Recommendation: The Council should further clarify and document its roles and responsibilities with regard to USICH matters requiring the Council's approval, the role of the Council Chair, and actions within the Executive Director's delegated authority. (Recommendation 1)

Agency: United States Interagency Council on Homelessness
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 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 Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, provide updated guidance for the oversight of privatized military housing, to include oversight objectives for each service to monitor the physical condition of privatized homes over the remaining duration of the ground leases. (Recommendation 1)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD (S)), as the Chief Housing Officer, issued guidance requiring the military departments to monitor work order completion for housing privatized under the Military Housing Privatization Initiative based on a combination of resident input, timeliness of work order completion, and number of repeat work orders for the same repair. The guidance also required increased tracking of MHPI project work orders by installation staff. Moving forward, the ASD(S) plans to issue quarterly program review guidance that establishes oversight objectives for the military departments to monitor the physical condition of MHPI housing over the duration of their project ground leases, formalizing the requirement that the data be monitored by the Chief Housing Officer. DOD expects this to be completed by December 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Army should take steps, in collaboration with the Army's private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 2

Agency: Department of Defense: Department of the Army: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Secretary of the Army has taken several steps toward addressing this recommendation. For example, the Army published the Portfolio and Asset Management Handbook creating a multi-tiered assessment approach of performance metrics to measure the health of each privatized home through inspection, assessment, satisfaction, and feedback. The Army and the private housing partners revised the Incentive Fee Performance Management Plan, placing increased emphasis on resident satisfaction and work order/maintenance management. The Army also put Commanders in charge, ensuring Army leadership at every Army installation is tracking housing quality and safety. In late 2020, the Army plans to review and evaluate these actions and make a determination by 31 Jan 2021 if any changes or revisions are needed to best implement the recommendation. As such, we will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Air Force should take steps, in collaboration with the Air Force's private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 3)

Agency: Department of Defense: Department of the Air Force: Office of the Secretary of the Air Force
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Air Force is engaging in several steps to address this recommendation. Specifically, in March 2020, the Air Force tasked each of the Military Housing Offices to inspect all move-in, move-out, and change of occupancy maintenance events and all emergency, urgent, and life, health, and safety work orders, which is outlined in Air Force guidance. The Air Force is also engaging in several ongoing actions. In response to a memo to the military departments to provide consistency of performance incentive fees, the Air Force was negotiating with the privatized housing project owners to update performance incentive fee metrics in accordance with ASD directed categories and weightings. As of August 2020, agreements had been finalized with 2 partners and work was ongoing with the remaining partners. In addition, the Air Force was working with the project owners to deploy Satisfacts, a survey tool to independently measure resident satisfaction with projects' work order performance, across all Air Force projects with an expected completion by December 2020. We will continue to monitor the status of these recommendations.

Recommendation: The Secretary of the Navy should take steps, in collaboration with the Navy and Marine Corps' private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 4)

Agency: Department of Defense: Department of the Navy: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Navy and Marine Corps are engaging in several steps to address this recommendation. Specifically, the Navy and Marine Corps have developed a centralized electronic data warehouse, which receives data from privatized housing partner maintenance systems to display work order and survey performance dashboards. By February 2021, the Navy expects to complete the development of metrics displayed by the data warehouse to include key service call performance metrics and resident feedback data. The Navy and Marine Corps are also developing a web-based monitoring matrix tool housing officials can use to evaluate the performance of privatized housing partners. The tool is intended to provide improved tracking capabilities and improved accessibility to information, thus providing more consistent oversight and improved advocacy service members and their families. The Navy is also working to hire 247 additional Navy and Marine Corps housing staff to review and analyze private partner provided recurring maintenance and customer satisfaction reports in an effort to strengthen oversight and monitoring, with an estimated completion of September 2020. Moving forward, we will continue to monitor the status of these and other efforts.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments and private housing partners, establish minimum data requirements and consistent terminology and practices for work order data collection for comparability across installations and projects and to track trends over time. (Recommendation 5)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: e Department of Defense (DOD) partially concurred with this recommendation. In its August 2020 response, DOD stated that the Assistant Secretary of Defense for Sustainment (ASD(S)), as the Chief Housing Officer, plans to issue a policy directing the military departments to establish, to the maximum extent practical, minimum data requirements and consistent terminology and practices for MHPI housing unit work order collection to aid in comparability across installations and projects, and for tracking trends over time. However, DOD noted that the department cannot mandate changes to existing MHPI project legal documents. DOD estimates that this effort will be completed by December 2021. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment require the military departments to establish a process to validate data collected by the private housing partners to better ensure the reliability and validity of work order data and to allow for more effective use of these data for monitoring and tracking purposes. (Recommendation 6)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)), as the Chief Housing Officer, issued guidance directing the military departments to exercise proper oversight to ensure Military Housing Privatization Initiative (MHPI) projects perform in accordance with legal agreements, to include due diligence in monitoring and auditing project maintenance records and other project performance data. The guidance also required military departments to review their entire portfolios of MHPI projects to ensure accurate and appropriate work order management processes. In response to the new guidance, DOD noted that the military departments put in place appropriate oversight measures and undertook the required reviews, though the investigations of project business practices were ongoing in some cases. As another step, the ASD(S) plans to issue guidance directing the military departments to establish a process to validate data collected by their respective MHPI Project Owners to better ensure the reliability and validity of work order data and to allow for more effective use of these data for monitoring and tracking purposes. DOD expects this to be completed by the end of September 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, develop a process for collecting and calculating resident satisfaction data from the military departments to ensure that the data are compiled and calculated in a standardized and accurate way. (Recommendation 7)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) partially concurred with this recommendation based on the fact that the draft report listed the incorrect office as the source for addressing the deficiency, but subsequently changed its response to concur after the recommendation was directed to the appropriate office in the final report. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)) plans to issue guidance establishing a department-wide process for collecting and calculating resident satisfaction data to ensure that the data are compiled and calculated in a standardized and accurate way effective with the survey collection effort in Fiscal Year 2021. The department expects this effort to be completed by October 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure the Assistant Secretary of Defense for Sustainment provides additional explanation of the data collected and reported in future reports to Congress, such as explaining the limitations of available survey data, how resident satisfaction was calculated, and reasons for any missing data, among other things. (Recommendation 8)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) partially concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)) would provide additional explanation of the MHPI resident satisfaction data collected and reported in future annual Military Housing Privatization Initiative (MHPI) reports to Congress, effective with the annual report covering fiscal year 2019. DOD noted that the additional information will include, among other things, an explanation of the limitations of available survey data, how resident satisfaction was calculated, and reasons for any missing data. As of August 2020, the annual MHPI report covering fiscal year 2018 was in final coordination and the department noted that the report would addresses a vast majority, but not all, of the requirements identified in our recommendation. DOD noted that the additional information would be provided in the next annual MHPI report. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Army should develop and implement a plan to clearly and systematically communicate to residents the difference between the military housing office and the private partner. At a minimum, these plans should include the Army housing office's roles, responsibilities, locations, and contact information and should ensure that all residents are aware that they can directly contact Army housing office officials. (Recommendation 9)

Agency: Department of Defense: Department of the Army: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its response, DOD noted that the Army developed a "Plain Language" briefing as required by the 2020 National Defense Authorization Act that included the Army Housing Office's roles, responsibilities, location, and contact information at each privatized housing project site. DOD noted that the intent of the briefing was to ensure that all residents were aware of their ability to directly contact Army Housing Office and/or the Garrison Commanders. DOD stated that the briefing was disseminated to all of the Military Housing Offices, who are using it in newcomer briefings, and stated that the briefing would be provided to all current residents of privatized military housing, but that measure would not be tracked due to attrition. In addition, DOD noted that Headquarters, Department of the Army was tasking Army Materiel Command to develop a more detailed plan to communicate to residents the difference between the Army Housing Office and the private housing partner. The Army's intent is to not only capture residents upon their arrival at an installation, but making the services of the MHO known over the duration of a resident's time on at installation. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Navy should develop and implement a plan to clearly and systematically communicate to residents the difference between the military housing office and the private partner. At a minimum, these plans should include the Navy housing office's roles, responsibilities, locations, and contact information and should ensure that all residents are aware that they can directly contact Navy housing office officials. (Recommendation 11)

Agency: Department of Defense: Department of the Navy: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Navy has taken various steps to address this recommendation, with additional steps planned. For example, the Navy has ensured that each installation has a specific issue resolution process description marketing flyer available, both in hard copy and on the public housing websites, with a reminder that residents can contact both the privatized housing property manager and the Navy housing office with any issues. Moreover, every housing unit has been provided with a refrigerator magnet reminding residents that they can and should contact the Navy housing office if they have any issues with their home. In addition, the Navy and Marine Corps have established a requirement to contact each privatized housing resident not later than 15 days after move-in and again 60 days after move-in to provide an opportunity to request assistance and remind them of available support. Moving forward, the Navy has an ongoing effort to require private housing companies to market the same messaging as the service issue resolution processes for the MHOs that they support, for consistent advocacy messaging to the tenants. The information will be added to PPV partner websites, printed material and resident handbooks. The Navy also plans to use its annual survey to tracks resident satisfaction and awareness of the Navy's issue resolution process, with expected completion by October 2020. In addition, the Marine Corps has identified a near-term initiative to procure name tags for all MHO employees to wear, identifying themselves as distinct and separate from privatized housing property management company, which will be standardized across all USMC installations. The Marine Corps also plans to develop a standard welcome aboard package to include magnets and other items with key point of contact information. The Marine Corps expects these efforts to be completed by the end of September 2020.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, assess the risks of proposed initiatives aimed at improving the privatized military housing program on the financial viability of the projects. (Recommendation 12)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment, as the Chief Housing Officer, planned to issue a policy establishing the assessment of Military Housing Privatization Initiative (MHPI) project financial viability as part of quarterly program reviews as a long-term requirement. The department noted that the program review data would be augmented by input from the MHPI companies, who are assessing the likely impact of proposed initiatives in conjunction with their third party lenders. The department expected this effort to be completed by December 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of HUD should define and document roles and responsibilities for identifying opportunities to promote more efficient shared service usage through business process analyses, including defining roles for monitoring and implementing actions recommended because of these analyses. (Recommendation 1)

Agency: Department of Housing and Urban Development: Office of the Secretary
Status: Open

Comments: In a letter dated May 19 2020, HUD's Chief Financial Officer stated that HUD concurred with this recommendation and will more specifically define who is responsible for identifying and implementing opportunities for achieving efficiencies with service usage, including roles for the business process analyses the Working Capital Fund division conducts from time to time. HUD expects to complete this action by December 31, 2020. When we can confirm what actions HUD has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of HUD, in conjunction with OCFO, should ensure that the results of the WCF Division's business process analyses are assessed to better understand how these analyses contribute to the WCF's established goal to support the efficient delivery of enterprise goods and services. (Recommendation 2)

Agency: Department of Housing and Urban Development: Office of the Secretary
Status: Open

Comments: In a letter dated May 19 2020, HUD's Chief Financial Officer stated that HUD concurred with this recommendation and will add the results of the Working Capital Fund division's business process analyses as a performance metric to its Working Capital Fund performance scorecard. HUD expects to complete this action by December 31, 2020. When we can confirm what actions HUD has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of HUD should ensure that the WCF Committee conducts periodic reviews of WCF business lines, as authorized in the WCF Committee Charter, to ensure effective management, strong performance, and customer satisfaction. (Recommendation 3)

Agency: Department of Housing and Urban Development: Office of the Secretary
Status: Open

Comments: In a letter dated May 19 2020, HUD's Chief Financial Officer stated that HUD concurred with this recommendation and is in the process of implementing this recommendation. According to the letter, reviews of Working Capital Fund business lines are conducted as a part of regular Working Capital Fund Committee meeting discussions. However, the Committee plans to hold formal review sessions dedicated to reviewing the business lines. HUD expects to complete this action by December 31, 2020. When we can confirm what actions HUD has taken in response to this recommendation, we will provide updated information.

Recommendation: The FHA Commissioner should take steps to improve the quality and accuracy of HECM termination data. These steps may include updating the termination reasons in the HERMIT system or updating the HERMIT User Guide to more clearly instruct servicers how to record termination reasons. (Recommendation 1)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

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

Recommendation: The FHA Commissioner should establish, periodically review, and report on performance indicators for the HECM program—such as the percentage of terminations due to borrower defaults, the proportion of active HECMs with delinquent property charges, the amount of servicer advances, and the percentage of distressed borrowers who have received foreclosure prevention options—and examine the impact of foreclosure prevention options in the forthcoming HECM program evaluation. (Recommendation 2)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

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

Recommendation: The FHA Commissioner should develop analytic tools, such as dashboards or watch lists, to better monitor outcomes for the HECM portfolio, such as reasons for HECM terminations, defaults, use of foreclosure prevention options, or advances paid by servicers on behalf of HECM borrowers. (Recommendation 3)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

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

Recommendation: The FHA Commissioner should evaluate FHA's foreclosure prioritization process for FHA-assigned loans. Such an analysis should include the implications that the process may have for HECM borrowers, neighborhoods, and FHA's insurance fund. (Recommendation 4)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

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

Recommendation: The FHA Commissioner should develop and implement procedures for conducting on-site reviews of HECM servicers, including a risk-rating system for prioritizing and determining the frequency of reviews. (Recommendation 5)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: As of February 2020, FHA had taken steps to implement this recommendation--including developing a HECM Servicing Review Guide and scheduling reviews of the three largest HECM servicers--but had not finalized a risk-rating system for prioritizing and determining the frequency of additional HECM servicing reviews. We will update the status of the recommendation when FHA provides documentation of a risk-rating system for prioritizing and determining the frequency of reviews and has completed the three reviews scheduled for fiscal year 2020.

Recommendation: The FHA Commissioner should work with CFPB to complete an agreement for sharing the results of CFPB examinations of HECM servicers with FHA. (Recommendation 6)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

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

Recommendation: The CFPB Director should work with FHA to complete an agreement for sharing the results of CFPB examinations of HECM servicers with FHA. (Recommendation 7)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: As of April 2020, CFPB has begun to take steps to complete an information sharing agreement to facilitate the process of sharing confidential information with FHA, including the results of HECM examinations. However, work on the agreement remains ongoing and CFPB noted it looks forward to finalizing the agreement as soon as practicable.

Recommendation: The FHA Commissioner should periodically analyze available internal and external consumer complaint data about reverse mortgages to help inform management and oversight of the HECM program. (Recommendation 9)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: As of March 2020, FHA had taken steps to implement this recommendation, including using a different system to collect and record consumer complaints about HECMs and generating monthly reports on the information for FHA senior management. We will update the status of the recommendation when FHA provides documentation showing that it also periodically analyzes external consumer complaint data on HECMs.

Recommendation: The Commissioner of FHA should clearly define DASP objectives and develop measurable targets for all program objectives. (Recommendation 3)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued Standard Operating Procedures for these sales on October 17, 2019. We will continue to follow up with the agency on how it defines the DASP objectives and its development of measurable targets for the program objectives.

Recommendation: The Commissioner of FHA should use performance data to develop criteria for when to hold DASP sales. (Recommendation 4)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued a Standard Operating Procedure for these sales on October 17, 2019. However, HUD has not yet developed criteria for when to hold a DASP sale based on performance criteria.

Recommendation: The Commissioner of FHA should monitor individual purchasers' compliance with FHA's modification requirements and ensure the purchasers submit the data needed to evaluate the sustainability of modifications. (Recommendation 6)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued s Standard Operating Procedure for these sales on October 17, 2019. However, HUD has not yet addressed purchasers' compliance with FHA's modification requirements to ensure that purchasers submit the data needed to evaluate the sustainability of modifications. We will continue to follow up on the agency's response to this recommendation.

Recommendation: The Commissioner of FHA should develop a methodology to assess the range of possible outcomes for loans when setting DASP reserve prices. (Recommendation 8)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: HUD issued a Standard Operating Procedure for these sales on October, 17, 2019. The procedures address reserve pricing but we will continue to follow up with the agency on any plans to develop a methodology to assess the range of possible outcomes when setting the reserve prices.

Recommendation: The Commissioner of FHA should enhance the content and communication of FHA's policies and procedures on conveyance condition, including by considering the program stakeholder views discussed in this report and other stakeholder input. (Recommendation 1)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

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

Recommendation: The Commissioner of FHA should develop a formal plan for evaluating the outcomes of the preconveyance inspection pilot that includes key elements of evaluation design—such as evaluation objectives and measures—and utilizes participant feedback and control groups, as appropriate. (Recommendation 3)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

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

Recommendation: Congress should consider requiring Ginnie Mae to evaluate the adequacy of its current guaranty fee for single-family mortgage-backed securities and report to Congress with recommendations, if any, on revising the fee, such as by adopting standards under which the fee should be determined. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of September 2020, Congress had not enacted legislation to require Ginnie Mae to evaluate the adequacy of its current guaranty fee for single-family mortgage-backed securities and report to Congress with recommendations.

Recommendation: Congress should consider requiring Ginnie Mae to evaluate its reliance on contractors and report to Congress on how it would use fee revenue available to hire contractors to also hire in-house staff. (Matter for Consideration 2)

Agency: Congress
Status: Open

Comments: As of September 2020, Congress had not enacted legislation to require Ginnie Mae to evaluate its reliance on contractors and report to Congress on its findings.

Recommendation: Congress should consider requiring Ginnie Mae to provide a report on how it would use greater flexibility or broader authority to set the compensation of its in-house staff. (Matter for Consideration 3)

Agency: Congress
Status: Open

Comments: As of September 2020, Congress has not enacted legislation to require Ginnie Mae to report on how it would use greater flexibility or broader authority to set the compensation of its in-house staff.

Recommendation: Congress should consider reforms to Ginnie Mae's oversight structure that can help address its increasing risks. (Matter for Consideration 4)

Agency: Congress
Status: Open

Comments: As of September 2020, Congress has not enacted legislation that considers reforms to Ginnie Mae's oversight structure that can help address its increasing risks.

Recommendation: The Chief Risk Officer of Ginnie Mae should periodically conduct an actuarial or similar analysis that includes a stress test to evaluate the extent to which the current level of the guaranty fee for single-family MBS provides Ginnie Mae with sufficient reserves to cover potential losses under different economic scenarios. (Recommendation 1)

Agency: Department of Housing and Urban Development: Government National Mortgage Association (Ginnie Mae)
Status: Open
Priority recommendation

Comments: Ginnie Mae (HUD) agreed with this recommendation. As of September 2020, Ginnie Mae took steps to address this recommendation. First, according to its 2020 budget justification, Ginnie Mae has concluded that it would be advantageous to have the authority to administratively adjust its guarantee fee and requested that the permissible guarantee fee be established within a range. Upon receipt of this authority, Ginnie Mae would then establish an administrative process through which an adjustment could be made. Second, Ginnie Mae has developed a stress test framework and solicited public comment. According to officials, by early 2021, Ginnie Mae plans to have its contractor develop an economic model to explore the current level of the guaranty fee under different economic scenarios including variations in issuer types and across Ginnie Mae programs. To fully implement this recommendation, Ginnie Mae needs to follow through on this effort and provide additional detail on changes to the existing models and its plan to periodically conduct this analysis. We will continue to monitor Ginnie Mae's progress in implementing our recommendation.

Recommendation: The Senior Vice President of Ginnie Mae's Office of Management Operations should analyze the costs of using contractors for its operations and develop a plan to determine the optimal mix of contractor or in-house staff for operations. (Recommendation 2)

Agency: Department of Housing and Urban Development: Government National Mortgage Association (Ginnie Mae)
Status: Open
Priority recommendation

Comments: Ginnie Mae (HUD) agreed with this recommendation. As of September 2020, Ginnie Mae said it procured a contractor to do this analysis on their behalf at the end of fiscal year 2020. Officials expected the cost analysis to commence in early 2021. To fully implement this recommendation, Ginnie Mae should ensure the analysis and plan are completed. We will continue to monitor Ginnie Mae's progress in implementing our recommendation.

Recommendation: The Senior Vice President of Ginnie Mae's Office of Management Operations should assess its contract administration options to determine the most efficient and effective use of funds. (Recommendation 3)

Agency: Department of Housing and Urban Development: Government National Mortgage Association (Ginnie Mae)
Status: Open
Priority recommendation

Comments: Ginnie Mae (HUD) agreed with this recommendation. As of October 2020, Ginnie Mae stated it assesses procurement approaches on a per contract basis on whether to administer a contract within HUD or outsource the contract administration. However, GAO recommends Ginnie Mae comprehensively evaluate whether the outsourcing of its contract administration has met its intended purposes and is the most efficient and effective use of funds. In order to implement this recommendation, Ginnie Mae should reevaluate its decision to use an external provider.

Recommendation: The Chief Financial Officer of Ginnie Mae and Senior Vice President of Ginnie Mae's Office of Management Operations should finalize efforts to assess the costs and benefits of options to revise its compensation structure within current authority and submit proposals, if warranted, to HUD for review and consideration. (Recommendation 4)

Agency: Department of Housing and Urban Development: Government National Mortgage Association (Ginnie Mae)
Status: Open
Priority recommendation

Comments: Ginnie Mae (HUD) agreed with this recommendation. As of September 2020, Ginnie Mae has taken steps to assess options to revise its compensation structure. More specifically, according to Ginnie Mae, in the development of its fiscal year 2020 budget request, Ginnie requested authority to develop alternative pay options, such as premium pay, pay bands and critical pay. In August 2020, Ginnie Mae was given authority to proceed with implementing critical pay by the Office of Personnel Management. Critical Pay authority permits an agency to set a higher rate of basic pay than would otherwise be payable for a position that requires expertise of an extremely high level in a scientific, technical, professional, or administrative field and is critical to the successful accomplishment of an important mission. As of September 2020, Ginnie Mae is working with HUD on developing an implementation plan to implement critical pay within its Office of Enterprise Risk. In addition, Ginne Mae is working with OMB to ensure program execution and outcomes are aligned between the agencies. We will continue to monitor Ginnie Mae's progress in implementing our recommendation.

Recommendation: Congress should consider legislation establishing permanent statutory authority for a disaster assistance program administered by HUD or another agency that responds to unmet needs in a timely manner and directing the applicable agency to issue implementing regulations.

Agency: Congress
Status: Open

Comments: A bill introduced and passed by the House of Representative in the 116th Congress, HR 3702, would permanently authorize the Community Development Block Grant Disaster Recovery (CDBG-DR) program.

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: Congress should consider legislation for the future federal role in housing finance that addresses the structure of the enterprises, establishes clear, specific, and prioritized goals and considers all relevant federal entities, such as FHA and Ginnie Mae. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of March 16, 2020, Congress has not considered any legislation for housing finance system reform.

Recommendation: The Assistant Secretary for Financial Institutions should annually collect and evaluate HFAs' risk assessments, which include HFAs' risk levels. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: According to Treasury, as of March 2019, the agency had requested that each Housing Finance Agency evaluate its controls and update its Risk and Control Matrix to ensure that it reflects the risk assessment level of each control that has been assessed and to provide this information to Treasury. Treasury stated that it would evaluate the risk assessments to verify that the appropriate risk level had been assessed and that proper segregation of duties exists. As of August 2020, Treasury had not demonstrated that it had annually collected or evaluated HFA's risk assessments.

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: Congress should consider designating an agency to regularly collect and maintain specified cost-related data from credit allocating agencies and periodically assess and report on LIHTC project development costs. (Matter for Congressional Consideration 1)

Agency: Congress
Status: Open

Comments: As of August 2020, Congress had not designated an agency to regularly collect and maintain data on LIHTC project development costs.

Recommendation: IRS's Associate Chief Counsel, in consultation with Treasury's Assistant Secretary for Tax Policy, should require general contractor cost certifications for LIHTC projects to verify consistency with the developer cost certification. (Recommendation 1)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that requiring general contractor cost certifications would help address a known fraud risk.

Recommendation: To help allocating agencies analyze development cost trends and drivers and make comparisons to other agencies, IRS's Commissioner of the Small Business/Self-Employed Division should encourage allocating agencies and other LIHTC stakeholders to collaborate on the development of more standardized cost data, considering information in this report about variation in data elements, definitions, and formats. (Recommendation 2)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that greater standardization of LIHTC cost data would facilitate analysis of cost drivers and cost-management practices.

Recommendation: IRS's Associate Chief Counsel, in consultation with Treasury's Assistant Secretary for Tax Policy, should communicate to credit allocating agencies how to collect information on and review LIHTC syndication expenses, including upper-tier partnership expenses. (Recommendation 3)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that communicating expectations about the collection and review of syndication expenses would enhance program transparency and allocating agency financial assessments.

Recommendation: The HUD Assistant Secretary for the Office of Public and Indian Housing should complete its updates of the Housing Choice Voucher (HCV) Program Guidebook and Public Housing Occupancy Guidebook to reflect current guidance on criminal history policies for its public housing and HCV programs. (Recommendation 1)

Agency: Department of Housing and Urban Development: Office of Public and Indian Housing
Status: Open

Comments: HUD is in the process of revising both guidebooks. HUD officials stated that the updated guidebooks will include revisions to reflect HUD's current criminal history policies. The revised guidebooks are expected to be completed no later than December 2019.

Recommendation: The HUD Assistant Secretary for the Office of Public and Indian Housing should review HUD's Compliance Monitoring Checklist to determine if questions should be added to address additional federal criminal history requirements and revise checklist instructions to direct HUD staff to obtain information on PHAs' implementation of these requirements during compliance reviews. (Recommendation 2)

Agency: Department of Housing and Urban Development: Office of Public and Indian Housing
Status: Open

Comments: HUD Office of Public and Indian Housing staff, including Regional Directors, reviewed the checklist and determined that no additional questions should be added as they believe the checklist currently addresses federal criminal history requirements. Therefore, they also maintain that the related checklist instructions also do no require revision.

Recommendation: The HUD Assistant Inspector General for the Office of Investigation should collect and assess more comprehensive information on regional efforts to implement the activities listed in the 2018 Standard Operating Procedure. (Recommendation 3)

Agency: Department of Housing and Urban Development: Office of the Inspector General: Office of Investigation
Status: Open

Comments: HUD OIG did not agree with this recommendation, stating that it was a management function not required in statute or regulation and would be unduly burdensome. We maintain the recommendation is valid. According to HUD OIG's standard operating procedures, they will be responsible for collecting and reporting statistics for some regional office activities. As discussed in this report, we believe the HUD OIG could obtain more comprehensive information on additional required regional activities using existing resources.

Recommendation: The HUD Assistant Inspector General for the Office of Investigation should, in collaboration with the FBI, determine what information on fugitive apprehensions and any estimated program savings that occur as the result of the Fugitive Felon Initiative would be most useful and consistently share such information with the FBI. (Recommendation 4)

Agency: Department of Housing and Urban Development: Office of the Inspector General: Office of Investigation
Status: Open

Comments: HUD OIG did not agree with this recommendation, stating that its ability to determine apprehensions and program savings is limited. However, the MOU between the HUD OIG and the FBI (as of the issuance of the report) states that the HUD OIG is to share this information with the FBI. We believe our recommendation provides sufficient flexibility for the HUD OIG and the FBI to determine what information on results would be feasible to collect, and maintain that such collaboration could better position the HUD OIG and the FBI to enhance their ability to identify any areas for improvement and evaluate the effectiveness of the initiative.

Recommendation: The HUD Assistant Inspector General for the Office of Investigation should, in collaboration with the FBI, update the Fugitive Felon Initiative memorandum of understanding (MOU) to reflect the agencies' current activities and responsibilities. (Recommendation 5)

Agency: Department of Housing and Urban Development: Office of the Inspector General: Office of Investigation
Status: Open

Comments: HUD OIG agreed with this recommendation and would be taking steps to address it.

Recommendation: The Director of the FBI should, in collaboration with the HUD OIG, determine what information on fugitive apprehensions that occur as the result of the Fugitive Felon Initiative would be most useful and consistently share such information with the HUD OIG. (Recommendation 6)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

Comments: The Department of Justice agreed with this recommendation and stated that it will continually provide apprehension statistics on a fiscal year basis. The department will also collaborate with the HUD OIG to provide any additional assistance necessary for quality information sharing.

Recommendation: The Director of the FBI should, in collaboration with the HUD OIG, update the Fugitive Felon Initiative MOU to reflect the agencies' current activities and responsibilities. (Recommendation 7)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

Comments: The Department of Justice agreed with this recommendation and will take action to update the MOU, in collaboration with the HUD OIG.

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: For RHS properties whose mortgages have matured, Congress should consider granting RHS the authority to renew annual rental assistance payments to owners who wish to continue to receive them and provide vouchers to tenants living in rental assistance units in properties whose owners choose to no longer receive rental assistance.

Agency: Congress
Status: Open

Comments: In September 2019, Sen. Jeanne Shaheen introduced S. 2567 that proposed decoupling Section 521 rental assistance from the Section 515 mortgage, allowing rental assistance to continue after the mortgage is paid in full. The bill also would expand the use of the Section 542 Rural Development Voucher program to include all tenants in properties with loans that had matured, rather than just tenants in properties with prepaid mortgages. Sen. Shaheen's bill was referred to the Senate Committee on Banking, Housing, and Urban Affairs. As of September 2020, no additional action had been taken.

Recommendation: The RHS Administrator should establish additional controls to check the accuracy of all loan information entered into RHS information technology systems, to help ensure complete, accurate, and reliable data for estimating rural rental housing property exit dates. (Recommendation 1)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: USDA said it would prioritize the development of options for the RHS Information Technology System , including dashboards and other protocols, to provide more analytical assessments and accurate data with respect to mortgage maturity dates and property-level information. It also said it would strengthen its partnership with Rural Development's Information Technology staff and develop more effective communication tools with RHS field personnel to highlight the importance of maintaining reliable data. USDA estimated it would complete these steps by September 30, 2019. However, as of May 2020, USDA officials had not provided us documentation of their efforts.

Recommendation: The RHS Administrator should establish a process to help ensure regular and frequent updates for the preservation tool and its underlying data. (Recommendation 2)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: USDA said it would embed quality assurance in the preservation tool to ensure that the underlying data are accurately sourced, maintained, and analyzed. USDA also said it would ensure involvement from RHS National Office staff and RHS field office staff in this process to maximize the resources allocated to ensuring that the tool's data are integral and timely. Finally, USDA said RHS National Office personnel in the Deputy Administrator's office will be assigned quality control responsibility for the accurate maintenance of the tool. USDA estimated it would complete these steps by September 30, 2019. However, as of May 2020, USDA officials had not provided us documentation of their efforts.

Recommendation: The RHS Administrator should establish performance goals and measures for its rural rental housing preservation and rehabilitation efforts and report out these outcomes. (Recommendation 3)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: USDA said it would incorporate preservation goals, objectives, and measures into its on-going updates and edits to handbook guidance. As an initial step, on June 4, 2018, the agency incorporated the guidance provided in the Unnumbered Letter titled "Dynamic Servicing Strategies for the Multi-family Housing Direct Loan Portfolio." The revisions also renamed Chapter 6 of the handbook to "Portfolio and Property Assessment." USDA said on-going guidance updates will prioritize preservation as the goal of servicing strategies and require program staff to exhaust all potential remedies to achieve this goal prior to proceeding to terminate assistance or otherwise not preserve the affordable housing property. USDA officials expected these and other steps to be completed by September 30, 2019. However, in May 2020, USDA officials said publication of the guidance had been delayed, and guidance was not expected to issue until early fiscal year 2022.

Recommendation: The RHS Administrator should monitor the results of rural rental housing preservation efforts and assess the degree to which those efforts yielded intended outcomes. (Recommendation 4)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: USDA said that in conjunction with its establishment of preservation goals and objectives, it would utilize a performance tracking system and establish management routines to discuss and strategize how to achieve these goals. In November 2019, USDA officials said they had assessed the Section 515 Multi-Family Housing Preservation and Revitalization demonstration program and planned to finalize a plan that would enhance program delivery efficiency and consistency within 8 months (July 2020). However, as of May 2020, USDA officials had not provided documentation showing performance tracking or routine monitoring efforts. The officials said they planned to complete an evaluation of rural housing preservation goals or objectives by the third quarter of fiscal year 2022.

Recommendation: The RHS Administrator should identify, analyze, and respond to risks to achieving its preservation goals, including resource and staffing limitations. (Recommendation 5)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: USDA said it would utilize a performance tracking system and establish management routines to discuss and strategize how to achieve its goals. According to USDA, this will include an assessment of challenges and risks that may affect the achievement of performance and preservation objectives. However, as of May 2020, USDA had not provided us documentation of its efforts to identify, analyze and respond to risks to achieving its preservation goals.

Recommendation: Congress should consider providing necessary authority for other agencies to continue remaining activities when ONHIR closes. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: Legislation has not yet been enacted that would authorize other agencies to assume remaining functions from ONHIR. The report accompanying the Consolidated Appropriations Act for fiscal year 2019 directs ONHIR to continue working on the development of a comprehensive plan for closing ONHIR which includes legal analysis on whether any enacting legislation is required to transfer functions to another agency or organization. We will continue to monitor any relevant legislation.

Recommendation: Congress should consider determining (1) whether the requirement for the land acquired pursuant to the Settlement Act as amended to be used solely for the benefit of relocatees should continue and (2) how grazing on the New Lands should be regulated. (Matter for Consideration 2)

Agency: Congress
Status: Open

Comments: Legislation has not yet been enacted that would address whether the requirement for the land to be used solely for the benefit of relocatees should continue or regulation of grazing on the New Lands. A committee report accompanying ONHIR's fiscal year 2019 appropriations directs ONHIR to work closely with the tribes, the Office of the Special Trustee, the Bureau of Indian Affairs, and the Department of Justice to develop and implement a comprehensive plan for the closure of ONHIR. We will continue to monitor any relevant legislation.

Recommendation: Congress should consider addressing the mandatory trust acquisition provision for the Navajo Nation in the Settlement Act as amended. (Matter for Consideration 3)

Agency: Congress
Status: Open

Comments: Legislation has not yet been enacted to address the mandatory trust acquisition provision. A committee report accompanying ONHIR's fiscal year 2019 appropriations directs ONHIR to work closely with the tribes, the Office of the Special Trustee, the Bureau of Indian Affairs, and the Department of Justice to develop and implement a comprehensive plan for the closure of ONHIR. We will continue to monitor any relevant legislation.

Recommendation: Congress should consider whether the requirement for the Navajo Nation to repay the U.S. Treasury for appropriations made to the Navajo Rehabilitation Trust Fund should continue. (Matter for Consideration 4)

Agency: Congress
Status: Open

Comments: Legislation has not yet been enacted to address the mandatory trust acquisition provision. A committee report accompanying ONHIR's fiscal year 2019 appropriations directs ONHIR to work closely with the tribes, the Office of the Special Trustee, the Bureau of Indian Affairs, and the Department of Justice to develop and implement a comprehensive plan for the closure of ONHIR. We will continue to monitor any relevant legislation.

Recommendation: The Executive Director of ONHIR should request a presidential determination as to whether ONHIR has fully discharged its responsibilities and whether it should close. (Recommendation 1)

Agency: Office of Navajo and Hopi Indian Relocation
Status: Open

Comments: The explanatory statement to the Consolidated Appropriations Act for fiscal year 2019 states that the determination that ONHIR's functions have been fully discharged requires development of a comprehensive plan. In October 2018, ONHIR officials stated that they continue to work on transition planning, including helping to develop closeout legislation. We will continue to monitor ONHIR's actions in response to this recommendation.

Recommendation: The Executive Director of ONHIR should prepare complete information on the remaining denied households who could still file for federal appeals. Such information could include paper case files and information in ONHIR's client database for those households. (Recommendation 2)

Agency: Office of Navajo and Hopi Indian Relocation
Status: Open

Comments: As of October 2018, ONHIR officials had developed a schedule of cases that were still eligible to file for federal appeals and reported that the files have been gathered, organized and prepared. Officials also stated that all closed case files that are not subject to an administrative appeal were transferred to the National Archives and Records Administration. We will continue to follow up with ONHIR on the availability of the paper files and the status of efforts to transition its database to another agency upon closure.

Recommendation: The Executive Director of ONHIR should prepare complete information on warranties and contractors. Such preparation should include linking warranty complaints to the relevant contractor, completing missing warranty information, and completing information on contractors' past performance. (Recommendation 3)

Agency: Office of Navajo and Hopi Indian Relocation
Status: Open

Comments: As of October 2018, ONHIR officials had produced a report of outstanding warranty complaints, reviewed paper case files for additional information on the status of the complaints, and updated the database accordingly. ONHIR has also developed a report of case files that will need to remain at ONHIR until the warranty period expires. We will continue to follow up to determine how information on contractors' past performance will be maintained.

Recommendation: The Executive Director of ONHIR should establish a comprehensive inventory of (1) properties located on trust land it administers, (2) leases of those properties, and (3) surface use and other use agreements for trust land it administers. (Recommendation 4)

Agency: Office of Navajo and Hopi Indian Relocation
Status: Open

Comments: In June 2018, ONHIR reported that it had updated and maintains a comprehensive inventory that includes property, leases, and surface use agreements on all trust land it administers. Our review of the updated inventory found that not all leases are included, and it is unclear why some properties are listed more than once in the inventory. We will continue to monitor actions ONHIR takes in response to this recommendation.

Recommendation: The Executive Director of ONHIR should identify which leases and other agreements need to be amended or assigned because (1) ONHIR is the lessor, (2) the lease or agreement provides for annual payments to be made to ONHIR, and/or (3) the lease or agreement terminates upon ONHIR's closure. (Recommendation 5)

Agency: Office of Navajo and Hopi Indian Relocation
Status: Open

Comments: As of October 2018, ONHIR stated that it is working to record all current leases with the Department of Interior and plans to identify any needed amendments or assignments once a successor entity is identified.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment revises its guidance on privatized military housing to include a requirement that the military departments incorporate measures of future sustainment into their assessments of privatized housing projects. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report. In its response, the department stated that it was working with the military departments to determine appropriate measures of future sustainment and would revise its guidance to require the military departments to incorporate measures of future sustainment into their assessments of privatized housing projects. In May 2019, an official from the Office of the Assistant Secretary of Defense for Sustainment stated that DOD anticipates being able to issue this guidance sometime in calendar year 2019.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment takes steps to resume issuing required reports to Congress on the financial condition of privatized housing in a timely manner. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report and stated that it was working to further streamline the reporting format and data collection process to ensure more timely reporting to Congress. Subsequently, in September 2018 DOD issued its report to Congress on the financial condition of privatized housing covering fiscal years 2015 and 2016, and in May 2019 DOD issued the report covering fiscal year 2017. An official from the Office of the Assistant Secretary of Defense for Sustainment noted in May 2019 that the next report will cover updated reporting requirements from the National Defense Authorization Act for Fiscal Year 2019. The official said that DOD was in the process of reviewing its schedule to determine when it will be able to submit the report covering fiscal year 2018, with the expectation that the submission will be made in December 2019 or no later than March 2020. The official added that collection, reconciliation, and coordination of the information in the report remains the biggest challenge to timely submittal, as well as other privatized housing-related work requirements. Because it is unclear whether future reports reflecting the updated reporting requirements will be submitted in a timely manner, we will continue to monitor DOD's response to this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment reports financial information on future sustainment of each privatized housing project in its reports to Congress. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report and stated that it would ensure that financial information on future sustainment of each privatized housing project would be included in the report to Congress on privatized housing covering fiscal year 2017. However, the report covering fiscal year 2017 was issued in May 2019 and did not include financial information on the future sustainment of each privatized housing project. We will continue to monitor any actions DOD takes to implement this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment provides guidance directing the military departments to assess the significance of the specific risks to individual privatized housing projects resulting from the reductions in the basic allowance for housing and identify courses of action to respond to any risks based on their significance. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report. In its response, the department stated that it would issue guidance to the military departments to annually report on their assessment of the specific risk of changes in the basic allowance for housing to individual privatized housing projects and identify any courses of action to respond to the risks based on their significance. In May 2019, an official from the Office of the Assistant Secretary of Defense for Sustainment stated that DOD anticipates being able to issue this guidance sometime in calendar year 2019.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment finalizes guidance in a timely manner that clearly defines the circumstances in which the military departments should provide notification of project changes and which types of project changes require prior notification or prior approval. (Recommendation 7)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report. In its response, the department stated that DOD has coordinated draft guidance with the military departments which it expected to issue in fiscal year 2018. However, in May 2019, an official from the Office of the Assistant Secretary of Defense for Sustainment stated that the guidance has been delayed due to other pressing requirements and DOD now anticipates being able to issue this guidance sometime in calendar year 2019.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment revises its guidance on privatized military housing to require the military departments to define their risk tolerances regarding the future sustainability of their privatized housing projects. (Recommendation 8)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report. In its response, the department stated that it would revise its privatized housing guidance to require the military departments to define their risk tolerances regarding future sustainability of privatized housing projects. In May 2019, an official from the Office of the Assistant Secretary of Defense for Sustainment stated that DOD anticipates being able to issue this guidance sometime in calendar year 2019.

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: Congress should consider amending the National Housing Act to specify the economic conditions the MMI Fund would be expected to withstand without substantial risk of drawing on permanent and indefinite budget authority, and require FHA to specify and comply with a capital ratio consistent with these conditions. In specifying the economic conditions, Congress should take into account FHA's statutory operational goals and role in supporting the mortgage market during periods of economic stress. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of July 2020, Congress had not yet acted on this matter for consideration.

Recommendation: The Administrator of RHS should develop and implement a plan for ongoing monitoring, including testing and evaluation, of the obligation tool using relevant data. (Recommendation 1)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: In June 2019, RHS said that implementing the recommendation would require information technology funding.

Recommendation: The Administrator of RHS should develop controls to check the reasonableness of rental assistance agreement amounts calculated by the obligation tool. (Recommendation 2)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: In June 2019, RHS said that implementing the recommendation would require information technology funding.

Recommendation: The Administrator of RHS should develop controls to ensure that RHS uses the inflation rates from the President's economic assumptions in developing budget estimates. (Recommendation 3)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: In June 2019, RHS said it would incorporate the recommended controls into the fiscal year 2021 budget cycle.

Recommendation: The Administrator of RHS should provide guidance to Rural Development state offices that specifies that prior to obligating funds, staff are to review information related to a property's mortgage servicing status. (Recommendation 4)

Agency: Department of Agriculture: Rural Housing Service
Status: Open

Comments: In June 2019, RHS said it was working toward providing the recommended guidance to Rural Development state offices.

Recommendation: To ensure that the financial benefits of EULs that the Department of Veterans' Affairs reports in its annual Consideration Report on the EUL program are transparent and reliable, the Secretary should revise its Enhanced-Use Leasing Post Transaction Handbook (Handbook 7454) and specify that VA will: (1) Report consistently the enhanced services benefits from its EULs separately from other financial benefits that directly affect VA's budget, and (2) Include an explanation in its reporting on estimated EUL enhanced services that its estimates may not adequately capture all benefits of the EUL project and that certain costs associated with providing such benefits that are incurred by parties outside VA are not included in the analysis.

Agency: Department of Veterans Affairs
Status: Open

Comments: In August 2020, VA stated that the handbook was out for concurrences and received significant feedback/edits. VA is currently working through those edits and plans on submitting the revised version for internal concurrences in the next two weeks. VA said it will follow back up with GAO to provide a status on the handbooks approval and subsequent publishing

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 reduce uncertainty and provide FHFA sufficient direction for carrying out its responsibilities as conservator of the enterprises, Congress should consider legislation that establishes objectives for the future federal role in housing finance, including the structure of the enterprises, and a transition plan to a reformed housing finance system that enables the enterprises to exit conservatorship.

Agency: Congress
Status: Open

Comments: As of March 16, 2020, Congress has not taken action on this matter.

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: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to enhance screening of loan guarantee applicants, the Secretary of Agriculture should direct the Undersecretary for Rural Development to complete steps to obtain access to Treasury's Do Not Pay portal and establish policies and procedures to deny loan guarantees to applicants who are subject to administrative offsets for delinquent child support payments.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said that implementing the recommendation would require a rule change and that it anticipated publishing a proposed rule by December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to strengthen oversight of lenders and servicers, the Secretary of Agriculture should direct the Undersecretary for Rural Development to develop and publish in the Federal Register qualification requirements for the principal officers of lenders and servicers seeking initial or continued approval to participate in the guarantee program.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said it anticipated publishing a proposed rule to implement this recommendation by December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to strengthen oversight of lenders and servicers, the Secretary of Agriculture should direct the Undersecretary for Rural Development to develop and publish in the Federal Register capital and financial requirements for guarantee program lenders that are not regulated by a federal financial institution regulatory agency.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said it anticipated publishing a proposed rule to implement this recommendation by December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to strengthen risk assessment and reporting, the Secretary of Agriculture should direct the Undersecretary for Rural Development to improve performance measures comparing RHS and the Federal Housing Administration loan performance, potentially by making comparisons on a cohort basis and limiting comparisons to loans made in similar geographic areas.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said it was working with a contractor to establish more meaningful performance measures and estimated a completion date of December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to strengthen risk assessment and reporting, the Secretary of Agriculture should direct the Undersecretary for Rural Development to develop risk thresholds for the guarantee program, potentially in the form of maximum portfolio- or loan-level loss tolerances.

Agency: Department of Agriculture
Status: Open

Comments: Rural Development hired a contractor to help establish risk thresholds for the guarantee program. The contractor's October 2016 report developed and recommended portfolio-level and loan-level risk thresholds (values that trigger consideration of policy adjustments) and also recommended that program officials conduct stress tests to validate that each recommended risk threshold was appropriate for the program's overall risk appetite. As of August 2020, Rural Development said it was continuing to work with the contractor to stress test the risk thresholds and estimated a completion date of December 31, 2020.

Recommendation: To improve compliance with OMB Circular A-129 standards and strengthen management and oversight of the guarantee program, and to more effectively fulfill the requirements for conducting program reviews described in OMB Circular A-129, the Secretary of Agriculture should direct the Undersecretary for Rural Development to develop procedures for selecting RD credit programs for review based on risk and establish a prioritized schedule for conducting the reviews.

Agency: Department of Agriculture
Status: Open

Comments: In August 2020, Rural Development said that its Chief Risk Officer was working with the agency on establishing procedures for selecting Rural Development credit programs for review based on risk, including a prioritized schedule. Rural Development estimated a completion date of June 30, 2021.

Recommendation: To better align program goals with agency missions and improve program administration and oversight, Congress should consider designating the Department of Housing and Urban Development as a joint administrator of the program responsible for oversight. As part of the deliberation, Congress also should direct HUD to estimate the costs to monitor and perform the additional oversight responsibilities, including a discussion of funding options.

Agency: Congress
Status: Open

Comments: As of June 2020, Congress had not enacted legislation to give HUD an oversight role for LIHTC.

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 Defense
Status: Open

Comments: DOD partially 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. In a December 2017 follow up, DOD stated that it plans to address our recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. DOD added that it will work closely with the military Departments and HUD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

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 Defense
Status: Open

Comments: DOD partially 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. DOD stated that while it already provides generic information about the property, the LRAs and interested homeless assistance providers can undertake facility assessments following the tours. However, DOD did not provide additional detail or explanation about how it would provide information about the condition of the property or access to it. In a December 2017 follow up, DOD stated that it plans to address our recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. DOD added that it will work closely with the military Departments and HUD 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 Defense
Status: Open

Comments: DOD did not concur 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. In its response, DOD stated that the existing regulatory guidance is adequate for providers' expressions of interest, given that these expressions evolve as the redevelopment planning effort proceeds and they learn more about the property. In a December 2017 follow up, DOD officials stated that they will not take action because they believe this is a community-driven action. 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 Defense
Status: Open

Comments: DOD partially 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. DOD did not commit to taking any actions to provide this information and instead noted that any action should ensure that a legally binding agreement does not bind DOD to disposal actions it is unable to carry out. Nothing in the recommendation requires DOD to sign an agreement it cannot carry out. DOD further noted that the purpose of the legally binding agreement is to provide remedies and recourse for the LRA and provider in carrying out an accommodation following property disposal. In a December 2017 follow up, DOD stated that it plans to address our recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. DOD added that it will work closely with the military Departments and HUD 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 Defense
Status: Open

Comments: DOD did not concur 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. In its response, DOD stated that providers may only be considered through specific expressions of interest in surplus BRAC property, and these suggested alternatives may only be considered within the context of what is legally permissible given the specific circumstances at each installation. Further, DOD noted in its response that HUD may provide examples of alternatives to on-base property that have been approved to date as part of a local accommodation to offer examples for LRAs and providers. In a December 2017 follow up, DOD officials stated that they will not take action because they believe this is a community-driven action. 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 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 strengthen FHA accountability for complying with the Fund's statutory capital requirement, Congress should consider requiring that FHA submit a capital restoration plan and regular updates on plan implementation whenever the capital ratio falls below 2 percent as calculated in the annual actuarial review of the Fund, or the Fund's financial condition does not meet other congressionally-defined requirements.

Agency: Congress
Status: Open

Comments: As of October 2019, Congress had not yet acted on this matter for consideration.

Recommendation: To provide additional perspective on the Fund's financial status, FHA should disclose estimates of the individual cash flows associated with the liability for loan guarantees (premiums, claims, and recoveries), including their value for each year of the 30-year estimation period.

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: As of October 2019, HUD had not yet acted on this recommendation.

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: In order to better ensure that servicers are effectively implementing the agency's loss mitigation programs and that distressed borrowers are receiving the assistance they need as early as possible before they become seriously delinquent, the Secretary of the Department of Agriculture should require servicers to report information about their efforts to reach distressed borrowers. For example, servicers could report on their efforts to reach borrowers and whether borrowers have responded to outreach from the servicer regarding early delinquency interventions and are receiving informal foreclosure mitigation actions.

Agency: Department of Agriculture
Status: Open

Comments: In its 60 day response letter, USDA noted that currently, its Rural Housing Service (RHS) guaranteed loan servicers are required to perform outreach and early delinquency intervention and informal mitigation actions within agency-prescribed timeframes. Also, each servicer is required to maintain automated records of these contacts and attempted contacts. According to USDA. RHS will utilize both internal and external means to analyze data obtained periodically through loan servicers. Loan level data outlining foreclosure prevention efforts such as borrower contact, loss mitigation actions attempted, loss mitigation actions implemented, and failed loss mitigation actions will be assessed in order to better evaluate the effectiveness of RHS'foreclosure prevention guidance. Data will be collected from loan servicers via monthly reporting in conjunction with data obtained through compliance reviews conducted by RHS and its program compliance agent. Utilizing these compliance reviews, USDA stated that RHS will perform a management review of the results and will provide feedback to the servicers to increase compliance. In a September 2013 status update, USDA stated that it was developing manual processes that will provide clarity with respect to lender loss mitigation performance as recommended by GAO. USDA currently captures limited loss mitigation data that yields performance results, assisting the program in its efforts to mitigate risk. These manual processes will remain in effect until USDA has completed the build-out of the enhanced electronic data reporting requirements of lenders that participate in the program. In addition, USDA noted that it was finalizing a Memorandum of Understanding with Ginnie Mae to gain access to their program default data that will provide insight into the loss mitigation retention workout performance of 502 Guaranteed borrowers. According to an update from USDA, the Memorandum of Understanding with Ginnie Mae is no longer being pursued because Ginnie Mae was not in favor of it.

Recommendation: The Secretary of USDA should determine the extent to which distressed borrowers have not been reached and assess whether changes are needed to help ensure servicers are complying with USDA's loss mitigation requirements.

Agency: Department of Agriculture
Status: Open

Comments: In its 60 day response letter, USDA stated that it supported GAO's recommendation to require servicers to report their efforts to reach distressed borrowers and report, on a portfolio level, the extent to which servicers are complying with USDA's loss mitigation requirements. USDA also stated that data will be collected from loan servicers via monthly reporting in conjunction with data obtained through compliance reviews conducted by it Rural Housing Service (RHS) and its program compliance agent. Utilizing these compliance reviews, RHS will perform a management review of the results and will provide feedback to the servicers to increase compliance. In a September 2013 status update, USDA stated that it was developing manual processes that will provide clarity with respect to lender loss mitigation performance as recommended by GAO. USDA currently captures limited loss mitigation data that yields performance results, assisting the program in its efforts to mitigate risk. These manual processes will remain in effect until USDA has completed the build-out of the enhanced electronic data reporting requirements of lenders that participate in the program. In addition, USDA noted that it was finalizing a Memorandum of Understanding with Ginnie Mae to gain access to their program default data that will provide insight into the loss mitigation retention workout performance of 502 Guaranteed borrowers. This data, which will help evaluate the effectiveness of loss mitigation efforts on both borrower outcome and agency cost bases, will be gathered with the assistance of the consulting team now supporting lender compliance. According to an update from USDA, the Memorandum of Understanding with Ginnie Mae is no longer being pursued because Ginnie Mae was not in favor of it.

Recommendation: To more fully understand the strengths and risks posed by foreclosure mitigation actions and protect taxpayers from absorbing avoidable losses to the maximum extent possible, the FHA, VA, and USDA should conduct periodic analyses of the effectiveness and the long-term costs and benefits of their loss mitigation strategies and actions. These analyses should consider (1) the redefault rates associated with each type of home retention action and (2) the impact that loan and borrower characteristics have on the performance of different home retention actions. The agencies should use the results from these analyses to reevaluate their loss mitigation approach and provide additional guidance to servicers to effectively target foreclosure mitigation actions. If FHA, VA, and USDA do not maintain data needed to consider this information, they should require services to provide them.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA has made progress on implementing this recommendation. In June 2019, VA deployed the first iteration of a redesigned VA loan electronic reporting interface (VALERI-R). According to VA, VALERI-R provides enhanced capability for VA lenders and servicers to report VA loan information electronically, including information on loan redefaults. VA said that while VALERI-R maintains data longitudinally (a feature critical to analyzing redefaults), the initial deployment of VALERI-R lacks the functionality to perform the analysis needed to satisfy GAO's recommendation. Since deploying VALERI-R, VA said it has exercised optional tasks on the VALERI-R contract to develop and enhance data and reports to provide the ability to conduct the analysis required. In December 2019, VA said it expects to deploy the enhanced functionality by June 30, 2020, and is targeting September 30, 2020, as the time frame for completing the analysis.

Recommendation: To better ensure that requirements for tenant eligibility are met across the FLH portfolio, the Secretary of Agriculture should direct the Administrator of RHS to require its loan servicers to use the Systematic Alien Verification and Entitlements (SAVE) program administered by the Department of Homeland Security to verify tenant's residency status during supervisory reviews.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, according to officials, USDA has proposed revisions to its regulations that will incorporate the usage of Systematic Alien Verification and Entitlements (SAVE) program. The proposed rule is under interagency review with the Office of Management and Budget. Publication of the final rule is planned to occur in fiscal year 2022 according to USDA officials. We will continue to monitor USDA's progress in implementing our recommendation.

Recommendation: The Secretary of Agriculture should direct the Administrator of RHS to better utilize available data on demand for the FLH program--such as systematically reviewing local market analyses, further analyzing occupancy data on a statewide, regional, or national level, and retaining and analyzing application information--to help target available funding to areas of greatest need.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, according to officials, USDA has conducted an analysis of occupancy data and information retained in program applications, to determine how funding can be allocated to better meet market demand, and support community revitalization and affordable housing needs. Officials planned to use the results of this analysis to revise USDA's Farm Labor Housing Notice for Solicitation of Applications. The notice is currently undergoing an internal clearance process, which USDA anticipates completing by fiscal year 2022. We will continue to track the agency's progress on this recommendation.

Recommendation: To strengthen accountability and transparency in FHA's management of the Fund, Congress may wish to consider clarifying (1) the definition of the Fund's capital ratio--specifically, whether the denominator of the ratio was intended to be the amortized insurance-in-force; (2) the definition of the phrase "established target subsidy rate" used in HERA; and (3) the nature and extent of information that FHA should be reporting on subsidy rates pursuant to HERA, recognizing that subsidy rates are generally only reestimated once a year under current budget processes.

Agency: Congress
Status: Open

Comments: As of October 2019, Congress had not acted on this matter for consideration.

Recommendation: To the extent that the CDBG program continues to be the primary vehicle used to provide post-disaster assistance for permanent housing, Congress may wish to consider providing more specific direction regarding the distribution of disaster-related CDBG assistance that states are to provide for homeowners and renters. If Congress wishes to change the proportion of assistance directed to homeowners and rental property owners in future recovery efforts, Congress could, for example, require states to demonstrate to HUD that they are adequately addressing the needs of both homeowners and renters with their CDBG allocation and other resources as a condition for receiving funds. Alternatively, Congress could direct HUD to develop a formula that accounts for the housing needs of both homeowners and renters. Such a formula could be used by states to determine the proportions of their disaster CDBG funds that should be used for housing, specifically rental housing. Further, the formula could also reflect the anticipated production levels of other programs that provide permanent housing assistance, such as the Low-Income Housing Tax Credit program.

Agency: Congress
Status: Open

Comments: Since 1993, Congress has appropriated Community Development Block-Disaster Recovery (CDBG-DR) funding in the wake of numerous presidentially-declared disasters, including, most recently, $2.431 billion in Public Law 116-20, the majority of which amount is for disasters that occurred in 2018 and 2019. Similar to previous CDBG-DR appropriations, the CDBG-DR appropriation in Public Law 116-20, enacted June 6, 2019, neither requires states to demonstrate to HUD that they adequately addressed the needs of both homeowners and renters nor, alternatively, directs HUD to develop a formula that accounts for the housing needs of both homeowners and renters. A bill introduced and reported out of committee in the 115th Congress, HR 4557, required HUD to disapprove a state action plan that detailed a grantee's use of funds if, among other reasons, the plan did not provide an equitable allocation of resources among homeowners, renters, and persons experiencing homelessness. A draft bill, whose provisions were essentially identical to HR 4557, was the focus of a hearing during the 116th Congress.

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.

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 Transportation: Federal Transit Administration
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.