LEAD PAINT IN 

HOUSING

HUD Should 

Strengthen Grant 

Processes, 

Compliance 

Monitoring, and 

Performance 

Assessment 

Report to Congressional Committees

June 2018

GAO-18-394

United States Government Accountability Office
United States Government Accountability Office

 

Highlights of GAO-18-394, a report to 

congressional committees

June 2018 

LEAD PAINT IN HOUSING

HUD Should Strengthen Grant Processes, 

Compliance Monitoring, and Performance 

Assessment 

What GAO Found

The Department of Housing and Urban Development’s (HUD) lead grant and 

rental assistance programs have taken steps to address lead paint hazards, but 

opportunities exist for improvement. For example, in 2016, HUD began using 

new tools to monitor how public housing agencies comply with lead paint 

regulations. However, HUD could further improve efforts in the following areas: 

 

• Lead grant programs. While its recent grant award processes incorporate 

statutory requirements on applicant eligibility and selection criteria, HUD has 

not fully documented or evaluated these processes. For example, HUD’s

guidance is not sufficiently detailed to ensure consistent and appropriate 

grant award decisions. Better documentation and evaluation of HUD’s grant 

program processes could help ensure that lead grants reach areas at risk of 

lead paint hazards. Further, HUD has not developed specific time frames for 

using available local-level data to better identify areas of the country at risk 

for lead paint hazards, which could help HUD target its limited resources. 

• Oversight. HUD does not have a plan to mitigate and address risks related 

to noncompliance with lead paint regulations by public housing agencies. We 

identified several limitations with HUD’s monitoring efforts, including reliance 

on public housing agencies’ self-certifying compliance with lead paint 

regulations and challenges identifying children with elevated blood lead 

levels. Additionally, HUD lacks detailed procedures for addressing

noncompliance consistently and in a timely manner. Developing a plan and 

detailed procedures to address noncompliance with lead paint regulations 

could strengthen HUD’s oversight of public housing agencies. 

• Inspections. The lead inspection standard for the Housing Choice Voucher 

program is less strict than that of the public housing program. By requesting 

and obtaining statutory authority to amend the standard for the voucher 

program, HUD would be positioned to take steps to better protect children in 

voucher units from lead exposure as indicated by analysis of benefits and 

costs. 

• Performance assessment and reporting. HUD lacks comprehensive goals

and performance measures for its lead reduction efforts. In addition, it has 

not complied with annual statutory reporting requirements, last reporting as 

required on its lead efforts in 1997. Without better performance assessment

and reporting, HUD cannot fully assess the effectiveness of its lead efforts. 

Examples of Homes with Lead Paint Hazards 

Why GAO Did This Study

Lead paint in housing is the most 

common source of lead exposure for 

U.S. children. HUD awards grants to 

state and local governments to reduce

lead paint hazards in housing and 

oversees compliance with lead paint 

regulations in its rental assistance 

programs. The 2017 Consolidated 

Appropriations Act, Joint Explanatory 

Statement, includes a provision that 

GAO review HUD’s efforts to address 

lead paint hazards. This report 

examines HUD’s efforts to (1) 

incorporate statutory requirements and

other relevant federal standards in its 

lead grant programs, (2) monitor and 

enforce compliance with lead paint 

regulations in its rental assistance 

programs, (3) adopt federal health 

guidelines and environmental 

standards for its lead grant and rental 

assistance programs, and (4) measure

and report on the performance of its 

lead efforts. GAO reviewed HUD 

documents and data related to its grant 

programs, compliance efforts, 

performance measures, and reporting. 

GAO also interviewed HUD staff and 

some grantees. 

What GAO Recommends

GAO makes nine recommendations to 

HUD including to improve lead grant 

program and compliance monitoring

processes, request authority to amend

its lead inspection standard in the 

voucher program, and take additional 

steps to report on progress. HUD 

generally agreed with eight of the 

recommendations. HUD disagreed that 

it should request authority to use a 

specific, stricter inspection standard. 

GAO revised this recommendation to 

allow HUD greater flexibility to amend 

its current inspection standard as 

indicated by analysis of the benefits 

and costs. 

View GAO-18-394. For more information, 

contact Daniel Garcia-Diaz at (202) 512-8678 

or garciadiazd@gao.gov. 
Page i GAO-18-394 Lead Paint in Housing

Letter 1

Background 5

HUD Has Incorporated Relevant Requirements for Awarding 

Recent Lead Grants, but Could Better Document and Evaluate 

Grant Processes 13

HUD Could Take Additional Steps to Monitor Compliance with 

Lead Paint Regulations 24

HUD’s Blood Lead Level Standard Aligns with CDC Guidelines 

and Lead Inspection Standards Are Less Stringent in the 

Voucher Program 33

HUD Could Better Measure and Report on Performance of Lead 

Efforts 37

Conclusions 41

Recommendations for Executive Action 42

Agency Comments and Our Evaluation 43

Appendix I Nonfederal Funding Sources Used by Selected Grantees of HUD Lead 

Hazard Control Grants 47

Appendix II Objectives, Scope, and Methodology 51

Appendix III Comments from the Department of Housing and Urban Development 58

Appendix IV GAO Contact and Staff Acknowledgments 67

Tables

Table 1: HUD’s Lead-Based Paint Hazard Control Grant and Lead 

Hazard Reduction Demonstration Grant Programs’ 

Scoring Factors and Point Distribution, 2017 14

Table 2: Department of Housing and Urban Development (HUD) 

Lead Grant Programs: Selected Grantees’ Sources of 

Nonfederal Funds as Matching Contributions, 2013–2017 49

Contents
Page ii GAO-18-394 Lead Paint in Housing

Figures

Figure 1: The Department of Housing and Urban Development’s 

Lead Hazard Control Grant Programs, Fiscal Years 

2013–2017 11

Figure 2: The Department of Housing and Urban Development’s 

Lead Grant Programs’ Processes for Reviewing and 

Selecting Applicants 17

Figure 3: Department of Housing and Urban Development (HUD) 

Lead Grant Awards (2013–2017) and Indicators of Lead 

Paint Hazard Risk by County 23

Figure 4: Department of Housing and Urban Development’s 

(HUD) Process for Monitoring Public Housing Agencies’ 

Compliance with Lead Paint Regulations 27

Figure 5: Key Elements of Program Performance Assessment for 

Federal Agencies 38

Abbreviations

CDC Centers for Disease Control and Prevention

CDBG Community Development Block Grant

EPA Environmental Protection Agency

funding notice Notice of Funding Availability

HHS Department of Health and Human Services

HUD Department of Housing and Urban Development

Lead Office Office of Lead Hazard Control and Healthy Homes

OFO Office of Field Operations

OMB Office of Management and Budget

PD&R Office of Policy Development and Research

PHA public housing agency

PIH Office of Public and Indian Housing

Title X Residential Lead-Based Paint Hazard Reduction

 Act (Title X of the Housing and Community

 Development Act of 1992)

voucher program Housing Choice Voucher program

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-18-394 Lead Paint in Housing

441 G St. N.W.

Washington, DC 20548

June 19, 2018

The Honorable Susan Collins

Chairman

The Honorable Jack Reed

Ranking Member

Subcommittee on Transportation, Housing and Urban Development, and

 Related Agencies 

Committee on Appropriations

United States Senate

The Honorable Mario Diaz-Balart

Chairman

The Honorable David Price

Ranking Member

Subcommittee on Transportation, Housing and Urban Development, and

 Related Agencies

Committee on Appropriations

House of Representatives

The Centers for Disease Control and Prevention (CDC) have estimated 

that approximately half a million U.S. children (ages 1 to 5) have blood 

lead levels higher than most children’s levels.

1 According to CDC, no safe 

level of lead in the blood has been identified. When absorbed into the 

body, especially in young children, lead can damage the brain and 

nervous system, slow development and growth, and cause learning or 

behavioral problems. According to CDC, lead-based paint hazards, such 

as dust containing lead and chips from deteriorated lead-based paint, are 

the most common source of lead exposure for U.S. children.2 Young 

children are at greater risk of being exposed to lead because they often 

crawl on the floor, have frequent hand-to-mouth activity, and intentionally 

 

1

CDC is an agency within the Department of Health and Human Services. CDC reviewed 

National Health and Nutrition Examination Survey data from 2007–2010 to develop this 

estimate of the number of children with blood lead levels high enough for targeting 

prevention-related actions. For more information, see the Background section of this 

report. 

2

Throughout the report, we refer to lead-based paint hazards as “lead paint hazards” and 

lead-contaminated dust as “lead dust.” Lead paint hazards include any condition that can 

cause harmful exposure to lead from lead dust, soil, or paint that is deteriorated or present 

in accessible, friction, or impact surfaces (e.g., walls, windows, door frames). 

Letter
Page 2 GAO-18-394 Lead Paint in Housing

ingest nonfood items. Also, exposure to lead impacts young children 

more because of their small body size and weight compared to adults.

The Department of Housing and Urban Development’s (HUD) most 

recent survey of housing conditions estimated that roughly 35 percent of 

U.S. homes (37 million) contained some lead-based paint.3 Additionally, 

the survey estimated that 93 percent of the homes with lead paint were 

built before 1978––the year the United States banned lead-containing 

paint used in housing.4 HUD has certain statutory responsibilities related 

to reducing lead exposure in housing, which include, awarding grants to 

states and local governments to help address lead paint hazards in 

private, low-income housing and promulgating lead paint regulations for 

HUD’s rental assistance programs.

The 2017 Consolidated Appropriations Act, Joint Explanatory Statement, 

Division K, includes a provision for GAO to report on HUD’s policies, 

procedures, and processes for addressing lead paint hazards in housing.5

This report examines HUD’s efforts to (1) incorporate statutory 

requirements and other relevant federal standards in its lead grant 

programs; (2) monitor and enforce compliance with lead paint regulations 

for its rental assistance programs; (3) adopt federal health guidelines and 

environmental standards for lead paint hazards in its lead grant and rental 

assistance programs; and (4) measure and report on its performance 

related to making housing lead-safe. The provision also directs GAO to 

review opportunities to improve coordination and leveraging of public and 

private (i.e., nonfederal) sources of funds to reduce federal costs 

associated with identifying and remediating lead paint hazards. 

Information about nonfederal sources of funds used by grantees as part 

of HUD’s lead grant programs is included in appendix I of this report.

In this report, we examine lead paint hazards in housing and we focus on 

HUD’s lead hazard control grant programs and its two largest rental 

 

3

Department of Housing and Urban Development, American Healthy Homes Survey: Lead 

and Arsenic Findings, April 2011. HUD conducted the survey from June 2005 through 

March 2006. The survey measured levels of lead, lead hazards, allergens, arsenic, 

pesticides, and mold in homes nationwide. 

4

For the Consumer Product Safety Commission’s ban on lead-containing paint, see LeadContaining Paint and Certain Consumer Products Bearing Lead-Containing Paint: 

Establishment as Banned Hazardous Products, 42 Fed. Reg. 44193 (Sept. 1, 1977).

5

See 163 Cong. Rec. H4088 (daily ed. May 3, 2017). 
Page 3 GAO-18-394 Lead Paint in Housing

assistance programs that serve the most families with children: the 

Housing Choice Voucher (voucher) and public housing programs.6

To address the first objective, we compared HUD’s lead grant programs’ 

processes with statutory requirements and federal internal control 

standards.7 For example, we reviewed HUD’s annual notices of funding 

availability to identify the criteria HUD has used to evaluate grant 

applications and determine the extent to which the 2017 notices 

incorporated statutory requirements. We also compared HUD’s lead grant 

program processes to the Office of Management and Budget (OMB) 

requirements for competitively awarded grants.8 To review the extent to 

which grant awards have gone to counties with indicators of lead paint 

hazard risk, we analyzed HUD’s grant data from 2013 through 2017 and 

county-level U.S. Census Bureau data on the age of housing and poverty 

level of individuals in the United States. HUD’s grant data were not 

available electronically before 2013, when the agency started using 

grants management software. We determined the HUD and Census data 

were sufficiently reliable for our purposes––to identify the locations and 

grant award amounts for HUD grantees and to identify counties with older 

housing and individuals living in poverty. Additionally, we interviewed 

HUD staff about the agency’s grant application and award processes. To 

obtain information and perspectives from HUD grantees, we also 

reviewed a nongeneralizable sample of 20 grant applications and 

interviewed 10 of the 20 grantees. We conducted site visits to 5 of the 10 

grantees we interviewed. We selected these grantees to achieve variation 

in geographic locations and the type of HUD grants they had previously 

received, among other things.

 

6

For a description of the Housing Choice Voucher and public housing programs, see the 

Background section of this report. We did not examine lead hazards in schools, daycare 

centers, commercial buildings, water, food, or products such as toys, ceramics, or jewelry. 

For additional work on lead in water, see GAO, Drinking Water: Additional Data and 

Statistical Analysis May Enhance EPA’s Oversight of the Lead and Copper Rule, 

GAO-17-424 (Washington, D.C.: Sept. 1, 2017). Additionally, we have ongoing work 

reviewing lead service lines and lead in school drinking water. 

7

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014). 

8

Office of Management and Budget, Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal Awards (codified at 2 C.F.R. pt. 200), 

effective for grants awarded starting in December 2014.
Page 4 GAO-18-394 Lead Paint in Housing

To address the second objective, we reviewed relevant laws and HUD’s 

lead paint regulations and guidance and internal memorandums related to 

its efforts to monitor and enforce compliance with these regulations. We 

reviewed HUD databases used to monitor compliance and observed HUD 

staff demonstrating these databases. We reviewed HUD documentation 

of instances of potential noncompliance by public housing agencies 

(PHA) with lead paint regulations and enforcement actions HUD has 

taken.9 We compared HUD’s regulatory compliance monitoring and 

enforcement approach to federal internal control standards.10 We 

interviewed HUD staff about internal procedures for monitoring and 

enforcing compliance of lead paint regulations. To address the third 

objective, we compared HUD’s programs and regulations with relevant 

CDC health guidelines and Environmental Protection Agency (EPA) 

standards. We also interviewed staff from CDC and EPA to obtain 

information about their health guidelines and environmental standards 

related to lead.

To address the fourth objective, we reviewed HUD documentation related 

to performance goals, measures, program evaluations, and reporting 

requirements, including HUD’s recent annual performance reports. We 

compared HUD’s practices against leading practices for assessing 

program performance and federal internal control standards.11 Finally, we 

interviewed HUD staff to understand performance goals, measures, and 

reporting HUD has used to assess its lead efforts. Appendix II contains a 

more detailed description of our objectives, scope, and methodology.

We conducted this performance audit from March 2017 to June 2018 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

 

9

PHAs are state and local agencies that administer HUD’s Housing Choice Voucher and 

public housing programs. 

10GAO-14-704G. 

11We have previously stated that performance goals and measures are important 

management tools that can serve as leading practices for planning at lower levels within 

federal agencies, such as individual programs or initiatives. For example, see GAO, 

Veterans Justice Outreach Program: VA Could Improve Management by Establishing 

Performance Measures and More Fully Assessing Risks, GAO-16-393 (Washington, D.C.: 

Apr. 28, 2016); Performance Measurement and Evaluation: Definitions and Relationships,

GAO-11-646SP (Washington, D.C.: May 2, 2011); and GAO-14-704G. 
Page 5 GAO-18-394 Lead Paint in Housing

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

While HUD has primary responsibility for addressing lead paint hazards in 

federally-assisted housing, EPA also has responsibilities related to setting 

federal lead standards for housing. EPA sets federal standards for lead 

hazards in paint, soil, and dust.12 Additionally, EPA regulates the training 

and certification of workers who remediate lead paint hazards.13 CDC 

sets a health guideline known as the “blood lead reference value” to 

identify children exposed to more lead than most other children.

14 As of 

2012, CDC began using a blood lead reference value of 5 micrograms of 

lead per deciliter of blood. For children whose blood lead level is at or 

above CDC’s blood lead reference value, health care providers and public 

health agencies can identify those children who may benefit the most 

from early intervention. CDC’s blood lead reference value is based on the 

97.5th percentile of the blood lead distribution in U.S. children (ages 1 to 

5), using data from the National Health and Nutrition Examination 

 

12See e.g. Lead; Identification of Dangerous Levels of Lead, 66 Fed. Reg. 1206 (Jan. 5, 

2001). EPA also sets federal standards to reduce lead in drinking water under a treatment 

technique rule, known as the Lead and Copper Rule. See 40 C.F.R. § 141.80 et seq. As 

previously noted, lead in drinking water is outside the scope of this report. 

1340 C.F.R. pt. 745; See ex. Lead; Notification Requirements for Lead-Based Paint 

Abatement Activities and Training, 69 Fed. Reg. 18489 (Apr. 8, 2004); Lead; Renovation, 

Repair, and Painting Program, 73 Fed. Reg. 21692 (Apr. 22, 2008).

14Previously, children under age 6 years were identified by CDC as having a blood lead 

“level of concern” if the test result was greater than or equal to 10 micrograms of lead per 

deciliter of blood. CDC no longer uses the term “level of concern.” 

Background

Common Sources of Lead Paint Hazards in 

a Child’s Home

Source: GAO. | GAO-18-394

Lead-based paint hazards, such as dust 

containing lead and chips from deteriorated 

lead-based paint, are the most common 

source of lead exposure for U.S. children. 

Young children are at greater risk of being 

exposed to lead because they often crawl on 

the floor, have frequent hand-to-mouth 

activity, and intentionally ingest nonfood 

items. Also, exposure to lead impacts young 

children more because of their small body 

size and weight compared to adults.

Federal Agencies and Key 

Regulations Related to 

Lead Paint Hazards
Page 6 GAO-18-394 Lead Paint in Housing

Survey.

15 Children with blood lead levels above CDC’s blood lead 

reference value have blood lead levels in the highest 2.5 percent of all 

U.S. children (ages 1 to 5). HUD, EPA, and the Department of Health and 

Human Services (HHS) are members of the President’s Task Force on 

Environmental Health Risks and Safety Risks to Children.16 HUD cochairs the lead subcommittee of this task force with EPA and HHS. The 

task force published the last national lead strategy in 2000.17

The primary federal legislation to address lead paint hazards and the 

related requirements for HUD is the Residential Lead-Based Paint Hazard 

Reduction Act (Title X of the Housing and Community Development Act of 

1992).18 We refer to this law as Title X throughout this report. Title X 

required HUD to, among other things, promulgate lead paint regulations, 

implement the lead hazard control grant programs, and conduct research 

and reporting, as discussed throughout this report.

The two key regulations that HUD has issued under Title X are the Lead 

Disclosure Rule and the Lead Safe Housing Rule:

 

15The survey is a population-based survey to assess the health and nutritional status of 

adults and children in the United States and to determine the prevalence of major 

diseases and associated risk factors. Blood lead levels are one of several laboratory tests 

conducted as part of the survey. CDC reviews National Health and Nutrition Examination 

Survey data as they are updated and reviews the blood lead reference value every 4

years based on the two most recent cycles of data. The current blood lead reference value

is based on National Health and Nutrition Examination Survey data from 2007–2008 and 

2009–2010. According to CDC staff, as of February 2018, the agency was considering 

updating its blood lead reference value based on National Health and Nutrition 

Examination Survey data from 2011–2014.

16Exec. Order No. 13045, 3 C.F.R. § 13045 (1998). The President’s Task Force on 

Environmental Health Risks and Safety Risks to Children was created, among other 

duties, to identify children’s environmental health and safety issues (including lead), 

develop federal interagency strategies, and communicate information to federal, state, and 

local decision makers. It has 17 members. 

17President’s Task Force on Environmental Health Risks and Safety Risks to Children, 

Eliminating Childhood Lead Poisoning: A Federal Strategy Targeting Lead Paint Hazards, 

February 2000.

18Housing and Community Development Act of 1992, Pub. L. No. 102-550, title X, § 1001 

et seq. (1992) (codified generally at 42 U.S.C. § 4851-56. and 15 U.S.C. 2681-92) 

(hereinafter Title X). Prior to this, in 1971, Congress had passed the Lead-Based Paint 

Poisoning Prevention Act, Pub. L. No. 91-695, 84 Stat. 2078 (1971) (codified at 42 U.S.C. 

§ 4801-46). This law required that the government establish procedures aimed at 

eliminating lead paint hazards in federally assisted housing. 
Page 7 GAO-18-394 Lead Paint in Housing

• Lead Disclosure Rule. In 1996, HUD and EPA jointly issued the 

Lead Disclosure Rule.19 The rule applies to most housing built before 

1978 and requires sellers and lessors to disclose any known 

information, available records, and reports on the presence of lead 

paint and lead paint hazards and provide an EPA-approved 

information pamphlet prior to sale or lease. 

• Lead Safe Housing Rule. In 1999, HUD first issued the Lead Safe 

Housing Rule, which applies only to housing receiving federal 

assistance or federally-owned housing being sold.20 The rule 

established procedures for evaluating whether a lead paint hazard 

exists, controlling or eliminating the hazard, and notifying occupants of 

any lead paint hazards identified and related remediation efforts. The 

rule established an “elevated blood lead level” as a threshold that 

requires landlords and PHAs to take certain actions if a child’s blood 

test shows lead levels meeting or exceeding this threshold. In 2017, 

HUD amended the rule to align its definition of an “elevated blood lead 

level” with CDC’s blood lead reference value.

21 This change lowered 

the threshold that generally required landlords and PHAs to act from 

20 micrograms to 5 micrograms of lead per deciliter of blood. 

According to the rule, when a child under age 6 living in HUD-assisted 

housing has an elevated blood lead level, the housing provider must 

take several steps. These generally include testing the home and 

other potential sources of the child’s lead exposure within 15 days, 

ensuring that identified lead paint hazards are addressed within 30 

days of receiving a report detailing the results of that testing, and 

reporting the case to HUD.

 

19Requirements for Disclosure of Known Lead-Based Paint and/or Lead-Based Paint 

Hazards in Housing, 61 Fed. Reg. 9064 (Mar. 6, 1996). 

20Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards 

in Federally Owned Residential Property and Housing Receiving Federal Assistance, 64 

Fed. Reg. 50140 (Sept. 15, 1999). Throughout the report, the term “lead paint regulations” 

means the parts of the Lead Disclosure Rule and the Lead Safe Housing Rule applicable 

to HUD’s public housing and Housing Choice Voucher programs, unless otherwise 

specified. See ex. 24 C.F.R. part 35, sbpts. A, L, and M. The Lead Safe Housing Rule 

includes other requirements, such as those for residential housing owned by federal 

agencies other than HUD or HUD-owned single family properties, but as previously noted 

these programs or requirements were not the focus of this review.

21Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards 

in Generally Owned Residential Property and Housing Receiving Federal Assistance, 82 

Fed. Reg. 4151 (Jan. 13, 2017). 
Page 8 GAO-18-394 Lead Paint in Housing

Office of Lead Hazard Control and Healthy Homes (Lead Office).

HUD’s Lead Office is primarily responsible for administering HUD’s two 

lead hazard control grant programs, providing guidance on HUD’s lead 

paint regulations, and tracking HUD’s efforts to make housing lead-safe. 

The Lead Office collaborates with HUD program offices on its oversight 

and enforcement of lead paint regulations.22 For instance, the Lead Office 

issues guidance, responds to questions about requirements of lead paint 

regulations, and provides training and technical assistance to HUD 

program staff, PHA staff, and property owners. The Lead Office’s 

oversight efforts also include maintaining email and telephone hotlines to 

receive complaints and tips from tenants or homeowners, among others, 

as they pertain to lead paint regulations.23 Additionally, the Lead Office, in 

collaboration with EPA, contributes to the operation of the National Lead 

Information Center––a resource that provides the general public and 

professionals with information about lead, lead hazards, and their 

prevention.24

Office of Public and Indian Housing (PIH). HUD’s PIH oversees and 

enforces HUD’s lead paint regulations for the rental assistance 

programs.25 As discussed earlier, this report focuses on the two largest 

rental assistance programs serving the most families with children––the 

Housing Choice Voucher and public housing programs.

• Housing Choice Voucher program. In the voucher program, eligible 

families and individuals are given vouchers as rental assistance to 

 

22HUD’s Office of the Secretary has delegated oversight and enforcement authority for 

lead paint laws and regulations to HUD’s Lead Office. See Delegation of Authority for the 

Office of Lead Hazzard Control and Healthy Homes, 81 Fed. Reg. 89496 (Dec. 12, 2016). 

According to the Lead Office’s interpretive guidance for the Lead Safe Housing Rule, 

monitoring and enforcement of compliance with the Lead Safe Housing Rule will be 

integrated into the administrative procedures for each affected HUD program, such as the 

voucher and public housing programs. 

23Property owners or tenants of HUD-assisted housing can email 

Lead_Regulations@HUD.gov or call (202) 402-7690. Additionally, PHAs and property 

owners can call or email to request technical assistance.

24The general public can call 1 (800) 424-LEAD or see 

https://www.epa.gov/lead/forms/lead-hotline-national-lead-information-center for more 

information. 

25Other HUD offices, including the Office of Housing and Office of Community Planning 

and Development, oversee other forms of rental assistance covered by the Lead Safe 

Housing Rule; however, as previously noted these programs were not the focus of this 

review. 

HUD Offices Involved in 

Lead Efforts and HUD’s 

Rental Assistance 

Programs
Page 9 GAO-18-394 Lead Paint in Housing

use in the private housing market. Generally, eligible families with 

vouchers live in the housing of their choice in the private market. The 

voucher generally pays the difference between the family’s 

contribution toward rent and the actual rent for the unit.26 Vouchers 

are portable; once a family receives one, it can take the voucher and 

move to other areas where the voucher program is administered.27 In 

2017, there were roughly 2.5 million vouchers available.28

• Public housing program. Public housing is reduced-rent 

developments owned and operated by the local PHA and subsidized 

by the federal government.29 PHAs receive several streams of funding 

from HUD to help make up the difference between what tenants pay 

in rent and what it costs to maintain public housing. For example, 

PHAs receive operating and capital funds through a formula allocation 

process. PHAs use operating funds to pay for management, 

administration, and day-to-day costs of running a housing 

development. Capital funds are used for modernization needs, such 

as replacing roofs or remediating lead paint hazards. According to 

HUD rules, generally families that are income-eligible to live in public 

housing pay 30 percent of their adjusted income toward rent. In 2017, 

there were roughly 1 million public housing units available.

For both of these rental assistance programs, the Office of Field 

Operations (OFO) within PIH oversees PHAs’ compliance with lead paint 

regulations, in conjunction with HUD field office staff. The office has a 

risk-based approach to overseeing PHAs and performs quarterly risk 

assessments. Also within PIH, staff from the Real Estate Assessment 

 

26Specifically, a family generally pays 30 percent of its monthly adjusted income toward 

rent, and the PHA pays to the landlord the remainder of the rent through a HUDsubsidized “voucher.” The voucher generally is equal to the difference between (1) the 

lesser of the unit’s gross rent (generally, rent plus utilities) or a local “payment standard” 

and (2) the household’s payment. The payment standard is based on the local fair market 

rent established by HUD. HUD defines “adjusted income” as a family’s annual income 

minus a number of mandatory deductions, such as an amount for unreimbursed 

reasonable child care expenses necessary to enable a family member to work or further 

their education.

27The portability of vouchers may be subject to some restrictions, such as a 12 month 

waiting period before a tenant can move to a location outside of the PHA’s jurisdiction. 

28Congress usually provides funding for vouchers annually in the appropriations for HUD.

29Some states, such as Massachusetts, fund public housing properties that do not receive 

assistance from HUD and are separate from HUD’s public housing program. These are 

not included in the scope of our work. 
Page 10 GAO-18-394 Lead Paint in Housing

Center are responsible for inspecting the physical condition of public 

housing properties.

Office of Policy Development and Research (PD&R). HUD’s PD&R is 

the primary office responsible for data analysis, research, and program 

evaluations to inform the development and implementation of programs 

and policies across HUD offices.

HUD has had two grant programs that competitively award lead hazard 

control grants to state and local jurisdictions: the Lead-Based Paint 

Hazard Control grant program and the Lead Hazard Reduction 

Demonstration grant program.30 For both grant programs, HUD has 

issued annual Notices of Funding Availability (funding notices) to solicit 

applications from these jurisdictions.31 Both grant programs have had a 3-

year term and are intended to help jurisdictions identify and control lead

hazards in low-income, private housing where children under age 6 reside 

or are likely to reside.32 However, the Lead Hazard Reduction 

Demonstration grant program has been focused on urban jurisdictions 

with rental housing built before 1940 and higher rates of childhood lead 

poisoning. Both grant programs have required grantees to meet certain 

matching requirements, but the percentage of matching contribution 

differed for each program. Specifically, the Lead-Based Paint Hazard 

Control grant program has required grantees to match at least 10 percent 

 

30The grant programs are authorized by Title X § 1011(codified as amended at 42 U.S.C. 

§ 4852). The Consolidated Appropriations Act 2018, Pub. L. No. 115-141, Div. L, Title II 

(2018), provides funds for a single grant program referred to as the Lead Hazard 

Reduction Program. According to HUD, the single grant program would cover the breadth 

of the two previous lead grant programs.

31Other federal agencies sometimes refer to these announcements as Notices of Funding 

Opportunity. Federal agencies publish these notices to announce opportunities for 

applicants to apply for competitively awarded grants. 

32HUD is authorized to provide grants to eligible applicants to evaluate and reduce lead 

paint hazards in housing that is not federally assisted, owned, or public housing. 

Specifically, HUD noted in its 2017 funding notice that the lead grant programs assist 

jurisdictions in undertaking programs to control lead paint hazards in eligible privately 

owned rental or owner-occupied housing. 

Example of a Home with Lead Paint 

Hazards

Source: GAO. | GAO-18-394

The sign provided a warning about lead paint 

hazard and was posted at a home in Baltimore, 

Maryland, which was undergoing lead paint 

hazard remediation work funded by the 

Department of Housing and Urban 

Development’s lead hazard control grant 

program.

Example of a Home with Peeling Lead Paint

Source: GAO. | GAO-18-394

The exterior siding of this home in Alameda 

County, California, showed peeling paint 

identified as a lead paint hazard. Alameda 

County used grant funds from the Department 

of Housing and Urban Development’s lead 

hazard control grant program for the 

remediation work.

HUD’s Lead Hazard 

Control Grant Programs
Page 11 GAO-18-394 Lead Paint in Housing

of the total grant amount, while the Lead Hazard Reduction 

Demonstration grant program has required at least a 25 percent match.33

For fiscal years 2013–2017, HUD awarded $527 million for its lead 

hazard control grants, which included 186 grants to state and local 

jurisdictions (see fig. 1). In these 5 years, about 40 percent of grants 

awarded went to jurisdictions in the Northeast and 31 percent to 

jurisdictions in the Midwest––regions of the country known to have a high 

prevalence of lead paint hazards.34

Figure 1: The Department of Housing and Urban Development’s Lead Hazard 

Control Grant Programs, Fiscal Years 2013–2017

Note: The percentages do not always add to 100 percent due to rounding.

 

33For instance, if HUD’s grant award is $3 million, the grantee is required to contribute at 

least $300,000 (10 percent) for the Lead-Based Paint Hazard Control grant program or at 

least $750,000 (25 percent) for the demonstration grant program. The Consolidated 

Appropriations Act 2018, Pub. L. No. 115-141, Div. L, Title II (2018), does not specify a 

match requirement for the single grant program referred to as the Lead Hazard Reduction 

Program. 

34Department of Housing and Urban Development, American Healthy Homes Survey: 

Lead and Arsenic Findings, April 2011. 
Page 12 GAO-18-394 Lead Paint in Housing

Additionally, in these 5 years, 90 percent of grant awards went to 

grantees at the local jurisdiction level (cities, counties, and the District of 

Columbia). The other 10 percent of grant awards went to state 

governments. During this time period, HUD awarded the most grants to 

jurisdictions in Ohio (17 grants), Massachusetts and New York (15 grants 

each), and Connecticut (14 grants).
Page 13 GAO-18-394 Lead Paint in Housing

HUD’s Lead-Based Paint Hazard Control grant and the Lead Hazard 

Reduction Demonstration grant programs have incorporated Title X 

statutory requirements through recent annual funding notices and their 

grant processes. Title X contains applicant eligibility requirements and 

selection criteria HUD should use to award lead grants.

To be eligible to receive a grant, applicants need to

• be a state or local jurisdiction,

• contribute matching funds to supplement the grant award,

• have an approved comprehensive affordable housing strategy, and

• have a certified lead abatement program (if the applicant is a state 

government).35

HUD has incorporated these eligibility requirements in its grant programs’ 

2017 funding notices, which require applicants to demonstrate that they 

meet these requirements when they apply for a lead grant. According to 

the 2017 funding notices, applicants must detail the sources and amounts 

of their matching contributions in their applications. Similarly, applicants 

must submit a form certifying that the proposed grant activities are 

consistent with their local affordable housing strategy. HUD’s 2017 

 

35A certified lead abatement program is a state-administered program that trains and 

certifies lead abatement professionals and has been authorized by EPA.

HUD Has 

Incorporated 

Relevant 

Requirements for 

Awarding Recent 

Lead Grants, but 

Could Better 

Document and 

Evaluate Grant 

Processes

Lead Grant Programs 

Have Incorporated 

Statutory Requirements 

for Eligibility and Selection
Page 14 GAO-18-394 Lead Paint in Housing

funding notices state that if applicants did not meet these eligibility 

requirements, HUD would not consider their applications.

Additionally, Title X requires HUD to award lead grants according to the 

following applicant selection criteria:

• the extent to which an applicant’s proposed activities will reduce the 

risk of lead poisoning for children under the age of 6;

• the degree of severity and extent of lead paint hazards in the 

applicant’s jurisdiction;

• the applicant’s ability to supplement the grant award with state, local, 

or private funds;

• the applicant’s ability to carry out the proposed grant activities; and

• other factors determined by the HUD Secretary to ensure that the 

grants are used effectively.

In its 2017 funding notices, HUD incorporated the Title X applicant 

selection criteria through five scoring factors that it used to assess lead 

grant applications. HUD allocated a certain number of points to each 

scoring factor. Applicants are required to develop their grant proposals in 

response to the scoring factors. When reviewing applications, HUD staff 

evaluated an applicant’s response to the factors and assigned points for 

each factor. See table 1 for a description of the 2017 lead grant programs’ 

scoring factors and points.

Table 1: HUD’s Lead-Based Paint Hazard Control Grant and Lead Hazard Reduction Demonstration Grant Programs’ Scoring 

Factors and Point Distribution, 2017

HUD’s scoring factors Description Maximum 

available points

1. Capacity of the applicant and 

relevant organizational 

experience

Applicants must demonstrate that they and their partners have sufficient 

qualified personnel and are prepared to perform lead hazard control work, 

among other things.

20

2. Need/extent of the problem Applicants must demonstrate need for a lead grant in the applicant’s jurisdiction 

through publicly available data, including elevated blood lead level data, income 

data, housing data, and other factors contributing to need. 

20

3. Soundness of approach Applicants must demonstrate their ability to carry out lead hazard control work 

and prepare a quality workplan to implement the proposed lead grant activities.

46

4. Budget proposal Applicants must thoroughly estimate all applicable costs for lead grant activities 

and present them in a clear and coherent format.

10

5. Achieving results and 

program evaluation

Applicants must identify procedures for monitoring grant performance and 

measuring outcomes, among other things.

4

Total 100 points

Source: Department of Housing and Urban Development’s (HUD) 2017 Notices of Funding Availability for the lead grant programs. | GAO-18-394
Page 15 GAO-18-394 Lead Paint in Housing

As shown in table 1, HUD awarded the most points (46 out of 100) to the 

“soundness of approach” scoring factor, according to HUD’s 2017 funding 

notices. Through this factor, HUD incorporated Title X selection criteria on 

an applicant’s ability to carry out the proposed grant activities and 

supplement a grant award with state, local, or private funds. For example, 

HUD’s 2017 funding notices required applicants to describe their detailed 

plans to implement grant activities, including how the applicants will 

establish partnerships to make housing lead-safe. Specifically, HUD 

began awarding 2 of the 100 points to applicants who demonstrated 

partnerships with local public health agencies to identify families with 

children for enrollment in the lead grant programs. Additionally, HUD 

asked applicants to identify partners that can help provide assistance to 

complete the lead hazard control work for high-cost housing units. 

Furthermore, HUD required applicants to identify any nonfederal funding, 

including funding from the applicants’ partners. Appendix I includes 

examples of state, local, and nongovernmental funds that selected 

grantees planned to use to supplement their lead grants.

In its lead grant programs, HUD has taken actions that were consistent 

with OMB’s requirements for competitively awarded grants.36 OMB 

generally requires federal agencies to: (1) establish a merit-review 

process for competitive grants that includes the criteria and process to 

evaluate applications; and (2) develop a framework to assess the risks 

posed by applicants for competitive grants, among other things.37

Through a merit-review process, an agency establishes and applies 

criteria to evaluate the merit of competitive grant applications. Such a 

process helps to ensure that the agency reviews grant applications in a 

fair, competitive, and transparent manner. Consistent with the OMB 

requirement to establish a merit review process, HUD has issued annual 

funding notices that communicate clear and explicit evaluative criteria. In 

addition, HUD has established processes for reviewing and scoring grant 

 

36Competitively awarded federal grants generally follow stages of pre-award, award, 

implementation, and closeout. Our review focused on the pre-award stage. We define the 

term “pre-award” to mean those grant program activities that occur prior to the official 

award negotiations and agreement between the agency and grantee. The pre-award 

process varies from grant to grant, but it generally involves the preparation and publication 

of the funding notice by the agency, the development and submission of the application by 

applicants, the review of applications by the agency, and the agency award selection.

37Office of Management and Budget, Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal Awards (codified at 2 C.F.R. pt. 200), 

effective for grants awarded starting in December 2014.

HUD Has Taken Actions 

Consistent with OMB 

Requirements but Has Not 

Fully Documented or 

Evaluated Its Lead Grant 

Programs’ Processes
Page 16 GAO-18-394 Lead Paint in Housing

applications using these evaluative criteria, and selects grant recipients 

based on the review scores (see fig. 2). For example, applicants that 

score at or above 75 points are qualified to receive awards from HUD. 

Also, HUD awards funds beginning with the highest scoring applicant and 

proceeds by awarding funds to applicants in a descending order until 

funds are exhausted. Furthermore, consistent with the OMB requirement 

to develop a framework to assess applicant risks, HUD has developed a 

framework to assess the risk posed by lead grant applicants by, among 

other things, deeming ineligible those applicants with past performance 

deficiencies or those that do not have a financial management system 

that meets federal standards.
Page 17 GAO-18-394 Lead Paint in Housing

Figure 2: The Department of Housing and Urban Development’s Lead Grant Programs’ Processes for Reviewing and Selecting 

Applicants

However, HUD has not fully documented or evaluated its lead grant 

processes in reviewing and scoring the grants and making award 

decisions:

Documenting grant processes and award decisions. While HUD has 

established processes for its lead grant programs, it lacks documentation, 

including detailed guidance to help ensure that staff carry out processes 

consistently and appropriately. Federal internal control standards state 
Page 18 GAO-18-394 Lead Paint in Housing

that agency management should develop and maintain documentation of 

its internal control system.38 Such documentation assists agency 

management by establishing and communicating the processes to staff. 

Additionally, documentation of processes can provide a means to retain 

organizational knowledge and communicate that knowledge as needed to 

external parties.

The Lead Office’s Application Review Guide describes its grant 

application review and award processes at a high level but does not 

provide detailed guidance for staff as to how tasks should be performed.39

For example, the Guide notes that reviewers score eligible applications 

according to factors contained in the funding notices but does not 

describe how the reviewers should allocate points to the subfactors that 

make up each factor. Lead Office staff told us that creating detailed 

scoring guidance would be challenging because applicants’ proposed 

grant activities differ widely, and they said that scoring grant applications 

is a subjective process. While scoring grant applications may involve 

subjective judgments, improved documentation of grant review and 

scoring processes, including additional direction to staff, can help staff 

apply their professional judgment more consistently in evaluating 

applications. By better documenting processes, HUD can better ensure 

that staff evaluate applications consistently.

Additionally, HUD has not fully documented its rationale for deciding 

which applicants receive lead grant awards and for deciding the dollar 

amounts of grant awards to successful applicants. In prior work 

examining federal grant programs, one recommended practice we 

identified is that agencies should document the rationale for award 

decisions, including the reasons individual applicants were selected or not 

and how award funding amounts were determined.40 While HUD’s internal 

memorandums listed the applicants selected and the award amounts, 

these memorandums did not document the rationale for these decisions 

or provide information sufficient to help applicants understand award 

 

38GAO-14-704G. 

39Department of Housing and Urban Development, Office of Lead Hazard Control and 

Healthy Homes, Application Review Guide: Guidance for Notice of Funding Availability 

Review Teams, 2017.

40GAO, Intercity Passenger Rail: Recording Clearer Reasons for Awards Decisions Would 

Improve Otherwise Good Grantmaking Practices, GAO-11-283 (Washington, D.C.: Mar. 

10, 2011).
Page 19 GAO-18-394 Lead Paint in Housing

outcomes.41 Lead Office staff told us that most grantees have received 

the amount of funding they requested in their applications, which was 

generally based on HUD’s maximum grant award amount. Lead Office 

staff said they could use their professional judgment to adjust award 

amounts to extend funding to more applicants when applicants received 

similar scores.

However, the Lead Office’s documentation we reviewed did not explain 

this type of decision making. For example, in 2017, when two applicants 

received identical scores on their applications, HUD awarded each 

applicant 50 percent of the remaining available funds rather than 

awarding either applicant the amount they requested. Representatives of 

one of the two grantees told us they did not know why the Lead Office 

had not provided them the full amount they had requested. Lead Office 

staff told us that, to date, HUD has not considered alternative ways to 

award grant funding amounts. By fully documenting grant award 

processes, including the rationale for award decisions and amounts, HUD 

could provide greater transparency to grant applicants about its grant 

award decisions.

Evaluating processes. HUD lacks a formal process for reviewing and 

updating its lead grant funding notices, including the factors and point 

allocations used to score applications. Federal internal control standards 

state that agencies should implement control activities through policies 

and that periodic review of policies and procedures can provide 

assurance of their effectiveness in achieving the agency’s objectives.42

Lead Office staff told us that previous changes to the factors and point 

allocation used to score applicants have been made based on informal 

discussions among staff. However, the Lead Office does not have a 

formal process to review and evaluate the relevance and appropriateness 

of the factors or points used to score applicants. Lead Office staff told us 

that they have never analyzed the scores applicants received for the 

factors to identify areas where applicants may be performing well or 

poorly or to help inform decisions about whether changes may be needed 

to the factors or points.

 

41According to the Lead Office’s memorandums, the documents constitute the final report 

of the Application Review Panel. 

42GAO-14-704G. 
Page 20 GAO-18-394 Lead Paint in Housing

Additionally, HUD has not changed the threshold criteria used to make 

award decisions since the threshold was established in 2003. As 

previously shown in figure 2, applicants who received at least 75 points 

(out of 100) have been qualified to receive a grant award. However, HUD 

grant documentation, including the funding notices and the Application 

Review Guide, does not explain the significance of this 75-point 

threshold. Lead Office staff stated that this threshold was first established 

in 2003 by HUD based on OMB guidance. A formal review of this 75-point 

threshold can help HUD determine whether it remains appropriate for 

achieving the grant programs’ objectives. Furthermore, by periodically 

evaluating processes for reviewing and scoring grant applications, HUD 

can better determine whether these processes continue to help ensure 

that lead grants reach areas of the country at greater risk for lead paint 

hazards.

HUD has begun to develop analyses and tools to inform its efforts to 

target outreach and ensure that grant awards go to areas of the country 

that are at risk for lead paint hazards. However, HUD has not developed 

time frames for incorporating the results of the analyses into its lead grant 

programs’ processes. HUD has required jurisdictions applying for lead 

grants to include data on the need or extent of the problem in their 

jurisdiction (i.e., scoring factor 2). Additionally, Lead Office staff told us 

that HUD uses information from the American Healthy Homes Survey to 

obtain information on lead paint hazards across the country.43 However, 

the staff explained that the survey was designed to provide meaningful 

results at the regional level and did not include enough homes in its 

sample to provide information about housing conditions, such as lead 

paint hazards, at the state or local level. Because HUD awards lead 

grants to state and local jurisdictions, it cannot effectively use the survey 

results to help the agency make award decisions or inform decisions 

about areas for potential outreach.

In early 2017, the Lead Office began working with PD&R to develop a 

model to identify local jurisdictions (at the census-tract level) that may be 

at heightened risk for lead paint hazards. Lead Office staff said that they 

hope to use results of this model to develop geographic tools to help 

 

43Department of Housing and Urban Development, American Healthy Homes Survey:

Lead and Arsenic Findings (April 2011). HUD conducted the survey from June 2005

through March 2006. The survey measured levels of lead, lead hazards, allergens, 

arsenic, pesticides, and mold in homes nationwide. 

HUD Has Begun to 

Develop Analyses to Help 

More Fully Identify Areas 

at Risk for Lead Paint 

Hazards but Has Not Set 

Time Frames for Using 

Local-Level Data
Page 21 GAO-18-394 Lead Paint in Housing

target HUD funding to areas of the country at risk for lead paint hazards 

but not currently receiving a HUD lead grant. Lead Office staff said that 

they could reach out to these at-risk areas, help them build the capacity 

needed to administer a grant, and encourage them to apply. For example, 

HUD has identified that Mississippi and two major metropolitan areas in 

Florida (Miami and Tampa) had not applied for a lead grant. HUD has 

conducted outreach to these areas to encourage them to apply for a lead 

grant. In 2016, the City of Jackson, Mississippi, applied for and received a 

lead grant.

Though the Lead Office has collaborated with PD&R on the model, HUD 

has not developed specific time frames to operationalize the model and 

incorporate the results of the model for using local-level data to help 

better identify areas at risk for lead paint hazards. Federal internal control 

standards require agencies to define objectives clearly to enable the 

identification of risks.44 This includes clearly defining time frames for 

achieving the objectives. Setting specific time frames could help to ensure 

that HUD operationalizes this model in a timely manner. By 

operationalizing a model that incorporates local data on lead paint hazard 

risk, HUD can better target its limited grant resources towards areas of 

the country with significant potential for lead hazard control needs.

We performed a county-level analysis using HUD and Census Bureau

data and found that most lead grants from 2013 through 2017 have gone 

to counties with at least one indicator of lead paint hazard risk.45

Information we reviewed, such as relevant literature, suggests that the 

two common indicators of lead paint hazard risk are the prevalence of 

housing built before the 1978 lead paint ban and the prevalence of 

 

44GAO-14-704G. 

45We used county-level estimate data on the age of housing and poverty level in the 

United States from the Census Bureau’s 2011–2015 American Community Survey data. 

The specific variables used were year structure built and poverty status. The estimated 

county-level percentages of older housing and poverty rate are expressed as a range of 

values. For the lower and upper ends of the range, we generated a 95 percent confidence 

interval that was within plus or minus 20 percentage points. Our analysis did not account 

for population, but for the purposes of awarding grants, population density of a jurisdiction 

may be one of a number of relevant factors, according to HUD staff. For additional details 

on our analysis, see appendix II.
Page 22 GAO-18-394 Lead Paint in Housing

individuals living below the poverty line.46 We defined areas with lead 

paint hazard risk as counties that had percentages higher than the 

corresponding national percentages for both of these indicators. The 

estimated average percentage nationwide of total U.S. housing stock 

constructed before 1980 was 56.9 percent and the estimated average 

percentage nationwide of individuals living below the poverty line was 

17.5 percent.47 As shown in figure 3, our analysis estimated that 18 

percent of lead grants from 2013 through 2017 have gone to counties 

with both indicators above the estimated national percentages, 59 percent 

of grants have gone to counties with estimated percentages of old 

housing above the estimated national percentage, and 7 percent of grants 

have gone to counties that had estimated poverty rates above the 

estimated national percentage.48 (For an interactive version of this map, 

click here.) When HUD finalizes its model and incorporates information 

into its lead grant processes, HUD will be able to better target its grant 

resources to areas that may be at heightened risk for lead paint hazards.

 

46For example, see Eric M. Roberts and Paul B. English, “Analysis of multiple-variable 

missing-not-at-random survey data for child lead surveillance using NHANES,” Statistics 

in Medicine 35 (August 2016) and A Targeted Approach to Blood Lead Screening in 

Children, Washington State: 2015 Expert Panel Recommendations, prepared by the 

Washington State Department of Health (November 2015). 

47We calculated the estimated percentages nationwide for the age of housing and poverty 

level in the United States using county-level data from the Census Bureau’s 2011–2015 

American Community Survey. The estimated average nationwide percentages of older 

housing and poverty rates are expressed as a range of values. For the lower and upper 

ends of the range, we generated a 95 percent confidence interval that was within plus or 

minus 20 percentage points. The Survey data on the age of housing is separated by the 

decade in which the structure was built. We selected 1980 as the threshold for older 

housing because it was the demarcation point closest in time to the 1978 lead paint ban. 

48For state government grantees (12 of them), we used address data provided by HUD 

and assigned a corresponding county. However, state government grantees can specify 

other counties within their state where lead hazard control activities may occur. In our 

analysis, we were not able to account for the actual counties where state grantee lead 

hazard control activities took place. 
Page 23 GAO-18-394 Lead Paint in Housing

Figure 3: Department of Housing and Urban Development (HUD) Lead Grant Awards (2013–2017) and Indicators of Lead Paint 

Hazard Risk by County

Note: This map shows the locations of HUD lead grant awards from 2013 through 2017. Also, this 

map compares counties in the United States with the estimated average percentages nationwide of 

two commonly known indicators of lead paint hazard risk. The two indicators and their estimated 

national percentages are: older housing as measured by pre-1980 housing (56.9 percent of the total 

U.S. housing stock) and poverty rate (17.5 percent of the total U.S. population). We calculated the 

estimated average percentages nationwide of the two indicators using county-level data from the 
Page 24 GAO-18-394 Lead Paint in Housing

2011–2015 American Community Survey. The estimated national and county-level percentages of 

the two indicators are expressed as a range of values. For the lower and upper ends of the range, we 

generated a 95 percent confidence interval that was within plus or minus 20 percentage points. We 

omitted the data for 12 counties that we determined were unreliable for our purposes. We categorized 

a given county based on whether the county had estimated percentages of pre-1980 housing and 

poverty statistically higher than one, both, or neither of the corresponding national percentages of 

both indicators. These two indicators do not reflect any differences in population density across 

counties, which may affect the quantity of housing stock at-risk for lead paint hazards. According to 

HUD staff, for the purposes of awarding lead grants, population density of a jurisdiction may be one of 

a number of possible relevant factors.

a

The location markers for the state grantees in this map represent the address of the grantees but 

may not necessarily reflect the areas where lead hazard control activities occurred.

In 2016, HUD began to incorporate new steps to monitor PHAs’ 

compliance with lead paint regulations for nearly 4,000 PHAs.49

Previously, according to PIH staff, HUD required only that PHAs annually 

self-certify their compliance with lead paint laws and regulations, and 

HUD’s Real Estate Assessment Center inspectors check for lead paint 

inspection reports and disclosure forms at public housing properties 

during physical inspections.50 Starting in June 2016, PIH began using 

new tools for HUD field staff to track PHAs’ compliance with lead paint 

requirements in the voucher and public housing programs.

 

49As previously noted, PHAs are state and local agencies that administer HUD’s Housing 

Choice Voucher and public housing programs. Within PIH, OFO is responsible for the 

general oversight of PHAs, including compliance with lead paint regulations. OFO works in 

conjunction with staff from HUD’s field offices to help monitor PHAs’ compliance with laws 

and regulations.

50HUD Form 50077, PHA Certifications of Compliance with the PHA Plans and Related 

Regulations. A lead paint inspection report explains the result of a surface-by-surface 

investigation to determine the presence of lead paint hazards, if any, in a property’s 

housing units. The Real Estate Assessment Center does not inspect all units in a property 

but rather determines a statistically valid sample of units based on the number of units 

within a property. 

HUD Could Take 

Additional Steps to 

Monitor Compliance 

with Lead Paint 

Regulations

HUD Has Taken Steps to 

Strengthen Compliance 

Monitoring for Lead Paint 

Regulations
Page 25 GAO-18-394 Lead Paint in Housing

As shown in figure 4, PIH’s compliance oversight processes for the 

voucher and public housing programs include various monitoring tools for 

overseeing PHAs. Key components of PIH’s lead paint oversight 

processes include the following:

• Tools for tracking lead hazards and cases of elevated blood 

levels in children. HUD uses two databases to monitor PHAs’ 

compliance with lead paint regulations: (1) the Lead-Based Paint 

Response Tracker, which PIH uses to collect and monitor information 

on the status of lead paint-related documents, including lead 

inspection reports and disclosure forms, in public housing properties 

but not in units with voucher assisted households; and (2) the 

Elevated Blood Lead Level Tracker, which PIH uses to collect and 

monitor information reported by PHAs on cases of elevated blood 

levels in children living in voucher and public housing units. In June 

2016, OFO began using the Lead-Based Paint Response Tracker 

database to store information on public housing units and to help HUD 

field office staff to follow up with PHAs that have properties missing 

required lead documentation. In July 2017, OFO began using 

information recorded in the Elevated Blood Lead Level Tracker to 

track whether PHAs started lead remediation activities in HUDassisted housing within the time frames required by the Lead Safe 

Housing Rule.51

• Lead paint hazards included in PHAs’ risk assessment scores.

OFO assigns scores to PHAs based on their relative risk in four 

categories: physical condition, financial condition, management 

capacity, and governance.52 OFO uses these scores to identify high- 

 

51According to OFO staff, this tracker was created to help HUD monitor PHAs’ compliance 

with some of the new requirements noted in the January 2017 amendment to the Lead 

Safe Housing Rule. See Requirements for Notification, Evaluation, and Reduction of 

Lead-Based Paint Hazards in Federally Owned Residential Property and Housing 

Receiving Federal Assistance, 82 Fed. Reg. 4151 (Jan. 13, 2017). 

52HUD’s risk-based approach seeks to target oversight and monitoring efforts to those 

PHAs that are most at risk. OFO’s Risk Assessment Protocol includes qualitative and 

quantitative analysis of PHAs’ physical and financial condition, management capacity, and 

governance. For example, risks to physical assets are considered under the “physical 

condition” category, while risks related to PHAs’ occupancy levels and voucher utilization 

rates would be considered under the “management” category. According to the protocol, 

OFO generates a score for each PHA estimating its relative risk. Each quarter, OFO 

issues a new risk assessment report designating PHAs as very high risk; high risk; 

moderate risk; or low risk. According to the protocol, there are nearly 4,000 PHAs, and 

because HUD has diminishing resources for oversight, OFO must direct its resources 

toward the riskiest PHAs. See Department of Housing and Urban Development, Office of 

Field Operations, Risk Assessment Protocol, July 2017. 
Page 26 GAO-18-394 Lead Paint in Housing

and very high-risk PHAs that will receive on-site full compliance 

reviews. In July 2017, OFO incorporated data from the Real Estate 

Assessment Center into the physical condition category of its Risk 

Assessment Protocol to help account for potential lead paint hazards 

at public housing properties.53

• Questions about lead paint included as part of on-site full 

compliance reviews. In fiscal year 2016, HUD field offices began 

conducting on-site full compliance reviews at high- and very high-risk 

PHAs as part of HUD’s compliance monitoring program to enhance 

oversight and accountability of PHAs. In fiscal year 2017, as part of 

the reviews, HUD field office staff started using a compliance 

monitoring checklist to determine if PHAs comply with major HUD 

rules and to gather additional information on the PHAs. This checklist 

included lead-related questions that PIH field office staff use to 

determine whether PHAs meet the requirements in lead paint 

regulations for both the voucher and public housing programs.54

 

53According to the protocol, OFO assigns points (i.e., indicating increased risk) if there is 

evidence that the PHA has been identified to have properties that are pre-1978 with 

peeling paint, according to Real Estate Assessment Center physical inspection data. And, 

if Real Estate Assessment Center physical inspection data note either a missing lead 

inspection report or lead disclosure forms, OFO assigns additional points.

54For the voucher program, the checklist requires a review of a PHA’s lead-based paint 

policies, procedures, and practices. For the public housing program, the checklist asks for 

documentation that PHAs have met lead paint requirements, such as evidence that 

properties have been tested for the presence of lead paint and that lead abatement was 

carried out when required.
Page 27 GAO-18-394 Lead Paint in Housing

Figure 4: Department of Housing and Urban Development’s (HUD) Process for Monitoring Public Housing Agencies’ 

Compliance with Lead Paint Regulations

a

HUD’s Public Housing program (public housing) is one of HUD’s two largest rental assistance 

programs (the other is the Housing Choice Voucher program) serving the most low-income families 

with children. Public housing is reduced-rent developments owned and operated by state or local 

entities and subsidized by the federal government.

b

In HUD’s Housing Choice Voucher program (voucher program), eligible families and individuals 

receive vouchers as rental assistance to use in the private housing market.

c

HUD requires PHAs to self-certify compliance with lead paint laws and regulations through HUD 

Form 50077, PHA Certifications of Compliance with the PHA Plans and Related Regulations.

d

As of July 2017, HUD began using information recorded in the Elevated Blood Lead Level Tracker in 

the public housing and voucher programs to record information the agency requires PHAs to report 

on cases of children with elevated blood lead levels in public housing and voucher units.

e

As of June 2016, HUD started using the Lead-Based Paint Response Tracker, a database designed 

to help monitor PHAs’ compliance with lead paint regulations with information collected by Real 

Estate Assessment Center inspectors in public housing units. Real Estate Assessment Center 

inspectors check for the presence of lead inspection reports and lead disclosure forms at public 

housing units, and recorded instances of chipped and peeling paint in pre-1978 housing.

f

In Fiscal Year 2017, HUD included questions on lead paint regulations within the monitoring checklist 

for the full compliance reviews.
Page 28 GAO-18-394 Lead Paint in Housing

In 2016, OFO and HUD field offices began using information from the 

new monitoring efforts to identify potential noncompliance by PHAs with 

lead paint regulations and help the PHAs resolve the identified issues.55

According to HUD data, as of November 2017, the Lead-Based Paint 

Response Tracker indicated that 9 percent (357) of PHAs were missing 

both lead inspection reports and lead disclosure forms for one or more 

properties. There were 973 PHAs missing one of the two required 

documents. OFO staff told us that they prioritized following up with PHAs 

that were missing both documents. According to OFO staff, PHAs can 

resolve potential noncompliance by submitting adequate lead 

documentation to HUD. OFO staff told us the agency considers missing 

lead documentation as “potential” noncompliance because PHAs may 

provide the required documentation or they may be exempt from certain 

requirements (e.g., HUD-designated elderly housing). 

While HUD has taken steps to strengthen compliance monitoring 

processes, it does not have a plan to identify and address the risks of 

noncompliance by PHAs with lead paint regulations. Federal internal 

control standards state that agencies should identify, analyze, and 

respond to risks related to achieving the defined objectives.56

Furthermore, when an agency has made significant changes to its 

processes—as HUD has done with its compliance monitoring 

processes—management review of changes to these processes can help 

the agency determine that its control activities are designed appropriately.

Our review found that HUD does not have a plan to help mitigate and 

address risks related to noncompliance with lead paint regulations by 

PHAs (i.e., ensuring lead safety in assisted housing). Additionally, our 

review found several limitations with HUD’s new compliance monitoring 

approach, which include the following:

• Reliance on PHA self-certifications. HUD’s compliance monitoring 

processes rely in part on PHAs self-certifying that they are in 

compliance with lead paint regulations, but recent investigations have 

 

55OFO works in conjunction with staff from HUD’s field offices to help monitor PHAs’

compliance with lead paint regulations. As previously noted, HUD’s Office of the Secretary 

has delegated oversight and enforcement authority for lead paint laws and regulations to 

HUD’s Lead Office, which collaborates with HUD program offices, such as PIH (OFO is 

within PIH), see 81 Fed. Reg. 89496 (Dec. 12, 2016).

56GAO-14-704G. 

HUD Does Not Have a 

Plan to Mitigate Risks 

Associated with Its 

Compliance Monitoring 

Approach
Page 29 GAO-18-394 Lead Paint in Housing

found that some PHAs may have falsely certified that they were in 

compliance. In November 2017, HUD filed a fraud complaint against 

two former officials of the Alexander County (Illinois) Housing 

Authority, alleging that the former official, among other things, falsely 

certified to HUD that the Housing Authority was in compliance with 

lead paint regulations.57 Further, PIH staff told us there are ongoing 

investigations related to potential noncompliance with lead paint 

regulations and false certifications at two other housing authorities.

• Lack of comprehensive data for the public housing program.

OFO started to collect data for the public housing program in the 

Lead-Based Paint Response Tracker in June 2016 and the inventory 

of all public housing properties includes units inspected since 2012. In 

addition, HUD primarily relies on the presence of lead inspection 

reports but does not record in the database when inspections and 

remediation activities occurred and does not determine whether they 

are still effective. Because of this, the information contained in the 

lead inspection reports may no longer be up-to-date. For example, a 

lead inspection report from the 1990s may provide evidence that 

abatement work was conducted at that time, but according to PIH 

staff, the housing may no longer be lead-safe.58

• Lack of readily available data for the voucher program. The 

voucher program does not have readily available data on housing 

units’ physical condition and compliance with lead paint regulations 

because data on the roughly 2.5 million units in the program are kept 

at the PHA level. According to PIH staff, HUD plans to adopt a new 

system for the voucher program that will include standardized, 

electronic data for voucher units. PIH staff said the new system 

(Uniform Physical Condition Standards for Vouchers Protocol) will 

allow greater oversight and provide HUD the ability to conduct data 

analysis for voucher units.

• Challenges identifying children with elevated blood lead levels.

For several reasons, PHAs face ongoing challenges receiving 

information from state and local public health departments on the 

 

57According to the complaint, the former Executive Director of the Alexander County 

Housing Authority had indicated that the Housing Authority had completed required lead 

inspections, but a review of the PHA’s records revealed that the submitted certifications 

were false. 

58In January 2018, HUD announced $25 million in grant funding to help identify and 

remediate lead paint hazards in public housing. According to the announcement, the 

funding is needed for housing that was tested and abated over 20 years ago and those 

past control methods may no longer be effective. 
Page 30 GAO-18-394 Lead Paint in Housing

number of children identified with elevated blood lead levels. First, 

children across the U.S. are not consistently screened and tested for 

exposure to lead.59 Second, according to CDC data, many states use 

a less stringent health guideline to identify children compared to the 

health standard that HUD uses (i.e., CDC’s current blood lead 

reference value).60 PIH staff told us that some public health 

departments may not report children with elevated blood levels to 

PHAs because they do not know that a child is living in a HUDassisted unit and needs to be identified using the more stringent HUD 

standard. Lastly, Lead Office staff told us that privacy laws in some 

states may impose restrictions on public health departments’ ability to 

share information with PHAs.

• Limited coverage of on-site compliance reviews. While full on-site 

compliance reviews can be used to determine if PHAs are in 

compliance with lead paint regulations, OFO conducts a limited 

number of these reviews annually. For example, in Fiscal Year 2017, 

OFO conducted 72 reviews of the roughly 4,000 total PHAs. Based on 

OFO information, there are 973 PHAs that are missing either lead 

 

59Blood lead testing is a covered service for children enrolled in the Medicaid program 

through the Early and Periodic, Screening, Diagnostic and Treatment benefit. All children 

enrolled in Medicaid are required to receive blood lead screening tests at ages 12 months 

and 24 months. States are allowed to request approval from the Centers for Medicaid & 

Medicare to implement targeted lead screening programs (i.e., not test all children 

enrolled in Medicaid) and one state has an approval (Arizona). According to a November 

2016 Centers for Medicaid & Medicare Services bulletin, data suggest that only about 38 

percent of children enrolled in Medicaid ages 1–2 are reported to have been screened for 

lead in 2015. However, the Centers for Medicaid & Medicare believe that this underrepresents the actual number of children who received blood lead screening tests 

because the claims and encounter data this finding was based on do not capture 

screenings that are not paid for by Medicaid, such as screenings performed by clinics 

using CDC funding or funded by state health departments. Nevertheless, the Centers for 

Medicaid & Medicare states the data indicate that there are many children at risk of lead 

exposure that are not being tested. Further, for children not enrolled in Medicaid, 

according to the American Academy of Pediatrics and CDC, universal screens or blood 

lead level tests are recommended for children living in high prevalence areas with 

increased risk factors as identified by CDC, such as older housing. 

60According to CDC’s data, as of February 2018, 18 states and the District of Columbia 

were aligned with the federal health guideline of 5 micrograms per deciliter of blood, and 

the remaining 32 states used a less stringent standard (i.e., a guideline greater than 5 

micrograms per deciliter of blood), which may result in fewer children with elevated blood 

lead levels being identified and reported. Additionally, CDC staff noted that the specific 

actions required to be taken when a child tests above the blood lead reference value vary.
Page 31 GAO-18-394 Lead Paint in Housing

inspection reports or lead disclosure forms indicating some level of 

potential noncompliance.61

HUD’s steps since June 2016 to enhance monitoring of PHAs’ 

compliance with lead paint regulations have some limitations that create 

risks in its new compliance monitoring approach. By developing a plan to 

help mitigate and address the various limitations associated with the new 

compliance monitoring approach, HUD could further strengthen its 

oversight and help ensure that PHAs maintain lead-safe housing units.

HUD does not have detailed procedures to address PHA noncompliance 

with lead paint regulations or to determine when enforcement decisions 

may be needed. Lead Office staff told us that their enforcement program 

aims to ensure that PHAs have the information necessary to remain in 

compliance with lead paint regulations. According to federal internal 

control standards, agencies should implement control activities through 

policies and procedures.62 Effective design of procedures to address 

noncompliance would include documenting specific actions to be 

performed by agency staff when deficiencies are identified and related 

time frames for these actions.

While HUD staff stated that they address PHA noncompliance through 

ongoing communication and technical assistance to PHAs, HUD has not 

documented specific actions to be performed by staff when deficiencies 

are identified. OFO staff told us that in general, PIH has not needed to 

take many enforcement actions because field offices are able to resolve 

most lead paint regulation compliance concerns with PHAs through 

ongoing communication and technical assistance.63 For example, HUD 

 

61Additionally, PHAs that OFO identifies for suspected or potential lead paint hazards but 

determines to not pose sufficiently high risks in other categories—financial condition, 

management, and governance—may not be ultimately identified as one of the high- or 

very high-risk PHAs to receive a full on-site compliance review. 

62GAO-14-704G. 

63PIH staff told us the violation would have to be egregious for HUD to take an 

enforcement action such as evidence that the PHA’s actions contributed to injury or harm 

of residents living in HUD-assisted housing units (i.e., evidence that the noncompliance 

contributed to elevated blood lead levels). In response to our requests for enforcement 

actions taken, HUD provided evidence of one. For example, in 2013 Springfield 

(Massachusetts) Housing Authority entered into consent agreements with HUD and EPA 

to pay civil monetary penalties as a result of a joint enforcement effort between HUD and 

EPA to resolve alleged violations of certain requirements of lead paint regulations. 

HUD Lacks Detailed 

Procedures to Address 

Noncompliance and Make 

Enforcement Decisions
Page 32 GAO-18-394 Lead Paint in Housing

field offices sent letters to PHAs when Real Estate Assessment Center 

inspectors could not locate required lead inspection reports and lead 

disclosure forms, and requested that the PHA send the missing 

documentation within 30 days. However, OFO’s fiscal years 2015–2017 

internal memorandums on monitoring and oversight guidance for HUD 

field offices did not contain detailed procedures, including time frames or 

criteria HUD staff would use to determine when to consider whether a 

more formal enforcement action might be warranted.

Additionally, Lead Office staff said if efforts to bring a PHA into 

compliance are unsuccessful, the Lead Office would work in conjunction 

with PIH and HUD’s Office of General Counsel’s Departmental 

Enforcement Center to determine if an enforcement action is needed, 

such as withholding or delaying funds from a PHA or imposing civil 

money penalties on a PHA. Lead Office staff also told us that instead of 

imposing a fine on a PHA, HUD would rather work with the PHA to 

resolve the lead paint hazard. However, the Lead Office provided no 

documentation detailing the specific steps or time frames HUD staff would 

follow to determine when a noncompliance case is escalated to the Office 

of General Counsel. In a March 2018 report to Congress, HUD noted that 

children continued to test positive for lead in HUD-assisted housing in 

2017.64 In the same report, HUD notes PIH and the Lead Office will 

continue to work with PHAs to ensure compliance with lead paint 

regulations. By adopting procedures that clearly describe when lead paint 

hazard compliance efforts are no longer sufficient and enforcement 

decisions are needed, HUD can better keep PHAs accountable in a 

consistent and timely manner.

 

64From April to December 2017, 33 and 4 children, respectively, in the voucher and public 

housing programs, tested positive for lead in their blood and the source of the lead was 

identified as lead paint hazards in their housing units. See Department of Housing and 

Urban Development, Office of Public and Indian Housing and Office of Lead Hazard 

Control and Healthy Homes, Report to Congress: HUD Oversight of the Lead Safe 

Housing Rule for the Public Housing and Housing Choice Voucher Programs (March 

2018). 
Page 33 GAO-18-394 Lead Paint in Housing

The standard HUD uses to identify children with elevated blood lead 

levels and initiate lead hazard control activities in its rental assistance 

aligns with the health guideline set by CDC in 2012.65 HUD also uses 

CDC’s health guideline in its lead grant programs.66 In HUD’s January 

2017 amendment to the Lead Safe Housing Rule, HUD made its standard 

for lead in a child’s blood more stringent by lowering it from 20 

micrograms to 5 micrograms of lead per deciliter of blood, matching 

CDC’s health guideline (i.e., blood lead reference value).67 Specifically, 

HUD’s stronger standard allows the agency to respond more quickly 

when children under 6 years old are exposed to lead paint hazards in 

voucher and public housing units.68 The January 2017 rule also 

established more comprehensive testing for children and evaluation 

 

65CDC has identified no safe level of exposure to lead, measured in blood. Since 2012, 

CDC has used a health guideline (i.e., blood lead reference value) of 5 micrograms of lead 

per deciliter of blood to identify children whose blood lead levels are much higher than 

most children’s levels and for whom it recommends initiation of public health actions. 

66According to HUD’s 2017 Notices of Funding Availability for the lead grant programs, it 

is a program requirement that children living in housing units that will undergo lead hazard 

control work have their blood tested for lead levels unless the child’s parent or guardian 

chooses not to have the child tested. Additionally, HUD requires applicants to report the 

number of children under age 6 with an elevated blood lead level above CDC’s current 

reference level of 5 micrograms of lead per deciliter of blood. HUD uses this information to 

score applicants and award grants. 

67HUD issued a final rule that amends HUD’s lead paint regulations, see 82 Fed. Reg. 

4151 (Jan. 13, 2017) (codified at 24 C.F.R. pt. 35). The 2017 Elevated Blood Lead Level 

Amendment to HUD’s Lead Safe Housing Rule became effective on February 13, 2017 

and required PHAs and landlords to comply with the rule starting July 13, 2017.

68As previously stated, according to the January 2017 rule, if a child under age 6 living in 

a HUD-assisted housing unit has an elevated blood lead level, then the housing provider 

must test the home and building common areas for sources of the child’s lead exposure 

within 15 days, remediate lead paint hazards within 30 days of receiving the results of that 

test, and must report the case to HUD.

HUD’s Blood Lead 

Level Standard Aligns 

with CDC Guidelines 

and Lead Inspection 

Standards Are Less 

Stringent in the 

Voucher Program

HUD’s Blood Lead Level 

Standard Aligns with the 

Current CDC Health 

Guideline
Page 34 GAO-18-394 Lead Paint in Housing

procedures for HUD assisted housing. According to HUD’s press release 

that accompanied the rule, by aligning HUD’s standard with CDC’s 

guidance, HUD can respond more quickly in cases when a child who lives 

in HUD assisted housing shows early signs of lead in their blood.69 The 

2017 rule notes HUD will revise the agency’s elevated blood lead level to 

align with future changes HHS may make to its recommended 

environmental intervention level.70 

HUD’s standards for lead dust levels align with EPA standards for its 

rental assistance programs and exceed EPA standards for the lead grant 

programs. In 2001, EPA published a final rule on lead paint hazard 

standards, including lead dust clearance standards.71 The rule 

established standards to help property owners, contractors, and 

government agencies identify lead hazards in residential paint, dust, and

soil and address these hazards in and around homes. Under these 

standards, lead is considered a hazard when equal to or exceeding 40 

micrograms of lead in dust per square foot sampled on floors and 250 

micrograms of lead in dust per square foot sampled on interior window 

sills. In 2004, HUD amended the Lead Safe Housing Rule to incorporate 

the 2001 EPA lead dust standards as HUD’s standards. Since this time, 

HUD has used EPA’s 2001 lead hazard standards in its rental assistance 

programs.

In February 2017, HUD released policy guidance for its lead grantees 

requiring them to meet new and more protective requirements for 

identifying and addressing lead paint hazards in the lead grant programs 

than those imposed by EPA’s 2001 standards that HUD uses in the rental 

assistance programs.72 For example, the policy guidance requires 

 

69Department of Housing and Urban Development, HUD Issues Final Rule To Help 

Children Exposed to Lead Paint Hazards (Jan. 13, 2017).

70The final rule notes that the current recommended environmental intervention level is 

tied to the CDC’s blood lead reference value. As previously noted, CDC reviews the blood 

lead reference value every 4 years based on National Health and Nutrition Examination 

Survey data as the data are updated. 

71Identification of Dangerous Levels of Lead, 66 Fed. Reg. 1206 (Jan. 5, 2001). The rule 

establishes standards for lead-based paint hazards (including hazards from lead in dust 

and soil) in most pre-1978 housing and child-occupied facilities. 

72Department of Housing and Urban Development, Office of Lead Hazard Control and 

Healthy Homes Policy Guidance 2017-01 Rev. 1, Revised Dust-Lead Action Levels for 

Risk Assessment and Clearance; Clearance of Porch Floors (Washington, D.C.: Feb. 16, 

2017).

HUD’s Lead Dust 

Standards Align with EPA’s 

for Rental Assistance 

Programs and Exceed 

Them for Lead Grant 

Programs
Page 35 GAO-18-394 Lead Paint in Housing

grantees to consider lead dust a hazard on floors at 10 micrograms per 

square foot sampled (down from 40) and on window sills at 100 

micrograms per square foot sampled (down from 250). The policy 

guidance noted that the new requirements are supported by scientific 

evidence on the adverse effects of lead exposure at low blood lead levels 

in children. Further, the policy guidance established a standard for porch 

floors––an area that EPA has not covered––because porch floors can be 

both a direct exposure source for children and a source of lead dust that 

can be tracked into the home.

On December 27, 2017, the United States Court of Appeals for the Ninth 

Circuit ordered EPA to issue a proposed rule updating its lead dust 

hazard standard and the definition of lead-based paint within 90 days of 

the decision becoming final and a final rule within 1 year of the proposed 

rule.

73 Because HUD’s Lead Safe Housing Rule generally defines lead 

paint hazards and lead dust hazards to mean the levels promulgated by 

EPA, if EPA changes its 2001 standards those new standards would be 

used in HUD’s rental assistance programs. On March 16, 2018, EPA filed 

a request to the court asking for clarification for when EPA is required to 

issue the proposed rule and followed up with a motion seeking 

clarification or an extension. In response to EPA’s motion, on March 26, 

2018, the court issued an order clarifying time frames and ordered that 

the proposed rule be issued within 90 days from March 26, 2018.

HUD’s Lead Safe Housing Rule requires a stricter lead inspection 

standard for public housing than for voucher units. According to HUD 

staff, HUD does not have the authority to require the more stringent 

inspection in the voucher program. While HUD has acknowledged that 

moving to a stricter inspection standard for voucher units would provide 

greater assurance that these units are lead-safe and expressed its plan to 

support legislative change to authorize it to impose a more stringent 

inspection standard, HUD has not requested authority from Congress to 

amend its inspection standard for the voucher program.

For voucher units, HUD requires PHAs to ensure that trained inspectors 

conduct visual assessments to identify deteriorated paint for housing units 

 

73The United States Court of Appeals for the Ninth Circuit also noted that the deadlines 

would only be modified if EPA presented new information showing modification was 

required. See In Re A Cmty Voice v. U.S. Environmental Protection Agency, 878 F.3d 779 

(2017). 

HUD Uses a Less 

Stringent Lead Inspection 

Standard for the Voucher 

Program
Page 36 GAO-18-394 Lead Paint in Housing

inhabited by a child under 6 years old.74 In a visual assessment, an 

inspector looks for deteriorated paint and visible surface dust but does not 

conduct any testing of paint chips or dust samples from surfaces to 

determine the presence of lead in the home’s paint.75 By contrast, for 

public housing units, HUD requires a stronger inspection process. Leadbased paint inspections are required for pre-1978 public housing units. If that 

inspection identifies lead-based paint, PHAs must then perform a risk 

assessment. In a risk assessment, in addition to conducting a visual 

inspection, an inspector tests for the presence of lead paint by collecting 

and testing samples of paint chips and surface dust, and typically using a 

specialized device (an X-ray fluorescence analyzer) to measure the 

amount of lead in the paint on a surface, such as a wall, door, or window 

sill.

Staff from HUD’s Lead Office and the Office of General Counsel told us 

that Title X did not include specific risk assessment requirements for 

voucher units, and HUD does not believe, therefore, that it has the 

statutory authority to require an assessment more thorough than a visual 

assessment of voucher units.

76 As of May 2018, HUD had not requested

statutory authority to change the visual assessment standard used in the 

voucher program. However, HUD previously acknowledged the limitation 

of the weaker inspection standard in a June 2016 publication titled LeadSafe Homes, Lead-Free Kids Toolkit.77 In this publication, HUD noted its 

plans to support legislative change to strengthen lead safety in voucher 

units by eliminating reliance on visual-only inspections. Staff from HUD’s 

Lead Office and Office of General Counsel told us the agency recognizes 

that risk assessments are more comprehensive than visual assessments. 

The staff noted that, by definition, a risk assessment is a stronger 

inspection standard than a visual-only assessment because it includes 

additional identification and testing.

 

7424 C.F.R. § 35.1215. This subpart of the Lead Safe Housing Rule applies only to HUDassisted housing units occupied or to be occupied by families or households that have one 

or more children of less than 6 years of age, common areas servicing such housing units, 

and exterior painted surfaces associated with such housing units or common areas. 

75According to HUD staff, pre-1978 housing units are generally presumed to have leadbased paint, unless paint testing or an inspection has proven otherwise. 

76According to HUD, the legislative history shows that Congress directed HUD not to require 

risk assessments for the voucher program, see e.g., S. Rep. No. 102-332 (1992). 

77Department of Housing and Urban Development, Office of the Secretary, Lead-Safe 

Homes, Lead-Free Kids Toolkit (Washington, D.C.: June 13, 2016). 
Page 37 GAO-18-394 Lead Paint in Housing

In responding to a draft of this report, HUD cited the need to conduct and 

evaluate the results of a statistically rigorous study on the impacts of 

requiring a lead risk assessment versus a visual assessment, such as the 

impact on leasing times and the availability of housing for low-income 

families. HUD further noted that such a study could explore whether 

alternative options to the full risk assessment standard (such as targeted 

dust sampling) could achieve similar levels of protection for children in the 

voucher program. Requesting and obtaining authority to amend the 

standard for the voucher program would not preclude HUD from doing 

such a study. Such analysis might support a range of options based on 

consideration of health effects for children, housing availability, and other 

relevant factors. 

Because HUD’s Lead Safe Housing Rule contains a weaker lead 

inspection standard for the voucher program children living in voucher 

units may be less protected from lead paint hazards than children living in 

public housing. By requesting and obtaining statutory authority to amend 

the voucher program inspection standard, HUD would be positioned to 

take steps to ensure that children in the voucher program are provided 

better protection as indicated by analysis of the benefits and costs from 

amending the standard.

HUD has taken limited steps to measure, evaluate, and report on the 

performance of its programmatic efforts to ensure that housing is leadsafe. First, HUD has tracked one performance measure for its lead grant 

programs but lacks comprehensive performance goals and measures. 

Second, while HUD has evaluated the effectiveness of its Lead-Based 

Paint Hazard Control grant program, it has not formalized plans and does 

not have a time frame for evaluating its lead paint regulations. Third, HUD 

has not issued an annual report on the results of its lead efforts since 

1997.

A key aspect to promoting improved federal management and greater 

efficiency and effectiveness is that agencies set goals and report on 

performance. We have previously reported that a program performance 

assessment contains three key elements––program goals, performance 

HUD Could Better 

Measure and Report 

on Performance of 

Lead Efforts
Page 38 GAO-18-394 Lead Paint in Housing

measures, and program evaluations (see fig. 5).78 In our prior work, we 

have noted that both the executive branch and congressional committees 

need evaluative information to help them make decisions about the 

programs they oversee––information that tells them whether, and why, a 

program is working well or not.79

Figure 5: Key Elements of Program Performance Assessment for Federal Agencies

Program goals and performance measures. HUD has tracked one 

performance measure for making private housing units lead-safe as part 

of its lead grant programs but lacks goals and performance measures that 

more fully cover the range of its lead efforts. In addition to our prior work 

on program goals and performance measures, federal internal control 

standards state that management should define objectives clearly and 

that defining objectives in measurable terms allows agency management 

to assess performance toward achieving objectives.80 According to Lead 

Office staff, HUD provides information on its goals and performance 

measures related to its lead efforts in the agency’s annual performance 

 

78For example, see GAO-16-393. Program goals communicate what the agency proposes 

to accomplish and allow agencies to assess or demonstrate the degree to which those 

desired results were achieved. Performance measures are concrete, objective, observable 

conditions that permit the assessment of progress made towards the goals. We have 

previously defined performance measurement as the ongoing monitoring and reporting of 

program accomplishments, particularly progress toward pre-established goals. Most 

federal agencies now use performance measures to track progress towards goals. 

Program evaluations are individual systematic studies conducted periodically or on an ad 

hoc basis to assess how well a program is working, typically relative to its objectives. 

Some federal agencies conduct in-depth program evaluations to assess their programs’ 

impact or learn how to improve results. 

79GAO-16-393 and GAO-11-646SP. 

80GAO-14-704G. 
Page 39 GAO-18-394 Lead Paint in Housing

reports.81 For example, the fiscal year 2016 report contains information

about the number of private housing units made lead-safe as part of 

HUD’s lead grant programs but does not include any performance 

measures on HUD’s lead efforts for the voucher and public housing 

programs.82 Lead Office staff told us HUD does not have systems to 

count the number of housing units made lead-safe in these two housing 

programs. The staff said the Lead Office and PIH recently began 

discussing whether data from an existing HUD database could be used to 

count units made lead-safe within these programs. However, they could 

not provide additional details on the status of all these efforts. Without 

comprehensive goals and performance measures, HUD does not know 

the results it is achieving with all its lead paint hazard reduction efforts. 

Moreover, HUD may be missing opportunities to use performance 

information to improve the results of its lead efforts.

Program evaluations. HUD has evaluated the effectiveness of its LeadBased Paint Hazard Control grant program but has not taken similar 

steps to evaluate the Lead Safe Housing Rule or Lead Disclosure Rule. 

As previously stated, our prior work on program performance assessment 

has noted the importance of program evaluations to know how well a 

program is working relative to its objectives. Additionally, Title X required 

HUD to conduct research to evaluate the long-term cost-effectiveness of 

interim lead hazard control and abatement strategies. For its Lead-Based 

Paint Hazard Control Grant program, HUD has contracted with outside 

experts to conduct evaluations. For example, the National Center for 

Healthy Housing and the University of Cincinnati’s Department of 

Environmental Health evaluated whether the lead hazard control methods 

used by grantees continued to be effective 1, 3, 6, and 12 years later.83

 

81HUD has reported the information on lead-safe housing units for the grant programs as 

part of an overall agency goal and performance measure related to the number of green 

and healthy housing units completed (some of which may not be related to lead-safe 

housing efforts). Lead Office staff told us they track the average dollar amount grantees 

have spent to make a housing unit lead-safe (i.e., a cost per unit metric) but the agency 

does not formally track or report this metric. 

82Additionally, the report contained information on the number of housing units made leadsafe for other HUD programs, such as HUD’s Office of Community Planning and 

Development’s implementation of the Community Development Block Grant and HOME 

Investment Partnerships programs. As noted previously, this office and these programs 

were not the focus of this review. 

83The purpose of the evaluations was to compare the effectiveness of the different lead 

hazard control methods used by grantees, using lead dust levels and blood lead levels as 

the primary measures of effectiveness. Results of the lead grant program evaluations 

have been published between 2004 and 2012; for a full list of publications see appendix II.
Page 40 GAO-18-394 Lead Paint in Housing

The evaluations concluded that the lead hazard control activities used by 

grantees substantially reduced lead dust levels and the original evaluation 

and those completed 1 and 3 years later were also associated with 

substantial declines in the blood lead levels of children living in the 

housing remediated using lead grant program funds.

HUD has general plans to conduct evaluations of the Lead Safe Housing 

Rule and the Lead Disclosure Rule, but Lead Office and PD&R staff said 

they did not know when or if the studies will begin. In a 2016 publication, 

HUD noted its plans to evaluate the Lead Safe Housing Rule 

requirements and noted that such an evaluation would contribute toward 

policy recommendations and program improvements.84 Additionally, in its 

2017 Research Roadmap, PD&R outlined HUD’s plans for two studies to 

evaluate the effectiveness of requirements within the Lead Safe Housing 

and Lead Disclosure Rules.85 However, PD&R and Lead Office staff were

not able to provide a time frame for when the studies would begin. PD&R 

staff told us that the plans noted within the Research Roadmap were 

HUD’s first step in research planning and prioritization but that 

appropriations for research have been prescriptive in recent years (i.e., 

tied to specific research topics) and fell short of the agency’s research 

needs. By studying the effectiveness of requirements included within the 

Lead Safe Housing and Lead Disclosure Rules, including the costeffectiveness of the various lead hazard control methods, HUD could 

have more complete information to assess how effectively it uses federal 

dollars to make housing units lead-safe.

Reporting. HUD has not reported on its lead efforts as required since 

1997.86 Title X includes annual and biennial reporting requirements for 

 

84Department of Housing and Urban Development, Office of the Secretary, Lead-Safe 

Homes, Lead-Free Kids Toolkit (Washington, D.C.: June 13, 2016).

85Department of Housing and Urban Development, Office of Policy Development and 

Research, HUD Research Roadmap: 2017 Update, January 2017. 

86Department of Housing and Urban Development, Office of Lead Hazard Control, Moving 

Toward A Lead-Safe America: A Report to the Congress of the United States, February 

1997. In March 2018 HUD issued a report in response to a request from Congress to 

report on the steps HUD has taken to improve its data collection and analysis processes 

for Housing Choice Voucher units with respect to lead paint regulations, see Department 

of Housing and Urban Development, Office of Public and Indian Housing and Office of 

Lead Hazard Control and Healthy Homes, Report to Congress: HUD Oversight of the 

Lead Safe Housing Rule for the Public Housing and Housing Choice Voucher Programs,

March 2018. 
Page 41 GAO-18-394 Lead Paint in Housing

HUD.87 Staff from HUD’s Lead Office and General Counsel told us that in 

1998 the agency agreed with the congressional committees of jurisdiction 

that HUD could satisfy this reporting requirement by including the 

required information in its annual performance reports. Lead Office staff 

told us HUD’s recent annual performance reports do not contain specific 

information required by law and that HUD has not issued other publicly 

available reports that contain the Title X reporting requirements. Title X 

requires HUD to annually provide Congress information on its progress in 

implementing the lead grant programs; a summary of studies looking at 

the incidence of lead poisoning in children living in HUD-assisted housing;

the results of any required lead technical studies; and estimates of federal 

funds spent on lead hazard evaluation and reduction in HUD-assisted 

housing.88 As previously stated, the annual performance reports have 

provided information on the number of housing units made lead-safe 

through the agency’s lead grant programs, but not through the voucher or 

public housing programs. In March 2018, Lead Office staff told us HUD 

plans to submit separate reports on the agency’s lead effort, covering the 

Title X reporting requirements, starting in fiscal year 2019. By HUD 

complying with Title X statutory reporting requirements, Congress and the 

public will be in a position to better know the progress HUD is making 

toward ensuring that housing is lead-safe.

Lead exposure can cause serious, irreversible cognitive damage that can 

impair a child for life. Through its lead grant programs and oversight of 

lead paint regulations, HUD is helping to address lead paint hazards in 

housing. However, our review identified specific areas where HUD could 

improve the effectiveness of its efforts to identify and address lead paint 

hazards and protect children in low-income housing from lifelong health 

problems:

• Documenting and evaluating grant processes. HUD could improve 

documentation for its lead grant programs’ processes by providing 

more specific direction to staff and documenting grant award 

rationale. In doing so, HUD could better ensure that grant program 

staff score grant applications consistently and appropriately and 

 

87Title X § 1061, 106 Stat. 3926 (codified at 42 U.S.C. § 4856).

88Biennial reporting requirements include reporting on HUD’s progress in implementing 

expanded lead paint hazard evaluation and reduction activities, as well as providing 

information on the effectiveness of the Lead Disclosure Rule in making the public aware of 

lead paint hazards, among other things.

Conclusions
Page 42 GAO-18-394 Lead Paint in Housing

provide greater transparency about its award decisions. Additionally, 

periodically evaluating its grant processes and procedures could help 

HUD better ensure that its lead grants reach areas most at risk for 

lead paint hazards.

• Identifying areas at risk for lead hazards. By developing specific 

time frames to finalize and incorporate the results of its model to more 

fully identify areas at risk for lead paint hazards, HUD can better 

identify and conduct outreach to at-risk localities that its lead grant 

programs have not yet reached.

• Overseeing compliance with lead paint regulations. False selfcertifications of compliance by some PHAs and other limitations in 

HUD’s compliance monitoring approach make it essential for HUD to 

develop a plan to mitigate and address limitations, as well as establish 

procedures to determine when enforcement decisions are needed. 

These actions could further strengthen HUD’s oversight and keep 

PHAs accountable for ensuring that housing units are lead-safe.

• Amending inspection standard in the voucher program. Children 

living in voucher units may receive less protection from lead paint 

hazards than children living in public housing units because HUD 

applies different lead inspection standards to the two programs. HUD 

could ensure that children in the voucher program are provided better 

protection from lead by requesting and obtaining statutory authority to 

amend the voucher program inspection standard as indicated by 

analysis of the benefits and costs of amending the standard.

• Assessing and reporting on performance. Fully incorporating key 

elements of performance assessment—by developing comprehensive 

goals, improving performance measures, and adhering to reporting 

requirements—could better enable HUD to assess its own progress 

and target its resources toward lead efforts that maximize impact. 

Additionally, HUD may be missing opportunities to inform the 

Congress and the public about how HUD’s lead efforts have helped 

reduce lead poisoning in children.

We are making the following nine recommendations to HUD:

• 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)

• The Director of HUD’s Lead Office should ensure that the office 

periodically evaluates its processes for scoring and awarding lead 

grants. (Recommendation 2)

Recommendations for 

Executive Action
Page 43 GAO-18-394 Lead Paint in Housing

• The Director of HUD’s Lead Office, in collaboration with PD&R, should 

set time frames for incorporating relevant data on lead paint hazard 

risks into the lead grant programs’ processes. (Recommendation 3)

• The Director of HUD’s Lead Office and the Assistant Secretary for PIH

should collaborate to establish a plan to mitigate and address risks 

within HUD’s lead paint compliance monitoring processes. 

(Recommendation 4)

• 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 

PHA noncompliance with lead paint regulations. (Recommendation 5)

• 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)

• 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)

• 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)

• 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)

We provided a draft of this report to HUD for review and comment. We 

also provided the relevant excerpts of the draft report to CDC and EPA for 

their review and technical comments. In written comments, reproduced in 

appendix III, HUD disagreed with one of our recommendations and 

generally agreed with the remaining eight. HUD and CDC also provided 

technical comments, which we incorporated as appropriate. EPA did not 

have any comments on the relevant excerpts of the draft report provided 

to them.

Agency Comments

and Our Evaluation
Page 44 GAO-18-394 Lead Paint in Housing

In its general comments, HUD noted that the lead grant programs and 

HUD’s compliance assistance and enforcement of lead paint regulations 

have contributed significantly to, among other things, the low prevalence 

of lead-based paint hazards in HUD-assisted housing. Further, HUD said

the lead grant programs and compliance assistance and enforcement of 

lead paint regulations have played a critical part in developing and 

maintaining the national lead-based paint safety infrastructure. HUD 

asked that this contextual information be included in the background of 

the report. The draft report included detailed information on the purpose 

and scope of HUD’s lead grant programs, two key regulations related to 

lead paint hazards, and efforts to make housing lead-safe. Furthermore, 

the draft report provided context on other federal agencies’ role in 

establishing relevant standards and guidelines for lead paint hazards. We 

made no changes in response to this comment because we did not think 

it was necessary for background purposes.

HUD disagreed with the draft report’s sixth recommendation to request 

authority from Congress to use the risk assessment inspection standard 

to identify lead paint hazards in the Housing Choice Voucher program. As 

discussed in the report, HUD’s Lead Safe Housing Rule requires a more 

stringent lead inspection standard (risk assessments) for public housing 

than for Housing Choice Voucher units, for which a weaker inspection 

standard is used (visual assessments). In its written comments, HUD said 

that before deciding whether to request the statutory authority to 

implement risk assessments for voucher units, it would need to conduct 

and evaluate the results of a statistically rigorous study on the impacts of 

requiring a lead risk assessment versus a visual assessment, such as the 

impact on leasing times and the availability of housing for low-income 

families. HUD further noted that such a study could explore whether 

alternative options to the full risk assessment standard (such as targeted 

dust sampling) could achieve similar levels of protection for children in the 

voucher program. We note that requesting and obtaining authority to

amend the standard for the Housing Choice Voucher program would not 

preclude HUD from doing such a study. We acknowledge that the results 

of such a study might support a range of options. Therefore, we revised 

our recommendation to provide HUD with greater flexibility in how it might 

amend the lead inspection standard for the voucher program based on 

consideration of not only leasing time and availability of housing, as HUD 

emphasized in its written comments, but also based on the health effects 

on children. The need for HUD to review the lead inspection standard for 

the voucher program is underscored by the greater number of households

with children served by the voucher program compared to public housing, 
Page 45 GAO-18-394 Lead Paint in Housing

as well as recent information indicating that more children with elevated 

blood lead levels are living in voucher units than in public housing. 

HUD generally agreed with our remaining eight recommendations and 

provided specific information about planned steps and other 

considerations related to implementing them. For example, in response to 

our first three recommendations on the lead grant programs, HUD 

outlined specific steps it plans to take, such as updating its guidance for 

scoring grant applications and reviewing its grant application scoring 

methods to identify potential improvements. In response to our fourth and 

fifth recommendations to the Director of HUD’s Lead Office on 

compliance monitoring and enforcement of lead paint regulations, HUD 

noted that PIH should be the primary office for these recommendations 

with the Lead Office providing support. While these recommendations 

had already recognized the need for the Lead Office to collaborate with 

PIH, we reworded them to clarify that it is not necessary for the Lead 

Office to have primary responsibility for their implementation. 

HUD generally agreed with our seventh and eighth recommendations, but 

noted some considerations for implementing them. For our seventh 

recommendation about performance goals and measures, HUD noted 

that it will re-examine the availability of information from the current 

housing databases to determine whether data on housing unit production 

can be added to the existing data collected. HUD noted if that information 

is not sufficient, it would need to obtain Office of Management and Budget 

approval and have sufficient funds for such an information technology 

project. For our eighth recommendation about evaluating the Lead Safe 

Housing and Lead Disclosure Rules, HUD noted if its own resources are 

insufficient, the time frame for implementing this recommendation may 

depend on the availability of funding for contracted resources. Finally, in 

response to our ninth recommendation, HUD said that it will draft and 

submit annual and biennial reports to the congressional authorizing and 

appropriations committees and then post the reports on the Lead Office’s 

public website. 

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of the Department of Housing and Urban 

Development, the Administrator of the Environmental Protection Agency, 

and the Secretary of Health and Human Services, and other interested 

parties. In addition, the report is available at no charge on the GAO 

website at http://www.gao.gov. 
Page 46 GAO-18-394 Lead Paint in Housing

If you or your staff have any questions about this report, please contact 

me at (202) 512-8678 or garciadiazd@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix IV.

Daniel Garcia-Diaz

Director, Financial Markets and Community Investment
Appendix I: Nonfederal Funding Sources Used 

by Selected Grantees of HUD Lead Hazard 

Control Grants

Page 47 GAO-18-394 Lead Paint in Housing

Under the Department of Housing and Urban Development’s (HUD) 

Lead-Based Paint Hazard Control and the Lead Hazard Reduction 

Demonstration grant programs, HUD competitively awards grants to state 

and local jurisdictions, as authorized by the Residential Lead-Based Paint 

Hazard Reduction Act (Title X of the Housing and Community 

Development Act of 1992).1 Title X requires each grant recipient to make 

matching contributions with state, local, and private funds (i.e., 

nonfederal) toward the total cost of activities. For the Lead-Based Paint 

Hazard Control grant and the Lead Hazard Reduction Demonstration 

grant programs, the matching contribution has been set at no less than 10

percent and 25 percent, respectively, of the total grant amount.2 For 

example, if the total grant amount is $3 million, then state or local 

jurisdictions must provide at least $300,000 and $750,000, respectively, 

for each grant program, in additional funding toward the cost of activities.3

HUD requires lead grant applicants to include information on the sources 

and amounts of grantees’ matching contributions as part of their grant 

applications.4 Additionally, Title X requires HUD to award grants in part 

based on an applicant’s ability to leverage state, local, and private funds 

to supplement the federal grant funds.5

To identify the nonfederal funding sources grantees used in the lead 

hazard control grants, we selected and reviewed the lead grant 

applications of 20 HUD grantees and interviewed representatives from 10 

 

1

See Title X § 1011 (codified as amended at 42 U.S.C. § 4852).

2

Title X, the original authorizing statute for both grant programs, requires that applicants 

provide a matching contribution “in an amount not less than 10 percent of the total grant 

amount.” 42 U.S.C. § 4852(h). The Lead Hazard Reduction Demonstration has been 

reauthorized annually through appropriations legislation. The Fiscal Year 2017 

Consolidated Appropriations Act requires applicants to this grant program to provide a 

matching contribution in “an amount not less than 25 percent of the total.” Consolidated 

Appropriations Act, 2017, Pub. L. No. 115-31, 131 Stat. 777-78 (2017). The Consolidated 

Appropriations Act 2018, Pub. L. No. 115-141, Div. L, Title II (2018), provides funds for a 

single grant program referred to as the Lead Hazard Reduction Program and does not 

specify a match requirement for the single grant program.

3

Grantees must use their matching contributions to pay for grant activities that are 

specified in HUD’s annual notices of funding for the agency’s lead grant programs. 

4

HUD staff told us that the agency had previously awarded additional points to applicants 

who contributed more than the required matching contributions in 2000 through 2011 and 

also noted that the agency is considering doing so again in future years.

5

Grantees can use nonfederal funds to satisfy the grant programs’ matching contribution 

requirements and pay for eligible grant activities that are allowable under HUD’s annual 

notices of funding availability for the its lead grant programs.

Appendix I: Nonfederal Funding Sources 

Used by Selected Grantees of HUD Lead 

Hazard Control Grants
Appendix I: Nonfederal Funding Sources Used 

by Selected Grantees of HUD Lead Hazard 

Control Grants

Page 48 GAO-18-394 Lead Paint in Housing

of these.6 We selected these grantees based on their geographic 

locations; the number of HUD lead grants they had previously received; 

experience with HUD’s lead hazard control grants; and whether they have 

received both grants from 2013 through 2017. Grantees we selected 

included entities at the state, municipality, and county levels. Information 

from our grant application reviews and interviews of grantees cannot be 

generalized to all HUD grantees.

Based on our review of the selected grant applications and interviews of 

selected grantees, we found that grantees planned to use the following 

types of nonfederal funding sources as their matching contributions to 

support their lead grants activities: 

• State and local funds. Eighteen of the 20 grantees we selected 

noted that they planned to use state or local funding sources to 

supplement HUD’s grant funds. The state and local funding sources 

included state or local general funds and local property taxes or fees.7

For example, grantees in Connecticut, Baltimore, and Philadelphia 

used state or local general funds to cover personnel and operating 

costs. Additionally, grantees in Alameda County (California), 

Hennepin County (Minnesota), Malden, St. Louis, and Winnebago 

County (Illinois) planned to use local taxes, including property taxes or 

fees, such as real estate recording and building permit fees, to cover 

some costs associated with their lead hazard control grants activities.

• Community Development Block Grant funds. Ten of the 20 

grantees we selected indicated that they planned to use Community 

Development Block Grant (CDBG) program funds to cover part of the 

costs of their lead hazard control grants.8 CDBG program funds can 

be used by states and local communities for housing; economic 

 

6

We selected 20 grantees in Alameda County, California; Atlanta, Georgia; Baltimore, 

Maryland; State of Connecticut; Cuyahoga County, Ohio; District of Columbia; Denver, 

Colorado; Hennepin County, Minnesota; Lewiston, Maine; Malden, Massachusetts; 

Memphis, Tennessee; Monroe County, New York; Philadelphia, Pennsylvania; 

Providence, Rhode Island; San Antonio, Texas; San Francisco, California; St. Louis, 

Missouri; Tucson, Arizona; State of Vermont; and Winnebago County, Illinois. 

7

A general fund is the primary fund a state or a local government uses to collect revenues 

and pay expenses that are not designated to a specific fund.

8

CDBG program funds are annually appropriated by Congress. After funds are set aside 

for special statutory purposes—the Indian Community Development Block Grant program 

and allocated insular areas—70 percent of the remaining CDBG appropriation is allocated 

to entitlement communities (generally metropolitan cities and counties) and 30 percent to 

states.
Appendix I: Nonfederal Funding Sources Used 

by Selected Grantees of HUD Lead Hazard 

Control Grants

Page 49 GAO-18-394 Lead Paint in Housing

development; neighborhood revitalization; and other community 

development activities.9 For example, grantees in Baltimore and 

Memphis noted in their grant applications that they planned to use the 

funds to cover costs related to personnel, operations, and training.

• Nongovernmental contributions or discounts. Eight of 20 grantees 

we selected stated that they anticipated some forms of 

nongovernmental contributions from nonprofit organizations or 

discounts from contractors to supplement the lead grants. For 

example, all eight grantees stated that they expected to receive 

matching contributions from nonprofit organizations.

Table 2 summarizes the nonfederal funds by source that the 20 selected 

grantees planned to use, based on our review of these grantees’ 

applications.

Table 2: Department of Housing and Urban Development (HUD) Lead Grant Programs: Selected Grantees’ Sources of 

Nonfederal Funds as Matching Contributions, 2013–2017

Fiscal year of grant 

application

State or 

local funds 

(in dollars)a

Community 

Development Block 

Grant funds (in dollars)

Nongovernmental 

contributions 

(in dollars)b

Total matching 

contribution 

(in dollars)

Number of 

applications 

selectedc

2013 493,248 1,576,304 0 2,069,552 3

2014 4,193,929 0 227,161 4,421,090 4

2015 3,299,807 1,601,355 9,489 4,910,651 3

2016 783,369 982,282 100,000 1,865,651 4

2017 1,586,513 1,267,321 1,902,594 4,756,428 6

2013–2017 (in dollars) 10,356,866 5,427,262 2,239,244 18,023,373 20

2013–2017 (as a percentage 

of total dollars)

57 30 12 100

Source: GAO analysis of selected grant applications of HUD’s lead grant programs. | GAO-18-394

Note: We selected a nonprobability sample of 20 lead grant applications from 2013 through 2017. We 

reviewed these applications and identified the sources and amounts of nonfederal funds that grantees 

had planned to use as matching contributions. The information we identified may or may not be 

representative of the actual matching contributions that grantees used for grants awarded from 2013 

through 2017. Percentages do not sum to 100 percent due to rounding.

a

The state and local funds included state or local general funds, and local property taxes or fees.

b

The nongovernmental funds included contributions from nonprofit organizations and discounts from 

contractors.

 

9

According to federal law, although CDBG is funded by federal funds, CDBG funds may 

be treated as nonfederal funds that may be used, as allowed, for another federal grant 

program. See 42 U.S.C. § 5305(a)(9); 24 C.F.R. § 570.201(g). HUD’s lead hazard control 

grant programs allow CDBG funds to be counted toward the matching contribution 

requirements. 
Appendix I: Nonfederal Funding Sources Used 

by Selected Grantees of HUD Lead Hazard 

Control Grants

Page 50 GAO-18-394 Lead Paint in Housing

c

We selected and reviewed one lead grant application each from 20 grantees in Alameda County, 

California; Atlanta, Georgia; Baltimore, Maryland; State of Connecticut; Cuyahoga County, Ohio; 

District of Columbia; Denver, Colorado; Hennepin County, Minnesota; Lewiston, Maine; Malden, 

Massachusetts; Memphis, Tennessee; Monroe County, New York; Philadelphia, Pennsylvania; 

Providence, Rhode Island; San Antonio, Texas; San Francisco, California; St. Louis, Missouri; 

Tucson, Arizona; State of Vermont; and Winnebago County, Illinois.

Furthermore, almost all of the selected grantees stated in their grant 

applications or told us that they expected to receive or have received 

other nonfederal funds in excess of their matching contributions. For 

example, 15 grantees stated that they generally required or encouraged 

property owners or landlords to contribute toward the lead hazard 

remediation costs. Also, grantees in Baltimore, District of Columbia, 

Lewiston, and Providence indicated that they expected to receive 

monetary or in-kind donations from organizations to help carry out lead 

hazard remediation, blood lead-level testing, or training. Additionally, the 

grantee in Alameda County (California) told us that they have received 

nonfederal funds from a litigation settlement with a private paint 

manufacturer. 
Appendix II: Objectives, Scope, and 

Methodology

Page 51 GAO-18-394 Lead Paint in Housing

This report examines the Department of Housing and Urban 

Development’s (HUD) efforts to (1) incorporate statutory requirements 

and other relevant federal standards in its lead grant programs; (2) 

monitor and enforce compliance with lead paint regulations for its rental 

assistance programs; (3) adopt federal health guidelines and 

environmental standards for lead hazards in its lead grant and rental 

assistance programs; and (4) measure and report on its performance 

related to making housing lead-safe.

In this report, we examine lead paint hazards in housing, and we focus on 

HUD’s lead hazard control grant programs and its two largest rental 

assistance programs that serve the most families with children: the 

Housing Choice Voucher (voucher) and public housing programs.1

To address all four objectives, we reviewed relevant laws, such as the 

Residential Lead-Based Paint Hazard Reduction Act (Title X of the 

Housing and Community Development Act of 1992, referred to as Title X 

throughout this appendix) and relevant HUD regulations, such as the 

Lead Safe Housing Rule and a January 2017 amendment to this rule.2 To 

examine trends in funding for HUD’s lead grant programs for the past 10 

years, we also reviewed HUD’s budget information for fiscal years 2008 

through 2017. We interviewed HUD staff from the Office of Lead Hazard 

Control and Healthy Homes (Lead Office), Office of Public and Indian 

Housing (PIH), Office of Policy Development and Research (PD&R), and 

other relevant HUD program and field offices. Finally, we reviewed our 

prior work and those of HUD’s Office of Inspector General.3

 

1

We did not examine lead hazards in schools, daycare centers, commercial buildings, 

water, food, or products such as toys, ceramics, or jewelry. For additional work on lead in 

water and schools, see GAO, Drinking Water: Additional Data and Statistical Analysis May 

Enhance EPA’s Oversight of the Lead and Copper Rule, GAO-17-424 (Washington, D.C.: 

Sept. 1, 2017). Additionally, we have ongoing work reviewing lead service lines and lead 

in school drinking water. 

2

See e.g. Title X; 24 C.F.R. pt. 35; Requirements for Notification, Evaluation and 

Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and 

Housing Receiving Federal Assistance, 82 Fed. Reg. 4151 (Jan. 13, 2017). We also 

reviewed relevant congressional committee reports that originally accompanied Title X, 

see ex. S. Rep. No. 102-332 (1992).

3

GAO, Department of Housing and Urban Development: Actions Needed to Incorporate 

Key Practices into Management Functions and Program Oversight, GAO-16-497 

(Washington, D.C.: July 20, 2016); and Department of Housing and Urban Development, 

Office of Inspector General, Risk Based Enforcement Could Improve Program 

Effectiveness, 2014-OE-0002 (Washington, D.C.: Feb. 12, 2016). 

Appendix II: Objectives, Scope, and 

Methodology
Appendix II: Objectives, Scope, and 

Methodology

Page 52 GAO-18-394 Lead Paint in Housing

To address the first objective, we reviewed HUD’s Notices of Funding 

Availability (funding notices), policies, and procedures to identify HUD’s 

grant award processes for the Lead-Based Paint Hazard Control grant 

and Lead Hazard Reduction Demonstration grant programs. For example, 

we reviewed HUD’s annual notices of funding availability from 2013 

through 2017 to identify HUD’s scoring factors for evaluating grant 

applications. We compared HUD’s grant award processes in 2017 with 

Title X statutory requirements, the Office of Management and Budget 

(OMB) requirements for awarding federal grants, and relevant federal 

internal control standards.4 We also interviewed HUD staff about the 

agency’s grant application review and award processes.

To determine the extent to which HUD’s grants have gone to counties in 

the United States potentially at high risk for lead paint hazards, we 

compared grantee locations from HUD’s lead grant data for grants 

awarded from 2013 through 2017 with county-level data on two indicators 

of lead paint hazard risk from the 2011–2015 American Community 

Survey—a continuous survey of households conducted by the U.S. 

Census Bureau. We analyzed HUD’s grant data to determine the number 

and dollar amount of grants received by each grantee, and the grantees’ 

addresses. We then conducted a geographic analysis to determine 

whether each HUD lead grant went to a county that met at least one, 

both, or neither of the two commonly known indicators of lead paint 

hazard risk—the age of housing and poverty level. We identified these 

two indicators through a review of relevant academic literature, agency 

research, and state lead modelling methodologies.5

We used data from the 2011–2015 American Community Survey because 

the data covered a time frame that best aligned with the 5 years of lead 

grant data (2013 through 2017). Using its county-level data, we calculated 

an estimated average percentage nationwide of housing units built before 

 

4

Title X; Office of Management and Budget, Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal Awards (codified at 2 C.F.R. pt. 200) , 

effective for grants awarded starting in December 2014; and GAO, Standards for Internal 

Control in the Federal Government, GAO-14-704G (Washington, D.C.: September 2014). 

5

For example, see Eric M. Roberts and Paul B. English, “Analysis of multiple-variable 

missing-not-at-random survey data for child lead surveillance using NHANES,” Statistics 

in Medicine 35 (November 2016); Department of Housing and Urban Development, 

American Healthy Homes Survey: Lead and Arsenic Findings, April 2011; and Washington 

State Department of Health, Division of Environmental Public Health, A Targeted 

Approach to Blood Lead Screening in Children, Washington State: 2015 Expert Panel 

Recommendations (November 2015). 
Appendix II: Objectives, Scope, and 

Methodology

Page 53 GAO-18-394 Lead Paint in Housing

1980 (56.9 percent) and an estimated average percentage nationwide of 

individuals living below the poverty level (17.5 percent). We used 1980 as 

a benchmark for age of housing because the American Community 

Survey data for age of housing is separated by the decade of construction 

and 1980 was closest in time to the 1978 federal lead paint ban. We 

categorized counties based on whether their levels of pre-1980 housing 

and poverty were above one, both, or neither of the respective national 

average percentage for each indicator.6 The estimated average 

nationwide and county-level percentages of the two indicators (e.g., older 

housing and poverty rate) are expressed as a range of values.7 For the 

lower and upper ends of the range, we generated a 95 percent 

confidence interval that was within plus or minus 20 percentage points.

We classified a county as above the estimated average percentages 

nationwide if the county’s confidence interval was higher and did not 

overlap with the nationwide estimate’s confidence interval. We omitted 

the data for 12 counties that we determined were unreliable for our 

purposes.8 We analyzed data starting in 2013 because that was the first 

year for which these grant data were available electronically. We also 

interviewed HUD staff to understand their efforts and plans to perform 

similar analyses using indicators of lead paint hazard risk. To assess the 

reliability of HUD’s grant data, we reviewed documentation of HUD’s 

grant database, interviewed Lead Office staff on the processes HUD used 

to collect and ensure the reliability of the data, and tested the data for 

missing values, outliers, and obvious errors. To assess the reliability of 

the American Community Survey data, we reviewed statistical information 

from the Census Bureau and other publicly available documentation on 

the survey and conducted electronic testing of the data. We determined 

 

6

Our analysis did not account for population, but for the purposes of awarding grants, 

population density of a jurisdiction may be one of a number of relevant factors, according 

to HUD staff. Additionally, for state government grantees (12 of them), we used address 

data provided by HUD and assigned a corresponding county. However, state government 

grantees can specify other counties within their state where lead hazard control activities 

may occur. In our analysis, we were not able to account for the actual counties of where 

state grantee lead hazard control activities took place.

7

The American Community Survey is a probability survey and only one of a large number 

of samples that might have been drawn. Because each sample could have provided 

different estimates, we express our confidence in the precision of the particular sample’s 

results as a range (i.e., the confidence interval). This range would contain the actual 

population value for 95 percent of the samples we could have drawn.

8

Specifically, the estimates for these 12 counties had margins of error greater than 20 

percent.
Appendix II: Objectives, Scope, and 

Methodology

Page 54 GAO-18-394 Lead Paint in Housing

that the HUD grant data and American Community Survey county-level 

data on age of housing and poverty were sufficiently reliable for 

identifying areas at risk of lead paint hazards and determining the extent 

to which lead grants from 2013 through 2017 have gone to at-risk areas. 

Furthermore, to obtain information about how HUD works with grantees to 

achieve program objectives, we conducted in-person site visits to five 

grantees located in five localities (Alameda County, California; Atlanta, 

Georgia; Baltimore, Maryland; District of Columbia; and San Francisco, 

California); and interviewed an additional five grantees on the telephone 

(Hennepin County, Minnesota; Lewiston, Maine; Malden, Massachusetts; 

Providence, Rhode Island; and Winnebago County, Illinois). In addition, 

we reviewed the grant applications of the 10 grantees we spoke to and an 

additional 10 grantees from 10 additional jurisdictions (State of 

Connecticut; Cuyahoga County, Ohio; Denver, Colorado; Monroe County, 

New York; Philadelphia, Pennsylvania; Memphis, Tennessee; San 

Antonio, Texas; St. Louis, Missouri; Tucson, Arizona; and State of 

Vermont).

We selected the 10 grantees for site visits or interviews based on the 

following criteria: geographic variation, number of years the grantees had 

HUD’s lead grants, and grantees that have received both types of lead 

grants from 2013 through 2017. We selected the 10 additional grantees’ 

applications for review based on geographic diversity and to achieve a 

total of two applications for each year during our 5-year time frame, with 

at least one application from each of the two HUD lead grant programs. 

As part of our review of selected grant applications, we identified 

nonfederal funding sources used by grantees, such as local tax revenues, 

contractor discounts, and property owner contributions. Information from 

the selected grantees and grant applications review cannot be 

generalized to those grantees we did not include in our review. 

Additionally, we interviewed representatives from housing organizations 

to obtain additional examples of any nonfederal funding sources, such as 

state or local bond measures, or low-interest loans to homeowners.9

To address the second objective, we also reviewed HUD guidance and 

internal memorandums related to its efforts to monitor and enforce 

compliance with lead paint regulations for public housing agencies (PHA), 

 

9

For example, we interviewed representatives from the National Center for Healthy 

Housing and the Green and Healthy Homes Initiative. 
Appendix II: Objectives, Scope, and 

Methodology

Page 55 GAO-18-394 Lead Paint in Housing

the entities that manage HUD’s voucher and public housing rental 

assistance programs.10 In addition, we reviewed HUD’s documentation of 

databases it uses to monitor compliance, including the Lead-Based Paint 

Response Tracker and the Elevated Blood Lead Level Tracker, and 

observed HUD staff’s demonstrations of these databases. HUD staff also 

provided a demonstration of the Record and Process Inspection Data 

database (known as “RAPID”) used by HUD’s Real Estate Assessment 

Center to collect physical inspection data for public housing units. We 

obtained and reviewed information from HUD about instances of potential 

noncompliance with lead paint regulations by PHAs as of November 2017 

and enforcement actions HUD has taken. We compared HUD’s regulatory 

compliance monitoring and enforcement approach to federal internal 

control standards.11 We interviewed staff from HUD’s Lead Office, Office 

of General Counsel, Office of Field Operations, and field staff, including 

four HUD regional directors in areas of the country known to have a high 

prevalence of lead paint hazards, about internal procedures for 

monitoring and enforcing compliance with lead paint regulations by the 

PHAs within their respective regions.

To address the third objective on HUD’s adoption of federal health 

guidelines and environmental standards for lead paint hazards in its lead 

grant and rental assistance programs, we reviewed relevant rules and 

HUD documentation. To identify relevant federal health guidelines and 

environmental standards, we reviewed guidelines and regulations from 

the Centers for Disease Control and Prevention (CDC) and the 

Environmental Protection Agency (EPA) and interviewed staff from each 

agency. To identify state and local laws with different requirements than 

these federal guidelines and standards, we obtained information from and 

interviewed staff from CDC’s Public Health Law Program and the National 

Conference of State Legislatures. We compared HUD’s requirements to 

CDC’s health guideline known as the “blood lead reference value” and 

EPA’s standards for lead-based paint hazards and lead-dust clearance 

 

10For example, see Department of Housing and Urban Development, Guidance on EPA’s 

Lead-Based Paint Renovation, Repair and Painting (RRP) Rule, HUD’s Lead Safe 

Housing Rule, and the EPA-HUD Lead Disclosure Rule, Notice PIH 2011-44 (HA), 

OHHLHC 2011-01 (Washington, D.C.: July 29, 2011) and Interpretative Guidance on 

HUD’s Lead Safe Housing Rule: The HUD Regulation on Controlling Lead-Based Paint 

Hazards in Housing Receiving Federal Assistance and Federally Owned Housing Being 

Sold (24 CFR Part 35), (Washington, D.C.: June 2004).

11GAO-14-704G. 
Appendix II: Objectives, Scope, and 

Methodology

Page 56 GAO-18-394 Lead Paint in Housing

standards.12 Finally, we reviewed information in HUD’s 2017 funding 

notices and lead grant programs’ policy guidance about requirements for 

grantees as they pertain to health guidelines and environmental 

standards. We also interviewed HUD staff about how HUD has used the 

findings from lead technical study grants to consider changes to HUD’s 

requirements and processes regarding identifying and addressing lead 

paint hazards for the grant programs.

To address the fourth objective, we reviewed HUD documentation related 

to performance goals and measures, program evaluations, and reporting. 

For example, we reviewed HUD’s recent annual performance reports to 

identify goals and performance measures related to HUD’s efforts to 

make housing lead-safe. Further, we reviewed Title X to identify 

requirements related to evaluating and reporting on HUD’s lead efforts. 

We reviewed program evaluations and related studies completed by 

outside experts for the lead grant programs and interviewed staff from 

one of the organizations that conducted the evaluations.13 In addition, we 

interviewed Lead Office and PD&R staff about the agency’s plans to 

evaluate the requirements in the Lead Safe Housing Rule and reviewed 

 

12Since 2012, CDC has used a health guideline (i.e., blood lead reference value) of 5 

micrograms of lead per deciliter of blood to identify children whose blood lead levels are 

much higher than most children’s levels and for whom it recommends initiation of public

health actions.

13The National Center for Health Housing and The University of Cincinnati Department of 

Environmental Health, Evaluation of the HUD Lead-Based Paint Hazard Control Grant 

Program, a final report prepared for the Department of Housing and Urban Development, 

Office of Healthy Homes and Lead Hazard Control (May 1, 2004); Sherry L. Dixon, 

Jonathan W. Wilson, Paul A. Succop, Mei Chen, Warren A. Galke, William Menrath, and 

C. Scott Clark, “Residential Dust Lead Loading Immediately After Intervention in the HUD 

Lead Hazard Control Grant Program,” Journal of Occupational and Environmental 

Hygiene, vol. 1, no. 11 (2004); Sherry L. Dixon, Jonathan W. Wilson, C. Scott Clark, 

Warren A. Galke, Paul A. Succop, and Mei Chen, “Effectiveness of lead hazard control 

interventions on dust lead loadings: Findings from the evaluation of the HUD Lead-Based 

Paint Hazard Control Grant Program,” Environmental Research, vol. 98 (2005); Jonathan

W. Wilson, Tim Pivetz, Peter Ashley, David Jacobs, Warren Strauss, John Menkedick, 

Sherry Dixon, Hsing-Chaun Tsai, Vincent Brown, Warren Friedman, Warren Galke, and 

Scott Clark, “Evaluation of HUD-funded lead hazard control treatments at 6 years postintervention,” Environmental Research, vol. 102 (2006); and Sherry Dixon, David Jacobs, 

Jonathan Wilson, Judith Akoto, Rick Nevin, and C. Scott Clark, “Window replacement and 

residential lead paint hazard control 12 years later,” Environmental Research, vol. 113 

(2012).
Appendix II: Objectives, Scope, and 

Methodology

Page 57 GAO-18-394 Lead Paint in Housing

corresponding agency documentation about these plans.14 Additionally, 

we reviewed the Lead Office’s most recent strategic plan (2009) and 

annual report (1997) on the agency’s lead efforts.15 We compared HUD’s 

use of performance goals and measures, program evaluations, and 

reporting against leading practices for assessing program performance 

and federal internal control standards.16 Finally, we interviewed staff from 

HUD to understand goals and performance measures used by the agency 

to assess their lead efforts.

We conducted this performance audit from March 2017 to June 2018 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 

14For example see Department of Housing and Urban Development, Office of the 

Secretary, Lead-Safe Homes, Lead-Free Kids Toolkit (Washington, D.C.: June 13, 2016) 

and Office of Policy Development and Research, HUD Research Roadmap: 2017 Update, 

January 2017.

15Department of Housing and Urban Development, Office of Healthy Homes and Lead 

Hazard Control, Leading Our Nation to Healthier Homes: The Healthy Homes Strategic 

Plan, July 2009 and Office of Lead Hazard Control, Moving Toward A Lead-Safe America: 

A Report to the Congress of the United States, February 1997.

16For example, see GAO, Veterans Justice Outreach Program: VA Could Improve 

Management by Establishing Performance Measures and More Fully Assessing Risks, 

GAO-16-393 (Washington, D.C.: Apr. 28, 2016); Performance Measurement and 

Evaluation: Definitions and Relationships, GAO-11-646SP (Washington, D.C.: May 2, 

2011); and GAO-14-704G. 
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 58 GAO-18-394 Lead Paint in Housing

Appendix III: Comments from the 

Department of Housing and Urban 

Development
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 59 GAO-18-394 Lead Paint in Housing
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 60 GAO-18-394 Lead Paint in Housing
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 61 GAO-18-394 Lead Paint in Housing
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 62 GAO-18-394 Lead Paint in Housing
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 63 GAO-18-394 Lead Paint in Housing
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 64 GAO-18-394 Lead Paint in Housing
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 65 GAO-18-394 Lead Paint in Housing
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 66 GAO-18-394 Lead Paint in Housing
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 67 GAO-18-394 Lead Paint in Housing

Daniel Garcia-Diaz, (202) 512-8678 or garciadiazd@gao.gov

In addition to the contact named above, John Fisher (Assistant Director), 

Beth Faraguna (Analyst in Charge), Enyinnaya David Aja, Farah 

Angersola, Carol Bray, William R. Chatlos, Anna Chung, Melinda 

Cordero, Elizabeth Dretsch, Christopher Lee, Marc Molino, Rebecca 

Parkhurst, Tovah Rom, Tyler Spunaugle, and Sonya Vartivarian made 

key contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101934)
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