Recommendation: The OHS Director should require Head Start grantees to document that water provided to children has been tested for lead. OHS could determine various ways that are feasible and efficient for grantees to satisfy this requirement; for example, verification could be done through OHS' current grantee data collection or monitoring processes. (Recommendation 1)

Agency: Department of Health and Human Services
Status: Open

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

Recommendation: The Assistant Secretary for the Administration for Children and Families should direct OCC and OHS to develop an agreement with EPA on their roles and responsibilities in implementing the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities. For example, these agreements may include the ways in which guidance and information will be shared with states and Head Start grantees, such as through webinars or email, and how frequently. (Recommendation 2)

Agency: Department of Health and Human Services
Status: Open

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

Recommendation: The Assistant Administrator of the Office of Water should develop an agreement with HHS's Offices of Child Care and Head Start on their roles and responsibilities in implementing the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities. For example, these agreements may include the ways in which guidance and information will be shared with states and Head Start grantees, such as through webinars or email, and how frequently. (Recommendation 3)

Agency: Environmental Protection Agency
Status: Open

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

Recommendation: The Assistant Administrator of the Office of Water should direct the Office of Water to specify how it will track progress toward the outcomes of the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities and determine how it will regularly monitor and update the MOU. For example, the Office of Water could develop performance measures for each of the MOU's outcomes. In addition, the Office of Water could submit annual reports on progress toward achieving the MOU's outcomes or it could plan to update the agreement at specific intervals. (Recommendation 4)

Agency: Environmental Protection Agency
Status: Open

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

Recommendation: The Assistant Secretary for Elementary and Secondary Education should improve the usability of Education's websites to ensure that the states and school districts can more easily find and access federal guidance to address lead in school drinking water, by taking actions such as clarifying which links contain guidance; highlighting new or important guidance; improving their websites' search function; and categorizing guidance. (Recommendation 5)

Agency: Department of Education
Status: Open

Comments: The Department of Education agreed with this recommendation. The agency said it would identify and include an information portal dedicated to enhancing the usability of federal resources related to testing for and addressing lead in school drinking water. Also, Education said it is interested in increasing coordination across all levels of government and it shares the view expressed in our report that improved federal coordination, including with EPA, will better enhance collaboration to encourage testing for lead in school drinking water. In 2019, Education said it planned to complete work on this recommendation by January 1, 2020. We will consider closing this recommendation when these efforts are complete.

Recommendation: The Assistant Secretary for Elementary and Secondary Education should collaborate with EPA to encourage testing for lead in school drinking water. This effort could include disseminating EPA guidance related to lead testing and remediation in schools or sending letters to states to encourage testing in all school districts that have not yet done so. (Recommendation 7)

Agency: Department of Education
Status: Open
Priority recommendation

Comments: The Department of Education agreed with this recommendation. Education stated it has held multiple meetings with the Environmental Protection Agency (EPA) and stated that it plans to hold a virtual meeting with EPA to share information and resources about safe drinking water and raise awareness of the importance of testing for lead. Education also stated it is developing a timeline to conduct additional collaboration activities with EPA. Education officials said they are considering joining an EPA-led Memorandum of Understanding to, among other things, encourage schools to test drinking water for lead. We will consider closing this recommendation when these efforts are complete.

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 Assistant Administrator for Water of EPA's Office of Water should require states to report available information about lead pipes to EPA's Safe Drinking Water Information System (SDWIS)/Fed (or a future redesign such as SDWIS Prime) database, in its upcoming revision of the LCR. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open
Priority recommendation

Comments: As of July 2020 there has been no change in the status of this recommendation. In July 2019, EPA said that the 2016 America's Water Infrastructure Act (AWIA) requires EPA to conduct an assessment of the costs to replace lead service lines and that EPA would conduct this assessment (a survey) in 2020. In a previous update, EPA said that it would consider GAO's recommendation to require states to report available information about lead pipes along with those of other stakeholders as part of the development of the revisions to the Lead and Copper Rule. EPA officials estimated that the agency would publish a proposal for the revisions in 2019.

Recommendation: The Assistant Administrator for Water of EPA's Office of Water should require states to report all 90th percentile sample results for small water systems to EPA's SDWIS/Fed (or a future redesign such as SDWIS Prime) database, in its upcoming revision of the LCR. (Recommendation 2)

Agency: Environmental Protection Agency
Status: Open
Priority recommendation

Comments: As of July 2020 there has been no change in the status of this recommendation. In July 2019, EPA said that it would consider GAO's recommendation to require states to report all 90th percentile sample results for small systems along with those of other stakeholders as part of the development of the revisions to the Lead and Copper Rule. EPA officials estimated that a proposal for the revisions would be published in 2019.

Recommendation: The Assistant Administrator for Water of EPA's Office of Water and the Assistant Administrator of EPA's Office of Enforcement and Compliance Assurance should develop a statistical analysis that incorporates multiple factors--including those currently in SDWIS/Fed and others such as the presence of lead pipes and the use of corrosion control--to identify water systems that might pose a higher likelihood for violating the LCR once complete violations data are obtained, such as through SDWIS Prime. (Recommendation 3)

Agency: Environmental Protection Agency
Status: Open
Priority recommendation

Comments: As of July 2020 there has been no change in the status of this recommendation. In July 2019, EPA stated that the agency developed a Lead and Cooper Rule (LCR) violation reporting tool that is updated and distributed to the EPA regional offices on a quarterly basis. This tool, according to EPA, enhances national oversight by fostering closer engagement with the regional offices to continuously assess any new water systems violating the LCR. EPA has stated that the agency has also developed, and shared with its regional offices, an internal resource to make ad hoc assessments of water systems, nationwide, that would benefit most from assistance with lead service line replacements or (for water systems without lead service lines) corrosion control treatment installation/re-optimization. According to EPA, this internal resource takes a multi-factor approach that considers historical action level exceedance occurrences and information on additional factors (for which information is already available through regulatory development efforts for the LCR long-term revisions or internet search engine queries). These additional factors include the number of lead service lines known to be present in a given water system; the proportion of a system's service connections that are served by lead service lines; and potential technical, managerial, and financial capacity challenges experienced by that system. Although EPA has made progress in addressing the recommendation, GAO will leave this recommendation open until SDWIS Prime is implemented.