oversight

HUD's Technical Assistance Award Selection and Assignment Process for Continuum of Care and Homeless Programs Was Conducted in an Appropriate Manner

Published by the Department of Housing and Urban Development, Office of Inspector General on 2018-08-07.

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

     Office of Community Planning and
                Development
              Washington, DC
    Technical Assistance Awards for Continuum of Care
                 and Homeless Programs




Office of Audit, Region 9     Audit Report Number: 2018-LA-0003
Los Angeles, CA                                   August 7, 2018
To:            Lori Michalski, Acting General Deputy Assistant Secretary for Community
               Planning and Development, HHQ

               //SIGNED//
From:          Tanya E. Schulze, Regional Inspector General for Audit, 9DGA
Subject:       HUD’s Technical Assistance Award Selection and Assignment Process for
               Continuum of Care and Homeless Programs Was Conducted in an Appropriate
               Manner


Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our review of HUD’s technical assistance award selection and
assignment process for Continuum of Care and homeless programs.
HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on
recommended corrective actions. For each recommendation without a management decision,
please respond and provide status reports in accordance with the HUD Handbook. Please furnish
us copies of any correspondence or directives issued because of the audit.
The Inspector General Act, Title 5 United States Code, section 8M, requires that OIG post its
publicly available reports on the OIG website. Accordingly, this report will be posted at
http://www.hudoig.gov.
If you have any questions or comments about this report, please do not hesitate to call me at
213-534-2471.
                    Audit Report Number: 2018-LA-0003
                    Date: August 7, 2018

                    HUD’s Technical Assistance Award Selection and Assignment Process for
                    Continuum of Care and Homeless Programs Was Conducted in an
                    Appropriate Manner

Highlights

What We Audited and Why
We audited the U.S. Department of Housing and Urban Development’s (HUD) Community
Compass and Technical Assistance and Capacity Building program due to a complaint specific
to the Continuum of Care (CoC) and homeless portion of the program. The complaint alleged
that the Office of Special Needs Assistance Programs had been steering technical assistance
notice of funding availability applicants toward coordinating or subcontracting with a particular
nonprofit, as part of the nonprofit’s initiative, rather than directly addressing the needs of the
grantees. Our audit objective was to determine whether the technical assistance award selection
and assignment process for applicants qualifying for CoC and homeless programs was conducted
in an appropriate manner.

What We Found
The technical assistance award selection and assignment process appeared to have been
conducted in an appropriate manner. Although we determined that some aspects of the
complaint were true, such as the establishment of initiatives and nonprofits acting as a
subcontractor on their own initiatives, we found no program violations or evidence that the needs
of grantees were not being met.

What We Recommend
There are no recommendations.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................5
         Finding 1: HUD’s Technical Assistance Award Selection and Assignment Process
         for Continuum of Care and Homeless Programs Was Conducted in an Appropriate
         Manner. .............................................................................................................................. 5

Scope and Methodology ...........................................................................................7

Internal Controls ......................................................................................................9

Appendixes ..............................................................................................................10
         A. Auditee Comments and OIG’s Evaluation ............................................................. 10




                                                                      2
Background and Objective
The Community Compass Technical Assistance and Capacity Building program is designed to
help the U.S. Department of Housing and Urban Development’s (HUD) customers navigate
complex housing and community development challenges by equipping them with the
knowledge, skills, tools, capacity, and systems to implement HUD programs and policies
successfully. The goal of Community Compass is to empower communities by providing
effective technical assistance and capacity building so that successful program implementation is
sustained over the long term.

Recognizing that HUD’s customers often interact with a variety of HUD programs as they
deliver housing or community development services, Community Compass brings together
technical assistance investments from across HUD program offices, including the Offices of
Community Planning and Development, Fair Housing and Equal Opportunity, Housing, and
Public and Indian Housing. Applicants are encouraged to procure subcontractors and consultants
to demonstrate expertise across a wide range of HUD programs as well as in specific skills and
policy areas. Community Compass is centrally managed by HUD headquarters with
involvement of the HUD regional and field offices.
HUD awarded 21 technical assistance awards for fiscal year 2017, 22 for fiscal year 2016, and
23 for fiscal year 2015; however, only 9 of the grantees selected between fiscal years 2015 and
2017 worked with Continuum of Care (CoC) and homeless grantees.
                              Fiscal year    Fiscal year    Fiscal year
      Technical assistance        2015           2016           2017          Total
           provider             funding        funding        funding        amount
                                amount         amount         amount
 1   Abt. Associates, Inc.   $ 9,100,000    $ 8,415,119    $ 5,965,000    $ 23,480,119
 2   Cloudburst Consulting     4,800,000      3,875,000      4,955,000      13,630,000
     Group
 3   Collaborative             1,325,000      1,350,000       500,000        3,175,000
     Solutions, Inc.
 4   Corporation for             675,000      5,000,000      3,125,000       8,800,000
     Supportive Housing
 5   HomeBase/The Center       1,700,000      3,500,000      2,000,000       7,200,000
     for Common Concerns
 6   ICF Incorporated         11,225,000    11,544,121     13,509,000       36,278,121
 7   Partnership Center,         525,000     1,000,000      1,000,000        2,525,000
     Ltd.
 8   TDA Consulting, Inc.        500,000      1,875,000      2,308,608       4,683,608
 9   Technical Assistance        500,000      1,000,000      1,400,000       2,900,000
     Collaborative
     Total                    30,350,000    37,559,240      34,762,608     102,671,848




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Our audit objective was to determine whether the technical assistance award selection and
assignment process for applicants qualifying for CoC and homeless programs was conducted in
an appropriate manner.




                                              4
Results of Audit

Finding 1: HUD’s Technical Assistance Award Selection and
Assignment Process for Continuum of Care and Homeless Programs
Was Conducted in an Appropriate Manner
HUD’s technical assistance award selection and assignment process for applicants qualifying for
CoC and homeless programs was conducted in an appropriate manner. Our review of four of the
nine technical assistance providers that worked with CoC and homeless grantees found aspects
of the complaint to be true, such as the establishment of initiatives. We also found that there
were at least two cases in which a technical assistance provider used a subcontractor for its own
initiative. However, we found no program violations with this aspect of Community Compass or
evidence that the needs of grantees were not being met.

HUD Established Initiatives Through Technical Assistance Funding
Although we confirmed the complaint that the Office of Special Needs Assistance Programs
(SNAPS) implemented initiatives related to homelessness through the technical assistance award
funding, we identified no associated program violations with this process.

As part of HUD’s strategic plan and goals to end homelessness, a CoC or homeless grantee could
ask for direct technical assistance or be offered technical assistance via one of the initiatives.
Typically, initiatives are established to serve difficult populations, such as veterans, youth, and
chronically homeless groups. Instead of waiting for communities to request assistance, HUD
makes the initiatives proactive. SNAPS uses the data that it reports to Congress to get the
initiative technical assistance providers on the ground to provide outreach. Initiatives can be
created by the Director of SNAPS, Congress, or other Federal agencies or as the result of another
entity’s1 request to partner with HUD.

Subcontractors Had Acted as the Lead on Their Own Initiatives
Although we did find examples where technical assistance providers subcontracted with entities
to work on their own initiatives, we did not find that SNAPS steered the providers toward
coordinating or subcontracting with the particular entity.
The assignment of technical assistance providers to lead initiatives is decided by HUD
headquarters,2 and the assistance is spread out nationally to various cities and counties. We
sampled four technical assistance providers from the nine that worked with the CoC and



1
  These entities may have no other relationship with HUD but provide a value to the community, such as veterans’
initiatives.
2
  HUD assigns technical assistance providers previously selected and determined to be qualified through the notice
of funding availability process.


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homeless grantees. (See the Scope and Methodology section.) For two of the four providers, a
subgrantee spearheaded its own initiative for the technical assistance provider.

   •   Corporation for Supportive Housing subcontracted with Community Solutions to assist
       with its own Zero: 2016 campaign, which HUD had adopted. This initiative was a
       movement of communities working to end veterans’ homelessness by the close of 2015
       and end chronic homelessness 1 year later.
   •   HomeBase/The Center for Common Concerns subcontracted with Rapid Results Institute
       for the 100-Days Challenge initiative. This initiative was designed to support and guide
       three communities (Austin, TX, Cleveland, OH, and Los Angeles, CA) in their efforts to
       develop and implement a coordinated community approach to end youth homelessness.
With each of the above technical assistance providers, HUD did not require them to select the
subcontractor. Corporation for Supportive Housing’s 2016 application identified 13
subcontractors and 4 consultants that it would possibly work with if needed, and Community
Solutions was included as one of the subcontractors. Corporation for Supportive Housing
confirmed that it found Community Solutions to be adequately qualified or it would not have
selected it as a subcontractor.
Technical Assistance Addressed the Needs of Grantees
Although the complaint alleged initiatives did not directly address the needs of the grantees, we
found no evidence this was the case. Grantees were not required to respond to or accept outreach
related to an initiative, but were able to do so when they had a need in the respective area. The
initiatives were appropriately focused on addressing homelessness. In addition, grantees could
still request direct technical assistance in areas they needed assistance. The local field offices
could also request direct technical assistance on behalf of the grantee after consulting with the
grantee or noticing problems during monitoring the grantee. Our review of sample direct
requests indicated they were appropriately evaluated and assigned to a technical assistance
provider.
Conclusion
HUD’s technical assistance award selection and assignment process for applicants qualifying for
CoC and homeless programs was conducted in an appropriate manner. Aspects of the complaint
were accurate, such as the establishment of initiatives and the technical assistance providers’
subcontracting with entities on their own initiatives. However, we found no issues or program
violations with this aspect of Community Compass.

Recommendations
There are no recommendations.




                                                6
Scope and Methodology
We performed our audit fieldwork from March to June 2018 at our offices in Los Angeles, CA.
Our audit period covered technical assistance providers related to CoC and homeless programs
awarded funding from fiscal years 2015 through 2017 and technical assistance requests for the
same period.

To accomplish our objective, we

   •   Reviewed applicable HUD requirements and internal procedures;

   •   Interviewed appropriate HUD personnel from SNAPS;

   •   Interviewed HUD Office of Community Planning and Development directors;

   •   Interviewed technical assistance providers;

   •   Reviewed technical assistance provider applications, application ratings, cooperative
       agreements, and workplans; and

   •   Reviewed technical assistance requests made in 2017.

Only 9 of at least 21 technical assistance awardees for fiscal years 2017, 2016, and 2015 worked
with CoC and homeless grantees. Four of the nine technical assistance providers were selected
for review during the audit. We randomly selected three providers and included one additional
sample provider to ensure that we included the entity mentioned in the complaint. The four
selected technical assistance providers were Abt. Associates, Inc., Corporation for Supportive
Housing, HomeBase/The Center for Common Concerns, and Partnership Center, Ltd.

We also reviewed technical assistance requests made in 2017. We received a file from HUD,
which included a universe of 826 technical assistance requests. After filtering out the 2015 and
2016 requests, along with all ineligible requests (requests made by individuals seeking housing
or rental assistance), we were left with a universe of 319 technical assistance requests. We then
used Excel to randomly select four technical assistance requests. We reviewed four direct
technical assistance requests submitted in 2017 related to CoC and homeless grantees. All four
requests were received, were recorded, and had a technical assistance provider assigned to them
in an appropriate manner.

We relied on data received from HUD. Specifically, we relied on data HUD retrieved from
grantsolutions.gov. This website supports Federal agencies throughout the full grant life cycle,
from preaward planning through application, award, and closeout. HUD uses this website to
obtain a list of all applications submitted for technical assistance awards, rating the applications



                                                  7
and tracking the assignment of providers. We also relied on data from the Technical Assistance
Portal on the HUD Exchange, which is used to request technical assistance. Although we did not
perform a detailed assessment of the reliability of the data, we determined that that data were
sufficiently reliable for the purposes of our review because that data in the sampled items were
supported by interviews with the technical assistance providers and HUD Office of Community
and Planning and Development directors.

We conducted the audit 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
objective(s). We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.




                                                8
Internal Controls
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the achievement of the organization’s mission,
goals, and objectives with regard to

•   effectiveness and efficiency of operations,
•   reliability of financial reporting, and
•   compliance with applicable laws and regulations.

Internal controls comprise the plans, policies, methods, and procedures used to meet the
organization’s mission, goals, and objectives. Internal controls include the processes and
procedures for planning, organizing, directing, and controlling program operations as well as the
systems for measuring, reporting, and monitoring program performance.

Relevant Internal Controls
We determined that the following internal controls were relevant to our audit objective:

•   Controls to ensure that HUD does not violate program rules in the award selection and
    assignment process for technical assistance providers.

We assessed the relevant controls identified above.

A deficiency in internal control exists when the design or operation of a control does not allow
management or employees, in the normal course of performing their assigned functions, the
reasonable opportunity to prevent, detect, or correct (1) impairments to effectiveness or
efficiency of operations, (2) misstatements in financial or performance information, or (3)
violations of laws and regulations on a timely basis.
We evaluated the internal controls related to the audit objective in accordance with generally
accepted government auditing standards. Our evaluation of internal controls was not designed to
provide assurance regarding the effectiveness of the internal control structure as a whole.
Accordingly, we do not express an opinion on the effectiveness of HUD’s internal control.




                                                  9
Appendixes

Appendix A
             Auditee Comments and OIG’s Evaluation



Ref to OIG
Evaluation    Auditee Comments




Comment 1


Comment 2
Comment 3

Comment 4




                               10
                         OIG Evaluation of Auditee Comments


Comment 1   The OIG agrees technical assistance initiatives are directed and initiated by HUD;
            however, the initiative itself is not always originated by HUD. We found
            instances when the idea for the initiative came from the subcontractor and
            associated activity had already been underway, such as with Zero: 2016 and the
            100-Days Challenge. We agree that the technical assistance providers and their
            subcontractors are guided by HUD’s assignments, approved workplans, and
            subcontractor agreements.
Comment 2   We agree, by saying the funding is spread out, the OIG was trying to convey that
            technical assistance does not only go to larger cities or to only a few areas but is
            spread out across the United States to make sure all cities and counties small and
            large are able to benefit from technical assistance. We adjusted the report to
            clarify this.
Comment 3   We agree and the change was made to the report.
Comment 4   We agree that data also came from the Technical Assistance Portal and added this
            information to the report.




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