ExpectMore.gov


Detailed Information on the
Native American Housing Block Grants Assessment

Program Code 10000318
Program Title Native American Housing Block Grants
Department Name Dept of Housing & Urban Develp
Agency/Bureau Name Public and Indian Housing Programs
Program Type(s) Block/Formula Grant
Assessment Year 2007
Assessment Rating Moderately Effective
Assessment Section Scores
Section Score
Program Purpose & Design 100%
Strategic Planning 75%
Program Management 100%
Program Results/Accountability 53%
Program Funding Level
(in millions)
FY2007 $624
FY2008 $630
FY2009 $627

Ongoing Program Improvement Plans

Year Began Improvement Plan Status Comments
2003

Simplify reporting requirements for grantees. HUD should re-examine the essential data needed to evaluate grantee performance and compliance with federal regulations and also give consideration to how administratively burdensome reporting requirements are on smaller tribes.

Action taken, but not completed Update actions have are being taken; revisions to reporting and planning forms are underway. Proposed IHP/APR form revisions that streamline the process are under review and shall be completed shortly.

Completed Program Improvement Plans

Year Began Improvement Plan Status Comments
2003

Look to the HOME program, which received a management score of 100 percent, for ways to effectively run a housing block grant.

Completed
2003

Develop short- and long-term, outcome-oriented performance measures that track reductions in overcrowded housing.

Completed Completed.
2003

Complete the development and implementation of performance tracking systems.

Completed HUD scheduled and funded the development of information technology systems for the block grant in 2003.

Program Performance Measures

Term Type  
Long-term Outcome

Measure: Reduce overcrowded American Indian and Alaska Native households by 10 percent by 9/30/2010, from the baseline of 47,169, which was established in 2003 by HUD and tribal officials.


Explanation:The target is to reduce overcrowding by 4,717 households by 9/30/2010, the last day of fiscal year 2010. The 4,717 figure is 10 percent of 47,169, a baseline that was established in 2003 by HUD officials and tribal representatives, who estimated the number of overcrowded households in Indian areas. This baseline was estimated at less than the Census figures for overcrowding in order to exclude those who live outside Indian areas and are, therefore, ineligible for program benefits.

Year Target Actual
2003 472 1447
2004 472 2053
2005 472 1916
2006 472 2040
2007 472 1865
2008 472
2009 472
2010 472
Annual Output

Measure: Provide assistance to 6,770 households (counting families who received a newly constructed or acquired home, or benefited from rehabilitation to an existing program-funded unit).


Explanation:The measure tracks those that have received and/or benefited form of NAHASDA assistance through activities including; housing assistance, development, housing services, housing management services and crime prevention/safety activities during the past FY.

Year Target Actual
2003 none defined 6363
2004 8655 7752
2005 6770 8433
2006 6770 7786
2007 6770 6387
2008 5930
2009 5930
Long-term/Annual Efficiency

Measure: Identify the average IHBG contribution for homeownership units built nationally, and by region


Explanation:The six program "regions," also called "areas," are defined as follows: "Eastern/Woodlands" includes Indian areas east of the Mississippi River plus those in the States of Wisconsin and Iowa; "Southern Plains" includes the Indian areas in KS, LA, MO, OK, and TX; "Northern Plains" is CO, MT, NE, ND, SD, UT, and WY; "Southwest" AZ, CA, NV, NM; "Northwest" ID, OR, and WA; and "Alaska" is a region of its own. The program office maintains averages for each region and nationally.

Year Target Actual
2005 n/a $210,280
2006 $220,794 $91,700
2007 $96,285 $71,598
2008 $101,099
2009 $106,154
Long-term/Annual Efficiency

Measure: Identify the average IHBG contribution for homeownership units acquired, by region and nationally.


Explanation:The six program "regions," also called "areas," are defined as follows: "Eastern/Woodlands" includes Indian areas east of the Mississippi River plus those in the States of Wisconsin and Iowa; "Southern Plains" includes the Indian areas in KS, LA, MO, OK, and TX; "Northern Plains" is CO, MT, NE, ND, SD, UT, and WY; "Southwest" AZ, CA, NV, NM; "Northwest" ID, OR, and WA; and "Alaska" is a region of its own. The program office maintains averages for each region and nationally.

Year Target Actual
2005 n/a $86,691
2006 $91,026 $37,425
2007 $39,296 $46,977
2008 $49,326
2009 $51,792
Long-term/Annual Efficiency

Measure: Identify the average IHBG contribution for rental units built, nationally and by region


Explanation:The six program "regions," also called "areas," are defined as follows: "Eastern/Woodlands" includes Indian areas east of the Mississippi River plus those in the States of Wisconsin and Iowa; "Southern Plains" includes the Indian areas in KS, LA, MO, OK, and TX; "Northern Plains" is CO, MT, NE, ND, SD, UT, and WY; "Southwest" AZ, CA, NV, NM; "Northwest" ID, OR, and WA; and "Alaska" is a region of its own. The program office maintains averages for each region and nationally.

Year Target Actual
2005 n/a $99,468
2006 $104,441 $103,404
2007 $108,574 $85,952
2008 $114,003
2009 $119,703
Long-term/Annual Efficiency

Measure: Identify the average IHBG contribution for rental units acquired, nationally and by region


Explanation:The six program "regions," also called "areas," are defined as follows: "Eastern/Woodlands" includes Indian areas east of the Mississippi River plus those in the States of Wisconsin and Iowa; "Southern Plains" includes the Indian areas in KS, LA, MO, OK, and TX; "Northern Plains" is CO, MT, NE, ND, SD, UT, and WY; "Southwest" AZ, CA, NV, NM; "Northwest" ID, OR, and WA; and "Alaska" is a region of its own. The program office maintains averages for each region and nationally.

Year Target Actual
2005 n/a $76,340
2006 $80,157 $88,679
2007 $93,113 $48,352
2008 $97,768
2009 $102,656

Questions/Answers (Detailed Assessment)

Section 1 - Program Purpose & Design
Number Question Answer Score
1.1

Is the program purpose clear?

Explanation: The primary objectives of the program are outlined in NAHASDA [the Native American Housing Assistance and Self-Determination Act of 1996] in Title II, Sec. 201(a), and state: (1) to assist and promote affordable housing activities to develop, maintain, and operate affordable housing in safe and healthy environments on Indian reservations and in other Indian areas for occupancy by low-income Indian families; (2) to ensure better access to private mortgage markets for Indian tribes and their members and to promote self-sufficiency of Indian tribes and their members; (3) to coordinate activities to provide housing for Indian tribes and their members with Federal, State, and local activities to further economic and community development for Indian tribes and their members; (4) to plan for and integrate infrastructure resources for Indian tribes with housing development for tribes; and (5) to promote the development of private capital markets in Indian Country and to allow such markets to operate and grow, thereby benefiting Indian communities. The eligible affordable housing activities are clearly outlined in Title II, Sec. 202. The NAHASDA Reauthorization Act of 2002 (P.L. 107-292) defined "housing related community development" as any tribally owned and operated facility, business, activity, or infrastructure that (i) is necessary to direct construction of reservation housing; and (ii) would help an Indian tribe or its tribally designated housing entity reduce the cost of construction of Indian housing or otherwise promote the findings of this Act."

Evidence: Title II of the Natve American Housing Assistance and Self-Determination Act of 1996 (NAHASDA), Sec. 201 and 202, as outlined under "Explanation."

YES 20%
1.2

Does the program address a specific and existing problem, interest, or need?

Explanation: The program addresses low-income housing needs for Native Americans. There continues to be a lack of good quality, affordable housing on tribal lands. Legal restrictions related to tribal trust lands and high unemployment rates have made it difficult to access capital from the private financial markets.

Evidence: According to a 1996 HUD/Urban Institute study, 21 percent of Native Americans living on tribal lands experience overcrowding, compared to just 3 percent of all citizens. This 1996 study continues to be used in Indian Country. US Census data from 2000 shows for American Indians and Alaska Natives alone or in combination with one or more other races, 11.3 percent live in overcrowded homes, compared to 5.7 percent of all United States citizens.

YES 20%
1.3

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: This program does not duplicate other federal, state, or local efforts. It is unique in that it provides grant dollars to tribes to determine and address affordable housing needs within their communities.

Evidence: There is no other federal, state, or local affordable housing grant program that allows tribes to determine and address their unique housing needs.

YES 20%
1.4

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The program enables tribes to determine and serve their local housing needs. Before the program's inception in 1997, affordable housing was provided through a variety of HUD programs that dictated unit counts and building types, and were generally designed to serve households in cities. Tribal interests, cultural values, and traditions were not considered in the administration of housing programs on tribal lands. The approach now is effective because tribes have the flexibility to address local housing needs, whether rural or urban, in a way that takes into consideration local customs and priorities.

Evidence: Before the program's inception, tribes received funding under a wide range of programs including U.S. Housing Act of 1937 Housing Development, Modernization, Youthbuild, HOME, Drug Elimination, other resident initiatives, and the McKinney Homeless programs. Tribes and Indian housing authorities had to compete for this funding, which made it difficult to plan for future years. Tribes had little control over the management of housing programs to fit the local needs. These earlier HUD policies and program designs that led to poor quality housing on reservations included a manufactured housing initiative in the 1980s, inappropriate cost, construction, and design guidelines for some regions of the country, and the termination of HUD housing inspections. Based on the success of the program, and the support it receives from its grantees, it is clear that this program is more effective than the previous approach.

YES 20%
1.5

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The program is the largest single source of funding for affordable housing on tribal lands. It was designed to give direct control to tribes in identifying and addressing their affordable housing needs. Projects are limited to low-income households to ensure that beneficiaries are targeted as intended.

Evidence: The program has distributed over $5.7 billion in funding to tribes or tribally designated housing entities from 1998 - 2006. Over the last 3 years (2004-2006), the program has funded the construction of more than 6,000 affordable housing units and provided housing assistance to 24,000 families.

YES 20%
Section 1 - Program Purpose & Design Score 100%
Section 2 - Strategic Planning
Number Question Answer Score
2.1

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: In the long term, the program seeks to relieve overcrowded conditions in Indian Country. It is widely recognized that overcrowding is especially prevalent and severe in Indian Country, along with the negative economic, social, and health impacts it brings about. Overcrowding in Indian Country is almost always attributable to a lack of safe, decent, affordable housing. It happens to be an almost universal concern among the program's participants because Native American cultural norms tend to encourage extended family members to move in together rather than become homeless "on the street." To relieve overcrowding, the program funds activities that will increase the suitable housing stock, including the production of new housing units through construction, acquisition, and the rehabilitation of old units. This activity supports the program's strategic goals of increasing Native American homeownership rates and promoting safe, decent, and affordable rental housing. It is anticipated that these and other program activities will, over time, reduce the rate of overcrowding, regardless of uncontrollable factors such as population growth, migration, and natural disasters.

Evidence: The program's long-term performance goal is to reduce overcrowded American Indian and Alaska Native households by 10 percent by 9/30/2010, from the baseline of 47,169, which was established in 2003 by HUD and tribal officials. Each new housing unit constructed with program funds relieves overcrowding by one household. See the Agency's Annual Performance Plans and Performance and Accountability Reports for 2004-2006.

YES 12%
2.2

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The 8-year timeframe for this long-term measure (2003-2010) was established to coincide with the decennial Census, upon which the baseline was derived. The Agency's ambitious target is to reduce overcrowding by 4,717 households by 9/30/2010, the last day of fiscal year 2010. The 4,717 figure is 10 percent of 47,169, a baseline that was established in 2003 by HUD officials and tribal representatives, who estimated the number of overcrowded households in Indian areas. This baseline was estimated at less than the Census figures for overcrowding in order to exclude those who live outside Indian areas and are, therefore, ineligible for program benefits. The ease with which this target has been met suggests that the program could increase the target or alternatively that the measure overstates the reduction in over-crowding. As more data is collected and the 2010 provides new counts of over-crowding, the program will be able to perfect the target and the measure.

Evidence: See the Agency's Annual Performance Plans and Performance and Accountability Reports for 2004-2006. As of 5/16/2007, the Agency could report 1,447 new units were built in 2003; 2,053 in 2004; 1,916 in 2005; and 2,040 in 2006. The total for 2003-2006 is 7,456 new units. Subtracting this number from the original baseline (established in 2003), leaves a new baseline in 2007 of 39,713. Therefore, the program has already exceeded its goal by 2,739 units, or 6 percent.

YES 12%
2.3

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: Two annual performance measures support the long-term goal to reduce overcrowding in Indian Country. The number of new units built and the number of American Indian and Alaska Native families receiving assistance represent two of the most important and consistent uses of program funds. They are also the most indicative of increases in affordable housing stock. "Families receiving assistance" is defined as those who received a housing unit because of construction, acquisition, or rehabilitation activities. Each new unit built alleviates overcrowding by one household. Currently, over-crowding data is only available from the decennial Census. Correlating information from the 2010 Census with the results of the program's annual measures will allow the program to align the annual measure better with the long-term outcome goal. The program also has several performance indicators that support the Agency's strategic goal to embrace high standards of ethics, management, and accountability. For example, undisbursed grant balances more than 3 years old are tracked, and average unit construction costs are tracked by region.

Evidence: The following are the program's annual performance goals for 2007 that support the long-term goal. (1) Reduce overcrowded households in Indian Country by 472. (2) Provide assistance to 6,770 households (counting families who received a newly constructed or acquired home, or benefited from rehabilitation to an existing program-funded unit). See the Agency's Annual Performance Plans and Performance and Accountability Reports for 2004-2006.

YES 12%
2.4

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The baseline for overcrowding was established in 2003 by officials from HUD and tribal representatives. This group looked at Census 2000 figures for overcrowding and then estimated what portion of that represented eligible beneficiaries living in program areas. This baseline of overcrowded Indian households was established as 47,169, in 2003. The annual target is to reduce that baseline by 472 families (or one percent of the 47,169 baseline). This annual goal (472) has been consistently exceeded. However, external factors, such as population growth, might offset gains made by the program. The long-term, net result, or the actual increase or decrease in overcrowding will be ascertained when the decennial 2010 Census is published. The baselines for numbers of housing units built, acquired, and rehabilitated are determined by accomplishment data in the Performance Tracking Database from years past (2003-2006). Accomplishments must be reported to the Chief Financial Officer and the Public and Indian Housing Budget Office soon after the close of the fiscal year, before all grantees have reported to the Agency; therefore, ambitious targets have been set at the approximate levels of accomplishment that the Performance Tracking Database reports soon after the close of the fiscal year. A few months after year-end, late entries and adjustments have consistently added some units to the final reported figures. It must be understood that this program adheres to the concept of tribal self-determination, which is enjoyed by the program's grantees, that is, federally recognized tribes. The grantees themselves??not the Agency??determine how best to use their program dollars each year, based on their local needs. Although all of the program's eligible activities support the Agency's strategic goals, specific performance targets set by the Agency are not directly imposed on grantees. In other words, the Agency cannot anticipate, with any certainty, which eligible program activities the grantees will undertake in any given year. Not all program activities are captured in the Performance Tracking Database. However, Agency officials believe that the performance indicators that are monitored (especially the number of units built, acquired, and rehabilitated) represent the most important and consistent use of program funds.

Evidence: See the Agency's Annual Performance Reports and Performance and Accountability Reports for 2003-2006. The Agency-estimated baseline of overcrowded households in Indian Country in 2003: 47,169. In 2003, 1,447 new units were built. In 2004, 2,053 new units were built. In 2005, 1,916 new units were built. In 2006, 2,040 new units were built. In 2007, the Agency-estimated baseline of overcrowded households in Indian Country is 39,713. The following are annual program performance goals for 2007: --Build 1,070 Homeownership Units. --Acquire 535 Homeownership Units. --Rehabilitate 3,745 Homeownership Units. --Build 640 Rental Units. --Acquire 155 Rental Units. --Rehabilitate 625 Rental Units. Combined, these six output measures define the annual goal to "provide assistance to 6,770 households," (counting families who received a newly constructed or acquired home, or benefited from rehabilitation to an existing program-funded unit).

YES 12%
2.5

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: Program partners are committed to reducing overcrowding in Indian Country, and, through a variety of program activities, they work toward realizing the Agency's strategic goals of increasing homeownership; promoting safe, decent, and affordable housing; strengthening communities; and embracing high standards of ethics, management, and accountability. However, grantees do not commit to specific performance targets, such as the number of housing units built. The program is designed so that tribes can practice self-determination; production targets are determined at the local level and are based on locally determined priorities. Overcrowding happens to be an almost universal concern among the program's participants because Native American cultural norms tend to encourage extended family members to move in together rather than become homeless "on the street." Tribal officials have met with Agency officials in every region to share strategies that address overcrowding. For example, five tribes from the Northern Plains region meet regularly with Agency officials and, with the help of Agency facilitators, have developed action plans to address overcrowding in their areas. These action plans are reviewed periodically at meetings where progress reports are shared. Officials from USDA, HHS, HUD, DOI, and EPA signed a Memorandum of Understanding in January 2006 to better coordinate the federal government's efforts in the delivery of infrastructure services and financial assistance in Indian Country in support of tribal communities. Facilitating the provision of infrastructure will contribute to the overall supply of safe, decent, affordable housing, which will, in turn, help to relieve overcrowding. Officials from USDA Rural Development, HUD, and BIA signed a Memorandum of Understanding in September 2004 to establish a framework for partnering among the Agencies to improve assistance to American Indians and Alaska Natives in the development and operation of affordable housing on trust or restricted lands, reservations, and in approved service areas. A workgroup consisting of Agency employees and tribal representatives meets regularly to discuss and analyze potential changes to the recipients' annual Performance Reports and Indian Housing Plans, which are used as data collection instruments.

Evidence: Grantees commit to work toward their own annual program goals, and their commitments are documented each year in their Annual Performance Plans. All eligible program activities support a strategic long-term goal, as well as one or more annual goals. The grantees' Annual Performance Reports must explain if goals were not met. See the tribal action plans to address overcrowding. See the Memorandum of Understanding, January 2006, signed by officials from USDA, HHS, HUD, DOI, and EPA. See the Memorandum of Understanding, September 2004, signed by officials from USDA, HUD, and BIA.

NO 0%
2.6

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: An independent evaluation of sufficient scope and quality has not been performed. The program, however, has contracted for an independent, comprehensive program evaluation, which is expected to be completed by August 2008. Quality Management Reviews, carried out on a regular basis by the Department, examine management procedures and processes. In addition, a cost study is soon to be completed that will provide valuable information about the cost to run Indian housing. This study includes the systematic collection of data and information on the practices, challenges, and costs of operating housing units from at least 70 tribes. The budgets and accounts of individual tribes are expected to be a major source of information in providing a true picture of operating costs. This operating cost study will produce a report, available in the summer of 2007, describing project-based operating costs.

Evidence: See the contracts securing the Indian Housing Cost Study and the comprehensive evaluation of the program.

NO 0%
2.7

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: The agency includes performance measures in its annual budget justifications. Performance accomplishments are noted and compared to the targets that were established the previous year. These "budget performance indicators" are also mirrored in the Agency's Annual Performance Plan.

Evidence: See the Performance Measurement Table from the Public and Indian Housing budget justifications for Native American Housing Block Grants, from years 2005-2008. The table for the 2008 budget year showed, as of December 2006, the planned and actual performance data for building, acquiring, or rehabilitating 5,350 homeownership units; building, acquiring, or rehabilitating 1,420 rental units; and reducing overcrowded households by 472 families.

YES 12%
2.8

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The Agency has developed an automated process for collecting and reporting program accomplishments. The Agency is currently reviewing its data collection instruments with the goals of streamlining reporting and collecting more relevant and accurate data. The Agency is researching the feasibility of using various methods to measure overcrowding and substandard housing conditions in Indian areas. The program has used regional and national conferences of grantees and other stakeholders to foster support for structured performance measurement.

Evidence: Within the last 4 years, the Agency developed its Performance Tracking Database to collect and aggregate program performance data. The Performance Tracking Database generates management reports that show progress made toward achieving program goals. Also, a workgroup consisting of Agency officials and tribal representatives met several times to evaluate the program's data collection forms (the Indian Housing Plan and the Annual Performance Report). This group has made recommendations for revisions to the forms. In addition, the Agency is working with a consultant to analyze the feasibility of using various methodologies to track overcrowding and substandard housing conditions.

YES 12%
Section 2 - Strategic Planning Score 75%
Section 3 - Program Management
Number Question Answer Score
3.1

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The Agency regularly uses data submitted by grantees to improve performance and increase accountability. The Agency is required to and does collect Annual Performance Reports from grantees. The detailed annual reports compare grantees' actual accomplishments to their Annual Performance Plans. The annual report must give reasons for slippage if established objectives were not met, and it must give analyses and explanations of cost overruns or high unit costs. The reports show how much program money the grantees spent on the various eligible activities. In addition, the reports show the number of housing units built, acquired, or rehabilitated and whether those units were intended for homeownership or rental. Agency personnel enter data from the Annual Performance Reports into the Performance Tracking Database. Aggregated data is provided to program managers on at least a monthly basis.

Evidence: See the program regulations at 24 CFR §§1000.512, 1000.514, 1000.516, and 1000.518. Grantees commit to work toward annual program goals, and their commitments are documented each year in their Annual Performance Plans. All eligible program activities support a strategic long-term goal, as well as one or more annual goals. The grantees' Annual Performance Reports must explain if goals were not met.

YES 11%
3.2

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Program grantees are held accountable when they are not in compliance with reporting requirements, when funds are misused, or if they do not make adequate progress in correcting regulatory or statuory findings. The Agency's Grants Evaluation Division regularly monitors grantees' accomplishments and these monitoring efforts sometimes result in enforcement actions. However, the Agency attempts to correct most grantees' deficiencies as soon as they are discovered, by providing technical assistance and advice to correct the problems. Program managers at the national office, and at each of six regional offices are subject to rigorous and continuous evaluation through the agency's Performance Accountability and Communication System. This system electronically tracks managers' performance on and accomplishments of a series of critical job elements over time. Integrated into these critical job elements are the annual performance goals and targets, which also support the Department's broader strategic goals. The Performance Tracking Database is updated monthly, and accomplishments, by region, are disseminated to managers. Supervisors review and evaluate their subordinates' progress toward their completion of targets at 6-month intervals, and rate them annually according to the successful completion of regional and national goals.

Evidence: The remedies process is used to address circumstances in which recipients fail to take actions to address or resolve identified noncompliance with statutory or regulatory requirements. Such actions are taken when grant recipients are unwilling or unable to implement remedial or corrective actions recommended by the Agency in a timely manner. Before remedies are imposed, grantees are sent, first, a Letter of Warning, then a Notice of Intent to Impose Remedies. If problems still exist, an Imposition of Remedies Letter is sent, which describes remedies the Agency intends to take and information on the grantee's right to a hearing before an Administrative Law Judge. In 2006, 86 Letters of Warning were issued, 19 Notices of Intent to Impose Remedies were issued, but no remedies were imposed. In 2005, 67 Letters of Warning were issued, 3 Notices of Intent to Impose Remedies were issued, and 3 remedies were imposed. Over the life of the program (since 1998), there have been 144 Enforcement Actions initiated and 22 Impositions of Remedies issued. Of the 22 Impositions of Remedies, all but 7 were resolved without imposing remedies. In addition, settlements or voluntary agreements were reached with eight grantees to avoid remedies. Remedies typically include the adjustment, reduction, or withdrawal of future grant amounts. As a part of the Agency's monitoring activities, there are times when expenditures are questioned and in some cases, determined to be ineligible due to statutory or regulatory violations. Recent examples of this are as follows: A tribe in the Northwest was questioned on costs due primarily to construction change orders that could not be supported. The tribe paid back the $1.6 million by having grant funds reduced over a 3-year timeframe. Another tribe, also in the Northwest, was questioned on costs due to unallowable entertainment, unsupported travel, and unallowable stipends. The tribe remitted $425,256 to the Agency to repay the questioned costs. A tribe in Oklahoma was questioned on costs of over $11 million related to missing financial documents, including books of account, bank statements, and audits. The Agency was about to impose sanctions, but as a result of negotiations between the tribe and the Agency, the tribe recently agreed to assign housing activities to a designated entity and will repay all ineligible and/or unsupported costs from future grants. This arrangement will ensure that there is continuous housing service for low-income tribal members. A forensic audit is being conducted of the tribe's housing records to determine the exact amount to be repaid. See the annual and mid-year staff evaluations, stored electronically in the Performance Accountability and Communication System. See the monthly reports, by region, and nationally, of the Performance Tracking Database. Supervisors review and evaluate their subordinates' progress toward their completion of targerts at 6-month intervals, and rate them annually according to the successful completion of regional and national goals.

YES 11%
3.3

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: Program funds are obligated in a timely manner. The rate of spending matches or exceeds that of other programs that include housing construction among the eligible activities.

Evidence: On average, program funds spend out over 4 years, which is a realistic rate for a program that supports new construction. At the beginning of FY 2005, this program had $285.8 million in undisbursed funds from program years 1998 through 2002. By the end of FY 2005, this balance had been reduced by 50 percent. At the beginning of FY 2006, this program had $260.2 million in undisbursed funds from program years 1998 through 2003. By the end of FY 2006, this balance had been reduced by 29 percent. At the beginning of FY 2007, this program had $183.8 million in undisbursed funds from program years 1998 through 2004. (FY 2007 reduction has not yet been calculated.) The amount of undisbursed funds more than 2 years old, measured at the beginning of each fiscal year, has declined steadily since 2005, indicating that grantees are making progress toward more timely obligations of funds.

YES 11%
3.4

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: Program execution is continuously made more efficient and effective by the procedures and processes practiced by the Agency and by the program grantees. For example, the agency as well as the program grantees practice competitive sourcing in procurement activities. The agency developed and has distributed a self-monitoring guidebook for grantees and provides classroom training on self-monitoring. The Agency issues Total Development Cost limits annually to ensure that modest housing is constructed with program funds, and adherence to these limits is monitored. The Agency works consistently with contractors and grantees to improve its Performance Tracking Database. The Annual Performance Report form and the Indian Housing Plan form are being revised in coordination with tribal representatives in order that more meaningful data is provided to track program performance. The Agency is also evaluating its current IT systems with a goal of modernizing and standardizing them all. The program's efficiency measure tracks the average cost of housing units built and acquired with program funds, by region. (The six program "regions," also called "areas," are defined as follows: "Eastern/Woodlands" includes Indian areas east of the Mississippi River plus those in the States of Wisconsin and Iowa; "Southern Plains" includes the Indian areas in KS, LA, MO, OK, and TX; "Northern Plains" is CO, MT, NE, ND, SD, UT, and WY; "Southwest" AZ, CA, NV, NM; "Northwest" ID, OR, and WA; and "Alaska" is a region of its own.) The "average costs-per-unit" are also broken down by whether the units are for homeownership or rental.

Evidence: See the Agency Notice 2006-17, issued April 17, 2006, "Total Development Costs for Affordable Housing." See the Agency's Self-Monitoring Handbook. See the drafts of the two revised data collection forms, the Indian Housing Plan and the Annual Performance Report. Federal regulations at 24 CFR part 85 and 24 CFR 1000.26 require grantees to follow competitive sourcing rules. The Performance Tracking Database collects the costs of housing units built and acquired with program funds, and tracks the average costs of those units, by region. The data is further broken down between rental units and homeownership units. This average cost-per-unit information is provided to program managers for trends analysis. Also, the Agency has funded a study (substantially completed in March 2007) to examine the real cost of operating housing in Indian Country. This study will include the systematic collection of data and information on the practices, challenges, and costs of operating housing units from at least 70 tribes. The budgets and accounts of individual tribes are expected to be a major source of information in providing a true picture of operating costs. This operating cost study will produce a report in April 2007 describing project-based operating costs.

YES 11%
3.5

Does the program collaborate and coordinate effectively with related programs?

Explanation: The Agency and tribal entities collaborate effectively with related federal programs and local programs. On a national level, the Agency has initiated a Memorandum of Understanding with the Environmental Protection Agency, signed in January 2006, regarding the "delivery of infrastructure services and financial assistance in Indian Country in support of tribal communities." In addition to HUD and EPA, the Departments of Agriculture, Health and Human Services, and Interior have executed this agreement. The parties have committed to better coordination, a better understanding of each other's programs as they relate to housing and infrastructure efforts, enhancing the leveraging of funds, and facilitating exchange of data. The Internal Revenue Service and the Agency signed a Memorandum of Understanding to coordinate and encourage outreach and training on Earned Income Tax Credits to the residents of Public and Indian housing. In September 2004, a Memorandum of Understanding was signed by officials from USDA, HUD, and DOI's BIA. This memorandum established a partnership among the three agencies to increase homeownership in Indian Country. The agencies agreed to work together and with tribes, tribally designated housing entities, and other resource providers to assist tribes in the development of affordable housing. The agencies agreed to increase communication with one another through meetings at the local, regional, and national level to discuss policy issues, programs, and budgets that impact the goals of the memorandum. The Agency sponsors meetings and activities to coordinate efforts related to mold prevention. Involved in this effort are tribes, the Indian Health Service, USDA, BIA, EPA, and various offices within HUD. Locally, tribes and their designated housing entities work with private lenders and agency staff on expanding participation in the home loan programs. Tribes coordinate locally with the Indian Health Service for water and sewer needs, and with the BIA on roads. Here are some examples of the results of successful collaboration: Sicangu Wicoti Awanyakape, Inc., the designated housing entity of the Rosebud Sioux of South Dakota, collaborated with Habitat for Humanity to construct new homes on the Rosebud Reservation. Sicangu has contributed program funds through a Memorandum of Agreement with Habitat for Humanities since 2004. Sicangu has a Memorandum of Agreement with two non-profit shelters, the White Buffalo Calf Woman's Society and Watchful Homes; both provide shelter for domestic violence victims. Sicangu has collaborated with the Boys and Girls Club by providing $100,000 in its 2005 Indian Housing Plan to be used for club activities. The Agency's Alaska Office of Native American Programs has a Memorandum of Understanding with more than 20 state and federal agencies under the auspices of the Denali Commission. The Memorandum implements the Commission's specific purpose, "to deliver the services of the Federal Government in the most cost-effective manner possible." The agencies work together to eliminate duplication, share resources, and bring a "best practices" approach to program delivery. The Agency's Administrator of Native American programs in Alaska is a member of the Commission's Housing and Infrastructure Workgroup. The group works to coordinate the development of housing and infrastructure necessary to support housing, including roads, power, solid waste, water and sewer. The Agency's Alaska Office created a team of state and federal agencies including the BIA, the Bureau of Land Management, the Federal Townsite Trustee, the Alaska Native Tribal Health Consortium, and the Alaska Department of Commerce to develop site control training for program recipients. The goal is for tribes to be better able to access and attract additional private and public resources as leverage for construction. Many more examples of effective collaboration exist and are available upon request.

Evidence: See the Memorandum of Understanding, dated Janaury 2006, between HUD, EPA, USDA, HHS, and DOI regarding infrastructure development. Facilitating the provision of infrastructure will contribute to the overall supply of safe, decent, affordable housing, which will, in turn, help to relieve overcrowding. See the Memorandum of Understanding between HUD and the Internal Revenue Service regarding Earned Income Tax Credits. See the Memorandum of Understanding, dated September 2004, signed by HUD, USDA, and the Bureau of Indian Affairs related to affordable housing and Title Status Reports.

YES 11%
3.6

Does the program use strong financial management practices?

Explanation: Under program regulation, grantees are required to establish and maintain sound financial management systems according to OMB Circular A-87 and obtain audits according to A-133. Financial management systems are reviewed during on-site monitoring by Agency staff.

Evidence: The HUD Office of Inspector General, in an August 2001 report (2001-SE-107-0002), found some financial management weaknesses within the program. The Agency has corrected all of the weaknesses identified in that report.

YES 11%
3.7

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The Agency is currently reviewing the accuracy of grantee performance data and developing a consistent process for collecting and reporting this data in the future. Program managers communicate continuously with one another to share best management practices. Agency officials have stressed the importance of accurate and timely reporting to grantees at recent consultations. Also, a workgroup consisting of Agency officials and tribal representatives met several times to evaluate the program's data collection forms (the Indian Housing Plan form and the Annual Performance Report form). This group has made recommendations for revisions to the forms.

Evidence: See the drafts of the revised data collection forms (the Indian Housing Plan form and the Annual Performance Report form). In late 2004, the Agency established and staffed the Office of Performance and Planning that oversees performance measurement and reporting efforts. Six Departmental Quality Management Reviews were performed in 2005 and 2006--one for each field office--to evaluate effectiveness and efficiencies of the program's field offices' processes and procedures. Within the last 4 years, the Agency developed its Performance Tracking Database to collect and aggregate program performance data. The Performance Tracking Database generates management reports that show progress made toward achieving program goals.

YES 11%
3.BF1

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The program has several levels of oversight that provide information about grantee activities. An annual compliance assessment is a requirement of all grantees (24 CFR 1000.502) and results are reported in the Annual Performance Reports. The Agency maintains a monitoring schedule, based on annual risk assessments that identify higher risk grantees. The Agency reviews data on funds received and disbursed quarterly through receipt of the Federal Cash Transaction Report (form HUD-272-I), and reports from the accounting system are reviewed monthly to monitor drawdown and disbursement activity and provide technical assistance to grantees. The Performance Tracking Database tracks audits, Releases of Funds, amendments, pre-award conditions, and close-out activity. Grantees that are subject to Circular A-133 audit requirements are responsible for resolving audit findings. The Agency reviews Annual Performance Reports to determine if goals established in the Indian Housing Plan are being achieved. On-site and remote grantee monitoring reports are issued with findings and corrective actions. Non-responses may lead to enforcement actions. In general, grantees that receive $10 million or more annually are monitored on an annual basis, grantees receiving between $500,000 and $10 million annually are monitored every 3 years, and grantees receiving less than $500,000 annually are selected for review on a random basis. In addition, a grantee may be monitored on-site or remotely in response to complaints or other issues of concern that arise unexpectedly. The Agency issues letters of warning to grantees for lack of administrative capacity (not resolving monitoring findings), late submission of audits, and late submission of annual performance reports. Notices of Intent to Impose Remedies are issued to grantees for nonsubmission of audits and annual performance reports. Remedies are imposed on grantees that fail to comply with audit and reporting requirements.

Evidence: An annual compliance assessment is a requirement of all grantees (24 CFR 1000.502) and results are reported in the Annual Performance Reports. The Agency maintains a monitoring schedule, based on annual risk assessments that identify higher risk grantees. The annual monitoring schedule is developed based upon an annual risk assessment of each grantee. The Risk Assessment for 2006 focused on annual grant amounts, disbursed amounts, time since last monitoring visit, status of audits and audit findings, open monitoring findings, delinquent reports, self-monitoring, inspection activities, and preservation of older housing units built under the 1937 Housing Act. In 2005, the Agency conducted 70 on-site reviews. In 2006, the Agency conducted 58 on-site reviews. In 2005, 67 letters of warning were issued; 3 notices of intent to impose remedies were issued; and 2 grantees had remedies imposed. In 2006, 86 letters of warning were issued; 19 notices of intent to impose remedies were issued; however, in 2006, no grantees had remedies imposed. Over the life of the program (since 1998), there have been 144 Enforcement Actions initiated and 22 Impositions of Remedies issued. Of the 22 Impositions of Remedies, all but 7 were resolved without taking sanctions (imposing remedies). In addition, settlements or voluntary agreements were reached with eight grantees to avoid sanctions.

YES 11%
3.BF2

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: An Agency website lists the program's annual performance indicators and the related accomplishments for 2005 and 2006. Another website offers success stories from around Indian Country, offering encouraging narratives and some photographs of completed projects. An Agency website posts recent monitoring reports and the schedule for upcoming monitoring reviews. The monitoring reports list findings and required corrective actions. In addition, grantees make their annual performance reports available to tribal members and other citizens living in their Indian areas, in sufficient time to permit comment before submission of the report to the Agency. All grantee reporting is public information.

Evidence: See the program regulations at 24 CFR §§1000.512, 1000.514, 1000.516, and 1000.518. http://www.hud.gov/offices/pih/ih/grants/oversight.cfm http://www.hud.gov/offices/pih/ih/codetalk/onap/success.cfm http://www.hud.gov/offices/pih/ih/codetalk/onap/accomplishments.cfm#top

YES 11%
Section 3 - Program Management Score 100%
Section 4 - Program Results/Accountability
Number Question Answer Score
4.1

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: Excellent progress has been demonstrated toward reducing overcrowded households in Indian Country. The evidence shows that the program has had demonstrable positive effects on the amount and quality of housing stock. New units have been built and acquired, and old units have been rehabilitated. Because the program is the main source of housing assistance funds for most tribes, it can be reasonably assumed that, without the program funding, most of the reported accomplishments would not have been realized. As of May 2007, the Performance Tracking Database shows that, from the program's first year in FY 1998, through FY 2006, more than 12,600 new housing units were built--an average of about 1,400 new units per year. The ease with which this target has been reached suggests that the program could increase the target, or alternatively, that the measure overstates the reduction in over-crowding. As more data is collected and the 2010 provides new counts of over-crowding, the program will be able to perfect the target and the measure.

Evidence: See the Agency's Annual Performance Plans and Performance and Accountability Reports for 2004-2006. See the Office of Native American Programs' performance guidebooks for FYs 2003 - 2007. The 2003 Agency-estimated baseline of overcrowded households in Indian Country: 47,169. May 2007 Agency-estimated baseline of overcrowded households in Indian Country: 39,713.

YES 20%
4.2

Does the program (including program partners) achieve its annual performance goals?

Explanation: The program largely achieves its annual performance goals. Since FY 2004, all targets for construction and rehabilitation have been achieved or exceeded. In FY 2004, rental acquistions reached 87 percent of the target, and homeownership acquisitions reached 84 percent of the target. In FY 2005, rental acquisitions reached 74 percent of the target; homeownership acquisitions reached 51 percent of the target. When analyzing program accomplishments, it must be understood that this program adheres to the concept of tribal self-determination, which is enjoyed by the program's grantees, that is, federally recognized tribes. The grantees themselves??not the Agency??determine how best to use their program dollars each year, based on their local needs. Although all of the program's eligible activities support the Agency's strategic goals, specific performance targets set by the Agency are not directly imposed on grantees. In other words, the Agency cannot anticipate, with any certainty, which eligible program activities the grantees will undertake in any given year. Accomplishment levels in each category can vary a good deal from year-to-year.

Evidence: See the Agency's Annual Performance Plans and Performance and Accountability Reports for 2004-2006.

LARGE EXTENT 13%
4.3

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The program has created several efficiency measures. Because this is a recent development, little actual data has been collected. Results thus far have been mixed and wide variances from year to year and relative to targets suggest the measures need refinement. A recently launched cost study will contribute to this objective. With each year, the program expects to perfect the measures and set ambitious goals for improvement. The Performance Tracking Database collects the costs of housing units built and acquired with program funds, and tracks the average costs of those units, by region. The data is further broken down between rental units and homeownership units. This average cost-per-unit information is provided to program managers for trends analysis. The six program "regions," also called "areas," are defined as follows: "Eastern/Woodlands" includes Indian areas east of the Mississippi River plus those in the States of Wisconsin and Iowa; "Southern Plains" includes the Indian areas in KS, LA, MO, OK, and TX; "Northern Plains" is CO, MT, NE, ND, SD, UT, and WY; "Southwest" AZ, CA, NV, NM; "Northwest" ID, OR, and WA; and "Alaska" is a region of its own. Also, the Agency has funded a study to examine the real cost of operating housing in Indian Country. This study will include the systematic collection of data and information on the practices, challenges, and costs of operating housing units from at least 70 tribes. The budgets and accounts of individual tribes are expected to be a major source of information in providing a true picture of operating costs. This operating cost study will produce a report in the summer of 2007 describing project-based operating costs. Undisbursed grant balances more than 3 years old are also tracked in the Performance Tracking Database to alert managers that grantees might not be spending grant funds timely. Over the last 3 years, these undisbursed balances have consistently been addressed by management, and substantially reduced each year.

Evidence: See efficiency measure data in Performance Measures section.

NO 0%
4.4

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: This program compares favorably to other housing assistance programs that benefit Native Americans. In most cases, the program is the main source of funds for tribal housing programs; however, it is usually not the only source. The program integrates easily and well into tribes' overall housing assistance strategies, which often include assistance from rural housing programs administered by the US Department of Agriculture, and the Home Improvement Program, administered by the Bureau of Indian Affairs. The program encourages grantees to leverage grant monies to secure other sources of funding, public and private, including the use of low-income housing tax credits. It also encourages each grantee to strategically plan for its unique needs, and ensures that tribes have the authority to determine for themselves which eligible program activities they will pursue.

Evidence: Annual Indian Housing Plans and Annual Performance Reports from program grantees consistently show that the program's funds are the mainstay of comprehensive Indian housing programs. The program's funds are often leveraged to secure additional monies; however, the block grant itself is almost always the primary resource from which all Indian housing assistance activities are based.

YES 20%
4.5

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: An independent evaluation of the sufficient scope and quality has not been performed. The Agency in March 2007, however, awarded a contract for an independent, comprehensive program evaluation. The evaluation will be complete by August 2008. Also, the Agency has funded a study to examine the real cost of operating housing in Indian Country. This study will include the systematic collection of data and information on the practices, challenges, and costs of operating housing units from at least 70 tribes. The budgets and accounts of individual tribes are expected to be a major source of information in providing a true picture of operating costs. This operating cost study will produce a report in June 2007 describing project-based operating costs.

Evidence: See the contracts for the Indian Housing Cost Study and the comprehensive evaluation of the program.

NO 0%
Section 4 - Program Results/Accountability Score 53%


Last updated: 09062008.2007SPR