    HUD Inspections: Steps Needed to Address Uncertainty in Inspection Scores
    (Letter Report, 11/08/2000, GAO/GAO-01-109).

    The Department of Housing and Urban Development (HUD) created the Real
    Estate Assessment Center (REAC) to conduct physical inspections of HUD's
    public and multifamily housing properties to determine whether the
    properties are safe, decent, and in good repair. Although REAC uses
    sampling to select units and buildings for inspection, it did not, at
    the time of GAO's review, routinely calculate the sampling error
    associated with the physical condition score assigned to each property.
    Under REAC's sampling procedure, buildings and units do not always have
    the same chance of being included in the inspection sample. REAC
    officials told GAO that they were introducing new sampling procedures
    that would nearly equalize the chance that each property's dwelling
    units would be selected. The actions that HUD is proposing should
    address that. GAO's concerns about HUD's sampling procedures.

    --------------------------- Indexing Terms -----------------------------

     REPORTNUM:  GAO-01-109
         TITLE:  HUD Inspections: Steps Needed to Address Uncertainty in
    	     Inspection Scores
          DATE:  11/08/2000
       SUBJECT:  Public housing
    	     Data integrity
    	     Housing programs
    	     Rental housing
    	     Building inspection
    	     Building codes
    	     Quality assurance
    	     Statistical data
    	     Statistical methods

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    GAO-01-109

    A

    Report to the Secretary of Housing and Urban Development

    November 2000 HUD INSPECTIONS Steps Needed to Address Uncertainty in
    Inspection Scores

    GAO- 01- 109

    Lett er

    November 8, 2000 The Honorable Andrew M. Cuomo The Secretary of Housing and

    Urban Development Dear Mr. Secretary: In 1997, the Department of Housing and
    Urban Development (HUD) created the Real Estate Assessment Center (REAC) to,
    among other things, administer physical inspections of HUD's public and
    multifamily housing properties. REAC's new inspection system uses data
    gathered by inspectors to calculate scores that measure the physical
    condition of HUD's properties- that is, the extent to which the properties
    are safe, decent, and in good repair. REAC then uses these scores, which
    range from 0 to 100, to determine what follow- up is needed to address the
    problems identified

    during the inspections. Soon, REAC will also use these scores to determine
    when properties should be reinspected. The new system does not require the
    inspection of all units and buildings within each property because HUD's
    housing inventory is large and its resources for inspections are limited;
    instead, for most properties, the system provides for inspecting samples of
    units and buildings. Sampling introduces a degree of uncertainty, called
    sampling error, which statisticians commonly express as a range associated
    with numerical results, such as REAC's property inspection scores. Sampling
    error is a routine and accepted outcome of sampling.

    We reported on various aspects of REAC's physical inspection program in July
    2000. 1 Although we found that REAC's system improved on HUD's previous
    inspection systems, we also found that weaknesses in the system's quality
    assurance procedures limited REAC's effectiveness in ensuring the
    reliability of the inspections. We also found some sampling and statistical
    issues that affect the reliability of the inspection scores. As agreed with
    the requesters of our July report, we are transmitting this report to you on
    the impact of sampling on inspection scores. Specifically,

    this report examines (1) how REAC accounts for sampling error when
    calculating and reporting inspection scores and (2) whether the formula

    1 HUD Housing Portfolios: HUD Has Strengthened Physical Inspections but
    Needs to Resolve Concerns About Their Reliability (GAO/ RCED- 00- 168, July
    25, 2000).

    that REAC uses to calculate inspection scores is consistent with the
    sampling procedures it uses to select buildings and units.

    Results in Brief Although REAC uses sampling to select units and buildings
    for inspection, it did not, at the time of our review, routinely calculate
    the sampling error associated with the physical condition score assigned to
    each property. REAC did, however, study the effects of sampling for about
    8,800 out of 40, 000 properties. Our analysis of these data indicates that
    the sampling error for about 71 percent of the properties was 3 or fewer
    points, but for less than 1 percent of the properties, it was much higher-
    from 8 to 19 points. Further analysis identified instances when the sampling
    error was great enough to create uncertainty about whether the properties'
    inspection scores fell above or below the administrative thresholds that HUD
    uses to determine what follow- up actions its field offices should take or
    when the property should be reinspected. For example, we found such

    uncertainty associated with about 8 percent of the multifamily properties
    whose inspection scores we analyzed. HUD recently agreed to take actions to
    address our concerns about its treatment of sampling error. These actions
    include routinely calculating the sampling error for each inspection score
    and revising the procedures for determining what key follow- up actions are
    needed when the sampling error would otherwise create

    uncertainty about the appropriate action for the property. When implemented,
    these actions should address our basic concerns.

    Under the sampling procedure that REAC uses as part of its physical
    inspection process, buildings and units do not always have the same chance
    of being included in an inspection sample. This sampling procedure is
    acceptable, but the formula REAC uses to calculate inspection scores is not
    consistent with the procedure. As a result, some inspection scores are

    inaccurate. According to REAC's analysis of data for about 5,000 properties,
    correcting the formula to account for the probability of units' and
    buildings' inclusion in a sample changed the scores of about 30 percent

    of the properties inspected. For most of the properties whose scores
    changed, the change was minimal; however, for about 1.4 percent of the
    properties, the scores changed by 4 to 9 points- enough, potentially, to
    affect REAC's decisions about the type of follow- up and the frequency of
    reinspection. HUD's plans for changing its sampling and scoring processes
    should, when implemented, address our concerns.

    Background To ensure that families living in rental housing that is owned,
    insured, or subsidized by HUD have decent, safe, and sanitary
    accommodations, REAC

    conducts annual inspections of public housing and multifamily properties.
    For its first round (or baseline) of inspections, REAC inspected over 3,100
    public housing authorities with 13, 607 properties and 26, 528 privately
    owned multifamily properties- a total of 40,135 properties. Public housing
    serves low- income families, the elderly, and persons with disabilities and
    is operated by public housing authorities using funds provided by HUD.
    Privately owned multifamily housing includes properties that receive some
    form of rental assistance, including Section 8 assistance, from HUD;
    properties whose mortgages are insured or held by HUD; and properties that
    are financed by HUD. 2

    During an inspection, an inspector enters observations into a hand- held
    computer and then electronically submits the data to REAC for verification
    and calculation of a score ranging from 0 to 100. Using this scoring range,
    HUD establishes administrative thresholds to determine what follow- up
    actions its field offices need to take and how soon the properties need to
    be reinspected. The thresholds for multifamily and public housing properties
    differ somewhat. Multifamily properties with scores below 60 are subject

    to greater follow- up requirements than properties with scores of 60 or
    higher, and properties with scores of 30 or below are referred to the
    Departmental Enforcement Center. Furthermore, multifamily properties that
    score below a certain threshold will be reinspected annually, whereas
    properties with higher scores will be reinspected less frequently. In
    November 2000, HUD expects to issue a final rule with the thresholds for
    reinspections of multifamily properties.

    The follow- up requirements for public housing are more complex. A public
    housing authority receives a physical condition score for each of its public
    housing properties. The properties' scores are then combined into an overall
    indicator of the physical condition of the housing authority's properties.
    The indicator for physical condition is then combined with three other
    indicators, derived from assessments of the housing authority's financial
    health, management operations, and residents' satisfaction, to arrive at an
    overall score for the housing authority. Starting June 30, 2000,

    2 Currently, HUD inspects housing that receives Section 8 project- based
    assistance (“ projectbased” assistance is attached to the
    structure, whereas “tenant- based” assistance is attached to the
    resident).

    HUD's policy has been to use this overall score to determine what followup
    actions its field offices need to take, as well as how soon the housing
    authority's properties should be reinspected. (Previously, HUD treated the
    scores for public housing authorities as advisory- i. e., nonbinding. 3 )
    When

    a housing authority receives an overall score below 70, HUD will generally
    require it to develop a formal improvement plan, and when an authority
    receives an overall score below 60, HUD will designate it as
    “troubled” and refer it to the Troubled Agency Recovery Center.
    Conversely, when a housing authority receives an overall score of at least
    90, it may be designated as a “high performer.” High- performing
    housing authorities that also receive a physical condition score of at least
    90 will be reinspected every other year, rather than annually. The purpose
    of the thresholds for both multifamily and public housing is to allow HUD to
    concentrate its monitoring resources on properties with lower scores.

    Most physical inspection scores are based on inspections that cover a sample
    of units or buildings. The results for the sample of units or buildings are
    then used to estimate a score that represents the condition of the entire
    property. REAC's protocol requires inspectors to inspect a statistical
    sample of units or buildings. HUD officials told us that sampling was the
    most cost- effective way to ensure that all properties get inspected.
    However, sampling introduces some uncertainty into the final inspection
    score. This uncertainty, or lack of precision, can be estimated using a
    measure called sampling error. Because REAC employs a sampling procedure
    (called probability sampling) to select the sample of units and buildings
    used to estimate a

    property's physical condition score, each property's estimated score has a
    measurable precision, or sampling error, which may be expressed as a plus/
    minus figure. A sampling error indicates how closely HUD can reproduce from
    a sample the score that HUD would have obtained if all units and buildings
    at the property had been inspected. By adding the sampling error to and
    subtracting it from the estimate, HUD can develop upper and lower bounds for
    each property's estimated physical condition score. This range is called a
    confidence interval. Sampling errors and confidence intervals are stated at
    a certain confidence level- for example, 95 percent. A confidence interval,
    at the 95- percent confidence level, means

    3 Prior to June 30, 2000, HUD reported the scores to housing authorities for
    informational purposes, requiring only that they correct any life-
    threatening health and safety violations found during inspections.

    that in 95 out of 100 instances, the sampling procedures that REAC used
    would produce a confidence interval containing the physical condition score
    that would have been obtained if all units and buildings at the property had
    been inspected.

    Sampling Leads to Nearly all of the properties that HUD inspects using the
    new physical Uncertainty About

    inspection protocol are subject to a sampling of units, and a much smaller
    percentage are subject to a sampling of buildings. However, we found that,
    Follow- up

    in its baseline inspections, HUD did not routinely estimate or consider the
    Requirements

    sampling error for each score. Using the information that REAC provided for
    a subset of inspected properties, we found that the sampling error was
    generally no more than 3 points, but for less than 1 percent of the
    properties, it was much higher- from 8 to 19 points. As a result, sampling
    caused some uncertainty about the appropriate type of follow- up required
    for some properties.

    Sampling Error Varies Under its new physical inspection protocol, HUD
    inspects a sample of units Widely for about 95 percent of the 40, 000
    properties it inspects, and for about 20 percent of the properties, it
    inspects a sample of buildings. We asked REAC

    for information on the sampling error of the physical condition scores it
    had estimated for inspected properties. REAC provided us with the data it
    had used to study the effects of its current sampling procedures on 8,813
    properties- 6,291 multifamily and 2, 522 public housing properties. 4 Using
    REAC's information, we computed the sampling error for these properties. We
    determined that the sampling error was 3 or fewer points for about 70
    percent of the 8,813 properties. However, the sampling error varied widely-
    from 0 to 19 points- as shown in table 1.

    4 HUD's current sampling procedures require the inspection of no more than
    27 units, when dwelling units are sampled, and no more than 27 buildings
    with dwelling units, when buildings are sampled. The actual number of units
    and buildings sampled depends on the number of units and buildings in the
    property. For example, any property with more than 1, 461 units would have
    27 units sampled for inspection.

    Table 1: Sampling Error for 8,813 Physical Inspection Scores

    Sampling error in points

    Cumulative Sampling error of score Frequency Percent percent

    0 1, 884 21. 4% 21.4% 1 1, 497 17. 0% 38.4% 2 1, 543 17. 5% 55.9% 3 1, 341
    15. 2% 71.1% 4 1, 130 12. 8% 83.9% 5 782 8.9% 92. 8% 6 441 5.0% 97. 8% 7 143
    1.6% 99. 4% 8 28 0. 3% 99. 7% 9 11 0. 1% 99. 9% 10- 19 13 0. 1% 100. 0%

    Total 8, 813 100%

    Note: The sampling error, rounded to the nearest whole point, is calculated
    at the 95- percent confidence level for inspections using the current
    maximum sample size of 27. We multiplied the standard error, supplied by
    REAC, by a t- value of 2 to obtain the sampling error. REAC's samples ranged
    from 5 to 27 units. The appropriate t- values were 2.776 and 2.056 when the
    numbers of units sampled were 5 and 27, respectively. Because we used a t-
    value that was consistently lower than

    appropriate, our estimates somewhat understate the sampling error. We could
    not use the appropriate t- value because the data we obtained did not
    include the number of units sampled. Source: GAO's analysis of REAC's data.
    Sampling Caused

    Multifamily properties are placed in one of four categories, depending on
    Uncertainty About Followup their inspection scores. Properties with scores
    of 60 and above are required for Some Multifamily

    only to correct deficiencies found during inspection, whereas properties
    Properties with lower scores have additional requirements. When a property's
    physical condition score is from 31 through 59, a HUD field office imposes
    follow- up requirements. When the score is 30 or below, the property is
    referred to the Departmental Enforcement Center. Table 2 lays out the

    different requirements for multifamily properties.

    Table 2: Follow- up Requirements for Multifamily Properties Based on Their
    Inspection Scores

    Physical inspection score Follow- up requirement

    60 and above No certification or corrective plan is required unless the
    field office requests one. 46 - 59 The HUD field office requires the
    property owner to inspect all

    units and buildings and develop a plan of correction. The plan should give
    the results of the owner's own inspection, list corrections already made to
    identified deficiencies, discuss plans to correct the remaining
    deficiencies, and list the resources to be used by the owner to make
    repairs. 31- 45 In addition to complying with the requirements for
    properties that received scores from 46 through 59, the property owner

    must develop a management improvement plan and complete its goals for
    correcting deficiencies. The field office can require another inspection to
    confirm the completion of repairs. 30 and below The property is referred to
    the Departmental Enforcement

    Center (DEC) for evaluation. DEC conducts an evaluation to confirm that the
    property should be assigned to it. The property owner is required to develop
    a plan to correct deficiencies, and the field office is required to ensure
    that all health and safety deficiencies are corrected in a timely manner.
    Note: At all properties, regardless of score, deficiencies found during
    inspection must be corrected. Moreover, life- threatening health and safety
    deficiencies are expected to be corrected within a certain time frame,
    usually within a few days of the inspection.

    Using information provided by REAC on 6,291 of the over 26,000 multifamily
    properties it inspected, we determined the follow- up category to which each
    property would have been assigned, given its reported

    physical inspection score. We then determined, after considering the
    sampling error of the estimated score, whether HUD could be confident that
    the property would have been placed in the same follow- up category if its
    score, based on a full inspection of all of its buildings and units, had

    been known. For example, if a property's score, based on a sample, was 33
    and the sampling error for the estimated score was plus or minus 5, the
    resulting confidence interval would range from 28 through 38. HUD therefore
    could not be sure whether this property belonged in the “30 and
    below” or the “31- 45” category. As shown in table 3,
    sampling produced uncertainty about the appropriate requirements for 7. 6
    percent of the 6,291 multifamily properties tested.

    Table 3: Follow- up Referrals for 6,291 Multifamily Properties Properties
    whose placement in category was questionable after sampling error was
    considered

    Follow- up category Number of

    based on physical properties placed inspection score of

    in category Number Percent

    60 and above 5, 684 157 2. 8% 46- 59 384 218 56. 8% 31- 45 150 90 60. 0% 30
    and below 73 16 21.9%

    Total 6, 291 481 7. 6%

    Note: For an additional 4 to 6 percent of the multifamily properties, we
    could not tell whether the scores were reliable enough to place the
    properties in the correct follow- up category. The sampling error for these
    properties appeared to be reported as 0 simply because no variation in
    physical condition was observed among the sampled units or buildings. In
    such cases, the sampling error cannot be calculated, and we could not tell
    whether the score could reliably be used to determine the appropriate
    follow- up actions for the property. We assumed that appropriate actions
    could be determined for these properties, but, in so doing, we may have
    understated the percentage of properties whose categories may be affected by
    sampling error.

    Source: GAO's analysis of REAC's data.

    Besides using the physical condition scores to determine the follow- up
    requirements for multifamily properties, HUD plans to use the scores to
    determine how soon the properties will be reinspected once it issues the

    scoring thresholds for reinspection. For some properties, such decisions
    will also be subject to uncertainty because of sampling error.

    Sampling will also cause uncertainty for some public housing properties.
    Once the public housing scores become binding, HUD will use the scores to
    determine the follow- up and reinspection requirements for public housing
    properties. However, the effect of sampling may be lessened for two reasons.
    First, the thresholds will be based on the physical condition of all
    properties within an authority. Second, the thresholds will be based on a
    number of factors in addition to the physical inspection score, including
    the authority's financial health and management.

    REAC officials told us that REAC has established many safeguards to ensure
    that the physical inspection process is accurate and fair. These include
    quality assurance activities at various levels of the inspection process,
    technical reviews of inspections, appeals procedures, and postinspection
    reviews. They said that all of these processes can be used to help address
    concerns about the accuracy and reliability of inspections. However, none of
    these processes directly deal with uncertainties in inspection scores
    stemming from sampling error. 5

    In an August 2000 meeting, REAC's Director told us that REAC was planning,
    on the basis of discussions with us about sampling issues, to calculate
    confidence intervals for all inspection scores for internal use. In

    addition, for properties whose scores are close to the administrative
    thresholds HUD uses in determining follow- up actions (30 and 60), REAC
    would request that HUD field offices consider other information on the
    condition of these properties to help ensure that they are placed in the
    appropriate follow- up category. Finally, for other properties whose scores
    are associated with unusually large sampling errors, REAC would examine the
    reasons for the large sampling errors and either take actions to reduce

    the errors or alert the appropriate HUD field offices if there is
    uncertainty about what follow- up actions should be taken. In its October
    13, 2000, letter commenting on our draft report, HUD stated that it plans to
    use an alternative approach for addressing our concerns about sampling
    error. HUD is now proposing that when the confidence interval for a
    property's inspection score crosses one of its key

    administrative thresholds for determining follow- up actions (30 or 60
    points), it will adjust the score downward so that the property will be
    treated as if its score falls into the follow- up category requiring more
    intensive monitoring. While this approach differs somewhat from the approach
    that HUD proposed in the August 2000 meeting and that we had discussed with
    REAC officials, we believe that it should still address our basic concerns.
    6

    5 Our July report discusses other concerns about the reliability of REAC's
    inspection scores. 6 The approaches that we had discussed generally focused
    on having HUD program offices perform additional analyses for properties
    whose scores could not be relied on to ensure that appropriate follow- up
    actions were taken. For example, if there were uncertainty due to sampling
    error about whether a property's score was above or below 60, staff might
    take into account the owner's past responsiveness in addressing physical
    defects when determining whether a written corrective action plan should be
    required.

    We recognize that HUD's proposal focuses on two key administrative
    thresholds (30 and 60 points) and does not specifically cover other
    administrative thresholds that HUD uses to determine follow- up or
    reinspection requirements. However, the fact that HUD will routinely
    calculate the sampling error for all inspection scores should help it
    determine the extent to which sampling may cause uncertainty about decisions
    in these areas as well. This should put HUD in a good position to continue
    identifying strategies and opportunities to mitigate the effects of

    uncertainty caused by sampling. REAC's Scoring

    REAC attempted to reduce the sampling error associated with its Formula Is
    Not

    inspection scores by giving buildings with a large number of units a greater
    chance of being selected for inspection than other buildings. Although the
    Consistent With Its use of such a sampling procedure is acceptable, the
    formula that REAC

    Sampling Technique used to calculate the inspection scores was not
    consistent with this sampling approach. REAC used a formula that was
    appropriate only when all units and all buildings with dwelling units at a
    property had an equal

    chance of being inspected. As a result, HUD incorrectly calculated some
    inspection scores. HUD tested a method for calculating the score that
    corrected this problem, using data for 5, 030 properties, and found that the
    revision changed the scores of about 30 percent of these properties (see
    table 4).

    Table 4: Change in Physical Condition Score After Accounting for the
    Probability of Selection for Inspection

    Change in points

    Percentage of Change in score Number of properties properties

    0 3, 561 70. 8% 1 1, 058 21. 0% 2 258 5.1% 3 84 1. 7% 4-9 69 1. 4%

    Total 5, 030 100.0%

    Source: GAO's analysis of REAC's tables.

    While the scores of 97 percent of the properties tested changed by no more
    than 2 points, the scores for 69 (or 1.4%) of the 5,030 properties changed
    by 4 to 9 points. As noted, when a score changes by even one point, the
    followup requirements can change. Among the 69 properties whose scores
    changed by 4 or more points, REAC identified 6 properties whose follow- up
    requirements could have been affected. 7 For example, one multifamily
    property in this analysis received a score of 64. Given this score, HUD
    would not have required a corrective plan for the property. However, when
    the differing probabilities of buildings' and units' selection for
    inspection were considered, the property received a score of 58 points. With
    this score, the HUD field office would require the owner to inspect all of
    the

    property's units and buildings and develop a corrective plan to ensure the
    repair of all deficiencies. REAC agrees that, for complete accuracy, the
    scores estimated from samples of units and buildings should account for
    differing probabilities of selection. In an August meeting, REAC officials
    told us they were introducing new sampling procedures that would nearly
    equalize the

    chance that each of a property's dwelling units would be selected for
    inspection. They said that information obtained during the baseline
    inspections made the new sampling method feasible.

    In its October 13, 2000, letter commenting on our draft report, HUD agreed
    to take further actions to address our concerns. HUD said it would change
    its sampling procedures to obtain a self- weighting sample of units and

    modify the inspection- scoring algorithm to include the probability of
    selection for sampled buildings. These actions, when implemented, should
    address our concerns in this area. Conclusions We understand REAC's need to
    sample buildings and units when performing physical inspections and
    recognize the inherent uncertainty associated with sampling. However, it is
    important for REAC to recognize

    both the extent to which this uncertainty affects its inspection scores and
    the need for appropriate procedures to mitigate the effects of the
    uncertainty. The actions that HUD is proposing to take in response to our

    concerns about its sampling procedures should, we believe, basically address
    these concerns. 7 REAC did not provide information on how frequently the
    changes in the scores for the other 1, 400 properties affected their follow-
    up requirements.

    Agency Comments and We provided HUD with a draft of this report for its
    review and comment.

    Our Evaluation HUD said that to resolve our concerns, it has revised its
    procedures to ensure that all inspected properties are properly and
    consistently

    monitored in accordance with risk management practices and it will alter
    scoring- related processes to increase precision. More specifically, to
    address the recommendations we made in our draft report, HUD stated that it
    would begin calculating the confidence interval for every inspection score.
    In addition, HUD said that when the confidence interval for a property's
    inspection score crossed one of the key administrative thresholds for
    determining follow- up actions (30 or 60 points), it would adjust the score
    downward so that the property would be

    treated as if its score fell into the follow- up category requiring more
    intensive monitoring by HUD. According to HUD, this action would reduce or
    eliminate the risk of inadequate monitoring. HUD noted that it expected this
    action would affect only about 3 percent of its multifamily properties and
    that the benefits of increased scrutiny would exceed the inconvenience to a
    small number of property owners.

    HUD also agreed to change its data collection, scoring, and reporting
    processes to incorporate new sampling procedures in its inspection data
    collection device to obtain a self- weighting sample of units, modify the

    inspection- scoring algorithm to include the probability of selection for
    sampled buildings, and modify its inspection summary report to show the
    probability of selection for sampled buildings. We revised our report to
    include the actions HUD is proposing. We also dropped our draft report's
    recommendations for improvements in these areas, since HUD's actions, when
    implemented, should address our basic concerns about HUD's sampling
    procedures. The complete text of HUD's comments appears in appendix I.

    Scope and To determine whether REAC's procedures were producing inspection
    Methodology

    scores that could reliably be used to determine the appropriate follow- up
    requirements for inspected properties, we reviewed REAC's current sampling
    procedures and discussed these procedures with the appropriate REAC
    officials. We also obtained REAC's calculations of standard errors and
    scores for 8,813 properties- including 6,291 multifamily and 2,522 public
    housing properties- inspected using the current sampling procedures. We
    calculated the sampling error for each property using its

    inspection score and standard error. From the 6,291 multifamily properties,
    we identified those for which the sampling error introduced uncertainty
    about the appropriate follow- up action.

    To determine whether the method used to compute scores was correctly
    estimating the score a property would have received if the entire property,
    and not just a sample of its dwelling units or buildings, had been
    inspected, we reviewed REAC's documentation for sampling procedures and
    formula for calculating scores. We obtained REAC's analysis of how the
    scores for 5,030 properties would change if the formula were changed. We
    also discussed REAC's procedures and analysis with appropriate REAC
    officials. We conducted our work from December 1999 through October 2000 in
    accordance with generally accepted government auditing

    standards. We are sending copies of this report to Honorable Rick Lazio,
    Chairman, and the Honorable Barney Frank, Ranking Minority Member,
    Subcommittee on Housing and Community Opportunity, House Committee on
    Banking and Financial Services, who requested our July 2000 report on HUD's
    physical inspection system. We will also make copies of this report
    available to others on request. If you or your staff have any questions
    about this report, please call me at (202) 512- 7631. Key contributors to
    this report

    were Karen Bracey, Martha Chow, and Richard Hale. Sincerely yours,

    Stanley J. Czerwinski Director, Physical Infrastructure Issues

    Appendi xes Comments From the Department of Housing

    Appendi x I and Urban Development

    Lett er (385874) Lett er

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    Federal Programs

    e- mail: fraudnet@ gao. gov 1- 800- 424- 5454 (automated answering system)

    GAO United States General Accounting Office

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    Appendix I

    Appendix I Comments From the Department of Housing and Urban Development

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    Appendix I Comments From the Department of Housing and Urban Development

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    United States General Accounting Office Washington, D. C. 20548- 0001

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