HUD’s explanation for revising or eliminating performance measures and targets is reasonable.1 HUD’s report reflected the data output generated by a methodology approved by ONDCP. Each National Drug Control Program agency must submit to the director of ONDCP, not later than February 1 of each year, a detailed accounting of all funds spent by the agency for National Drug Control Program activities during the previous fiscal year (21 U.S.C. (United States Code) 1704(d)(A)). In addition, the accounting must be “authenticated by the Inspector General for each agency prior to submission to the Director.” The accounting and related assertions are the responsibility of HUD’s management and were prepared by HUD personnel as specified in the ONDCP Circular: Accounting of Drug Control Funding and Performance Summary, dated January 18, 2013. As required by Federal statute (21 U.S.C. 1704(d)(A)), we reviewed HUD’s Report on Drug Control Accounting, including its written assertions. We conducted our attestation review in accordance with attestation standards established by the American Institute of Certified Public Accountants (AICPA) and the standards applicable to attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States. Our responsibility is to express a conclusion on the subject matter or assertion based on our review. The AICPA standards require that we plan and perform the review to obtain limited assurance about whether any material modifications should be made to the subject matter in order for it to be in accordance with (or based on) the criteria. A review is substantially smaller in scope than an examination, the objective of which is to obtain reasonable assurance about whether the subject matter is in accordance with (or based on) the criteria in all material respects or the responsible party’s assertion is fairly stated in all material respects in order to express an opinion. Accordingly, we do not express such an opinion. We performed review procedures on HUD’s assertions and the accompanying table. In general, we limited our review procedures to inquiries and analytical procedures appropriate for the attestation review. Based upon our review, nothing came to our attention that caused us to believe that management’s assertions, referred to above and included in the accompanying submission of this report, are not fairly stated in all material respects, and the review provides a reasonable basis for the practitioner’s conclusion, based on the criteria set forth in the ONDCP Circular: Accounting of Drug Control Funding and Performance Summary. However, we were unable to issue this attestation report by the due date required by ONDCP because HUD did not complete its final report by the mandated deadline of February 1, 2018. 1 HUD’s narrative disclosed changes to performance measures, ongoing efforts to enhance performance data, and plans to establish performance targets. 2 While this report is an unrestricted public document, the information it contains is intended solely for the use of HUD, ONDCP, and Congress. The purpose of this report is to authenticate HUD’s reporting on national drug control spending to the Director of ONDCP. This report is not suitable for any other purpose. Thank you for the cooperation and participation of HUD personnel in completing the attestation review. If you have any questions or comments to be discussed, please contact me at (202) 402- 8216. Attachment cc: Irving L. Dennis, Chief Financial Officer, F Neil Rackleff, Assistant Secretary for Community Planning and Development, D Henry Hensley, Director, Office of Strategic Management and Planning, X Emily Kornegay, Assistant Chief Financial Officer for Budget, FO 3 Appendixes Appendix A HUD’s Office of National Drug Control Program Reporting 4 OTHER DISCLOSURES HUD has not identified any other disclosures relating to the fiscal year 2017 drug control funds. MANAGEMENT ASSERTIONS The management assertions for HUD’s accounting report are found in the attached: Tab A 5 Department of Housing and Urban Development FY 2017 Performance Summary Report PERFORMANCE MEASURES & PRIOR YEARS PERFORMANCE TARGETS AND RESULTS Information regarding the performance of the drug control efforts of HUD is based on data collected from programs receiving funding through the annual CoC program competition. The table and accompanying text below highlight HUD’s drug‐related achievements during fiscal year 2016. Office of Special Needs Assistance Programs Selected Measures of FY 2013 FY 2014 FY 2015 FY 2016 FY 2017 Performance Achieved Achieved Achieved Achieved Achieved » Percentage of participants exiting N/A 59.4% 52.0% 47.3% N/A CoC‐funded transitional housing, rapid rehousing, and supportive services only projects that move into permanent housing.* » Percentage of participants in CoC‐ N/A 91.8% 92.9% 93.3% N/A funded permanent supportive housing remaining in or exiting to permanent housing.* » Projected number of participants 86,140 87,286 76,390 73,755 68,813 who report substance abuse as a barrier to housing to be served in CoC‐funded projects. *The data for exits and retention of permanent housing have a 1‐year time lag. In each CoC Program Competition, communities report on the performance from the last fiscal year. Thus, in the FY 2017 CoC Program Competition, communities reported on their outcomes from FY 2016. In the first performance measure – exits from transitional housing, rapid rehousing, and supportive services only projects to permanent housing destinations – there was a decrease between 2015 and 2016 from 52 percent to 47.3 percent. The second measure looks at the percent of persons served in CoC‐funded permanent supportive housing projects that remain in or exit to permanent housing. The data from 2016 shows a slight increase from last year – an increase to 93.3 percent. Both of the measures reflect the importance for persons who receive homeless services through HUD funded programs to exit to a stable housing situation. The final measure continues to track the number of persons proposed to be served by HUD’s CoC‐funded programs who enter with chronic substance abuse issues. In fiscal year 2017, there was a reduction of 4,942 persons with chronic substance abuse that were projected to be served. This reduction is due to HUD’s decision to encourage its providers to shift from 6 transitional housing projects (many of which serve persons with chronic substance abuse) to more permanent housing options. HUD believes that the number of persons with chronic substance abuse will likely increase again as other project types are prioritizing the hard to house populations, which often include a substance abuse element. Also, many of the CoCs are choosing to fund rapid rehousing projects in lieu of transitional housing and these rapid rehousing projects generally have a higher turnover rate, allowing CoCs to serve more people experiencing homelessness throughout the year. As an additional note on performance, between calendar years 2016 and 2017, HUD saw a decline of 5 percent in families experiencing homelessness (27 percent decline since 2010), as reported in HUD’s 2017 Annual Homeless Assessment Report (AHAR): Part 1 – Point‐in‐Time Estimates of Homelessness. QUALITY OF PERFORMANCE DATA HUD has updated its data collection across CoCs to improve the ability for CoCs to understand performance across the entire CoC – not merely at the project level. HUD has collected data across the entire CoC for 2 years now. This process has not only improved HUD’s knowledge of performance across an entire CoC but it also has resulted in higher data quality at the project level. HUD requires CoCs to report to HUD their data quality information. HUD includes data quality in its annual CoC Program Competition to incentivize higher data quality. HUD has also switched its data collection system for its CoC‐funded projects. This new system requires CoCs to upload their data from their local Homeless Management Information Systems (HMIS). This improves the data quality because the upload process does not accept imported data that has obvious errors. If an import is not accepted the system alerts the recipient to the specific areas of concern and the recipient is required to update their local HMIS to ensure the data is accurate. HUD is confident that this process has forced recipients to clean up their data and provide better data at the CoC level and nationally. MANAGEMENT ASSERTIONS The management assertions on the performance information contained in this report can be found in Tab B. 7 Appendix B Management Representations 8 9 10 11
Independent Attestation Review: U.S. Department of Housing and Urban Development, Office of Special Needs Assistance Continuum of Care, Regarding Drug Control Accounting for Fiscal Year 2017
Published by the Department of Housing and Urban Development, Office of Inspector General on 2018-05-04.
Below is a raw (and likely hideous) rendition of the original report. (PDF)