Open Recommendations

Deobligate the 835 administrative obligations totaling $38,525,836.88 identified for deobligation during the fiscal year 2024 OOR that had not been deobligated as of February 28, 2025.

Deobligate the 101 program obligations totaling $1,967,991.45 identified for deobligation
during the fiscal year 2024 OOR that had not been deobligated as of February 28, 2025.

More clearly define successful prepurchase and postpurchase homeownership counseling outcomes and use these definitions to help establish performance metrics and benchmarks for HUD's Office of Housing Counseling and HUD-approved housing counseling agencies. This should include the types of successful outcomes under the Homeownership Initiative Grant, as well as other positive outcomes for clients that do not involve immediate homeownership.

Implement routine client outcome data analysis to identify trends, quantify performance metrics and benchmarks, and measure the impact of prepurchase and postpurchase counseling on advancing homeownership. This should include routine analysis that HUD's Office of Housing Counseling can implement based on data collected as well as continuing to pursue an updated housing counseling data system to help overcome client outcome data limitations.

Enhance monitoring of HUD-approved housing counseling agencies' performance, to include progress toward the established performance metrics and benchmarks.

Collaborate with ONDCP to determine the necessary adjustments to the CoC reporting methodology that ensures HUD reports annual numeric targets and actuals to ONDCP by the required November 1 due date.

Collaborate with ONDCP to determine the necessary adjustments to the RHP reporting methodology that ensures HUD reports numeric targets to ONDCP by the required November 1 due date.

Develop and execute a written agreement with ONDCP on the reporting methodology for the CoC annual numeric targets and actuals that would meet future reporting requirements and comply with the Strategy and timeframe for implementation.

Develop and execute a written agreement with ONDCP on the use of reporting annual numeric targets for the RHP performance measures that would meet future reporting requirements and comply with the Strategy and timeframe for implementation.

Establish and implement formal policies and procedures that include (1) the ONDCP reporting process between HUD's OCFO and CPD, (2) the process for reporting to ONDCP, (3) references to any written agreements between HUD and ONDCP, and (4) a requirement for periodic reviews of these written agreements to address any changes in administration, roles, responsibilities, reporting programs, reporting requirements, and reporting methodologies.

We recommend that HUD's Deputy Assistant Secretary for Multifamily Housing implement training at the regional level to provide instruction on and stress the importance of monitoring civil rights compliance as part of the MORs.

We recommend that HUD's Deputy Assistant Secretary for Multifamily Housing direct HUD staff to perform all required monitoring of civil rights compliance as part of the MORs conducted.

We recommend that HUD's Deputy Assistant Secretary for Multifamily Housing instruct the PBCAs to include the completion of the addendum B checklist as part of the MORs performed by the PBCAs.

We recommend that HUD's Deputy Assistant Secretary for Multifamily Housing provide technical training to the multifamily property owners and management agents on completing addendum B accurately as part of the MORs.

We recommend that HUD's General Deputy Assistant Secretary for Community Planning and Development implement training on civil rights monitoring reviews. Additionally, CPD should ensure that training on civil rights monitoring reviews is regularly provided to CPD staff.

We recommend that HUD's General Deputy Assistant Secretary for Community Planning and Development develop guidance clarifying the use of the exhibit for on-site, hybrid, and remote monitoring to ensure a full review of grantees' compliance with civil rights requirements, and incorporate this guidance into the training developed as a result of recommendation 1A.

Work with the prime award recipients that had subaward reporting deficiencies to ensure that
their subaward information is reported or reported accurately.

Update and expand the guidance on FFATA subaward reporting requirements provided to prime
award recipients by (1) updating program website(s) with comprehensive information about FFATA,
(2) implementing training, (3) issuing formal communication, and (4) implementing a feedback
mechanism to ensure that all prime award recipients have the opportunity to share challenges with
HUD and ask questions.

Integrate FFATA reporting requirements into program monitoring procedures for all programs
and conduct regular reviews to assess compliance.

Ensure that programs with subaward activity include specific clauses related to FFATA
compliance in their grant agreements, and notices of funding opportunities.

Work with the prime award recipients that had subaward reporting deficiencies to ensure that
their subaward information is reported or reported accurately.

Update and expand the guidance provided to prime award recipients by (1) updating program
website(s) with comprehensive information about FFATA, (2) implementing training, (3) issuing
formal communication, and (4) implementing a feedback mechanism to ensure that all prime award
recipients have the opportunity to share challenges with HUD and ask questions.

Integrate FFATA reporting requirements into the program monitoring procedures for all
programs and conduct regular reviews to assess compliance.

Develop a policy or update the existing Grants Management Policy to include 1) the process and
controls that HUD will use to hold the prime recipients accountable for FFATA compliance and 2)
clearly defined roles and responsibilities between OCFO and the program offices to ensure that action
is prioritized by the correct responsible parties regarding FFATA compliance.

Work with applicable program offices to develop training materials and tools, such as dashboards,
to assist program offices in monitoring their grant portfolios for subaward reporting compliance.