HOUSING CHOICE 

VOUCHER 

PROGRAM

Limited Indications of 

Potential Fraud 

against Participants 

Identified

Report to Congressional Requesters

December 2017

GAO-18-53

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-53, a report to 

congressional requesters

December 2017

HOUSING CHOICE VOUCHER PROGRAM

Limited Indications of Potential Fraud against 

Participants Identified

What GAO Found

Public Housing Agencies (PHA) have reported various types of fraud schemes 

against Housing Choice Voucher (HCV) participants, including older adults, but 

were aware of limited instances of such schemes. Similarly, GAO identified few 

potential indicators of these schemes in online covert testing of rental ads and 

websites. According to GAO’s analysis of fraud alerts and complaint data, the 

type of fraud participants may encounter—such as waiting-list, rental, and sidepayment fraud—depends on where they are in the HCV process and whether 

they are applicants, voucher holders, or landlords, as shown in the figure below.

For example, side-payment fraud involves agreements—mutual or compelled—

in which the voucher holder pays additional rent or other payments to the 

landlord for benefits, for example to secure a rental or avoid eviction.

Types of Reported Fraud in the Housing Choice Voucher Process

According to GAO’s survey of PHAs representing approximately 1.9 million 

households, PHAs reported few incidents of the various fraud types, although 

side-payment fraud, a program violation, was noted most frequently. Specifically, 

GAO estimates that while 41 percent of PHAs were aware of instances of sidepayment fraud in the prior year, most reported 2 to 5 incidents in the prior year. 

In addition, 3 to 10 percent of PHAs were aware of instances of the other types 

of fraud GAO identified. GAO’s online covert testing also found few indicators of 

potential fraud. For example, some websites requested payment for information 

about the HCV application process, but none explicitly offered to do something 

prohibited by program rules, such as placing someone on a waiting list for a fee.

The Department of Housing and Urban Development’s (HUD) and PHAs’ 

antifraud regulations, guidance, and information largely focus on efforts to 

protect the HCV program. For example, PHAs are required by HUD to inform 

families of program-related fraud and abuse, including the prohibition against 

side payments. In addition, GAO found that several PHAs voluntarily provide

targeted messages to participants about fraud schemes by outside parties. 

Through industry associations, PHAs have mechanisms through which they 

share best practices that could include these and other issues.

View GAO-18-53. For more information, 

contact Rebecca Shea at (202) 512-6722 or 

shear@gao.gov.

Why GAO Did This Study

With the goal of providing safe, decent, 

affordable housing, HUD provides 

rental assistance to low-income 

households through its HCV program, 

administered locally by approximately

2,200 PHAs around the country. In 

fiscal year 2016, the HCV program 

received approximately $20 billion in 

funding and provided rental assistance 

to approximately 2.4 million 

households. Local demand in the 

program may exceed voucher supply, 

and individuals may wait years before 

receiving a voucher. After receiving a 

voucher, participants have a limited 

amount of time to secure a rental. 

Accordingly, PHAs have issued alerts

about criminals targeting program 

participants with fraud schemes, such 

as by claiming to offer admission to the 

program for a fee.

This report describes (1) the types of 

reported fraud schemes against HCV 

participants, including older adults, 

PHAs’ awareness of such schemes 

and their frequency, and indicators of 

such schemes online; and (2) HUD’s 

and PHAs’ antifraud regulations, 

guidance, and information related to 

fraud risks affecting program 

participants. GAO reviewed online 

fraud alerts and consumer complaint 

data from calendar years 2011 to 

2016; conducted a generalizable 

survey of PHA officials about their 

awareness of fraud against

participants; interviewed agency 

officials and experts; and conducted 

online covert tests of 350 rental ads 

and 26 commercial websites. GAO 

visited eight PHAs, selected based on 

size and location, among other factors.

GAO is not making recommendations 

in this report. HUD had no comments

on a draft of this report.
Page i GAO-18-53 Housing Choice Voucher Program

Letter 1

Background 4

Various Reported Fraud Schemes against Housing Choice 

Voucher Participants Can Occur, but PHAs Reported Limited 

Incidents, and GAO Covert Testing Found Limited Online 

Indicators of Fraud 8

HUD and PHA Antifraud Efforts Focus Mainly on Fraud against 

the HCV Program; Some PHAs Voluntarily Provide Information 

about Fraud against Participants 17

Agency Comments 20

Appendix I Objectives, Scope, and Methodology 21

Appendix II Results of GAO’s Survey of Public Housing Agencies 33

Appendix III GAO Contact and Staff Acknowledgments 48

Tables

Table 1: Estimated Percentage of PHAs Aware of Fraud Type—

Survey Question 1 34

Table 2: Reported Incidents of Fraud Type (Raw Counts)—Survey 

Question 1 34

Table 3: Methods by Which PHAs Became Aware of Fraud Type 

(Raw Counts)—Survey Question 1 35

Table 4: PHAs Reporting That Older Adults Were Targeted in 

Fraud Incidents (Raw Counts)—Survey Question 1 35

Table 5: Estimated Percentage of PHAs Aware of Fraud Type—

Survey Question 2 36

Table 6: Reported Incidents of Fraud Type (Raw Counts)—Survey 

Question 2 36

Table 7: Methods by Which PHAs Became Aware of Fraud Type 

(Raw Counts)—Survey Question 2 37

Table 8: PHAs Reporting That Older Adults Were Targeted in 

Fraud Incidents (Raw Counts)—Survey Question 2 37

Table 9: Estimated Percentage of PHAs Aware of Fraud Type—

Survey Question 3 38

Contents
Page ii GAO-18-53 Housing Choice Voucher Program

Table 10: Reported Incidents of Fraud Type (Raw Counts)—

Survey Question 3 38

Table 11: Methods by Which PHAs Became Aware of Fraud Type 

(Raw Counts)—Survey Question 3 39

Table 12: PHAs Reporting That Older Adults Were Targeted in 

Fraud Incidents (Raw Counts)—Survey Question 3 39

Table 13: Estimated Percentage of PHAs Aware of Fraud Type—

Survey Question 4 40

Table 14: Reported Incidents of Fraud Type (Raw Counts)—

Survey Question 4 40

Table 15: Methods by Which PHAs Became Aware of Fraud Type 

(Raw Counts)—Survey Question 4 41

Table 16: PHAs Reporting That Older Adults Were Targeted in 

Fraud Incidents (Raw Counts)—Survey Question 4 41

Table 17: Estimated Percentage of PHAs Aware of Fraud Type—

Survey Question 5 42

Table 18: Reported Incidents of Fraud Type (Weighted 

Estimates)—Survey Question 5 42

Table 19: Reported Incidents of Fraud Type (Raw Counts)—

Survey Question 5 43

Table 20: Methods by Which PHAs Became Aware of Fraud Type 

(Weighted Estimate)—Survey Question 5 43

Table 21: Methods by Which PHAs Became Aware of Fraud Type 

(Raw Counts)—Survey Question 5 43

Table 22: PHAs Reporting That Older Adults Were Targeted in 

Fraud Incidents (Weighted Estimates)—Survey Question 

5 44

Table 23: PHAs Reporting That Older Adults Were Targeted in 

Fraud Incidents Incidents (Raw Counts)—Survey 

Question 5 44

Table 24: Estimated Percentage of PHAs Aware of Fraud Type—

Survey Question 6 44

Table 25: Reported Incidents of Fraud Type (Raw Counts)—

Survey Question 6 45

Table 26: Methods by Which PHAs Became Aware of Fraud Type 

(Raw Counts)—Survey Question 6 45

Table 27: PHAs Reporting That Older Adults Were Targeted in 

Fraud Incidents (Raw Counts)—Survey Question 6 45

Table 28: Estimated Percentage of PHAs Aware of Fraud Type—

Survey Question 7 46

Table 29: Reported Incidents of Fraud Type (Raw Counts)—

Survey Question 7 46
Page iii GAO-18-53 Housing Choice Voucher Program

Table 30: Methods by Which PHAs Became Aware of Fraud Type 

(Raw Counts)—Survey Question 7 47

Table 31: PHAs Reporting That Older Adults Were Targeted in 

Fraud Incidents (Raw Counts)—Survey Question 7 47

Figures

Figure 1: Housing Choice Voucher Application and Rental 

Process 6

Figure 2: Types of Reported Fraud in the Housing Choice Voucher 

Process 9

Figure 3: Estimated Percentage of PHAs with Awareness of 

Incidents of Fraud in Their Jurisdiction between Spring 

2016 and Spring 2017, by Fraud Types 12

Figure 4: Examples of HCV Program-Related Fraud Listed in the 

Housing Choice Voucher Program Guidebook 18

Figure 5: Key Methodologies Used to Identify Types of Reported 

Fraud, Fraud Awareness, and Indicators of Online Fraud 22
Page iv GAO-18-53 Housing Choice Voucher Program

Abbreviations

CFR U.S. Code of Federal Regulations

FTC Federal Trade Commission

HCV Housing Choice Voucher

HOME Home Investment Partnerships Program

HUD Department of Housing and Urban Development

LIHTC Low Income Housing Tax Credit

OIG Office of Inspector General

PHA Public Housing Agency

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-18-53 Housing Choice Voucher Program

441 G St. N.W.

Washington, DC 20548

December 4, 2017

The Honorable Susan Collins

Chairman

The Honorable Robert P. Casey

Ranking Member

Special Committee on Aging

United States Senate

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

With the goal of providing safe, decent, and affordable housing to lowincome families, the elderly, and the disabled, the U.S. Department of 

Housing and Urban Development (HUD) supplements tenants’ rental 

payments in privately owned housing chosen by tenants through its 

Housing Choice Voucher (HCV) program.1 This program is administered 

locally by approximately 2,200 Public Housing Agencies (PHA) around 

the country. In fiscal year 2016, HUD received approximately $20 billion 

for the HCV program, providing rental assistance to approximately 2.4 

million households.2 Local demand in the program may exceed voucher 

supply, and households may be on waiting lists for years before they 

receive a voucher. In addition, after receiving a voucher, participants have 

a limited amount of time to secure a rental. PHAs and others have issued 

alerts about criminals targeting HCV program participants (including 

applicants, voucher holders, and landlords) in potentially fraudulent

schemes, such as individuals who fraudulently claim to offer vouchers for 

a fee.

 1

The Section 8 program assists eligible families in the private rental market. The HCV 

program is one component of the Section 8 program; the other is the Project-Based 

Rental Assistance program, which attaches voucher assistance to specific housing units. 

HUD also administers three other rental-assistance programs, the Public Housing 

Program, the Home Investment Partnerships Program (HOME), and the Low Income 

Housing Tax Credit (LIHTC). Only the HCV program was within the scope of our work.

2

According to HUD’s HCV program guidebook, a household is defined as either a single 

person or a group of persons.

Letter
Page 2 GAO-18-53 Housing Choice Voucher Program

You asked that we investigate possible fraud against HCV program 

participants and examine applicable federal oversight, including any 

preventive and educational measures taken to help identify and limit such 

fraudulent activity affecting HCV participants—including older adults and 

other vulnerable populations—and to provide information about fraudulent 

activity identified to date. In this report, we describe (1) the types of 

reported fraud schemes committed against HCV participants (including 

older adults), awareness by PHAs and other relevant organizations of 

fraud incidents and how often they occur, and indicators of such schemes 

online; and (2) antifraud regulations, guidance, and informational 

materials, if any, that HUD and PHAs have in place to identify and 

mitigate fraud against program participants.

For our first objective, we employed a number of methodologies. 

Specifically, to describe the types of fraud schemes reported as being 

committed against HCV participants in 2016 and 2017, we searched for 

fraud alerts that a nongeneralizable sample of 60 PHAs publicly posted 

on the Internet and reviewed the 22 alerts (posted by 20 separate PHAs) 

that we found. We also reviewed complaints from the Federal Trade 

Commission’s (FTC) Consumer Sentinel database for calendar years 

2011 through 2016.3 We reviewed complaint data to identify examples of 

housing and HCV-specific fraud, including schemes affecting older adults. 

We assessed the reliability of the data by interviewing officials and 

reviewing related documentation, and found the data sufficiently reliable 

for the purposes of our reporting objectives. We also interviewed PHA 

officials about fraud schemes against HCV participants. Finally, we 

identified key academic research that classified online rental fraud, and 

interviewed one of the authors of the research.

To determine awareness of incidents of fraud schemes among PHAs and 

other relevant organizations, we surveyed PHA officials and conducted 

site visits to interview PHAs and other relevant organizations and experts. 

In our survey of a nationally representative, random sample of executive 

directors of 278 PHAs, we asked about their awareness of fraud against 

participants, in the last year (spring 2016–spring 2017), within the 

jurisdiction to which they provide oversight. If the executive directors 

 3

The Consumer Sentinel database combines consumer complaints provided to a number 

of organizations, including, among others, FTC, the Consumer Financial Protection 

Bureau, the Better Business Bureau, and the Identity Theft Assistance Center. We 

provided FTC with a set of search terms to use in the query. Terms were related to the 

HCV program and to rental property and rental advertisement websites, among others.
Page 3 GAO-18-53 Housing Choice Voucher Program

responded that they were aware of these schemes, we asked that they 

provide information on the number of incidents, within their jurisdiction, 

that they were aware of in the prior year.4 Examples of fraud types 

included in the survey were promising placement or a higher place on a

voucher waiting list, selling fake vouchers, theft of security deposits, 

requiring side payments and favors, and offering suspect credit-report 

services. We surveyed executive directors from all 83 PHAs that 

administered 5,000 or more vouchers as of the fourth quarter of 2015, 

and a probability sample of 195 executive directors of PHAs with 1,000 to 

4,999 vouchers. The survey had a response rate of 84 percent and is 

generalizable to the full population of PHAs that administer at least 1,000 

vouchers. In addition, we interviewed eight PHAs in total, from locations 

in the Midwest, Northeast, and West Coast regions of the United States. 

These PHAs were selected using criteria to provide a range of PHAs 

across geographical locations and PHA size, among other factors. 

Moreover, we also interviewed an HCV voucher holder about the holder’s 

knowledge of fraud against participants. We also interviewed industry 

experts—selected based on their expertise and experience with legal and 

financial issues affecting older adults and low-income individuals—about 

fraud affecting older adults, and about identity theft affecting low-income 

individuals. Finally, we interviewed officials from the HUD Office of 

Inspector General (OIG).

To identify indicators of fraud schemes online, we used covert testing to 

investigate (1) a nongeneralizable sample of 350 rental advertisements in 

a selection of U.S. cities across several rental websites, and (2) a 

nongeneralizable sample of 26 commercial websites advertising 

information on, or assistance with, the HCV program. For our sample of 

rental advertisements, we counted any communications with online 

advertisers as having an indicator of fraud if they contained requests such 

as asking for a wire transfer of a security deposit or first month rent 

without first offering to show the property. For commercial websites, we 

used multiple search terms across two search engines to produce a list of 

target websites. Using undercover identities, we visited each website and 

input any requested information, including a name and e-mail address, 

and made a payment if the website requested payment for a service. We 

also asked website operators whether they could place us on a waiting 

list. Because covert testing of advertisements and websites was carried 

 4

Because each executive director responded with respect to the jurisdiction of the PHA he 

or she administers, we attribute the survey results to the respective PHA. See app. I for 

more information on our sampling methodology.
Page 4 GAO-18-53 Housing Choice Voucher Program

out on a nongeneralizable sample, results of this effort are also 

nongeneralizable.

To describe antifraud regulations, guidance, and informational materials, 

we reviewed relevant HUD regulations and policy documentation, as well 

as informational materials developed by the eight PHAs we interviewed, 

designed to educate HCV participants about the program. We interviewed 

PHA officials about the HCV program and about the information they 

provide to participants. We also interviewed officials from FTC, the 

Consumer Financial Protection Bureau, the HUD OIG, the U.S. Postal 

Inspection Service, and the Department of Health and Human Services 

about practices used by federal agencies to inform the public about fraudrelated issues. For additional details on our scope and methodology, see 

appendix I.

We conducted this performance audit from May 2016 to December 2017 

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. We conducted our related 

investigative work from January 2017 to July 2017 in accordance with 

investigative standards prescribed by the Council of the Inspectors 

General on Integrity and Efficiency.

The HCV program, administered by HUD, subsidizes housing costs for 

low-income households in the private rental market. Because HUD 

provides HCV assistance directly to the household, participants are able 

to find their own housing, including single-family homes, townhouses, and 

apartments. If the household moves out of the unit, it can move with 

continued assistance to another private rental unit.5

PHAs administer the HCV program at the local level, while HUD 

administers funding and furnishes technical and professional assistance 

to PHAs in planning, developing, and managing the program. 

Approximately 2,200 PHAs across the country administer the voucher 

 5

Voucher holders may not be able to move out of the area immediately; they may have to 

live in the jurisdiction of the initial PHA for a year before they can move.

Background
Page 5 GAO-18-53 Housing Choice Voucher Program

program on HUD’s behalf, managing day-to-day operations in the HCV 

program, including the application and voucher distribution processes, as 

well as housing inspection and approval. PHAs are responsible for 

ensuring that rents are reasonable, determining households’ eligibility, 

calculating and periodically redetermining households’ incomes and rental 

payments, and making subsidy payments to landlords. In addition, PHAs 

perform basic program functions, such as establishing and maintaining a 

waiting list, processing tenant moves, conducting landlord and tenant 

outreach, and reporting to HUD.

Local PHAs determine the eligibility of households, approve applications, 

and distribute vouchers. In general, to be eligible to participate in the HCV 

program, households must have very low incomes—that is, incomes not 

exceeding 50 percent of the area median income. Moreover, at least 75 

percent of new voucher program participants must have extremely low 

incomes, not exceeding 30 percent of the area median income. Once a 

household is approved by a PHA to participate in the program and finds a 

rental unit, that household pays 30 percent of its monthly income, after 

certain adjustments, toward rent. The remaining portion of the rent is paid 

through the HUD-subsidized voucher. PHAs can pay subsidies to cover 

between 90 percent and 110 percent of the fair market rent for their 

areas.

The HCV application and rental process is displayed in figure 1.
Page 6 GAO-18-53 Housing Choice Voucher Program

Figure 1: Housing Choice Voucher Application and Rental Process

The following applies in the HCV application process:

• Households seeking to enter the HCV program may wait years for 

their local PHA to announce an open application period. PHAs may 

establish waiting lists if the number of applicants to the program 

exceeds available vouchers, and may close the waiting list if it 

contains more households than the PHA can assist in the near future. 

Therefore, prospective applicants in some locations can wait years for 

a local PHA to determine the eligibility of those already on the waiting 

list—and provide vouchers to eligible individuals—before reopening 

waiting lists to new applicants.

• During open application periods, applicant households may encounter 

processes and requirements that vary amongst PHAs. Applying for a 

voucher from a local PHA may take place in person or online, while 

PHAs may determine an applicant’s priority to receive a voucher by 

varying methods, such as a random lottery amongst all applicants, or 

on a first-come-first-serve ordering of when applicants applied. 

Moreover, PHAs can establish local preferences for selecting 
Page 7 GAO-18-53 Housing Choice Voucher Program

applicants from their waiting lists. For example, PHAs may give 

preference to a household that (1) is homeless or living in 

substandard housing, (2) is paying more than 50 percent of its income 

for rent, or (3) has an older-adult household member. Regardless of 

methods to determine eligibility, apply for, and obtain a voucher within 

the HCV program, it is free to participants.

• When an open application period ends and before determining 

household eligibility, PHAs may initially put applicant households on a 

waiting list. Because the demand for vouchers may exceed the supply 

available to the local PHA, households that have already waited to 

apply to the program may also wait years to receive a determination 

of eligibility and receive a voucher.

• After receiving a voucher, households must find eligible privatemarket rental housing within a limited time frame. A PHA will make 

contact with and issue a voucher to a household that is determined to 

be eligible and is subsequently selected from the waiting list. 

Households receiving vouchers use them to subsidize their rents in 

private apartments or houses available in the rental market.

Households must find housing quickly—generally within 60 days—

unless the PHA grants an extension. In some cases, PHAs direct 

voucher holders to websites dedicated to rentals in the HCV program, 

where private landlords list available units.

• When a voucher-holding household finds a unit that it wishes to 

occupy—and reaches an agreement with the landlord over the lease 

terms—the PHA inspects the dwelling and determines whether the 

rent requested is reasonable. To be eligible, a rental unit must meet 

HUD minimum housing-quality standards, and must provide an 

acceptable level of health and safety. After the unit is inspected and 

deemed eligible, the household signs a contract with HUD, and both 

HUD and the household sign contracts with the landlord. The contract

stipulates that the PHA will make the housing-assistance payment to 

the landlord and the household will pay the difference between the 

housing-assistance payment and the rent. Landlord participation in 

the HCV program is free, and landlords do not pay to maintain 

compliance with the program. Moreover, the HCV program provides 

for the use of vouchers across locations. Once a household receives 

a voucher, it may use the voucher in any location in which a PHA 

administers the voucher program, as long as it remains eligible.
Page 8 GAO-18-53 Housing Choice Voucher Program

Reported fraud schemes against program participants—including 

prospective applicants, individuals on waiting lists, current voucher 

holders, and landlords providing rental units—can occur at each point in 

the HCV application and rental process, according to program officials 

and our analysis of FTC complaint data. On the basis of our reviews of 

fraud alerts issued by PHAs and complaints submitted to the FTC, the 

type of fraud that participants, including older adults, may encounter 

depends on where they are in the process and whether they are landlords 

or renters. Fraudsters perpetrate reported schemes in a variety of ways, 

such as through in-person impersonation of PHA staff or by manipulating 

telephone numbers to convince landlords to make unnecessary 

payments. Reported types of fraud schemes and when they could 

potentially occur in the HCV application and rental process are displayed 

in figure 2.

Various Reported 

Fraud Schemes 

against Housing 

Choice Voucher 

Participants Can 

Occur, but PHAs 

Reported Limited 

Incidents, and GAO 

Covert Testing Found 

Limited Online 

Indicators of Fraud

Waiting-List, Rental, and 

Side-Payment Fraud Are 

among the Reported 

Types of Schemes That 

Can Affect Voucher 

Participants
Page 9 GAO-18-53 Housing Choice Voucher Program

Figure 2: Types of Reported Fraud in the Housing Choice Voucher Process
Page 10 GAO-18-53 Housing Choice Voucher Program

As shown in figure 2, various reported fraud types can be carried out 

against HCV participants. While some fraud types are specific to the HCV 

program, participants may also be victims of general rental-housing fraud. 

The reported fraud types, which we identified through interviews with 

PHAs and others and through an analysis of PHA fraud alerts and 

Consumer Sentinel complaints, include the following:

• Waiting-List Placement Fraud. In online or in-person settings, 

fraudsters may claim they can provide a voucher, place applicants 

onto a waiting list, or move individuals to a higher position on the 

waiting list. In exchange, fraudsters may request a payment, or may 

request information (such as name, credit-card number, and e-mail 

address) that may put participants at risk of credit-card fraud or 

identity theft.6 Waiting lists maintained by PHAs may open 

infrequently, and program application processes and requirements 

vary from location to location. Reported fraud schemes may take 

advantage of applicant unfamiliarity with program rules, and target 

those seeking to enter the program or awaiting a voucher.

• Rental-Advertisement Fraud. Because they rent in the private market, 

voucher holders are susceptible to online rental-fraud schemes. 

Those who place online rental advertisements may request wire 

transfers from prospective renters to secure fake rentals, or steer 

potential renters to suspect credit-reporting services that offer 

commissions to the scammers or realtor services that charge users a 

onetime or recurring monthly fee.

• Side-Payment Fraud. Officials from PHAs and other organizations 

characterized side payments as two distinct activities—alternatively, 

as landlord fraud against tenants on one hand, and mutually beneficial 

agreements between tenants and landlords on the other. In exchange 

for property rental or successful inspection, landlords or building 

inspectors may fraudulently request additional payments or pressure 

participants for other favors from voucher holders. Landlords may ask 

tenants for a monthly payment above the agreed rent, or may require 

HCV participants to pay for utilities when not required to in their rental 

 6

An identity-theft expert we interviewed defined these types of fraud as follows. Creditcard fraud occurs if the perpetrator steals a credit-card number, expiration date, and threedigit Card Security Code. With that information, a fraudster can buy things using an 

existing credit card, but cannot start a new line of credit using the stolen information, 

because the fraudster is missing date of birth and Social Security number of the victim. 

Identity theft involves the theft of information required for credit-card fraud, along with date 

of birth and Social Security number of the victim. The perpetrator can then claim to be the 

victim and open a new line of credit.
Page 11 GAO-18-53 Housing Choice Voucher Program

agreement. For example, a Midwest PHA we interviewed reported 

being aware of coercive demands by landlords for side payments or 

sexual favors in exchange for a rental unit. Side payments may also 

be a mutual arrangement between landlord and voucher holders. For 

example, voucher holders may make a payment above their monthly 

rent—in violation of program rules—and in exchange the landlord 

agrees not to report that there are unauthorized occupants living in 

the unit, again in violation of program rules. A West Coast PHA we 

interviewed characterized most side payments it is aware of as mutual 

agreements of this type.

• Security-Deposit Fraud. Because they rent in the private market, 

voucher holders may encounter fraudsters advertising a rental and 

requiring a security deposit from one or several prospective renters 

even if there is no rental unit available or only one of the prospective 

renters will ultimately obtain the rental.

• Program-Compliance Fraud against Landlords. Fraudsters may take 

advantage of landlord unfamiliarity with HCV program rules. In calls to 

HCV program landlords, fraudsters mask their phone number with that 

of the local PHA, and direct the landlords to make a credit-card 

payment over the phone to purchase materials or to make a payment 

in order to remain in compliance with program rules.

An overwhelming majority of surveyed PHAs did not report awareness of 

any occurrences of most fraud types that could affect HCV program 

participants, while those that were aware of fraud against participants 

reported few instances, according to our survey results and interviews. 

We surveyed a nationally representative sample of PHAs representing 

approximately 1.9 million households. We inquired about incidents 

occurring within their area of jurisdiction from spring 2016 through spring 

2017. We asked about fraudsters promising placement onto or a higher 

place on a waiting list, selling vouchers, stealing security deposits, or 

offering suspect credit-report services; voucher holders and landlords 

engaging in side payments; and landlords and building inspectors illegally 

soliciting favors.7 Apart from incidents of side payments (discussed in 

detail below), on the basis of PHA responses to our survey we estimate 

that between 3 and 10 percent of all PHAs with 1,000 or more vouchers 

were aware of any occurrences of the types of fraud schemes included in 

our survey (see fig. 3). Further, when PHAs were aware of such fraud 

 7

For full survey results, see app. II.

PHAs Are Aware of 

Limited Instances of Fraud 

Affecting Voucher 

Participants in Their 

Jurisdictions, with SidePayment Fraud Reported 

Most Often
Page 12 GAO-18-53 Housing Choice Voucher Program

schemes, most reported between 2 to 5 cases in their local area of 

jurisdiction from spring 2016 through spring 2017. Our other sources of 

evidence were consistent with our survey results. For example, we 

interviewed officials with two PHA associations—representing 

approximately 1,900 total PHAs—about fraud against HCV participants 

(other than side payments). The associations reported that they were 

unaware of widespread instances of these types of fraud against 

participants.

Figure 3: Estimated Percentage of PHAs with Awareness of Incidents of Fraud in Their Jurisdiction between Spring 2016 and 

Spring 2017, by Fraud Types

PHAs were much more likely to report awareness of incidents of side 

payments than the other types of fraud included in our survey, according 

to our analysis of survey responses. As noted above, side-payment fraud 

involves agreements—mutual or compelled—in which the voucher holder 

pays additional rent or other payments to the landlord in return for 

benefits, to secure a rental, or to avoid eviction. On the basis of survey 

responses, we estimate that 41 percent of all PHAs with 1,000 or more 
Page 13 GAO-18-53 Housing Choice Voucher Program

vouchers were aware of incidents of side payments in the prior year, as 

shown in figure 3 above.8 Of PHAs reporting side payments, we estimate 

that the vast majority (93 percent) were aware of 1 to 10 instances of side 

payments in the prior year (spring 2016–spring 2017), with most reporting 

between 2 and 5 incidents in the past year. Further, we estimate that 7 

percent were aware of 11 or more instances in the prior year.9

Officials from all eight PHAs we interviewed similarly told us that they 

were aware of side payments, but some said that participants rarely 

report cases of side payments to them.10 Because violation of HVC rules 

could result in termination of a lease or loss of voucher for the recipient, it 

is possible that side payments are not always reported to PHAs. Two 

experts providing legal services to low-income individuals said that, in 

regard to fraud affecting HCV participants, landlord requests for side 

payments is relatively more common than other types of fraud. In 

addition, a current voucher holder told us about personal experiences 

involving requests for such payments by landlords, but also said that he 

or she had not experienced any other types of fraud.

In response to our open-ended survey question on other fraud not 

specifically mentioned in the survey, three PHAs in two regions reported 

variations of a type of fraud that intends to convince landlords that they 

are not in compliance with HCV rules, and that they must make a 

payment over the phone. Although this type of fraud was not included 

explicitly in our survey and is therefore not included in figure 3 above, in 

survey comments one West Coast PHA and two PHAs in the Southeast 

reported instances of this type of fraud. In open-ended survey comments, 

a West Coast PHA reported being aware of two attempts of similar fraud, 

in which fraudsters called landlords and asked them to make a credit-card 

payment over the phone to maintain program compliance. Similarly, two 

southeastern PHAs also reported being aware of instances of similar 

fraud schemes in the last year, although neither provided the number of 

cases reported to them. Furthermore, another West Coast PHA that was 

not included in our survey issued an online alert about scammers calling 

 8

The 95 percent confidence interval for this estimate is (37, 46).

9

The 95 percent confidence interval for the percentage of PHAs reporting 1 to 10 

instances is (86, 97), while the 95 percent confidence interval for the percentage of PHAs 

reporting 11 or more instances is (3, 14).

10Some of the PHAs we interviewed also participated in our survey, so survey results and 

interview responses are not cumulative.
Page 14 GAO-18-53 Housing Choice Voucher Program

landlords, masking their actual phone number with the PHA’s phone 

number, and stating that in order for the landlord to maintain program 

compliance, the landlord must make a credit-card payment over the 

phone to purchase a program manual. In an interview, officials from this 

PHA reported being aware of 36 attempts of this fraud type against 

landlords from September 2015 to April 2017.

According to PHA officials, fraud schemes generally have not targeted 

older-adult HCV participants. In survey responses, a limited number of 

PHAs reported fraud against older adults. For example, we estimate that 

of PHAs reporting awareness of side-payment schemes, very few PHAs 

(about 8 percent) were aware of instances in which landlords targeted 

older adults in side-payment requests.11 Moreover, an official from one 

PHA we interviewed stated that because older adults are likely to have 

advocates helping them to find housing, they are less likely than other 

HCV participants to be victims of fraud. Similarly, one expert providing 

legal services to older adults in the HCV program indicated that projectbased participants—who rent units only in specific buildings—are more 

likely than HCV participants to be targets of in-person fraud because they 

are located in identifiable properties.

Several PHAs issued fraud alerts about schemes against participants, but 

officials at PHAs we interviewed about some of the alerts told us that 

incidents of these fraud types were limited.12 Specifically:

• A Midwestern PHA issued an alert about an individual promising a 

voucher for a fee and meeting victims in person to receive payment. 

In a follow-up interview, PHA officials stated that, in total, they 

received five to seven reports about this fraud. Each of these cases 

occurred while the PHA’s waiting list was open in 2015. A nearby PHA 

also reported that when its waiting list was open in 2011, an individual 

with fake PHA credentials fraudulently took payment from individuals 

and promised to move them to the top of the waiting list. The PHA 

was aware of 10 individuals who were victims of the fraud, and 

estimated that they each paid about $200 to the perpetrator.

• A West Coast PHA issued an alert about a website charging 

applicants to submit a program application. However, in an interview 

 11The 95 percent confidence interval for this estimate is (4, 15).

12We visited the websites of 60 PHAs; 20 posted online fraud alerts about various fraud 

types that could affect HCV program participants.
Page 15 GAO-18-53 Housing Choice Voucher Program

the PHA reported awareness of only one case over the last 3 years of 

fraud committed by outside parties against voucher participants.13

Although instances of fraud against HCV participants reported to PHAs 

appear relatively rare, participants who provide personal information to 

unknown individuals are still at risk for identity theft, according to some 

experts we interviewed. Two identity-theft experts stated that credit-card 

fraud is likely if individuals enter payment information in unverified sites. 

Furthermore, one expert stated that low-income individuals can be targets 

for identity theft because fraudsters can use stolen identities with low 

credit scores to obtain high-interest loans that they do not intend to pay 

off.

In covert testing using undercover tools and techniques, we found no 

indicators of fraud in rental advertisements posted online, and few 

indicators of fraud in commercial websites offering information to 

participants about the HCV program.

Through our online covert testing, we found no indicators of potential 

fraud in 350 advertisements—selected using a random-selection

methodology—posted in online marketplaces across six cities.14 On the 

basis of an academic study of online fraud schemes on rental 

marketplaces and information provided by PHAs, we developed a list of 

indicators of potential fraud.15 These indicators include requests for a wire 

transfer of security deposit or first month rent without offering to provide 

an in-person viewing of the property, or requesting an up-front or monthly 

side-payment agreement as a condition of rental. In searches of one 

rental website, we came across a small number of advertisements that 

initially appeared to contain an indicator of potential fraud—specifically, 

links to a website for specialized realtor services; covert testing of that link 

did not find further indicators of potential fraud.

None of the 26 commercial websites we covertly tested contained text 

explicitly stating that they would place or move someone up a waiting list 

 13All three PHAs discussed here were survey participants and may have included these 

fraud incidents in their responses. Therefore, survey results and interview responses are 

not cumulative.

14For more about our advertisement search methodology, see app. I.

15Youngsam Park, Damon McCoy, and Elaine Shi, “Understanding Craigslist Rental 

Scams,” International Conference on Financial Cryptography and Data Security (2016): 3–

21.

Few Indicators of Potential 

Fraud Found in Online 

Covert Testing
Page 16 GAO-18-53 Housing Choice Voucher Program

for a fee. Further, in e-mail correspondence with every website, we asked 

whether they could help place us on a waiting list. Some website 

operators never replied and some stated they could not do so, with none 

agreeing to place us on a list. However, some websites used HUD’s 

Equal Housing Opportunity logo, which might make them appear to be 

associated with official government programs, while others requested 

payment for suspect services and products. For example:

• One PHA fraud alert specifically named one of the websites we tested 

covertly, and indicated that the website fraudulently offered to submit 

an application for the HCV program for a onetime registration fee. Our 

covert testing found that this website displayed HUD’s Equal Housing 

Opportunity logo, and charges a fee for a “guide” about the voucher 

program, but at the time of our testing the website did not offer to 

submit an application for a fee. Payment to the website resulted in 

access to a guide and online forum containing a list of open PHA 

waiting lists for the HCV program and links to publicly available PHA 

websites.

• One website we covertly tested requested payment for an e-book 

guide to assist with the HCV application process. We made payment 

but never received the e-book.

• One website subject to covert testing stated that landlords in the HCV 

program may deny or refuse to rent to a potential tenant based on his 

or her credit-report information, and referred us to a suspect website 

offering credit reports. The website claimed to offer a “free credit 

report” and requested personal information including a Social Security 

number and credit-card number. As part of our covert testing, we 

provided a credit-card number. We also entered all zeroes as a Social 

Security number on the site, prompting the site to state that it could 

not provide us with a credit report, as we had not provided a valid 

Social Security number. Despite that fact, the site charged our credit 

card a recurring payment. In a phone call, a representative of the 

website stated that, in the terms-of-use for the website, users are 

informed that they must explicitly request that recurring payments be 

terminated or that those payments would continue.
Page 17 GAO-18-53 Housing Choice Voucher Program

HUD regulations and guidance and PHA informational materials pertinent 

to fraud primarily focus on protecting the HCV program rather than 

protecting participants from fraud committed by external parties.16 For 

example, where the regulations mention fraud explicitly, it is generally in 

relation to mitigating program violations by owners and voucher program 

participants, recovering program losses from fraud, and assessing 

participants, applicants, and owners for participation or continued 

participation in the program.

Apart from requiring that PHAs inform participants about a prohibition 

against side payments to landlords (a program rule violation), HUD’s 

antifraud guidance, as outlined in the Housing Choice Voucher Program 

Guidebook, generally focuses on preventing fraud against the program, 

as opposed to fraud against participants. For example, an applicant 

misrepresenting income and assets to obtain an HCV voucher and a 

landlord bribing a PHA employee to approve substandard rental housing 

are types of program fraud. See figure 4 for examples of HCV programrelated fraud listed in the guidebook.

 16The implementing regulations for the HCV program are contained in Title 24 of the U.S. 

Code of Federal Regulations (CFR). Part 982 contains program requirements for the HCV 

housing-assistance program under Section 8 of the United States Housing Act of 1937. 

HUD and PHA 

Antifraud Efforts 

Focus Mainly on 

Fraud against the 

HCV Program; Some 

PHAs Voluntarily 

Provide Information 

about Fraud against 

Participants
Page 18 GAO-18-53 Housing Choice Voucher Program

Figure 4: Examples of HCV Program-Related Fraud Listed in the Housing Choice Voucher Program Guidebook

Education and outreach requirements for PHAs specified in the HCV 

guidebook largely focus on providing adequate public notice of waiting-list 

openings; an oral briefing when the PHA selects a family to participate in 

the program; and a written briefing packet for participants, which must 

include a variety of subjects related to program administration, leasing a 

unit, and family obligations. Consistent with the guidebook, written or 

online briefing materials from the eight PHAs we interviewed mention 

various types of program violations. All but one specifically state that sidepayment agreements between landlords and tenants are prohibited, 

which, as discussed above, can be viewed as both fraud affecting the 

participant and against the program. HUD directs PHAs to inform 

participants that landlord–participant side payments are prohibited.

HUD provides guidance on how a PHA should handle a situation in which 

the landlord is collecting side payments. If the PHA finds that the landlord 

is collecting side payments, the PHA must notify the landlord to 

immediately cease collecting these payments and require repayment to 

the tenant of the full amount collected. The PHA must determine whether 

the landlord also collected side payments from other participants and 
Page 19 GAO-18-53 Housing Choice Voucher Program

follow up to require repayment. The amount can be repaid by offsetting 

the amount due against future housing-assistance payments. At its 

discretion, the PHA may terminate the housing-assistance payments 

contract with the landlord immediately, even if the landlord has repaid 

amounts due the tenant, but the PHA must cancel the contract if the 

landlord fails to repay.

Although not required, several PHAs we visited or contacted voluntarily 

provided informational materials to program participants that included 

targeted messages and alerts notifying them of certain housingassistance fraud by outside parties, such as voucher-sale fraud, or fraud 

involving being placed on or moved up a waiting list. For example, in 

program briefing documents given to participants,

• a northeastern PHA warns participants of housing-assistance scams, 

and specifically advises participants not to pay to, among other things, 

(1) be placed on or be moved up a waiting list or (2) receive an HCV 

voucher or voucher extension;

• a different northeastern PHA advises HCV participants not to give 

their voucher to anyone, including the apartment owner, agent, or 

property manager; and not to give any money to the apartment 

broker, owner, or agent until the PHA approves the selected 

apartment; and

• a West Coast PHA advises HCV applicants and participants to be 

aware of fraud, particularly schemes that require a payment to file an 

application or to move up a waiting list.

In addition, PHAs share best practices that could include these and other 

issues. For example, two industry associations representing 

approximately 1,900 PHAs provide mechanisms for PHAs to share 

information and best practices about HCV administration and issues 

affecting HCV program participants and their communities. Both regularly 

hold conferences, meetings, and other events that provide a venue for 

members to discuss relevant issues. In addition, one of these 

associations has published reports on issues affecting older adults and 

connecting housing and community services, among other issues, while 

the other published a report on issues related to rental reform proposals.
Page 20 GAO-18-53 Housing Choice Voucher Program

We provided a draft of this report for review and comment to HUD, FTC, 

the Consumer Financial Protection Bureau, the Department of Health and 

Human Services, and the U.S. Postal Service. We received e-mails from 

HUD, the Consumer Financial Protection Bureau, and the Department of 

Health and Human Services in which liaisons to GAO for those agencies 

stated they had no comments on the report. We received technical 

comments from FTC and the U.S. Postal Service, which we incorporated 

in the report as appropriate. 

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Housing and Urban Development, the 

Federal Trade Commission, the Director of the Consumer Financial 

Protection Bureau, the Secretary of Health and Human Services, and the 

Postmaster General of the U.S. Postal Service. In addition, the report is 

available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-6722 or shear@gao.gov. Contact points for our

Offices of Congressional Relations 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 III.

Rebecca Shea, Director

Forensic Audits and Investigative Service

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 21 GAO-18-53 Housing Choice Voucher Program

In this report, we describe (1) the types of reported fraud schemes 

committed against Housing Choice Voucher (HCV) participants (including 

older adults), awareness by Public Housing Agencies (PHA) and other 

relevant organizations of fraud incidents and how often they occur, and 

indicators of such schemes online; and (2) antifraud regulations, 

guidance, and informational materials, if any, that the Department of 

Housing and Urban Development (HUD) and PHAs have in place to 

identify and mitigate fraud against program participants.

To address our first objective we used a variety of methods (see fig. 5). 

Details on our use of these methodologies are described below.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 22 GAO-18-53 Housing Choice Voucher Program

Figure 5: Key Methodologies Used to Identify Types of Reported Fraud, Fraud Awareness, and Indicators of Online Fraud
Appendix I: Objectives, Scope, and 

Methodology

Page 23 GAO-18-53 Housing Choice Voucher Program

Some PHAs issue online alerts and post these on their websites to inform 

HCV applicants and participants about potential fraud schemes. We 

initially identified PHA fraud alerts by performing online searches about 

fraud in the HCV program. We then developed a structured search 

method for identifying additional fraud alerts. To do this, in 2016 and 

2017, we searched fraud alerts issued by a nongeneralizable sample of 

60 PHAs; in total, 20 PHAs published 22 alerts about fraud affecting HCV 

applicants and participants on their websites.

We identified our nongeneralizable sample of 60 PHAs using 2015 fourthquarter Picture of Subsidized Households data from HUD, which contain 

information on subsidized housing units by several types of programs 

including the HCV program. The initial population contained PHAs 

ordered by total number of HCV program vouchers available. We 

selected our sample of PHAs based on those with the most vouchers.

We reviewed consumer complaint data from the Federal Trade 

Commission’s (FTC) Consumer Sentinel database from calendar years 

2011 through 2016. The date range of the data represents the mostrecent years available at the time of our request. Our review of the data 

focused on complaints related to the HCV program and companies that 

offer rental housing services. We assessed the reliability of the data by 

interviewing officials and reviewing related documentation and found the 

data sufficiently reliable for the purposes of our reporting objectives.

We developed several categories for reviewing complaints based on 

criteria on fraud schemes affecting HCV program applicants and 

participants. To develop an initial list of categories, we selected a 

subsample of the first entries in the data and independently created 

categories that could be used to categorize the complaints in the 

subsample. On the basis of this methodology, we identified a set of 

defined coding categories, which were as follows:

1. HCV-specific fraud,

2. housing-related fraud (HCV not mentioned),

3. housing-related fraud involving the purchase of foreclosed property,

First Objective

Types of Reported Fraud

Fraud Alerts

Consumer Complaint Data
Appendix I: Objectives, Scope, and 

Methodology

Page 24 GAO-18-53 Housing Choice Voucher Program

4. housing-related credit-report fraud,

5. housing-related fraud requesting electronic wire transfer of funds,

6. HCV-specific complaints where fraud is not mentioned or the nature of 

fraud is unclear,

7. housing-related complaints where fraud is not mentioned or the nature 

of fraud is unclear, and

8. complaints not related to the scope of the engagement.

We also separately coded whether the subject matter of each complaint 

specifically affected an older adult.

We applied a two-person data-coding process to ensure 

intercategorization reliability. FTC delivered the data to us in batches 

organized along search terms we provided. For several of the initial 

batches we received, as a first step in the coding process, a coder 

categorized each complaint into one of the categories above, and 

simultaneously identified any complaints that contained relevant housingrelated or HCV-related fraud types that we had not already discovered. 

As a second step, a reviewer assessed a nonrandomized sample of the 

data to determine whether coding was correct, and whether the coder had 

identified any previously unknown fraud types in the batch. We repeated 

this process for three of the five batches that we received, and reviewed 

over 600 total complaints. Upon finding no new fraud types in the coded 

data, we ceased analysis and did not code the remaining two batches we 

received, which we deemed to contain complaint categories unlikely to 

reveal new types of fraud.

We also interviewed PHA officials from eight PHAs (selected using a 

methodology discussed below). Additionally, we reviewed an academic 

study describing fraud against prospective renters in online marketplaces, 

which allowed us to identify several fraud types that could be used 

against HCV participants searching for rental units. The study used 

crawling and automated interaction to identify fraud types.1 We 

interviewed an author of the study to clarify research techniques. We 

assessed that the individual was sufficiently independent. Our 

 1

Youngsam Park, Damon McCoy, and Elaine Shi, “Understanding Craigslist Rental 

Scams,” International Conference on Financial Cryptography and Data Security (2016): 

3–21. Crawling is the automatic process of systematically traversing a group of webpages 

by following their embedded electronic links in order to build an index of relevant 

information.
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-18-53 Housing Choice Voucher Program

methodological specialist assessed the study, and found its conclusions 

to be sufficiently valid and reliable for our purposes.

We conducted a web-based survey with a nationally representative 

stratified random sample of executive directors overseeing PHAs. In the 

survey, we asked PHA executive directors and their staffs to provide 

information on known fraudulent activities by fraudsters or impersonators, 

fraudulent activities by landlords and building inspectors, and any other 

information on fraudulent activities adversely affecting HCV program 

applicants and participants from spring 2016 through spring 2017. We 

administered our survey from April to May 2017. Estimated percentages 

of the responses for all closed-ended questions from the survey are 

included in appendix II.

We identified the population of PHA executive directors using 2015 

fourth-quarter Picture of Subsidized Households data from HUD, which 

contain information on subsidized housing units by several types of 

programs including the HCV program. The Picture of Subsidized 

Households data also contain the percentage of households using these 

programs by factors such as age, income, and disability. We assessed 

the reliability of the data for use as our sampling frame by reviewing 

technical documentation, conducting electronic testing, and interviewing 

officials who oversee the data system; we found the data sufficiently 

reliable for our purposes.

Our initial population list contained a total of 2,243 PHA executive 

directors, and our sample contained 278 PHA executive directors. We 

stratified the population by size of PHAs as follows: We drew (1) a 

certainty sample of 83 executive directors who oversaw at least one PHA 

with 5,000+ vouchers (“large” PHAs) and (2) a probability sample of 195 

executive directors who oversaw at least one PHA with 1,000–4,999 

Awareness of Fraud 

Incidents

Survey
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-18-53 Housing Choice Voucher Program

vouchers (“medium” PHAs).2 For purposes of discussion, we refer to the 

experiences of PHAs in our analysis, although our sampling unit was the 

executive directors of the PHAs.3

To formulate our survey questionnaire on the types of fraud potentially 

adversely affecting HCV program applicants and participants, we 

conducted research on the topic of fraud by interviewing PHA officials, 

reviewing fraud alerts publicly posted on the Internet by large PHAs, and 

reviewing consumer complaint data. On the basis of the results of our 

research, we developed our survey questionnaire to include questions on 

external fraud such as (1) fraudsters or impersonators promising 

placement on a voucher waiting list, (2) fraud offering higher placement 

on voucher waiting lists, (3) fraud offering fake vouchers, (4) fraud 

offering suspect credit-report services, (5) landlords requiring prohibited 

side payments, (6) illegal solicitation of favors by landlords and building 

inspectors, and (7) illegal solicitation of rental-unit security deposits by 

landlords. We pretested our survey instrument with four PHAs located in 

Maryland, Michigan, Ohio, and Virginia. We revised our questionnaire 

language and format based on input received by officials in these four 

PHAs in order to improve the clarity of the questions. An independent 

survey specialist within GAO also reviewed a draft of the questionnaire 

prior to its administration; it is available in appendix II.

We administered a web-based questionnaire accessible through a secure 

server. When we completed the final survey questions and format, we 

sent an e-mail announcement of the survey to 278 PHAs in April 2017. 

The PHA points of contact were notified that the questionnaire was 

available online and were given unique passwords and usernames. We 

sent follow-up e-mail messages twice in May 2017 to those who had not 

yet responded. We contacted remaining nonrespondents by telephone, 

beginning in May 2017. The questionnaire was available online until midMay 2017.

 2

We used professional judgement and HUD’s PHA size labels to devise the PHA size 

categories used in our report. HUD uses several different size categorizations when 

presenting data on PHAs. On the basis of our analysis of the distribution of number of 

vouchers per PHA, we classified PHAs into one of three size categories—large, medium, 

and small—to optimize sampling among PHAs with 1,000 vouchers or more. We excluded 

PHAs with fewer than 1,000 vouchers because 98 percent of missing data was 

attributable to these PHAs.

3

An executive director may oversee more than one PHA. Two executive directors who 

were in scope for our sample oversaw another large- or medium-sized PHA.
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-18-53 Housing Choice Voucher Program

We obtained a weighted overall response rate of 84 percent, and the 

response rate by stratum was 86 percent for our first stratum (“large” 

PHAs) and 83 percent for our second stratum (“medium” PHAs). Because 

we followed a probability procedure on random selections, our sample is 

only one of a large number of samples that we might have drawn. Since 

each sample could have provided different estimates, we express our 

confidence in the precision of our particular sample’s results as a 95 

percent confidence interval (e.g., plus or minus 10 percentage points). 

This interval would contain the actual population value for 95 percent of 

the samples we could have drawn. Confidence intervals are provided 

along with each sample estimate in the report. All survey estimates 

presented in this report are generalizable to the population of large and 

medium PHAs, or to either the population of large PHAs or medium PHAs 

analyzed separately. Unless otherwise noted, estimates for the full 

population of large and medium PHAs have a margin of error for a 95 

percent confidence interval within +/-4.5 percentage points or less. Unless 

otherwise noted, estimates for the medium PHAs analyzed separately 

have a maximum margin of error for a 95 percent confidence interval of 

+/-5.4 percentage points or less. Unless otherwise noted, estimates for 

the large PHAs analyzed separately have a maximum margin of error for 

a 95 percent confidence interval of +/-4.5 percentage points or less. 

Some questions had too few respondents to generate reliable estimates. 

In these cases, we report the raw frequencies of respondents to our 

survey.

To minimize nonsampling errors, and to enhance data quality, we 

employed recognized survey design practices in the development of our 

survey questionnaire and in the collection, processing, and analysis of the 

survey data. To minimize errors arising from differences in how survey 

questions might be interpreted and to reduce variability in responses that 

should be qualitatively the same, we conducted pretesting of our survey 

questionnaire; see discussion on pretesting above. To reduce 

nonresponse, a source of nonsampling error, as mentioned above we 

followed up by e-mail and by telephone with PHAs who had not 

responded to the survey to encourage them to complete it.

To analyze open-ended comments provided by those responding to the 

survey, we conducted a content analysis for the purpose of identifying 

fraudulent activities against HCV program participants not addressed in 

our survey questionnaire. We analyzed open-ended responses to identify 

fraud types not directly addressed in our survey. We identified two 

additional types of fraud. One type of fraud involved fraudsters posing as 

PHA officials, calling landlords to convince them to make unnecessary 
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-18-53 Housing Choice Voucher Program

payments. This type of fraud against landlords is discussed in the report. 

The other type of fraud identified was not related to participation in the 

HCV program, and so is not discussed in the report.

As part of our site visits, we interviewed officials from eight PHAs located 

in three U.S. regions. On the East Coast, we interviewed officials with the 

New York City Department of Housing Preservation and Development, 

the New York City Housing Authority, and New York State Homes and 

Community Renewal. In the Midwest, we interviewed officials with the 

Cuyahoga Metropolitan Housing Authority, the Detroit Housing 

Commission, and the Flint Housing Commission. On the West Coast, we 

interviewed officials with the Housing Authority of the County of San 

Bernardino and the Housing Authority of the City of Los Angeles. We 

identified our interviewee selection on the basis of ensuring geographical 

representation, budgetary considerations, metropolitan cities with a large 

population, PHAs’ issuance of fraud alerts, PHA size—large, medium, 

and small, PHA in states with a large number of older adults, and 

consideration for overlap of other GAO ongoing work in the area of the 

HCV program. Our sample of PHA interviewees is nongeneralizable. 

Moreover, we interviewed an HCV voucher holder about the voucher 

holder’s knowledge of fraud against participants.

We also interviewed government and nongovernment officials and others 

based on their knowledge and expertise on the topic of fraud in general; 

fraud education campaigns; fraud adversely affecting HCV program 

applicants and participants; fraud affecting older adults; or identity theft. 

Specifically in reference to government agencies, we interviewed officials 

from the U.S. Federal Trade Commission (FTC), the Consumer Financial 

Protection Bureau, the U.S. Postal Inspection Service, and the 

Department of Health and Human Services about fraud types and about 

practices used by federal agencies to inform the public about fraudrelated issues. We also interviewed officials from the HUD Office of 

Inspector General (OIG) about any past or ongoing work related to the 

scope of our reporting objectives.4 For our interviewee selection, we 

considered recommendations from other organizations such as PHAs and 

legal-assistance organizations and reviewed prior GAO work on the issue 

 4

According to an official at HUD OIG, it had no ongoing or past work related to fraud 

against HCV participants by outside parties. Moreover, a search of published OIG reports 

produced no reports on the subject of landlord–tenant side payments.

Interviews of Government 

Officials, Nongovernment 

Officials, and Others
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-18-53 Housing Choice Voucher Program

of older-adult financial exploitation.5 We also considered organizations’ 

characteristics in terms of fraud prevention or work performed in assisting 

potential fraud victims. These characteristics include whether the 

organization

• has an investigative unit that may have data on fraud schemes,

• posts fraud alerts on its Internet websites,

• has data on fraud cases,

• collaborates with other groups on fraud awareness,

• has a fraud or complaint hotline,

• works on fraud prevention and provides support to victims of fraud, or

• works with vulnerable populations including low-income individuals or 

the older-adult population on social or legal issues.

On the basis of an academic study about fraud in online rental 

marketplaces (discussed above) and PHA-provided information, we 

developed a list of indicators of potential fraud that might appear in online 

advertisements. We used covert tools and techniques to test a 

nongeneralizable sample of advertisements posted on commercial 

websites commonly used by HCV voucher holders and landlords for 

rental property listings, counting advertisements as potentially fraudulent 

if the originator of the advertisement did any of the following:

• Requested a wire transfer of security deposit or first month’s rent, or 

both, without offering to provide an in-person viewing of the property. 

For example, the person who posted the advertisement might state 

that the rental is available, but that the person is currently not in the 

country.

• Provided a link to a suspect credit-report site within the advertisement 

or subsequent correspondence. While requiring a credit report is a 

normal part of the rental process, fraudsters may post a fake rental 

advertisement and redirect victims to a credit-score company. If the 

 5

See GAO, Elder Justice: National Strategy Needed to Effectively Combat Elder Financial 

Exploitation, GAO-13-110 (Washington, D.C.: Nov. 15, 2012).

Indications of Potential 

Fraud Online

Covert Testing
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-18-53 Housing Choice Voucher Program

victim pays for the credit score, the credit-score company will pay the 

fraudster a commission.

• Stated in correspondence that the rental unit is no longer available, 

but recommended a suspect site providing rental search, broker 

services, or monthly payments toward purchase of a foreclosed 

property.

• Requested an up-front or monthly side-payment agreement as a 

condition of rental.

• Included an e-mail address directly in the text of the ad. According to 

one academic expert on fraud, it was rare to see a legitimate 

advertisement poster embed an e-mail address in a post, because 

most people do not want to expose that information on the Internet.

Advertisements or correspondence containing an indicator of fraud do not 

necessarily reveal the presence of a fraud scheme. For example, the 

presence of an e-mail address directly in the text of an advertisement 

may also indicate that the advertisement was posted by a realtor service.

We selected 6 geographically diverse cities nationwide for covert testing 

of online rental advertisements. To generate a list of cities for possible 

selection, we identified cities containing the 20 PHAs with the largest 

number of HCV vouchers.6 We identified one commonly used online 

housing-rental marketplace for the general public and another online 

rental marketplace specifically dedicated to HCV rentals. We then 

determined the total number of advertisements available across the two 

rental websites in those cities. We used the following criteria to select 

cities for covert testing:

• From the 20 cities described above, we selected 3 cities with the most 

available advertisements across the two online rental marketplaces.

• From the 20 cities described above, we selected 2 cities where a 

nearby PHA had closed its HCV waiting lists in the last half of 2016.

• Outside of the 20 cities described above, we also selected 1 city with 

a large number of available advertisements where we had previously 

completed a site visit.

In each metropolitan area selected for covert testing, we identified 

relevant online rental marketplaces operating in the area. We then used a 

 6

Some cities contained more than one such PHA. The number of vouchers for each PHA 

was as of the last quarter of 2015.
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-18-53 Housing Choice Voucher Program

random-selection methodology to identify advertisements for testing from 

amongst all current advertisements on each marketplace. In total, we 

responded to 350 advertisements. On sites specifically dedicated to HCV 

rentals, we generally sampled from among all current ads. On sites 

featuring a mix of private rental ads, we developed a list of search 

keywords and sampled only among ads that explicitly stated that they 

would accept an HCV voucher. By e-mail, we contacted the originator of 

each of the 350 advertisements we covertly tested and engaged in 

correspondence.

To determine the extent of detected potential fraud in online sites, we 

covertly tested websites identified as offering information or assistance 

with the HCV program; note that this methodology is distinct from that 

described above to covertly test advertisements. To discover sites for 

investigation, we performed web searches with a variety of relevant 

search terms using two popular search engines. We clicked through the 

first few pages of each set of search results, and collected the names of 

commercial sites that appeared either within search results or in ads 

accompanying the results. Finally, we entered the address of each of the 

websites we found into a separate search portal. This search portal 

suggests possible competitor and similar websites for the target website; 

we added websites discovered through this method to our list of websites 

for investigation. In total, we tested 26 websites. If the website requested 

a payment of any kind, we made the payment. We also corresponded 

with each website, asking explicitly whether it could place us on an HCV 

waiting list.

To address our objective regarding antifraud regulations, guidance, and 

informational material, if any, that HUD and PHAs have in place to identify 

and mitigate potential fraud against program participants, we reviewed 

HUD regulations on the HCV Program and the Section 8 Management 

Assessment Program. These regulations outline the requirements for 

PHAs to perform education and outreach on the HCV program. We also 

reviewed HUD’s HCV Program Guidebook. This guidebook provides 

direction to PHAs administering the HCV Program on informing applicants 

about program-related fraud.

We also reviewed written or online briefing materials for participants 

developed by the eight PHAs we interviewed. These briefing materials 

must include a variety of subjects, related to program administration, 

leasing a unit, and family obligations.

Second Objective
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-18-53 Housing Choice Voucher Program

We conducted this performance audit from May 2016 to December 2017 

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. We conducted our related 

investigative work from January 2017 to July 2017 in accordance with 

investigative standards prescribed by the Council of the Inspectors 

General on Integrity and Efficiency.
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 33 GAO-18-53 Housing Choice Voucher Program

To determine awareness of incidents of fraud schemes among PHAs, we 

conducted a web-based survey to a nationally representative sample of 

executive directors overseeing Public Housing Agencies (PHA) from April 

2017 to May 2017. We solicited input on executive directors’ familiarity 

with and awareness of fraud schemes against U.S. Housing and Urban 

Development (HUD) Housing Choice Voucher (HCV) Program applicants 

and participants. We distributed the survey to 278 PHAs, of which 233 (84 

percent) responded. We stratified the population by size of PHA as 

follows: (1) a certainty sample of 83 executive directors who oversaw at 

least one PHA with 5,000+ vouchers (“large” PHAs); and (2) a probability 

sample of 195 executive directors who oversaw at least one PHA with 

1,000–4,999 vouchers (“medium” PHAs). Results of our survey are 

generalizable to the entire population of large and medium PHAs. For a 

more-detailed discussion of our survey methodology, see appendix I.

The results of our survey provide the input of PHA executive directors and 

their staffs at the time they completed the survey in April and May 2017. 

The questions we asked in our survey are presented below. Our survey 

comprises seven top-level, fixed-choice questions; three subquestions for 

each “yes” response to top-level questions; and one open-ended 

question. In this appendix, we include all survey questions, and the 

estimated percentages for the responses to the top-level questions. 

Because of the limited number of respondents answering “yes” to the toplevel survey questions, we could not generate reliable estimates for the 

survey subquestions; therefore we present only raw frequency counts for 

all subquestions except those corresponding to survey question 5 where 

we present both estimated percentages and raw frequency counts for 

those responses.

In our survey open-ended question, we asked PHA executive directors to 

provide information on fraudulent activities affecting HCV program 

participants other than those covered by the seven fixed-choice 

questions. This element was our attempt at identifying fraud types not 

directly addressed in our survey. While we are not providing the 

responses to the open-ended question, our analysis of those responses 

identified two additional types of fraud. One type of fraud involved 

fraudsters posing as PHA officials, calling landlords to convince them to 

make unnecessary payments. The other type of fraud identified was not 

related to participation in the HCV program, and so is not discussed in the 

report.

Appendix II: Results of GAO’s Survey of 

Public Housing Agencies
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 34 GAO-18-53 Housing Choice Voucher Program

Table 1: Estimated Percentage of PHAs Aware of Fraud Type—Survey Question 1

In the past year, is your PHA aware of scam artists or impersonators promising a place on a waitlist in exchange for payment from your 

PHA program applicants who are currently not on a waitlist? (Question 1)

Analysis group Response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence 

interval—upper bound 

(percent)

Full population Yes 9.5 6.1 14.0

No 90.5 86.0 93.9

Medium Public Housing 

Agencies (PHA)

Yes 7.4 3.9 12.6

No 92.6 87.4 96.1

Large PHAs Yes 19.7 16.4 23.5

No 80.3 76.5 83.6

Source: GAO. | GAO-18-53

Note: Overall estimates are generalizable to all PHAs and to PHAs by size.

Tables 2–5 below present results for PHAs that responded “yes” to 

question 1. Because of the limited number of respondents answering 

“yes” to question 1, we could not generate reliable estimates for question 

1 subquestions, and present raw frequency counts only.

Table 2: Reported Incidents of Fraud Type (Raw Counts)—Survey Question 1

About how many incidents like this is your PHA aware of in the past year? Please only include incidents that occurred in your PHA. 

(Question 1A)

Analysis group 1 incident 2–5 incidents 6–10 incidents

11 or more 

incidents

Frequency 

missing

Full population 3 14 5 2 2

Medium PHA 1 6 3 0

Large PHA 2 8 2 2

Source: GAO. | GAO-18-53

Fraudulent Activities 

by Fraudsters or 

Impersonators

Survey Question 1 

Responses
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 35 GAO-18-53 Housing Choice Voucher Program

Table 3: Methods by Which PHAs Became Aware of Fraud Type (Raw Counts)—Survey Question 1

How did your PHA become aware of these incidents? (Question 1B)

Analysis group Response

The victim, or 

target of the fraud, 

informed us

PHA staff witnessed 

or came across 

fraudulent activity

Someone other 

than the victim or 

PHA staff

Some other 

way

Full population Checked 22 5 5 5

Not checked 4 21 21 21

Medium PHA Checked 10 2 1 2

Not checked 2 10 11 10

Large PHA Checked 12 3 4 3

Not checked 2 11 10 11

Source: GAO. | GAO-18-53

Note: Respondents could select more than one response option.

Table 4: PHAs Reporting That Older Adults Were Targeted in Fraud Incidents (Raw Counts)—Survey Question 1

Were elderly program participants targeted by scam artists or impersonators in these incidents? (Question 1C)

Analysis group Yes No Unsure Not checked

Full population 4 7 14 1

Medium PHA 1 4 6 1

Large PHA 3 3 8 0

Source: GAO. | GAO-18-53
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 36 GAO-18-53 Housing Choice Voucher Program

Table 5: Estimated Percentage of PHAs Aware of Fraud Type—Survey Question 2

In the past year, is your PHA aware of scam artists or impersonators—promising to move your PHA program applicants higher on the 

waitlist—in exchange for payment? (Question 2)

Analysis group Response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence 

interval—upper bound 

(percent)

Full population Yes 2.5 0.9 5.4

No 97.5 94.6 99.1

Medium PHA Yes 1.9 0.4 5.3

No 98.1 94.7 99.6

Large PHA Yes 5.6 3.9 8.1

No 94.4 91.9 96.1

Source: GAO. | GAO-18-53

Note: Overall estimates are generalizable to all PHAs and to PHAs by size.

Tables 6–8 below present results for PHAs that responded “yes” to 

question 2. Because of the limited number of respondents answering 

“yes” to question 2, we could not generate reliable estimates for question 

2 subquestions, and present raw frequency counts only.

Table 6: Reported Incidents of Fraud Type (Raw Counts)—Survey Question 2

About how many incidents like this is your PHA aware of in the past year? Please only include incidents that occurred in your PHA. 

(Question 2A)

Analysis group 1 incident 2–5 incidents 6–10 incidents

11 or more 

incidents

Frequency 

missing

Full population 2 2 0 1 2

Medium PHA 1 1 0 0

Large PHA 1 1 0 1

Source: GAO. | GAO-18-53

Survey Question 2 

Responses
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 37 GAO-18-53 Housing Choice Voucher Program

Table 7: Methods by Which PHAs Became Aware of Fraud Type (Raw Counts)—Survey Question 2

How did your PHA become aware of these incidents? (Question 2B)

Analysis group Response

The victim, or 

target of the fraud, 

informed us

PHA staff witnessed 

or came across 

fraudulent activity

Someone other 

than the victim or 

PHA staff

Some other

way

Full population Checked 5 0 1 2

Not checked 2 7 6 5

Medium PHA Checked 2 0 0 0

Not checked 1 3 3 3

Large PHA Checked 3 0 1 2

Not checked 1 4 3 2

Source: GAO. | GAO-18-53

Note: Respondents could select more than one response option.

Table 8: PHAs Reporting That Older Adults Were Targeted in Fraud Incidents (Raw Counts)—Survey Question 2

Were elderly program participants targeted by scam artists or impersonators in these incidents? (Question 2C)

Analysis group Yes No Unsure Not checked

Full population 1 2 3 1

Medium PHA 1 1 0 1

Large PHA 0 1 3 0

Source: GAO. | GAO-18-53
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 38 GAO-18-53 Housing Choice Voucher Program

Table 9: Estimated Percentage of PHAs Aware of Fraud Type—Survey Question 3

In the past year, is your PHA aware of scam artists or impersonators providing a fake voucher to your PHA program applicants or 

participants in exchange for payment? (Question 3)

Analysis group Response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence 

interval—upper bound 

(percent)

Full population Yes 3.2 1.4 6.4

No 96.8 93.6 98.6

Medium PHA Yes 1.9 0.4 5.3

No 98.1 94.7 99.6

Large PHA Yes 9.9 7.5 12.9

No 90.1 87.1 92.5

Source: GAO. | GAO-18-53

Note: Overall estimates are generalizable to all PHAs and to PHAs by size.

Tables 10–12 below present results for PHAs that responded “yes” to 

question 3. Because of the limited number of respondents answering 

“yes” to question 3, we could not generate reliable estimates for question 

3 subquestions, and present raw frequency counts only.

Table 10: Reported Incidents of Fraud Type (Raw Counts)—Survey Question 3

In the past year, is your PHA aware of scam artists or impersonators providing a fake voucher to your PHA program applicants or 

participants in exchange for payment? (Question 3)

Analysis group 1 incident 2–5 incidents 6–10 incidents

11 or more 

incidents

Frequency 

missing

Full population 1 6 1 1 1

Medium PHA 0 2 0 0

Large PHA 1 4 1 1

Source: GAO. | GAO-18-53

Survey Question 3 

Responses
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 39 GAO-18-53 Housing Choice Voucher Program

Table 11: Methods by Which PHAs Became Aware of Fraud Type (Raw Counts)—Survey Question 3

How did your PHA become aware of these incidents? (Question 3B)

Analysis group Response

The victim, or 

target of the fraud, 

informed us

PHA staff witnessed 

or came across 

fraudulent activity

Someone other 

than the victim or 

PHA staff

Some other 

way

Full population Checked 7 3 2 1

Not checked 3 7 8 9

Medium PHA Checked 2 1 0 0

Not checked 1 2 3 3

Large PHA Checked 5 2 2 1

Not checked 2 5 5 6

Source: GAO. | GAO-18-53

Note: Respondents could select more than one response option.

Table 12: PHAs Reporting That Older Adults Were Targeted in Fraud Incidents (Raw Counts)—Survey Question 3

Were elderly program participants targeted by scam artists or impersonators in these incidents? (Question 3C)

Analysis group Yes No Unsure Not checked

Full population 2 5 2 1

Medium PHA 1 0 1 1

Large PHA 1 5 1 0

Source: GAO. | GAO-18-53
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 40 GAO-18-53 Housing Choice Voucher Program

Table 13: Estimated Percentage of PHAs Aware of Fraud Type—Survey Question 4

We know there are legitimate reasons for requiring payment to run a credit report. However, in the past year, is your PHA aware of 

scam artists or impersonators illegitimately requiring payment to run a credit report for your PHA program applicants and program 

participants? (Question 4)

Analysis group Response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence 

interval—upper bound 

(percent)

Full population Yes 2.5 0.9 5.5

No 97.5 94.5 99.1

Medium PHA Yes 2.5 0.7 6.2

No 97.5 93.8 99.3

Large PHA Yes 2.8 1.7 4.7

No 97.2 95.3 98.3

Source: GAO. | GAO-18-53

Note: Overall estimates are generalizable to all PHAs and to PHAs by size.

Tables 14–16 below present results for PHAs that responded “yes” to 

question 4. Because of the limited number of respondents answering 

“yes” to question 4, we could not generate reliable estimates for question 

4 subquestions, and present raw frequency counts only.

Table 14: Reported Incidents of Fraud Type (Raw Counts)—Survey Question 4

About how many incidents like this is your PHA aware of in the past year? Please only include incidents that occurred in your PHA. 

(Question 4A)

Analysis group 1 incident 2–5 incidents 6–10 incidents

11 or more 

incidents

Frequency 

missing

Full population 0 3 2 0 1

Medium PHA 0 1 2 0

Large PHA 0 2 0 0

Source: GAO. | GAO-18-53

Survey Question 4 

Responses
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 41 GAO-18-53 Housing Choice Voucher Program

Table 15: Methods by Which PHAs Became Aware of Fraud Type (Raw Counts)—Survey Question 4

How did your PHA become aware of these incidents? (Question 4B)

Analysis group Response

The victim, or 

target of the 

fraud, informed 

us

PHA staff witnessed 

or came across 

fraudulent activity

Someone other 

than the victim or 

PHA staff

Some other 

way

Full population Checked 4 0 0 1

Not checked 2 6 6 5

Medium PHA Checked 3 0 0 0

Not checked 1 4 4 4

Large PHA Checked 1 0 0 1

Not checked 1 2 2 1

Source: GAO. | GAO-18-53

Note: Respondents could select more than one response option.

Table 16: PHAs Reporting That Older Adults Were Targeted in Fraud Incidents (Raw Counts)—Survey Question 4

Were elderly program participants targeted by scam artists or impersonators in these incidents? (Question 4C)

Analysis group Yes No Unsure Not checked

Full population 1 2 2 1

Medium PHA 1 1 1 1

Large PHA 0 1 1 0

Source: GAO. | GAO-18-53
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 42 GAO-18-53 Housing Choice Voucher Program

Tables 17–23 below present results for PHAs that responded “yes” to 

question 5. Because of the number of respondents answering “yes” to 

question 5, we were able to generate reliable estimates for question 5 

subquestions and present both estimates and raw frequency counts.

Table 17: Estimated Percentage of PHAs Aware of Fraud Type—Survey Question 5

In the past year, is your PHA aware of landlords requiring side payments in addition to regular rent payments for your PHA program 

applicants and program participants? (Question 5)

Analysis group Response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence 

interval—upper bound 

(percent)

Full population Yes 41.4 37.0 45.9

No 58.6 54.1 63.0

Medium PHA Yes 37.7 32.3 43.0

No 62.3 57.0 67.7

Large PHA Yes 59.2 54.7 63.5

No 40.8 36.5 45.3

Source: GAO. | GAO-18-53

Note: Overall weighted estimates for question 5 are generalizable to all PHAs and to PHAs by size.

Table 18: Reported Incidents of Fraud Type (Weighted Estimates)—Survey Question 5

About how many incidents like this is your PHA aware of in the past year? Please only include incidents that occurred in your PHA. 

(Question 5A)

Full population response

Estimated 

percentage

95 percent confidence interval—

lower bound (percent)

95 percent confidence interval—

upper bound (percent)

1 incident 27.3 18.9 37.0

2–5 incidents 55.6 48.8 62.4

6–10 incidents 9.9 4.9 17.4

11 or more incidents 7.2 3.0 14.1

Source: GAO. | GAO-18-53

Note: Overall weighted estimates for subquestion 5A are generalizable to all PHAs and to PHAs by 

size.

Fraudulent Activities 

by Landlords and 

Building Inspectors

Survey Question 5 

Responses
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 43 GAO-18-53 Housing Choice Voucher Program

Table 19: Reported Incidents of Fraud Type (Raw Counts)—Survey Question 5

About how many incidents like this is your PHA aware of in the past year? Please only include incidents that occurred in your PHA. 

(Question 5A)

Analysis group 1 incident 2–5 incidents 6–10 incidents 11 or more incidents Frequency missing

Full population 26 56 10 10 1

Medium PHA 18 34 6 2

Large PHA 8 22 4 8

Source: GAO. | GAO-18-53

Table 20: Methods by Which PHAs Became Aware of Fraud Type (Weighted Estimate)—Survey Question 5

How did your PHA become aware of these incidents? (Question 5B)

Full population Response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence 

interval—upper 

bound (percent)

The victim, or target of the 

fraud, informed us 

Checked 79.2 70.1 86.6

Not checked 20.8 13.4 29.9

PHA staff witnessed or came 

across fraudulent activity

Checked 23.9 16.0 33.3

Not checked 76.1 66.7 84.0

Someone other than the 

victim or PHA staff

Checked 13.3 7.4 21.4

Not checked 86.7 78.6 92.6

Some other way Checked 5.5 1.9 11.8

Not checked 94.5 88.2 98.1

Source: GAO. | GAO-18-53

Note: Respondents could select more than one response option. Also, overall weighted estimates for 

subquestion 5B are generalizable to all PHAs and to PHAs by size.

Table 21: Methods by Which PHAs Became Aware of Fraud Type (Raw Counts)—Survey Question 5

How did your PHA become aware of these incidents? (Question 5B)

Analysis 

group Response

The victim, or target 

of the fraud, informed 

us

PHA staff witnessed 

or came across 

fraudulent activity

Someone other than 

the victim or 

PHA staff

Some 

other way

Full 

population

Checked 82 23 16 6

Not checked 21 80 87 97

Medium PHA Checked 48 16 6 3

Not checked 13 45 55 58

Large PHA Checked 34 7 10 3

Not checked 8 35 32 39

Source: GAO. | GAO-18-53
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 44 GAO-18-53 Housing Choice Voucher Program

Table 22: PHAs Reporting That Older Adults Were Targeted in Fraud Incidents (Weighted Estimates)—Survey Question 5

Were elderly program participants targeted by landlords in these incidents? (Question 5C)

Full population 

response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence 

interval—upper bound 

(percent)

Yes 8.0 3.6 15.1

No 73.6 63.9 81.8

Unsure 18.4 11.4 27.3

Source: GAO. | GAO-18-53

Note: Overall estimates are generalizable to all PHAs and to PHAs by size.

Table 23: PHAs Reporting That Older Adults Were Targeted in Fraud Incidents (Raw Counts)—Survey Question 5

Were elderly program participants targeted by landlords in these incidents? (Question 5C)

Analysis group Yes No Unsure Not checked

Full population 8 73 21 1

Medium PHA 5 46 9 1

Large PHA 3 27 12 0

Source: GAO. | GAO-18-53

Table 24: Estimated Percentage of PHAs Aware of Fraud Type—Survey Question 6

In the past year, is your PHA aware of landlords or building inspectors requiring favors, such as sexual favors, in addition to regular rent 

payments for your PHA program participants? (Question 6)

Analysis group Response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence 

interval—upper bound 

(percent)

Full population Yes 5.0 2.6 8.7

No 95.0 91.3 97.4

Medium PHA Yes 4.3 1.8 8.7

No 95.7 91.3 98.2

Large PHA Yes 8.5 6.3 11.3

No 91.5 88.7 93.7

Source: GAO. | GAO-18-53

Note: Overall estimates are generalizable to all PHAs and to PHAs by size.

Survey Question 6 

Responses
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 45 GAO-18-53 Housing Choice Voucher Program

Tables 25–27 below present results for PHAs that responded “yes” to 

question 6. Because of the limited number of respondents answering 

“yes” to question 6, we could not generate reliable estimates for question 

6 subquestions, and present raw frequency counts only.

Table 25: Reported Incidents of Fraud Type (Raw Counts)—Survey Question 6

About how many incidents like this is your PHA aware of in the past year? Please only include incidents that occurred in your PHA. 

(Question 6A)

Analysis group 1 incident 2–5 incidents 6–10 incidents

11 or more 

incidents

Frequency 

missing

Full population 9 3 0 0 1

Medium PHA 4 2 0 0

Large PHA 5 1 0 0

Source: GAO. | GAO-18-53

Table 26: Methods by Which PHAs Became Aware of Fraud Type (Raw Counts)—Survey Question 6

How did your PHA become aware of these incidents? (Question 6B)

Analysis group Response

The victim, or 

target of the fraud, 

informed us

PHA staff 

witnessed or 

came across 

fraudulent activity

Someone other

than the victim or

PHA staff

Some 

other way

Full population Checked 8 0 3 1

Not checked 5 13 10 12

Medium PHA Checked 4 0 1 1

Not checked 3 7 6 6

Large PHA Checked 4 0 2 0

Not checked 2 6 4 6

Source: GAO. | GAO-18-53

Note: Respondents could select more than one response option.

Table 27: PHAs Reporting That Older Adults Were Targeted in Fraud Incidents (Raw Counts)—Survey Question 6

Were elderly program participants targeted by landlords or building inspectors in these incidents? (Question 6C)

Analysis group Yes No Unsure Not checked

Full population 0 11 1 1

Medium PHA 0 6 0 1

Large PHA 0 5 1 0

Source: GAO. | GAO-18-53
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 46 GAO-18-53 Housing Choice Voucher Program

Table 28: Estimated Percentage of PHAs Aware of Fraud Type—Survey Question 7

In the past year, is your PHA aware of incidents where a landlord asked a prospective tenant of your PHA to provide a security deposit 

when there was no unit or apartment available? (Question 7)

Analysis group Response

Estimated 

percentage

95 percent confidence 

interval—lower bound 

(percent)

95 percent confidence

interval—upper bound 

(percent)

Full population Yes 4.3 2.1 7.7

No 95.7 92.3 97.9

Medium PHA Yes 3.1 1.0 7.1

No 96.9 92.9 99.0

Large PHA Yes 9.9 7.5 12.9

No 90.1 87.1 92.5

Source: GAO. | GAO-18-53

Note: Overall estimates are generalizable to all PHAs and to PHAs by size.

Tables 29–31 below present results for PHAs that responded “yes” to 

question 7. Because of the limited number of respondents answering 

“yes” to question 7, we could not generate reliable estimates for question 

7 subquestions, and present raw frequency counts only.

Table 29: Reported Incidents of Fraud Type (Raw Counts)—Survey Question 7

About how many incidents like this is your PHA aware of in the past year? Please only include incidents that occurred in your PHA. 

(Question 7A)

Analysis group 1 incident 2–5 incidents 6–10 incidents

11 or more 

incidents

Frequency 

missing

Full population 4 6 0 1 1

Medium PHA 1 2 0 1

Large PHA 3 4 0 0

Source: GAO. | GAO-18-53

Survey Question 7 

Responses
Appendix II: Results of GAO’s Survey of Public 

Housing Agencies

Page 47 GAO-18-53 Housing Choice Voucher Program

Table 30: Methods by Which PHAs Became Aware of Fraud Type (Raw Counts)—Survey Question 7

How did your PHA become aware of these incidents? (Question 7B)

Analysis group Response

The victim, or 

target of the fraud, 

informed us

PHA staff witnessed 

or came across 

fraudulent activity

Someone other 

than the victim or 

PHA staff

Some other 

way

Full population Checked 11 1 0 0

Not checked 1 11 12 12

Medium PHA Checked 4 0 0 0

Not checked 1 5 5 5

Large PHA Checked 7 1 0 0

Not checked 0 6 7 7

Source: GAO. | GAO-18-53

Note: Respondents could select more than one response option.

Table 31: PHAs Reporting That Older Adults Were Targeted in Fraud Incidents (Raw Counts)—Survey Question 7

Were elderly program participants targeted in these incidents? (Question 7C)

Analysis group Yes No Unsure Not checked

Full population 0 10 1 1

Medium PHA 0 4 0 1

Large PHA 0 6 1 0

Source: GAO. | GAO-18-53
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 48 GAO-18-53 Housing Choice Voucher Program

Rebecca Shea, (202) 512-6722 or shear@gao.gov

In addition to the contact named above, Kathy Larin (Director), Tonita 

Gillich (Assistant Director), Scott Hiromoto (Analyst-in-Charge), Maurice 

Belding, Yue Pui Chin, Colin Fallon, Dennis Fauber, Maksim Glikman, 

Ronald La Due Lake, Jill Lacey, Won Lee, Robert Letzler, Barbara Lewis, 

Olivia Lopez, Maria McMullen, Anna Maria Ortiz, Sabrina Streagle, Adam 

Windram, and Helina Wong made key contributions to this report.

Also contributing were Marcus Corbin, Cory Marzullo, Wayne McElrath, 

Josephine Perez, Samuel Portnow, and Paul Schmidt.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100853)
The Government Accountability Office, the audit, evaluation, and investigative 

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