Native American Housing: Challenges Facing HUD's Indian Housing Program
(Testimony, 03/12/97, GAO/T-RCED-97-105).

GAO discussed the Department of Housing and Urban Development's (HUD)
Native American housing programs, focusing on the: (1) funding history
and results of HUD's housing programs for Native Americans; (2) factors
that complicate and make costly the development and maintenance of
affordable housing for Native Americans; and (3) HUD's ability to detect
mismanagement in Native American housing and the potential impact of the
recently enacted Native American Housing Assistance and
Self-Determination Act of 1996 on HUD's oversight of Native American
housing.

GAO noted that: (1) from fiscal year (FY) 1986 through FY 1995, HUD
provided $4.3 billion (constant 1995 dollars) for housing and community
development in tribal areas; (2) of this amount, HUD provided $3.9
billion to approximately 189 Native American housing authorities to
develop and maintain affordable housing and assist low-income renters;
(3) in this period, the authorities used the funds to construct over
24,000 single-family homes, operate and maintain existing housing, and
encourage other development; (4) over the decade, HUD also has provided
direct block grants totalling over $424 million (constant 1995 dollars)
to eligible tribes for community development and mortgage assistance;
(5) many factors complicate and make costly the development and
maintenance of affordable housing for Native Americans; (6) these
factors include the remoteness and limited human resources of many
Native American housing authorities and the Native American communities
they serve, land-use restrictions and the inhospitality of the land, the
difficulty that contractors and Native American housing authorities have
in complying with statutory requirements to give hiring preference to
Native Americans, and the vandalism and neglect that make heavy demands
on the scarce maintenance funds available to Native American housing
authorities; (7) in December 1996, the Seattle Times reported 29
instances of possible mismanagement or misuse of federal funds by Native
American housing authorities; (8) for example, the Times reported that
Native American housing authorities used federal funds to build luxury
homes, covered the mismanagement of one federal grant with funds from
another grant, and reprogrammed large federal grants without HUD's
approval; (9) HUD's Inspector General found that most of these reports
were accurate; (10) GAO's work found that HUD does not effectively apply
its system for alerting it to poorly performing Native American housing
authorities across its Native American Programs field offices; (11) as a
result, HUD may not be able to detect additional instances of
mismanagement or misuse of funding; and (12) futhermore, HUD's approach
to overseeing Native American housing may change, depending on
regulations now being developed to implement the new Native American
housing legislation.

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

 REPORTNUM:  T-RCED-97-105
     TITLE:  Native American Housing: Challenges Facing HUD's Indian 
             Housing Program
      DATE:  03/12/97
   SUBJECT:  Native Americans
             Indian lands
             Low income housing
             Federal aid for housing
             Hiring policies
             Housing construction
             Land use law
             Block grants
             Maintenance (upkeep)
             Community development
IDENTIFIER:  HUD Indian Housing Program
             HUD Public Housing Program
             HUD Mutual Help Home Ownership Program
             HUD Low Income Rental Program
             HUD Rental Program for Native Americans
             HUD Risk Assessment and Determination of Resources System
             HUD Partners in Progress Program
             
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Cover
================================================================ COVER


Before the Committees on Indian Affairs and Banking, Housing, and
Urban Affairs U.S.  Senate

For Release
on Delivery
Expected at
2:30 p.m.  EST
Wednesday
March 12, 1997

NATIVE AMERICAN HOUSING -
CHALLENGES FACING HUD'S INDIAN
HOUSING PROGRAM

Statement of Judy A.  England-Joseph,
Director, Housing and Community
Development Issues.
Resources, Community, and Economic
Development Division

GAO/T-RCED-97-105

GAO/RCED-97-105T


(385666)


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

  GAO -
  HUD -
  BIA -
  IHA -
  RADAR -
  PIP -

============================================================ Chapter 0

Messrs.  Chairmen and Members of the Committees: 

We are pleased to have this opportunity to discuss the Department of
Housing and Urban Development's (HUD) Indian housing programs.  The
federal government has moved from giving no recognition at all to
Indian housing needs; to funding them through Indian housing
authorities along with public housing; to establishing in October
1997 a system of housing block grants for the sovereign tribes to
provide them with additional opportunities for self-determination. 
Federal housing assistance is needed in tribal areas.  The Urban
Institute recently reported that 40 percent of Native Americans in
tribal areas live in overcroweded or physically inadequate housing
compared with 6 percent of the U.S.  population.\1 Moreover,
providing safe and decent housing at a reasonable cost in tribal
areas is difficult because of the austere and remote nature of the
setting. 

Today, our testimony focuses on the (1) funding history and results
of HUD's housing programs for Native Americans, (2) factors that
complicate and make costly the development and maintenance of
affordable housing for Native Americans, and (3) HUD's ability to
detect mismanagement in Indian housing and the potential impact of
the recently enacted Native American Housing Assistance and
Self-Determination Act of 1996 on HUD's oversight of Indian housing. 
Our testimony is based on our draft report on HUD's Indian housing
programs that we are preparing at the request of the Subcommittee on
VA, HUD, and Independent Agencies, House Committee on Appropriations;
our recent visits to several Indian housing authorities; and our
discussions with officials at selected field offices of HUD's Office
of Native American Programs. 

In summary, we found the following: 

  -- From fiscal year 1986 through fiscal year 1995, HUD provided
     $4.3 billion (constant 1995 dollars) for housing and community
     development in tribal areas.  Of this amount, HUD provided $3.9
     billion to approximately 189 Indian housing authorities to
     develop and maintain affordable housing and assist low-income
     renters.  In this period, the authorities used the funds to
     construct over 24,000 single-family homes, operate and maintain
     existing housing, and encourage other development.  Over the
     decade, HUD also has provided direct block grants totaling over
     $428 million (constant 1995 dollars) to eligible tribes for
     community development and mortgage assistance. 

  -- Many factors complicate and make costly the development and
     maintenance of affordable housing for Native Americans.  These
     factors include the remoteness and limited human resources of
     many Indian housing authorities and the Indian communities they
     serve, land-use restrictions and the inhospitality of the land,
     the difficulty that contractors and Indian housing authorities
     have in complying with statutory requirements to give hiring
     preference to Indians, and the vandalism and neglect that make
     heavy demands on the scarce maintenance funds available to
     Indian housing authorities. 

  -- In December 1996, the Seattle Times reported 29 instances of
     possible mismanagement or misuse of federal funds by Indian
     housing authorities.  For example, the Times reported that
     Indian housing authorities used federal funds to build luxury
     homes, covered the mismanagement of one federal grant with funds
     from another grant, and reprogrammed large federal grants
     without HUD's approval.  HUD's IG found that most of these
     reports were accurate.  Our work found that HUD does not
     effectively apply its system for alerting it to poorly
     performing Indian housing authorities.  As a result, HUD may not
     be able to detect additional instances of mismanagement or
     misuse of funding.  Furthermore, HUD's approach to overseeing
     Indian housing may change, depending on regulations now being
     developed to implement the new Indian housing legislation. 


--------------------
\1 Assessment of American Indian Housing Needs and Programs, Urban
Institute, May 1996. 


   BACKGROUND
---------------------------------------------------------- Chapter 0:1

The United States Housing Act of 1937 established the Public Housing
Program to provide decent, safe, and sanitary housing for low-income
families.  For many years, this act was interpreted to exclude Native
Americans living in or near tribal areas.  In 1961, however, HUD and
the Bureau of Indian Affairs (BIA) determined that Native Americans
could legally participate in the rental assistance for low-income
families authorized by the 1937 act and issued regulations to
implement this determination.  In 1988, the Indian Housing Act
established a separate Indian housing program and prompted HUD to
issue regulations specific to this program.  With the recently
enacted Native American Housing Assistance and Self-Determination Act
of 1996 (whose regulations are scheduled to take effect on Oct.  1,
1997), the Congress completed the process of separating Indian
housing from public housing. 

According to the May 1996 report by the Urban Institute, the housing
needs of Native Americans are growing.  Their population rose sixfold
over the past four decades to over 2 million in 1990, 60 percent of
whom live in tribal areas or in the surrounding counties.  And,
compared to non-Indians, Native Americans are more
family-oriented--37 percent of Native American households are married
couples with children versus 28 percent of non-Indian households. 
Compared to non-Indians, Native Americans have a higher unemployment
rate (14 percent versus 6 percent), a smaller number of workers in
"for-profit" firms per thousand people (255 versus 362), and a higher
share of households with very low incomes (33 percent versus 24
percent).  Moreover, Indian housing conditions are much worse than
housing conditions in other areas of the country:  40 percent of
Native Americans in tribal areas live in overcrowded or physically
inadequate housing compared with 6 percent of the U.S.  population. 

Through its Native American Programs headquarters office and its six
field offices, and with the help of approximately 189 Indian housing
authorities, HUD administers the majority of the housing programs
that benefit Native American families in or near tribal areas. 
Several significant differences exist, however, between HUD's
assistance to these families and to families (non-Indian and Indian)
living in urban and other areas.  First, HUD's support for Native
Americans derives, in part, from the nation's recognition of special
obligations to the Native American population and is reflected in
treaties, legislation, and executive orders.  Second, the federal
government deals with recognized tribes directly in a
sovereign-to-sovereign relationship, rather than through the general
system of state and local government.  This status allows tribes to
establish their own system of laws and courts.  Third, the Bureau of
Indian Affairs often holds in trust a considerable amount of land for
a tribe as a whole; thus, this land is not subdivided into many
private holdings as occurs in the rest of the country.\2

This trust arrangement has frustrated the development of private
housing markets in tribal areas and has long been seen as a special
justification for federal assistance in housing production. 


--------------------
\2 BIA also provides a relatively small amount of funding,
approximately $20 million annually, through its Housing Improvement
Program for constructing new affordable housing. 


   HUD PROVIDES MOST FUNDING FOR
   HOUSING ASSISTANCE THROUGH
   INDIAN HOUSING AUTHORITIES
---------------------------------------------------------- Chapter 0:2

Under current regulations, IHAs administer most of the low-income
housing assistance that HUD provides to Native Americans.  But HUD
also provides some housing assistance directly to tribes and
individuals.  Funding provided through housing authorities is used to

  -- develop housing for eventual ownership by individual families
     through the Mutual Help Program under which families lease and
     then buy their homes by making payments to the IHA of
     approximately 15 percent of their adjusted income and must cover
     their own routine operating and maintenance expenses;

  -- develop and maintain rental housing for low-income families
     through the Rental Housing Program which, like the public
     housing program, makes low-income rental housing available to
     families from an IHA at a cost of 30 percent of their adjusted
     income;

  -- modernize and rehabilitate established low-income housing
     through the public housing modernization program; and

  -- subsidize IHAs to defray operating expenses that rental income
     does not cover and provide rental vouchers for low-income
     families. 

Funding available to tribes and individuals includes

  -- loan guarantees for home mortgages,

  -- block grants through the HOME program for tribes to develop
     affordable housing in tribal areas, and

  -- community development block grants to enhance infrastructure and
     other economic development activities. 

As shown in table 1, over the past decade HUD provided a total of
$4.3 billion for these programs, which have produced or are expected
to produce a total of 24,542 housing units. 



                                Table 1
                
                 Results of Major Housing and Community
                    Development Programs for Native
                    Americans, Fiscal Years 1986-95,
                   Constant 1995 dollars in millions

                                    Funding for FY  Significant
Program                                  1986-1995  results
------------------------------  ------------------  ------------------
Mutual Help Program                         $1,613  Completed 15,721
                                                     units
Rental Housing Program                         831  Completed 8,821
                                                     units
Modernization of low-income                    926  Rehabilitated
 housing                                             housing units to
                                                     meet HUD's
                                                     standards and
                                                     upgraded IHAs'
                                                     management,
                                                     financial, and
                                                     accounting
                                                     control systems
IHA operating subsidy                          548  Subsidized IHAs'
                                                     expenses for
                                                     managing the
                                                     82,000 assisted
                                                     units and
                                                     provided funding
                                                     for various
                                                     management
                                                     activities
Section 184 loan guarantee                       3  Provided
                                                     guarantees for
                                                     477 loans in
                                                     1995, the
                                                     program's first
                                                     year
HOME affordable housing block                   54  Provided 59 grants
 grant                                               to construct,
                                                     rehabilitate, and
                                                     acquire houses
Community Development Block                    371  Supported housing
 Grant (CDBG)                                        programs and
                                                     homeownership
                                                     assistance; the
                                                     construction of
                                                     community
                                                     facilities, such
                                                     as roads, water,
                                                     and sewer
                                                     facilities and
                                                     community
                                                     buildings; and
                                                     economic
                                                     development
                                                     activities
======================================================================
Total                                       $4,347  Completed 24,542
                                                     units
----------------------------------------------------------------------

   PROVIDING HOUSING ASSISTANCE
   FOR NATIVE AMERICANS IS
   CHALLENGING AND COSTLY
---------------------------------------------------------- Chapter 0:3

HUD and IHAs encounter unique challenges and costly conditions in
administering and providing housing programs for Native Americans. 
Because of the over 550 separate Indian nations, cultures, and
traditions, not all of these conditions are equally prevalent
throughout tribal areas, nor do they have a common impact on
developing and maintaining housing.  Among the challenges and
conditions highlighted in our discussions with officials of HUD and
several IHAs, as well as in the May 1996 study by the Urban
Institute, are

  -- the remoteness and limited human resources of many IHAs and the
     Native American communities they serve;

  -- the lack of suitable land and the severity of the climate;

  -- the difficulty contractors and IHAs have in complying with
     statutory requirements to give hiring preference to Native
     Americans; and

  -- the pressure that vandalism, tenants' neglect, and unpaid rent
     put on scarce maintenance funds. 


      REMOTE RESERVATIONS LIMIT
      INFRASTRUCTURE AND
      AVAILABILITY OF HUMAN
      RESOURCES
-------------------------------------------------------- Chapter 0:3.1

The extent and pattern of the lands held by Native Americans are very
different today from what they were at the beginning of the 19th
century.  During that century, the land area over which Indians had
sovereignty and which was available for creating reservations was
often reduced to small pieces in isolated areas.  The remoteness of
some of these tribal areas has created significant problems for
housing development.  In contrast to metropolitan areas, where basic
infrastructure systems (including sewers, landfills, electricity,
water supply and treatment, and paved roads) are already in place,
remote tribal areas may require a large capital investment to create
these systems to support new housing. 

The remoteness of many of the tribal areas also increases the cost of
transporting the supplies, raises labor costs, and reduces the
availability of supplies and of an "institutional infrastructure" of
developers and governmental and private entities.  For example,
transporting a drilling rig over many miles and hours into the desert
to a tribal area in California is far more costly than if the well
had been needed in a less remote area.  In addition, as the Urban
Institute found in its study of Native American housing needs,
private housing developers, contractors, and suppliers; governmental
planners and building inspectors; private financial institutions; and
nonprofit groups are all less available in remote tribal areas. 

The limited human resources of many IHAs also contributes to the high
cost of developing and maintaining housing.  HUD's Deputy Assistant
Secretary for Native American Programs told us that housing
authorities that recruit their staff from a small tribal population
often have difficulty finding qualified managers to administer
multimillion-dollar housing grants.  This problem is made worse when
coupled with the statutory requirement to give Indians first
consideration for such jobs.  Because many Indian applicants have
incomplete formal educations, they often need more time to become
familiar with HUD's assisted housing program and regulations than
applicants from the larger pool enjoyed by a public housing authority
in an urban area, according to the Deputy Assistant Secretary. 

The executive director at the Gila River Housing Authority in
Sacaton, Arizona, echoed these views when he described his inability
to hire skilled and dependable tribal members.  He pointed out that
many skilled members have personal problems associated with drugs and
alcohol, causing the housing authority to search outside the tribal
area for much of its labor force.  He also said that because members
of the available semiskilled work force need a significant amount of
training before they are employable, he cannot afford to hire them. 
Moreover, some of the tribe's laborers are drawn to cities away from
the reservation, he said, because of the greater employment
opportunities and higher wages there. 

This lack of skilled human resources is costly.  HUD officials told
us that as a general rule in the construction industry, labor costs
should not exceed 50 percent of the total cost, but in tribal areas
labor costs can run as high as 65 percent because contractors
generally have to bring in skilled workers and pay for lodging and
commuting costs. 


      LAND-USE RESTRICTIONS AND
      THE INHOSPITALITY OF THE
      LAND COMPLICATE THE
      DEVELOPMENT AND MAINTENANCE
      OF LOW-INCOME HOUSING
-------------------------------------------------------- Chapter 0:3.2

In many tribal areas, observers see what appears to be a vast expanse
of unused land.  However, a lack of available land is, in fact, a
constraint that many IHAs face as they develop low-income housing. 
Factors that limit the availability of land for housing include the
trusts in which BIA holds the land that, until this year, limited
leases to 25 years in many instances.  Special environmental and
other restrictions also exist.  For example, in planning for
development, IHAs and tribes avoid archaeological and traditional
burial sites because cultural and religious beliefs preclude using
these sites for housing.  In many cases, sufficient tribal land
exists for housing, but environmental restrictions prohibit the use
of much of it for housing.  The Urban Institute's survey of IHAs
revealed that, overall, wetlands restrictions, water quality
considerations, and contaminated soils add to the cost of housing in
tribal areas. 

In the Western desert, once low-income housing is developed, the
severity of the climate can complicate maintenance.  The effects of
high salt and mineral content in the water and soil were evident at
the Gila River Housing Authority, causing damage to water heaters and
copper and cast iron pipes.  The executive director told us that the
average life of a hot water heater costing $300 is about 6 months. 
To remedy the corrosion to plumbing, the IHA has begun placing
plumbing in ceilings and converting to plastic piping.  Also, the
water's high mineral content damages the water circulation systems of
large fans called "swamp coolers," used for summer cooling.  The
executive director told us that because of calcium buildup, the IHA
must replace the coolers annually.  He also explained that because of
the soil's high salt content, housing foundations and sewer systems
also deteriorate more rapidly than in more benign environments. 


      COMPLYING WITH INDIAN HIRING
      PREFERENCE AND DAVIS-BACON
      ACT REQUIREMENTS INCREASES
      BURDEN FOR IHAS
-------------------------------------------------------- Chapter 0:3.3

Certain statutes, including the Indian Self-Determination and
Education Assistance Act and the Davis-Bacon Act,\3 are intended to
protect and provide opportunities for specific groups.  However, IHA
officials and HUD officials whom we contacted believe that these
statutes can make developing housing in tribal areas more costly
because they have the effect of raising the cost of labor over local
wage rates or restricting the supply of labor. 

The Indian Self-Determination and Education Assistance Act of 1975
requires IHAs to award contracts and subcontracts to Indian
organizations and Indian-owned economic enterprises.  IHA executive
directors find that implementing the act's requirement is difficult
and believe that the regulations add to contractors' time and costs
to bid on work for IHAs.  The officials said that factors that
undermine the requirement include a lack of qualified Indian
contractors in the area, the creation of fraudulent joint ventures
that are not owned or managed by Indians, and the occasional need to
use qualified firms outside the region that do not understand local
conditions. 

Under the Davis-Bacon Act, firms that contract with IHAs for housing
development must pay wages that are no less than those prevailing in
the local area.  However, HUD officials told us that this requirement
generally increases IHAs' costs of developing housing in tribal
areas.  The costs increase because the applicable Davis-Bacon wage
rate is often based on wage surveys done by HUD of large unionized
contractors based in larger metropolitan areas, and the rate is
therefore about $10.00 per hour higher than the rate prevailing in
the local tribal area.  Officials of the Chemehuevi IHA in Havasu
Lake, California, told us that because of high Davis-Bacon wage
rates, their cost to develop a single-family home ranges between
$85,000 and $98,000.  Using the prevailing rate of approximately
$6.50 to $8.00 per hour, they estimate the development cost to be
between $65,000 and $80,000. 


--------------------
\3 The Davis-Bacon Act provides that workers in certain trades
involved in federal construction contracts be paid wages determined
by the Secretary of Labor to be prevailing in the area of
construction. 


      NEGLECT AND VANDALISM DRAW
      ON MAINTENANCE BUDGETS THAT
      ARE SHRINKING BECAUSE OF
      UNPAID RENT
-------------------------------------------------------- Chapter 0:3.4

If housing units are abused through neglect or vandalism and not
regularly maintained, costly major repairs can be needed.  These
avoidable repairs put pressure on maintenance budgets that are
shrinking because a high percentage of rents are unpaid in tribal
areas.  Moreover, maintaining assisted housing for Native Americans
is an increasingly difficult challenge because of its age--44 percent
of the units were built in the 1960s and 1970s. 

For housing units in HUD's Rental Housing Program for Native
Americans, the Urban Institute reported that 65 percent of the IHA
officials responding to its telephone survey identified tenants'
abuse and the vandalism of vacant homes as the factors contributing
most to maintenance costs.  For units under the Mutual Help Program
(which are owned or leased by the residents), the Urban Institute
reported that, according to IHA officials, residents' neglect to
perform needed maintenance accounted for 30 percent of the poor
physical conditions associated with this segment of the housing
stock. 

Our discussions with IHA officials reinforce these findings.  The
executive director at the Gila River Housing Authority told us that
vandalism by juveniles was a major problem for him and that because
the tribal area borders Phoenix, Arizona, it is more susceptible to
gang activity and violence.  Chemehuevi IHA officials pointed out
that once a family that has neglected to perform expected maintenance
moves out and the tribe turns the housing back to the IHA, the IHA
often incurs a large and unexpected rehabilitation cost before it can
lease the unit to another family. 

The high level of unpaid rent among assisted Native American families
has exacerbated the problem of accomplishing needed maintenance. 
Routine and preventive maintenance is an operating expense that an
IHA pays for out of rental income and an operating subsidy that HUD
provides to help defray expenses.  However, according to HUD,
appropriations for these subsidies have not been sufficient to cover
all operating expenses not covered by rental income.  Therefore,
shortfalls in rental income generally mean fewer funds to spend on
maintenance.  In recent years, these shortfalls have been at high
levels for both the Rental Housing and the Mutual Help programs.  For
example, the Urban Institute reported that at the end of 1993, 36
percent of all tenants in the rental program were delinquent in their
rent payments.  In contrast, the average delinquency rate in public
housing is only 12 percent. 

To counter shortfalls in rental income, some IHAs enforce strong
eviction policies.  Others, however, are either unwilling or unable
to do so.  The IHAs attributed the ineffectiveness of their policies
to such factors as tribal court systems that do not support
evictions, the conflict of such policies with tribal culture, and
their own lack of forceful management.  Regardless of the reason,
these shortfalls coupled with insufficient operating subsidies likely
will lead to deferred maintenance and higher costs for major repairs
in the future. 


   HUD DOES NOT APPLY ITS RISK
   ASSESSMENT PROGRAM EFFECTIVELY,
   AND NEW LEGISLATION MAY REQUIRE
   CHANGES IN OVERSIGHT
---------------------------------------------------------- Chapter 0:4

In December 1996, the Seattle Times reported a series of articles
describing the possible mismanagement and misuse of federal funds by
Indian housing authorities.  The articles covered 29 instances of
questionable performance and in many cases suggested that more
effective oversight by HUD could have precluded or mitigated the
mismanagement at the housing authority.  HUD's IG found that most of
the Times reports were accurate, including reports of Indian housing
authorities using federal funds to build luxury homes for families
with incomes that exceeded the program's eligibility criterion and
reprogramming significant federal funds from one purpose to another
without HUD's approval.  Although HUD has a system to identify poorly
performing Indian housing authorities, our work showed that this
system did not detect, for the most part, mismanagement by the
authorities as reported in the Times.  This lack of detection was
because HUD's system focuses primarily on authorities assessed as
having a high risk of mismanagement.  Furthermore, HUD had not
assessed those authorities named in the Times as "high risk." Not
having an effective oversight tool could be problematic for HUD,
depending on the regulations that are negotiated to implement new
Indian housing legislation taking effect in October 1997. 


      HUD RELIES ON RISK
      ASSESSMENT PROGRAM TO
      IDENTIFY POORLY PERFORMING
      IHAS
-------------------------------------------------------- Chapter 0:4.1

HUD field office staff rely on their Risk Assessment and
Determination of Resources (RADAR) system to identify "high risk"
IHAs.  These are the IHAs whose management demonstrates weaknesses
that could lead to the misuse of federal funding.  The RADAR system
uses performance and environmental factors to assess an IHA's
management risks and HUD field staff rely on it to determine where
they will allocate their scarce monitoring resources, contract for
intensive on-site technical assistance, and focus their training for
HUD's Partners in Progress (PIP) program--a technical assistance
program for IHAs with long-standing operating difficulties.  HUD
staff score Indian authorities on the basis of their funding levels,
management control and operating procedures, and compliance with
regulations.  These scores form the basis for HUD staff to assess the
IHA's risk of mismanaging federal funds. 

One of the most important factors that RADAR uses to identify poorly
performing IHAs is on-site monitoring that provides information about
an IHA's performance and verifies the accuracy of the data submitted
by the IHA.  At two of the HUD field offices we visited, however,
restrictions on the on-site monitoring of IHAs have resulted in a
lack of assurance about the conditions that existed at the IHAs. 
These field offices account for nearly half of all IHAs.  In
addition, the staff at the offices we visited believed that their
knowledge of IHAs' operations was insufficient and that they do not
know enough to accurately assess the IHAs with the RADAR system. 
Because of this overall lack of assessment in accordance with the
RADAR system, and because HUD had not assessed most of the IHAs cited
in the Seattle Times articles as high risk, HUD staff were not able
to detect inappropriate activities if they occurred. 


      IMPACT OF NEW INDIAN HOUSING
      LEGISLATION ON HUD'S
      OVERSIGHT IS UNCLEAR
-------------------------------------------------------- Chapter 0:4.2

In 1996, the Congress enacted legislation that will change
significantly the way that Indian housing is funded and overseen. 
Under the Native American Housing and Self-Determination Act of 1996,
HUD will begin in October 1997 to provide directly to Indian tribes,
or their designated recipients, block grants to carry out affordable
housing activities.  To qualify for the grants, tribes must submit to
HUD annual plans and 5-year plans that provide statements of the
tribes' needs and resources available to address those needs.  In
addition, tribes must submit annual performance reports that describe
the accomplishments of the prior year and describe how the tribe
would change its program as a result of its experiences.  HUD, in
turn, is required to conduct a limited review of each Indian housing
plan to ensure that the plan complies with the various criteria
outlined in the act and review the performance reports to determine
whether they are accurate. 

Among the act's requirements are that tribes include in their housing
plans descriptions of the housing needs of low-income families and of
how the geographic distribution of assistance is consistent with the
needs for various types of housing assistance.  In addition, the
plans are to include detailed descriptions of the affordable housing
resources available in the tribes' jurisdictions and of how various
government and private entities will coordinate these resources.  For
example, the plan is to describe how the tribe will coordinate its
resources with those of tribal and state welfare agencies to ensure
that the residents of such housing will have access to assistance in
obtaining employment and achieving self-sufficiency.  These plans and
the year-end performance report are significant undertakings and are
meant to ensure that federal funds are used effectively to meet the
needs of low-income families. 

HUD is now engaged in a negotiated rulemaking with Indian tribes and
their representatives to develop a structure under which both the
tribes and HUD can comply with the new Indian housing law.  Until
these regulations are approved and implemented, it is unclear how
HUD's oversight of Native American programs will change and whether
HUD can effectively provide such oversight with its current systems
and resources. 


-------------------------------------------------------- Chapter 0:4.3

Messrs.  Chairmen, this concludes our testimony.  We would be pleased
to answer questions that you or Members of the Committees may have at
this time. 


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