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September 8, 2005

Regulations Division

Office of General Counsel

U.S. Department of Housing and Urban Development

451 7^th^ St., S.W., Room 10276

Washington, D.C. 20410

Re: FR- 4970-N-01; HUD-2005-0011

Dear Sir or Madam:

The Council of State Community Development Agencies (COSCDA) is the
premier national organization which represents state community
development agencies that administer several HUD programs, including the
Community Development Block Grant (CDBG), HOME, HOPWA and ESG programs.
We offer comments an input on the Notice published on June 10, 2005
regarding the Draft Outcome Performance Measurement System (HUD CPD
Performance Measurement System). As a member of the Joint
Grantee/HUD/OMB Performance Measures Working Group that developed the
list of indicators in the aforementioned Notice, we are extremely
pleased that the Department has invested significant effort in seeking
input from grantees about the indicators and implementation issues. The
Notice and five regional forums held this past summer are important
steps towards successful implementation of this new Performance Measures
System.

As the discussions about the indicators have evolved, certain key issues
have emerged that we wish to offer comments on in this letter. They are:

-   Additional Indicators

-   Implementation Issues

-   Reporting

-   Training Issues

[Additional Indicators]{.underline}

COSCDA supports adding certain indicators to the HUD CPD Performance
Measurement System if those indicators report on an outcome which
relates to a significant portion of the expenditures (in the above
listed programs) and if the outcomes are a significant part of the
national story about the programs' results that we believe is of
interest to Congress. Based on feedback at the regional feedback
Performance Measure forums, we recommend adding indicators in the areas
of homeless prevention, disaster relief and emergency or partial housing
rehabilitation. We would be happy to work with the Department on the
development of indicators in these areas. At this time, we do not
support adding indicators on other types of activities or projects and
would ask that the Department seek input from stakeholder groups before
adding any other indicators.

[Clarification of Indicators]{.underline}

For the two indicators related to jobs, the Notice refers to an
exemption on reporting how many newly created or retained jobs went to
previously unemployed persons when the grantee has agreed that the
business must report only how many of those jobs were "made available
to" low-income persons. To clarify, the reason why this kind of activity
is exempt from reporting on this indicator is because the business will
not have that data. Job applications, the only source of data on the
employment status, are not the only source of documentation required of
the business by the grantees. Job fairs and other recruitment efforts
are also used as primary documentation. Therefore, the number of persons
previously unemployed that the business the jobs were" made available
to" is not consistently available and should remain exempt.

[Implementation Issues]{.underline}

Implementation of the HUD CPD Performance Measurement System will be
daunting task at every level, from HUD headquarters to HUD Field
Offices, and the grantees, sub-grantees and the non-profit organizations
that deliver the activities at the community level. A smooth transition
depends on a clear and organized plan that all parties involved agree to
and can achieve. When the forums were held, there were more questions
than answers about implementation, and some are still unanswered.

COSCDA recommends that HUD, in consultation with stakeholders, publish a
timetable with step by step guidance for grantees on what they need to
do in order to implement this system. At the same time, HUD must
immediately and sequentially revise the Consolidated Plan, Annual Plan,
CAPER and PER in order for grantees to integrate the new objectives,
outcomes and indicators into their programs. IDIS must be revised
simultaneously. Feedback from our members who attended the regional
forums indicates that they did not receive enough information about
HUD's plans for changes to HUD's planning and reporting mechanisms
(listed above), and consequently, they are concerned with HUD's ability
to facilitate implementation of the new Performance Measures System.

[Reporting]{.underline}

COSCDA is aware that the Department is planning several reporting
changes for the CDBG program as part of the IDIS system revisions. Many
of these have been previously discussed outside of the new HUD CPD
Performance Measure System and relate to data consistency across HUD
programs. COSCDA members have disagreed with some of these changes in
the past because of the differences between the state and entitlement
CDBG programs. These objections stem from the way states create projects
and the unit of measurement in certain activities- for example, states
may report on the number of households where entitlements may report on
the number of persons, or vice versa, particularly for certain housing
or public service activities. Also, the labor involved in entering the
data of each individual housing unit, which is something that has been
discussed as a change for states, would be enormous.

A similar concern has arisen about certain indicators in the Notice. The
Joint Grantee/HUD/OMB Performance Measures Working Group the HUD CPD
Performance Measure System also tried to address the issue of data
consistency in its deliberations. They agreed that to the extent
possible grantees should provide consistent data on indicators across
all four involved programs, but they also recognized that the need for
exceptions. For the indicators asking for a simple yes or no answer,
such as the homeownership assistance to first-time homebuyers or
subsidized tenants, the intent was not to enter each unit that would be
in each category, but to answer whether the entire project was meant to
serve that target population. No one in the state CDBG program in the
Working Group expected that they would have to enter individual
addresses and actual unit counts for those categories. Actual counts for
this indicator will impose a great administrative burden on
subrecipients and subgrantees, which are small towns and non-profit
organizations. If there was a way in the new IDIS system to
electronically send this data from the sub-grantees to the state and
then on to HUD, perhaps COSCDA would withdraw its objection, but at this
point we cannot agree that individual unit data be entered in order to
provide the numbers of units instead of a true yes or no for those
indicators.

COSCDA supports reporting all outcomes and data for all indicators that
grantees believe are applicable to their activities. HUD has asked for
input on whether grantees would agree to designate only one outcome as
the primary outcome and others as secondary. COSCDA would suggest
requiring one primary outcome and allowing and encouraging grantees to
report on other outcomes using the term "additional outcomes", as we
find that term more positive than the term that has been proposed
)"secondary".

[Training]{.underline}

Training is the key to successful implementation of this new System, and
COSCDA stands ready to assist HUD in its efforts to provide training to
state grantee and their sub-grantees. COSCDA recommends the Department
provide:

-   Standardized definitions must be developed, and grantees need to be
    advised as soon as possible of the new indicators and data
    requirements so they can begin implementation;

-   Sample applications and data collection forms;

-   Two-page standard description of the System that can be used to
    brief local officials, colleagues, subrecipients, and local
    partners;

-   A cross-walk of indicators to activities and outcomes that is also
    across all four programs. This would be extremely helpful with the
    Consolidated Plan;

-   Training that states and entitlements can offer to their
    sub-grantees and sub-recipients is also urgently needed.
    Standardized training of this kind is essential. Training should be
    provided to HUD staff so that they can be responsive to the needs of
    grantees.  Participants strongly favored having HUD staff attend the
    same trainings as grantees, and hear the same messages delivered to
    grantees.

We appreciate the opportunity to comment on this developing System and
look forward to continued dialogue with Department on other issues that
arise as we move towards implementation of this new System.

Sincerely,

Dianne E. Taylor

Executive Director