HUD’s Office of Multifamily Housing Programs Did Not Always Follow Mitigation Requirements for Its FHA-Insured Multifamily Projects

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General, audited HUD’s Office of Multifamily Housing Programs upon receiving a hotline complaint. The hotline complaint contained allegations that (1) HUD routinely fails to perform Endangered Species Act analysis or consultations; (2) there are many projects that have deficiencies in noise analysis and environmental assessment site factors; (3) the environmental reviews for projects with fewer than 200 units are not performed properly; and (4) there is no oversight for projects with fewer than 200 units, and there are no safeguards for checking reviews for projects with fewer than 200 units. Our objective was to determine whether (1) the complainant’s allegations were substantiated for the 8 properties reviewed and (2) the Office of Multifamily Housing Programs properly followed mitigation requirements for the 17 properties reviewed. We partially substantiated allegation 3 and incorporated that issue into the finding. We were not able to substantiate the other allegations. HUD did not always properly follow mitigation requirements for its Federal Housing Administration-insured multifamily projects. Specifically, HUD did not always identify required mitigation measures or upload mitigation resolutions into the HUD Environmental Review Online System (HEROS) to document completion of its projects. Additionally, HUD did not conduct the required radon mitigation for one of its projects before final endorsement. This condition occurred because the multifamily HEROS users lacked training, HUD did not have procedures in place, and radon requirements were not updated on the closing documents. As a result, HUD was at risk of not conducting all required measures to mitigate conditions that would endanger the health and safety of its multifamily residents and lacked assurance that the new radon requirements were properly followed before the checklist update for the final endorsement closing documents. We recommended that the Deputy Assistant Secretary for Multifamily Housing (1) conduct and make available internal HEROS training for all multifamily HEROS users on how to document the environmental review mitigation measures, (2) establish and implement written procedures specifying which multifamily employees are required to upload mitigation resolutions after construction completion and at final endorsement, (3) upload the 17 missing mitigation resolutions and the 1 missing radon testing document into HEROS for the projects in this finding, (4) Strengthen HEROS or internal procedures to add an additional requirement confirming that the mitigation resolutions have been uploaded at final endorsement, and (5) strengthen HEROS by adding a column on the dashboard to show the progress of the overall mitigation status.