The CDO should coordinate with HUD’s Records Office, Privacy Office, and program offices to develop data policies and procedures for data inventory, categorization, and labeling in support of zero trust architecture.

Status

HUD is working on a plan to address the recommendation. HUD OIG anticipates receiving a corrective action plan no later than April 11, 2025, with a plan for resolving this recommendation.

Analysis

By addressing the recommendation, HUD will be positioned better to protect and prioritize protection for data in its IT systems. This will allow HUD to have a better understanding of the specifics of the most sensitive data as well as allow recommendation 2024-OE-0002a-003 to be addressed by HUD.

HUD maintains billions of records of PII and sensitive data within IT systems and the IT environment. Knowing more specifics about the data is essential in the ability to protect and recover from attempted exfiltration attempts.

Define and communicate policies and procedures to ensure that its products, system components, systems, and services comply with its cybersecurity and SCRM requirements. This recommendation includes:

• Identification and prioritization of externally provided systems (new and legacy), components, and services.
• How HUD maintains awareness of its upstream suppliers.
• The integration of acquisition processes tools, and techniques to use the acquisition process to protect the supply chain.
• Contract tools or procurement methods to confirm that contractors are meeting their obligations (derived from OIG FISMA metric 14).

Status

On January 17, 2025, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) informed HUD OIG that the Office of the Federal Register published a notice, Modifying HUD’s Elevated Blood Lead Level Threshold for Children Under Age 6 Who Are Living in Certain HUD-Assisted Target Housing Covered by the Lead Safe Housing Rule. The notice announced that HUD is lowering its EBLL threshold from 5 to 3.5 µg/dL for a child under the age of 6, consistent with the CDC’s current blood lead reference value of 3.5 µg/dL, effective January 17, 2025. Next, OLHCHH will assist the Office of Community Planning and Development, the Office of Multifamily Housing Programs, and the Office of Public and Indian Housing to draft, circulate, and publish EBLL notices. The estimated completion date is June 30, 2025.

Analysis

To fully address this recommendation, OLHCHH must provide evidence that it has updated its regulations, policies, and procedures so that they are consistent with CDC’s lowered blood lead reference value of 3.5 ug/dL.

Implementation of this recommendation will help ensure children living in public housing with elevated blood lead levels receive effective environmental interventions.

Develop an enterprise-wide IT modernization strategy that establishes a framework to align with the IT modernization roadmap.

Corrective Action Taken

In January, 2024, HUD provided an OCIO approved an IT Modernization strategy that established a framework that aligned with its IT modernization roadmap. The strategy addressed each of the recommendation components (a. roles and responsibilities, b. prioritization of modernization initiatives, c. coordination process between OCIO and program offices, d. phased approach, and e. how lessons learned will be captured.

Implement a software asset management capability for software and operating systems to ensure that software executes only from the authorized software inventory and all unauthorized software is blocked from executing on HUD's network.

Status

In April 2024, the Office of the Chief Information Officer reported that it was in the process of implementing a software management tool that would allow it to control which software is authorized to access the network. This is the first step to creating rules for allowing only authorized software to be used through HUD's endpoint security software. The final implementation of this new tool is expected by Quarter 2 of FY 2025.

Analysis

To fully address this recommendation, HUD must provide evidence that it has an automated whitelist and it is implemented as per the NIST Special Publication 800-167 or accept the risk and document mitigating measures via a Risk-Based Decision memorandum.

Implementation of this recommendation will result in HUD having the capability to ensure only authorized software is used on HUD’s network based on its software asset listing.

Implement multifactor authentication mechanisms for all nonprivileged users who access information systems that process, store, or transmit PII.

Status

The Office of the Chief Information Officer reported that it has implemented a new software security solution to implement multifactor authentication, starting with a pilot on 15 FHA systems. In October 2024, HUD received additional funds through the Technology Modernization Fund for this project enterprisewide.

Analysis

To fully address the recommendation, HUD must implement multifactor authentication enterprisewide.

Implementation of this recommendation will result in an enterprise-wide identity and access management solution. Users will be required to use multifactor authentication methods to access HUD data, networks, and devices.

Implement multifactor authentication mechanisms for all privileged users who access information systems that process, store, or transmit PII.

Status

The Office of the Chief Information Officer reported that it has implemented a new software security solution to implement multifactor authentication, starting with a pilot on 15 FHA systems. In October 2024, HUD received additional funds through the Technology Modernization Fund for this project enterprisewide.

Analysis

To fully address this recommendation, HUD must implement the eICAM plan it developed with the funding it received.

Implementation of this recommendation will result in an enterprise-wide identity and access management solution. Users will be required to use multifactor authentication methods to access HUD data, networks, and devices.

In April 2024, HUD OIG met with HUD OCIO to discuss progress and requirements for closure of this recommendation. In addition, OIG reviewed this recommendation as part of the annual FY 2024 FISMA evaluation in April 2024 and learned from HUD OCIO that that there would be a procedure update that would implement the ingestion and monitoring of all inbound and outbound traffic. The OIG requested to be provided with these procedures when finalized and evidence of implementation on May 1, 2024.

Corrective Action Taken

HUD OCIO updated its Cybersecurity Incident Response Plan and developed more detection and protection mechanisms to monitor network traffic in its IT environment. These mechanisms include anti-malware agents, data loss prevention, endpoint detection and response, firewalls, and intrusion detection and prevention systems. HUD’s SOC also developed standard operating procedures and playbooks for abnormal traffic alerts triggered by the above tools that are posted internally for SOC personnel to utilize. Addressing this recommendation resulted in improvement of HUD’s networking monitoring process by enhancing visibility into network traffic. It also increased HUD’s incident response program capabilities by ensuring that HUD has a plan to monitor traffic and better detect and respond to security incidents. As part of our regular Federal Information Security Act of 2014 (FISMA) assessments, HUD OIG will continue to assess HUD’s incident response effectiveness and threat detection to ensure HUD addresses new and evolving threats.

Enforce the requirement for all HUD web applications and services to be approved by the CIO and ensure OCIO reviews and approves all IT contracts and services agreements dealing with creation or support of web applications or services.

Corrective Action Taken

In January 2023, HUD's Office of the Chief Information Officer developed and released a Web Applications Directive to all HUD program offices. This directive described how web applications are defined, approved, inventoried, and maintained, including processes for tracking, and monitoring such applications.