oversight

Veteran Homelessness: VA and HUD Are Working to Improve Data on Supportive Housing Program

Published by the Government Accountability Office on 2012-06-26.

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

             United States Government Accountability Office

GAO          Report to the Committee on Veterans’
             Affairs, House of Representatives



June 2012
             VETERAN
             HOMELESSNESS
             VA and HUD Are
             Working to Improve
             Data on Supportive
             Housing Program




GAO-12-726
                                              June 2012

                                              VETERAN HOMELESSNESS
                                              VA and HUD Are Working to Improve Data on
                                              Supportive Housing Program
Highlights of GAO-12-726, a report to the
Committee on Veterans’ Affairs, House of
Representatives




Why GAO Did This Study                        What GAO Found
According to a HUD and VA report,             The Department of Veterans Affairs (VA) and Department of Housing and Urban
veterans are overrepresented among            Development (HUD) rely on VA medical centers (VAMC) and public housing
the homeless population. The HUD-             agencies (PHA) that serve veterans directly to determine participant eligibility for
VASH program combines rental                  the HUD-VA Supportive Housing (HUD-VASH) program. VAMC staff GAO
assistance for homeless veterans in           contacted said that they interview veterans interested in the HUD-VASH program
the form of section 8 Housing Choice          to assess whether the veteran met the program’s definition of homelessness,
vouchers provided by HUD with case            check VA’s electronic patient record system to determine whether the veteran
management and clinical services              was eligible for VA health care, and obtain the veteran’s agreement to participate
provided by VA at VAMCs and                   in case management. VAMCs refer eligible veterans to partnering PHAs (subject
community-based outpatient clinics.           to rental assistance voucher availability) and are required to place them on an
This collaborative initiative between the     interest list when no vouchers are available. PHA staff GAO contacted said that
two agencies is intended to target the        they compare the veteran’s reported income to information provided by third-
most vulnerable, most needy, and              party sources, such as the Social Security Administration, to verify that the
chronically homeless veterans. GAO
                                              veteran’s household income did not exceed HUD-VASH program limits and
was asked to examine (1) how VA and
                                              check state sex offender registries to help ensure that no member of the
HUD determine veteran eligibility for
HUD-VASH, (2) what data VA and
                                              veteran’s household was subject to a lifetime registration requirement.
HUD collect and report on HUD-VASH            VA and HUD collect various data on veteran participation and voucher utilization
and their data reliability efforts, and (3)   and are taking steps to address the reliability of data collected and reported on
what is known about HUD-VASH                  HUD-VASH. Since 2008, VA has used an electronic database referred to as the
performance.                                  Dashboard to collect and report various data, such as the number of veterans
                                              issued a voucher and seeking housing and the number of veterans housed. VA
To address these objectives, GAO              described taking a number of steps intended to help ensure the reliability of
reviewed HUD-VASH program
                                              Dashboard-based reports, including routine reviews of underlying reports. VA
requirements and reported program
                                              expects to fully implement reporting based on data collected with its new
data through March 2012; and
interviewed VA and HUD headquarters           Homeless Operations Management and Evaluation System (HOMES) by July
officials, staff at a non-representative      2012. According to VA, HOMES incorporates additional data reliability controls,
sample of 10 VAMCs and 10 PHAs,               such as data fields that automatically limit responses to predefined ranges. HUD
and representatives of organizations          also collects data on HUD-VASH voucher utilization, although HUD officials
that advocate for veterans or                 acknowledged discrepancies between VA and HUD data. VA and HUD are
individuals experiencing                      working to finalize an information-sharing agreement intended to help the
homelessness.                                 departments better identify the source of the discrepancies and validate reports
                                              based on HOMES data.
GAO makes no recommendations in
this report. HUD, VA, and the U.S.
                                              HUD-VASH data show that the program has moved previously homeless
Interagency Council on Homelessness           veterans into housing. As of March 2012, nearly 31,200 veterans lived in HUD-
generally agreed with GAO’s                   VASH supported housing (about 83 percent of the rental assistance vouchers
conclusions.                                  authorized under the program). The program goal is to have veterans in housing
                                              represent 88 percent of authorized vouchers by September 2012; several states
                                              had met or exceeded the goal as of March 2012. VAMC and PHA staff GAO
                                              contacted also cited challenges in administering the HUD-VASH program,
                                              including a lack of resources to assist veterans with moving into housing. In April
                                              2012, HUD released a best practices document that illustrated how some of the
                                              challenges identified had been addressed. For example, one PHA applied for
                                              county Community Development Block Grant funds to assist veterans with
                                              security and utility deposits.
View GAO-12-726 For more information,
contact Alicia Puente Cackley at (202) 512-
8678 or cackleya@gao.gov.

                                                                                       United States Government Accountability Office
Contents


Letter                                                                                 1
               Background                                                             3
               HUD-VASH Eligibility Is Determined at the Local Level                 10
               Both VA and HUD Have Been Taking Steps to Address Data
                 Reliability                                                         14
               HUD-VASH Data Show the Program Has Moved Veterans into
                 Housing                                                             18
               Agency Comments                                                       29

Appendix I     Objectives, Scope, and Methodology                                     31



Appendix II    Comments from the Department of Housing and Urban Development          35



Appendix III   Comments from the Department of Veterans Affairs                       37



Appendix IV    Comments from the U.S. Interagency Council on Homelessness             39



Appendix V     GAO Contact and Staff Acknowledgments                                  40




Tables
               Table 1: HUD-VASH Program Measures That VA Collects in
                        Dashboard System and Reports                                 14
               Table 2: HUD-VASH Measures on Voucher Utilization (as of March
                        28, 2012)                                                    19
               Table 3: Selected HUD-VASH Outcome Metrics, 2011                      22


Figures
               Figure 1:HUD-VASH Program Obligations, Fiscal Years 2008
                        through 2011                                                   5




               Page i                                     GAO-12-726 Veteran Homelessness
Figure 2:VA and HUD Responsibilities during Provision of HUD-
         VASH Assistance                                                                   7
Figure 3:HUD-VASH Voucher Allocations and Percentage of
         Vouchers under Lease by State, as of March 28, 2012                              20
Figure 4:VA Medical Centers and Public Housing Agencies
         Contacted                                                                        32




Abbreviations

HOMES             Homeless Operations Management and Evaluation
                  System
HUD               Department of Housing and Urban Development
HUD-VASH          Department of Housing and Urban Development and
                  Veterans Affairs Supportive Housing
PHA               Public Housing Agency
PIC               Public and Indian Housing Information Center
OMB               Office of Management and Budget
VA                Department of Veterans Affairs
VAMC              Veterans Administration Medical Center
VISN              Veterans Integrated Service Network
VMS               Voucher Management System



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Page ii                                                 GAO-12-726 Veteran Homelessness
United States Government Accountability Office
Washington, DC 20548




                                   June 26, 2012

                                   The Honorable Jeff Miller
                                   Chairman
                                   The Honorable Bob Filner
                                   Ranking Member
                                   Committee on Veterans’ Affairs
                                   House of Representatives

                                   According to a Department of Housing and Urban Development (HUD)
                                   and Department of Veterans Affairs (VA) report, veterans are
                                   overrepresented among the homeless population. 1 In 2010, they
                                   accounted for roughly 9.5 percent of the total adult population (over the
                                   age of 18) but 13 percent of homeless adults in shelters or transitional
                                   housing. The report also notes that veterans represented 16 percent of
                                   homeless adults at a given point in time. 2 The larger percentage of
                                   veterans identified during the point-in-time count may reflect the greater
                                   likelihood of chronic homelessness among veterans. Chronically
                                   homeless veterans include those who cycle between streets and shelters,
                                   have frequent episodes of homelessness, and struggle with physical or
                                   mental health problems.

                                   VA and HUD, in collaboration with other federal agencies, are committed
                                   to preventing and ending veteran homelessness by 2015, and both
                                   departments fund several programs to house homeless veterans. The
                                   HUD-VA Supportive Housing (HUD-VASH) program, a collaborative
                                   initiative between HUD and VA, is intended to target the most vulnerable,
                                   most needy, and chronically homeless veterans. Its primary goal is to
                                   move veterans and their families out of homelessness and promote


                                   1
                                    HUD and VA, Veteran Homelessness: A Supplemental Report to the 2010 Annual
                                   Homeless Assessment Report to Congress (Washington, D.C.: 2011).
                                   2
                                    Communities annually submit point-in-time estimates to HUD. The counts attempt to
                                   enumerate both unsheltered persons (those in places not meant for human habitation
                                   such as the streets, abandoned buildings, or cars) and sheltered persons (those in
                                   emergency shelter or transitional housing on the night of the point-in-time count).
                                   Communities typically conduct their counts during a 24-hour period in the last week in
                                   January when a large share of the homeless population is expected to seek shelter rather
                                   than stay outside. The timing of the point-in-time count is intended to improve accuracy
                                   because counts of people in shelters are more precise than counts of people on the
                                   streets.




                                   Page 1                                                GAO-12-726 Veteran Homelessness
housing stability. HUD-VASH combines rental assistance for homeless
veterans in the form of section 8 Housing Choice vouchers provided by
HUD with case management and clinical services provided by VA at
Veterans Administration Medical Centers (VAMC) and community-based
outpatient clinics. HUD provides the vouchers through public housing
agencies (PHA) that partner with eligible medical centers or other
entities. 3 As of March 28, 2012, more than 35,800 HUD-VASH vouchers
were in use. 4 HUD-VASH is the nation’s largest permanent supportive
housing initiative for veterans.

You requested that we review the HUD-VASH program, including
compliance with statutory eligibility criteria, data integrity, and utilization of
performance measures to track long-term outcomes. In this report, we
examine (1) how VA and HUD determine that veterans who participate in
the HUD-VASH program meet the statutory eligibility criteria, (2) what
data VA and HUD collect and report on the HUD-VASH program and the
steps that VA and HUD take to help ensure the reliability of these data,
and (3) what is known about the performance of the HUD-VASH program.

In conducting this work, we reviewed VA and HUD documents that
describe the purpose of the HUD-VASH program and the agencies’ roles
and responsibilities related to HUD-VASH. We reviewed eligibility
requirements in the HUD-VASH statute and program manuals. We
selected a purposive, non-representative sample of 10 locations in which
to interview management and staff at VAMCs and their partnering PHAs.
We asked VAMC and PHA staff about their procedures for administering
HUD-VASH, including making eligibility determinations; cooperation at the
local level; data they collect and report on HUD-VASH; and their



3
 A PHA is a local entity, typically created under state law, which receives funds from HUD
to administer the voucher program. A family that is issued a housing voucher is
responsible for finding a suitable housing unit of the family’s choice which the owner
agrees to rent under the program. A housing subsidy is paid to the landlord directly by the
PHA on behalf of the family. The family pays the difference between the actual rent
charged by the landlord and the amount subsidized by the program.
4
  More specifically, VA’s data for “vouchers currently in use” represent the sum of totals
from three categories: (1) vouchers reserved for veterans who are undergoing PHA
validation, (2) vouchers issued to veterans who are actively seeking a lease, and (3)
current veterans housed/under lease. The data represent voucher utilization at a point-in-
time.




Page 2                                                  GAO-12-726 Veteran Homelessness
             perspectives on the program’s effectiveness. We selected the 10
             locations based on several criteria, including a significant presence of
             homeless veterans in and a large allocation of HUD-VASH vouchers to
             the state for fiscal years 2008 through 2010, identified best practices or
             challenges in administering the HUD-VASH program, and geographic
             diversity. To obtain information on the presence of homeless veterans by
             state, we reviewed the jointly developed veteran supplements to HUD’s
             annual homeless reports for 2009 and 2010. We used information from
             HUD on annual HUD-VASH voucher allocations by PHA and partnering
             VAMC for fiscal years 2008 through 2010, as the program was expanded
             with funding for new vouchers in 2008. We also reviewed federal strategic
             plans that address veteran homelessness to obtain information on VA’s
             and HUD’s goals for reducing veteran homelessness. To determine what
             is known about the performance of the HUD-VASH program, we reviewed
             VA and HUD reports on HUD-VASH voucher utilization and other VA
             reports on the program. In addition, we interviewed representatives of,
             and gathered documentation from, HUD and VA headquarters; the U.S.
             Interagency Council on Homelessness (Interagency Council); and veteran
             and homeless advocacy organizations, including the National Coalition for
             Homeless Veterans, the National Coalition for the Homeless, the National
             Alliance to End Homelessness, and Vietnam Veterans of America. See
             appendix I for a more detailed discussion of our scope and methodology.

             We conducted this performance audit from September 2011 through June
             2012 in accordance with generally accepted government auditing
             standards. Those standards require that we plan and perform the audit to
             obtain sufficient, appropriate evidence to provide a reasonable basis for
             our findings and conclusions based on our audit objectives. We believe
             that the evidence obtained provides a reasonable basis for our findings
             and conclusions based on our audit objectives.


             HUD and VA established HUD-VASH in 1992 to target veterans with
Background   severe psychiatric or substance use disorders. From fiscal years 1992
             through 1994, the program provided approximately 1,753 housing
             vouchers to homeless veterans. 5 After the initial voucher distributions, no
             new vouchers were made available to homeless veterans until fiscal year



             5
              According to HUD officials, HUD did not track HUD-VASH vouchers separately from
             general section 8 vouchers until the program was expanded in fiscal year 2008.




             Page 3                                              GAO-12-726 Veteran Homelessness
                  2008. From fiscal years 2008 through 2011, the program received funding
                  for about 37,000 new HUD-VASH vouchers. As of fiscal year 2008,
                  program participants are no longer required to have chronic mental
                  illnesses or chronic substance use disorders with required treatment.
                  However, a significant number of veterans with those issues are expected
                  to be helped within the program’s target population of veterans
                  experiencing chronic homelessness.


Program Funding   Obligations for new HUD-VASH vouchers and supportive services
                  increased from $78 million in fiscal year 2008 to $172 million in fiscal year
                  2011 (see fig. 1). 6




                  6
                   These figures do not include HUD-VASH voucher obligations after the initial
                  appropriation year of the vouchers. After the initial funding year, HUD-VASH vouchers are
                  renewed via a funding formula used for regular section 8 vouchers and HUD does not
                  report those obligations separately from other section 8 vouchers.




                  Page 4                                                 GAO-12-726 Veteran Homelessness
                             Figure 1: HUD-VASH Program Obligations, Fiscal Years 2008 through 2011




                             Note: Totals may not add due to rounding.


Administration of            As of April 2012, more than 140 VA facilities were participating in HUD-
Assistance and Eligibility   VASH. 7 In addition, according to HUD, more than 360 PHAs had
                             partnered with VA facilities to administer HUD-VASH nationwide since
                             fiscal year 2008. 8 The allocation process for HUD-VASH vouchers is a
                             collaborative approach that relies on three sets of data to determine
                             geographic need: HUD point-in-time data on homeless veterans needing
                             services in the area, VAMC data on the number of contacts with
                             homeless veterans, and performance data from PHAs and VAMCs.
                             Based on this analysis of geographic need (adjusted by the number of
                             vouchers received in previous years’ allocations), HUD and VA identify
                             communities that should receive VASH vouchers. The agencies then
                             determine the exact number to allocate in proportion with each
                             community’s level of need. VA then identifies VAMCs from these
                             communities to participate in HUD-VASH, taking into account VA’s case
                             management resources. HUD considers a PHA’s administrative


                             7
                              According to VA officials, VA does not count its community-based outpatient clinics as
                             separate entities for HUD-VASH administration. The clinics operate under a parent VA
                             facility (such as a VAMC).
                             8
                              PHAs participating in HUD-VASH from fiscal years 2008 through 2012 may not have
                             been awarded vouchers for each fiscal year during that time frame.




                             Page 5                                                 GAO-12-726 Veteran Homelessness
performance and in consultation with VA identifies PHAs located in the
jurisdiction of the VAMCs and invites them to apply for HUD-VASH
vouchers. The selected VAMCs and PHAs in a given community must
partner to administer the program. Under certain terms, HUD allows
PHAs to make a portion of their HUD-VASH vouchers project-based (that
is, tied to a specific housing unit and not to a tenant). PHAs can request
that a portion of their allocation of HUD-VASH vouchers be project-based
as long as funding for those vouchers, when added to the funding for
vouchers from the PHA’s regular voucher program that have been
project-based, does not exceed 20 percent of the PHA’s overall voucher
budget authority and the partnering VAMC supports the project.

The Veterans Health Administration within VA issues a HUD-VASH
handbook, which establishes procedures and responsibilities for
administering HUD-VASH. VA also has released a HUD-VASH Resource
Guide that was developed in conjunction with other federal and
community partners. It includes additional HUD-VASH guidance and
provides technical assistance on clinical issues pertaining to individuals in
permanent supportive housing programs.

HUD’s policies and procedures for HUD-VASH, including PHA
responsibilities, are defined in a Federal Register notice, the most recent
of which dates to March 2012. Figure 2 illustrates the processes and
activities for which VA and HUD (through PHAs in compliance with HUD
regulations) are responsible when providing HUD-VASH assistance. For
example, VA screens veterans to help ensure the following.

•   That they are homeless based on the McKinney-Vento Homeless
    Assistance Act definition; that is generally, a person who lacks
    regular, adequate housing or will imminently lose housing and lacks
    resources to obtain other permanent housing. 9


9
 The McKinney-Vento Act, as amended per the HEARTH Act of 2009, defines a homeless
individual to include "(1) an individual . . . who lacks a fixed, regular, and adequate
nighttime residence; (2) an individual . . . with a primary nighttime residence that is a
public or private place not designed for or ordinarily used as a regular sleeping
accommodation for human beings . . . ; (3) an individual . . . living in a supervised publicly
or privately operated shelter designed to provide temporary living accommodations . . .;
(4) an individual who resided in a shelter or place not meant for human habitation and who
is exiting an institution where he or she temporarily resided; (5) an individual . . . who (A)
will imminently lose [his or her] housing. . . ; (B) has no subsequent residence identified;
and (C) lacks the resources or support networks needed to obtain other permanent
housing." 42 U.S.C. § 11302(a).




Page 6                                                    GAO-12-726 Veteran Homelessness
                                       •      That they are eligible for VA health care. 10
                                       •      That they are willing to participate in case management services that
                                              are intended to promote housing stability and link the veteran to
                                              needed clinical services. According to VA, many veterans
                                              experiencing homelessness have physical, emotional, or other
                                              problems that make the goal of living independently challenging.

Figure 2: VA and HUD Responsibilities during Provision of HUD-VASH Assistance




                                           Note: HUD provides funding for the program, but HUD-VASH administration at the local level is
                                           carried out by PHAs.


                                       VAMCs refer veterans who meet VA requirements to PHAs, which
                                       determine eligibility based on HUD’s income requirements for section 8.
                                       To be eligible for assistance, households generally must have very low
                                       incomes—not exceeding 50 percent of the area median income, as
                                       determined by HUD. 11 Except for a sex offender provision, HUD-VASH
                                       offers several waivers to the regular section 8 voucher requirements.
                                       Specifically, under HUD-VASH, PHAs cannot deny assistance to
                                       potentially eligible households for past section 8 violations, such as
                                       previous nonpayment, or for criminal history. However, no members of


                                       10
                                         VA health care is generally only available to a veteran enrolled in the VA health care
                                       system. The term veteran is defined in 38 U.S.C. § 101(2) as “a person who served in the
                                       active military, naval, or air service, and who was discharged or released there from under
                                       conditions other than dishonorable.”
                                       11
                                         The veteran must provide proof of qualifying income level. Typically, the veteran pays
                                       approximately 30 percent of the adjusted household income to the landlord and the PHA
                                       pays the remainder (the rental subsidy) up to a predetermined amount.




                                       Page 7                                                          GAO-12-726 Veteran Homelessness
                             the veteran household can be subject to a lifetime registration
                             requirement under a state registration program for sex offenders. Once
                             the veteran meets HUD’s requirements for the program, the PHA can
                             issue the voucher for participation in HUD-VASH.


Data Collection, Analysis,   According to VA, the agency has assumed primary responsibility for
Reporting, and Systems       collecting and reporting HUD-VASH data, which it does for internal
                             performance purposes, monthly congressional reporting, and compliance
                             with Office of Management and Budget (OMB) reporting. VA and HUD
                             officials told us that VA also provides HUD with program data, which HUD
                             uses for internal performance purposes and for OMB reporting.

                             More than one VA office shares responsibilities for HUD-VASH data
                             collection and analysis. VA’s National Center for Homelessness among
                             Veterans (national center), which falls under the National Homeless
                             Program Office, undertakes development and evaluation of care options
                             and research and methodology related to VA’s homeless programs.
                             Additionally, VA’s Northeast Program Evaluation Center supports and
                             oversees data collection for VA’s mental health programs. According to a
                             VA official, this center provides sites with day-to-day support on technical
                             aspects of data collection, and the national center provides specific
                             feedback on the data collection process and analysis, among other
                             activities.

                             VA currently uses two systems to collect HUD-VASH program
                             information. According to VA, in 2008, it implemented a HUD-VASH
                             database, referred to as the Dashboard, to collect monthly program status
                             updates from HUD-VASH sites. VAMC staff submit Dashboard reports to
                             their respective Veterans Integrated Service Networks (VISN), which in
                             turn submit facility-level reports to the national center. 12 VA officials told
                             us that VA implemented a new data collection system, the Homeless
                             Operations Management and Evaluation System (HOMES), in April 2011,
                             and VA is in the process of fully implementing reporting mechanisms




                             12
                               More than 20 VISNs report to VA’s national center. In 1995, the Veterans Health
                             Administration established VISNs to oversee daily operations and decisions affecting
                             hospitals, clinics, nursing homes, and veteran centers located within their regions.
                             According to VA, VISNs remain the fundamental units for managing funding and ensuring
                             accountability.




                             Page 8                                               GAO-12-726 Veteran Homelessness
required to generate reports based on HOMES data. 13 HOMES collects
information for several of VA’s homeless programs, including HUD-VASH.
It is designed to track and maintain data on individual veterans as they
move through VA’s system of care, including HUD-VASH participation.
For example, VA’s HOMES user manual states that a HUD-VASH
clinician who is familiar with the veteran should complete and submit a
HUD-VASH monthly status report form for veterans currently enrolled in
the program. The report is intended to capture various information on the
veteran for the past 30-day period, including the number of contacts the
veteran had for case management, the veteran’s housing arrangement,
amount and source of any income, visits to the emergency room or other
hospitalizations (including those for mental health conditions), use of
alcohol or illegal drugs, and satisfaction (including with their current
accommodations, safety of living, and leisure activities).

According to HUD officials, as part of its section 8 program, HUD collects
voucher utilization and household information using two information
systems, the Voucher Management System (VMS) and Public and Indian
Housing Information Center (PIC). PHAs are responsible for submitting
VMS and PIC data to HUD. HUD uses VMS as a centralized system to
monitor and manage PHAs’ use of vouchers. VMS data include PHAs’
monthly leasing and expenses for HUD-VASH vouchers, which HUD uses
to obligate and disburse PHA funding. PHAs enter voucher totals in VMS
rather than individual records of HUD-VASH voucher activity. HUD uses
PIC as a centralized system to track information on households assisted
and lease activity. PIC data fields include PHA identification, assistance
program type (such as HUD-VASH), and household demographic
information. PIC data fields also include information on income sources
and amounts, assets, rent, housing type, and whether the subsidy is
tenant-based or project-based.




13
  According to VA, HOMES is a component of the Homeless Registry, the system which
facilitates the actual HUD-VASH reporting functions. The Homeless Registry incorporates
data collected through HOMES, legacy program evaluation data, VA benefits,
administrative data, and data from the clinical records. According to one official, this
registry is the foundation for the Homeless Services cube which allows numerous,
multifaceted reporting, trending, aggregation, and dissection across time, location,
programs and patient characteristics.




Page 9                                                GAO-12-726 Veteran Homelessness
                       According to VA and HUD, the departments rely on VAMCs and PHAs to
HUD-VASH Eligibility   make determinations on veteran eligibility for the HUD-VASH program.
Is Determined at the   Based on our meetings with staff at 10 VAMCs and 10 PHAs nationwide,
                       VAMCs and PHAs generally followed the same procedures to determine
Local Level            that veterans met statutory requirements.


Initial Screening      VAMC staff that we contacted described how they screened veterans to
Determines Whether     determine whether they met requirements for HUD-VASH.
Veterans Meet VA
                       •   Homeless status: To verify that a veteran met the McKinney-Vento
Requirements               definition of “homeless,” VAMC staff told us that they interviewed the
                           veteran. This included, for example, discussing the veteran’s current
                           housing situation (homeless, precariously housed, doubled up, in own
                           housing but facing housing loss/eviction, or stably housed), and
                           history or pattern of housing stability/instability. Some VAMC staff also
                           told us that community organizations referring veterans into the HUD-
                           VASH program may provide documentation supporting the veteran’s
                           homeless status.
                       •   VA health care: To verify that a veteran is eligible for VA health care,
                           VAMC staff in several locations told us that they determined if the
                           individual had an existing record in VA’s electronic patient record
                           system. VA determines VA health care eligibility based on whether the
                           individual meets the definition of veteran, has a minimum period of
                           active duty service, and is enrolled in the VA health care system. A
                           dishonorable discharge generally disqualifies an individual from
                           receiving VA benefits.
                       •   Case management: According to VAMC staff, a psychosocial
                           assessment, which evaluates the veteran’s clinical and service needs,
                           helps them to determine an appropriate level of case management for
                           each veteran. This involves considering whether the veteran has (1)
                           complex service needs or health conditions, such as serious mental
                           illness or substance use disorder; (2) nonchronic service needs that
                           could be overcome or managed with treatment; or (3) few or minor
                           service needs and is employable. Prior to enrollment in HUD-VASH,
                           each veteran must agree to participate in case management.
                           According to VA guidance, case managers must document the
                           veteran’s HUD-VASH enrollment using a HOMES form. For veterans
                           who do not enter the program, the form lists reasons the veteran did
                           not enter, including the veteran’s refusal to agree with the terms of the
                           program (case management). In Los Angeles, New York, Washington,
                           D.C., and Wyoming, VAMC staff explained that they required veterans
                           to sign a case management agreement. VA officials told us that this
                           was a local management practice rather than a requirement based on


                       Page 10                                        GAO-12-726 Veteran Homelessness
    the HUD-VASH handbook. Following enrollment, the case manager
    and the veteran work together to develop an individualized treatment
    plan with goals that are revisited over the course of the veteran’s
    participation in HUD-VASH. VA views case management as a key
    component of HUD-VASH and its case management services are
    intended to help improve the veteran’s physical and mental health and
    enhance the veteran’s housing stability. Additionally, VA’s case
    management aims to support recoveries from physical and mental
    illness and substance use disorders. According to VA, HUD-VASH
    does not require veterans to be sober prior to program enrollment;
    however, the veteran’s treatment plan is recovery-focused and
    incorporates his or her recovery goals. In addition to monitoring the
    veteran’s treatment plan, the role of the case manager involves
    helping the veteran to access other medical and behavioral treatment
    resources as needed.

VA regards failure to participate in case management as grounds for
termination or denial of program participation. However, several VAMC
staff told us that VA makes every effort to re-engage veterans in case
management before proceeding with termination for nonparticipation. If
VA determines that the veteran no longer requires case management
services, the veteran may continue to receive the HUD-VASH housing
subsidy. In such cases, the VA case manager should notify the PHA that
case management is no longer required but that the veteran’s eligibility
for a housing voucher remains unchanged. If the PHA has a voucher
available in its regular section 8 program, the PHA can offer that voucher
to the veteran and make the HUD-VASH voucher available to another
homeless veteran.

As previously noted, VA refers veterans who meet its requirements for
HUD-VASH to PHAs, subject to voucher availability. The HUD-VASH
handbook requires that if there are no available case management
openings or vouchers, HUD-VASH program staff place the veteran on an
interest list. According to VA, this list consists of all individuals who have
been in contact with HUD-VASH staff and expressed interest in the
program. These persons are subsequently screened for eligibility and a
determination is made regarding acceptance. If a veteran is not eligible
but vouchers are available, staff would make a referral to other VA or
community resources. If a veteran is eligible but no vouchers are
available, program staff must document the reason for denial in HOMES
as lack of voucher availability. As of March 28, 2012, VA data show that
an estimated 1,689 or 4 percent of the HUD-VASH vouchers authorized
nationwide were available for use. Of the 10 VAMCs we contacted, 6 had



Page 11                                         GAO-12-726 Veteran Homelessness
                          vouchers available for use as of March 28, 2012, including the Bronx
                          (New York) VAMC with an estimated 63 vouchers available for use and
                          the Seattle VAMC with an estimated 32 vouchers available for use. The
                          other four VAMCs had fewer than five remaining vouchers as of the same
                          date. Regarding interest lists, staff at the Washington, D.C. VAMC told us
                          that there were about 1,000 veterans on their facility’s interest list. The
                          staff also told us that they had developed a screening tool to help make
                          acceptance decisions and prioritize remaining vouchers for veterans on
                          their interest list. According to VA, in addition to targeting chronically
                          homeless veterans, consideration for HUD-VASH enrollment also may be
                          given to women, families with children, disabled veterans, and those who
                          served in Operations Iraqi Freedom and New Dawn in Iraq and Operation
                          Enduring Freedom in Afghanistan.

                          VAMC staff we contacted generally told us that they routinely directed
                          veterans screened for HUD-VASH to other suitable VA programs,
                          including VA’s Grant and Per Diem and Domiciliary Care for Homeless
                          Veterans programs. 14 For example, the staff explained that they might
                          refer veterans to other VA programs pending HUD-VASH acceptance if
                          another program was more immediately appropriate for the veteran or if
                          the veteran needed services not available under HUD-VASH (such as
                          dental care). Some VAMC staff also mentioned local resources as
                          another referral option.


PHAs Conduct Additional   PHA staff that we contacted described how they screened veterans to
Screening on Income and   determine whether they met income and other requirements after
Other Requirements        receiving a referral from the VAMC.

                          •    Income: PHA staff told us that they generally relied on third-party
                               sources, such as the Social Security or Veterans Benefits


                          14
                            Initially called the Comprehensive Service Programs, the Grant and Per Diem program
                          was introduced as a pilot program in 1992 through the Homeless Veterans
                          Comprehensive Services Act (Pub. L. No. 102-590). The law establishing the Grant and
                          Per Diem program, which was made permanent in the Homeless Veterans
                          Comprehensive Services Act of 2001 (Pub. L. No. 107-95), authorizes VA to make grants
                          to public entities or private nonprofit organizations to provide services and transitional
                          housing to homeless veterans. Domiciliary care consists of rehabilitative services for
                          physically and mentally ill or aged veterans who need assistance, but are not in need of
                          the level of care offered by hospitals and nursing homes. Congress first provided funds for
                          the Domiciliary Care program for homeless veterans in 1987 through a supplemental
                          appropriations act (Pub. L. No. 100-71).




                          Page 12                                                 GAO-12-726 Veteran Homelessness
     administrations, to verify the reported income of HUD-VASH
     applicants. HUD requires PHAs to include certain sources of
     household income in determining income eligibility, including earned
     and benefits-related income. The HUD-VASH voucher subsidizes
     recipients’ rental payments and applicants must provide proof that
     their income level qualifies for this assistance.
•    State sex offender registry status: PHA staff told us that they
     checked the sex offender registry for all members of the veteran
     household who were at least 18. In New York, the PHA staff informed
     us that they checked for all household members over 16 in
     compliance with the age limit for that state. If the veteran was subject
     to lifetime registration under a state registration program for sex
     offenders, the PHA would refuse the voucher application. If a family
     member who intended to occupy the assisted unit was subject to
     lifetime registration under such a program, the application would
     proceed only if that individual was removed permanently from the
     household.
To familiarize veterans approved for a HUD-VASH voucher with the
PHA’s requirements for HUD-VASH, staff at some PHAs we contacted
told us that they conducted briefings with veterans. In several locations,
PHAs held such briefings in a group format. Staff at PHAs with a smaller
number of HUD-VASH vouchers sometimes met one-on-one with
veterans.

Once the veteran is in housing, PHAs reverify income and complete a
housing unit inspection, typically on an annual basis. Some PHAs may
conduct recertification procedures less frequently. 15 One of the PHAs in
our sample was in this category and conducted recipient renewals
annually or biannually on a case-by-case basis. The PHA can terminate
assistance when a veteran has been evicted from a unit or for serious
and repeated lease violations. However, prior to terminating any section 8
participant, PHAs must provide the opportunity for an informal hearing.
According to HUD officials, as part of HUD’s routine review of PHA


15
   PHAs that participate in HUD’s Moving to Work demonstration program have the
flexibility to design and test various approaches for providing and administering housing
assistance that are intended to reduce costs or to provide incentives to families with
children where the head of household is working or seeking employment opportunities.
For example, Moving to Work PHAs can conduct less frequent recertifications for certain
households living on fixed incomes. For more information on the Moving to Work
demonstration program, see GAO, Moving to Work Demonstration: Opportunities Exist to
Improve Information and Monitoring GAO-12-490 (Washington, D.C.: Apr. 19, 2012).




Page 13                                                GAO-12-726 Veteran Homelessness
                                             records (such as to determine the accuracy of family income and rent
                                             calculations), HUD may review HUD-VASH tenant files if the files are
                                             included in a larger sample, but such reviews are not specific to the HUD-
                                             VASH program.



Both VA and HUD
Have Been Taking
Steps to Address Data
Reliability
VA Provides the Primary                      Both VA and HUD report on HUD-VASH using information from VA’s
Data for HUD-VASH                            Dashboard database. VA uses the Dashboard to collect summary count
Reporting                                    information from VAMCs and provides monthly Dashboard-based reports
                                             to HUD and Congress. Those reports typically include several data
                                             elements or measures on voucher utilization, including the number of
                                             veterans issued a voucher and looking for housing and the number of
                                             veterans housed (under lease). See table 1 for additional Dashboard data
                                             elements.




Table 1: HUD-VASH Program Measures That VA Collects in Dashboard System and Reports

Data element                                               Description
Total vouchers authorized and appropriated                 Total number of vouchers allocated to each PHA partnering with the
                                                           VAMC facility since fiscal year 2008
Vouchers currently in use                                  Total number of vouchers either reserved for or issued to a veteran
Vouchers reserved for veterans who are undergoing PHA      Number of vouchers VAMC has reserved for veterans who have been
validation                                                 referred to a participating PHA for voucher application processing
Vouchers issued to veterans who are actively seeking a     Number of veterans already awarded a voucher by a PHA and who are
lease                                                      currently seeking housing
Current veterans housed/ under lease                       Number of veterans awarded a voucher by a PHA and living in PHA-
                                                           approved housing
                                             Source: VA.


                                             In addition to the Dashboard, VA uses HOMES to collect data on
                                             veterans. HOMES data reflect a series of electronic forms that case
                                             managers must complete from the time a veteran is screened for the
                                             program to the time a veteran leaves the program. Although HOMES data
                                             could be used to create the information captured in the Dashboard



                                             Page 14                                              GAO-12-726 Veteran Homelessness
                            database, VA has not yet completed development and testing of report-
                            generating mechanisms necessary to release reports based on HOMES
                            data, according to VA officials. VA officials also told us that they intended
                            to begin using HOMES data for congressional reporting purposes by July
                            2012 and eventually discontinue the Dashboard reporting mechanism.


VA Has Taken a Number of    VA has taken a number of steps to help ensure the reliability of HUD-
Steps to Help Ensure Data   VASH data reported though the Dashboard database. We compared VA’s
Reliability                 processes against standards for internal control, including, among other
                            things, having processes and procedures that provide reasonable
                            assurance of the reliability of reports for internal and external use by

                            •    establishing and supporting a control environment with clearly defined
                                 areas of responsibility and appropriate lines of reporting,
                            •    incorporating controls over information processing, and
                            •    monitoring performance measures and indicators. 16
                            HUD-VASH reporting responsibilities, as identified in VA’s guidance,
                            appeared to be consistent with HUD-VASH program responsibilities. For
                            instance, case managers collect and submit HUD-VASH evaluation data
                            on veterans. HUD-VASH program coordinators are responsible for
                            conducting appropriate audits of performance measures. VAMC facility
                            directors are responsible for verifying that staff provide timely reporting of
                            veteran activity. Finally, the VISN’s homeless coordinators are
                            responsible for helping ensure that data are submitted in a timely manner
                            and the VISN directors are responsible for helping ensure the accuracy of
                            these data.

                            According to VA officials, the national center reviews individual weekly
                            Dashboard reports from VISNs for reasonableness by comparing
                            submissions with prior week reports. Questions or concerns are
                            addressed to the respective VISN and the national center corrects weekly
                            reports accordingly.

                            As discussed previously, Dashboard reports include a number of program
                            performance measures, including a specific measure for the program’s
                            goal of moving veterans out of homelessness (the number of veterans


                            16
                             See GAO, Standards for Internal Control in the Federal Government,
                            GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).




                            Page 15                                             GAO-12-726 Veteran Homelessness
                         under lease). In addition to providing data for external reporting, VA
                         officials told us that the Dashboard database serves as a program
                         management tool. According to VA officials, the national center uses the
                         Dashboard reports to monitor program status at individual sites and also
                         compares program performance across sites.

                         VA also has taken a number of steps to help ensure the reliability of HUD-
                         VASH data collected through HOMES. Consistent with standards for
                         internal control, HOMES reporting responsibilities are clearly defined in
                         VA guidance and, according to VA officials, HOMES data are collected for
                         individual veterans as opposed to the Dashboard’s facility-level counts
                         that did not identify individuals. HOMES includes a number of additional
                         controls. For example, electronic data checks incorporated into HOMES
                         improve data validity and reduce the risk of errors. Authorized program
                         service providers enter program and veteran information into HOMES but,
                         where appropriate, certain data fields automatically limit responses to
                         predefined data ranges to reduce data entry errors. According to VA
                         officials, the system is capable of flagging records for review based on
                         approximate matches of name or Social Security number. Furthermore,
                         only certain authorized users may edit records after data are submitted.


VA and HUD Have Been     Although counts of voucher use generated from HUD’s and VA’s
Taking Steps to Reduce   information systems produce different totals, a proposed information-
Data Discrepancies       sharing agreement between HUD and VA is intended to facilitate data
                         sharing and identify and resolve discrepancies. HUD has compared VA
                         data with its VMS and PIC data for the purpose of validating HUD-VASH
                         data. 17 Validating data (in this case, Dashboard data) with an independent
                         data source (such as HUD data) is an additional standard for internal
                         control. HUD collects some HUD-VASH data, including the number of
                         veterans receiving housing assistance (veterans under lease) through its
                         VMS and PIC systems, but generally does not use these data for HUD-
                         VASH reporting purposes. According to HUD and VA officials, both
                         departments consistently use Dashboard data for reporting purposes.

                         HUD provided its analysis of VA, VMS, and PIC data comparisons of
                         vouchers under lease. For November 2011, HUD’s analysis listed three


                         17
                           However, this review and validation is not incorporated in VA’s monthly Dashboard
                         reports due to time lags associated with HUD’s reporting processes, according to agency
                         officials.




                         Page 16                                               GAO-12-726 Veteran Homelessness
totals for vouchers under lease: 27,159 vouchers according to VMS,
24,768 vouchers according to PIC, and 27,285 vouchers according to VA
data. The totals also differed when HUD compared voucher counts at
individual PHAs for the same month. HUD noted three totals for vouchers
under lease at the Harrisburg Housing Authority: 19 vouchers according
to VMS, 33 according to PIC, and 34 according to VA data. In another
example, HUD noted three totals for vouchers under lease at the Housing
Authority of Waco: 116 vouchers according to VMS, 13 according to PIC,
and 119 according to VA data.

According to HUD officials, data discrepancies between VA and HUD
data may have been due to one or more factors, assuming VA data
provided at that time were accurate.

•   First, PHAs may have incorrectly or inaccurately entered PIC or VMS
    data that relate to HUD-VASH participation counts.
•   Second, PIC and VMS use different methodologies for assigning
    HUD-VASH voucher counts when veterans move across PHA
    jurisdictions, which could affect comparisons of participation data at
    the facility level. Under the HUD-VASH program, a veteran may use a
    HUD-VASH voucher in a jurisdiction outside of the PHA that initially
    awarded the voucher. 18 VMS voucher counts are associated with the
    initial voucher allocation site, regardless of the participating veteran’s
    current location. PIC counts veteran households assisted and
    associates those counts with the veteran’s current location.
•   Third, in comparison with VA reporting, HUD has taken longer to
    make data available for analysis. For example, up to 80 days may
    elapse from the time a PHA must submit VMS data to the time that
    VMS information is available for analysis. According to VA, the
    agency typically has provided Dashboard data to Congress within 50
    days after the end of each reporting month.

HUD’s VMS and VA’s Dashboard data are comparable when veteran
participation is categorized by location; however, these respective data
sources are not tied to personally identifying information. Therefore, the
agencies have a difficult time identifying the specific source of data
discrepancies.



18
  At the discretion of the VAMC and subject to program requirements, a HUD-VASH
participant can move outside of the jurisdiction of the PHA that made the initial award as
long as VA case management can be continued in the receiving PHA’s jurisdiction.




Page 17                                                  GAO-12-726 Veteran Homelessness
                       A proposed information-sharing agreement between HUD and VA is
                       intended to facilitate record-level data sharing between the agencies and
                       allow them to precisely identify and resolve data discrepancies between
                       HUD’s PIC data and VA’s HOMES data. According to VA officials, once
                       VA fully implements new reporting mechanisms, HOMES data will enable
                       VA to provide summary status reports and identify information for veteran
                       records used to create the summary totals. Further, they said that the
                       agreement will allow VA to provide HUD with HUD-VASH data including
                       the participating VAMC and PHA, and personally identifying information
                       for each veteran. According to HUD officials, HUD intends to compare
                       these records with PIC data (which include personally identifying
                       information) and then the agencies plan to coordinate with field offices to
                       resolve discrepancies. As of June 2012, the information-sharing
                       agreement was under review. The agencies expected to complete final
                       revisions to the agreement by June 25, 2012 and execute the agreement
                       by August 2012. If VA fully implements HOMES as a data source for
                       reporting purposes and the agencies execute the agreement as planned,
                       it would allow the agencies to match case records in the event of data
                       discrepancies. Although the agreement is not expected to affect VA’s
                       monthly report submissions to Congress, according to the agencies, the
                       information-sharing agreement should further improve their ability to
                       validate HUD-VASH data on an ongoing basis.



HUD-VASH Data
Show the Program
Has Moved Veterans
into Housing
HUD-VASH Performance   Information VA reports for the HUD-VASH program has focused on
                       voucher utilization (such as the number of veterans housed), but HOMES
                       is supposed to provide VA with additional data on veteran outcomes. VA
                       currently reports a number of measures (or various data) related to
                       voucher utilization in monthly reports to Congress (see table 2).




                       Page 18                                       GAO-12-726 Veteran Homelessness
Table 2: HUD-VASH Measures on Voucher Utilization (as of March 28, 2012)

                                                        Percentage (of vouchers
 Measure                                Number                      authorized)
 Vouchers authorized                     37,552
 Veterans in housing                     31,197                               83
 Vouchers issued to veterans actively
 seeking a lease                          4,046                               11
 Vouchers reserved for veterans
 undergoing PHA validation                 620                                 2
 Vouchers available for use               1,689                                4
Source: VA.


These measures show that HUD-VASH has moved veterans out of
homelessness. Nearly 31,200 veterans lived in HUD-VASH-supported
housing as of March 28, 2012; veterans in housing represented about 83
percent of the vouchers authorized under the program. In addition, PHAs
issued 4,046 vouchers to veterans who were actively seeking a lease and
VAMCs reserved 620 vouchers for veterans undergoing PHA validation
as of the same date. According to VA, the department’s goal is for
veterans in housing to represent at least 88 percent of authorized HUD-
VASH vouchers by September 30, 2012. As figure 3 shows, several
states had achieved or nearly achieved this goal as of March 2012,
including the four states with the largest number of vouchers authorized—
California, Florida, New York, and Texas.




Page 19                                           GAO-12-726 Veteran Homelessness
Figure 3: HUD-VASH Voucher Allocations and Percentage of Vouchers under Lease by State, as of March 28, 2012




                                       Page 20                                          GAO-12-726 Veteran Homelessness
For the 10 VAMCs we contacted, the percentage of veterans in housing
varied, ranging from 70 percent to 95 percent as of March 28, 2012. For
VAMCs further from the goal, such as the Sheridan VAMC in Wyoming
(70 percent in housing), challenges with getting veterans placed in
housing may be related to local housing markets. For example, Sheridan
VAMC staff told us that there was a lack of affordable housing in the area.
Similarly, staff at Greater Los Angeles Health Care System (79 percent in
housing) told us that suitable housing stock (meeting program
requirements for cost and housing quality) was limited, particularly in the
West Los Angeles area where the VAMC facility is located. VA data show
that both VAMCs had assigned 100 percent of their authorized vouchers
to a veteran as of March 2012. However, nearly 30 percent of the
Sheridan VAMC’s vouchers and 21 percent of the Greater Los Angeles
Health Care System’s vouchers were assigned to veterans actively
seeking housing at that time. We discuss challenges with getting veterans
placed in housing in greater detail later in this report.

In October 2011, VA submitted a report to Congress that provides
additional descriptive and performance-related information on HUD-VASH
for June 2008 through September 2010. Summary information from the
report includes

•   characteristics of veterans admitted to the program;
•   average number of days at each stage of the admission and housing
    process;
•   veterans’ typical 90-day housing situation within 3, 6, and 12 months
    of beginning case management; and
•   reasons for ending case management.

For example, according to VA, for veterans who completed the housing
process, the time frame from initial referral to HUD-VASH to the move
into permanent housing averaged 130 days.

VA has plans to report additional information, such as measures of the
time it took to complete various processes within the program (see table
3). In December 2011, VA issued guidance to its service networks
outlining several outcome measures and related targets for which the
department planned to start collecting data in fiscal year 2012.




Page 21                                       GAO-12-726 Veteran Homelessness
Table 3: Selected HUD-VASH Outcome Metrics, 2011

 Performance metric                            Target
 Time frame to make decision on                Within 3 working days of referral
 acceptance into HUD-VASH program
 Time frame to refer veteran to PHA once       Within 15 days of acceptance into the
 accepted into HUD-VASH program                program
 Time frame from acceptance into HUD-          Within 100 days of acceptance into the
 VASH program to placement in housing          program
 Percentage of discharges from HUD-VASH 10 percent or less
 program for adverse reasons
Source: VA.




VA also recently began conducting research (although not always
nationwide) related to (1) the Housing First approach to supportive
housing; (2) positive and negative outcomes for veterans who leave the
HUD-VASH program; and (3) various case management approaches for
treating veterans for substance abuse. 19 VA officials told us that they
intend to use the results of these studies to assess operations and update
policies and procedures accordingly, and to offer guidance on innovative
practices to VAMCs. In June 2012, VA officials provided us with updates
on these studies:

•     Based on piloting the Housing First approach in Washington, D.C.’s
      HUD-VASH program in fiscal year 2009, VA determined that Housing
      First yielded several positive outcomes. The study compared results
      for 105 HUD-VASH vouchers set aside for Housing First and 70
      vouchers that followed VA’s usual treatment process. VA found that,
      under Housing First, veteran placement into housing took, on
      average, 35 days from admission, compared with 223 days under the
      usual treatment process. Additionally, under Housing First, a reduced
      proportion of veterans had used emergency room and inpatient
      mental health services, and the housing retention rate was 98 percent
      after 1 year, compared with 86 percent under the usual treatment
      process. The pilot was expanded to 13 additional sites in fiscal year
      2012, with VA and HUD monitoring for 3 years. Each site had 50
      vouchers set aside for Housing First.



19
  The Housing First model aims to provide rapid rehousing for homeless families and
identifies the need for interventions and social services support after housing is secured.




Page 22                                                  GAO-12-726 Veteran Homelessness
•   Based on program data available at the end of June 2011, VA
    analyzed veterans who were already housed and left HUD-VASH for
    reasons categorized as positive (such as accomplishing goals or no
    longer needing program supports), negative (such as failing to comply
    with program requirements or being evicted), and neutral (such as
    death, illness, or transferring to another program site). According to
    VA, within the sample, 37 percent of exits were positive, 23 percent
    were negative, 30 percent were neutral, and there were insufficient
    data for 10 percent of exits. VA officials told us that VA and HUD will
    work together to conduct a more in-depth study of veterans leaving
    the program for adverse reasons to identify the major factors involved.
    The officials informed us that as of March 2012, the departments were
    in the process of obtaining OMB approval to follow up with veterans
    who had left HUD-VASH.
•   VA has launched a 3-site research study comparing the effectiveness
    of four different intervention methods for veterans with substance use
    disorders and mental health problems. Methods tested will include
    standard case management, intensive case management, tele-
    coaching, and electronic interactive practices. As of June 2012, VA
    officials told us that they had begun interviewing veterans to
    participate in the study. VA did not expect results to be available until
    2013.

HUD-VASH case managers have started to complete a monthly status
form in HOMES that includes data on outcomes. For example, case
managers must record (1) changes in the veteran’s community
adjustment and social contacts; (2) hospitalizations for unscheduled
medical conditions or mental health conditions; (3) employment status
and other sources of income or benefits; and (4) use of alcohol or illegal
drugs, using a clinical rating scale. In addition to the monthly status form,
case managers are required to complete in HOMES a HUD-VASH exit
form for each veteran who is discharged from the program. The exit form
includes some of the indicators in the monthly report, the veteran’s status
upon discharge, and the reason for exit.

Housing stability for veterans participating in HUD-VASH is a component
of the program’s primary goal, along with moving those veterans out of
homelessness and into housing. VA’s case management efforts play an
integral role in helping veterans to achieve housing stability. VA’s current
monthly reports, which show the number of veterans housed under the
program, do not address housing stability. However, VA’s October 2011
report to Congress gave some indication of general voucher turnover and
housing tenure. More specifically, the report showed the number and



Page 23                                         GAO-12-726 Veteran Homelessness
                          percentage of veterans leaving the program for positive and negative
                          reasons at various stages of the housing process. It also showed
                          veterans’ typical housing situation over the previous 90 days after 3, 6,
                          and 12 months of participation. Beginning in April 2011, VA told us that
                          case managers began using HOMES to record information on HUD-
                          VASH participants. This would include entering information on each
                          veteran’s housing situation upon enrollment, every 30 days following
                          enrollment, and upon exit from the program. While not enough time has
                          passed to assess the reporting related to HOMES data, VA expects it to
                          provide a range of useful data for site monitoring and program
                          management. Along with other data expected to be collected in HOMES,
                          detailed information on veterans’ housing situation every 30 days should
                          provide VA with an opportunity to assess program performance in helping
                          veterans to achieve housing stability.

HUD Has Disseminated      Based on our interviews at 10 VAMCs and partnering PHAs, staff
Strategies to Address     frequently cited four challenges relating to program administration or
Some Program Challenges   processes that they perceived as negatively affecting the goal of housing
                          homeless veterans and helping them maintain housing stability.

                          Delayed VAMC referrals to the PHA. As previously noted, for fiscal year
                          2012, VA’s goal is for VAMCs to refer veterans accepted into HUD-VASH
                          to the PHA within 15 days of acceptance into the program. However, PHA
                          staff discussed challenges associated with receiving timely HUD-VASH
                          referrals from the partnering VAMC, particularly at the beginning of a new
                          allocation year. In 9 of the 10 locations, PHA staff told us that delayed
                          referrals from VA slowed the voucher utilization process. While PHAs
                          generally can begin accepting referrals once HUD awards the vouchers,
                          delayed referrals from VA extended the time frame between a PHA
                          receiving the vouchers and getting the voucher holder into housing. Staff
                          at King County Housing Authority in Seattle suggested that VA’s initial
                          delay in making HUD-VASH referrals was related to VA needing to hire
                          and assign case managers, while HUD could move quickly to pass
                          funding on to the PHAs to issue vouchers. Staff at two VAMCs
                          acknowledged the challenge in making initial referrals to the PHA. In one
                          location, the staff explained that to provide an adequate number of case
                          managers, they would need to know how many new vouchers had been
                          added and, therefore, how many new HUD-VASH veterans they would
                          need to serve. Moreover, once new case managers were hired, they had
                          to undergo training and orientation, resulting in additional delays. Staff in
                          several PHA locations noted that VAMC referral time frames had been
                          improving.



                          Page 24                                        GAO-12-726 Veteran Homelessness
HUD-VASH case manager workload. VA’s goal is to have a ratio of 1
case manager to 25 veterans. However, when we contacted VAMCs in
January and February 2012, several VAMC staff told us that some case
managers had 40 or more cases, as the following examples illustrate:

•   In South Dakota, staff at the Meade County Housing and
    Redevelopment Commission expressed general concern that the
    workload for the case manager serving their area may have been
    unreasonable or otherwise impractical. According to staff at Black
    Hills Health Care System, which partners with the housing authority,
    the case manager assigned to Meade County and other locations
    managed 51 cases in total.
•   Similarly, case managers at James A. Haley VAMC in Tampa had
    between 45 and 50 cases. Staff at the Tampa Housing Authority told
    us that more intensive case management could reduce or eliminate
    veteran terminations from HUD-VASH due to nonpayment or other
    violations of the housing agreement.
•   Staff at Greater Los Angeles Health Care System told us that efforts
    were under way to reduce their average caseload of 45 per case
    manager. The facility was accepting applications for additional case
    managers and also planning to contract with an external entity to
    supplement case management services.

VA has made efforts to address staffing at its VAMCs, and when we later
contacted two of the VAMCs identified with challenges, the staff told us
that hiring additional case managers had reduced their caseloads
significantly. Additionally, VA provided us with a report on HUD-VASH
program hiring as of February 29, 2012. The report showed that 95
percent of program positions across all VISNs were filled. Among the
VAMCs we contacted, the percentage of HUD-VASH positions filled
ranged from 50 percent to 100 percent. Case managers represent the
majority of HUD-VASH positions, but some facilities have also hired
clinical supervisors, substance use disorder specialists, peer support and
housing specialists, and other program support staff.

Identifying housing for veterans. Staff at VAMCs in several locations
told us that veterans experienced challenges with finding housing. In
Wyoming, the VAMC staff explained that the market for affordable
housing was tight in Casper and Sheridan, areas served by the VAMC.
Additionally, they said that the partnering PHA that served Sheridan
recently reduced the maximum allowable housing assistance payment
from $595 to $571 and this amount limited access to decent housing in
the area. The staff added that many landlords also have been reluctant to



Page 25                                       GAO-12-726 Veteran Homelessness
rent to veterans with criminal histories. VAMC staff in South Dakota
similarly noted that a partnering PHA had decreased the housing
allowance for the area it served while some landlords had increased their
rents. They explained that they used communications with a local
homeless coalition, community stakeholders, and landlords to identify
options for affordable housing. At Greater Los Angeles Health Care
System, the staff told us that a housing specialist had been hired and kept
staff informed of new housing stock while working with developers and
realtors to identify suitable housing. According to the VAMC staff, the
housing specialist also has conducted outreach to educate landlords on
HUD-VASH and advocate for veterans, making them aware that case
management will be available to HUD-VASH tenants.

Move-in resources for veterans. Both PHA and VAMC staff discussed
challenges veterans experience accessing the funds and household items
that they needed to move in once they found a suitable housing unit. In
some instances, veterans were delayed in moving into their units because
of a lack of available funds to pay rental application fees, security
deposits for rent or utilities, and the first month’s rent. Such delays could
affect VA’s goal for placing veterans into housing within 100 days of being
accepted into the program.

The availability of resources to help veterans varied among locations, but
generally was more limited outside of larger cities. Two of the 10 locations
had a consistent source that could provide this type of assistance to
veterans. For example, New York City has a Department of Homeless
Services that provides a range of services to homeless individuals.
Through this entity, HUD-VASH veterans could receive assistance with
security deposits, first month’s rent, and household items. In Seattle,
HUD-VASH veterans could access a limited-term Human Services and
Veterans Levy that assisted veterans, military personnel and their
families, and others in need through a variety of housing and supportive
services. In other locations, VAMC and PHA staff told us that veterans
had relied on local public or nonprofit assistance and on Homeless
Prevention and Rapid Re-Housing Program funds that were temporarily




Page 26                                        GAO-12-726 Veteran Homelessness
provided under the Recovery Act. 20 Additionally, several said that they
hoped veterans would be able to use funds that would be provided under
the new Supportive Services for Veteran Families grant program. 21
Homeless Prevention and Rapid Re-Housing Program funds are no
longer available and the other sources mentioned, according to the staff,
often were insufficient or were not guaranteed.

In some locations, the VAMC staff had developed other approaches to
mitigating this challenge for veterans. For example, at several facilities,
including Greater Los Angeles Health Care System, Black Hills Health
Care System in South Dakota, and Washington, D.C. VAMC, the staff
explained that they solicited landlords’ cooperation in waiving or
spreading out up-front fees. Additionally, staff at White River Junction
VAMC in Vermont had developed a handbook for veterans participating in
VA’s homeless programs that included a community resources guide.
They explained that the guide was included to assist veterans with
obtaining furniture, household items, and other resources they needed to
move into housing.

In April 2012, HUD released a best practices document that included
practices submitted by PHAs and VAMCs that administer HUD-VASH.
According to HUD, the purpose of the document is to share effective
strategies for administering HUD-VASH and highlight the efforts of
specific sites and other partners. According to HUD officials, VA was
involved in soliciting best practices from VAMCs and reviewed the
document that HUD developed. HUD intends to revise the document over
time. While the document was developed from the housing standpoint, it
includes information on strategies for carrying out procedures pertaining
to general PHA and VAMC management. More specifically, it describes


20
  Under the American Recovery and Reinvestment Act (Pub. L. No. 111-5), $1.5 billion
was appropriated for Homelessness Prevention and Rapid Re-Housing Program grants.
The grants were distributed to communities and states to provide short- or medium-term
rental assistance and relocation and stabilization services, including housing search,
mediation or outreach to property owners, credit repair, security or utility deposits, utility
payments, rental assistance for a final month at a location, moving cost assistance, case
management, or other appropriate activities.
21
  The Supportive Services for Veteran Families program was established by the Veterans’
Mental Health and Other Care Improvements Act of 2008. The program provides grants to
private nonprofit organizations and consumer cooperatives that will coordinate or provide
supportive services to very low-income veteran families residing in or transitioning to
permanent housing.




Page 27                                                    GAO-12-726 Veteran Homelessness
                            the ways in which individual sites have addressed specific challenges
                            such as those identified previously. For example, in addition to the Los
                            Angeles VAMC hiring a housing specialist, the document described other
                            facilities’ efforts to direct veterans to suitable housing by contracting with
                            a nonprofit housing referral organization, maintaining a list of potential
                            housing options in the VAMC’s service area, and conducting targeted
                            landlord outreach. Similarly, several PHAs had established a loan fund or
                            trust fund to assist veterans with move-in costs, and one PHA applied for
                            county Community Development Block Grant funds to assist veterans
                            with security and utility deposits.


Advocacy Organizations      Advocates for veterans and the homeless that we contacted generally
Generally Shared Positive   agreed that HUD-VASH was essential in helping homeless veterans to
Views of HUD-VASH and       access housing and long-term treatment. Representatives at one of the
                            organizations stated that the long-term housing HUD-VASH provides was
Also Suggested Program      crucial to addressing the immediate and long-term needs of homeless
Improvements                individuals and that combining case management with housing was
                            appropriate for veterans with the most significant problems. Additionally,
                            representatives at two organizations told us that HUD and VA sharing a
                            common strategic goal had been beneficial and that program
                            administrators had been responsive to the HUD-VASH community.
                            Moreover, they noted that the program’s administration had improved
                            over time. Specifically, they explained that VA had been willing to make
                            changes to improve HUD-VASH, including in terms of leadership.

                            The advocates offered suggestions for improving the HUD-VASH
                            program, including the following.

                            •   One advocate suggested that the program should continue to target
                                those with the greatest need for assistance and explore flexibility for
                                service delivery mechanisms, including having case managers
                                conduct more work in communities and outside of the traditional
                                VAMC appointment approach. Related to this point, recently the
                                Veterans Health Administration Homeless Program National Director
                                noted that VA was taking steps to have more of a presence in the
                                community. This included hiring HUD-VASH case managers living in
                                communities where veterans were being served and seeking more
                                opportunities to have case managers co-located with community-
                                based organizations.
                            •   A second advocate thought it would be useful to remove the section 8
                                limits on project-based housing under HUD-VASH to allow developers
                                to allocate portions of higher-quality, mixed-use developments for



                            Page 28                                         GAO-12-726 Veteran Homelessness
                       project-based HUD-VASH vouchers. The representative explained
                       that this would be particularly helpful in locales with limited affordable
                       housing and in areas that are desirable (particularly for female
                       veterans with dependent children). HUD officials clarified that PHAs
                       can make the case to HUD to have funding for project-based HUD-
                       VASH vouchers exceed the voucher budget authority limit of 20
                       percent. 22 According to HUD officials, exceeding the limit must be tied
                       to effective administration of HUD-VASH, and HUD had not received
                       any such requests as of May 2012.
                  •    A third advocate expressed that VA should increase its outreach to
                       veteran service organizations to advertise to veterans who may not be
                       participating in VA programs. VA officials told us that VA has a
                       national outreach initiative under way that includes collaborating with
                       veteran service organizations to make information on HUD-VASH and
                       other VA programs more readily available.
                  •    Finally, a fourth advocate emphasized that sufficient resources
                       needed to be committed to HUD-VASH in support of the goal of
                       ending veteran homelessness. The representative explained that a
                       certain volume of vouchers needed to be in the system for it to be
                       successful and that inconsistent resources led to uncertainty among
                       service providers and veterans who need to access the program.

                  We provided a draft of this report to the Secretary of Housing and Urban
Agency Comments   Development, the Secretary of Veterans Affairs, and the Executive
                  Director of the U.S. Interagency Council on Homelessness. We received
                  comments from HUD, VA, and the Interagency Council that are
                  reproduced in appendixes II, III, and IV, respectively. HUD and VA also
                  provided technical comments, which we incorporated in the report as
                  appropriate. In their responses, HUD, VA, and the Interagency Council
                  generally agreed with our conclusions. HUD and VA noted that they were
                  committed to their partnership and the continued improvement of the



                  22
                    Under the voucher program (including HUD-VASH), PHAs are limited by law to using up
                  to only twenty percent of their overall tenant-based voucher budget authority for project-
                  based vouchers. 42 U.S.C. § 1437f(o)(13). HUD has the authority to grant a PHA’s
                  request to exceed the 20 percent limit for the purposes of project-basing HUD-VASH
                  vouchers. In connection with the HUD-VASH annual appropriations since 2008, HUD has
                  been authorized to waive (with a few exceptions) statutory and regulatory requirements
                  applicable to the HUD-VASH program, “upon a finding by the Secretary [of HUD] that any
                  such waivers. . . are necessary for the effective delivery and administration of such
                  voucher assistance.” See, e.g., HUD’s fiscal year 2012 appropriations, Pub. L. 112-55,
                  125 Stat. 552, 678-679 (2011).




                  Page 29                                                GAO-12-726 Veteran Homelessness
HUD-VASH program. The Interagency Council stated in its response that
VA and HUD work closely on local implementation through VA medical
centers and public housing agencies, and have improved lease-up rates,
enhanced data collection, and reduced the amount of time it takes to
house veterans in the HUD-VASH program.

We are sending copies of this report to appropriate congressional
committees; the Secretary of Housing and Urban Development; Secretary
of Veterans Affairs; and the Executive Director of the U.S. Interagency
Council on Homelessness. This report will also be available at no charge
on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact
me at (202) 512-8678 or cackleya@gao.gov. Contact points for our
Offices of Congressional Affairs and Public Affairs may be found on the
last page of this report. GAO staff who made major contributions to this
report are listed in Appendix V.




Alicia Puente Cackley
Director, Financial Markets and
  Community Investment




Page 30                                       GAO-12-726 Veteran Homelessness
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              Our objectives were to examine (1) how the Department of Veterans
              Affairs (VA) and the Department of Housing and Urban Development
              (HUD) determine that veterans who participate in the HUD-VA Supportive
              Housing (HUD-VASH) program meet the statutory eligibility criteria, (2)
              what data VA and HUD collect and report on the HUD-VASH program
              and the steps that VA and HUD take to help ensure the reliability of these
              data, and (3) what is known about the performance of the HUD-VASH
              program.

              To address all three objectives, we reviewed VA and HUD documents to
              determine the purpose of the HUD-VASH program and the agencies’
              roles and responsibilities related to HUD-VASH. In addition, we reviewed
              federal strategic plans that address veteran homelessness to obtain
              information on VA’s and HUD’s goals related to reducing veteran
              homelessness. We interviewed officials at the Veterans Health
              Administration within VA and in HUD’s Office of Public and Indian
              Housing and Office of Community Planning and Development. We
              reviewed VA and HUD Office of Inspector General reports pertaining to
              HUD-VASH and our previous reports. We selected a purposive, non-
              representative sample of 10 locations in which to interview management
              and staff at VA medical centers (VAMC) and their partnering public
              housing agencies (PHA) (see fig. 4). Results of these interviews cannot
              be projected to other VAMCs or PHAs. We selected the 10 locations (9
              states and the District of Columbia) based on several criteria, including a
              significant presence of homeless veterans in and a large allocation of
              HUD-VASH vouchers to the state, identified best practices or challenges
              in administering the HUD-VASH program, and geographic diversity. To
              obtain information on the presence of homeless veterans by state, we
              reviewed the jointly developed veteran supplements to HUD’s 2009 and
              2010 Annual Homeless Assessment Reports to Congress. We used
              information from HUD on annual HUD-VASH voucher allocations by PHA
              and partnering VAMC for fiscal years 2008 through 2010.




              Page 31                                       GAO-12-726 Veteran Homelessness
                                       Appendix I: Objectives, Scope, and
                                       Methodology




Figure 4: VA Medical Centers and Public Housing Agencies Contacted




                                       To address our first objective, we reviewed eligibility requirements in the
                                       HUD-VASH statute to assess how VA and HUD are to determine that
                                       veterans who participate in HUD-VASH meet the statutory eligibility
                                       criteria. We also reviewed requirements specific to VA in the Veterans
                                       Health Administration’s HUD-VASH handbook and a HUD-VASH
                                       resource guide developed by the National Center for Homelessness
                                       among Veterans. To obtain specific information on how VA screened
                                       veterans to determine if they were eligible for the program, we
                                       interviewed VAMC management and staff in the selected 10 locations.
                                       The centers are responsible for screening and evaluating veterans for
                                       acceptance into HUD-VASH, referring veterans to partnering PHAs, and
                                       coordinating veterans’ case management under HUD-VASH. Similarly, to
                                       obtain more specific information on how PHAs (following HUD’s
                                       procedures) screened veterans referred by partnering VAMCs, we


                                       Page 32                                       GAO-12-726 Veteran Homelessness
Appendix I: Objectives, Scope, and
Methodology




interviewed management and staff at PHAs that partner with the 10
VAMCs to assess veterans and also manage various aspects of the
housing process. In our interviews with VAMC and PHA staff, we asked
about their general procedures for administering HUD-VASH, including
how they made eligibility determinations based on VA’s requirements and
HUD’s guidelines, respectively. We also discussed cooperation at the
local level between partnering VAMCs and PHAs.

To address our second objective, we reviewed program manuals and
guidance on data that VA and HUD collect on HUD-VASH, their data
collection mechanisms, and reliability controls. We interviewed VA and
HUD officials to determine what HUD-VASH information the agencies
report and the systems they use for collecting and reporting the related
data. We obtained and reviewed selected monthly Dashboard-based
reports that VA provided to Congress during fiscal years 2011 and 2012
to identify the data elements typically reported for HUD-VASH; we
reviewed VA program data through March 2012. While VA provides
monthly voucher utilization reports to Congress, HUD reports to Congress
on HUD-VASH only upon request. To identify the steps that VA takes to
help ensure the reliability of its data, we interviewed knowledgeable VA
officials about the purpose, structure, and quality controls used to capture
or report HUD-VASH program data using VA’s Dashboard and HOMES.
We reviewed VA documentation, including the HOMES user manual,
HUD-VASH data entry forms, and data validity checks. In interviews with
VAMC staff at the 10 selected locations, we asked about data collection
and reporting, and any related challenges. In addition, we observed a
demonstration of VA’s reporting mechanism for HUD-VASH on-site.
Finally, we compared VA’s data collection and reporting procedures to
standards for internal control in the federal government. To identify the
steps that HUD takes to help ensure the reliability of its data, we
interviewed knowledgeable HUD officials about the purpose, structure,
and relevant quality controls for HUD-VASH data, including information
captured in HUD’s Voucher Management System (VMS) and Public and
Indian Housing Information Center (PIC). We also interviewed PHA staff
at the 10 selected locations about data collection and reporting, and any
related challenges. We reviewed relevant documentation, including the
information systems’ user guidance and HUD’s documented analysis of
comparisons between VMS, PIC, and VA data.

To address our third objective, we reviewed performance-related
information reported by VA such as monthly Dashboard-based reports on
HUD-VASH voucher utilization and a more descriptive report submitted to
Congress in October 2011. In addition, we interviewed representatives of,


Page 33                                        GAO-12-726 Veteran Homelessness
Appendix I: Objectives, Scope, and
Methodology




and gathered documentation from, HUD and VA headquarters; the U.S.
Interagency Council on Homelessness (Interagency Council); and veteran
and homeless advocacy organizations, including the National Coalition for
Homeless Veterans, the National Coalition for the Homeless, the National
Alliance to End Homelessness, and Vietnam Veterans of America. In
interviews with VA and HUD officials, we asked about performance
measures the agencies were monitoring for HUD-VASH. In interviews
with representatives of advocacy organizations, we discussed their
perspectives on HUD-VASH administration and the program’s
performance. We also asked VAMC and PHA staff for their perspectives
on HUD-VASH performance, potential ways to measure program
success, and opportunities for improvement.

We conducted this performance audit from September 2011 through June
2012 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




Page 34                                      GAO-12-726 Veteran Homelessness
Appendix II: Comments from the Department
             Appendix II: Comments from the Department
             of Housing and Urban Development



of Housing and Urban Development




             Page 35                                     GAO-12-726 Veteran Homelessness
Appendix II: Comments from the Department
of Housing and Urban Development




Page 36                                     GAO-12-726 Veteran Homelessness
Appendix III: Comments from the
              Appendix III: Comments from the Department
              of Veterans Affairs



Department of Veterans Affairs




              Page 37                                      GAO-12-726 Veteran Homelessness
Page 38   GAO-12-726 Veteran Homelessness
Appendix IV: Comments from the U.S.
              Appendix IV: Comments from the U.S.
              Interagency Council on Homelessness



Interagency Council on Homelessness




              Page 39                               GAO-12-726 Veteran Homelessness
Appendix V: GAO Contact and Staff
                  Appendix V: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Alicia Puente Cackley, (202) 512-8678, cackleya@gao.gov
GAO Contact
                  In addition to the contact named above, Marshall Hamlett (Assistant
Staff             Director), Bernice Benta, F. Chase Cook, Pamela Davidson, Cynthia
Acknowledgments   Grant, John McGrail, Marc Molino, and Barbara Roesmann made key
                  contributions to this report.




(250630)
                  Page 40                                     GAO-12-726 Veteran Homelessness
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