Housing: HUD's Program for Persons With AIDS (Letter Report, 03/24/97,
GAO/RCED-97-62).
Pursuant to a congressional request, GAO reviewed the Housing and Urban
Development's (HUD) Housing Opportunities for Persons with AIDS (HOPWA)
program, focusing on: (1) what the rationale is for having a housing
program within HUD specifically for people with acquired
immunodeficiency syndrome (AIDS); (2) what kinds of activities are being
funded through the program; (3) whom the program is serving; (4) how the
program is coordinated with the Department of Health and Human Services'
(HHS) Ryan White AIDS assistance programs; and (5) how HUD headquarters
oversees program administration and monitoring.
GAO noted that: (1) the legislative history for the HOPWA program
indicates that the Congress established the program within HUD in 1990
because the existing housing resources at the time were reportedly not
meeting the needs of people with AIDS, who often had difficulty
obtaining suitable housing because of the need for supportive services,
discrimination, or other problems; (2) HUD and HHS officials, along with
several grantees and project sponsors GAO contacted, generally believe
that these problems still exist and that the HOPWA program is still
needed to counteract them; (3) grantees can use funds for a broad range
of housing assistance and supportive services intended to prevent
homelessness; (4) the limited data available from HUD indicate that
about 71 percent of the funds that have been expended has been used to
provide housing assistance, about 16 percent has been used to provide
supportive services independent of housing assistance, and the remaining
13 percent has been used for housing information services, resource
identification, and grantees' and project sponsors' administrative
costs; (5) however, it should be recognized that these data do not fully
reflect the grantees' use of program appropriations; (6) as of October
7, 1996, the grantees had expended 37 percent of the total funds
appropriated since fiscal year 1992; (7) under the Department's
regulations, the program generally provides assistance to low-income
individuals with the human immunodeficiency virus (HIV) or AIDS and
their families; (8) GAO's analysis of the limited data available from
the Office of HIV/AIDS Housing indicates that 70 percent of the program
participants received housing assistance, while about 30 percent
received supportive services not associated with housing assistance
funded by the program; (9) of those that received housing assistance,
about 67 percent were adult males, and about 70 percent had incomes
below $500 per month; (10) coordination between the HOPWA and Ryan White
Titles I and II programs, which provide grants to states and localities
to fund a wide range of services to assist people with HIV/AIDS, occurs
primarily at the grantee level; (11) according to officials in HUD and
HHS, coordination of the two programs is basically informal; (12) HUD
field offices are primarily responsible for the oversight and monitoring
of grantees under the program; and (13) headquarters directs and monito*
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-97-62
TITLE: Housing: HUD's Program for Persons With AIDS
DATE: 03/24/97
SUBJECT: Interagency relations
Formula grants
Grant administration
Housing programs
Acquired immunodeficiency syndrome
Disadvantaged persons
Federal aid for housing
Management information systems
Grants to states
Grant monitoring
IDENTIFIER: HUD Housing Opportunities for Persons with AIDS Program
HUD Section 8 Rental Assistance Program
Community Development Block Grant
Emergency Shelter Grant
HUD Home Investment Partnership Program
HUD Integrated Disbursement and Information System
AIDS
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Cover
================================================================ COVER
Report to the Subcommittee on VA, HUD and Independent Agencies,
Committee on Appropriations, House of Representatives
March 1997
HOUSING - HUD'S PROGRAM FOR
PERSONS WITH AIDS
GAO/RCED-97-62
Housing for Persons With AIDS
(385649)
Abbreviations
=============================================================== ABBREV
AIDS - acquired immunodeficiency syndrome
AIDS-OIs - AIDS opportunistic infections
CARE - Comprehensive AIDS Resources Emergency
CDC - U.S. Centers for Disease Control and Prevention
CPD - Office of Community Planning and Development
GAO - General Accounting Office
HHS - Department of Health and Human Services
HIV - human immunodeficiency virus
HOME - HOME Investment Partnerships program
HOPWA - Housing Opportunities for Persons With AIDS
HRSA - Health Resources and Services Administration
HUD - Department of Housing and Urban Development
IDIS - Integrated Disbursement and Information System
VA -
HIV/AIDS -
AIDS/HIV -
Letter
=============================================================== LETTER
B-276110
March 24, 1997
The Honorable Jerry Lewis
Chairman
The Honorable Louis Stokes
Ranking Minority Member
Subcommittee on VA, HUD and Independent Agencies
Committee on Appropriations
House of Representatives
The acquired immunodeficiency syndrome (AIDS) epidemic, well into its
second decade, has posed a serious health threat to the American
public. Through June 1996, over 545,000 cases of AIDS had been
reported in the United States, in addition to a large but
undetermined number of people who had not been diagnosed with AIDS
but were infected with the human immunodeficiency virus (HIV), which
causes AIDS. Housing Opportunities for Persons With AIDS (HOPWA),
the only federal program targeted specifically to meeting the housing
needs of people with HIV/AIDS, was established within the Department
of Housing and Urban Development (HUD) under the National Affordable
Housing Act of 1990. From fiscal year 1992, when the HOPWA program
began, through fiscal year 1996, the Congress appropriated over $645
million for the program and an additional $196 million for fiscal
year 1997.
This report responds to your request that we review (1) what the
rationale is for having a housing program within HUD specifically for
people with AIDS, (2) what kinds of activities are being funded
through the program, (3) whom the program is serving, (4) how the
program is coordinated with the Department of Health and Human
Services' (HHS) Ryan White AIDS assistance programs, and (5) how HUD
headquarters oversees program administration and monitoring. As
requested, we are also providing background information on how the
program works.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
The legislative history for the Housing Opportunities for Persons
With AIDS program indicates that the Congress established the program
within the Department of Housing and Urban Development in 1990
because the existing housing resources at the time were reportedly
not meeting the needs of people with AIDS, who often had difficulty
obtaining suitable housing because of the need for supportive
services, discrimination, or other problems. Department of Housing
and Urban Development and Department of Health and Human Services
officials, along with several grantees and project sponsors we
contacted, generally believe that these problems still exist and that
the Housing Opportunities for Persons With AIDS program is still
needed to counteract them. However, critics have questioned the
program because, for instance, they believe that it is not
appropriate to target assistance to persons with one disease and not
others or that any additional federal resources should be focused on
preventing AIDS.
Grantees can use funds for a broad range of housing assistance and
supportive services intended to prevent homelessness. The limited
data available from HUD indicate that about 71 percent of the funds
that have been expended has been used to provide housing assistance;
about 16 percent has been used to provide supportive services
independent of housing assistance, such as health care, chemical
dependency treatment, and nutritional services; and the remaining 13
percent has been used for housing information services, resource
identification, and grantees' and project sponsors' administrative
costs. However, it should be recognized that these data do not fully
reflect the grantees' use of program appropriations. As of October
7, 1996, the grantees had expended 37 percent of the total funds
appropriated since fiscal year 1992. Furthermore, the grantees'
reports describing their use of program funds that were available
from the Department of Housing and Urban Development's Office of
HIV/AIDS Housing as of October 7, 1996, covered only 27 percent of
the funds that the grantees had expended during that time.
Under the Department's regulations, the program generally provides
assistance to low-income individuals with HIV/AIDS and their
families. Our analysis of the limited data available from the Office
of HIV/AIDS Housing indicates that 70 percent of the program
participants received housing assistance, while about 30 percent
received supportive services not associated with housing assistance
funded by the program. The Department does not collect data on the
characteristics of the program participants who receive only
supportive services. However, of those that received housing
assistance, about 67 percent were adult males, and about 70 percent
had incomes below $500 per month. Over half of the participants were
living in rental housing prior to receiving housing assistance under
the program, while the rest came from various situations, such as
living with relatives or in shelters, substance abuse facilities, or
hospitals.
Coordination between the Housing Opportunities for Persons With AIDS
program and Ryan White Titles I and II programs, which provide grants
to states and localities to fund a wide range of services to assist
people with HIV/AIDS, occurs primarily at the grantee level.
According to officials in the Departments of Housing and Urban
Development and Health and Human Services, coordination of the two
programs at the national level is basically informal. While the
agencies have taken steps to increase coordination in recent years,
several grantees and project sponsors we contacted believed that the
two programs could be better coordinated. Furthermore, we noted that
while the formula used to distribute Ryan White funds has been
revised to reflect estimates of the current number of people living
with AIDS, the formula for the housing opportunities program is still
based on cumulative AIDS cases, which can lead to funding inequities.
Also, the requirements governing how the Ryan White grantees are to
coordinate with other parties when planning the use of grant funds
provide greater assurance that all affected parties will have a voice
in determining how the funds will be used than do the requirements
for the housing opportunities program.
Department of Housing and Urban Development field offices are
primarily responsible for the oversight and monitoring of grantees
under the program. The field offices can use a variety of tools to
oversee grantees and monitor their use of funds, including a review
of the consolidated plans and progress reports prepared by the
grantees, as well as on-site visits and consultation with community
officials and other stakeholders. The field offices also have
considerable latitude and flexibility in how they use these tools.
Headquarters directs and monitors the field offices' oversight of the
grant programs.
Although we did not review the field offices' monitoring of grants,
in an August 1996 telephone survey, field community planning and
development grant program directors expressed a general belief that
headquarters has not sufficiently emphasized completing essential
monitoring and that insufficient staff and travel funds have
prevented sufficient on-site inspection visits. Also, headquarters
has not made effective use of the available data on the performance
of grantees because it has not used the grantees' annual progress
reports to assess overall program accomplishments nor ensured that
these reports are received and processed in a timely manner.
BACKGROUND
------------------------------------------------------------ Letter :2
First identified in 1981, AIDS impairs the immune system and leaves
affected individuals susceptible to certain cancers and infections.
Through June 1996, over 545,000 people with AIDS had been reported to
the Centers for Disease Control and Prevention (CDC); 343,000 of
these had died.\1 The CDC reported that in 1994, the most recent year
of analysis, HIV infection was the most common cause of death among
persons aged 25 to 44 years.\2
The Congress created the program of Housing Opportunities for Persons
With AIDS in 1990 under the National Affordable Housing Act,
authorizing grants for a broad range of housing activities and
supportive services designed to prevent homelessness among people
with HIV/AIDS. For fiscal year 1997, the Congress appropriated $196
million for the HOPWA program (including $25 million transferred from
HUD's Section 8 rental assistance program). HOPWA grantees may carry
out eligible program activities themselves, through any of their
administrative agencies, or by contract with a project sponsor. A
project sponsor can be any nonprofit organization or governmental
housing agency that receives funds under a contract with a grantee to
carry out eligible HOPWA activities. The grantees and project
sponsors may also contract with for-profit entities to provide
services associated with their HOPWA activities.
HUD awards 90 percent of the annual HOPWA appropriation by formula to
eligible metropolitan statistical areas and states. On the basis of
the statute, metropolitan areas with populations greater than 500,000
and more than 1,500 cumulative cases of AIDS\3 are eligible for HOPWA
formula grants; the most populous city in an eligible metropolitan
area serves as that area's HOPWA grantee. In addition, states with
more than 1,500 cumulative cases of AIDS in areas outside of eligible
metropolitan areas qualify for formula funds. For fiscal year 1996,
27 states and 49 metropolitan areas had enough AIDS cases to qualify
for formula grants.
The remaining 10 percent of HOPWA's annual appropriation is set aside
for grants awarded on a competitive basis. The states and localities
that do not qualify for formula grants may apply for competitive
grants for projects that are part of long-term strategies for
providing housing and services. These grants are awarded on the
basis of criteria such as the applicant's capacity to implement the
proposed project; the area's need for the project; the
appropriateness of housing and supportive services, including how the
activities will provide a continuum of housing and services to meet
the changing needs of people with AIDS; the extent of leveraged
public and private resources for the project; the extent of local
planning and coordination of housing programs for people with AIDS;
and the likelihood of the continuation of state and local efforts.
In addition, any state, locality, or nonprofit organization may apply
for a competitive grant to fund a Special Project of National
Significance. These grants are awarded on the basis of many of the
same criteria as other competitive grants, in addition to two other
criteria: the innovative nature of the proposal and its potential
for replication in similar localities or nationally, and the extent
to which the proposal provides for the evaluation and dissemination
of information on the project's success. HUD has awarded competitive
grant funds for fiscal years 1992 through 1996 to a total of 81
grantees.
Eligible states and cities apply for HOPWA formula funds through the
Consolidated Plans they submit to HUD. Under the Consolidated Plan
process, jurisdictions submit a single document that consolidates the
planning and application aspects of the four formula grant programs
administered by HUD's Office of Community Planning and Development
(CPD).\4
Applicants are to develop their Consolidated Plans through a
communitywide effort that assesses needs, creates a multiyear
strategy, and proposes an action plan for using federal funds and
other community resources in a coordinated and comprehensive manner.
HUD's regulations require jurisdictions applying for formula grants
to adopt a citizen participation plan that provides for and
encourages citizens to participate in developing the Consolidated
Plan. The Consolidated Plan process, which applies to all four
Community Planning and Development formula grant programs, also
requires the grantees to consult with other public and private
agencies that provide assisted housing, health services, and social
services, including those that focus on specific populations such as
people with HIV/AIDS. The grantees' Consolidated Plans are to
describe the agencies, groups, and others who participated in the
planning process; their consultations with social service agencies
and other entities; and their activities to enhance coordination
between public and assisted housing providers and private and
governmental health, mental health, and service agencies. In
addition, regulations specific to the HOPWA program require the
grantees to cooperate and coordinate with state and local government
agencies responsible for services in the area for people with
HIV/AIDS and their families, and with other public and private
organizations that provide services for these people.
Before enacting HOPWA's authorizing legislation, in 1990 the Congress
enacted the Ryan White Comprehensive AIDS Resources Emergency (CARE)
Act (P.L.101-381) to improve the availability and quality of
community-based health care and support services for individuals and
families with HIV/AIDS. The Health Resources and Services
Administration (HRSA), within the Department of Health and Human
Services (HHS), administers the Ryan White legislation. HRSA's
Bureau of Health Resources Development administers titles I and II of
the act, which provide grants to those metropolitan areas
disproportionately affected by the HIV epidemic and to states. Title
I provides both formula and competitive grants for "emergency
assistance" to localities to provide medical and support services to
those with HIV/AIDS and their families; title II provides formula
grants to states to improve the quality, availability, and
organization of health care and support services for people with
HIV/AIDS and their families. For fiscal year 1996, the Congress
appropriated $762 million for the Ryan White program; a total of over
$652 million was appropriated for titles I and II.
--------------------
\1 Of the cumulative number of people reported with AIDS through June
1996, about 85 percent were males. In addition to the number of AIDS
cases reported, an undetermined number of individuals who have not
been diagnosed with AIDS are infected with HIV, which causes AIDS.
According to a recent CDC report, estimates of the prevalence of HIV
infection in the United States in 1992 placed the number of people
infected between 650,000 and 900,000.
\2 Because of the prolonged period from the initial HIV infection to
the onset of AIDS, recent trends in HIV-related mortality reflect the
trends in HIV transmission several years earlier. Despite recent
increases in HIV-related mortality, the decreases in the percentages
of HIV-related deaths resulting from particular HIV-related illnesses
suggest some success in the treatment and prevention of these
illnesses. According to CDC's HIV/AIDS Surveillance Report, the
estimated number of new diagnoses of severe HIV-related illnesses,
called AIDS opportunistic infections (AIDS-OIs), are useful for
tracking recent courses of the epidemic. CDC's report of the data
through June 1996 states that the recent trends in the number of
AIDS-OIs illustrate an overall slowing in the rate of growth of the
AIDS epidemic. According to the CDC report, while the estimated
number of AIDS-OIs is still increasing slightly each year, it is
likely that in the near future, the estimated number will stabilize
or decline slightly. However, these overall trends at the national
level are likely to mask diverse local subepidemics.
\3 The count of cumulative AIDS cases represents the total number of
cases reported to and confirmed by the CDC since AIDS reporting began
in 1981.
\4 In addition to HOPWA, CPD administers the Community Development
Block Grant program, the Emergency Shelter Grant program, and the
HOME Investment Partnerships (HOME) program. The block grant program
provides annual grants, principally to state and local governments,
to aid in the development of viable communities. The emergency
shelter program provides grants for safe and sanitary housing,
supportive services, and other assistance to the homeless. HOME
provides funds to produce affordable housing units.
THE CONGRESS ESTABLISHED THE
HOPWA PROGRAM IN RESPONSE TO
UNMET HOUSING NEEDS REPORTED
FOR PEOPLE WITH AIDS
------------------------------------------------------------ Letter :3
The legislative history for the National Affordable Housing Act of
1990 (P.L. 101-625), which established the HOPWA program, indicates
that, at that time, people with AIDS constituted a growing proportion
of the homeless population. In its report on proposed legislation
that ultimately became Public Law 101-625, the Senate Committee on
Banking, Housing, and Urban Affairs reported that the Partnership for
the Homeless had estimated that between 28,000 and 32,000 people with
AIDS, and an additional 10,000 to 11,000 of their dependents, were
homeless throughout the United States. According to the Committee's
report, housing, especially housing with supportive services, was
extremely limited for people with AIDS; for example, the National
Coalition for the Homeless had reported that in Los Angeles, only 5
out of 42 shelters would accept someone infected with HIV. The
Committee stated that it viewed adequate housing as the cornerstone
of a comprehensive community-based network of services for people
with AIDS and that care in home- or community-based settings was
compassionate and more cost-effective than hospitalizing people with
AIDS who did not need acute care but could not be discharged because
they had nowhere to live.
The Congress reauthorized the HOPWA program under the Housing and
Community Development Act of 1992 (P.L. 102-550). In that same
year, the National Commission on AIDS had reported that an estimated
15 percent of the homeless population was infected with HIV and that
one-third to one-half of all people with AIDS were either homeless or
in imminent danger of becoming so because of their illness, lack of
income, and weak support networks. The Commission added that the
housing crisis for people with AIDS was partially the result of an
overall lack of adequate, affordable housing for all citizens.
HUD has not conducted any comprehensive, nationwide studies to
evaluate the current housing needs of people with AIDS. However,
AIDS Housing of Washington, the recipient of a HOPWA competitive
grant in fiscal year 1995 to provide technical assistance nationwide
to communities and housing providers for people with AIDS, has
compiled data that provide some indication of the housing needs. The
organization surveyed 2,593 people with AIDS during the course of its
work in a mix of eight cities, counties, and states.\5 The results
show that 36 percent of those surveyed in these locations had been
homeless since learning of their HIV infection or AIDS. In addition,
officials in HHS' HRSA identify housing assistance as a continuing
priority need for people with AIDS.
The Director of HUD's Office of HIV/AIDS Housing told us that HUD
strongly believes that the HOPWA program is still needed. He noted
that the Congress has not only continued funding for the program but
has approved funding increases in fiscal years 1993, 1994, 1995, and
1997. Furthermore, several grantees and project sponsors whom we
contacted believe that the need for the program has not only
continued, but has increased because of current developments in the
AIDS epidemic. The grantees and sponsors cited trends such as
increasing infection among African-American and Hispanic communities,
women, families with children, and injection drug users. In
addition, they noted that the life expectancy for a person with AIDS
has increased since the initial years of the epidemic and may
continue to increase with the development of new treatments. The
Director of HUD's Office of HIV/AIDS Housing and some advocates
maintain that these new treatments may enhance the importance of
adequate housing for people with AIDS because they require a very
strict regimen to be effective; without stable housing and support,
individuals could find it very difficult to adhere to the prescribed
regimen or to even access programs that make the new treatments
available.
In contrast, some parties have questioned the HOPWA program. For
instance, a Senior Fellow at the Heritage Foundation told us that HUD
has not proven its ability to provide decent, safe, and sanitary
housing at a competitive price and, therefore, should not attempt to
administer programs like HOPWA that go beyond basic housing provision
to offer supportive services. This is particularly true, he said,
when another agency, HHS, already has expertise in supportive service
programs. Americans for a Sound AIDS/HIV Policy\6 questions the
HOPWA program on the principle that AIDS should be addressed in the
same way that other medical problems are addressed at the national
level; while federal assistance should be available to people with
AIDS, programs should not be targeted only to the AIDS population but
should be available to anyone with a serious disease. In addition,
during floor debate on HOPWA's appropriation for fiscal year 1997,
the argument was made that any additional federal resources to
address the AIDS epidemic would be better spent on increased efforts
to prevent HIV infection and the disease's progression from HIV to
AIDS, rather than on increasing the appropriation for housing. It
was argued that HIV/AIDS is largely a preventable disease and that no
matter how much money the nation spends on compassionate care in the
later stages of AIDS, it will never be enough; instead, the key to
solving the AIDS crisis lies in focusing federal efforts on
preventing HIV infection and providing drugs that could prevent
HIV-infected individuals from developing AIDS.
--------------------
\5 AIDS Housing of Washington surveyed people with AIDS in Chicago,
Illinois; Alameda County, California; Contra Costa County,
California; Riverside/San Bernardino Counties, California; Phoenix,
Arizona; and the states of Minnesota and Washington. The studies
were conducted using convenience sampling, and the results cannot be
projected to the overall AIDS population.
\6 Americans for a Sound AIDS/HIV Policy is a Washington, D.C.-based
organization that provides education, prevention, and direct service
programs related to HIV disease.
LIMITED DATA SHOW THAT PROGRAM
HAS PRIMARILY FUNDED HOUSING
ASSISTANCE
------------------------------------------------------------ Letter :4
Grantees can use HOPWA funds for a wide range of activities designed
to prevent homelessness, including housing, social services, and
program planning and development. Eligible activities include all
forms of housing assistance, such as the acquisition, rehabilitation,
or new construction of housing units; operating costs;\7 rental
assistance; technical assistance; and short-term rental, mortgage,
and utility payments to prevent homelessness. As part of any
assisted housing, the grantees must provide appropriate supportive
services, which could include health care, mental health services,
drug and alcohol abuse treatment and counseling, day care, or
nutritional services, among other things. The grantees can also use
HOPWA funds to provide services independent of any housing activity.
Grantees can also use HOPWA funds for
-- housing information services, such as counseling and referral
services, to assist an eligible participant to locate, acquire,
finance, and maintain housing;
-- resource identification to establish, coordinate, and develop
housing assistance resources for eligible participants,
including conducting preliminary research and determining the
feasibility of specific housing-related initiatives; and
-- administrative costs, which may not exceed 3 percent of the
grant amount for grantees and 7 percent for project sponsors.
For fiscal years 1992 through 1996, the Congress appropriated a total
of about $646 million for the HOPWA program. As of October 7, 1996,
grantees had spent nearly $239 million, or 37 percent, of these
appropriated funds. According to officials in HUD's Office of
HIV/AIDS Housing, the remaining $407 million had not yet been
expended by grantees for several reasons, including that (1) HUD
allows a 3-year period to fully expend a grant award; (2) some
grantees intentionally reserve funds until the final year of their
grant period to ensure that they can provide assistance for the full
3-year period; (3) facility development can be slow because of
complexities such as environmental reviews and siting difficulties;
and (4) some grantees who had not developed an approach to assisting
people with HIV/AIDS before receiving the HOPWA grant waited to spend
grant funds until they had identified resources and developed an
overall plan.
HUD's Office of HIV/AIDS Housing collects data on the use of program
funds through annual progress reports submitted by the grantees to
their local HUD field office. As of October 7, 1996, the HIV/AIDS
Housing Office had received annual progress reports representing
about $65 million, or 27 percent, of the $239 million expended since
the program's inception.\8 The available data indicate that grantees
used about 71 percent of the expended funds to provide housing
assistance\9 and about 16 percent to provide supportive services
independent of HOPWA-funded housing assistance. The remaining 13
percent was used to fund housing information services, resource
identification, and administrative costs (see fig. 1). However,
these data must be interpreted with caution because they may not be
representative of how the remaining 73 percent of expended funds have
been used.
Figure 1: HOPWA Expenditures
(Reflects Data From 1992
Through Oct. 7, 1996)
(See figure in printed
edition.)
Notes: Housing assistance expenditures can include supportive
services provided in connection with assisted housing.
The information represents 27 percent of the funds expended.
Source: Grantees' annual progress reports received by HUD's Office
of HIV/AIDS Housing as of October 7, 1996.
--------------------
\7 Operating costs for housing include expenses for maintenance,
security, operation, insurance, utilities, furnishings, equipment,
and supplies.
\8 The Office of HIV/AIDS Housing had not received annual progress
reports on the other 73 percent of funds. Some of these reports were
not due as of the October date, but others were overdue. This issue
is discussed later in our report.
\9 Housing assistance expenditures can include funds for supportive
services provided in conjunction with assisted housing.
LIMITED DATA SHOW THAT PROGRAM
HAS PRIMARILY PROVIDED HOUSING
ASSISTANCE TO ADULT MALES WITH
HIV/AIDS
------------------------------------------------------------ Letter :5
The statute establishing the HOPWA program (P.L. 101-625) limited
eligibility to persons with HIV/AIDS or related diseases. The
Congress amended the act in 1992 (P.L. 102-550) to include the
families of those with HIV/AIDS, which HUD's regulations define as a
household of two or more related persons, someone important to the
care or well-being of a person with HIV/AIDS living with that person,
or family members living with someone with HIV/AIDS in a
HOPWA-assisted unit at the time of that person's death.\10
HUD has generally limited program participation to low-income
individuals and families.\11
The limited data available from the grantees' annual progress reports
at HUD's HIV/AIDS Housing Office as of October 7, 1996, indicate that
over 70 percent of the program participants received housing
assistance, while about 30 percent received supportive services not
connected with any housing assistance (see fig. 2). However, we
again caution that these data represent only 27 percent of the total
funds expended as of the October date and may not be representative
of the population assisted with the remaining 73 percent of funds
expended since the program's inception.
Figure 2: Number of Persons
Receiving Housing Assistance
and Supportive Services
(Reflects Data From 1992
Through Oct. 7, 1996)
(See figure in printed
edition.)
Note: The information represents 27 percent of the HOPWA funds
expended.
Source: Grantees' annual progress reports received by HUD's Office
of HIV/AIDS Housing as of October 7, 1996.
The annual progress reports submitted by grantees collect information
on the characteristics of program participants who receive housing
assistance but do not collect data on participants who receive only
supportive services. Our analysis of the annual progress report data
available from HUD headquarters indicates that about 67 percent of
those who received housing assistance were adult males; those aged 31
to 50 accounted for almost 46 percent of the people assisted (see
fig. 3). The program participants generally had very low incomes:
About 70 percent had incomes below $500 per month (see fig. 4).
Over half of those who received housing assistance were living in
rental housing prior to receiving the HOPWA assistance (see fig. 5).
According to officials in HUD's Office of HIV/AIDS Housing, those
living in rental housing did not necessarily relocate upon receiving
HOPWA assistance; rather, they believe that the HOPWA housing
assistance likely helped these participants remain in their current
residences.
Figure 3: Percentage of
Program Participants by Gender
and Age Group (Reflects Data
From 1992 Through Oct. 7,
1996)
(See figure in printed
edition.)
Notes: The information represents only those participants receiving
housing assistance.
The information represents 27 percent of the HOPWA funds expended.
Source: Grantees' annual progress reports received by HUD's Office
of HIV/AIDS Housing as of October 7, 1996.
Figure 4: Gross Monthly Family
Incomes of Program Participants
(Reflects Data From 1992
Through Oct. 7, 1996)
(See figure in printed
edition.)
Notes: The information represents only those participants receiving
housing assistance.
The information represents 27 percent of the HOPWA funds expended.
Source: Grantees' annual progress reports received by HUD's Office
of HIV/AIDS Housing as of October 7, 1996.
Figure 5: Previous Living
Situations of HOPWA
Participants (Reflects Data
From 1992 Through Oct. 7,
1996)
(See figure in printed
edition.)
Notes: The information represents only those participants receiving
housing assistance.
"Other" includes situations reported as "other" by grantees as well
as those reported as domestic violence situations and psychiatric
facilities. The information represents 27 percent of the HOPWA funds
expended.
Source: Grantees' annual progress reports received by HUD's Office
of HIV/AIDS Housing as of October 7, 1996.
--------------------
\10 HOPWA-funded health services may be provided only to those with
HIV/AIDS and not to the family members of these individuals.
\11 HUD instituted the low-income limitation after concluding that
the HOPWA statute was somewhat ambiguous on whether eligible persons
must also be low-income. HUD noted that several provisions of the
HOPWA legislation restricted authorized activities to those that
benefited persons with AIDS who were homeless (or in danger of
becoming so) or low-income persons with AIDS. Taking these
provisions into account, as well as the fact that limited funds were
available for HOPWA, HUD decided to limit the program to low-income
individuals (those with incomes that do not exceed 80 percent of the
median income for the area) to help target the limited resources to
those with the greatest need. However, HOPWA funds may be used to
provide housing information services to people with HIV/AIDS and
their family members regardless of income, and any person living in
proximity to a HOPWA-funded community residence may participate in
that residence's community outreach and educational activities
regarding AIDS.
OPPORTUNITIES EXIST TO INCREASE
CONSISTENCY AND COORDINATION
BETWEEN HOPWA AND RYAN WHITE
PROGRAMS
------------------------------------------------------------ Letter :6
Neither the HOPWA nor the Consolidated Plan regulations specifically
require HOPWA grantees to coordinate with grantees under the Ryan
White CARE Act that provide services in the area. In contrast, the
CARE Act requires title I grantees, in planning the use of funds, to
include grantees under other federal HIV programs. Consistent with
the intent stated by the Senate Labor and Human Resources Committee
in its report on proposed Ryan White legislation in 1996, HHS has
interpreted the category "grantees under other Federal HIV programs"
to include representatives of any HOPWA grantees that provide
services in the area. The two sources of grant funds are similar to
some extent, in that both HOPWA and Ryan White grants may be used to
provide supportive services for people with HIV/AIDS; both may also
be used to provide housing assistance, although Ryan White grants may
be used only for limited housing services, such as housing referral
services or emergency housing assistance, but not for construction,
renovation, or continuing rental assistance.
According to officials in HUD's Office of HIV/AIDS Housing and in
HHS' Health Resources and Services Administration (HRSA),
coordination between HOPWA and Ryan White funding occurs primarily at
the grantee level, and the effectiveness of this coordination is
variable; some grantees coordinate the two sources of funds very
effectively, while other grantees do not coordinate as well. Our
discussions with several grantees and project sponsors support this
perception. Most of those we contacted were satisfied with the
coordination between HOPWA and Ryan White funds in their area, but
some believed that coordination needed improvement. According to the
AIDS Action Council, a Washington, D.C.-based advocacy group for
federal AIDS policy, it is important that the HOPWA and Ryan White
programs be coordinated, especially to the extent that grantees can
use the relatively scarce HOPWA funds to provide housing itself and
coordinate with the larger Ryan White program to provide services.
At the federal level, officials from the Office of HIV/AIDS Housing
and HRSA told us that coordination between the HOPWA and Ryan White
programs is basically informal but ongoing. For example, according
to officials in the Office of HIV/AIDS Housing, they interact with
HHS officials as part of the interdepartmental efforts among several
agencies to provide information on and improve the understanding of
AIDS and to help coordinate housing issues associated with AIDS.
According to the Office of HIV/AIDS Housing, HUD's communications
with HRSA have increased over the past couple of years. For example,
for fiscal year 1996 HUD and HHS entered into a joint initiative to
each target a portion of their fiscal year 1996 competitive grant
funds under the HOPWA and Ryan White programs, respectively, for
projects to assist homeless persons with multiple diagnoses of
HIV/AIDS, chronic substance abuse problems, and/or serious mental
illness. This HIV Multiple-Diagnoses Initiative is a collaborative
effort between HUD and HHS to establish, evaluate, and disseminate
information on model programs to integrate health care and other
supportive services with housing assistance. An HRSA official said
that this joint initiative was very useful in increasing
communication and coordination between the two agencies and that HUD
and HHS should continue to examine ways to undertake more such joint
initiatives. The AIDS Action Council agrees that the joint
initiative represents a good step toward increased coordination but
says that HUD and HRSA should further explore ways to work more
closely together because both types of assistance are critical needs
of the AIDS population. Several grantees and project sponsors we
contacted also agreed that the HOPWA and Ryan White programs could be
better coordinated.
One area in which the HOPWA and Ryan White programs differ is the
basis for determining funding eligibility and distribution. The
HOPWA funding formula distributes grant funds on the basis of an
area's cumulative number of AIDS cases since reporting began in 1981.
In considering amendments to the HOPWA program in 1992 (P.L.
102-550), the Senate Committee on Banking, Housing, and Urban Affairs
reported that the cumulative number of cases should serve as the
eligibility criteria, adding that this basis was consistent with the
way that the Ryan White CARE Act determined eligibility for its
formula distribution of funds. However, in 1996 the Congress passed
amendments to the Ryan White CARE Act, changing the title I and title
II funding formulas to reflect an area's estimated number of people
currently living with AIDS rather than cumulative cases. Prior to
the amendments, eligibility was based on the cumulative number of
cases since AIDS reporting began in 1981, over 60 percent of whom
have died. As we reported in 1995,\12 because the CARE Act formulas
included deceased persons, the areas that experienced the first
outbreak of AIDS were receiving substantially more per-case funding
than areas with a more recent growth in AIDS cases.
Although the CARE Act formulas now reflect more current estimates of
people with AIDS, excluding deceased persons, the HOPWA formula is
still based on cumulative cases. Eight of the 11 grantees and
project sponsors we contacted either supported the idea of changing
the HOPWA formula to reflect a more current measure of need, similar
to the recent changes under the CARE Act, or were indifferent to such
a change. Americans for a Sound HIV/AIDS Policy, which believes that
the current HOPWA formula distributes funds inequitably, also
supports the idea of changing the program's formula to reflect more
current needs.\13 In discussing possible modifications of the HOPWA
formula, officials in HUD's HIV/AIDS Housing Office pointed out that
there are several differences between the Ryan White CARE Act and
HOPWA programs and that any changes to HOPWA's formula should be
considered very carefully. According to officials in the HIV/AIDS
Housing Office, differences between the Ryan White CARE Act and HOPWA
programs that affect formula allocations include the number of AIDS
cases that triggers grant eligibility; HOPWA's mechanism for
distributing additional funds to metropolitan areas with a
higher-than-average per capita incidence of AIDS; the CARE Act's
mechanism for awarding supplemental funds to metropolitan areas; and
funding eligibility for states under the two programs. The officials
said that any change has the potential to shift funding between
communities, create instability or unpredictable results, and disrupt
the support needed to continue grantees' current efforts. We
recognize that differences between the two programs may make it
inappropriate to apply identical formulas to both programs and that
the effects of changes in the grantees' funding levels need to be
carefully considered. Nonetheless, in our view, the general
principle of allocating grants on the basis of the estimated number
of people living with AIDS, excluding those who are deceased, ensures
a more equitable allocation of the available funds and is a principle
that applies equally to both programs.
Another difference between the HOPWA and Ryan White programs is the
requirements on planning the use of funds. Under title I of the CARE
Act, eligible metropolitan areas must use a community planning body
to plan for the use of title I funds. The requirements for the
composition of these planning bodies are very specific, identifying
12 different parties that must be involved in the planning process,
including representatives of HOPWA grantees that provide services in
the area.\14 On the other hand, the HOPWA planning requirements are
more general in setting forth who should be included in the planning
process. According to HUD, the Consolidated Plan process involves
citizens in developing a plan for providing housing assistance and
services to people with HIV/AIDS and serves as a vehicle for
coordinating HOPWA with other affordable housing efforts. However,
on the basis of our discussions with grantees, project sponsors, and
other AIDS organizations, it appears that HUD's requirements may not
ensure that grantees involve and coordinate with all relevant parties
in planning the use of program funds.
Along these lines, a representative of AIDS Housing of Washington,
the recipient of a HOPWA grant to provide technical assistance to
other AIDS housing organizations, noted that although one of HOPWA's
most positive aspects is its flexibility that allows jurisdictions a
great deal of latitude in implementing the program, this same
flexibility and local latitude have permitted some jurisdictions to
administer the program less effectively than they otherwise might.
Similarly, the AIDS Action Council believes that HUD's requirements
lack oversight and accountability mechanisms to ensure that a
jurisdiction's HOPWA planning is actually meaningful and involves the
proper parties. The Council advocates mandating that the HOPWA
planning process be more inclusive, much as the Ryan White statute
requires inclusive representation on title I planning councils. Of
the 11 grantees and project sponsors we contacted, 7 either agreed
that HOPWA's requirements for planning the use of funds and
coordinating with other sources of AIDS assistance are not specific
enough or said that, although the general requirements have had no
negative effects in their particular area, adding more specific
requirements could be helpful for the program as a whole.\15
--------------------
\12 Ryan White CARE Act of 1990: Opportunities to Enhance Funding
Equity (GAO/HEHS-96-26, Nov. 13, 1995).
\13 The other three grantees and project sponsors opposed a formula
change for reasons such as (1) satisfaction with the current formula
and (2) concern that some areas would be "winners" but others would
be "losers" if the funding formula were changed.
\14 The Ryan White legislation requires that title I HIV health
services planning councils include at least one representative from
each of 12 membership categories, including health care providers;
community-based organizations serving affected populations; social
service providers; mental health and substance abuse providers; local
public health agencies; hospital planning agencies; affected
communities, including individuals with HIV/AIDS and historically
underserved groups; non-elected community leaders; state government;
grantees under other titles of the CARE Act; and grantees providing
services in the area under other federal HIV programs, which HHS has
interpreted to include HOPWA.
\15 Three of the other four grantees and project sponsors said that
the current requirements have been specific enough, in their
experience. The fourth was unfamiliar with HOPWA's planning
requirements and could not give an opinion, because the grantee
follows the more stringent title I requirements to plan the use of
HOPWA funds as well as CARE Act funds.
OVERSIGHT OF PROGRAM
ADMINISTRATION AND MONITORING
------------------------------------------------------------ Letter :7
Fiscal year 1997 is the first year of a new grants management system
for HOPWA and three other formula grant programs administered by
HUD's Office of Community Planning and Development. According to
HUD, this new system is intended to address material weaknesses in
overall program management identified by us and HUD's Inspector
General and to respond to the Government Performance and Results Act
of 1993, which requires agencies to develop and document performance
standards and outcomes for their programs. According to HUD, the new
system seeks to strike a balance between ensuring compliance with
program requirements and helping grantees achieve a high level of
performance to serve their clients. While in the past HUD saw its
grant management responsibilities primarily as helping communities
understand requirements for programs and monitoring to ensure they
complied with the requirements, the new process is intended to
emphasize a more collaborative approach, including up-front
assistance, to help grantees achieve their objectives and to help
them identify and solve problems.
HUD's field offices have the primary responsibility for evaluating
and validating grantees' performance through a process that HUD calls
performance-based program management. While the process uses
techniques and approaches already used by the field staff, the new
system is designed to work in conjunction with the Office of
Community Planning and Development's (CPD) Consolidated Plan process,
to put more emphasis on continuous evaluation throughout a grantee's
program year and to take better advantage of existing opportunities
to raise performance issues and document their resolution. HUD's
guidance outlines a number of opportunities that field staff have to
assess grantees' performance, and the guidance encourages field
offices to exercise discretion and flexibility in all aspects of
their management of CPD grant programs. HUD's guidance lists the
following opportunities that field staff have to assess
performance:\16
-- Review and assessment of a grantee's Consolidated Plan. As
previously discussed, grantees must submit these plans to apply
for and receive CPD grants. The plans are intended to establish
a community-based strategy for using CPD grants and other
resources to address community needs.
-- Review of information and reports from CPD's new Integrated
Disbursement and Information System (IDIS). This system is
intended to provide information on critical grant performance
indicators, such as grant drawdowns, the number and
characteristics of the people served, and the program's
benefits. Once fully implemented, probably sometime during
fiscal year 1998, it will replace the requirement for the
recipients of HOPWA formula grants to submit annual progress
reports. However, the recipients of HOPWA competitive grants
will continue to use annual progress reports.
-- The annual community assessment. This is HUD's annual
assessment of each grantee's performance to determine whether
the grantee has carried out its planning and grant activities
and has reported in accordance with the statutory requirements.
-- On-site monitoring. HUD's guidance states that on-site
monitoring remains a key vehicle for validating information and
evaluating performance, but it acknowledges that limited
resources prevent CPD staff from conducting on-site monitoring
of each grantee on a routine basis.
-- Consultation. HUD's guidance points out that consultation with
local officials and program participants helps CPD staff to
evaluate the grantees' performance, provides an opportunity for
HUD to convey its observations and conclusions, and provides an
occasion to identify technical assistance needs.
The Field Management Division, a part of CPD's Office of Executive
Services at HUD headquarters, is responsible for overseeing CPD
functions at HUD's field offices. Among other duties, this Division
provides direction to the field offices on how they should monitor
the CPD grant programs and how they should provide technical
assistance to grantees. The Field Management Division has seven
field management officers who serve as principal advisers to HUD's
Assistant Secretary for Community Planning and Development on all
matters related to the administration and management of the CPD
programs. Each of these field management officers is responsible for
monitoring performance in 5 to 7 of HUD's 43 CPD field offices.
--------------------
\16 The HOPWA grantees are also subject to the Single Audit Act (31
U.S.C. 7501-7507). In general, this act requires state or local
governments that receive $300,000 or more a year in federal financial
assistance to be audited at least annually. The audit must be made
by an independent auditor in accordance with generally accepted
government auditing standards. These audits provide HUD with another
source of information on grantees' performance.
PROGRAM DIRECTORS' HAVE
CONCERNS ABOUT MONITORING
---------------------------------------------------------- Letter :7.1
Our recent work to update the status of HUD as a "high-risk" area\17
found several concerns about monitoring activities among the CPD
program directors in HUD's field offices. We asked the directors for
their perspectives on a wide range of corrective actions that HUD had
taken over the last 2 years. Forty-one percent of the CPD directors
we surveyed said that headquarters' emphasis on completing essential
monitoring was low, and about 59 percent believed that headquarters'
emphasis should be higher. While 91 percent of the CPD directors
said that their staffs had conducted on-site inspections during the
preceding year, 66 percent believed that the amount of on-site
inspections should be increased. (The majority of CPD directors were
satisfied with the existing levels of other types of monitoring, such
as telephone inquiries and review of records and documents submitted
by grantees.) CPD directors cited the lack of staff and travel funds
as the biggest reasons why levels of monitoring activity were lower
than they should be.\18
--------------------
\17 We began a special effort in 1990 to review and report on the
federal program areas we considered high-risk because they were
especially vulnerable to waste, fraud, abuse, and mismanagement.
HUD, as an agency, has been designated as one of our high-risk areas
since January 1994. For our latest update, see High-Risk Series:
Department of Housing and Urban Development (GAO/HR-97-12, Feb.
1997).
\18 The complete results of the survey are reported in HUD: Field
Directors' Views on Recent Management Initiatives (GAO/RCED-97-34,
Feb. 12, 1997).
HUD COULD IMPROVE ITS USE OF
INFORMATION FROM GRANTEES'
ANNUAL PROGRESS REPORTS
---------------------------------------------------------- Letter :7.2
In our current work, we found that HUD headquarters has not been
using performance data that the grantees provide in annual progress
reports as a basis for the Department's reporting of HOPWA's overall
accomplishments. Grantees must submit annual progress reports to HUD
field offices within 90 days after the end of their operating year.
The data required in the reports include (1) the number of persons
with HIV/AIDS receiving housing services, supportive services, and
housing information services; (2) descriptive information on those
who received housing assistance, such as age, gender, income, and
previous living situation; (3) information on the available HOPWA
funds and breakouts of how much was spent in various categories of
assistance; and (4) the number and size of housing units assisted.
The field offices are instructed to review the reports as soon as
possible after receipt to determine if the grantee's program is
achieving results, to identify actions HUD should take on the basis
of the grantee's description of barriers and recommendations for
change, to detect inconsistencies between the reported information
and what the grantee proposed to do, and to identify areas in which
the grantee could benefit from technical assistance.
While, according to HUD, the annual progress report was designed
primarily to be a tool for the field offices' oversight of grantees,
the field offices are also to send copies of these reports to HUD
headquarters for entry into a centralized database, which is intended
to generate statistics about the agency's progress in assisting
persons with HIV/AIDS and their families to obtain appropriate
housing assistance and supportive services. However, to date, HUD
has reported information on the HOPWA program's activities primarily
from the grantees' descriptions of planned activities, as contained
in grant applications and Consolidated Plan reports, rather than from
the accomplishments reported in the annual progress reports. For
example, CPD's 1996 annual report to the Congress includes an exhibit
showing the percentage of HOPWA formula grant funds that 1994
grantees used for each eligible program activity. These data,
however, reflect planned (rather than actual) uses of funds, as
described by the grantees in their 1994 funding applications.
Commenting on our analysis of the grantees' annual progress reports,
officials in HUD's Office of HIV/AIDS Housing said they believed that
the planned uses reflected the actual uses of funds.
We also found that HUD headquarters has no system to track when the
annual progress reports are due and whether they are received and
processed in a timely manner. As a result, there is no ready way of
determining how many or which reports may be late. However, HUD
headquarters officials recently estimated that 36 of 110 HOPWA annual
progress reports (covering funds awarded in fiscal years 1992, 1993,
and 1994) were past due as of October 7, 1996. Of the 36 overdue
reports, 16 were for fiscal year 1992 grant recipients, 7 were for
fiscal year 1993 recipients, and 13 were for fiscal year 1994
recipients. As previously discussed, the annual progress reports
that were available centrally at headquarters as of that same date
reflected only about 27 percent of the HOPWA funds that HUD reported
that the grantees had spent. While this difference is partially
explained by the time lag between when a grantee spent the funds and
when the next annual progress report was due, the overdue reports
were also a major factor.
HUD IS IMPLEMENTING A NEW
REPORTING SYSTEM
---------------------------------------------------------- Letter :7.3
HUD's new Integrated Disbursement and Information System (IDIS) will,
in the future, replace most current CPD's grantee reporting
requirements. IDIS is an on-line computer system through which
grantees draw down funds against their grants and report
accomplishments. HUD intends that the system simplify and streamline
grant management for the participants and facilitate comparing and
reporting to the Congress on the activities and accomplishments of
CPD's four grant programs. Once a recipient of a HOPWA formula grant
is operational on IDIS, it no longer has to submit annual progress
reports. However, the recipients of HOPWA's competitive grants will
continue to use annual progress reports.
IDIS requires the grantees to report much of the same accomplishment
data as required in the annual progress reports. However, HUD
believes IDIS offers the advantage of being able to provide more
current information. Rather than waiting until the end of the year
to file an annual progress report, once the grantees are on IDIS, HUD
officials said they will expect the grantees to update the HOPWA
accomplishment information at least quarterly to keep it current. We
noted, however, that HUD's guidance to grantees does not clearly
state this expectation, stating only that the information should be
updated "periodically" or "as of the end of the program year." Also,
it is not yet clear how HUD plans to ensure that the grantees keep
the accomplishment data current. According to a HUD official who is
leading the development of the IDIS software, the system can tell
when grantees enter data, but it does not as yet generate a report
that would show whether or not grantees have met the expectation for
quarterly updates.
As of January 1997, HUD was in the process of training CPD grantees
on the use of IDIS and bringing the grantees on-line as they are
ready. Of the approximately 950 entities that will eventually be
using IDIS, 135 were on-line as of that time, mostly small to
moderately sized communities, according to HUD. HUD's goal is to
have all CPD grantees using the system by the end of fiscal year 1997
(Sept. 30, 1997), but officials acknowledge that there may be a few
grantees that come on later in the next fiscal year, either because
they lack the technical capacity to implement IDIS or because they
are new grantees that have not yet established their HOPWA programs.
HUD officials note that the HOPWA program is administered primarily
by the larger cities and by state governments, which often must
select a variety of sponsors and serve geographically different
communities and therefore may take longer than other grantees to
convert to IDIS. For these reasons, it is difficult to predict when
all of the HOPWA formula grantees will be using IDIS. Because it may
take some time for all HOPWA formula grantees to fully convert to
IDIS, it will remain important that HUD headquarters be able to track
the receipt and processing of their annual progress reports for as
long as they are filed. Because the HOPWA competitive grantees will
continue using the annual progress reports to provide performance
information, a system for tracking the receipt of these reports will
also be important.
CONCLUSIONS
------------------------------------------------------------ Letter :8
While the legislative amendments enacted in 1996 changed the Ryan
White programs' formulas to allocate funds on the basis of the
estimated number of people currently living with AIDS, the HOPWA
formula continues to be based on the cumulative number of AIDS cases
since 1981. As we noted in a November 1995 report on the Ryan White
programs, such an allocation formula can result in funding inequities
because it includes those who have died and no longer need services.
While we recognize that because of the differences between the HOPWA
and Ryan White programs, it may not be appropriate to use precisely
the same formula for both, we believe the principle of allocating
funds on the basis of those currently living with AIDS applies to
HOPWA as well as to Ryan White grants.
HOPWA's requirements governing how grantees are to coordinate with
other parties when planning the use of grant funds are much less
explicit than the coordination requirements under the Ryan White
title I program. Whereas the Ryan White program's requirements
identify the specific parties with whom grantees must coordinate,
HOPWA's regulations are relatively general in this area, thus
providing less assurance that grantees involve and coordinate with
all relevant parties. In our view, revising the HOPWA requirements
along the lines of those that exist under the Ryan White title I
program would provide greater assurance that all affected parties
have a voice in determining how the HOPWA funds are to be used.
Although the HOPWA grantees are required to make annual progress
reports to HUD, the agency has not used the information from these
reports to generate programwide analyses of HOPWA's accomplishments.
As a result, HUD has relied primarily on planned, rather than actual,
activities when reporting to the Congress and other interested
parties on the program's accomplishments. HUD headquarters also has
not established a system to track the receipt of these reports. For
this reason, HUD headquarters has no ready way of knowing whether it
has received all the reports that are due and, thus, that it has the
most complete, up-to-date information available about the grantees'
use of funds. Although the new IDIS should eventually replace the
annual progress reports for formula grantees, this system may take
some time to be fully implemented, and competitive grantees will
continue to use the annual progress reports rather than IDIS to
report on their performance. While IDIS offers the potential for
providing more current information on the HOPWA grantees' actual
accomplishments, thus far HUD's guidance on the new system does not
clearly communicate to grantees how frequently HUD expects them to
update accomplishment information, and it is unclear how HUD will
ensure that grantees keep this information current.
RECOMMENDATIONS
------------------------------------------------------------ Letter :9
To help ensure that the HOPWA funds are allocated to grantees as
equitably as possible and that grantees involve all relevant parties
in planning the use of these funds, and to promote greater
consistency and coordination between the HOPWA and Ryan White
programs, we recommend that the Secretary of HUD direct the Assistant
Secretary for Community Planning and Development to (1) examine the
changes to the funding formulas under titles I and II of the 1996
Ryan White CARE Act amendments, determine what legislative revisions
are needed to make the HOPWA formula more reflective of current AIDS
cases, and make appropriate recommendations to the Congress and (2)
specify the representatives that the grantees must include in
planning the use of the HOPWA funds, similar to the CARE Act title I
planning requirements.
To better assess HOPWA's overall accomplishments and to ensure the
effective use of the annual progress reports required of the HOPWA
grantees, we recommend that the Secretary of HUD direct the Assistant
Secretary for Community Planning and Development to implement a
procedure, such as a tracking system, to ensure that all reports are
received and processed by HUD in a timely manner.
To ensure that IDIS, the new reporting system for the grantees,
provides current accomplishment information for the HOPWA grants, we
recommend that the Secretary of HUD direct the Assistant Secretary
for Community Planning and Development to clearly state in guidance
to the grantees the requirements for updating the information and
establish a means of ensuring that the grantees update the
information as required.
AGENCY COMMENTS AND OUR
EVALUATION
----------------------------------------------------------- Letter :10
We provided a draft copy of this report to HUD for its review and
comment. While not disagreeing with the facts presented, HUD
believed that the report presented information in a manner that
understates grantees' performance on the timely expenditure of funds
and on reporting on their accomplishments. The information we
presented showed that grantees had expended 37 percent of the total
funds appropriated since fiscal year 1992 and that grantees' reports
describing their use of program funds that were available from HUD's
Office of HIV/AIDS Housing as of October 7, 1996, covered only 27
percent of the funds that grantees had expended during that time.
HUD's comments point out that grantees had, for example, used 95
percent of fiscal year 1992 funds and 85 percent of fiscal year 1993
funds. The comments also assert that over $103.5 million of the
HOPWA funds were spent between January 24, 1996, and October 7, 1996,
and that only a small portion of these expenditures would have been
required or contained in the annual progress reports HUD provided us.
The information we presented on grantees' use of program
appropriations was not intended to criticize the timeliness of
grantees' spending of funds, but rather to put into perspective the
data reported on funded activities and program participants. Our
report points out that HUD allows grantees 3 years to spend program
funds and that several factors may delay expenditures. In connection
with grantees' reporting of expenditures, our report recognizes that
the low percentage of funds covered in the annual progress reports
was due, in part, to the fact that grantees' reports covering some
expenditures were not yet due. However, we note that HUD does not
dispute the fact that a substantial number of reports were overdue.
HUD generally concurred with our recommendations. In commenting on
the recommendation that the Department examine changes needed to make
the HOPWA funding formula more reflective of current AIDS cases, HUD
stated that it will consider alternative formula constructions and
make a recommendation to the Congress. However, HUD noted that there
are several differences between the HOPWA statute and the CARE Act,
especially in their levels of funding, and that even small changes to
HOPWA's current allocation formula could adversely affect ongoing
programs by making a number of current grantees ineligible for future
funding. Our report acknowledges that there are differences between
the programs and, accordingly, does not suggest that precisely the
same formula should be used for both. We also believe that the lower
level of funding for the HOPWA program heightens the importance of
allocating those funds to the communities with the greatest need,
which we believe is better measured by estimates of those still
living with AIDS than by estimates of the cumulative cases of AIDS.
In response to our recommendation that the Department specify the
representatives that the grantees must include in planning the use of
HOPWA funds, HUD stated that such prescriptive requirements would be
inconsistent with its goal of involving a broad cross-section of the
community to discuss the whole of a community's housing needs. We
disagree. Any such requirements should set forth only the minimum
standards that grantees must meet and would not minimize the
importance of involving as broad a cross-section of the community as
possible. Appendix I contains HUD's complete comments and our
evaluation of them.
--------------------------------------------------------- Letter :10.1
We conducted our review from August 1996 through February 1997 in
accordance with generally accepted government auditing standards.
(See app. II for a discussion of our scope and methodology.)
We are sending copies of this report to the appropriate congressional
committees; the Secretary of HUD; the Director, Office of Management
and Budget; and other interested parties. We will also make copies
available to others upon request.
Please call me on (202) 512-7631 if you or your staff have any
questions. Major contributors to this report are listed in appendix
III.
Lawrence J. Dyckman
Associate Director, Housing and
Community Development Issues
(See figure in printed edition.)Appendix I
COMMENTS FROM THE DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT
============================================================== Letter
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GAO COMMENTS
----------------------------------------------------------- Letter :11
The following are GAO's comments on the Department of Housing and
Urban Development's letter dated February 25, 1997.
1. Our report is not intended to criticize the timeliness of
grantees' spending but presents information on the program's total
appropriations and expenditures to put into perspective the data
reported on funded activities and the program's participants. Our
report points out that there are several reasons why grantees have
not fully expended program funds.
2. HUD states that the information available is reflective of the
use of program funds by all grantees because the data represent
different grantees by geographic location, size, and type. However,
HUD notes that it is not a statistical sample. As such, there is no
way of knowing to what extent the available data accurately reflect
the use of all program funds, and whether other grantees' data could
indicate different results.
3. Our report recognizes that the low percentage of funds covered in
the annual progress reports occurred, in part, because grantees'
reports covering some expenditures were not yet due. Nevertheless,
HUD does not dispute the fact that a significant number of reports,
dating back to fiscal year 1992, are overdue.
4. Our report acknowledges the differences between the HOPWA and
CARE Act programs and for this reason recommends that HUD consider
the issue and identify appropriate changes to make the formula more
reflective of current AIDS cases. We did not recommend that the
HOPWA and CARE Act formulas be the same. We also note that the lower
level of funding for the HOPWA program heightens the importance of
allocating those funds to the communities with the greatest need,
which is better measured by estimates of those still living with AIDS
than by estimates of cumulative cases of AIDS.
5. While agreeing with our recommendation, HUD's response suggests
that identifying specific representatives that grantees must include
in planning the use of HOPWA funds would be inconsistent with the
goal of involving a broad cross-section of the community to discuss
the whole of a community's housing needs. In our view, however, any
such requirements would set forth only the minimum standards that
grantees must meet; grantees clearly should be encouraged to go
beyond these standards to involve as broad a cross-section of the
community as possible. Additionally, our report does not recommend
that HUD specify precisely the same participants as required by title
I of the CARE Act, but only that the HOPWA planning requirements be
made more specific, as they are under the CARE Act. HUD's
requirements could include whichever parties it deems relevant.
Furthermore, while HUD states that the consolidated plan process
involves the larger housing community (public and private entities
that create, develop and/or manage housing resources within each
community), we note that HOPWA is the only program under the process
that addresses housing within the context of a specific health issue
and that, as such, it may benefit from specific requirements beyond
those set forth for all programs in general under the consolidated
planning process.
6. We have clarified the report to indicate that the statements
referring to supportive services provided independent of housing
assistance refer specifically to the services provided independent of
HOPWA-funded housing assistance.
OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================== Appendix II
As requested by the Subcommittee on VA, HUD and Independent Agencies,
House Committee on Appropriations, we reviewed five aspects of the
Department of Housing and Urban Development's Housing Opportunities
for Persons with AIDS (HOPWA) program: (1) what the rationale is for
having a housing program within HUD specifically for people with
AIDS, (2) the kinds of activities funded through the program, (3)
whom the program is serving, (4) how the program is coordinated with
the Department of Health and Human Services' (HHS) Ryan White AIDS
assistance programs, and (5) how HUD headquarters oversees the
program's administration and monitoring. As requested, we also
obtained background information on how the program works.
We obtained information on the rationale for having a housing program
within HUD specifically for people with AIDS from HOPWA's authorizing
legislation (the National Affordable Housing Act of 1990 (P.L.
101-625), as amended) and its legislative history. To determine to
what extent the factors used to originally support the need for the
program still exist, we reviewed data on the housing needs of persons
with AIDS compiled by AIDS Housing of Washington (the recipient of a
1995 HOPWA competitive grant to provide technical assistance to AIDS
housing developers nationally) and by the National Commission on
AIDS, and we obtained the views of a mix of parties that either
support or question the continuation of the HOPWA program: (1)
officials in the HUD headquarters Office of HIV/AIDS Housing; (2)
staff from HHS' Health Resources and Services Administration (HRSA);
(3) officials from HUD's field offices in Fort Worth, Texas, and
Chicago, Illinois; (4) staff representing 11 HOPWA grantees and
project sponsors;\19 (5) a representative from the AIDS Action
Council; (6) an official from the Heritage Foundation; and (7) an
official from Americans for a Sound AIDS/HIV Policy.
To identify the activities funded by HOPWA and whom the program is
serving, we analyzed a database compiled by HUD's Office of HIV/AIDS
Housing, which contains information from the annual progress reports
submitted by the HOPWA grantees. We also obtained hard copies of the
annual progress reports that had been received by the Office of
HIV/AIDS Housing as of October 7, 1996. We verified the information
that we used from the database against these reports and made
necessary corrections to the database in order to perform our
analysis. We did not verify the accuracy of the information the
grantees provided in the reports.
We obtained background information on how the HOPWA program works and
determined how funds are distributed by reviewing HUD's regulations
and written procedures, focusing on the process by which eligible
states and metropolitan areas apply for funds and the process by
which HUD allocates funds for both formula and competitive grants.
We also obtained views on possible improvements to the process for
allocating formula grants from HUD's Office of HIV/AIDS Housing,
Americans for a Sound AIDS/HIV Policy, and the 11 HOPWA grantees and
project sponsors that we contacted. We also used information from a
previous report that we issued on the funding allocation formulas for
HHS's Ryan White programs.\20
To obtain information on how HOPWA is coordinated with HHS' Ryan
White programs, we reviewed the coordination requirements in the
authorizing legislation and regulations for both programs. We also
obtained information on the level and effectiveness of coordination
from HUD's Office of HIV/AIDS Housing, HRSA, the 11 HOPWA grantees
and project sponsors that we contacted, and the AIDS Action Council.
To obtain information on how HUD headquarters oversees the program's
administration and monitoring, we reviewed the regulations and
guidance that prescribe the field offices' responsibilities for
evaluating grantees' performance and headquarters' responsibilities
for monitoring and overseeing the field offices' functions. We did
not review how the field offices have carried out their
responsibilities for monitoring grantees. We did, however, draw
information from a GAO telephone survey conducted in August 1996 of
those serving as directors of major programs in HUD's 40 largest
field offices (in terms of staffing). We asked officials responsible
for managing HOPWA and other Community Planning and Development grant
programs to assess the adequacy of the field offices' monitoring of
grantees. We reviewed HUD's regulations and guidance on
headquarters' and field offices' responsibilities for tracking and
using annual performance reports that grantees submit to HUD. We
also discussed HUD headquarters' and field offices' responsibilities
with HUD's Office of HIV/AIDS Housing and Field Management Office.
--------------------
\19 We selected these 11 grantees and project sponsors from a list of
suggested AIDS housing representatives provided by HUD's Office of
HIV/AIDS Housing. We selected several who were members of the Board
of Directors of the National AIDS Housing Coalition to provide a
broader, national perspective, and others to provide a more local
perspective. We also selected local grantees and project sponsors in
Dallas and Fort Worth, Texas, and Chicago, Illinois, on the basis of
their proximity to the GAO staff performing the work. The total
number of the HOPWA grantees and project sponsors is difficult to
quantify because grantees can change from year to year, and each
grantee may have multiple project sponsors; however, about 93
jurisdictions received formula grants for fiscal years 1992 through
1996, in addition to 81 competitive grants awarded during that time.
\20 Ryan White CARE Act of 1990: Opportunities to Enhance Funding
Equity (GAO/HEHS-96-26, Nov. 13, 1995).
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III
HOUSING AND COMMUNITY DEVELOPMENT
ISSUE AREA
Richard A. Hale
Leigh K. Ward
Andy C. Clinton
Woodliff L. (Skip) Jenkins, Jr.
DESIGN, METHODOLOGY, AND TECHNICAL
ASSISTANCE GROUP
Luann M. Moy
OFFICE OF THE GENERAL COUNSEL
John T. McGrail
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