oversight

Department of Housing and Urban Development Activities Financed Through the Assessment of Fees

Published by the Government Accountability Office on 1971-03-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                                       iriAR 2 3 1971

                  llllllllllllllllllllllllllllllllllllll~llllllllll
                           LM093023




Dear   Wr.   Condon:

        The General       Accounting     Gffice  has made a review              of the policies
and practices        followed      by the Repartment     of Housing            and Urban
Development       (HUR) in its management         and utilization              of funds obtained
through     the collection         of fees from the beneficiaries                 of eight   loan
and grant      programs.

        In fulfilling       its      responsibilities             for the administration          cf its
various       programs,    HUD makes project               audits     and inspections       and provides
representatives         at project          sites.       For each of the eight           programs
included        in our review,         I~IUXI has legal      authority      to collect      fees to
defray      the costs     of some or all              of these activities--which            are called
"nonadministrative"            activities.

         The Housing      and Urban Development         Act of 2970--enakt~d        fl~~pmber     ?i,
 l.970--contains      a provisFon        which permits     HUD to account    for these fee
revenues        cn a consolidated        basis  and to use fees collected         from the
beneficiaries        of'one     program     to cover nonadministrative       costs      inc?urred
in connection        with    other    programs    under which fees are assessed,

      HUDgs system of fee collections            and expenditures          does not operate
on a pay-as-you-go        basis.     The nonadministrative           funds available      to
HUD at any particular          time  represent,     in effect,       money in escrcw       to
cover nonadministrative           COSES to be incurred         throughout     the durations                5
of the projects       for which fees have been collected.,

        For several    years,       the     Department     has had available      for its use
substantial     amounts     of funds        --about    $34 million     as of Zune 30, 197%-
accumulated     as a result         of    fee collections        from the beneficiaries          of        _
the eight    programs.        AlSO,       the Department        has considerably      broadened
the scope of the activities                 financed     by ruse of available     nonadministrative
funds.

      Until   fiscal     year    1965,   the Congress       exercised     control     over HUD*s
use of nonadministrative           fends    through    the impos ition        of annual     limita-
tions   on the total       amount    of funds     that   could     be expended     in connection
with  the eight      Frograms.       At iKJD*s request,        the legislatively         imposed
spending     ceilings    were removed       in fiscal     year 1968.       In requesting      removal
of the spending       limitations     ) UllD    stated  that    its   nonadministrative
funds were self-limiting          since      they could     not be used for any purposes
other    than those for which fees were collected,                  and if nonadministrative
costs were not incurred,          the accumulated         fee collections          could  not be
used.                                                                          P        e

       We noted  in our               review,      however,      that as of June 30,              1970--prior
to the new legislative                   authorizations         for the administration                of fee
revenue

            --HUD was using       funds collected       from the beneficiaries                       of
               one program      to cover its costs        of making  inspections                     and
               audits    under a separately       enacted    program   for which                   the
               assessment     of fees was not legislatively          authorized                    and

            --three        of   the eight     programs    under which nonadministrative                                ,
                activities         are carried      on were being    operated at a "loss"
                in terms        of expenses      incurred    as they related   to fees
                collected.

            Fee supported     activities             have been a source            of concern        to HUD
officials        as indicated          in     your     January       1970 memorandum         to the Under
Stc.tz~cLd~y     iii   whicL     yuu     siaLeJ       &a~ Reese accxv~~les              llwx"have      developed
one by one over the years                       so that we have a complicated                 and inconsistent
administrative             monstrosity           to work with."           Subsequently,          HTJD formed       a
standing       committee          to provide         for continual'review             of the adequacy            of
established          fees and to make recommendations                        concerning        the adjustment
of fee rates           which are affected               by changes        of nonadministrative             activity
carried       on in connection               with    specific       programs.       In addition,          HUD
proposed       the previously              discussed        provision      which was enacted            as‘part
of the 1970 act.                       .

          On the basis        of our review,       we believe      the Congress    has not been
fully      informed       of (1) the substantial          amount     of funds available         to the
Department          for use in defraying         certain     expenses     and (2) the manner         in
which available            funds have been used by the Department.                  The enactment
of the 1970 act apparently               further      removes    HUD's nonadministrative
activities          from congressional        review,     and, at the same time,           provides
HUD with         increased      latitude   in its administration            of the activities.

            The details          of   our   examination       are   included       as an enclosure               to
this        letter.                                                                                                    _-
                                                          l




         Recognizing     that portions         of the           accumulated    balances       in the
nonadministrative         accounts       for several              of the programs     are available
to finance        future   inspection       and audit            work at ongoing       HUD-assisted
projects,       we recommend        that   HUD revise             its budget   presentation         to
clearly      show the Congress --in          addition             to the information        already

                                                                                                           -2-
presented         in   the   budget

        --the      amount     of the accumulated                    funds     available            for
            use    in  financing    nonadministrative                        activities;

        --the    Department’s            estima’tes             of fee revenues,   by source,
            to be received            during      the        fiscal”  year covered   by the
            budget ;
                                                                                                           ,        ,
        --the   amount        of funds expected                  to be available                  at     the
            end of the        fiscal  year;  and

        --the      Department’s        plans       for        use     of    available            funds         in
            future     fiscal      years,

          We believe        also     that    HUD, in carrying           out its nonadministrative
activities         under      the provisions          of the recent          legislation,         should
establish        its fee rates            to ensure       that    the beneficiaries            of one
HUD program           are not required           to support         nonadministrative            activities
carried       on in connection             with    other     programs.         We suggest,         therefore,                     ,
that      HUD continue          to establish        fee rates        on a program-by-program
basis      and,     through       its committee         on fees and charges,               ensure      that
those activities              to be financed          with fee revenues             are--for      each
program--who1           ly se If-sustaining.

        To assist   in this    effort,              we suggest                also    that        the     committee          on
rees    and charges    be given      the           adaltlonai               responsibility                for

        --defining     specifically              those  types of departmental                                  activities
            to be financed       with         fee revenue    and .

        --standardizing       , to the extent     feasible,    administration        of
            fee supported      activities   under    the various      programs    for which
            fee assessments        are to be made in order       that     the assessments
            can be equitably-established          for each program.

       We appreciate          the cooperation    and courtesies      extended    to our
representatives         during      this review.    We would also appreciate        your
comments      and advice        as to any action    taken   or planned     on the matters
discussed       in this     report.

                                                                    Sincerely           yours,



                                                                    B. E, Birkle
                                                         .          Assistant    Director
Eric losure
The Honorable      Lester   P. Condon
Assistant    Secretary    for Administration
Department    of Housing     and
   Urban Deve lopment
                                                                                                                            -3-
                                                                                                             ENCLOSURE
                                                                                                               PAGE 1

                            GENERAL ACCOUNTING--- OFFICE
             REVIEW OF DEPARTKENT OF FIOUSlNG AND --- TJRBcIN DEVELOP~iENT
              ACTIVITIES FZNliNCED THROUGH TIHE ASSESSMZNT OF FEES

    INTRODUCTION
                                                                                                   ,     I
             The Department          of Housing     and Urban Development          (HUD) is the
    principal        agency     of   the Federal     Government      that provides        financial
    assistance         to State      and local   public     bodies     and private      institutions
    to carry       out programs         designed    to provide     suitable     housing       and
    living      environments         for Americans.

             In fulfilling      its responsibilities           for administering            these
    financial        assistance    programs,       HUD makes project            audits   and inspec-
     tions     and provides     representatives          at project        sites.      These activities
    serve      the purposes     of protecting         Federal    interests         in HUD-assisted
    projects      and providing       guidance       to program      participants.                                        ,

              Prior   to enactment           of the Housing       and Urban Development           Act of
    1970, December          31, 1970, HUD assessed              fees against     participants        of
    eight       of its programs          to cover       the costs     of these activities--called
    "nonadministrative"              activities       .L/ For each of the eight            programs,
    HUD has legal          authority          to assess fees sufficient         to cove-r nonadmin-
    istrative        costs    incurred          in connection     with   each of the programs.

.           In its      legislative             proposals        for the 1970 act,           HUD included         a
    provision        to authorize             the Secretary          to charge      fees under all           HUD
    programs      rather        than      under      only the eight          programs.         This provision
    was enacted        as section            905(j)       of the 1970 act.             Section     905(j)      provides
    also     that additional              types of costs            may be covered         with    fee revenue
    and that       the revenue            may be accounted             for on a consolidated              basis.
    Thus,      HUD may use fee              rmenue        collected       from the beneficiaries               of one
    program      to cover         costs       incurred        in connection        with other        programs
    under which         fees are          assessed.



       These include         HUD loan and/or              grant      programs      for urban renewal,
        low-rent    public        housing,        urban planning,            open-space       land projects,
       neighborhood        facilities,            basic water          and sewer facilities,            public
       facilities,       and college             housing,        The Department         also has legislative
       authority      to assess         fees under           several      guarantee      and/or    registration
       programs     such as Federal               Housing       Administration         programs,      and the                 _
       New Communities            Development          program.         We limited       our review       to
        those departmental             activities         financed        from fees collected           in
       connection      with       HUD loan and grant               programs.
a


                                                                                                 ENCLOSURE
                                                                                                   PAGE 2

       The Department’s          system        of fee collections            and expenditures            for
    nonadministrative           activities        does not operate             on a pay-as-you-go
    basis o Rather,          under each of .the eight                 programs       that we reviewed,
    HUD collects         fees for projects            on a one-time,           lump-sum       basis,
    whereas,       the   nonadministrative            activities          it performs       in   connection
    with     those projects         may be performed             throughout        the durations         of the
    projects.          Under this       system,     the nonadministrative                funds available
    to HUD at any particular                 time represent,            in effect,       money in escrow
    to cover future          nonadministrative              costs.

             The Department         develops       fee rates       for each of the eight         programs
    on the basis        of expenses --both            direct      expenses      and certain   expenses
    for supporting          services    --expected          to be incurred         by the Department
    for carrying        out the nonadministrative                  activities.         Within each
    program,      the fees to be assessed                 against      the beneficiaries      of
    individual       projects       are calculated            on the basis       of the comparative
    costs      of the individual          projects        in that      program.

            Thefee assessments       are generally     billed     against the first
    funding   which the beneficiaries        of HUD’s loan and grant         programs
    receive.     Fee receipts    collected     in this      manner are recorded     in
    accounts   maintained     in connection      with  the individual     programs     under
    -which fees are assessed.

       1     HUD accounts      for its receipts,             expenditures,          and balances       of funds
    applicable        to fees through         program       control       accounts     and accounts
    maintained        in connection        with    its Administrative              Operations     E'und (Fund).
    The Fund was established               under     section       502(cIi3)       of the Housing        Act
    of 1948 to provide           for the efficient             and orderly         administration        of
    funds --including        receipts       from appropriations                and revolving      funds,     as
    well as fees --for         the staff        and operating           expenses      of the Department.
    All of HUD's expenditures               for the administration                 of its various
    programs --including           those for activities               classified       by HUD as
    nonadministrative        --are     financed        through      the Fund.

              Money needed          to cover       the estimated       costs     of nonadministrative
    activities          for each program             is transferred       from program            accounts      to
    the Fund.           The estimates          are periodically         updated       to more accurately
    reflect       anticipated          costs     of the nonadministrative               activities         and
    appropriate           adjustments        are made in the accounts.                  HUD’s financial
    records       indicate        that    the Department’s          nonadministrative              costs    for
    the eight         programs       we reviewed        have increased         substantially           in
    recent      years,       as shown below.
                                                                                               ENCLOSURE
                                                                                                 PAGE 3

                                               . *
       Fiscal      year                                Nonadministrative          costs
                                                             (in millions)

            1967                                                  $ 5.5                   P    a
            1968                                                    8.8
            1969                                                    9.9
            1970                                                   16.5

HUD officials         estimated     that    the volume     of fee-supported        activities
would continue          to increase      to about    $18.8   million     in fiscal       year         1971.

NEED FOR INCPZASED
                -- COVGRESSIONAL
AWARENESSCONCERNING HLJD'S
FEE RELATED        ACTIVITIES                                   EST
                                                                                                              ,
          The Department         has, for severai       years,    had available      for its
use substantial         amounts     of funds accumulated        from fee collections
from the beneficiaries            of the eight     programs     for which       the assessment
of fees is authorized.              Also,   the Department      has considerably
broadened        the scope of the activities           which are funded        from available
nonadministrative         funds.       We believe    that    the Congress      has not been
fnl ly infnrmo<           Qf < 1) th-c. -.LL"u‘.
                                        q--**-e c "L
                                                  n-C f,;,d:j     yV:iic:l ;;I= &~QL illlt:nL has
available       in its nonadministrative     accounts                   for use   in defraying
certain      staff   expenses:    and (2) the manner                  in which    the available
reserves      have been used by the Department.                          -

          The year-end       balances      of        HUD's nonadministrative           funds
increased       from about     $19 million            as of June 30, 1964, to about
$36 million         as of June 30, 1969,              and totaled      about    $34 million     as of
June 30, 1970.          The balances       of        these funds represent          the differences
between     accumulated      fee collections              from the participants           of the
programs     we reviewed       and cumulative             expenditures       for the nonadminis-
trative     activities     performed       by        HUD in connection         with   these programs.

          The $34 million        shown in HUD's financial                 records     as being
available     at June 30, 1970, for performing                  nonadministrative             activities          -
was comprised      primarily      of substantial          balances        which existed         in two
programs --the     Urban Renewal       program       ($23.7     million),         and the College
Housing     Loan program     ($7.2    million).         Also,    HUD's financial            records
show deficit     balances      for three        of the six remaining              programs.

           Our review           of HUD's recent        budget      justifications            as well    as        -
its   testimony          before    congressional        appropriation             committees     indicated
that    HUD does not,            in its   budgetary        process,        disclose       to the Congress
the extent          of the fee receipts          available         for HUD"s use.             In its
budget      justification,           HUD provides        the Congress           with estimates         of
                                                                                                ENCLOSURE
                                                                                                  PAGE 4


anticipated        nonadministrati\re           expenses.      However,       unlike        departmental
staff     expenses     funded       from sources       other   than fee collections--such
as appropriated          funds and certain           revolving       funds--there            is no
requirement        that expenditures            for nonadministrative             activities         be
 limited     to the estimates           presented      to the Congress.                    *     ’

        As previously        mentioned      $ three      of the eight       programs       we reviewed
were,    as of June 30, 1970,             being     operated       at a “loss”      in terms of
expenses       incurred    as they related            to fees collected.            This situation
appears      questionable        because     a portion       of the fee revenues            collected
under    each program        is required          to be reserved       by HUD to finance             its
nonadministrative          activities         throughout       the durations        of the projects
for which        the fees have been collected,                   HUD officials        advised      us
that future         fee revenues      collected        under     the three     programs       will     be
earmarked        to cover the deficits             which    currently      appear     in the
nonadministrative          funds for these programs.

           Until    fiscal    year 1968,      the Congress        exercised    control          over
HUD’s use of nonadministrative                    funds   through      the imposition           of
 limitations           on the total     amount      of such funds        that could      be     expended
each year in connection                with   the programs        for which assessment               of
fees was authorized.                These limitations          were increased         ffom      $374 :OOO
in11952          to about    $5.5 million       in 1967.

      At HUD’s reqcest,         the legislatively            imposed spending     ceilings
were removed     in fiscal      year    1968.     In presenting      its position         in
favor  of the removal        of the spending         limitations,      HUD stated       that
the funds were self-limiting             since    (1) they could       not be used for
any purposes     other    than those for which             the fees were collected           and
(2) if nonadministrative           costs    were not incurred,          the money accumulated
from fee collections         could    not be used.

         HUD’s position          concerning       the se If-limiting          nature       of its non-
administrative          funds has apparently           not been borne out by its
subsequent       actions       regarding     fee revenues           accumulated         in connection
with     the College        Housing      Loan program.         Under     this      program,     which
was authorized          by title       IV of the Housing           Act of 1950, as amended,                 ”
HUD provides         long-term       direct     loans   to finance         the costs        of con-
structing      student       and faculty       housing     and related          service      facilities
at colleges       and at hospitals            offering     medical       training.

       The General        Appropriation        Act of 1951 provided            that   the expense
of Federal      inspections         of college     housing    projects      financed        through         .
loans    should     be borne by the ‘Uenef iciary           institutions.           Similar
language     regarding       college    housing      loan projects        was included         in each
                                                                                                                ENCLOSURE
                                                                                                                  PAGE 5

  subsequent        year's     appropriation         act and last appcarcd     in the
  Independent         Offices      Appropriation        Act for fiscal   year 1964 which
  permitted        nonadministrative             fees to be assessed   for "***hereafter
  necessary        expenses***."

            Section        1705 of the Housing               and Urban Development                   Act of 1968,
  enacted        in August          1968, established              a program          providing        for annual
  debt service             grants      to educational            institutions            to reduce        their
  borrowing          costs,       and thereby         encourage           their     use of private           capital
  for the construction                   or purchase          of college           housing      and related
  facilities.              Because inspection               services         would be needed for those
  College        Housing        projects        funded      under       the recently          established
  debt service             grant     program,        HUD officials              requested       the HUD General
  Counsel,          Office      of Housing          Assistance,           to express         an opinion         as to
  whether        HUD could          administratively             impose         a requirement           to force
  grant       recipients          to pay a fixed            fee for inspections                 of grant-assisted
  projects,
                                                                                                                            C
            In December       1968, the Office          of Housing        Assistance         Counsel
   advised     that     since   the pertinent         legislation         authorizing          the assess-
   ment of nonadministrative              fees for college             housing      projects       is
   directed      specifically       to those projects             financed       through       loans,  it
   would be inappropriate             to administratively              assess a fee against
   the beneficiaries           of the "***senaratelv              enacted      grant     proiram***."

          In view of this           legal     opinion,       officials       of the Office          of Renewal
. and Housing         Assistance        (RHA),      in September        1969, requested           the
  Housing       Assistance       Counsel      to render       an opinion       as to whether           the
  balance       in the College          Housing       nonadministrative          fund--which         amounted
  to about        $7.3 million        as of June 1969--could               be used to pay the
  costs     of inspecting         projects       financed        under   the grant        program.         The
  Associate        General     Counsel,       RUA, advised           RHA program      officials        in
  November        1969, that,       although       HUD has no authority             to assess        non-
  administrative           fees against         College      Housing     grantees,        it would be
  permissible          to use surplus         nonadministrative            funds accumulated             from
  fixed     fees collected          under     the loan program           to pay costs           of inspection
  and audit        of grant      projects.

           In   support       of his opinion,         the Associate        General      Counsel,      RHA,                  1
   stated,      in part,       that for the purpose             of administration          and funding,
   the College         Housing       loan and grant        programs     are intended          to represent
   a continuum         rather      than two separate          and distinct        operations.         In
   this    connection,          the opinion      noted     that    the grant      program       is in large
   measure      designed        to replace     the loan program           and, accordingly,           HUD's
   use of the loan program's                nonadministrative           fund balances           to service                  -
   grant     projects       is justified.
                                                                                                         ENCLOSURE
                                                                                                           PAGE 6


            As a result           of the second. opinion,              the Acting        Assistant         Secretary     ,
    RHA, recommended              in a December         1969 memorandum            to the Assistant            Secretary
    for Administration                that expenses        incident       to inspection           and audit
    services        needed for the grant             program        be charged        to the College           Housing
    nonadministrative               fund.     Discussions        with     HUD officials           indicated        that
     this    recommendation             has been implemented.               These officials            were,     however,
    unable       to te 11 us the leve 1 of expense                   incurred        exclusively         for
    inspection         and audit          of debt service         grant     projects        since     these
    expenses       are combined            in a College        Housing      nonadministrative              expense
    account       with    similar        expenses     incurred       under      the direct         loan program,

            As stated      in the legal           opinion      of November      1969, the College
    Housing    debt service          grant      program--      because    of its reduced        impact      on
    annual    Federal      budget      outlays--       is intended      to replace       the direct
     loan program.         In this      connection,          the level      of funding      for the direct
     loan program      has declined            substantially         in recent    years--apparently                          9
    as a result       of the grant          program.         Although     both programs        have,     to
    date 9 been conducted            concurrently,           we were advised        that    HUD plans
     to use direct       loans     only in those instances               where institutions            are
    unable    to obtain       private       financing.

            The actions       taken by HUD to use nonadministrative                   ftinds accumulated
    under    the College        Housing   loan program         to finance     services      performed
    in connection        with     the debt service       grant      program   appear      to us to be
.   questionable       in th5.t the legislation           which established           the debt service
    grant    program     made no provision          for either        ( 1) the assessment        of any
    nonadministrative           fees or (2) changes         in the purposes         for which fees
    derived      from the previously         established         loan program      could    be used.

         HUD’s fee supported      activities                  have been a source       of concern
    to HUD officials.     In a “January                   1970 memorandum    to the Under Secretary
    of HUD, the Assistant    Secretary                    for Administration    stated    that:

                     I1 *** Fee supported   activities   have deve loped  one by one
             over the years so that we have a complica.ted         and inconsistent
             administrative     monstrosity     to work with.
                                                                                                                                 .
                      Some fees cover audit           expense;         others       do not.       Most cover
             inspection       expense,       but defined        differently           in different         pro-
             grams,      ***Scme      are collected         in advance;           others     are not.         Some
             have accumulated           surpluses     sufficient            to cover many years
             ahead ; others        are in deficit         position.           There are other            dif-                ...
             ferences.        Worst of all,        there      are so many different                 offices
             involved      that    the subject       cannot       be given        clear    and effective
             attention.         It needs a forum to provide                   unified      top-level.
             attention       on a continuing         basis.”
                                                                                                                      ENCLOSUW
                                                                                                                        PAGE 7

        Subsequently,       HUD f crmed a standing             committee      to provide     for
continual      review     of the <idequacy         of established        fees    and to make
recommendations         concerning        the ‘adjustment        of those     fee rates   which
are affected         by changes    in the amounts          of nonadministrative          activity
carried     on in connection         with     specific     programs,
                                                                                                     ,          *
CONCLUSIONS         AND RECOKMEY?.\TIONS

           On the basis          of our review,           we believe            that    HUD’s       financing
arrangements            for    and implementation                of its       nonadministrative
activities          have evolved          in such a way that                  these     activities--which
involve        substantial          amounts      of Federal           funds--have           become removed
from effective              congressional          control.          In addition,              the Department
itself,        in our opinion,            has little          basis       for     reasonable          assurance
that       its   accumulated          fee revenues          will      be sufficient              to cover
 the costs         of future        nonadministrative               services         to be performed
 throughout          the durations          of those        projects          for which          fees     have been
collected.                  +                                                                                                    ,

        The     enactment        of    the Housing         and Urban      Development      AC t of 1970
further       removed        HUD’s     ncnsdministrative          activities         from continuing
congressional            review,       and,   at the same time,             provided     HUD with
increased         latitude       in    its   administration         of the activities.
   I
        Although        the accumulated              balances       in the nonadministrative
accounts       for    several        of the programs             are reserved          to finance         future
inspection         and audit         work     at ongoing         HUD-assisted          projects,       we
believe      that     the Congress            should      be made aware           of the extent            of
the resources           available         to HUD for         its    nonadministrative             activities
and HUD’s        specific         plans     for    the use of those             resources.         Accordingly,
we recommend          that      HUD revise        its     budget      presentation           to clearly
show the Congress            --in      addition
                                        x              to the information              already      provided
in the budget

         --the      amount   of the accumulated                  funds        available        for       use        in
             financing     nonadministrative                 activities;

         --the     Department’s    estimates               of     fee revenues,              by source,
             expected     to be received              during        the fiscal            year  covered
             by the budget;

         --the      amount   of funds           expected         to    be available           at     the        end
             of   the fiscal    year;           and

         --the      Department’s            plans    for   use        of   available        funds          in
             future     fiscal        years.
                                                                                                                    ENCLOSURE
                                                                                                                      PAGE 8

        We believe         also    that      HUD, in carrying                  out these       activities            under
the provisions           of the recent              legislation,              should--for         those      HUD-assisted
programs       under     which     fees      are to be assessed--establish                           its     fee rates
to ensure         that   the beneficiaries                  of one program               are not required              to
support       nonadministrative              activities             carried        on in connect’ion            ‘with
other     programs,          Accordingly          , we suggest              that     HUD continue          to establish
fee rates         on a program-by-program                     basis       and,     through     its      committee         on
fees    and charges,          ensure       that       those      activities            to be financed            with     fee
revenues        are--for      each program--wholly                      self-sustaining,               We suggest
also    that,       to assist      in this          effort,         the committee            on fees       and charges
be given        the additional           responsibility                 for

         --defining     specifically                   those    types    of     departmental           activities
             to be financed        with          fee      revenue     and

         --standardizing      , to the extent          feasible,      administration        of                                  ,
             fee supported     activities        under     the various       programs    for which
             fee assessments       are to be made in order              that    the assessments
             can be equitably        established       for    each program.




                                  r