Public Housing: Impact of Designated Public Housing on Persons With
Disabilities (Letter Report, 06/09/98, GAO/RCED-98-160).

Pursuant to a legislative requirement, GAO reviewed: (1) the impact of
the Housing and Community Development Act of 1992 on the availability of
public housing for persons with disabilities; (2) how incremental
Section 8 certificates and vouchers that were made available since the
passage of the 1992 act were assisting persons with disabilities seeking
affordable rental housing; and (3) the number of households that may
meet the Department of Housing and Urban Development's (HUD) definition
for persons with disabilities.

GAO noted that: (1) provisions of the Housing and Community Development
Act of 1992 allowing public housing authorities to designate units as
elderly-only have had little impact on the availability of public
housing for people with disabilities; (2) 73 of the 3,200 public housing
authorities had allocation plans approved by HUD as of November 1, 1997,
allowing them to designate 24,902 of their units as elderly-only,
approximately 36 percent of their housing stock for the elderly and
persons with disabilities; (3) nearly all of these designated units had
been available previously to tenants who were elderly or who had
disabilities but were younger than 62; (4) the number of elderly
residents and residents with disabilities in these and other housing
units for which they were eligible had not changed substantially since
the housing authorities began submitting allocation plans; (5) the
number of younger tenants with disabilities living in housing designated
for the elderly had declined by about 1,100 at the 53 housing
authorities that provided complete occupancy data; (6) designating
public housing units as elderly-only may have more impact in the future,
depending on how many more housing authorities opt to do so and on what
the housing alternatives are for younger people with disabilities; (7)
it is too soon to determine the extent to which the Section 8 rental
certificates and vouchers set aside for persons with disabilities have
helped meet housing needs; (8) of approximately 3,000 certificates and
vouchers that were available to housing authorities November 1, 1997,
the authorities reported that they issued about 1,600 to persons with
disabilities who used 1,162 to obtain private rental housing; (9) about
18 percent of the users had been living in public housing that had been
designated for the elderly--indicating little movement by persons with
disabilities residing in housing now designated as elderly-only; (10)
how successful rental certificates and vouchers will be in providing
housing alternatives for people with disabilities will be influenced by
several factors, including statutory restrictions, local housing
markets, and willingness of tenants with disabilities to use
certificates and vouchers; and (11) according to housing authorities,
those persons with disabilities who used certificates and vouchers
required greater assistance than other recipients.

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

 REPORTNUM:  RCED-98-160
     TITLE:  Public Housing: Impact of Designated Public Housing on 
             Persons With Disabilities
      DATE:  06/09/98
   SUBJECT:  Persons with disabilities
             Housing for the elderly
             Housing for the disabled
             Public housing
             Housing programs
             Rent subsidies
             State-administered programs
             Statistical data
             Elderly persons
IDENTIFIER:  HUD Section 8 Certificate Program
             HUD Section 8 Voucher Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

June 1998

PUBLIC HOUSING - IMPACT OF
DESIGNATED PUBLIC HOUSING ON
PERSONS WITH DISABILITIES

GAO/RCED-98-160

Housing for Persons With Disabilities

(385693)


Abbreviations
=============================================================== ABBREV

  ADL - activity of daily living
  ASPE - Office of the Assistant Secretary for Planning and
     Evaluation
  FMR - fair market rents
  HHS - Department of Health and Human Services
  HUD - Department of Housing and Urban Development
  IADL - instrumental activity of daily living
  MR/DD - mental retardation or other developmental disabilities
  NHIS - National Health Interview Survey
  PHA - public housing authority
  SSI - Supplemental Security Income
  TVRHA - Tennessee Valley Regional Housing Authority
  USDA - U.S.  Department of Agriculture
  VA - Department of Veterans Affairs

Letter
=============================================================== LETTER


B-279436

June 9, 1998

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 Honorable Rodney Frelinghuysen
House of Representatives

Until 1992, all housing authorities were obligated by law to provide
equal access to units in developments known as "elderly buildings" to
both persons aged 62 or older and persons with disabilities,
regardless of age.  The Housing and Community Development Act of
1992, among other things, allowed public housing authorities, through
allocation plans approved by the Department of Housing and Urban
Development (HUD), to designate these units for either or both types
of tenants.  While elderly persons with disabilities remained
eligible for elderly-only housing, younger persons with disabilities
were no longer eligible to move into those buildings and needed other
housing options.\1 To provide options, HUD set aside incremental
(new) Section 8 rental housing certificates and vouchers for
low-income persons with disabilities.\2 The Congress appropriated $50
million for fiscal year 1997 and $40 million for fiscal year 1998 for
incremental certificates and vouchers for the exclusive use of
persons with disabilities.  Of the $90 million, $45 million was
earmarked for housing authorities with approved allocation plans, and
$45 million was earmarked for housing authorities that could identify
the impact on persons with disabilities of elderly-only preferences
established by privately owned projects in their communities. 

Concerned about the availability of housing for low-income persons
with disabilities who can no longer move into public housing
apartments that have been designated for the elderly, the
Subcommittee on VA, HUD, and Independent Agencies of the House
Committee on Appropriations directed us, in its July 11, 1997, report
(H.  Rep.  105-175) accompanying the fiscal year 1998 VA, HUD, and
Independent Agencies appropriations bill, to undertake a study. 
Specifically, the Subcommittee asked us to assess (1) the impact of
the Housing and Community Development Act of 1992 on the availability
of public housing for persons with disabilities and (2) how
incremental Section 8 certificates and vouchers that were made
available since the passage of the 1992 act were assisting persons
with disabilities seeking affordable rental housing.\3 As requested,
we also developed estimates of the number of households that may meet
HUD's definition for persons with disabilities.  Appendix I describes
in depth the methodology used to determine the size of this
population and HUD's definition for persons with disabilities. 

To obtain information for this report, we surveyed, out of the 3,200
housing authorities nationwide, all 96 housing authorities that
either had HUD-approved allocation plans or received certificates or
vouchers for the exclusive use of persons with disabilities as of
November 1, 1997.  All 96 housing authorities responded to our
survey.  We supplemented the survey results by conducting six case
studies at housing authorities around the country.  We also
interviewed housing officials at the federal and local levels as well
as representatives of national associations of persons with
disabilities and the elderly.  Our methodology is described further
in appendix II.  Our case study analyses appear in appendix III. 


--------------------
\1 Public housing authorities may not force tenants with disabilities
to move out of units they subsequently designate as being only for
elderly residents. 

\2 Persons using Section 8 certificates and vouchers pay a portion of
their income--usually 30 percent--toward renting a privately owned
apartment that meets HUD's rent requirements and housing quality
standards.  HUD generally pays the difference between the tenant's
portion and the total rent charged for a unit or a rent standard
established by HUD, in the case of vouchers. 

\3 The Subcommittee also requested that we assess the impact of the
1992 act on the availability of privately owned, HUD-subsidized
rental housing for low-income persons with disabilities.  We will
issue a separate report on those findings. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The provisions of the Housing and Community Development Act of 1992
allowing public housing authorities to designate units as
elderly-only have had little impact on the availability of public
housing for people with disabilities.  Seventy-three of the 3,200
public housing authorities had allocation plans approved by the
Department of Housing and Urban Development as of November 1, 1997,
allowing them to designate 24,902 of their units as elderly-only,
approximately 36 percent of their housing stock for the elderly and
persons with disabilities.  Nearly all of these designated units had
been available previously to tenants who were elderly or who had
disabilities but were younger than 62, although few were actually
occupied by younger people with disabilities.  Our survey found that,
as of November 1, 1997, the number of elderly residents and residents
with disabilities in these and other housing units for which they
were eligible had not changed substantially since the housing
authorities began submitting allocation plans.  The number of younger
tenants with disabilities living in housing designated for the
elderly had declined by about 1,100--or about 25 percent--at the 53
housing authorities that provided complete occupancy data. 
Designating public housing units as elderly-only may have more impact
in the future, depending on how many more housing authorities opt to
do so and on what the housing alternatives are for younger people
with disabilities. 

It is too soon to determine the extent to which the Section 8 rental
certificates and vouchers set aside for persons with disabilities
have helped meet this population's housing needs.  Although 59
housing authorities reported that they received 4,943 certificates
and vouchers, about 1,900 certificates and vouchers had just been
made available to the housing authorities as of November 1, 1997. 
The authorities had not had enough time to issue them to eligible
persons with disabilities.  Of the approximately 3,000 certificates
and vouchers that were available to housing authorities as of
November 1, 1997, the authorities reported that they issued about
1,600 to persons with disabilities who, in turn, used 1,162 to obtain
private rental housing.  About 18 percent of the users had been
living in public housing that had been designated for the
elderly--indicating little movement by persons with disabilities
residing in housing now designated as elderly-only.  The other 82
percent had been on waiting lists for public housing or for Section 8
rental certificates and vouchers.  How successful rental certificates
and vouchers will be in providing housing alternatives for people
with disabilities will be influenced by several factors, including
statutory restrictions, local housing markets, and the willingness of
tenants with disabilities to use the certificates or vouchers. 
Moreover, according to the housing authorities, those persons with
disabilities who used certificates and vouchers to find housing
required greater assistance than other recipients. 


   BACKGROUND
------------------------------------------------------------ Letter :2

The definition of "elderly families" used to determine eligibility
for certain public housing has evolved over time.  Until 1992, the
term encompassed low-income families whose head, spouse, or sole
member was aged 62 or older, as well as low-income individuals with
disabilities, regardless of age.  All housing authorities were
obligated by law to provide equal access to units in developments
known as "elderly buildings" to both elderly persons and persons with
disabilities.  These developments usually consisted of efficiencies
and one-bedroom units rather than the multiple-bedroom units typical
of family housing. 

As the number of younger persons with disabilities residing in
"elderly housing" increased, the complaints from their elderly
neighbors also increased.  Elderly residents cited the differences in
values and lifestyles they had with the younger residents as
impediments to safe and decent housing for the elderly.  In 1992, we
reported that nonelderly tenants with mental disabilities occupied
between 8 and 10 percent of the units in public housing for the
elderly, but were, according to public housing authorities (PHA),\4
causing a disproportionate share of problems for the elderly
residents as well as for the PHAs' management and staff.\5

Problems included complaints about noise, visitors, crime, and
disrespectful attitudes of the younger residents toward the elderly
residents. 

It was primarily this increase in the number of tenants with
disabilities in elderly housing and the resultant complaints that led
the Congress to promote designated housing in the 1992 act.  First,
the 1992 act established a definition of elderly persons that no
longer included persons with disabilities under the age of 62. 
Second, the act allowed PHAs to seek approval for designating housing
as elderly-only, disabled-only, or elderly and disabled through
allocation plans submitted to HUD.  The 1992 act laid out criteria
for the contents of allocation plans and standards that HUD should
use to approve the plans.\6 Specifically, the law stipulated that
approval is to be granted to only PHAs that demonstrate in their
allocation plans that designation is necessary to achieve the housing
goals for their jurisdictions and to meet the needs of the
jurisdictions' low-income population.  PHAs that do not have approved
allocation plans must continue to treat persons with disabilities and
the elderly equally and allow both to live in elderly buildings on a
first-come, first-serve basis.\7

Finally, the act allowed owners of privately owned, HUD-assisted
projects that were designed primarily for occupancy by elderly
families to designate housing for the elderly through the
establishment of elderly preferences or restrictions.  Unlike PHAs
that designate housing, however, owners of privately owned projects
do not need to seek HUD's approval prior to designation or to notify
HUD once designation occurs. 

To offset the potential loss of housing for persons with disabilities
and to provide them with greater housing choices, HUD set aside
Section 8 rental housing certificates and vouchers for their use. 
Through appropriations for fiscal years 1997 and 1998 for incremental
certificates and vouchers, the Congress augmented HUD's ability to
set aside Section 8 assistance for persons with disabilities
displaced by public and privately owned housing designated for the
elderly.  Separately, HUD has also made Section 8 certificates and
vouchers available to provide mainstream housing opportunities for
persons with disabilities.  The mainstream program is open to all
housing authorities, not just those with approved allocation plans. 
It is popular with persons with disabilities who want to find housing
in the private sector (known as "housing of choice") rather than in
public or project-based housing. 


--------------------
\4 In this report, the terms "public housing authority" and "PHA"
refer only to those housing authorities that own housing units.  Some
housing authorities own no housing units but do provide Section 8
rental assistance that recipients can use to rent privately owned
housing.  PHAs can also provide Section 8 rental assistance. 

\5 Public Housing:  Housing Persons With Mental Disabilities With the
Elderly (GAO/RCED-92-81, Aug.  12, 1992). 

\6 In the Housing Opportunity Program Extension Act of 1996, the
Congress, among other things, modified the requirements for
allocation plans to designate housing to make the application process
less onerous for PHAs.  It also directed HUD to conduct a limited
review of allocation plans submitted for approval.  It removed the
requirement that PHAs must rent to persons with disabilities any unit
in a designated building that had been vacant for more than 60 days
and that was ready for occupancy.  It also stipulated that a plan was
to be automatically approved if HUD failed to notify the PHA of the
plan's approval or disapproval within 60 days of its submission.  And
it extended the effective terms of allocation plans to 5 years, after
which PHAs can request 2-year extensions. 

\7 Here and elsewhere we refer to people under the age of 62 who have
disabilities simply as persons with disabilities.  In all instances,
we are referring to households in which the head of the household or
spouse is under the age of 62 and has a disability.  We do not
include households in which another family member has a disability. 
Elderly persons with disabilities are counted among elderly
households. 


   ALLOCATION PLANS HAVE HAD
   LITTLE IMPACT THUS FAR
------------------------------------------------------------ Letter :3

Only 73 of the nation's 3,200 PHAs had allocation plans as of
November 1, 1997.\8 These PHAs typically elected to designate units
for the elderly or for the elderly and persons with disabilities
combined.  Of all the 73 PHAs with allocation plans, 64 designated a
total of 24,902 housing units--approximately 36 percent of their
housing stock for the elderly or persons with disabilities--as
elderly-only.  As a result, these units may no longer be available to
persons with disabilities.  However, persons with disabilities
occupied only a portion of these units in the past, and most who
resided in those units still do.  Specifically, 53 of the 64 PHAs
that designated units as elderly-only and provided complete occupancy
data in our survey reported that when they submitted their plans,
about 4,100 persons with disabilities were occupying units now
designated for the elderly.  The number had fallen to about 3,000 as
of November 1, 1997.  Overall, there has been little change in the
number of persons with disabilities residing in units now designated
as elderly-only, disabled-only, and elderly and disabled or in other
undesignated units available to the elderly and persons with
disabilities.  One reason is that more than half of the PHAs with
allocation plans had them approved as recently as 1996 or 1997, so
the designations are relatively new.  Another reason is that PHAs are
not permitted to force residents with disabilities to move out of
housing newly designated for the elderly and residents with
disabilities may not wish to relocate.  (See app.  IV for our survey
instrument and the complete responses to our survey.)


--------------------
\8 As of April 16, 1998, HUD had approved an additional 18 allocation
plans, bringing the total number of PHAs with approved plans to 91. 
According to HUD, these 91 PHAs are designating over 29,000
efficiencies and one-bedroom apartments for the elderly only. 


      FEW PHAS HAVE APPROVED
      ALLOCATION PLANS
---------------------------------------------------------- Letter :3.1

According to HUD, 73 out of 3,200 PHAs had approved allocation plans
as of November 1, 1997.  HUD denied applications from another 22
PHAs, and 2 other PHAs withdrew their applications.  Although some
plans were approved as early as 1994, over half of them were approved
in 1996 and 1997.  The 73 PHAs with approved allocation plans
represent a cross-section of housing authorities in terms of size and
are located in 35 states.  Twenty-four PHAs with approved allocation
plans had fewer than 500 units of public housing, 16 had between 500
and 1,249 units, and 33 had 1,250 or more units.  All but one of
these PHAs--Toccoa, Georgia--reported designating housing units as
part of their allocation plans.  (See fig.  1.)

   Figure 1:  Locations of the 73
   PHAs With Approved Allocation
   Plans, as of November 1, 1997

   (See figure in printed
   edition.)

   Source:  HUD.

   (See figure in printed
   edition.)


      MOST APPROVED ALLOCATION
      PLANS DESIGNATED HOUSING
      UNITS AS ELDERLY-ONLY
---------------------------------------------------------- Letter :3.2

Most of the 73 PHAs with allocation plans designated units as
elderly-only.  Specifically, 64 of the PHAs that have approved
allocation plans reported in our survey that they designated 24,902
units as elderly-only, meaning that the units will no longer be
rented to new tenants who are not at least 62 years old.  Five PHAs
accounted for more than a third of the units designated as
elderly-only:  Worcester, Massachusetts; Milwaukee, Wisconsin;
Minneapolis, Minnesota; San Antonio, Texas; and Chicago, Illinois. 
Seven PHAs designated 50 or fewer units as elderly-only.  (See fig. 
2.)

   Figure 2:  Number of Units
   Designated as Elderly-Only

   (See figure in printed
   edition.)

Fewer units were designated as disabled-only or elderly and disabled. 
(See table 1.) Among the 64 PHAs that designated units only for the
elderly, 19 also designated units in which either the elderly or
persons with disabilities could be housed, and 7 also designated
units as disabled-only.  Four of the PHAs used all three of the
possible designations.  One PHA with an approved allocation plan
opted not to designate any housing units. 



                                Table 1
                
                 Designation of Public Housing Units by
                73 PHAs With Approved Allocation Plans,
                         as of November 1, 1997

Type of designation in                   Number of           Number of
allocation plan                             PHAs\a    designated units
------------------------------  ------------------  ------------------
Elderly-only                                    64              24,902
Disabled-only                                   13                 788
Elderly and disabled                            29               8,366
No units designated                              1                 N/A
----------------------------------------------------------------------
\a The total of the numbers in this column exceeds the 73 PHAs with
approved allocation plans because some of the PHAs designated more
than one type of housing. 

Finally, nonelderly persons with disabilities and the elderly were
eligible for an additional 23,870 units at the 73 PHAs with approved
allocation plans.  These units were not designated as elderly- or
disabled-only in the PHAs' allocation plans but were available to
these persons nonetheless.  Over half of these units belonged to
three PHAs:  Chicago had 5,320; Baltimore, 3,662; and Minneapolis,
3,572. 

Of the 24,902 units designated for elderly residents, 24,471 were
previously available to both the elderly and to younger persons with
disabilities.  About 19 percent of the units that were previously
available to both types of tenants were occupied by younger persons
with disabilities when the PHAs submitted their allocation plans.\9
An additional 367 units designated as elderly-only were newly
constructed or acquired, and 64 were in other types of public housing
units. 


--------------------
\9 This figure is based on the survey responses from 53 PHAs that
designated elderly-only units and provided complete occupancy data. 
The remaining 11 PHAs that designated elderly-only units did not
provide complete data on occupancy of these units. 


      OCCUPANCY HAS CHANGED LITTLE
      ACROSS ALL UNITS AVAILABLE
---------------------------------------------------------- Letter :3.3

Overall, PHAs reported in our survey that occupancy by both persons
with disabilities and the elderly declined slightly across all units
between the time the PHAs submitted their allocation plans and
November 1, 1997.\10 Specifically, the 56 PHAs that provided complete
occupancy data reported that occupancy by persons with disabilities
in units now designated for the elderly or persons with disabilities
or available to either declined by 533 households--about a 5-percent
decrease.  The number of units occupied by the elderly declined by
432--not quite a 2-percent decrease.  (See fig.  3.) Those PHAs that
had specifically designated units as elderly-only reported the same
pattern as did PHAs with allocation plans generally. 

   Figure 3:  Change in Occupancy
   of Designated Units and
   Undesignated Elderly and
   Disabled Units at PHAs With
   Approved Allocation Plans

   (See figure in printed
   edition.)

Notes:  Data are for the 56 PHAs with allocation plans that provided
complete occupancy data in our survey.  Occupancy data were not
available for 17 PHAs with allocation plans. 

Occupancy data are for those units that on November 1, 1997, were
designated elderly-only, disabled-only, or elderly and disabled--or
that were undesignated but available to persons with disabilities and
the elderly. 


--------------------
\10 This discussion includes units that are designated for or that
are available to the elderly and persons with disabilities but are
not designated as such.  It excludes 17 PHAs with approved allocation
plans that did not provide complete occupancy data. 


      CHANGE IN OCCUPANCY VARIED
      BY TYPE OF DESIGNATED UNITS
---------------------------------------------------------- Letter :3.4

While overall occupancy changed little, the occupancy of persons with
disabilities varied depending on whether the units were designated as
elderly-only or elderly and disabled.  Changes in occupancy also
varied by individual PHA.  Of the 53 PHAs that designated units as
elderly-only and provided complete occupancy data for those units in
their survey responses, 25 reported a decline in the number of
persons with disabilities residing in elderly-only units.  The total
decrease of 1,066 occupants represented about one-quarter of the
persons with disabilities residing in those PHAs' units designated as
elderly-only.  The Chicago Housing Authority accounted for much of
this decline, reporting 419 fewer people with disabilities residing
in units now designated elderly-only.  Thirteen PHAs reported no
change, and 15 reported increases.  One PHA reported an increase of
52 nonelderly people with disabilities occupying units that had been
designated elderly-only.  According to an official at this PHA, the
allocation plan permits the PHA to accept near-elderly
persons--including those with disabilities--if there is an
insufficient number of elderly persons to occupy designated units.\11
The increase in persons with disabilities at this PHA is due to the
large number of near-elderly persons with disabilities who moved into
designated units after the PHA submitted its allocation plan. 

Forty PHAs that designated units as elderly-only reported that 618
people with disabilities had moved out of the elderly-only units. 
Some of these PHAs also reported where these persons with
disabilities went:  80 moved into other public housing units; 138
moved into private housing using Section 8 certificates or vouchers;
and 275 moved into other housing.\12

The PHAs that designated units for the elderly and disabled combined
or that had undesignated units available for the elderly and persons
with disabilities reported a total increase in the number of persons
with disabilities occupying those units.  The 47 PHAs in this
category that provided complete occupancy data reported 472 more of
these units were occupied by persons with disabilities--about a
7-percent increase.  The 13 PHAs that designated 788 of their units
as disabled-only reported that occupancy of those units by persons
with disabilities increased by 20 households--more than a 4-percent
increase--between the time they submitted their allocation plans and
November 1, 1997.  (See table 2.)



                                         Table 2
                         
                           Changes in Occupancy of Elderly-Only
                         Units, Disabled-Only Units, and Elderly
                                    and Disabled Units

                       Persons with disabilities                    Elderly
                   ----------------------------------  ----------------------------------
Type of public     As of date  As of Nov.              As of date  As of Nov.
housing unit          of plan     1, 1997      Change     of plan     1, 1997      Change
-----------------  ----------  ----------  ----------  ----------  ----------  ----------
Elderly-only\a          4,094       3,028      -1,066      14,814      15,828       1,014
Disabled-only\b           445         465          20         218         207         -11
Elderly and             6,554       7,026         472      11,908      11,013        -895
 disabled\c
-----------------------------------------------------------------------------------------
\a Data are for the 53 PHAs for which there were complete occupancy
data; they accounted for 21,354 units designated as elderly-only. 

\b Data are for all 13 PHAs that designated units as disabled-only;
they accounted for all 788 such units. 

\c Data are for the 47 PHAs for which complete occupancy data were
available that designated 7,311 units as elderly and disabled and had
16,194 undesignated units available to the elderly and persons with
disabilities. 


--------------------
\11 HUD defines near-elderly persons as those between the ages of 50
and 62. 

\12 Data on where persons with disabilities moved were reported by
between 23 and 25 PHAs that designated units as elderly-only. 


      DESIGNATING HOUSING HAS HAD
      LITTLE IMPACT ON PERSONS
      WITH DISABILITIES FOR
      VARIOUS REASONS
---------------------------------------------------------- Letter :3.5

One reason the provisions in the 1992 act allowing PHAs to designate
units for the elderly have had little impact on the availability of
public housing for persons with disabilities is that so few PHAs have
sought to use the provisions thus far.  While we did not attempt to
survey the more than 3,100 PHAs that have not submitted allocation
plans to designate housing, HUD officials told us that most PHAs do
not view developing the plans as a priority or do not believe that
designated housing is necessary.  Moreover, HUD agreed that
designated housing has had little impact on housing opportunities for
persons with disabilities.  HUD cited the collaborative approach it
uses to review plans, coupled with the availability of targeted
Section 8 certificates and vouchers, as the factors that have
minimized the potential impact. 

Two-thirds of the PHAs responding to our survey indicated that their
designation of housing to date has neither helped nor hindered their
ability to meet the housing needs of persons with disabilities. 
Officials at the three PHAs we visited that had allocation plans
confirmed that designating units for the elderly had not had an
impact on persons with disabilities.  They noted that persons with
disabilities were not required to move out of the designated units
and that many of them had decided not to relocate.  For example, an
official at the Dallas Housing Authority said that many of the
tenants preferred to stay where they were.  At the Fall River Housing
Authority, persons with disabilities residing in units designated as
elderly-only were offered Section 8 certificates.  Some of these
residents were able to use these certificates to find housing in the
private market, while the other residents remained in their newly
designated units. 


   IMPACT OF SECTION 8
   CERTIFICATES AND VOUCHERS IS
   NOT YET KNOWN
------------------------------------------------------------ Letter :4

The extent to which Section 8 rental certificates and vouchers for
persons with disabilities have helped meet the demand for affordable
housing for persons with disabilities is not yet clear.  Fifty-nine
housing authorities reported receiving 4,943 certificates and
vouchers for persons with disabilities.  Thirty-three of these 59
authorities also designated units as elderly-only.  About two-thirds
of the PHAs with elderly-only units reported that they received more
certificates and vouchers than the number of persons with
disabilities residing in their elderly-only units.  However, as of
November 1, 1997, only about one-fourth of the total 4,943
certificates and vouchers reported had been used successfully. 
Officials from HUD and housing authorities that we surveyed gave
various reasons for certificates and vouchers not being used.  For
instance, because of the time involved in awarding certificates and
vouchers to housing authorities, many had not been in a position to
issue the new rental certificates and vouchers by November 1, 1997. 
Statutory restrictions on the funds have limited their use.  Persons
with disabilities seeking to use certificates and vouchers might have
had difficulty finding affordable, privately owned housing in their
communities.  And many tenants with disabilities might not be
interested in moving out of the public housing units they now occupy. 


      SECTION 8 ASSISTANCE HAS
      BEEN MADE AVAILABLE FOR
      PERSONS WITH DISABILITIES IN
      TWO WAYS
---------------------------------------------------------- Letter :4.1

The Section 8 Rental Certificate and Rental Voucher program is a
federally funded affordable housing option administered by the local
housing authorities, which issue the certificates and vouchers to
eligible tenants.\13 HUD has made Section 8 certificates and vouchers
available for persons with disabilities in two ways:  (1) in
connection with designated public or privately owned, HUD-subsidized
housing or (2) through a mainstream housing opportunities program. 

Since 1992, a total of $278.9 million has been earmarked for
certificates and vouchers for persons with disabilities.  As of
November 1, 1997, HUD had made $190.4 million available through four
notices of funding availability.\14 As figure 4 shows, only the funds
from the March 1995 notice and the April 1997 notice for the
mainstream program have been totally awarded to the housing
authorities.  HUD told us that between November 1997 and March 1998,
another $15 million made available through the October 1996 notice
was awarded to PHAs with newly approved allocation plans.  HUD
expects all the funds from the October 1996 notice to be spent by the
end of fiscal year 1998. 

   Figure 4:  Funds Available and
   Awarded for Section 8
   Certificates and Vouchers for
   Persons With Disabilities, as
   of November 1, 1997

   (See figure in printed
   edition.)

\a As of March 3, 1998, an additional $15 million was awarded to PHAs
with newly approved allocation plans. 

Source:  HUD. 

The April 1997 funding notice making $50 million available to PHAs
was the result of a set-aside in HUD's fiscal year 1997
appropriation.  The Congress set aside this money to fund Section 8
assistance to persons with disabilities affected by designated public
and private housing.  Half of the $50 million was earmarked for
housing authorities with approved allocation plans, and the other
half was earmarked for housing authorities that could identify the
impact on persons with disabilities of elderly-only preferences
established by privately owned projects in their communities.  As of
November 1, 1997, none of the $25 million for housing authorities
with approved allocation plans had been spent.  According to HUD
officials, this $25 million will be used once all of the funding made
available in the October 1996 notice is awarded.  From the $25
million intended to offset the impact of elderly-only preferences
established by privately owned projects, HUD had awarded $2.7 million
to five PHAs.  Appendix V provides further discussion of Section 8
certificates and vouchers for persons with disabilities. 

A total of 59 housing authorities reported receiving Section 8
certificates and vouchers for persons with disabilities.  (Fig.  5
shows their locations.) Six of these housing authorities received
awards for both designated housing and mainstream opportunities. 
They are Rochester, New York; Butler County, Pennsylvania; Kansas
City, Missouri; Wilmington, Delaware; Greensboro, North Carolina; and
Salem, Oregon. 

   Figure 5:  Locations of 59
   Housing Authorities That
   Received Section 8 Certificates
   and Vouchers, as of November 1,
   1997

   (See figure in printed
   edition.)

   Source:  HUD.

   (See figure in printed
   edition.)


--------------------
\13 Households using certificates are limited to paying not more than
30 percent of their adjusted income, or 10 percent of their gross
income, whichever is greater, for rent.  Households using vouchers
can seek housing with rents that exceed the rent payment standard
established by HUD.  Those households are allowed to pay more than 30
percent of their income for rent. 

\14 The $278.9 million includes $40 million appropriated in fiscal
year 1998 to offset the impact of designated public and privately
owned housing and $48.5 million appropriated in the same year for the
mainstream program.  HUD did not make this $88.5 million available
until April 30, 1998. 


      FEW OF THE CERTIFICATES AND
      VOUCHERS AWARDED HAVE BEEN
      USED
---------------------------------------------------------- Letter :4.2

Fifty-nine of the 96 housing authorities we surveyed reported that
they had received 4,943 certificates and vouchers for persons with
disabilities from one or more of the four notices of funding
availability.  However, because of the length of the process used to
make awards to housing authorities, many were not in a position to
issue the new rental certificates and vouchers awarded from one of
the 1997 notices by November 1, 1997.\15 Of the approximately 3,000
certificates and vouchers that were available to housing authorities
as of November 1, 1997, 1,558 had been issued to persons with
disabilities who, in turn, had used 1,162 to obtain private rental
housing and had turned back 174 unused, according to the authorities. 
Some housing authorities reported that their recipients were still in
the process of searching for housing.  Persons with disabilities
generally have 60 days to use certificates and vouchers and may ask
for extensions if necessary. 

Thirty-three PHAs reported that they designated units as elderly-only
and received 2,982 certificates and vouchers, primarily in connection
with their designation.  About two-thirds of these PHAs with
elderly-only units reported that they received more certificates and
vouchers than the number of persons with disabilities residing in
their elderly-only units.\16 These PHAs issued 1,236 of these
certificates and vouchers to persons with disabilities.  Of the
certificates and vouchers issued, 960 had been used by persons with
disabilities to obtain housing and 172 had been turned back to the
housing authorities unused.  The remaining recipients were still
looking for housing. 


--------------------
\15 According to HUD's data, the annual contribution contracts for
927 certificates and vouchers awarded to 15 housing authorities were
executed on November 1, 1997.  Contracts for an additional 967
certificates and vouchers were executed on October 1, 1997. 
Consequently, it is not likely that housing authorities would have
issued these 1,894 certificates and vouchers to persons with
disabilities by November 1, 1997. 

\16 According to a HUD official, this is due to the fact that
allocation plans must address the needs of all the groups affected by
designated housing.  The certificates and vouchers are often the
additional resources that PHAs use to address the needs of persons
with disabilities who are on the waiting list for public housing but
are no longer eligible for units that have been designated
elderly-only. 


      FUNDS FOR CERTIFICATES AND
      VOUCHERS REMAIN UNSPENT
---------------------------------------------------------- Letter :4.3

HUD still has funds remaining for certificates and vouchers
associated with designated housing, but all the funds for the
mainstream program have been awarded.  According to HUD officials,
there is not much demand for the designated housing certificates and
vouchers.  The Section 8 Certificates and Vouchers Director told us
that PHAs prefer to apply for the mainstream housing opportunities
program for persons with disabilities because it is less restrictive,
it does not require PHAs to submit allocation plans, and the funds
have 5-year terms.\17

HUD officials also told us that the restrictions placed on the $50
million the Congress set aside for persons with disabilities in the
fiscal year 1997 appropriation made the funds difficult to award. 
Consequently, HUD worked with the Congress to make the language less
restrictive for the $40 million set aside in the fiscal year 1998
appropriation.  The language now states that if the funds cannot be
awarded to PHAs that have designated housing or that have identified
the impact on persons with disabilities of elderly preferences
established by privately owned projects, then the Secretary of HUD
may make the remaining funds available for the mainstream program. 
This language is retroactive to the remaining funds from the fiscal
year 1997 appropriation.  On April 30, 1998, HUD published a notice
of funding availability to disseminate the $87.3 million from these
fiscal years and the $48.5 million earmarked for the fiscal year 1998
mainstream program. 


--------------------
\17 The certificates and vouchers have had different terms,
reflecting the amount of budget authority that the Congress provides
to HUD for a given year to fund certain certificates and vouchers. 
The terms have no impact on how long a recipient can use a
certificate or voucher. 


      SECTION 8 ASSISTANCE HAS HAD
      A MINIMAL EFFECT ON THE
      OVERALL OCCUPANCY LEVELS
---------------------------------------------------------- Letter :4.4

Our survey found that the number of persons with disabilities living
in public housing units managed by those PHAs that have designated
housing and received certificates and vouchers actually increased by
198 between the time the PHAs submitted their allocation plans and
November 1, 1997.\18 Similarly, occupancy by persons with
disabilities increased by 197 households at the PHAs that designated
elderly-only units and received certificates and vouchers and that
provided complete occupancy data.  Most of the persons with
disabilities using the certificates or vouchers were not tenants in
newly designated units; rather, they had been on the PHAs' waiting
lists for either public housing or Section 8 assistance.  As shown in
figure 6, only 18 percent of the 1,147 certificates and vouchers
whose recipients housing authorities were able to identify were used
to move persons with disabilities out of public housing.\19
Fifty-five percent were used by persons with disabilities who had
been on the PHAs' public housing waiting lists, and 27 percent were
used by persons with disabilities who had been on the PHAs' Section 8
waiting lists.\20

   Figure 6:  Circumstances of
   Persons With Disabilities Using
   Section 8 Certificates and
   Vouchers Set Aside for Them

   (See figure in printed
   edition.)

Note:  A person with disabilities might simultaneously have been on
one or more waiting lists and/or living in public housing. 

The 33 PHAs that made elderly-only designations and received
certificates and vouchers reported a very similar pattern of use. 
Our survey data support the view that tenants with disabilities may
be reluctant to move from what they perceive to be a stable, known
housing situation into an unknown situation.  Those on the waiting
lists, however, are seeking affordable housing opportunities and
therefore may be more willing to use the certificates and vouchers to
improve their housing situation. 


--------------------
\18 Data are for 29 PHAs that had approved allocation plans and
reported receiving certificates and vouchers and that provided
complete occupancy data in their survey responses.  Data were
incomplete for eight PHAs. 

\19 Some housing authorities reported that they did not track whether
the recipients of Section 8 assistance were previously on waiting
lists or living in public housing. 

\20 A person with disabilities might simultaneously have been on one
or more waiting lists and/or living in public housing. 


      CERTIFICATES AND VOUCHERS
      ARE NOT ALWAYS THE OPTIMAL
      HOUSING CHOICE
---------------------------------------------------------- Letter :4.5

Depending on the resident and on the housing market, Section 8
certificates and vouchers may or may not be as preferable as public
housing.  Some PHA officials told us that not every person with
disabilities residing in public housing that has been newly
designated as elderly-only wants to move.  Tenants may want to stay
because they have a network of friends nearby, supportive services,
and available transportation services.  Moreover, moving to Section 8
housing means paying security deposits, which would be an added
financial burden for these tenants.  In addition, some tenants
believe that a certificate or voucher would not be as permanent as
public housing.  Even at those PHAs that provide incentives, such as
paying for moving expenses and phone service transfers, public
housing residents with disabilities reportedly do not want to
relocate.  The Dallas Housing Authority, for example, found that even
with incentives, only 20 of the 80 persons with disabilities residing
in the newly designated elderly-only buildings were willing to use
Section 8 certificates.  As more PHAs continue to receive their
allotments of certificates and vouchers and to educate their
residents on how to use them, this situation may change. 

At other locations, certificates and vouchers may not be an
appropriate option for persons with disabilities because of tight
housing markets, rents that are above HUD's fair market rents (FMR),
or the prevalence of older housing that has not been adapted to the
needs of people with disabilities.\21 For example, because of the
high demand for rental housing in the San Francisco market and the
ease with which landlords can get rents higher than HUD's FMR,
landlords may not be willing to rent to subsidized tenants,
especially to persons with disabilities for whom they would have to
make accessibility accommodations.\22 HUD's FMR is also an issue in
Cambridge, Massachusetts, which recently underwent rent decontrol. 
The Cambridge Housing Authority used a portion of its Section 8
administrative fees to hire a housing-search worker to help Section 8
recipients find housing.  Another PHA we surveyed--in Westbrook,
Maine--also cited a tight housing market and a predominance of older,
inaccessible housing as obstacles faced by persons with disabilities
seeking housing in the private market.  Apartments in older buildings
usually have small rooms and narrow entrances, making it difficult to
improve their accessibility. 


--------------------
\21 Under Section 8, rental assistance payments are limited by the
FMR that HUD established for different housing market areas.  In
general, the FMR for an area is the amount that would be needed to
pay the gross rent (shelter plus utilities) of privately owned rental
housing of a modest nature that meets HUD's rent requirement and
housing quality standards.  Specifically, the FMR is set at the 40th
percentile of an area's rental housing; that is, the level at which
about 40 percent of a market area's rental housing can be obtained. 

\22 Under current law, PHAs are required to pay for physical
modifications to units or common areas they own if the changes are a
reasonable accommodation needed by a tenant with a disability. 
Private landlords, while required to allow modifications be made to
units they own as a reasonable accommodation to a tenant's
disability, are not required to pay for the modifications. 
Generally, the tenant must pay for them.  However, HUD regulations
allow PHAs to approve rents up to 20 percent above the applicable FMR
to pay for the modifications needed to make a unit accessible to a
person with disabilities. 


      WITH GREATER ASSISTANCE,
      THOSE USING CERTIFICATES AND
      VOUCHERS WERE ABLE TO FIND
      HOUSING
---------------------------------------------------------- Letter :4.6

Despite the difficulties encountered in some housing markets, when
persons with disabilities were offered Section 8 certificates and
vouchers, they appeared to be able to use them in most locations. 
Overall, only about 11 percent of the certificates and vouchers had
been turned back to the housing authorities unused as of the time of
our survey.  Half of the housing authorities reported that the rate
at which persons with disabilities turned back certificates and
vouchers was about the same as that for recipients without
disabilities.  Moreover, they said that these users were taking about
the same amount of time as the other recipients to find housing. 
However, the housing authorities reported in our survey that persons
with disabilities required greater assistance to locate private
housing.  In our case study interviews, housing authorities' managers
told us that the extra assistance they provided included preparing
lists of apartments that accepted Section 8 certificates or vouchers
and transportation to the apartments.  Where assistance was provided,
certificates and vouchers had helped persons with disabilities. 


      STILL TOO EARLY TO DETERMINE
      HOW SUCCESSFUL CERTIFICATES
      AND VOUCHERS HAVE BEEN
---------------------------------------------------------- Letter :4.7

In our survey, the majority of housing authorities reported that it
was still too early to determine how successful certificates and
vouchers have been in helping persons with disabilities rent private
housing.  This observation was affirmed by our case study work.  Four
of the six housing authorities where we conducted case studies had
received certificates or vouchers, but managers there said that it
was too early to determine how successful this Section 8 assistance
had been in providing housing options.  The Housing Authority of
Gloucester County, New Jersey, for example, had only recently hired a
full-time person to administer the 130 vouchers it received after it
identified privately owned projects that had established preferences
for the elderly; as of January 1998, it had successfully utilized 10
vouchers to provide housing.  Similarly, the Anaheim, California,
housing authority had not yet issued any of the 150 vouchers it had
received from the mainstream housing program.  It expected that all
150 vouchers would be used, however, and planned to apply for more
vouchers because it had 1,500 persons with disabilities on its
waiting list. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

We provided HUD with a draft of this report for review and comment. 
We met with HUD officials to discuss their comments and our response. 
Specifically, we met with the following officials from the Office of
the Assistant Secretary for Public and Indian Housing:  the Senior
Director of the Office of the Deputy Assistant Secretary for Policy,
Program, and Legislative Initiatives; the Acting Director of
Management and Planning; the Senior Program Manager, Real Estate and
Housing Performance Division (Section 8); and the Senior Program
Analyst, Customer Service and Amenities Division.  We also met with
officials from the Office of Fair Housing and Equal Opportunity and
the Special Assistant to the Secretary on Disability Rights.  There
were four general categories of comments, which are listed below with
our response. 

Comments on our analysis on the allocation plans:  HUD requested that
we include the most up-to-date information on the number of PHAs with
approved allocation plans and the number of designated units.  While
we did not obtain survey responses from the PHAs that received
approval for their allocation plans after November 1, 1997, we have
made note of the most recent data provided by HUD.  HUD also believed
that our analysis showing that the 24,902 units designated as
elderly-only represent 7.5 percent of these PHAs' total units was
misleading.  HUD said the figure implies that only an insignificant
percentage of the available public housing is no longer available to
persons with disabilities in communities with approved allocation
plans.  We have changed the language in the report to reflect that
the 24,902 units represent 36 percent of these PHAs' housing stock
for the elderly and for persons with disabilities.  HUD requested
that we include additional information on the statutory requirements
of the designated housing law.  Where appropriate, we have done so. 
Finally, we have incorporated HUD's position that the reason
designating housing for the elderly has had little impact on housing
opportunities for persons with disabilities is that HUD worked
closely with these PHAs to ensure that they were able to address the
needs of the members of all the groups affected by designations. 

Comments on our analysis on Section 8 certificates and vouchers:  HUD
believed that because of the length of time taken by the submission
and approval of applications and by the execution of annual
contributions contracts, many PHAs were not in a position to issue
the certificates and vouchers they were awarded from either of the
two notices of funding availability published in April 1997 until
late October or early November.  HUD requested that we add language
to state that it should not be surprising that only a small
percentage of certificates and vouchers had been issued and used by
persons with disabilities as of November 1, 1997.  We have added, in
the appropriate sections of the report, language to acknowledge the
time needed for the submission and approval of housing authorities'
applications and for the issuance and execution of annual
contributions contracts before certificates and vouchers are actually
available for use.  HUD also suggested that we include the fiscal
year 1998 funding of $48.5 million for the mainstream certificates
and vouchers program.  We did so.  However, we disagree with HUD's
suggestion that we delete from our analysis the $25 million of the
fiscal year 1997 appropriations and the $20 million of the fiscal
year 1998 appropriations that were directed at assisting nonelderly
persons with disabilities affected by elderly preferences established
by privately owned projects.  We included these amounts because the
Congress requested that our analysis include all new Section 8
certificates and vouchers for persons with disabilities. 

Comments on our survey instrument:  HUD thought that our survey
instrument should have included questions pertaining to housing
demand, characteristics of persons on public housing waiting lists,
and the number of efficiencies and one-bedroom units in family
developments.  Questions 24, 37, and 38 of the survey instrument
asked PHAs to evaluate the impact that designating housing and
issuing additional certificates and vouchers have had on their
ability to meet the housing needs of persons with disabilities.  We
expected the PHAs to take demand for housing and the characteristics
of the persons on their waiting lists into consideration in their
responses to these subjective questions.  Public housing waiting
lists, we discovered in our pretests, are imperfect measures of
demand for housing as they reflect demand only at the time the
individual is placed on the waiting list or when the list is updated. 
Our survey found that 82 percent of the certificates and vouchers
were used by persons with disabilities on public housing and/or
Section 8 waiting lists.  This is consistent with HUD's point that
persons on waiting lists are the group most helped by the targeted
Section 8 rental assistance.  Furthermore, the focus of the survey
questions regarding occupancy was on the designated units and the
units available to the elderly and persons with disabilities.  These
questions did not exclude the possibility of such units in family
buildings.  Finally, we disagree that our question on how many units
PHAs had designated for only persons with disabilities did not
differentiate between units designated in the allocation plan and
physically accessible units that were not designated in the plan. 
Questions 11 and 12 of the survey used the language "units you
designated in your allocation plan as 'disabled-only,'" which we
believe is very clear.  We had no indication from either our pretests
or our callbacks to housing authorities for response clarification
that they were incorrectly interpreting these questions. 

Comments on our population analysis:  HUD believed that we needed to
focus more on families with very low incomes (i.e., incomes at or
below 50 percent of the median family income for their area) in our
analysis, not just low-income families (i.e., those with incomes at
or below 80 percent of the median income for their area).  HUD stated
that families with incomes between 50 and 80 percent of the area's
median income qualify for a smaller number of public housing units
and generally do not qualify for Section 8 rental assistance.  We
concurred and made appropriate modifications.  HUD also pointed out
that our estimates of low-income persons with disabilities meeting
HUD's definition differ significantly from the conclusion HUD reached
in its 1997 report to the Congress on worst-case housing needs.\23

While we used the definition of disability used in HUD's housing
programs, HUD, in its report on worst-case housing needs, used a more
restrictive definition of disability than it uses in its housing
programs. 


--------------------
\23 Rental Housing Assistance--The Crisis Continues:  The 1997 Report
to Congress on Worst Case Housing Needs (April 1998). 


---------------------------------------------------------- Letter :5.1

We conducted our review from July 1997 through May 1998 in accordance
with generally accepted government auditing standards. 

We are sending copies of this report to the appropriate Senate and
House committees; the Secretaries of HUD and Health and Human
Services; and the Director of the Office of Management and Budget. 
We will make copies available to others on request. 

Please call me at (202) 512-7631 if you or your staff have any
questions about the material in this report.  Major contributors to
this report are listed in appendix VI. 

Judy A.  England-Joseph
Director, Housing and Community
 Development Issues


POPULATION OF LOW-INCOME PERSONS
WITH DISABILITIES MEETING HUD'S
DEFINITION IS AN ESTIMATED 9
MILLION NATIONALLY
=========================================================== Appendix I

To estimate the number of households in which the head of the
household or spouse meets the Department of Housing and Urban
Development's (HUD) definition of a low-income person with a
disability, we used data from the National Health Interview Survey
(NHIS) conducted for the Department of Health and Human Services'
(HHS) National Center for Health Statistics.  We worked with HHS'
Office of the Assistant Secretary for Planning and Evaluation (ASPE)
and the Special Assistant to the Secretary in HUD's Office of
Disability Policy to develop criteria for using data about income,
age, and disabilities from the 1994 survey.  HHS then applied these
criteria to estimate the number of noninstitutionalized households in
which the head of the household or spouse--or the sole person in the
case of a single-person household--would be considered under HUD's
definition to be a person with a disability. 

NHIS, which was first conducted in 1957, is a continuing national
survey of civilian, noninstitutionalized households.  It is the
principal source of information on the health of this population.  In
addition to the basic survey, NHIS in many years includes supplements
covering special topics.  For 1994, NHIS covered five special topics,
including disability and family resources--both of which were used in
the estimates of households meeting HUD's definition of persons with
disabilities.\24

Because NHIS estimates are based on a sample of households, they may
differ somewhat from the figures that would have been obtained from a
complete census.  In 1994, 45,705 households were interviewed,
resulting in a sample of 116,179 persons.\25 Since NHIS's design is a
complex multistage probability sample, the estimates provided do have
sampling errors; however, HHS did not compute the sampling errors for
each estimate.  Where we could identify similar estimates published
by others, we found that HHS' estimates were generally in the same
range.  We did not perform a technical review of HHS' programming. 

NHIS excludes members of the armed forces, U.S.  nationals living
abroad, nursing home residents, and institutionalized persons. 
According to the 1990 census, 3.3 million Americans lived in
institutions,\26 including 1.8 million persons in nursing homes.\27
An additional 340,000 persons lived in other types of institutions,
such as psychiatric hospitals and schools, hospitals, or wards for
the mentally retarded.  Some portion of the 340,000 persons in such
institutions, as well as those in nursing homes, might be expected to
have conditions that substantially impair their ability to live
independently, according to HUD officials.  However, these persons
are not included in the estimates presented here of the population
meeting HUD's definition for persons with disabilities.  The
remaining persons in institutions include 1.1 million persons in
correctional institutions and 104,200 in juvenile institutions. 


--------------------
\24 The NHIS Disability Supplement was administered in 1994 and 1995. 
In each year, a Phase I screening interview was conducted to identify
persons with disabilities.  Persons who screened in as having a
disability subsequently received a second, more detailed Phase II
interview.  The data on which the analyses in this appendix are based
come from the 1994 (first year) Phase I interviews. 

\25 NHIS has a very high response rate.  Of the 48,584 households
eligible to be interviewed in the 1994 survey, 2,879--or about 6
percent--were not included either because they refused to respond or
were not located. 

\26 An institution is a group quarters in which some residents are
not free to leave without permission. 

\27 According to the 1995 National Nursing Home Survey, about 1.5
million persons received care in nursing homes in 1995.  Nearly 90
percent of these residents were 65 and over, according to the
National Center for Health Statistics.  Of all persons 65 and over,
about 4 percent were living in nursing homes in 1995. 


   HUD'S DEFINITION OF LOW-INCOME
   PERSONS WITH DISABILITIES
--------------------------------------------------------- Appendix I:1

Low-income and very low-income families are eligible for housing
assistance under HUD's public and assisted housing programs. 
Generally, low-income families are those with adjusted incomes at or
below 80 percent of the median income in their areas, as determined
by HUD with adjustments for smaller and larger families.  Very
low-income families are those with adjusted incomes at or below 50
percent of their areas' median income.  Very low-income families
qualify for public housing and Section 8 rental assistance.  Families
with incomes between 50 and 80 percent of their area's median income,
however, are eligible for HUD's public housing programs but generally
compete for a smaller number of units, and most do not qualify for
Section 8 rental assistance. 

HUD's public and assisted housing programs use a definition of
disability that includes a measure of functional limitation that is
due to a medical condition of a certain duration.  Specifically, the
programs generally consider a person to have a disability if that
person (1) meets the definition used under section 223 of the Social
Security Act; or (2) meets the definition for developmental
disabilities found in the Developmental Disabilities Assistance and
Bill of Rights Act; or (3) has a physical, mental, or emotional
condition that is expected to be of long-continued and indefinite
duration, substantially impedes the person's ability to live
independently, and is of such nature that the person's ability to
live independently could be improved by more suitable housing
conditions. 

A low-income or very low-income family whose household head or spouse
meets HUD's definition of a person with a disability is ordinarily
eligible for housing units available to the elderly, even though the
household head or spouse may not be elderly.\28

However, the Housing and Community Development Act of 1992 allows
public housing authorities (PHA) that have approved allocation plans
and owners of certain HUD-assisted projects to restrict occupancy in
particular units to the elderly only. 


--------------------
\28 For single-person families, the sole member would need to meet
HUD's definition of a person with a disability. 


   APPLYING HUD'S DEFINITION TO
   THE NHIS DATA
--------------------------------------------------------- Appendix I:2

To identify low-income and very low-income families, we asked that
HHS compare total household income--excluding income from persons
under the age of 18--recorded in the NHIS data with HUD's 1994
adjusted median family income for metro and nonmetro areas within the
four census regions, adjusted for family size.\29 HHS summarized
responses to questions in the family resources supplement of NHIS on
components of household income for adult family members--in the case
of families--and for the sole person in single-person households. 
For NHIS, all persons in a household related to each other by blood,
marriage, or adoption constitute a family.\30 For about 16 percent of
the households, there were no income data; these households were
excluded from the estimates provided here.  We do not know how the
income of those households compared with the income of households for
which the data were available. 

To identify households in which the household head or spouse (or the
sole person in the case of a single-person household) was a person
with a disability as defined by HUD, we utilized responses to
questions about the receipt of Supplemental Security Income (SSI);\31
any conditions associated with developmental disabilities; the
presence of physical, mental, and emotional conditions; the duration
of the condition; and the difficulty experienced with activities of
daily living (ADL) and instrumental activities of daily living
(IADL).\32 Specifically, we estimated the number of households in
which the household head or spouse or sole individual (1) received
SSI; (2) met the definition of disability under the Developmental
Disabilities Assistance and Bill of Rights Act;\33 (3) had--without
the use of equipment, help, or supervision--a lot of difficulty with
or was unable to perform one or more ADL or IADL because of a
physical, mental, or emotional condition expected to last another 12
months; or (4) had a mental or emotional condition that seriously
interfered with his or her ability to work, attend school, or manage
day-to-day activities without regard to the duration of this
condition.\34 We did not attempt to determine if the person's ability
to live independently could have been improved by more suitable
housing conditions.  Also, we did not attempt to determine the
person's housing needs or whether a person was currently residing in
public or assisted housing. 


--------------------
\29 For HUD's public and assisted housing programs, family income is
compared with the adjusted median family income for the area in which
the family lives.  However, for income data, NHIS may only identify
the census region in which the family lives and whether the family
lives in a metropolitan statistical area.  In addition, while HUD
allows other exclusions of income, the only income excluded from the
analysis is that from members of the family younger than 18. 

\30 Additional groups of people living in the household are
considered secondary families, and, along with secondary individuals,
are excluded from the estimates provided here.  Of the approximate
116,000 unweighted observations in the survey, about 102,000 were
primary families, 12,500 primary individuals, 180 secondary families,
and 1,300 secondary individuals. 

\31 The Social Security Administration's SSI program provides
means-tested assistance to needy aged, blind, or disabled people. 

\32 ADLs included bathing or showering; dressing; eating; getting in
or out of bed or chairs; using the toilet, including getting to the
toilet; and getting around inside the home.  IADLs included preparing
meals, shopping, managing money, using the telephone, heavy
housework, and light housework. 

\33 ASPE has used the NHIS data for estimating persons with mental
retardation or other developmental disabilities (MR/DD).  Based on
statutory language, the following criteria were applied:  (1) a
reported condition commonly resulting in MR/DD (e.g., mental
retardation, cerebral palsy, Down's syndrome); or (2) problems with
one or more of three major life activities, namely self-care,
self-determination, and mobility (as measured by ADL or IADL status);
or (3) serious difficulty with learning; or (4) serious difficulty
with communicating or understanding other people (apart from language
problems); or (5) use of services typically used by persons with
MR/DD, such as sheltered workshops, transitional work training, or
supported employment.  Respondents were considered to have MR/DD if
their responses (or the responses of proxies) to questions indicated
that they met any of these criteria with an age of onset prior to age
22. 

\34 Persons who did not use special equipment or need help or
supervision, but had a lot of difficulty or were unable to perform
one or more of the ADLs or IADLs, were included, as were persons who
used special equipment or needed help or supervision from others and,
without such equipment or help, would have a lot of difficulty or
would have been unable to perform one or more of the ADLs or IADLs. 


   RESULTS OF THE ANALYSIS
--------------------------------------------------------- Appendix I:3

According to the estimates provided by HHS, in 1994 about 9 million
low-income households (including about 7 million very low-income
households) not living in institutions had as a household head or
spouse a person who may have met HUD's definition of a person with a
disability.  In almost half of these households, the household head
or spouse was a nonelderly adult with a disability.\35 There were an
estimated 2.5 million low-income renter households that had as a
household head or spouse a nonelderly person with a disability. 

The overall estimates provided by HHS were within the range of other
estimates of the number of persons with disabilities.  Specifically,
when not considering income, HHS estimated that there were about 11
million households--or almost 14 percent of all households--that had
as a household head or spouse a person who met HUD's definition of a
person with a disability.  In comparison, a 1996 study estimated that
for about 17 million families--or about 24 percent of all families in
the 1990 NHIS--the household head, or in the case of "partnered
families" one or both partners, had a disability.\36 A study using
data from the 1992 Survey of Income and Program Participation
estimated that about 48.9 million noninstitutionalized civilians--or
about 19.4 percent of this population--had a disability.\37 Of these,
about half had a severe disability.  Considering that in 1992,
households had an average of 2.62 persons, the number of households
with a member that had a disability would have been about 19 million,
and the number of households with a member that had a severe
disability would have been about 9 million.  According to the 1990
census, about 22 million noninstitutionalized persons aged 16 and
older had a work disability, a mobility limitation, or a self-care
limitation.  This may equate to about 8.5 million such households. 

Of the HHS-estimated 46.3 million low-income households, 8.7 million,
or about 19 percent, were households that were headed by persons or
spouses with disabilities and that had incomes at or below 80 percent
of HUD's adjusted median family income.  Of that 8.7 million
households, 6.6 million had incomes at or below 50 percent of HUD's
adjusted median family income.  A low-income household was more
likely than other households to have a person with a disability as a
household head or spouse.  About half of these households had as a
household head or spouse a person with a disability who was younger
than age 62.  Elderly households represented about 51 percent of the
low-income households headed by a person or a spouse with a
disability.  However, elderly households were twice as likely as
younger households to have a household head or spouse with a
disability.  That is, while 28 percent of low-income elderly
households had as a household head or spouse a person with a
disability, the figure was 14 percent for younger low-income
households.  About 45 percent of the low-income households headed by
a person or a spouse with a disability rented, rather than owned,
their homes.  Table I.1 shows the estimated income and disability
status of the households included in the 1994 NHIS. 



                                        Table I.1
                         
                          Estimated Income and Disability Status
                                      of Households

                                        (Millions)

Household head or                                Low-income           Very low-income
    spouse\a           All households           households\b            households\c
-----------------  ----------------------  ----------------------  ----------------------
                    All\d  Renter   Owner   All\d  Renter   Owner   All\d  Renter   Owner
-----------------  ------  ------  ------  ------  ------  ------  ------  ------  ------
All                  81.5    27.6    51.1    46.3    19.7    24.5    30.5    14.2    14.6
Person with a        11.1     4.3     6.2     8.7     3.9     4.3     6.6     3.3     2.9
 disability
Elderly\e            20.9     4.2    16.0    15.9     3.7    11.5    11.0     3.1     7.4
Elderly person        5.1     1.5     3.4     4.4     1.4     2.7     3.3     1.3     1.9
 with a
 disability
Nonelderly\f         60.6    23.4    35.0    30.4    15.9    13.0    19.5    11.1     7.2
Nonelderly person     6.0     2.9     2.8     4.3     2.5     1.6     3.3     2.1     1.0
 with a
 disability
-----------------------------------------------------------------------------------------
Note:  About 16 percent of all households were excluded because
income data were not available. 

\a Sole person in the case of single-person households.  Does not
include secondary families and individuals. 

\b Income at or below 80 percent of HUD's adjusted median family
income for the metro or nonmetro area and census region in which the
household lived, adjusted for family size. 

\c Income at or below 50 percent of HUD's adjusted median family
income for the metro or nonmetro area and census region in which the
household lived, adjusted for family size. 

\d Includes households that were renters or owners as well as
households that were neither. 

\e Head of household or spouse was aged 62 and older. 

\f Head of household or spouse was aged 18 to 61. 

Source:  HHS analysis of data from the 1994 National Health Interview
Survey, Disability Supplement (Phase I) and Family Resources
Supplement. 


--------------------
\35 Nonelderly adults are individuals aged 18 to 61. 

\36 Partnered families are those headed by a couple, whether married
or not.  The 1996 study defined disability for nonelderly adults as
the inability to work at a job or keep house, or limitations in the
ability to perform the amount or kind of these and other activities. 
See Mitchell LaPlante, Dawn Carlson, and others, Disability
Statistics Report:  Families With Disabilities in the United States,
prepared for the National Institute on Disability and Rehabilitation
Research, U.S.  Department of Education (Washington, D.C.:  U.S. 
Department of Education, Sept.  1996). 

\37 Lewis Kraus, Susan Stoddard, and David Gilmartin, Chartbook on
Disability in the United States, 1996, prepared for the National
Institute on Disability and Rehabilitation Research, U.S.  Department
of Education (Washington, D.C.:  U.S.  Department of Education,
1996). 


OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================== Appendix II

The Subcommittee on VA, HUD, and Independent Agencies of the House
Committee on Appropriations asked us to assess (1) the impact of the
Housing and Community Development Act of 1992 on the availability of
public housing for persons with disabilities and (2) how incremental
Section 8 certificates and vouchers that were made available since
the passage of the 1992 act were assisting persons with disabilities
seeking affordable rental housing.\38

As requested, we also developed estimates of the number of households
that may meet HUD's definition of persons with disabilities. 

To obtain information for this report, we conducted a survey of the
73 PHAs that, according to HUD, had approved allocation plans as of
November 1, 1997.  In addition, we sent the survey to 23 other
housing authorities that did not have approved allocation plans but
had been awarded Section 8 certificates and vouchers for the
exclusive use of persons with disabilities as of November 1, 1997. 
We mailed a questionnaire to each of these 96 housing authorities and
made follow-up calls as needed to stimulate responses or verify
unclear answers.  All 96 housing authorities responded to the survey. 
The results of the survey are summarized in appendix IV. 

To supplement the results of the survey, we conducted six case
studies at housing authorities and their immediate communities in (1)
Fall River, Massachusetts; (2) Dallas, Texas; (3) Corinth,
Mississippi; (4) Gloucester County, New Jersey; (5) Anaheim,
California; and (6) San Francisco, California.  We neither evaluated
these housing authorities' provision of affordable housing for
persons with disabilities nor compared one authority's efforts with
those of another.  Rather, our aim was to provide a comprehensive
picture of housing authorities facing different challenges in
providing housing for persons with disabilities.  Our criteria for
selecting the locations included the following: 

  -- Size of the housing authority--Our case studies included large
     and small housing authorities. 

  -- Size of the housing authority's community--Our case studies
     included large cities, suburban communities, and a rural
     community. 

  -- Condition of the housing market--Our case studies ranged from a
     city with a housing market known to be particularly tight to a
     community with a surplus of affordable housing. 

  -- Designated housing and Section 8 assistance--Of the six
     locations, three PHAs had allocation plans for designated public
     housing and Section 8 certificates and vouchers; two housing
     authorities had no designated public housing but received
     certificates and vouchers (one was a housing authority that had
     no public housing units but administered Section 8 assistance);
     and one PHA neither had an allocation plan nor received
     certificates or vouchers for the exclusive use of persons with
     disabilities. 

We visited these six locations and interviewed the local housing
authority officials about their experience in housing persons with
disabilities.  We also interviewed representatives of a judgmentally
selected number of HUD-subsidized, privately owned projects that
provided housing for the elderly and persons with disabilities to
determine whether they established preferences for the elderly. 
Finally, we spoke with advocates for both the elderly and persons
with disabilities in the communities we studied, where we were able
to identify them.  See appendix III for detailed information about
the six case studies. 

To conduct the analysis of the population of low-income persons with
disabilities, we asked the Department of Health and Human Services'
Office of the Assistant Secretary for Planning and Evaluation (ASPE)
to conduct population analyses of data from the agency's National
Health Interview Survey, using HUD's definition of low-income persons
with disabilities as parameters.  Bob Clark, Senior Program Analyst,
and Don Chontos, Programmer, of ASPE developed the analysis.  See
appendix I for information on the population analysis. 

Finally, we reviewed the legislative history of the provisions in the
1992 act that allowed housing authorities to seek approval from HUD
to designate housing for the elderly, persons with disabilities, or
both and the appropriations set-asides for Section 8 certificates and
vouchers in fiscal years 1997 and 1998.  We interviewed appropriate
HUD officials about designated housing, other housing for the elderly
and persons with disabilities, and Section 8 certificates and
vouchers (see app.  V for a discussion on Section 8 certificates and
vouchers).  We also interviewed representatives of the national
associations for persons with disabilities and the elderly.  We
conducted our review from July 1997 through May 1998 in accordance
with generally accepted government auditing standards. 


--------------------
\38 The Subcommittee also requested that we assess the impact of the
1992 act on the availability of privately owned, HUD-subsidized
rental housing for low-income persons with disabilities.  We will
issue a separate report on those findings. 


CASE STUDIES:  IMPACT ON PERSONS
WITH DISABILITIES AT SIX HOUSING
AUTHORITIES
========================================================= Appendix III

To better describe the impact of the Housing and Community
Development Act of 1992 on the availability of housing for persons
with disabilities, we visited six locations.  Three of the six have
housing authorities with approved allocation plans, and two of these
also have Section 8 certificates for persons with disabilities.  Two
other authorities in our case study do not have allocation plans but
received vouchers.  We selected the final location to review the
practicality of certificates and vouchers for persons with
disabilities in an extremely tight housing market.  Table III.1 shows
the six housing authorities we visited. 



                                       Table III.1
                         
                                 Summary of Case Studies

                                                        Section 8 certificates/vouchers
                                                       ----------------------------------
                    Year allocation            Public  For persons with         Total for
Location              plan approved   housing units\a      disabilities      all families
-----------------  ----------------  ----------------  ----------------  ----------------
Fall River, MA                 1996             1,707              76\b             2,181
Dallas, TX                     1995             4,647              80\b             9,182
Corinth, MS                    1995               343                 0               168
Gloucester                     None               262             130\c             1,615
 County, NJ
Anaheim, CA                    None                 0             100\c             3,390
San Francisco, CA              None             6,722                 0             4,945
-----------------------------------------------------------------------------------------
\a Includes federally supported public housing units only. 

\b Certificates. 

\c Vouchers. 

Five of the six locations we visited have housing authorities that
manage public housing units.  Officials from all five told us that
mixing elderly and nonelderly persons with disabilities in the same
buildings does not always work well.  In some cases it was the
lifestyles associated with youth, not necessarily disability, that
caused the underlying problems, and in other cases, it was younger
persons with mental disabilities and their friends and visitors who
caused problems for the elderly.\39

All three housing authorities with allocation plans--Fall River,
Dallas, and the Tennessee Valley Regional Housing Authority (TVRHA)
in Corinth--designated entire buildings for the elderly.  The Fall
River authority designated six of its federally aided
elderly/disabled buildings as elderly-only.  It also has one building
primarily for younger persons with disabilities, but officials there
said they will accept elderly applicants for these units as well. 
The Dallas Housing Authority designated two of its four
elderly/disabled buildings as elderly-only.  The other two buildings
are for mixed elderly/disabled occupancy.  TVRHA in Corinth
designated its one high-rise elderly/disabled building for the
elderly and near-elderly. 

HUD awarded Section 8 certificates for those younger persons with
disabilities in Dallas who wanted to move out of the buildings
designated for the elderly into privately owned rental units in the
community.  HUD also required the Fall River Housing Authority to
offer certain certificates it had been awarded previously to younger
persons with disabilities.  TVRHA officials told us that they had not
requested additional certificates or vouchers for persons with
disabilities because there was no need for them.  The authority had
no elderly or persons with disabilities on its waiting list. 
Officials at all three housing authorities stated that the elderly
and persons with disabilities may apply for appropriately sized units
in any of the other buildings the authorities manage.  TVRHA reported
that elderly and persons with disabilities constitute over two-thirds
of their public housing residents.  Housing authority officials in
Fall River said they constitute almost 39 percent. 

Table III.2 shows the number of units designated for the elderly and
for persons with disabilities as a result of the allocation plans,
and also shows the number of units that are not designated but are
considered elderly/disabled units. 



                              Table III.2
                
                 Federally Funded Public Housing Units
                      for Elderly and Persons With
                              Disabilities

                                                  Intended
                                    Designated   primarily  Undesignat
                                            as         for      ed but
                             Total    elderly-  nonelderly    elderly/
Location                     units        only    disabled    disabled
----------------------  ----------  ----------  ----------  ----------
Fall River, MA               1,707         637         208         N/A
Dallas, TX                   4,647         319         N/A         407
Corinth, MS                    343          50         N/A         N/A
----------------------------------------------------------------------
Note:  N/A means not applicable. 


--------------------
\39 In 1992, we reported that, in some cases, younger persons with
mental disabilities caused moderate or serious problems, such as
threatening other tenants and having disruptive visitors, and that
the number of these nonelderly persons with disabilities living in
public housing for the elderly was increasing.  See Public Housing: 
Housing Persons With Mental Disabilities With the Elderly
(GAO/RCED-92-81, Aug.  12, 1992). 


   IMPACT OF THE ALLOCATION PLANS
   AND CERTIFICATES AND VOUCHERS
------------------------------------------------------- Appendix III:1

The impact of the allocation plans on affordable housing for persons
with disabilities was minimal, at the time of our visits.  Occupancy
in the buildings designated for the elderly had not changed
substantially since the housing authorities submitted their
allocation plans, and where certificates and vouchers had been made
available, persons with disabilities on waiting lists were able to
use them to find housing.  TVRHA allowed near-elderly persons with
disabilities--those between the ages of 50 and 62--to move into its
elderly-only building.  Most of the persons with disabilities living
in the units designated for the elderly in Fall River and Dallas
chose to remain there rather than use the Section 8 certificates
allocated for them, according to housing authority officials.  In
Fall River, where 76 certificates had been set aside for the 77
persons with disabilities occupying units in elderly-only buildings,
22 chose to use a certificate to move.  In Dallas, which had 80
certificates allotted, 20 tenants used them.  As for the remaining
certificates, the Fall River authority offered them to younger
persons with disabilities on its other waiting lists, and all have
been used.  Dallas officials intend to offer them to people from
other developments but, at the time of our visit, had not yet made
them available.  They also told us that 49 additional persons with
disabilities had requested the certificates but had subsequently
returned them to the authority unused.  The officials said they
believed these residents decided to stay in their current units
because they felt comfortable there, but we did not verify this
assertion. 

Most of the advocates for persons with disabilities we spoke with
told us that their clients should be able to choose to live wherever
they want.  Some prefer to live independently, and some like the
security and amenities offered in buildings designed for the elderly. 
An advocate in Fall River did not consider the building reserved for
persons with disabilities an attractive alternative and told us that
the trend now is for this population to live in the community and
arrange for support services of their own choosing.  Similarly, some
advocates for the elderly told us that the elderly should have
choices and that they prefer to live among other elderly and not
among younger people. 

Officials at all three housing authorities with approved allocation
plans told us that the length of time the elderly and persons with
disabilities remain on the waiting list is about the same as it was
prior to the allocation plans.  They said that the average time an
applicant remains on the waiting list is between 60 to 90 days in
Dallas, about 2 to 3 months in Fall River, and about 30 days in
Corinth. 


   IMPACT OF CERTIFICATES AND
   VOUCHERS WHERE THERE WERE NO
   ALLOCATION PLANS
------------------------------------------------------- Appendix III:2

While three of the six authorities we visited--Gloucester County,
Anaheim, and San Francisco--do not have allocation plans, housing
authorities in Gloucester County and Anaheim received vouchers for
nonelderly persons with disabilities.\40 The San Francisco housing
authority had neither an allocation plan nor special certificates or
vouchers for persons with disabilities at the time of our visit, but
said it had considered the issue in the past and is likely to submit
an allocation plan at some future point.  The housing authorities in
Gloucester County and Anaheim requested vouchers for persons with
disabilities on their waiting lists, but for different reasons.  The
Housing Authority of Gloucester County manages a Section 8 project
that it designated as elderly-only in 1993 because the project was
originally built for the elderly.  To offset the loss of units to
persons with disabilities in this building, the housing authority
applied for 130 vouchers--roughly enough to handle all persons with
disabilities on its waiting lists.  The Anaheim Housing Authority
manages no public housing units, so it will use its 100 vouchers for
persons with disabilities on its Section 8 waiting list. 

At the time of our visits, it was too early to determine the impact
of these additional vouchers on affordable housing for persons with
disabilities, as neither housing authority had been able to issue
them all, officials there said.  HUD awarded funding for Gloucester
County's vouchers in September 1997.  Officials from the authority
said they then hired and trained a staff person to assist persons
with disabilities.  As of January 1998, the authority had interviewed
80 applicants, had successfully utilized 10 vouchers to provide
housing, and hoped to utilize 30 more by February 1. 

Officials from the Anaheim Housing Authority said they had not issued
any vouchers at the time of our visit because funding had been
awarded only recently.  They said they expected all the vouchers to
be used and planned to apply for more in the future because of the
demand.  They also said that with existing Section 8 certificates and
vouchers, persons with disabilities and the elderly have been
relatively easy to place compared with low-income families because
they are less transient than the families that apply for assistance. 
The only difficulty the officials anticipated was in placing persons
with mental disabilities.  But, according to its voucher application,
the authority plans to help individuals using these vouchers find
housing and also work with local agencies to provide additional
support services to these tenants. 

Officials from the San Francisco Housing Authority told us that the
use of certificates and vouchers by persons with or without
disabilities has been problematic because of the tight housing market
there.  Rents are very high and usually exceed what a certificate or
voucher will cover, making it difficult to find an appropriate
apartment using a Section 8 certificate or voucher, they said. 
Moreover, they have not opened their Section 8 waiting list since
1986, when about 10,000 households applied. 

An official from the Housing Authority of Gloucester County said that
persons with disabilities who apply for certificates or vouchers
return them unused at about the same rate as other people.  Anaheim
authority officials told us that they usually do not have problems
placing the elderly or persons with disabilities.  However, a San
Francisco Housing Authority official said persons with disabilities
often have special problems using the certificates or vouchers in
that area because apartments are scarce, the process of looking for
an apartment is challenging in the hilly city, and discrimination
against persons with physical and mental disabilities is believed to
be pervasive.  In Gloucester County and Anaheim, housing authority
officials said that for every three Section 8 certificates or
vouchers issued, two are returned and one is used.  Gloucester County
attributed this high turnback rate, in some cases, to applicants
being unable to afford the security deposits or utility bills.  They
also said that some persons with disabilities who live with their
families do not want to move away from home, but take a certificate
or voucher to please their families and then return it unused. 


--------------------
\40 The Housing Authority of Gloucester County submitted an
allocation plan, but HUD denied approval.  The authority plans to
modify and resubmit the plan. 


   FALL RIVER HOUSING AUTHORITY
------------------------------------------------------- Appendix III:3

Fall River is a city of about 91,000 located in the southeastern
corner of Massachusetts.  The Fall River Housing Authority's
allocation plan, approved in February 1996, designated six public
housing buildings for the elderly, with a seventh building primarily
serving younger persons with disabilities.  When the plan was
approved, HUD required the authority to offer Section 8 certificates
exclusively to persons with disabilities to compensate for the
housing units designated elderly-only. 

Fall River has a relatively depressed economy.  Although vacancy
rates in the private housing market are relatively high and rents are
relatively low, the area's high unemployment rate and low income
levels mean that many households still pay a large proportion of
their income in rent, putting Section 8 certificates and vouchers in
high demand.  When the waiting list for Section 8 assistance was last
opened in September 1997, over 1,100 people applied in a single day. 
Because vacancy rates are high and landlords generally welcome
Section 8 tenants, there is little difficulty with using certificates
or vouchers.  The housing authority administers 2,181 certificates
and vouchers. 

Fall River has a surplus of public housing, with more than 2,500
public housing units in buildings funded by the federal or state
government and nearly 1,700 units in private developments subsidized
by the federal or state government.  The overall vacancy rate is 9
percent, and waiting times for public housing are short--usually 2 to
3 months--for those who are willing to take the first available unit
in any building.  The housing authority has recently begun a
marketing effort to attract more applicants to public housing.  Table
III.3 shows the types of public and assisted housing in the
community. 



                              Table III.3
                
                  Public and Assisted Housing in Fall
                                 River

Type of units                                              Total units
----------------------------------------  ----------------------------
Public housing, federally funded                                 1,707
Public housing, state-funded                                       849
Section 8 certificates and vouchers                              2,181
Private developments, federal or state                         1,698\a
 subsidies
Total                                                            6,435
----------------------------------------------------------------------
\a There are 13 private housing developments, 10 of which are
administered by the Massachusetts Housing Finance Agency. 

Sources:  Fall River Housing Authority and HUD. 

The housing authority's allocation plan designated six of its seven
federally aided elderly/disabled projects as elderly-only.  At the
time the plan was approved, 77 younger persons with disabilities
lived in those projects.  A seventh project, Cardinal Medeiros
Towers, remained categorized as elderly/disabled, primarily serving
persons with disabilities under the age of 62.  A survey by the
housing authority found that of the younger persons with disabilities
living in the buildings designated elderly-only, 56 percent had
physical disabilities and 44 percent had mental disabilities, which
included mental illness, retardation, and substance abuse. 

Officials at the authority said that they decided to submit an
allocation plan because of complaints from elderly residents that
many of the younger residents played loud music, had undesirable
visitors at all hours of the night, or behaved in a generally
threatening or disruptive manner.  Officials at the authority and an
advocate for the elderly said that active hostility between the
elderly and the younger residents with disabilities ran both ways,
resulting in a tense living environment.  They also said that the
issue was one of age and not disability. 

None of the 77 younger persons with disabilities occupying units in
elderly-only buildings was forced to move.  The authority said it
offered each a Section 8 certificate or the opportunity to move to
other public housing units, including Cardinal Medeiros Towers, and
also offered staff assistance and money to help with the move. 
Twenty-two of the 77 had moved out of the elderly-only buildings by
November 1997, most using Section 8 certificates.  Housing authority
staff said that it has not been difficult for persons with
disabilities to find appropriate apartments in Fall River using the
certificates.  The rest of the certificates were used by persons with
disabilities who had been on the waiting lists for public housing or
for Section 8 assistance. 

Elderly residents are very happy with the results of the allocation
plan, according to housing authority officials, who also said that
there have been no complaints from younger persons with disabilities. 
We spoke with a representative of an advocacy group for persons with
disabilities who said she was concerned that the allocation plan did
not do enough to ensure the availability of accessible housing for
persons with physical disabilities.  She also did not consider the
one federal public housing option left open to younger persons with
disabilities, Cardinal Medeiros Towers, to be an attractive
alternative. 


   DALLAS HOUSING AUTHORITY
------------------------------------------------------- Appendix III:4

Dallas is the eighth largest city in the United States, with a
population of more than 1 million people.  In January 1995, the
Dallas Housing Authority submitted an allocation plan to designate
two of its four elderly/disabled buildings as elderly-only.  HUD did
not respond within the 90 days established by law, so the plan was
approved by default.\41 To provide an opportunity for persons with
disabilities living in designated housing to move into the community,
the housing authority requested and received 80 Section 8
certificates. 

Dallas has a tight rental market, with a vacancy rate around 5.5
percent and an estimated average rental cost of $696 for a
two-bedroom unit.  About 46 percent of low- and moderate-income
households pay more than 30 percent of their income for rent, and
that figure rises to about 72 percent among those with very low
incomes, according to HUD data. 

As of January 1998, 726 of the housing authority's 4,647 public
housing units in four developments were designated for the elderly
only or for the elderly/disabled (mixed housing).  The authority owns
another four buildings with a total of 572 units that receive
project-based Section 8 assistance and that are reserved for
residents who are elderly or have disabilities.  The authority also
administers funds to pay for 30 Section 8 units in a property run by
the Deaf Action Center.  Table III.4 shows the number of HUD-assisted
housing units available. 



                              Table III.4
                
                  HUD-Assisted Housing in the City of
                                 Dallas

Type of units                                          Number of units
----------------------------------------  ----------------------------
Public housing                                                   4,647
Assisted housing                                                18,682
Section 8 certificates/vouchers                                  9,182
======================================================================
Total                                                           32,511
----------------------------------------------------------------------
Sources:  The Dallas Housing Authority and HUD. 

The authority developed its allocation plan because concerns arose
about mixing elderly residents and younger people with disabilities. 
Staff told us that some of the elderly residents at the mixed
developments had raised noise and security issues.  In addition, a
resident survey indicated strong support for elderly-only housing. 

The impact of the housing authority's allocation plan on persons with
disabilities has been minimal thus far.  Occupancy in the two
buildings designated as elderly-only remained generally the same
before and after the designation.  The two developments designated,
Audelia Manor and Park Manor, had been mixed elderly/disabled housing
and had a total of 319 units. 

The authority requested and received 80 certificates to assist the
younger tenants with disabilities expected to move out of the
designated units.  The authority also provided incentives, offering
to pay for moving expenses, moving supplies, and telephone
reconnection fees, but did not require anyone to move.  At the time
of our visit, 20 of the younger tenants with disabilities in the
designated developments had used certificates to rent apartments in
the private sector.  Another 49 had requested certificates but
returned them unused.  Authority staff told us that many of these
residents were reluctant to leave the security of their surroundings. 
Most still reside in the buildings.  The housing authority received
permission from HUD to offer the remaining certificates to people
with disabilities residing at other developments and, as of April
1998, were offering them to residents at Forest Green and Lakeland
Manor. 

To assist the residents with disabilities eligible for the 80
certificates, the Dallas Housing Authority generally used its regular
Section 8 program to locate housing in the community.  Under this
program, the authority provides lists of landlords willing to rent to
Section 8 tenants and takes prospective Section 8 families on van
tours to properties that will accept certificates.\42 To further
assist the residents moving out of the developments newly designated
for the elderly, the housing authority contacted local landlords to
find those willing to rent to people with disabilities.  Housing
authority staff told us that landlords were typically more willing to
accept Section 8 individuals who were physically disabled than they
were to accept families receiving Section 8 assistance.  Advocates
for people with disabilities in Dallas said that the housing issues
their clients face are usually related to accessibility rather than
to the availability of assisted housing. 

Although the allocation plan did not result in as many of the younger
residents with disabilities moving out of the buildings designated
for the elderly as the housing authority had anticipated, officials
said complaints from elderly residents had declined even though
occupancy had not changed dramatically. 

Designating housing for the elderly has not affected waiting time for
units.  The waiting time for those needing an elderly/disabled unit
is about 60 to 90 days, though the wait may be as long as 6 months if
the applicant needs a studio or an accessible unit.  This contrasts
with an average waiting time of about 60 days for a regular public
housing unit.  The longer wait for elderly/disabled units stems from
the lesser availability of those units, however, not from the impact
of the allocation plan. 


--------------------
\41 The Housing Opportunity Program Extension Act of 1996, among
other things, shortened the time HUD has to notify public housing
authorities of its approval or disapproval of the allocation plans
they submit from 90 to 60 days. 

\42 The housing authority is currently operating under a remedial
order that resulted from the settlement of a lawsuit that alleged
discriminatory practices, according to officials of the authority. 
The settlement required the authority to implement a mobility program
to, among other things, assist its Section 8 families in locating
housing in areas of Dallas that are not impoverished. 


   TENNESSEE VALLEY REGIONAL
   HOUSING AUTHORITY
------------------------------------------------------- Appendix III:5

Corinth is a city with a population of fewer than 12,000 in Alcorn
County in northeastern Mississippi.  Public housing is administered
by both the Housing Authority of the City of Corinth and the
Tennessee Valley Regional Housing Authority (TVRHA), which serves
Alcorn and nine other counties.  TVRHA also administers Section 8
certificates and vouchers for its 10-county area.  In 1995, TVRHA
submitted an allocation plan to designate all 50 units in the
development in Corinth known as Fort Robinett Manor as elderly-only. 
HUD approved the plan on March 30, 1995.  TVRHA designated Fort
Robinett for elderly residents because 96 percent of its units were
occupied by the elderly and the development has amenities ideally
suited for the elderly.  TVRHA officials also told us that mixing
elderly and younger persons with disabilities is not always a good
idea.  TVRHA has not requested Section 8 certificates or vouchers for
the exclusive use of persons with disabilities but administers 168
regular certificates and vouchers in Alcorn County.  Corinth has 673
units of public housing, managed by two housing authorities.  About
66 percent of the units are occupied by either elderly tenants or
persons with disabilities, according to the two authorities.  Housing
authority officials and managers of private projects said that
subsidized housing units are overabundant in Corinth, and managers
are concerned about a high vacancy rate of around 11 percent. 
Corinth has more subsidized housing for its population than any place
else in the world, according to an official from the city's housing
authority.  The fair market rent for a one-bedroom unit is $290 per
month; most units administered by TVRHA rent for $77 plus utilities. 
Table III.5 shows the categories of public and assisted housing in
Corinth. 



                              Table III.5
                
                 Public and Assisted Housing in Corinth

Type of units                                          Number of units
--------------------------------------------------  ------------------
Public housing, TVRHA                                            343\a
City of Corinth public housing                                     330
Section 8 certificates, TVRHA (Alcorn County-                    150\b
 wide)
Section 8 vouchers, TVRHA (Alcorn County-wide)                      18
HUD assisted housing                                                40
Rural rental housing, USDA                                       235\c
======================================================================
Total                                                            1,116
----------------------------------------------------------------------
\a TVRHA administers HUD programs in 10 counties, which include 1,214
units of public housing.  All of TVRHA's 343 public housing units in
Alcorn County are located in Corinth. 

\b TVRHA reported that it actually has 164 certificates in use
because the certificates are portable, and it was able to use excess
funds from the Housing Assistance Payments Contract for this purpose. 

\c The U.S.  Department of Agriculture's (USDA) Rural Development
provides subsidized rental units in Corinth. 

Sources:  TVRHA, the Housing Authority of the City of Corinth, HUD,
and the USDA Rural Development. 

The impact of TVRHA's allocation plan on housing opportunities for
public housing residents with disabilities appears to have been
insignificant thus far.  At Fort Robinett, occupancy had remained
nearly the same.  At the time the allocation plan was submitted, 49
of the 50 units were occupied by elderly households.  As of November
1, 1997, 44 units were occupied by elderly households, 3 by
near-elderly persons with disabilities, and 2 by near-elderly persons
without disabilities, for a total of 49 occupied units.  When
selecting applicants for handicapped-accessible units, TVRHA gives
priority to families that include disabled persons who can benefit
from those features. 

TVRHA officials told us they had not requested additional Section 8
certificates and vouchers to offset the impact of designating housing
for the elderly because there were no persons with disabilities on
the authority's waiting list.  In addition to the handicapped units
at Fort Robinett, TVRHA has converted 17 more units for persons with
disabilities in Corinth--10 are wheelchair-accessible and 7 are for
those who have visual or hearing impairments.  Authority officials
said that these additional units, along with the normal turnover
rate, provide sufficient housing for the younger persons with
disabilities who are no longer eligible to live at Fort Robinett. 
Moreover, the allocation plan states that if any of the designated
units are vacant for over 60 days, they will be made available to
younger applicants. 

For Section 8 certificates and vouchers, TVRHA reported that persons
with disabilities and the elderly are given priority over single
applicants who are not elderly and who do not have disabilities. 
Renting units with Section 8 assistance is generally not a problem
for persons with disabilities, as they usually have a landlord in
mind who has been contacted and is willing to work with them,
according to TVRHA.  However, few landlords are willing to make
expensive modifications for tenants they are unfamiliar with because
they do not know how long the tenants will stay.  A TVRHA official
told us that as a result, it may sometimes take persons with
disabilities a little longer to secure a lease if units need various
changes to comply with HUD standards.  TVRHA officials said that
persons with disabilities usually prefer public housing instead of
certificates or vouchers because the public housing units are better
equipped for their needs. 

An official from the Housing Authority of the City of Corinth told us
that the authority had no need to designate housing for the elderly. 
It operates a 100-unit development for the elderly and persons with
disabilities.  At the time of our visit, 17 of the units were
occupied by persons with disabilities, but most of these tenants were
between 50 and 58 years old and fit in well with the older residents. 
He also told us that younger persons with disabilities do not
generally apply to live in this building.  Were the situation to
change and problems were to develop, the housing authority might
consider submitting an allocation plan to designate housing, the
official said. 


   HOUSING AUTHORITY OF GLOUCESTER
   COUNTY
------------------------------------------------------- Appendix III:6

Gloucester County, New Jersey, with a population of about 230,000, is
located within the highly urbanized Philadelphia metropolitan area,
although many parts of the county are rural or small-town in nature. 
In 1990, about 35 percent of the county's 79,000 households had low
or moderate incomes, according to data provided by Gloucester County. 
Because housing costs had risen much faster than household incomes,
almost 22 percent of all households paid over 30 percent of their
gross income for housing costs.  The overall housing vacancy rate in
the county was 4.4 percent. 

In 1997, HUD awarded the Housing Authority of Gloucester County 130
Section 8 vouchers for persons with disabilities as an alternative to
units in a building the authority had designated for the elderly in
1993.  The authority submitted an allocation plan in 1997 to
designate additional housing for the elderly, but HUD denied the plan
because it lacked necessary information.  However, in March 1998, HUD
conditionally approved the authority's revised allocation plan
subject to certain revisions. 

The authority has 262 public housing units and manages another
building with 199 units that receive Section 8 project-based rental
assistance.  With the exception of 20 units for people with mobility
impairments, the authority designated this 199-unit building for the
elderly in 1993.\43 To compensate for any loss of housing for persons
with disabilities, the authority applied for and received 130
additional vouchers because 133 younger persons with disabilities
were on its waiting lists for other programs.  Of the authority's
1,485 regular Section 8 certificates and vouchers, 260 were used by
persons with disabilities and 252 by elderly persons at the time of
our visit. 

In addition to the Housing Authority of Gloucester County, the
Housing Authority of the Borough of Glassboro also administers public
housing and Section 8 certificates in Gloucester County.  Table III.6
shows the number of subsidized units in the county. 



                              Table III.6
                
                     Public and Assisted Housing in
                           Gloucester County

Type of housing                                        Number of units
--------------------------------------------------  ------------------
Public housing (Housing Authority of Gloucester                    262
 County)
Public housing (Housing Authority of the Borough                   180
 of Glassboro)
Section 8 certificates and vouchers, including 130               1,615
 vouchers for persons with disabilities (Housing
 Authority of Gloucester County)
Section 8 certificates (Housing Authority of the                   112
 Borough of Glassboro)
State agency certificates and vouchers (State of                   176
 New Jersey)
Rural rental housing\a                                             248
HUD, project-based                                               1,431
======================================================================
Total                                                            4,024
----------------------------------------------------------------------
\a USDA Rural Development provides subsidized rental units. 

Sources:  USDA Rural Development and HUD. 

Besides the units already designated for the elderly, the allocation
plan the authority submitted unsuccessfully in 1997 would have
limited two high-rise buildings with a total of 200 units to elderly
and near-elderly tenants aged 50 and over.  The authority's director
told us he plans to modify the plan and resubmit it to HUD for
approval. 

Advocates both for the elderly and for persons with disabilities said
the housing problem in Gloucester County was a lack of affordable
housing, not necessarily mixing the two populations.  Overall,
advocates for the disabled said that the younger persons with
disabilities should have the freedom to choose where they live
because not all of them want to live with the elderly or with other
persons with disabilities.  However, this group may want to select
units in buildings for the elderly because many offer important
amenities, such as security, transportation, and supportive services. 
An official from the county office for the disabled said that
security is especially important for people who have visual or
hearing impairments.  At the same time, younger persons with
disabilities who are capable of living independently usually prefer
to do so.  An official from the department on aging said that she
believes the elderly prefer to live among other elderly because of
the conflicting lifestyles of younger persons with disabilities. 

At the time of our visit, it was too soon to determine the impact of
the special vouchers on the supply of affordable housing for persons
with disabilities because the authority was just beginning to issue
them.  To administer the 130 vouchers after HUD awarded funding in
September 1997, the authority hired a full-time staff person, who had
then spent several months in training before working with persons
with disabilities full time.  As of January 1, 1998, 40 vouchers had
been provided to persons with disabilities, 10 of which had been
successfully used to obtain housing.  An official said it was hoped
the other 30 recipients would have housing by February 1.  The number
of persons with disabilities on the authority's waiting list has
increased in the time since the authority applied for the 130
vouchers.  Staff said they would apply for additional vouchers if
necessary. 

The turnback rate for Section 8 certificates and vouchers issued to
persons with disabilities is about the same as for other Section 8
applicants--for every three certificates or vouchers issued, two are
returned, according to authority officials.  Among the reasons they
cited were applicants' not being able to afford security deposits or
utility bills and some applicants' requesting rental assistance as a
token effort to please their families, then returning the
certificates or vouchers unused. 


--------------------
\43 This building is owned by Senior Housing Development Corporation
of Gloucester County, an instrumentality of the Housing Authority of
Gloucester County, which is the managing agent.  The building is a
Section 8 non-FHA-insured, federally funded project with a Housing
Assistance Payments contract.  Because the building was originally
built for the elderly in 1979, the authority was able to designate it
for elderly occupancy under section 651 of the 1992 act. 


   ANAHEIM HOUSING AUTHORITY
------------------------------------------------------- Appendix III:7

Anaheim is a city with a population of approximately 300,000 in
Orange County in southern California.  The Anaheim Housing Authority
administers no public housing and therefore has no allocation plan,
but it provides other housing assistance, including Section 8 rental
certificates and vouchers.  Housing authority officials told us they
applied for 100 vouchers exclusively for persons with disabilities
because they had a high number of these people on their waiting list
for housing assistance--about 1,500 of the 6,000 individuals listed. 
The authority recently received those vouchers from HUD's 1997
funding for Mainstream Housing Opportunities for Persons With
Disabilities (the mainstream program). 

The need for affordable housing in Anaheim, particularly for the
elderly and for persons with disabilities, is great, according to
officials of the housing authority and of advocacy groups we spoke
with.  HUD data indicate that 70 percent of the city's elderly
residents pay more than 30 percent of their income for rent, with
many paying more than 50 percent.  According to an advocacy group for
persons with disabilities, its clients' incomes are about $600 a
month, making the typical rents for a one-bedroom apartment of $580
to $640 per month unaffordable.  Subsidized private housing projects
for the elderly and for persons with disabilities provide 391
affordable units in Anaheim.  Of the approximately 3,400 low-income
households receiving Section 8 certificates and vouchers in Anaheim
in 1995, about 1,300 were elderly or persons with disabilities. 

At the time of our visit, the Anaheim Housing Authority had not yet
issued any of the 100 vouchers HUD had awarded under the mainstream
program for persons with disabilities.  Housing authority officials
said they expected to use all of them, however, and planned to apply
for more vouchers in the future because of the demand. 

The effects of the 1992 act in Anaheim have been positive for persons
with disabilities, according to the housing authority officials, who
believed it had increased the number of affordable housing
opportunities for this group.  Because of the mainstream program
vouchers, they said they expected to be housing persons with
disabilities on their waiting list at a faster rate than other
applicants. 

On the basis of their previous experience with regular certificates
and vouchers, housing authority officials said they do not anticipate
difficulties or delays in using the mainstream program vouchers. 
They said persons with disabilities and the elderly have been
relatively easy to place compared with low-income families, which
tend to be more transient and often move out of the Anaheim area
before they use their certificates or vouchers.  The housing
authority officials anticipated greater difficulty with placing
persons with mental disabilities.  According to these officials,
evictions have been more common with this particular group than with
others, but they believe that this problem can be averted if these
tenants receive the necessary support services. 

To assist individuals in using the vouchers, the housing authority
plans to assemble a list of accessible rental units, provide
assistance to landlords willing to make modifications to make their
properties accessible, assign a full-time housing counselor to help
the mainstream program participants, and work with local nonprofit
agencies to get tenants additional support services.  The mainstream
vouchers will be offered first to the persons with disabilities who
have been on the housing authority's waiting list the longest. 

Officials of the housing authority and the advocacy group for the
disabled with whom we spoke generally agreed that "mainstreaming" is
the best housing option for persons with disabilities, although they
did not see a particular problem in housing elderly and persons with
disabilities together.  Housing authority officials qualified this by
saying that mainstreaming is usually the best option for persons with
physical disabilities, whereas persons with mental and developmental
disabilities usually do better in group settings where they get the
emotional support and the services that they need.  Officials we
spoke with at an advocacy group for persons with disabilities fully
supported mainstreaming in all cases because they believed that
segregation perpetuates stereotypes and prevents persons with
disabilities from believing that they can take care of themselves or
work. 


   SAN FRANCISCO HOUSING AUTHORITY
------------------------------------------------------- Appendix III:8

San Francisco is a racially and ethnically diverse city of about
760,000 people in northern California.  The San Francisco Housing
Authority has not submitted an allocation plan and has not obtained
certificates or vouchers exclusively for persons with disabilities. 
While the authority administers almost 5,000 certificates and
vouchers, San Francisco's housing market is extraordinarily tight and
finding landlords willing to accept Section 8 applicants--with or
without disabilities--has become a serious problem, according to
housing authority officials. 

The vacancy rate for rental units is very low, and rents have gone up
substantially in the past 2 years, with the median market rent for a
one-bedroom apartment in larger buildings at over $1,500.  According
to information provided by the Mayor's Office of Housing, affordable
housing is thus extremely scarce in San Francisco, and 55 percent of
low-income and 73 percent of very low-income renter households pay
more than 30 percent of their incomes in rent.  Overcrowding and
homelessness are also significant problems. 

Advocates for persons with disabilities with whom we spoke
universally described the housing situation for persons with
disabilities in San Francisco as extremely dire.  The housing stock
is generally old, and units tend to be small.  The topography of the
city, with its many hills, limits accessibility for persons with
disabilities and makes apartment-hunting difficult.  Less than 2
percent of the city's private rental stock is estimated to be
minimally accessible to people with physical disabilities.  The
situation is particularly difficult because discrimination against
persons with both physical and mental disabilities is believed to be
pervasive. 

The San Francisco Housing Authority has 43 developments with a total
of 6,722 units of public housing serving 12,436 residents. 
Twenty-one of these developments, serving 2,165 residents, are
intended to be elderly/disabled housing.  Roughly 9 percent of the
residents of these developments are persons with disabilities who are
under the age of 60.  The housing authority settled a class-action
lawsuit in 1991 by agreeing to increase its number of
handicapped-accessible units.  A Special Master appointed by the
court is assisting in the implementation of the settlement.  At the
time of our visit, the authority had only 144 accessible public
housing units, but it was adapting several hundred more and expected
to have 690 accessible or adaptable units within a few years. 

In addition to public housing, San Francisco has 9,892 project-based
units in 87 developments that either have federally insured mortgages
or receive federal subsidies.  The San Francisco Housing Authority
also administers 4,945 Section 8 certificates and vouchers.  The
authority has not applied for any certificates or vouchers since
about late 1995 because of various internal problems, an official
said. 

With the recent tightening of the housing market, finding landlords
willing to rent to people with Section 8 certificates and vouchers
has become problematic, in large part because HUD's fair market rents
are considered too low, according to both housing authority officials
and advocates.  Authority staff said that in their experience, about
15 percent of those receiving certificates or vouchers turn them
back, mostly because they cannot find affordable rental units;
another 30 percent or so have to move outside of San Francisco to
find affordable housing.  HUD is currently collecting data and
considering modifications to its fair market rent in San Francisco. 

The waiting lists for all types of subsidized housing are very long,
according to authority officials.  About 11,600 people are on the
waiting list for public housing, with an average wait of at least 2.5
to 3 years.  For persons with disabilities, the wait is slightly
longer because of a shortage of studio and one-bedroom apartments,
though for persons requiring handicapped-accessible units the wait is
slightly shorter.  The waiting list for certificates and vouchers has
not been opened since 1986, when about 10,000 people applied; as of
February 1998, the authority was still working off that list.  The
wait for units in the project-based Section 8 developments we visited
was at least 3 to 5 years. 

The authority had put together an exploratory committee in the early
1990s to consider the issue of designating certain buildings of its
own as elderly-only, but the committee fell to the wayside because of
other pressing concerns.  The authority has been working with a HUD
recovery team, and authority officials said that once the current
restructuring is complete, the issue will be revisited and an
allocation plan will likely be submitted to HUD. 

The authority first explored the possibility of submitting an
allocation plan to designate housing because of a perceived conflict
between elderly residents and younger persons with disabilities and a
strong consensus among the elderly tenants that they would prefer to
live among other seniors.  Elderly residents complained that younger
tenants played loud music; had guests at all hours of the night; and
displayed intimidating, threatening, or bizarre behavior.  The main
source of concern was younger residents who were mentally ill. 
Housing authority officials estimated that 70 to 80 percent of the
younger residents with disabilities had mental rather than physical
disabilities. 

When the idea of designating buildings as elderly-only was initially
discussed, many of the younger tenants with disabilities expressed
strong concerns.  We spoke with representatives of five advocacy
organizations for persons with disabilities.  Some said that the
concerns about mixing the elderly and younger persons with
disabilities were misguided and based largely on overreaction and
misunderstanding.  In general, they feared that elderly-only
designations would reduce the housing options for persons with
disabilities.  This is a special concern in San Francisco, they said,
where public housing and project-based Section 8 housing are the only
viable alternatives for many persons with disabilities because it is
so difficult to find affordable and accessible housing using a
certificate or voucher.  The advocates opposed segregating persons
with disabilities in housing designated disabled-only, which they
perceived as isolating, unfair, and antithetical to the ideal of
integrating persons with disabilities into mainstream society. 




(See figure in printed edition.)Appendix IV
PUBLIC HOUSING SURVEY INSTRUMENT
AND RESULTS
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


SECTION 8 CERTIFICATES AND
VOUCHERS FOR PERSONS WITH
DISABILITIES
=========================================================== Appendix V

Since passage of the Housing and Community Development Act of 1992,
HUD has made Section 8 certificates and vouchers for persons with
disabilities available in two ways:  in connection with designated
housing or through a mainstream housing opportunities program.\44

The funds for these certificates and vouchers, totaling $278.9
million, came from HUD's administrative set-asides and from
congressional set-asides in HUD's appropriations. 

The purpose of Section 8 certificates and vouchers awarded in
connection with designated housing is to offset the effects of
reserving units in public and privately owned, HUD-subsidized housing
for elderly residents.  To receive certificates and vouchers in
connection with designated public housing, a PHA must have a
HUD-approved allocation plan.  While HUD is more inclined to award
certificates and vouchers to a PHA that has designated units for the
elderly that were previously available to younger people with
disabilities, HUD officials told us that they look at other factors
as well in determining how many certificates and vouchers a PHA
should receive in connection with designated housing.  These factors
include the PHA's vacancy rates, the demand for affordable housing by
persons with disabilities, and the availability of other types of
housing to persons with disabilities, including efficiencies and
one-bedroom units in the PHA's family developments.  The number of
certificates or vouchers HUD awards a PHA is not a one-for-one
replacement for the units that the PHA has designated as
elderly-only.  Moreover, designating units as elderly-only does not
guarantee that a PHA will receive additional certificates and
vouchers.  These certificates and vouchers have budget authority
terms of 1, 2, and 5 years, depending on the funding.\45

In communities where privately owned, HUD-subsidized projects have
established preferences for the elderly, the housing authorities can
apply for certificates and vouchers if they can identify the number
of nonelderly persons with disabilities who are not receiving housing
assistance as a result of these preferences.  To prepare their
applications, the housing authorities may seek assistance from their
local HUD field offices to identify these privately owned projects. 
These certificates and vouchers have 1-year terms. 

The mainstream housing program is intended to provide persons with
disabilities greater opportunities to find affordable housing of
their choice in their communities (hence, the term "mainstreaming"). 
Any housing authority that administers the Section 8 rental
assistance program is eligible to apply for the mainstream
certificates and vouchers and may issue them to any persons with
disabilities eligible for Section 8 assistance.  The requirements for
the mainstream certificates and vouchers are less restrictive than
those for certificates and vouchers connected with designated
housing, and PHAs are not required to submit allocation plans to
qualify.  The mainstream program's certificates and vouchers have
terms of 5 years. 

As of November 1, 1997, HUD had made available $190.4 million of the
total $278.9 million set aside since 1992 for certificates and
vouchers for persons with disabilities.  To do so, HUD issued four
notices of funding availability:  one in March 1995, another in
October 1996, and two in April 1997.  The remaining $88.5 million was
from HUD's fiscal year 1998 appropriation:  $40 million of it to be
used in connection with designated public and private housing and
$48.5 million to be used for the mainstream program.\46 HUD issued a
fifth notice of funding availability on April 30, 1998, for these
funds and for the funds remaining from the fiscal year 1997
appropriation of $50 million. 

As table V.1 shows, only the funds made available through two of the
notices have been totally awarded:  the $13.3 million made available
through the March 1995 notice and the $48.5 million made available
through the April 1997 notice for the mainstream program.  Of the
$78.6 million HUD made available through its October 1996 notice,
$48.7 million had been awarded as of November 1, 1997, and HUD was
continuing to make awards.  HUD said that between November 1, 1997,
and March 1, 1998, it had awarded another $15 million from the
October 1996 notice to PHAs with newly approved allocation plans. 
HUD expected to award the remainder of the funds by the end of fiscal
year 1998. 



                                        Table V.1
                         
                         HUD Notices of Funding Availability for
                             Persons With Disabilities, as of
                                     November 1, 1997

                                                                                Number of
                                                                                  housing
                                                            Total              authoritie
                                                            funds       Total           s
Date of                                                 available     awarded   receiving
notice      Purpose of notice                          (millions)  (millions)    awards\a
----------  -----------------------------------------  ----------  ----------  ----------
March 1995  Designated housing through allocation         $13.3\b       $13.3          10
             plan
October     Designated housing through allocation            78.6        48.7          25
 1996        plan
April 1997  Mainstream housing                               48.5        48.5          25
April 1997  Designated housing through allocation            50.0         2.7           5
             plan and establishment of preferences by
             privately owned projects
-----------------------------------------------------------------------------------------
\a Six PHAs received certificates and vouchers for both designated
housing and mainstream purposes. 

\b In the March 1995 funding notice, HUD originally made available
$85.6 million, of which half was be used for certificates and
vouchers in conjunction with allocation plans and half for the
general mainstream program.  HUD subsequently rescinded most of this
funding.  The $13.3 million is the actual amount obligated. 

Source:  HUD. 

Of the $50 million made available under HUD's 1997 notice made in
connection with designated public and private housing, $2.7 million
had been awarded as of November 1, 1997.  The funds made available
through the notice were set aside by the Congress in HUD's fiscal
year 1997 appropriation.  Half of the money was earmarked for PHAs
with approved allocation plans, the other half for housing
authorities that could identify the impact that elderly preferences
established by privately owned projects in their communities had on
persons with disabilities.  As of November 1, 1997, none of the $25
million for PHAs with approved allocation plans had been awarded. 
HUD officials said the money will be used once all the funding from
the October 1996 notice is awarded.  Of the $25 million earmarked to
offset elderly preferences established by privately owned projects,
HUD had awarded $2.7 million to five PHAs that were able to identify
the impact the preferences had on persons with disabilities. 

As mentioned previously, the funding made available under the other
notice HUD issued in April 1997--the notice for the mainstream
program--had been totally awarded by November 1, 1997.  The $48.5
million made available through this notice came from the fiscal year
1997 funds appropriated for the Section 811 program for the capital
development of privately owned projects for persons with
disabilities.  According to HUD, 281 PHAs submitted approvable
applications for this disproportionately more popular program, but
HUD was able to award funds to only 25, providing them with 1,756
certificates and vouchers. 


--------------------
\44 HUD has also made certificates and vouchers available for special
groups of persons with disabilities, such as those who are also
homeless or those who are also veterans.  We did not include these
certificates and vouchers in our analysis. 

\45 The different terms reflect the amount of budget authority that
the Congress provides to HUD for a given period of time to fund
certain certificates and vouchers.  These terms have no impact on how
long a recipient can use a certificate or voucher, but housing
authorities usually prefer a longer term because it represents a
longer funding commitment by HUD. 

\46 The $48.5 million represents 25 percent of fiscal year 1997 funds
appropriated for the Section 811 program for the capital development
of privately owned projects for persons with disabilities.  In the
fiscal year 1998 appropriation, the Congress also authorized the
Secretary of HUD, at his discretion, to use up to 25 percent of the
Section 811 funds for Section 8 certificates and vouchers for persons
with disabilities. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI

HOUSING AND COMMUNITY DEVELOPMENT
ISSUE AREA

Stanley J.  Czerwinski, Associate Director
Jason Bromberg
Martha Chow
J.  Davis
Dennis Fricke
Jacqueline Garza
Diana Gilman
Mathew Scire

DESIGN, METHODOLOGY, AND TECHNICAL
ASSISTANCE GROUP

Carolyn Boyce

WRITING AND EDITING GROUP

Leslie Albin

OFFICE OF THE GENERAL COUNSEL

John T.  McGrail


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