HOMELESSNESS

To Improve Data and 

Programs, Agencies Have 

Taken Steps to Develop a 

Common Vocabulary

Statement of Alicia Puente Cackley, Director 

Financial Markets and Community Investment

Testimony 

Before the Subcommittee on Insurance, 

Housing, and Community Opportunity, 

Committee on Financial Services, 

House of Representatives

For Release on Delivery 

Expected at 10:00 a.m. EST

Thursday, December 15, 2011

GAO-12-302T

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-302T, a testimony 

before the Subcommittee on Insurance, 

Housing, and Community Opportunity, 

Committee on Financial Services, House of 

Representatives

December 15, 2011

HOMELESSNESS 

To Improve Data and Programs, Agencies Have 

Taken Steps to Develop a Common Vocabulary

Why GAO Did This Study

According to the Department of 

Housing and Urban Development’s 

(HUD) estimates of shelter use, the 

number of homeless families increased 

by 20 percent from 2007 to 2010 and 

families currently represent a much 

larger percentage of the shelter 

population than ever before. Multiple 

federal agencies administer programs 

designed to address the needs of 

children and youths experiencing 

homelessness, but some programs 

use different definitions of 

homelessness to determine eligibility. 

The definitions range from people 

living in emergency or transitional 

shelters or on the street to those living 

with others because of economic 

hardship or living in motels or 

campgrounds because they lack other 

adequate alternative accommodations.

This testimony discusses differences in 

the federal definitions of 

“homelessness” and other factors that 

may influence the effectiveness of 

programs serving persons 

experiencing homelessness, including 

children and youth. In completing this 

statement, GAO reviewed and 

updated, as appropriate, its June 2010 

report, Homelessness: A Common 

Vocabulary Could Help Agencies 

Collaborate and Collect More 

Consistent Data (GAO-10-702). In that 

report, GAO recommended that federal 

agencies develop a common 

vocabulary for homelessness and 

determine whether it would be costeffective to use this common 

vocabulary to develop and implement 

guidance for collecting consistent 

federal data on housing status. The 

agencies agreed with our 

recommendations. This statement also 

discusses the progress federal 

agencies have made in implementing 

these recommendations.

What GAO Found

Definitional differences of homelessness have posed challenges to providing 

services for children and youth. Children and youth living in precarious situations, 

such as living with others or in hotels, historically were excluded from receiving 

government-funded services. Congress enacted the Homeless Emergency 

Assistance and Rapid Transition to Housing Act of 2009 (HEARTH Act), which 

broadened the general definition of homelessness and provided greater statutory 

specificity concerning those who should be considered homeless. In November 

2011, HUD issued a final rule on the definition of homelessness, adding a new 

category of homelessness––unaccompanied youth, and families with children 

and youth who are defined as homeless under other federal statutes. The 

HEARTH Act and HUD’s recent definition changes may alleviate some 

challenges previously faced by children and youth in accessing services, but not 

enough time has passed to assess the impact of those changes. Some children 

and youth who previously were not considered homeless by HUD will now qualify 

as homeless. However, the broadening of the definition does not mean that 

everyone who meets the new definition would be entitled to benefits in all 

homeless assistance programs, and constraints on resources will likely continue 

to restrict access for some children and youths.

As of December 2011, the U.S. Interagency Council on Homelessness 

(Interagency Council) and federal agencies had taken steps to develop a 

common vocabulary for discussing homelessness and related terms, as GAO 

recommended in its June 2010 report. In January 2011, the Interagency Council 

convened a meeting of experts to discuss the development of a common 

vocabulary and the extent to which differences in definitions create barriers to 

accessing services. The Interagency Council issued a report to Congress in June 

2011 that summarized the feedback received during the meeting. The report 

notes that a common vocabulary would allow federal agencies to better measure 

the scope and dimensions of homelessness, and may ease program 

implementation and coordination. As of December 2011, Interagency Council 

staff told GAO that they held three meetings––in August, September, and 

October 2011––to discuss implementation of a common vocabulary and data 

standard with key federal agencies such as HUD; the Departments of 

Commerce, Education, Health and Human Services (HHS), Labor, and Veterans 

Affairs (VA); and the Social Security Administration. The Interagency Council 

also noted that individual federal agencies have taken some positive steps to 

create this common data standard and improve coordination across agencies. 

For example, HHS and VA have been working with HUD to plan the potential 

transition of some of their programs to HUD’s data system (Homelessness 

Management Information Systems). As GAO has reported in the past, a common 

vocabulary would allow agencies to collect consistent data that agencies could 

compile to better understand the nature of homelessness, and it would allow 

agencies to communicate and collaborate more effectively. 

View GAO-12-302T. For more information, 

contact Alicia Puente-Cackley at (202) 512-

8678 or cackelya@gao.gov.
 

Page 1 GAO-12-302T 

Chairman Biggert, Ranking Member Gutierrez, and Members of the 

Subcommittee:

I am pleased to be here to participate in today’s hearing on the barriers 

that homeless children and youths face in securing services. The Census 

Bureau indicates that 22 percent of all children in the United States (16.4 

million), lived in poverty in 2010, and some evidence suggests that 

homelessness among children is increasing. For example, according to 

the Department of Housing and Urban Development’s (HUD) estimates of 

shelter use, the number of homeless families increased by 20 percent 

from 2007 to 2010 and families currently represent a much larger 

percentage of the shelter population than ever before.1

My statement today is based on our June 2010 report on differences in 

the federal definitions of “homelessness” and other factors that may 

influence the effectiveness of programs serving persons experiencing 

homelessness, including children and youths.

Furthermore, the 

Department of Education (Education) identified 939,903 homeless 

students during the 2009-2010 school year, an 18 percent increase since 

the 2007-2008 school year. Multiple federal agencies administer 

programs designed to address the needs of children and youths 

experiencing homelessness, but some programs use different definitions 

of homelessness to determine eligibility. The definitions range from 

people living in emergency or transitional shelters or on the street, to 

those living with others because of economic hardship or living in motels 

or campgrounds because they lack other adequate alternative 

accommodations. Counts of homeless children vary by agency, partly 

because various federal programs have used different definitions. For 

example, Education’s counts of homeless children have differed from 

HUD’s counts, partly because Education’s counts also include children 

doubled up in private residences or living in hotels or motels while HUD’s 

have not.

2

 

1

The technical term is “homeless persons in families” and includes households with at 

least one adult and one child. This data point is according to HUD’s 1-year estimates of 

shelter use. According to HUD’s 2010 estimate, about 59 percent of the members of these 

homeless families—335,000—were children under age 18. Data limitations about 

homeless children and youths are discussed later in this statement.

To improve federal 

agencies’ understanding of homelessness and help mitigate the barriers 

2

See GAO, Homelessness: A Common Vocabulary Could Help Agencies Collaborate and 

Collect More Consistent Data, GAO-10-702 (Washington, D.C.: June 30, 2010).

 
 

Page 2 GAO-12-302T 

posed by having different definitions of homelessness, we made two 

recommendations in that report to federal agencies––working through the 

U.S. Interagency Council on Homelessness (Interagency Council). We 

recommended that they

• Develop joint federal guidance that establishes a common vocabulary 

for discussing homelessness and related terms. Such guidance may 

allow agencies to collaborate more effectively to provide services to 

those experiencing homelessness.

• Determine whether it would be cost-effective to use this common 

vocabulary to develop and implement guidance for collecting 

consistent federal data on housing status for programs that address 

homelessness.

Specifically, this statement focuses on how differences in the definition of 

homelessness may influence the effectiveness of programs, as well as 

the progress federal agencies have made in implementing our 

recommendations.

For our 2010 report, we reviewed relevant laws, regulations, and 

government reports across a number of programs specifically targeted to 

address issues related to homelessness. We also interviewed officials at 

HUD; the Departments of Health and Human Services (HHS) and 

Education; the Interagency Council; and the Departments of Justice and 

Labor. We conducted in-depth interviews with a variety of stakeholders, 

including advocates and researchers, as well as service providers, state 

and local government officials, and HUD field staff that had extensive 

experience with homeless programs. We conducted four site visits to 

large and medium-sized urban areas that were geographically distributed 

across the United States. To update information for this testimony, we 

interviewed officials from the Interagency Council and reviewed relevant 

documents related to actions taken to implement our recommendations.

This statement summarizes our June 2010 report that was based on work 

conducted between May 2009 and June 2010. We updated our work in 

November and December 2011. Both of these performance audits were 

conducted in accordance with generally accepted government auditing 

standards. These standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
 

Page 3 GAO-12-302T 

Congress first provided a general definition of homeless individuals in 

1987 in what is now called the McKinney-Vento Act.3 In 2002, Congress 

added a definition for homeless children and youths to be used in 

educational programs.4 In 2009, Congress enacted the Homeless 

Emergency Assistance and Rapid Transition to Housing Act (HEARTH 

Act).5 The HEARTH Act broadened the general definition of 

homelessness and provided greater statutory specificity concerning those 

who should be considered homeless. In November 2011, HUD issued a 

final rule to implement changes to the definition of homeless in the 

HEARTH Act.6 The rule expands who is eligible for various HUD-funded 

homeless assistance programs. The broadened definition adds a new 

category of homelessness, which includes unaccompanied youth and 

families with children and youth who are defined as homeless under other 

federal statutes––such as the Runaway and Homeless Youth Act and the 

Head Start Act.7 As a result, persons meeting other federal statutes’ 

broader definitions of homelessness also can be eligible for HUD 

programs.

The data on those experiencing homelessness have a number of 

shortcomings and consequently do not fully capture the extent and nature 

of homelessness. According to the Interagency Council’s 2010 federal 

strategic plan, the actual number of youths experiencing homelessness is 

unknown. As we reported in 2010, these data shortcomings derive from 

the difficulty of counting a transient population that changes over time and 

lack of comprehensive data collection requirements. For example, HUD, 

HHS, and Education each collect data for its own purposes, resulting in 

 

3

The act was originally named the Stewart B. McKinney Act but was changed to the 

McKinney-Vento Act in 1989.

4

Before the inclusion of this definition in the McKinney-Vento education subtitle in 2002, 

similar language was contained in policy guidance issued by Education in 1995.

5

Pub. L. No. 111-22 § 1001, et seq. (May 20, 2009). 

6

The rule was published in the Federal Register on December 5, 2011 (76 Fed. Reg. 

75994) and will be effective January 4, 2012. 

7

42 U.S.C. 5701 et seq. and 42 U.S.C. 9831 et seq.

Background 

Definitions of 

Homelessness

Data on Homeless 

Children and Youths
 

Page 4 GAO-12-302T 

differences in what data are collected and how they are aggregated. 

Often agencies solely count those receiving federally funded services, 

and because unaccompanied youth are often not connected to services 

or shelters, they are difficult to count. Furthermore, Education may not 

fully capture the extent of homelessness among school-aged children 

because, as we reported in 2010, districts we visited used a system of 

referrals and self-reporting to identify these children. As we reported in 

2010, many school officials and advocates said the term “homeless” 

carried a stigma that made people reluctant to self-report.

The Mckinney-Vento Act authorized the creation of the Interagency 

Council as an independent establishment whose membership is 

statutorily defined.8 The HEARTH Act directed the Interagency Council to 

coordinate the federal response to homelessness and create a national 

partnership at every level of government and with the private sector to 

reduce and end homelessness.9

 

8

The Interagency Council was established by title II of the McKinney-Vento Act, Pub. L. 

No. 100-77 § 20, as the “Interagency Council on the Homeless.” In 2004, Congress 

renamed it “United States Interagency Council on Homelessness.” Pub. L. No. 108-199 § 

201 (Jan. 23, 2004). The Interagency Council includes members from the following: the 

Departments of Agriculture, Commerce, Defense, Education, Energy, Health and Human 

Services, Homeland Security, Housing and Urban Development, Interior, Justice, Labor, 

Transportation, and Veterans Affairs; Corporation for National and Community Service; 

General Services Administration; Office of Management and Budget; Social Security 

Administration; U.S. Postal Service; and the White House Office of Faith-Based and 

Community Initiatives (now known as the White House Office of Faith-Based and 

Neighborhood Partnerships). 

The Interagency Council is also required 

to develop and annually update a federal strategic plan to end 

homelessness, as well as perform several other duties such as collecting 

and disseminating information relating to homeless individuals, 

developing joint federal agency initiatives to fulfill its goals, and providing 

professional and technical assistance to states, local governments, and 

other public and private nonprofit organizations. In fiscal year 2011, 

Congress appropriated $2.68 million for the Interagency Council to carry 

out its responsibilities. We are presently reviewing potential 

fragmentation, overlap, and duplication in federal homelessness 

programs, including agencies’ and the Interagency Council’s role in 

coordinating programs, and will issue a report in spring 2012.

9

See Pub. L. No. 111-22 § 1004. 

The Interagency Council 
 

Page 5 GAO-12-302T 

Definitional differences of homelessness have posed challenges to 

providing services for children and youths. As we reported in 2010, many 

advocates, government officials, service providers, and researchers we 

interviewed identified differences in definitions of homelessness as an 

important barrier to providing services, and several noted that families 

and youths living in precarious situations historically were not eligible for 

federal assistance under a narrow definition of homelessness. Some said 

that families and youths who were doubled up or living in hotels because 

of economic hardship often had similar or greater needs for services than 

those who met narrower definitions, but were excluded from receiving 

government-funded services. Those that cited differences in definitions as 

a barrier also said that families and youths with severe housing needs 

had to be on the street or in shelters to access some federally funded 

homeless assistance but shelters were not always available or 

appropriate for them. For instance, a researcher and a service provider 

suggested that adult shelters were not appropriate for unaccompanied 

youths or young adults, and few shelters were designed specifically for 

them. Furthermore, some family facilities do not provide shelter for males 

above a certain age, so families with male teenage children might not be 

able to find shelter together.

As we reported in 2010, many of those involved in homeless programs 

with whom we spoke were particularly concerned about the exclusion of 

families and youths from programs that addressed the needs of 

chronically homeless individuals.10

 

10Before enactment of the HEARTH Act, there was no statutory definition of chronic 

homelessness. In a 2003 Federal Register release announcing a joint agency initiative to 

end chronic homelessness, HUD, HHS, and the Department of Veterans Affairs defined 

the term to mean “an unaccompanied homeless individual with a disabling condition who 

has either been continuously homeless for a year or more, or has had at least four 

episodes of homelessness in the past three years.” Notice of Funding Availability for the 

Collaborative Initiative to Help End Chronic Homelessness, 68 Fed. Reg. 4018, 4019 (Jan. 

27, 2003). In an amendment to title IV of the McKinney-Vento Act (which authorizes the 

emergency shelter and transitional housing programs administered by HUD), the 

HEARTH Act added a definition of “chronically homeless” that includes individuals or 

families who qualify under the definition. Pub. L. No. 111-22 § 1101, 123 Stat. 1669. 

Before the passage of the HEARTH 

Act, families who otherwise met the criteria for chronic homelessness 

programs were not able to participate because chronic homelessness 

was defined to include only unaccompanied individuals. Our interviewees 

noted that the emphasis on funding programs for chronic homelessness 

meant that families have been underserved. A youth service provider 

further noted that youths effectively were excluded from programs for 

Definitional 

Differences Have 

Limited Providers’ 

Ability to Serve 

Children and Youths
 

Page 6 GAO-12-302T 

those experiencing chronic homelessness because youths generally did 

not live in shelters or keep records of where they had been living or for 

how long.

While the HEARTH Act and HUD’s recent definition changes may 

alleviate some challenges, not enough time has passed to assess the 

impact of the changes. The broadening of the definition of homeless does 

not mean that everyone who meets the new definition would be eligible 

for or entitled to benefits in all homeless assistance programs. For some 

programs, the definition of homeless determines whether individuals are 

eligible for program benefits and meeting the definition entitles the 

individual to certain benefits. For example, the Education of Homeless 

Children and Youth program entitles students to certain benefits as long 

as they meet the definition. However, for other programs, such as HUD’s 

homeless assistance grants or HHS’s Runaway and Homeless Youth 

programs, benefits are limited by the amount of funds appropriated for the 

program. For these programs, meeting the definition of homeless does 

not necessarily entitle individuals or families with children to benefits. 

Additionally, these programs have other eligibility criteria such as income 

levels, ages, or disability status to help determine and prioritize who 

receives the benefits.

Although more children and youth may be eligible for HUD programs 

under HUD’s new definition, barriers to serving them may persist. For 

example, according to our 2010 report, HHS officials told us that in the 

2009 program year, less than half of families in Head Start who 

experienced homelessness acquired housing. HHS attributed this to a 

lack of affordable housing and long waiting lists for housing assistance, 

not necessarily definitional differences. Also, officials at HHS 

acknowledged that Head Start programs across the country sometimes 

were not using the appropriate definition of homelessness to identify 

children who qualified for services. As a result, some homeless families 

did not receive Head Start services.

We also reported in 2010 that some interviewees stated that definitional 

differences of homelessness made collaboration more difficult. Because 

homelessness is a multifaceted issue and a variety of programs across a 

number of departments and agencies have been designed to address it, 

collaborative activities are essential to reducing homelessness in a costeffective manner. According to some interviewees, different definitions of 

homelessness and different terminology to address homelessness have 

made it difficult for communities to plan strategically for housing needs 
 

Page 7 GAO-12-302T 

and for federal agencies to collaborate effectively to provide 

comprehensive services.

As of December 2011, the Interagency Council and federal agencies 

have taken steps to develop a common vocabulary for discussing 

homelessness and related terms, as we recommended in our June 2010 

report. The HEARTH Act mandated that after the completion of our June 

2010 study, the Interagency Council convene a meeting of experts to 

discuss the need for a uniform federal definition of homelessness and the 

extent to which differences in definitions create barriers to accessing 

services. In January 2011, the Interagency Council held a meeting with 

85 participants from a variety of stakeholder organizations and issued a 

report to Congress in June 2011 that summarized the feedback received 

during the meeting.11

During the January 2011 meeting, participants also identified next steps 

for building a common vocabulary and data standard on housing status, 

which, according to the Interagency Council, would allow measurement of 

homelessness across agencies or at the federal level. As part of the next 

steps for building a common vocabulary, the Interagency Council 

developed an interagency workgroup that will conduct an inventory of 

current data standards across agencies to build on common reporting 

requirements. Additionally, the workgroup will focus on classifying existing 

reporting requirements into a common vocabulary that describes the 

varying conditions of homelessness that different federal agencies target. 

As of December 2011, Interagency Council staff told us that they held 

three meetings––in August, September, and October 2011––to discuss 

implementation of a common vocabulary and data standard with key 

According to the June 2011 report, developing a 

common vocabulary would entail developing shared terminology for 

talking about the many different types of homelessness, such as living on 

the streets, in shelters, or doubled up with family or friends. However, 

each federal agency still would maintain its own program eligibility criteria 

as defined by statute, regulation, or administrative rules. The June 2011 

report notes that a common vocabulary would allow federal agencies to 

better measure the scope and dimensions of homelessness, and may 

ease program implementation and coordination.

 

11U.S. Interagency Council on Homelessness, Report to Congress: Community Forum to 

Discuss GAO Recommendation to Develop a Common Federal Vocabulary on Housing 

Status, June 2011.

Federal Agencies 

Have Taken Steps to 

Develop a Common 

Vocabulary 
 

Page 8 GAO-12-302T 

federal agencies such as Education, HUD, HHS; the Departments of 

Commerce, Defense, Labor, and Veterans Affairs (VA); the Social 

Security and General Services Administrations; and the Office of 

Management and Budget.

The Interagency Council also noted that individual federal agencies have 

taken some positive steps to create this common data standard and 

improve coordination across agencies. In an update to its strategic plan in 

October 2011, the Interagency Council noted that agencies such as HHS 

and VA have been working with HUD to better coordinate data collection, 

analysis, and reporting.12

In conclusion, changes to the definition of homeless based on the 

HEARTH Act and HUD’s final rule may alleviate some of the challenges 

the narrower definitions previously presented. Also, federal agencies’ 

efforts to develop a common vocabulary and data standard will likely 

allow agencies to measure homelessness more consistently. However, a 

broader and more consistent definition of homeless does not mean that 

everyone who meets the new definition would be entitled to benefits in all 

homeless assistance programs, and constraints on resources will likely 

continue to restrict access for some children and youth.

For example, HHS, HUD, VA, and the 

Interagency Council issued joint guidance and hosted a webinar on 

strategies to improve the accuracy of HUD’s point-in-time counts of 

people experiencing homelessness, particularly for youth and veterans. 

Additionally, HHS and VA have each been working with HUD to plan the 

potential transition of some of their programs to HUD’s data system 

(Homelessness Management Information Systems, or HMIS). The 

Interagency Council has a goal of transitioning two other federal agencies 

to HMIS by December 31, 2014.

Chairman Biggert, Ranking Member Gutierrez, and Members of the 

Subcommittee, this concludes my prepared statement. I would be 

pleased to respond to any questions that you may have at this time.

 

12The Interagency Council issued its first strategic plan in June 2010, which included an 

objective to strengthen capacity and knowledge, including creating a common data 

standard and uniform performance measures if feasible. See U.S. Interagency Council on 

Homelessness, Opening Doors: Federal Strategic Plan to Prevent and End 

Homelessness, June 2010. For the 2011 update, see Opening Doors: Federal Strategic 

Plan to Prevent and End Homelessness Update 2011, October 2011.
 

Page 9 GAO-12-302T 

For further information on this testimony, please contact Alicia Puente 

Cackley at (202) 512-8678 or cackleya@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this statement. Individuals making key contributions to 

this testimony include Paul Schmidt, Assistant Director; Nancy Barry; 

William Chatlos; Beth Faraguna; Janet Fong; John McGrail; Barbara 

Roesmann; and Brian Schwartz.

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