibility and potential utility of alternative data sources or the use of a proxy in an appropriate methodology. For instance, whether it may be possible to approximate the APR based upon the note rate and information on closing costs that is collected in the current data system, or alternatively, whether the APR could be obtained or approximated through matching Home Mortgage Disclosure Act data for FHA loans. In a September 2020 email, HUD officials stated that HUD has certain unique considerations for review of its own QM rule as compared to the other federal agencies covered in the GAO report. HUD officials explained that HUD's QM rule implemented certain changes intended to conform with the Consumer Financial Protection Bureau's (CFPB) rule and constituted only a small subset of FHA's overall requirements related to underwriting and loan characteristics. According to HUD officials, HUD's QM rule was intended to make conforming changes to FHA's requirements, as statutorily required, in order to bring them into greater alignment with the new CFPB-promulgated QM rule requirements. They stated that HUD assesses FHA loan performance on an ongoing basis through a variety of mechanisms including the annual audit requirement and monitoring of the overall market and mortgage portfolio. According to the HUD officials, these mechanisms are used to assess the need for adjustments in underwriting criteria and mortgage insurance premiums as well as to assess the health and risks to safety and soundness of the MMIF Fund. HUD officials said that given these considerations, there is no specific stand-alone full evaluation of the HUD QM rule planned at this time.

Recommendation: To help determine the effectiveness of BRAC homeless assistance conveyances, the Secretaries of Housing and Urban Development and Defense should update the BRAC homeless assistance regulations to require that conveyance statuses be tracked. These regulatory updates could include requiring DOD to track and share disposal actions with HUD and requiring HUD to track the status following disposal, such as type of assistance received by providers and potential withdrawals by providers.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations to require that conveyance statuses be tracked, which could include requiring DOD to track and share disposal actions with HUD and requiring HUD to track the status following disposal. HUD stated that it is willing to update the BRAC homeless assistance regulations to track the conveyances of property for homeless assistance, but noted that it will require DOD agreement to do so because the regulations are joint. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include specific guidance that clearly identifies the information that should be provided to homeless assistance providers during tours of on-base property, such as the condition of the property.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include specific guidance that clearly identifies the information that should be provided to homeless assistance providers during tours of on-base property, such as the condition of the property. HUD stated that it will update its BRAC guidebook, website, and presentations to provide clarifying information for homeless assistance providers regarding what information should be included during tours of on-base property. HUD also noted in its response that this will require DOD and military department agreement to implement and that the provision of information about the condition of on-base property and access to that property is under the purview of the military department. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include information for homeless assistance providers to use for preparing their notices of interest.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include information for homeless assistance providers to use in preparing their notices of interest. HUD stated that it will update its BRAC guidebook, website, and presentations to provide clarifying information for homeless assistance providers to use in preparing their notices of interest. HUD also stated that it considered the current regulations and BRAC guidebook sufficient to inform providers as long as LRAs did not place additional requirements, which may create an undue burden for providers. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include guidance for legally binding agreements and clarification on the implications of unsigned agreements.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include guidance for legally binding agreements and clarification on the implications of unsigned agreements. HUD stated that it will update its BRAC guidebook, website, and presentations to provide clarifying information for homeless assistance providers to use in preparing legally binding agreements and on the implications of unsigned agreements. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include specific information on legal alternatives to providing on-base property, including acceptable alternative options such as financial assistance or off-base property in lieu of on-base property, information about rules of sale for on-base property conveyed to homeless assistance providers, and under what circumstances it is permissible to sell property for affordable housing alongside the no-cost homeless assistance conveyance.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include specific information on legal alternatives to providing on-base property, including acceptable alternative options such as financial assistance or off-base property in lieu of on-base property, information about rules of sale for on-base property conveyed to homeless assistance providers, and under what circumstances it is permissible to sell property for affordable housing alongside the no-cost homeless assistance conveyance. HUD stated that it will update its BRAC guidebook, website, and presentations to clarify that the use of off-base property and financial assistance are acceptable alternate means of homeless assistance accommodation in base redevelopment plans and to include examples of alternatives to on-base property that have been approved to date. HUD also stated that this will require DOD and military department agreement to implement. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To help improve the timeliness of the HUD review process, the Secretary of Housing Urban Development should develop options to address the use of staff resources dedicated to the reviews of bases during a BRAC round, such as assigning temporary headquarters staff or utilizing current field HUD staff.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to develop options to address the use of staff resources dedicated to the reviews of bases during a BRAC round, such as assigning temporary headquarters staff or utilizing current field HUD staff. HUD stated that it temporarily assigned headquarters staff and utilized field office staff during the 2005 round of BRAC. HUD also stated that, in the event of another BRAC round the size of 2005, it would encourage Congress to allocate funding for appropriate temporary staff resources to assist the department in meeting important timelines. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To ensure that HUD fully implements and sustains effective IT governance practices, the Secretary of Housing and Urban Development should direct the Deputy Secretary and the department's Chief Information Officer to place a high priority and ensure that the executive-level investment review board meets as outlined in its charter, documents criteria for use by the other boards, and distributes its decisions to appropriate stakeholders.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD has not provided information demonstrating that the department has addressed this recommendation. HUD reported that it established a new executive-level investment review board (i.e. the Executive Operations Committee) that replaced the board discussed in our report. The department also provide evidence of the board's initial governance activities, including providing criteria to guide board decision-making in January 2017. However, the board has not continued to meet and act in accordance with its charter. In April 2019, HUD reported that it was updating its governance process and charters and stated an intent to ensure that executive-level decision making is clearly defined including when a decision needs to be made, at what level that decision needs to be made, what criteria should be used, and how that decision will be communicated. HUD has not yet provided evidence that the updated governance process and charter have been finalized and implemented.

Recommendation: To ensure that HUD fully implements and sustains effective IT governance practices, the Secretary of Housing and Urban Development should direct the Deputy Secretary and the department's Chief Information Officer to place a high priority and fully establish and maintain a complete set of governance policies, establish time frames for establishing policies planned but not yet developed, and update key governance documents to reflect changes made to established practices.

Agency: Department of Housing and Urban Development
Status: Open

Comments: The department has taken steps to address this recommendation. In 2015, HUD updated its Project Planning and Management policy. Since that time, the department has developed additional policies (e.g., IT risk management policy), revised policies for the IT management framework and Agile development, and reported that it reviewed OCIO's existing policies in September 2018. In October 2018, HUD provided a copy of the draft of the revisions to its IT Management Framework (dated February 2018) and OCIO reported plans to continue developing and maintaining IT policies for each of the framework's elements and to review policies for currency annually on the anniversary date of the policy. As of March 2019, HUD reported that a central repository had been developed to store, track and monitor policy reviews. GAO is seeking additional evidence from the newly implemented policy review process.

Recommendation: To ensure that HUD fully implements and sustains effective IT governance practices, the Secretary of Housing and Urban Development should direct the Deputy Secretary and the department's Chief Information Officer to place a high priority and fully establish an IT investment selection process that includes (1) articulating how reviews of project proposals are to be conducted; (2) planning how data (including cost estimates) are to be developed and verified and validated; (3) establishing criteria for how cost, schedule, and project risk are to be analyzed; (4) developing procedures for how proposed projects are to be compared to one another in terms of investment size (cost), project longevity (schedule), technical difficulty, project risk, and cost-benefit analysis; and (5) ensuring that final selection decisions made by senior decision makers and governance boards are supported by analysis, consider predefined quantitative measures, and are consistently documented.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD has provided information demonstrating that the department has addressed elements of this recommendation. In 2015, HUD reported that it had begun using a new tool to support its IT selection process. In May 2018, the department provided a demonstration of its HUD PLUS tool, including how it had used the tool to automate its selection process. The officials demonstrated how the tool is being used to review proposed projects. They reported that segment sponsors are responsible for validating data submitted but have not provided evidence that the department has developed guidance for that process. The officials demonstrated how the tool supports analysis of investment costs, schedule, and risk. They also demonstrated how the tool helps the Office of the Chief Information Officer compare investments based on cost and showed how decision makers access information and can perform analysis for all projects in the system. Department officials have not yet provided evidence that HUD has improved each of the areas noted in our recommendation. OCIO reported in April 2019 that it intends to: conduct the selection process on a more frequent basis and allow more time for annual budget considerations, improve performance metrics, and further incorporate cost-benefit analysis. OCIO also reported that it intends to better incorporate its management and oversight of the portfolio into a more formal "re-select" process. OCIO also reported that HUD was updating its governance policies to detail the criteria, data, and process used to select investments and targeting action to close this recommendation in 2019.

Recommendation: To establish an enterprise-wide view of cost savings and operational efficiencies generated by investments and governance processes, the Secretary of Housing and Urban Development should direct the Deputy Secretary and Chief Information Officer to place a higher priority on identifying governance-related cost savings and efficiencies and establish and institutionalize a process for identifying and tracking comprehensive, high-quality data on savings and efficiencies resulting from IT investments and the IT governance process.

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: The department has taken steps to address this recommendation. Specifically, in April 2016, HUD provided examples of cost savings that the department had identified by "scrubbing" existing contracts during the budget formulation process, along with copies of a template that it designed and used to help identify such savings. In May 2018, department officials provided a demonstration of the HUD PLUS tool, including screens staff could use to report cost savings and avoidances related to specific projects--although they reported that HUD was not yet using that functionality. In April 2019, OCIO reported that HUD was updating its governance process and charters to ensure that executive-level decision making will be clearly defined. OCIO also reported an intent to implement Technology Business Management to, among other things, improve and expand the tracking of investments. HUD expects these two efforts to facilitate better tracking of the savings and efficiencies resulting from IT decisions. The department has not yet provided evidence that it has established guidance supporting a repeatable process for tracking enterprise-wide IT related cost savings and operational efficiencies, including those related to HUD's governance decisions.

Recommendation: To better ensure the viability and safety of manufactured housing produced in accordance with the HUD Code, the Secretary of the Department of Housing and Urban Development should develop a plan to assess how FHA financing might further promote the affordability of manufactured homes and identify the potential for better securitization of manufactured housing financing.

Agency: Department of Housing and Urban Development
Status: Open

Comments: According to HUD officials, Ginnie Mae and FHA met to discuss their manufactured housing programs and produced a white paper. Once we receive a copy of the white paper, we will determine if it addresses our recommendation.

Recommendation: To better ensure that Congress, stakeholders, and agencies have complete information about changing costs and whether a fee needs to be changed, HUD should assess the feasibility, including an analysis of the benefits and costs, of putting in place user fees for its dispute resolution and installation programs.

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of March 2018, HUD stated that the Office of Manufactured Housing Programs continues to work toward fully implementing both the installation and dispute resolution programs in the default states using two new contractors for these purposes. As the implementation of these programs continues to mature, HUD stated that its Office of Manufactured Housing Programs will be monitoring program requirements and service delivery and gathering data that it can use in assessing the feasibility of putting in place user fees for these programs. We will continue to monitor HUD's progress in implementing our recommendation.

Recommendation: To better ensure that Congress, stakeholders, and agencies have complete information about changing costs and whether a fee needs to be changed, HUD should establish the goals for use of reserves of the Manufactured Housing Fees Trust Fund, and the minimum and maximum thresholds for the reserves appropriate for meeting these goals.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In response to this recommendation, as of March 2018, HUD plans to consider user fee reserve best practices in evaluating any carryover balances and developing future operating budgets for its manufactured housing programs. The Office of Manufactured Housing Programs plans on reviewing best practices and determining next steps ideally by the end of Fiscal Year 2019. We continue to believe that setting clear goals for the reserve and clarifying how those reserves will be used helps ensure accountability and transparency both to Congress and users of fee-based programs. We will continue to monitor HUD's progress in implementing our recommendation.

Recommendation: To increase consistency and reduce time and predevelopment cost for NAHASDA grant recipients, an interagency effort similar to that of the federal infrastructure task force but specific to tribal housing should be initiated with participants from the Indian Health Service, HUD, Department of the Interior, and the U.S. Department of Agriculture to develop and implement a coordinated environmental review process for all agencies overseeing tribal housing development. In addition, the agencies should determine if it would be appropriate to designate a lead agency in this effort.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In September 2017, HUD provided us with documentation that an interagency Coordinated Environmental Review Process Workgroup was formed and included representatives from HUD, the Council on Environmental Quality (CEQ), USDA, Department of Commerce, Department of Energy, Environmental Protection Agency, HHS, Interior, and the Department of Transportation. The workgroup focused on identifying measures that could be taken to coordinate agencies' environmental review processes within the existing framework, and in December 2015, presented 12 recommendations in a final report. The recommendations included developing common categorical exclusions; providing training for agency staff and tribes; continuing review of related environmental laws and authorities to identify opportunities for greater efficiencies; creating regional consortiums; and establishing an ongoing environmental review interagency workgroup. In addition, the workgroup developed a draft implementation plan, and drafted a Memorandum of Understanding whose stated purpose is "to further the shared goals of the parties to ensure comprehensive NEPA environmental reviews while facilitating access to federal assistance for housing and housing-related infrastructure projects in Indian Country involving multiple agencies by avoiding duplication of analyses and ensuring efficient environmental review processes for both tribes and agencies". In December 2018, HHS notified GAO that the final draft implementation plan remained under review by members of the interagency workgroup.

Recommendation: To ensure effective management and modernization of HUD's IT environment, the Secretary of Housing and Urban Development should direct the department's Chief Information Officer to define the scope, implementation strategy, and schedule of its overall modernization approach, with related goals and measures for effectively overseeing the effort.

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In July 2018, the Office of the Chief Information Officer (OCIO) reported that the goal of the Chief Technology Officer's technical assessment of HUD's IT environment was to identify gaps and develop an implementation strategy and approach to establish a modernization roadmap. As of March 2020, OCIO reported that it had completed the technical assessment to identify gaps in IT. The department has also taken action to define an overall modernization approach, including the scope, implementation strategy, and schedule for modernizing its IT environment and systems. However, as of March 2020, HUD had not yet established measures for overseeing its modernization efforts.

Recommendation: In order to demonstrate compliance across the program with the statutory limit on funds that can be used for administration, the Secretary of HUD should direct the Assistant Secretary for Community Planning and Development to develop a process for generating annual reports on compliance across the program, including making any requisite changes to IDIS to better ensure that the agency has complete and analyzable data to support such reporting.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In May 2020, a HUD official told us that the agency did not have the funding necessary to make any changes to IDIS. According to this official, HUD was willing to create the recommended across-program report, but did not have the information technology funding required to make other, higher-priority changes to IDIS (such as fixing identified defects) or the change GAO recommended.

Recommendation: To better ensure that air ventilation systems in manufactured homes perform as specified and meet the HUD Code, HUD should develop an appropriate method to test and validate the performance of the ventilation system as part of the HUD certification process.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In March 2017, HUD stated that it has not developed a test to validate the performance of the whole-house ventilation specification. HUD reported that the Manufactured Housing Consensus Committee (MHCC) did not agree with the testing validation recommendations. As of March 2018, HUD continues to move forward in updating its standards, including a test for whole house ventilation. However, as part of the overall HUD effort to review regulations, HUD officials stated they are currently conducting a review of current and planned federal regulations for manufactured housing with the goal to facilitate the affordability of manufactured housing and to promote durable, safe, and cost effective construction techniques for manufactured homes. As a result, HUD does not anticipate moving forward with any manufactured housing regulations until it completes its review. We continue to believe that developing such a test will better ensure that air ventilation systems in manufactured homes perform as specified and meet the HUD Code and will continue to monitor HUD's progress in implementing our recommendation.

Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should consistently collect information that would enable them to track the specific type of assistance programs provide and the entrepreneurs they serve and use this information to help administer their programs.

Agency: Department of Housing and Urban Development
Status: Open

Comments: According to HUD, the department implemented improvements to its Integrated Disbursement and Information System in 2012, which were intended to upgrade HUD's ability to track Community Development Block Grant (CDBG) grantee progress in implementing activities and gather improved data with regard to performance. In addition, HUD completed an extensive CDBG data clean-up effort in response to a HUD Inspector General audit.

Recommendation: The Secretaries of the Departments of Agriculture, Commerce, and Housing and Urban Development, and the Administrator of the Small Business Administration should conduct more program evaluations to better understand why programs have not met performance goals and their overall effectiveness.

Agency: Department of Housing and Urban Development
Status: Open

Comments: According to HUD, the department implemented improvements to its Integrated Disbursement and Information System in 2012, which were intended to upgrade HUD's ability to track Community Development Block Grant (CDBG) grantee progress in implementing activities and gather improved data with regard to performance. In addition, HUD completed an extensive CDBG data clean-up effort in response to a HUD Inspector General audit.

Recommendation: To strengthen formal collaboration efforts, the Secretary of Transportation should direct the Administrator of the Federal Transit Administration, and the Secretary of Housing and Urban Development should direct the appropriate program offices, to develop a plan to ensure that data collected on the various programs of the agencies related to affordable housing and transit are sufficient to measure the agencies' performance toward goals and outcomes established in the HUD-FTA action plan and the Partnership for Sustainable Communities.

Agency: Department of Housing and Urban Development
Status: Open

Comments: On November 30, 2009, we received a response from HUD stating that actions were planned or underway to address this and the other recommendation in this report. As of July 2019, we are reviewing additional documentation provided by DOT and HUD on actions they have taken.