HOMELESS 

VETERANS

Management 

Improvements Could 

Help VA Better Identify 

Supportive-Housing 

Projects

Report to the Committee on Veterans' 

Affairs, U.S. Senate

December 2016

GAO-17-101

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-101, a report to the 

Committee on Veterans’ Affairs, U.S. Senate

December 2016

HOMELESS VETERANS

Management Improvements Could Help VA

Better Identify Supportive-Housing Projects

What GAO Found

As of September 2016, for veterans who were homeless or at risk of 

homelessness, the Department of Veterans Affairs (VA) had developed 35 

enhanced-use leases (EUL) for supportive-housing with low cost rental housing 

and coordinated access to medical, rehabilitative, mental healthcare, and other 

services. Each supportive-housing EUL is located on a VA medical center 

campus. Some lessee representatives told GAO that having access to federal 

property at little or no cost helped them to rehabilitate or build facilities to create 

supportive-housing. Furthermore, they noted that the close proximity to VA 

healthcare services allowed them to invest in other needed services for 

homeless veterans, such as counseling, job training, and quality-of-life 

amenities. 

VA has plans to develop additional supportive-housing EULs, 6 of which are 

under construction and 16 in development. However, VA needs to improve its 

documentation and update its policies to develop additional EULs. VA officials 

did not provide clear and complete documentation for the selection of supportivehousing EUL projects, as required by VA policy, and Standards for Internal 

Controls in the Federal Government. Completely documenting this decisionmaking process for selecting properties could provide institutional knowledge to 

inform future decisions. Also, Standards for Internal Controls in the Federal 

Government states that management should periodically review policies and 

procedures for continued relevance and effectiveness of a federal program, and 

that management considers the impact of deficiencies identified in achieving 

documentation requirements. VA’s existing policy on EUL projects is outdated. 

For example, it refers to an EUL authority that previously allowed the 

development of a full range of EUL projects. However, this authority is no longer 

in effect. VA is updating its EUL policy; however, the updated draft policy still 

does not discuss VA’s limited authority to provide housing for homeless 

veterans. Further, the updated draft policy does not specifically provide direction 

on how to determine whether a proposed supportive-housing EUL meets the 

needs of homeless veterans. Without documented policies and procedures that 

address these needs, VA may not be well positioned to identify viable 

supportive-housing EUL projects and help ensure that those projects are 

successfully developed. 

Three programs—Housing and Urban Development and VA Supportive-Housing 

(HUD-VASH), VA’s Grant and Per Diem (GPD), and Supportive Services for 

Veteran Families (SSVF)—were used in conjunction with supportive-housing 

EULs to help support the goal of ending veteran homelessness. From fiscal 

years 2012 to 2016, the number of chronically homeless and vulnerable veterans 

housed through the HUD-VASH program increased from about 37,000 to 72,500.

Community officials GAO interviewed stated that the HUD-VASH program has 

been instrumental in reducing chronic veteran homelessness. From fiscal years

2012 to 2016, veterans served by the transitional housing-focused GPD program 

remained relatively steady. Veterans and their family members participating in 

the SSVF program increased from about 33,000 in fiscal year 2012 to 149,000 in

fiscal year 2016. According to the VA, rental assistance made up the majority of 

the temporary financial assistance provided by the SSVF program.

View GAO-17-101. For more information, 

contact David J. Wise, (202) 512-2834 or

wised@gao.gov or Alicia Puente Cackley, 

(202) 512-8678 or cackleya@gao.gov

Why GAO Did This Study

In August 2016, HUD and VA 

announced that the number of 

homeless veterans in the United States 

had been cut nearly in half since 2010

to less than 40,000. Part of this effort is 

the EUL program, which uses 

unneeded federal property (land or 

buildings) for housing for homeless 

veterans.

GAO was asked to review VA’s EUL

program and other efforts to end 

veteran homelessness. This report 

examines: (1) how VA uses EULs to 

provide supportive-housing and 

services, (2) VA’s plans to develop 

additional supportive-housing through 

EULs and how past plans have been 

implemented, and (3) how HUD-VASH, 

GPD, and SSVF have helped support 

the goal of ending veterans’

homelessness. GAO analyzed agency 

documents, VA data on enhanced-use 

leases, and VA data on the HUDVASH, GPD, and SSVF programs.

GAO visited 13 active supportivehousing EUL sites, selected to provide 

a range of locations and housing types.

GAO interviewed VA and HUD 

officials, lessee representatives,

service providers, and veteran

organizations.

What GAO Recommends

GAO recommends that VA (1) 

document its decision-making process 

in selecting projects as required by 

VA’s policy and (2) update its policy to 

address the current authority and 

specify how to identify properties for 

supportive-housing EULs to meet the 

needs of homeless veterans. VA 

concurred with both recommendations 

but disagreed with some of GAO’s 

findings. GAO believes its findings are 

valid based on the evidence presented.

 
Page i GAO-17-101 Homeless Veterans

Letter 1

Background 5

VA Uses Supportive-Housing EULs to Provide Homeless 

Veterans with Affordable Housing and a Range of Services on 

VA Campuses 11

VA Continues to Develop Supportive-Housing EULs, but Faces 

Challenges and Lacks Specific Policies 20

VA Uses Three Additional Key Programs to Provide Housing 

Assistance and Supportive Services to Homeless Veterans 30

Conclusions 39

Recommendations for Executive Action 39

Agency Comments and Our Evaluation 40

Appendix I Objectives, Scope, and Methodology 43

Appendix II The Population of Homeless Veterans in the United States, by State, 

2016 48

Appendix III Participant Program Eligibility for Three Key Veterans’ Housing 

Programs 50

Appendix IV Department of Veterans Affairs’ (VA) 70 Supportive-Housing 

Enhanced-Use Leases (EULs) as of September 2016 52

Appendix V Profiles of the 13 Selected Supportive-Housing Enhanced-Use 

Leases 57

Appendix VI Comments from the United States Interagency Council on 

Homelessness 69

Contents
Page ii GAO-17-101 Homeless Veterans

Appendix VII Comments from the Department of Veterans Affairs 70

Appendix VIII GAO Contacts and Staff Acknowledgments 77

Tables

Table 1: Characteristics of Active Supportive-Housing EnhancedUse Leases (EUL) as of September 2016 13

Table 2: Considerations and Veterans Affairs Expenses for 29 

Supportive-Housing Enhanced-Use Leases (EUL) from 

Fiscal Years 2006 through 2015 18

Table 3: Status of the Building Utilization Review and Repurposing 

initiative and the “Legacy” Supportive-Housing EnhancedUse Lease (EUL) Projects as of September 2016 22

Table 4: Services Available for Homeless Veterans from the Three 

Key Veterans Housing Programs, as of September 2016 31

Table 5: Department Of Housing and Urban Development’s and 

Department Of Veterans Affairs’ Supportive-Housing 

(HUD-VASH) Program Reported Housing Outcomes 

(Fiscal Years 2012 through 2016) 32

Table 6: Grant and Per Diem (GPD) Program Reported 

Transitional Housing Outcomes (Fiscal Years 2012 

through 2016) 35

Table 7: Reported Outcomes for the Program of Supportive 

Services for Veteran Families (SSVF) Fiscal Years 2012 

through 2016 37

Table 8: Temporary Financial Assistance Provided through 

Supportive Services for Veteran Families (Fiscal Years 

2012 through 2015, Dollars in Millions) 38

Table 9: Department of Housing and Urban Development’s 

Population of Homeless Veterans in the United States in 

2016 48

Table 10: Participant Program Eligibility for Three Key Veterans’ 

Housing Programs, as of September 2016 50

Table 11: Department of Veteran Affairs’ (VA) Enhanced-Use 

Lease (EUL) Sites by Status as of September 2016 52
Page iii GAO-17-101 Homeless Veterans

Table 12: New Directions Sepulveda (I L.P., Building 4, and II 

L.P., Building 5), Department of Veterans Affairs 

Sepulveda Ambulatory Care Center, Los Angeles, 

California 57

Table 13: Cooke’s Manor, Department of Veterans Affairs Medical 

Center, Hines, Illinois 58

Table 14: Bishop Goedert Residence, Department of Veterans 

Affairs Medical Center, Hines, Illinois 59

Table 15: Freedom’s Path I, Department of Veterans Affairs 

Medical Center, Hines, Illinois 60

Table 16: Al Loehr Veterans and Community Studio Apartments, 

Department of Veterans Affairs Medical Center, St. Cloud, 

Minnesota 61

Table 17: Veterans and Community Housing, Department of 

Veterans Affairs Medical Center, Minneapolis, Minnesota 62

Table 18: Upper Post Veterans Community, Department of 

Veterans Affairs Medical Center, Fort Snelling Upper 

Post, Minnesota 63

Table 19: Valley Brook Village Phase I, Department of Veterans 

Affairs Medical Center, Lyons, New Jersey 64

Table 20: Iowa Avenue—Building 412, Department of Veterans 

Affairs Medical Center, Dayton, Ohio 65

Table 21: Ohio Avenue Commons—Building 402, Department of 

Veterans Affairs Medical Center, Dayton, Ohio 66

Table 22: Building 400, Department of Veterans Affairs Medical 

Center, Dayton, Ohio 67

Table 23: Lyons Place II, Department of Veterans Affairs Medical 

Center, Dayton, Ohio 68

Figures

Figure 1: Process for Development of a VA Supportive-Housing 

Enhanced-Use Lease, as of September 2016 7

Figure 2: Map of 35 Active Supportive-Housing Enhanced-Use 

Leases, 2016 12

Figure 3: Examples of Services Offered to Improve Veterans’ 

Health and Well-being at Supportive-Housing EnhancedUse Leases 15

Figure 4: Example of Financing for a Supportive-Housing 

Enhanced-Use Lease at Fort Snelling in Minneapolis, 

Minnesota 28
Page iv GAO-17-101 Homeless Veterans

Abbreviations

AMI area median income 

BURR Building Utilization Review and Repurposing

EUL enhanced-use lease 

GPD Grant and Per Diem 

HUD Department of Housing and Urban Development 

HUD-VASH HUD and VA Supportive Housing 

LIHTC Low Income Housing Tax Credit Program 

NDS New Directions Sepulveda 

OAEM Office of Asset Enterprise Management 

OIG Office of Inspector General

SSVF Supportive Services for Veteran Families

USICH U.S. Interagency Council on Homelessness

VA Department of Veterans Affairs

VAMC VA medical center 

VHA Veterans Health Administration 

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

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-101 Homeless Veterans

441 G St. N.W.

Washington, DC 20548

December 21, 2016

The Honorable Johnny Isakson 

Chairman

The Honorable Richard Blumenthal

Ranking Member 

Committee on Veterans’ Affairs 

United States Senate

In August 2016, the U.S. Department of Housing and Urban Development 

(HUD), the U.S. Department of Veterans Affairs (VA), and the U.S. 

Interagency Council on Homelessness (USICH) announced that the 

number of veterans experiencing homelessness in the United States had 

been cut nearly in half since 2010.1 HUD estimates that 39,471 veterans 

were homeless in January 2016, declining from 74,087 in January 2010.2

In 2009, USICH member agencies, including HUD and VA, outlined 

ending veteran homelessness by 2015 as a goal.3 One effort to house 

homeless veterans is through VA’s use of its statutory authority to enter 

into enhanced-use leases (EULs) to use unneeded federal real property 

 1

See appendix II for the population of homeless veterans by state as of January 2016. An 

interactive graphic of this information can be viewed at http://www.gao.gov/products/gao17-101. 

2

These estimates are from HUD’s point-in-time count of sheltered and unsheltered 

homeless persons on a single night in January 2016 and January 2010. Sheltered 

homeless persons consist of those sheltered in emergency shelter, transitional housing, 

and Safe Havens (a form of supportive-housing for hard-to reach homeless persons with 

severe mental illness). Unsheltered homeless persons consist of those with a primary 

nighttime residence in a public or private spaces not designed or ordinarily used as 

sleeping accommodation, such as a car, park, abandoned building, bus or train station, or 

camping ground.

3

HUD and VA are 2 of the 19 federal agencies that make up USICH. USICH has specified 

criteria for ending veteran homelessness. USICH stated that an end to homelessness 

does not mean that no one will ever experience a housing crisis again, but that every 

community will have a systematic response in place to prevent homelessness whenever 

possible and ensure that homelessness is a rare, brief, and non-recurring experience. 

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

(Washington D.C.: June 2015).

Letter
Page 2 GAO-17-101 Homeless Veterans

(land or buildings) for housing for homeless veterans.4 As of September 

2016, there are 35 active supportive-housing EULs on VA campuses—

that is, EULs that include supportive services such as mental health 

counseling or job training.5 EULs are typically long-term agreements with 

public and private entities, such as public-housing authorities and 

development corporations, for the use of federal property in exchange for 

cash considerations at fair value. As a part of the EUL program, VA 

provides access to federal facilities and land to the lessee and developer; 

however, the lessee is responsible for financing, developing, constructing, 

rehabilitating, operating, and maintaining the supportive-housing EUL for 

homeless veterans.6 Three federal programs play a key role in providing 

housing subsidies and supportive services in conjunction with VA’s 

EULs—the HUD and VA Supportive-Housing (HUD-VASH) program that 

is jointly administered by HUD and the Veterans Health Administration 

(VHA), and two VA-run programs—Grant and Per Diem (GPD) and 

Supportive Services for Veteran Families (SSVF).

You asked us to review VA’s use of EUL authority as well as other VA 

programs to provide housing for homeless veterans and end veteran 

homelessness. This report examines (1) how VA uses EULs to provide 

supportive-housing and services, (2) VA’s plans to develop additional 

supportive-housing through EULs and how past plans have been 

implemented, and (3) how HUD-VASH, GPD, and SSVF have helped 

support ending veteran homelessness.

To describe VA’s use of EUL authority to provide supportive-housing to 

veterans, we collected and analyzed data from VA on the 35 active and 

 4

See 38 U.S.C. § 8162. Statute defines a veteran as a person who served in the active 

military, naval or air service, and was discharged or released under conditions other than 

dishonorable. 38 U.S.C. §101(2). There are currently five types of discharges: (1) 

honorable; (2) general; (3) other than honorable conditions or undesirable; (4) bad 

conduct; and (5) dishonorable. Active service means full-time service, other than active 

duty for training, as a member of the Army, Navy, Air Force, Marine Corps, Coast Guard, 

or as a commissioned officer of the Public Health Service, Environmental Science 

Services Administration or National Oceanic and Atmospheric Administration, or its 

predecessor, the Coast and Geodetic Survey.

5

For the purpose of this report, we refer to EUL housing sites that provide supportive 

services as “supportive-housing EULs.”

6

VA, case managers, or other lessee staff who operate the facility provide services to the 

veterans living at supportive-housing EULs. 
Page 3 GAO-17-101 Homeless Veterans

other supportive-housing EULs from July 1998 to September 2016.7 We 

also conducted site visits to 13 of the 35 active supportive-housing EULs 

located on or near VA medical center (VAMC) campuses in Lyons, New 

Jersey; Dayton, Ohio; St. Cloud and Minneapolis, Minnesota; Hines, 

Illinois; and Los Angeles, California.8 We judgmentally selected these 

supportive-housing EULs to include sites that presented a range of 

geographic locations; variety of stakeholders (e.g., public, private, and 

non-profit lessees and service providers); housing types (transitional and 

permanent housing); and ages of leases. At these sites, we interviewed 

VAMC officials, lessees, and service providers to understand factors 

involved in developing the EULs, the supportive services provided, and 

the benefits and challenges of developing supportive-housing through the 

EUL program.

To examine VA’s plans to develop additional supportive-housing and how 

VA implemented past plans, we analyzed VA data from July 1998 to 

August 2016 for projects in construction, development, and on-hold. We 

also interviewed VA headquarters officials, local VA officials, lessees, and 

service providers at four VAMC campuses—Los Angeles, California; 

Hines, Illinois; Lyons, New Jersey; and St. Cloud, Minnesota—that have 

supportive-housing EULs under development.9 We also analyzed 

information on VA’s Building Utilization Review and Repurposing (BURR) 

initiative, including the process for selecting supportive-housing EULs.10

Additionally, we reviewed EUL program policies on establishing and 

managing EULs, such as VA Handbook 7415, Directive 7415, VA

 7

We assessed the reliability of the data through interviews with knowledgeable VA officials 

and a review of the data for completeness and potential outliers. 

8

Some supportive-housing EULs are located on the same VAMC campus. For example, 

VA entered into four separate EUL agreements on the VAMC campus in Dayton, Ohio. 

Additionally, a supportive-housing EUL can have several buildings or facilities under the 

same lease. 

9

These four campuses were locations that we had visited as a part of our 13 site visits. 

10Under the BURR initiative, VA evaluated unutilized and underutilized land and buildings 

on existing VA property for potential homeless housing projects for veterans through both 

public-private collaboration and VA’s EUL program. According to VA officials, since 1998, 

they have conducted three national real estate initiatives—(1) Capital Asset Realignment 

for Enhanced Services, (2) Site Review Initiative, and (3) BURR—to address the needs of 

Veterans, 21st century technologies, updated health care delivery, aging infrastructure, 

and finite resources. Of these, only the BURR initiative is within the scope of this report.
Page 4 GAO-17-101 Homeless Veterans

Handbook 7454, and Directive 7454.

11 We also reviewed the Standards 

for Internal Control in the Federal Government.12

To describe how VA leverages key programs—HUD-VASH, GPD, and 

SSVF—to support ending veteran homelessness, we obtained VA data 

on performance targets and outcomes for each program for fiscal years 

2012 to 2016.13 Additionally, we obtained analyses from VA, HUD, and 

academics on the effects of the three programs on veteran homelessness 

and the role these programs play in providing rent subsidies and services 

for supportive-housing EULs. To understand how these programs support 

housing for homeless veterans in general, as well as supportive-housing 

EULs in particular, we interviewed officials and representatives from the 

following agencies and organizations: VA; the Department of Labor; 

USICH; supportive-housing EUL lessees and service providers from 13 

site visits as discussed earlier; not-for-profit organizations concerned with 

veterans’ homelessness—including the National Alliance to End 

Homelessness, the National Coalition for Homeless Veterans, and 

Vietnam Veterans of America. We also interviewed officials in select 

locations that either have large populations of homeless veterans or have 

had success in reducing veterans’ homelessness. Additionally, we 

 11VA, VA Handbook 7415, Enhanced-Use Leasing Program (Washington, D.C.: Dec. 21, 

2011); VA, VA Directive 7415, Enhanced-Use Leasing Program (Washington, D.C.: Dec. 

21, 2011); VA, VA Directive 7454, Enhanced-Use Leasing Post Transaction (Washington, 

D.C.: June 29, 2012); and VA, VA Handbook 7454, Enhanced-Use Leasing Post 

Transaction (Washington, D.C.: June 29, 2012).

12GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C: September 2014).

13We assessed the reliability of the data through interviews with knowledgeable VA 

officials and a review of the data for completeness and potential outliers. This report 

focuses exclusively on VA’s housing programs for veterans—those programs that provide 

housing or housing subsidies to homeless veterans or veterans at risk of becoming 

homeless, in addition to other supportive services. It does not include all programs that VA 

administers that may support homeless veterans (i.e., the Health Care for Homeless 

Veterans Program and other such programs). In 2012, we found that 14 federal programs 

specifically targeted homeless veterans, including VA programs, Department of Labor’s 

Homeless Veterans Reintegration Program, and programs operated by other agencies. 

See GAO, Homelessness: Fragmentation and Overlap in Programs Highlight the Need to 

Identify, Assess, and Reduce Inefficiencies, GAO-12-491 (Washington, D.C.: May 10, 

2012).
Page 5 GAO-17-101 Homeless Veterans

reviewed our prior work and the work of others relevant to our research 

objectives.14 For more detail on our methods, please see appendix I.

We conducted this performance audit from October 2015 to December

2016 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.

According to The 2015 Annual Homeless Assessment Report to 

Congress, veterans make up about 9.2 percent of the total U.S. 

population, and, they comprise about 10 percent of all homeless people.15

Ninety-one percent of homeless veterans are men, and according to a 

literature review conducted for the Department of Labor, three major 

health risks contributed to veteran homelessness: mental health 

problems, substance abuse, and chronic illnesses.16 VA and HUD both 

play a role in assisting homeless veterans. VA provides a broad range of 

benefits, including health care and housing, to homeless veterans and 

certain members of a veteran’s family.17 HUD is the primary federal 

agency that provides funding for emergency shelters, permanent housing, 

and transitional housing to assist the homeless and those at risk of 

homelessness, including veterans.18

 14GAO, Homelessness: Fragmentation and Overlap in Programs Highlight the Need to 

Identify, Assess, and Reduce Inefficiencies, GAO-12-491 (Washington, D.C.: May 10, 

2012), and GAO, Veteran Homelessness: VA and HUD Are Working to Improve Data on 

Supportive-Housing Program, GAO-12-726 (Washington, D.C.: June 26, 2012)

15The U.S. Department of Housing and Urban Development, Office of Community 

Planning and Development; The 2016 Annual Homeless Assessment Report to Congress, 

Part 2: Estimates of Homelessness in the United States (Washington, D.C.: Oct. 2016). 

16Avar Consulting, Inc., submitted to the U.S. Department of Labor, A Review of the 

Literature Related to Homeless Veteran Reintegration (Rockville, MD.: Nov. 2015).

17For the purpose of receiving supportive services for housing, a veteran family includes a 

veteran who is a single person, and a family in which the head of household or the spouse 

of the head of household is a veteran. 38 U.S.C. § 2044(f)(7).

18GAO-12-491. In addition to VA and HUD, we found in May 2012 that six other federal 

agencies administer programs that target various homeless or at risk of becoming 

homeless populations. 

Background
Page 6 GAO-17-101 Homeless Veterans

VA views the authority to enter into EULs as an important component of 

both VA’s mission to end veterans’ homelessness and manage its real 

property assets. VA’s Fiscal Year 2017 “EUL Consideration Report,”

provided in its budget submission to Congress, describes its management 

of unutilized and underutilized real property using its EUL authority and 

how EULs align with VA’s initiative to eliminate veteran homelessness.19

VA is one of the largest non-defense federal property-holding agencies; 

VA officials stated that in fiscal year 2016, VA held about 155-million 

square feet and leased 25-million square feet of building assets, about 

11.5-million square feet (or 6.4 percent) of which were unutilized or 

underutilized. Previously, VA was authorized to lease its unutilized or 

underutilized real property to public or private entities for any use that 

contributed to VA’s mission.20 This EUL authority expired on December 

31, 2011.21 According to VA officials, from the EUL program’s inception 

through December 2011, VA entered into 100 EULs, 9 of which VA 

subsequently terminated or disposed of the property.22 In 2012, VA 

received authority to enter into EULs, but only for supportive-housing, 

through December 2023.23 Supportive-housing provides on-site and 

community-based support services for the veterans or their families who 

are homeless or at risk of homelessness.24 Additionally, VA received 

authority to accept cash payments or to enter into an EUL without 

receiving payment. VA can execute EULs for terms of up to 75 years.25

VA’s Office of Asset Enterprise Management (OAEM) administers the 

EULs, with support from the VA’s local facility staff. In addition, the lessee 

(such as a non-profit organization, public-housing authority, or a 

development corporation) play an important role in financing, developing, 

constructing, rehabilitating, operating, and maintaining the supportivehousing EUL for homeless veterans. The EUL process consists of four 

 19VA. Volume 4 of the Department of Veterans Affairs 2017 Budget Submission. 

(Washington, D.C.: February 2016). The VA “EUL Consideration Report” is a part of the 

VA budget submission.

20Pub. L. No. 102-86, § 401 (1991). 

21Pub. L. No. 106-117, § 208(e)(1999).

22Some of these EUL facilities are not yet in operation because they are still under 

development or in construction.

2338 U.S.C §§ 8161-8169.

2438 U.S.C. §8161(3). Supportive-housing includes transitional housing, single-room 

occupancy, permanent housing, assisted living housing, and other types of housing.

2538 U.S.C. § 8162(b)(2).

Enhanced-Use Leases
Page 7 GAO-17-101 Homeless Veterans

phases: development, execution, operational, and if applicable, disposal 

(see fig. 1).26 VA officials estimated that it takes 2 to 2.5 years from the 

time VA identifies unneeded property to the time doors open at a 

supportive-housing EUL.

Figure 1: Process for Development of a VA Supportive-Housing Enhanced-Use Lease, as of September 2016

Note: The Director of the Office of Management and Budget must provide advance certification that 

VA EULs comply with Public Law 112-154.

HUD-VASH, GPD, and SSVF provide different types of housing 

assistance to fulfill different levels and areas of need. These programs 

provide supportive services and housing subsidies to eligible veterans, 

including those who live at EUL housing sites. HUD-VASH provides 

permanent supportive-housing assistance for homeless veterans, 

prioritizing chronically homeless and highly vulnerable veterans who have 

 26VA uses the terms “formulation” to describe the development phase, and “steady state”

to describe the operational phase. Once a supportive-housing EUL is open, VA uses the 

term “active.” For the purposes of our review, we focused on the first three phases: 

development, execution, and operational. In addition, VA uses the term “pre-development”

to describe initial due diligence it conducts to determine if a property is suitable for an 

EUL. 

HUD and VA SupportiveHousing, Grant and Per 

Diem, and Supportive 

Services for Veteran 

Families 
Page 8 GAO-17-101 Homeless Veterans

a high level of housing and service needs, such as those with high 

barriers to employment and self-sufficiency.27 In contrast, GPD provides 

transitional housing and SSVF focuses on short-term, crisis intervention 

when providing homeless prevention and rapid rehousing; both of these 

programs also provide supportive services for veterans who do not have 

as high a level of needs as those in the HUD-VASH program. See app. III 

for participant program eligibility.

• HUD and VA established the HUD-VASH program in 1992. HUD, 

through public-housing authorities, allocates subsidized housing 

vouchers to eligible homeless veterans and their families while VA 

provides case management and other services.28 Through the 

program, the public-housing authority pays the subsidy to the landlord 

directly and the veteran family pays the remainder of the rent. A 

majority of the HUD-VASH vouchers are tenant-based, meaning that 

the vouchers move with the veterans. With the partnering VAMC’s 

support, HUD allows public-housing authorities to make their HUDVASH vouchers project-based (i.e., tied to a specific housing unit and 

not to a tenant).29 Separately, in fiscal years 2010, 2014, 2015, and

2016, HUD awarded project-based vouchers to specific projects 

 27Eligible veterans include the chronically homeless and others who are homeless with 

diminished functional capacity and need case management. HUD defines chronically 

homeless as a homeless individual with a disability who has not been living in a place 

meant for human habitation, in an emergency shelter, or in a safe haven for at least 12 

months continuously or on at least four occasions in the last 3 years where those 

occasions cumulatively total at least 12 months. Additionally, the disabling condition must 

be of long and continuing duration; substantially impedes the individual’s ability to live 

independently; and expected to improve with housing. VA defines highly vulnerable 

veterans as those who have (1) underlying chronic medical or mental health conditions 

that substantially affect life expectancy and/or ability to function that cannot be effectively 

cared for due to their homelessness; (2) advanced age and infirmity where unstable and 

unstructured homelessness places them at substantial risk for being able to maintain 

independent activities of daily living; (3) diminished cognitive capabilities that place them 

at increased risk of victimization physically, mentally, and/or through exploitation.

28VA and HUD determine the allocation of vouchers based on geographic need as 

determined by the VA, public-housing authority administrative performance, and other 

factors that HUD and VA may specify. 

29In September 2011, HUD revised its guidance to remove the 50 percent limit on the 

amount of allocated vouchers that could be converted to project-based vouchers by a 

public-housing authority. 
Page 9 GAO-17-101 Homeless Veterans

through competition.30 Between fiscal year 2008 and 2016, HUD 

allocated about 82,500 tenant-based vouchers to public-housing 

authorities and about 4,800 project-based vouchers through 

competition to specific projects. Overall, Congress appropriated 

approximately $75 million each year from 2008–2010 and 2012–2015, 

$50 million in 2011, and $60 million in 2016 for the HUD-VASH 

program.

• Congress originally authorized the GPD program in 1992 and 

reauthorized the program in December 2001. The program was 

permanently authorized in 2006.31 The GPD program generally 

provides transitional housing paired with intensive services and 

support to address a veteran’s barriers to achieving permanent 

housing. The program provides beds to homeless veterans in a 

supervised drug- and alcohol-free setting. Through GPD, VA awards 

grants to community agencies, including non-profit organizations and 

state and local government agencies. The grants fund up to 65 

percent of the cost for acquiring, renovating, or constructing 

supportive-housing facilities or service centers and purchasing vans 

for outreach and transportation. GPD also provides funding for 

programs that provide services to homeless veterans. These services 

include case management, mental health treatment, and substance 

abuse treatment to help homeless veterans increase their residential 

stability, skill levels or income, and independence. VA designates 

GPD liaisons to oversee the program, provide case management, and 

determine veterans’ program eligibility. Congress generally increased 

its appropriation for the GPD program over the years, to about $220 

million in fiscal year 2015.32

• Congress authorized SSVF in 2008, but the program first became 

operational in fiscal year 2012. SSVF provides rapid rehousing to 

prevent or address “literal” homelessness for very low income 

 30To apply for project-based HUD-VASH vouchers through HUD’s set-aside award 

process, the developer of a project must submit an application through the public-housing 

authority, which selects a proposal. To apply, the local VAMC must support the project 

and the project must meet other qualifying criteria. HUD then scores the projects using 

several factors, including project readiness for occupancy; existence of EUL agreement 

with VA; supportive services provided; and relative need of homeless veterans in the area. 

The number of vouchers requested was limited to 50 per application in the 2010 award, 

but subsequently increased to 75 for the 2013–2016 awards. 

31Pub. L. 109-461, sec. 703. 

32This figure does not include the appropriation for GPD liaisons. 
Page 10 GAO-17-101 Homeless Veterans

veterans and families.33 Through SSVF, VA awards grants to service 

providers, which are required to provide outreach, case management, 

VA benefit assistance, and provide or coordinate efforts to obtain 

other eligible benefits and community services for the veterans. 

Additionally, service providers provide temporary financial assistance 

such as rent, utility payments, childcare, and transportation.34 Funding 

for SSVF has expanded from the initial appropriation of $60 million in 

fiscal year 2011 to about $300 million annually since fiscal year 2013.

 33A very low income veteran family is a veteran family whose annual income does not 

exceed 50 percent of the median income for an area or community. SSVF serves veterans 

and their families who are (1) “literally” homeless but who are scheduled to become 

residents of permanent housing within 90 days; (2) “literally” homeless and exited 

permanent housing within the previous 90 days in order to seek housing more responsive 

to their needs and preferences; or (3) currently residing in permanent housing but are at 

risk of becoming “literally” homeless. “Literally” homeless is defined as (1) an individual or 

family that has a primary nighttime residence that is a public or private place not designed 

for or ordinarily used as regular sleeping accommodation for human beings; (2) an 

individual or family living in supervised publicly or privately operated shelter designed to 

provide temporary living arrangements; or (3) an individual exiting an institution where he 

or she resided for 90 days or less and who resided in an emergency shelter or place not 

meant for human habitation immediately before entering that institution. 

34With the exception of service providers that received 3-year non-renewable awards in 

fiscal year 2015, SSVF grantees are not required to provide temporary financial 

assistance. However, according to VA, all SSVF service providers offer temporary 

financial assistance as of August 2016. Service providers may only provide temporary 

financial assistance if it enables the veterans and their family to obtain or retain permanent 

housing. Service providers consider the minimum amount of assistance needed to prevent 

homelessness and determine the level of assistance on a case-by-case basis. When 

service providers cover rental assistance, VA encourages them to require participants to 

share the cost of rent as a condition for receiving assistance. The service provider pays 

the rent directly to the landlord. 
Page 11 GAO-17-101 Homeless Veterans

As of September 2016, VA had developed 35 active supportive-housing 

EULs for veterans who were homeless or at risk of homelessness with 

low cost rental housing and coordinated access to medical, rehabilitative, 

and mental healthcare, as well as other services on VA campuses.35 The 

35 EULs are located in 18 states.36 Most of them provide permanent37 or 

transitional housing while 5 EULs focus on senior and assisted living (see 

fig. 2). According to VA reports, supportive-housing EULs were developed 

for homeless and at-risk veterans; however, the population served was 

expanded to include senior veterans capable of independent living and 

veterans requiring assisted-living with supportive services.38

 35VA executed 30 non-housing EUL’s prior to the enactment of legislation, which limited 

EULs to supportive-housing. See Pub. L. No. 112-154, § 211(b)(2012).

36An interactive graphic with details on the 70 EULs can be viewed at 

http://www.gao.gov/products/gao-17-101. 

37Housing is one of the highest unmet needs for homeless veterans according to VA. VA, 

The Eighteenth Annual Progress Report, Community Homelessness Assessment, Local 

Education and Networking Groups (CHALENG) for Veterans Report Fiscal Year (FY) 

2011 (Washington., DC: February 2011). 

38VA, Enhanced-Use Lease Program (Washington, D.C.; June 2016), and VA, Volume 4 

of the Department of Veterans Affairs 2016 Budget Submission. (Washington, D.C.: 

February 2015). The VA “EUL Consideration Report” is a part of the VA’s budget 

submission. According to VA officials, supportive-housing EULs can house veteran family 

members and non-veterans. However, VA only collects data on the number of veterans 

housed. 

VA Uses SupportiveHousing EULs to 

Provide Homeless 

Veterans with 

Affordable Housing 

and a Range of 

Services on VA 

Campuses

VA Uses EULs to Provide 

a Mix of Permanent and 

Transitional Housing 
Page 12 GAO-17-101 Homeless Veterans

Figure 2: Map of 35 Active Supportive-Housing Enhanced-Use Leases, 2016

As of September 2016, almost half (17 of 35) of the active supportivehousing EULs had operated for more than 5 years. Based on our analysis 

of VA data, these EULs include both “legacy” projects—those that VA 

completed prior to the BURR initiative—and those from the BURR 

initiative (see table 3 for more details on these projects).39 In 1999, VA 

and the Housing Authority of the City of Vancouver established one of the 

 39As previously noted, under the BURR initiative, VA evaluated unutilized and

underutilized land and buildings on existing VA property for potential homeless housing 

projects for veterans through both public-private collaboration and VA’s EUL program.
Page 13 GAO-17-101 Homeless Veterans

first supportive-housing EULs, consisting of 124 units.40 Additional 

supportive-housing EULs resulted in 2,391 total housing units as of 

September 2016. About 74 percent of these units provide permanent 

housing, which includes seniors’ supportive-housing and assisted-living 

facilities (see table 1). According to VA officials, its four newest facilities 

opened in 2016 in Bedford and Northampton, Massachusetts, and 

Vancouver and Walla Walla, Washington. See appendix IV for a complete 

list of all 70 supportive-housing EULs and their status—active, under 

construction, in development, pre-development, on hold, and 

terminated—from 1998 through 2016.41

Table 1: Characteristics of Active Supportive-Housing Enhanced-Use Leases (EUL) as of September 2016

Type of supportivehousing EULs Description Number of 

supportivehousing EULs

Number of 

housing units

Permanent 

supportive-housing

Long-term housing with supportive services for people experiencing or 

at risk of homelessness, including those with disabilities

18 1496

Transitional Time-limited housing that aims to facilitate the movement of homeless 

individuals and families to permanent housing within a reasonable 

amount of time (up to 24 months)

8 607

Both permanent and 

transitional

See definitions above 4 a

Senior SupportiveHousingPermanent housing for seniors age 62 and over 4 202

Assisted living Permanent housing with services for the frail elderly and people with 

disabilities who can live independently but need assistance with 

activities of daily living 

1 86

Total for active supportive-housing EULs 35 2391

Source: Analysis of Department of Veterans Affairs’ Data and Information | GAO-17-101

a

We added the housing units for this category to the permanent and transitional housing totals. There 

are four supportive-housing EULs that have transitional and permanent housing units: (1) Barbers 

Point, Hawaii; (2) Canandaigua, New York; (3) Leavenworth, Kansas; and (4) Northampton, MA. See 

app. IV for information on each EUL.

 40The units are located in Vancouver, Washington, which is about 9 miles from Portland, 

Oregon. Through this EUL, VA leased a previously vacant and undeveloped land parcel to 

the Housing Authority of the City of Vancouver. The Housing Authority then constructed a 

124-unit single-resident occupant facility and studio apartments. Veterans receive priority 

placement into 62 units of the facility and benefit from its close proximity to a VA medical 

center. 

41Appendix IV includes details on the 35 active EULs discussed in this objective.
Page 14 GAO-17-101 Homeless Veterans

VA’s supportive-housing EULs serve a smaller but growing number of 

homeless veterans in relation to the other three key homeless programs 

in our review. Although the EUL program is smaller than the other key 

programs, VA officials stated that supportive-housing EULs play an 

important role in meeting the needs of homeless veterans with a mix of 

permanent and transitional housing on VA medical campuses. 

Furthermore, VA’s Fiscal Year 2016 “EUL Consideration Report,” noted 

that the amount of housing available to veterans has increased as VA has 

identified properties for development of additional supportive-housing 

EULs. As of fiscal year 2009, VA estimated that the supportive-housing 

EUL program provided housing for an average of 536 veterans a year.42

By fiscal year 2015 (the most recent year for which VA data are 

available), supportive-housing EULs provided 1,675 veterans with 

housing.

In addition to offering housing, EULs provide access to medical and 

rehabilitative care, mental health counselling, substance abuse treatment, 

and an array of other services on VA medical campuses aimed at 

improving veterans’ health and well-being.43 According to USICH, 

supportive-housing is widely recognized as the solution for vulnerable 

people experiencing chronic homelessness who often have the greatest 

challenge in finding and remaining in permanent housing.44 Figure 3 

provides examples of services that may be available at supportivehousing EULs to support veterans’ health and wellness.

 42VA, Enhanced-Use Lease Consideration Report Fiscal Year 2009-Final Report

(Washington, D.C.: August 2010). 

43According to VA officials, VA does not require a standard set of services at each 

location.

44USICH. Opening Doors: Federal Strategic Plan to Prevent and End Homelessness 

2015. (Washington, D.C.: June 2015).

Supportive-Housing EULs 

Provide a Range of 

Services on VA Medical 

Campuses to Improve 

Veteran Health and Wellbeing
Page 15 GAO-17-101 Homeless Veterans

Figure 3: Examples of Services Offered to Improve Veterans’ Health and Well-being at Supportive-Housing Enhanced-Use 

Leases

Below are examples of the services available at some of the permanent, 

transitional, and senior living supportive-housing EUL sites we visited. For 

profiles on each of the 13 sites we visited, including information about the 

supportive services offered and the housing assistance programs, see 

appendix V.

• Lyons, New Jersey (permanent housing): According to lessee 

officials, the majority of the units receive project-based HUD-VASH 

vouchers, which provide housing subsidies and case management 

services. Other supportive services include in-home counseling and 

on-site and 24/7 on-call crisis prevention and intervention, assistance 

with applying for benefits, financial budgeting, legal assistance, and 

vocational training.

• Los Angeles, California (permanent housing): Two supportive-housing 

EUL facilities are located on the VA Sepulveda Ambulatory Care 

Center campus and specifically serve disabled veterans. These 

supportive-housing EULs receive project-based HUD-VASH 

vouchers, which provide housing subsidies, on-site case 

management, and service coordination. Other supportive services 

include job training and placement, counseling, and legal services.

• Fort Snelling, Minneapolis, Minnesota (permanent housing): Three 

full-time, on-site service coordinators focus on assisting veterans with 

independent living, education, employment, and VA services. 

According to lessee officials, supportive-housing services provide 

trauma-informed care, crisis management, academic and social 

support, and job training. These supportive-housing EULs receive 
Page 16 GAO-17-101 Homeless Veterans

project based HUD-VASH vouchers, which provide housing subsidies, 

case management, and service coordination.

• St. Cloud, Minnesota (permanent housing): Located on the St. Cloud 

VAMC, the studio units are available to veterans who are in transition 

from a chemical-dependency treatment facility and in need of 

supportive services and housing. Facility amenities include media 

rooms, a communal kitchen, and a community room.

• Hines, Illinois (transitional housing): The supportive-housing EUL 

provides transitional housing and supportive services through the 

GPD program. These services focus on chemical dependency 

recovery for residents, and include structured days, balanced meals in 

a communal dining area, rehabilitative work training, individual 

counseling, recovery groups, holistic education, and assistance with 

permanent housing placement.

• Dayton, Ohio (senior housing): The senior-living supportive-housing 

serves low income veterans age 62 and over, including supportive 

services designed to help veteran residents achieve self-sufficiency. 

The supportive-housing EUL receives housing vouchers from HUD 

programs for the elderly and low income families.

In addition to the supportive services provided for residents at supportivehousing EULs, VA and the lessee provide basic-administrative and 

operational services, such as transportation, mail delivery, and law 

enforcement. In some cases, the lessees face challenges getting these 

services up and running as the provision of these services involves 

multiple parties, for example:

Transportation: VA officials identified the need to provide transportation 

services as a challenge in cases where public transportation is not easily 

accessible to the supportive-housing EUL location. We found that several 

supportive-housing EUL sites we visited provided veterans with some 

type of transportation. For example, one lessee provided veterans 

transportation to another VA campus for psychiatric, substance abuse, 

and other specialized care. Other lessee officials said that VA provided a 

campus shuttle to medical appointments on campus or provided funds for 

public transportation. A USICH report noted that transportation is critical 

in helping connect residents in supportive-housing to jobs, schools, health 

care, and childcare.45 We previously reported on VA programs to 

 45USICH. Opening Doors: Federal Strategic Plan to Prevent and End Homelessness 

2015. (Washington, D.C.: June 2015). 
Page 17 GAO-17-101 Homeless Veterans

transport homeless veterans to VA or other private medical care in 

partnership with community-based providers.46 For example, the Veterans 

Health Administration developed the Veterans Transportation Service to 

help veterans obtain care by improving coordination with other 

transportation service providers in the community. Similarly, lessees told 

us they work with other community organizations to find transportation 

options for residents.

Mail Delivery: In some cases, supportive-housing EULs faced the 

challenge of ensuring that the U.S. Postal Service delivers personal mail 

to residents, rather than to a central location on the VA campus. For 

example, at the supportive EUL in Sepulveda, California, it took 3 years to 

work out an arrangement with the Postal Service to deliver personal mail 

directly to the residents at the housing facility. EUL residents experienced 

delays in receiving mail when the Postal Service delivered it along with all 

of the mail for the entire VA medical campus. The mail for EUL residents 

was sorted from that delivered to the VA medical campus, delivered to the 

EUL, and then sorted again for each individual resident. This was 

problematic for the residents who needed personal mail on a timely basis 

for income and benefits, such as Social Security disability checks.

Law Enforcement: VA officials noted that they have helped resolve issues 

of jurisdictional law enforcement authority between local law enforcement 

and VAMC campus police. This issue is a concern at some supportivehousing EULs because the EUL is a private residential facility located on 

a federal medical campus. Local law enforcement has jurisdiction over 

the private housing facility, and VA has jurisdiction for the part of the 

campus it operates. However, at times, it is unclear to local law 

enforcement agencies which organization is the first responder for the 

EUL facility. According to VA attorneys, a memorandum of understanding 

with local authorities to clarify first responder roles has helped some 

supportive-housing EULs to address the challenges of concurrent 

jurisdiction.

 46See GAO, Transportation-Disadvantaged Populations: Federal Coordination Efforts 

Could Be Further Strengthened, GAO-12-647 (Washington, D.C.: June 2012). 
Page 18 GAO-17-101 Homeless Veterans

In addition to the benefits to homeless veterans, our analysis of VAreported data for EULs in operation from fiscal years 2006 through 2015 

generated almost $275 million in benefits to veterans, VA, and the 

community. These benefits came in the form of lease revenue, cost 

avoidance, cost savings, and enhanced services, net of any new VA 

expenses (see table 2).47 VA’s Fiscal Year 2017 “EUL Consideration 

Report,” said that supportive-housing EULs resulted in cost savings by 

repurposing underutilized capital assets or transferring the cost to 

construct or renovate, operate, and maintain these properties to thirdparty partners (the lessees of the supportive-housing EULs).48 Further, 

allowing homeless veterans to stay in a VA medical center bed is more 

costly than providing them with supportive-housing. VA also reported 

qualitative benefits, including strengthening the network of local services 

available to veterans and developing community partnerships.

Table 2: Considerations and Veterans Affairs Expenses for 29 Supportive-Housing 

Enhanced-Use Leases (EUL) from Fiscal Years 2006 through 2015

Types of Considerations and VA Expensesa Cumulative Fiscal Years 

2006-2015 for 29 

supportive-housing EULs 

($ in millions)b

Lease Revenue—Revenue from upfront payments and 

ongoing lease payments.

3.0

Cost Avoidance—Includes any amount VA would have 

had to pay to maintain a facility and/or services in the 

absence of a supportive-housing EUL.

147.9

Cost Savings—Include any discount realized on 

necessary VA purchases, such as energy, office space, or 

parking services.

0.4

 47Under VA’s EUL program, VA can retain funds from an EUL during the lease term and 

for disposal of a leased property for certain purposes. 38 U.S.C. § 8165. Retaining these 

proceeds provides an incentive for VA to be creative and aggressively pursue 

opportunities to collaborate with both private and non-profit entities. Cost avoidance and 

cost savings include reducing the cost of operating VA’s inventory of underutilized 

buildings and land, as well as transferring maintenance costs of land and improvements to 

lessees (without incurring the cost of disposal). We calculated these numbers based on 

the information VA provided for fiscal years 2006 to 2015 on 29 VA supportive-housing 

EULs that were listed in the Fiscal Year 2017 “EUL Consideration Report.”

48VA, Volume 4 of the Department of Veterans Affairs 2017 Budget Submission

(Washington, D.C.: February 2016). The VA “EUL Consideration Report” is a part of the 

VA budget submission.

Supportive-Housing EULs 

Can also Benefit VA, 

Lessees, Developers, and 

the Local Community
Page 19 GAO-17-101 Homeless Veterans

Types of Considerations and VA Expensesa Cumulative Fiscal Years 

2006-2015 for 29 

supportive-housing EULs 

($ in millions)b

Enhanced Services—Includes the value of newly 

available services to veterans, VA employees, or the 

community

165.6

VA Expenses—Includes VA’s capital contributions to EUL 

developments and per diem payments to service 

providers

-42.2

Total 274.8 

Source: GAO analysis of Department of Veterans Affairs’ data on 29 supportive-housing EULs from the Fiscal Year 2017 “EUL 

Consideration Report.” | GAO-17-101

Note: The Fiscal Year 2017 “EUL Consideration Report” did not include data for six recently opened 

supportive-housing EULs.

a

The descriptions of Types of Considerations and VA Expenses are taken from The Department of 

Veterans Affairs Fiscal Year 2017 “EUL Consideration Report.”

b

These figures are not adjusted for inflation.

According to VA officials, supportive-housing EULs benefit most of the 

lessees and developers by providing them with long-term access to 

federal property and land at little or no cost, access that can be 

particularly beneficial for those located in high-rent markets. According to 

the VA’s Fiscal Year 2017 “EUL Consideration Report,” 18 of 29 EULs did 

not pay any lease payment in fiscal year 2015. A few lessee officials we 

interviewed said access to federal property and land at little or no cost 

helped them to rehabilitate or construct facilities, in addition to providing 

needed services to homeless veterans. In addition, lessees we 

interviewed said the close proximity to VA medical, rehabilitative, and 

mental health services allowed them to invest in other needed services 

for homeless veterans, such as employment training and quality-of-life 

amenities.

According to VA and USICH, supportive-housing EULs can also have 

benefits for the local community. Communities that added relatively more 

permanent supportive-housing units over a 6-year time frame showed 

significant decreases in chronic homelessness over time.49 Evaluations of 

permanent supportive-housing have demonstrated significant 

improvements in housing stability, reductions in days of homelessness, 

and reductions in the utilization and costs of public services such as 

emergency shelter, hospital emergency room and inpatient care, sobering 

 49USICH, Opening Doors: Federal Strategic Plan to Prevent and End Homelessness 2015

(Washington, D.C.: June 2015).
Page 20 GAO-17-101 Homeless Veterans

centers, and jails. Supportive-housing EULs also can increase the tax 

base for the local community, because, according to VA officials, the 

facility is subject to state and local taxes, which can provide new longterm revenue sources for the local economy, jobs, and tax revenues for 

local and state entities. Furthermore, we identified several studies that 

attempted to quantify benefits to local communities. For example, a 2014 

study on supportive-housing projects found that these projects create 

fiscal benefits for the state and local governments as a result of sales 

taxes collected on construction materials, income taxes paid by 

construction and other workers, and corporation or income taxes on 

profits earned by builders, developers, and other firms.50 Another study 

found that in some cases, cities and states also receive revenues from 

fees on affordable housing developments from permitting, zoning, and 

utilities.51

With the development of 35 active supportive-housing EULs, 6 

supportive-housing EULs under construction, and 16 in development (see 

table 3), VA officials told us that they believe they have identified all 

currently viable opportunities on VA campuses. They said, however, that 

they continue to look for new sites on which to develop supportivehousing as changes occur in the use of VA’s properties. Challenges that 

VA faces in developing additional supportive-housing EULs include a lack 

of clear and complete documentation of project selection and 

implementation to inform future decisions, identifying available and 

suitable property for housing for homeless veterans, stakeholder 

opposition, and limited financing options for EULs. In addition, VA has not 

revised its EUL policy to address issues specific to developing supportivehousing EULs for veterans. These include the type of housing needed to 

serve homeless veterans in the local area, or the space configuration or 

square footage needed for supportive-housing as compared with 

available VA facilities. Without such consideration, VA may be missing an 

opportunity to help address these challenges.

 50The California Department of Housing and Community Development, 2014 Affordable 

Housing Cost Study, (Oct. 6, 2014).This report was a cost study on the benefits of building 

subsidized affordable rental housing in California.

51Planning Commissioners Journal, The Economic and Fiscal Benefits of Affordable 

Housing, Number 83 (Summer 2011). 

VA Continues to 

Develop SupportiveHousing EULs, but 

Faces Challenges 

and Lacks Specific 

Policies
Page 21 GAO-17-101 Homeless Veterans

In 2009, VA launched the Building Utilization Review and Repurposing 

(BURR) initiative, which included a 2-year strategic study, to identify as 

many VA unutilized and underutilized properties as possible with the 

potential for development as new housing for homeless or at-risk 

veterans and their families. VA’s EUL authority was set to expire at the 

end of December 2011, and they intended to identify as many properties 

as possible before that deadline to support the goal of housing homeless 

veterans. According to officials, VA initially identified over 350 potential 

sites for development. By December 2011, had signed lease agreements 

for 38 sites.52 VA executed these short term-leases without completing 

the entire process for development of a supportive-housing EUL (see fig. 

1 for a description of the process) in order to meet the deadline. These 

lease agreements allow the lessee 5 years for the supportive-housing 

EUL facility to become operational.

53 VA officials did not comprehensively 

document their decision-making process for selecting the final 38 sites for 

development as supportive-housing EULs under the BURR initiative with 

a final written report or analysis. However, during the selection process, 

the Secretary of the VA signed formal decision briefings and documents 

for the individual properties. The Department entered into these 38 EUL 

agreements with lessees to develop 4,100 BURR housing units.54 As of 

September 2016, 871 of the 4,100 planned BURR units (21 percent) were 

active. In order for VA to achieve its goal by the end of December 2016, it 

would need to open an additional 3,229 units. The 35 active supportivehousing EULs are comprised of 15 BURR and 20 “legacy” projects (see 

table 3 for details on the status of these EULs).55

 52Of the 38 leases executed in 2011, 14 are active, 10 projects are in development, 5 are 

in construction, 5 are on hold, and 4 are no longer on VA’s list of supportive-housing 

EULs. In addition, VA executed an additional 7 supportive-housing leases that were not a 

part of the original 38 leases executed in 2011.

53To expedite the BURR initiative, VA modified the steps in the EUL process and 

executed interim lease agreements of 5 years in December 2011 to allow the lessees time 

to obtain financing and finalize construction plans. If lessees do not secure sufficient 

financing for construction by the end of December 2016, VA could extend the lease with 

the lessees, reassign the lease to another qualified entity, or allow the interim lease 

agreements to expire. If the interim lease agreements expire after the initial 5-year period, 

VA would need to sign amended lease agreements in order to continue pursuing the 

development at those locations. If the lessees secure financing prior to the 5-year time 

frame, VA and the lessee would then execute the lease agreement, which could be for up 

to 75 years, including the 5-year interim lease agreement. 

54VA discussed its target for BURR in its Fiscal Year 2014 “EUL Consideration Report” to 

Congress.

55“Legacy” projects were completed prior to the BURR initiative.

VA Continues to Develop 

Supportive-Housing EULs, 

but Did Not 

Comprehensively 

Document Its DecisionMaking Process for 

Selecting EULs
Page 22 GAO-17-101 Homeless Veterans

Table 3: Status of the Building Utilization Review and Repurposing initiative and the “Legacy” Supportive-Housing EnhancedUse Lease (EUL) Projects as of September 2016

Building Utilization Review and 

Repurposing initiative (BURR)

“Legacy” projects (projects Prior 

to BURR)

BURR and “legacy”

projects

EUL Projects Number of sites Number of 

units

Number of sites Number of units Total sites Total units 

Active 15 871 20 1,520 35 2,391

Construction 6 302 0 N/A 6 302

Development 15 737 1 75 16 812

On-hold 5 240 0 N/A 5 240

Terminated 0 N/A 1 N/A 1 N/A

Total 41 2,150 22 1,595 63a 3,745

Source: GAO analysis of Department of Veterans Affairs’ data and information as of September 2016. | GAO-17-101

a

VA also listed seven additional projects: five projects on hold and two projects in the predevelopment stage that are not listed in this table. For those projects, VA had not entered into a lease 

agreement with a lessee or developer. VA also did not have an estimate of how many units these 

EUL projects would provide in the future. For further information on these seven projects, see 

appendix IV, which lists all 70 projects.

VA’s EUL policy states that to enter the development phase, EUL projects 

must be identified as valid priorities and included on the Department’s 

EUL project list.56 The policy describes several steps in the development 

phase, such as: (1) a preliminary inspection of the property; (2) 

identification of physical limitations such as local, state, or federal 

limitations on the site (e.g., zoning, environmental, or historic 

preservation); and (3) a preliminary asset valuation. It also requires 

collecting documentation about the site, such as title files, flood plain 

maps, and local zoning and code requirements. The policy further states 

that milestones, approvals, and supporting documents that occur during 

each phase of the process must be reported and attached in VA 

databases and that the office responsible for the project will ensure that 

all “reportables” are appropriately and accurately recorded.57

Furthermore, VA policy states that the Office of Asset Enterprise 

Management is responsible for establishing policies, procedures, 

guidelines, and assuring proper documentation for the EUL program. In 

the case of these 38 sites, under the expedited leasing process, VA 

 56Department of Veterans Affairs, VA Handbook 7415 Enhanced-Use Leasing Program

(Washington, D.C: Dec. 21, 2011).

57The policy refers to the Capital Asset Management System’s and the Capital Asset 

Inventory’s databases. 
Page 23 GAO-17-101 Homeless Veterans

completed some, but not all, of the steps in the development phase 

before entering into short-term leases. VA officials said they outlined the 

required transaction details needed to be completed before finalizing the 

EUL agreement, such as a development plan, financing, and 

environmental, and historic compliance. For example, VA analyzed the 

physical potential for housing, need for housing, and potential financing 

availability for the projects. However, VA officials did not consistently 

assess the same conditions for each site. In some cases, they 

documented known historic preservation or environmental issues but not 

in others. VA officials intended the short-term five-year leases to allow for 

the additional steps in the development process, but they did not clarify in 

their BURR documents the steps they had completed before signing the 

leases and those they planned to complete later. This lack of clarity made 

it difficult to assess how VA officials complied with their own policy. VA 

could not provide us with a final summary report or analysis documenting 

the BURR initiative. For the final site selection, VA officials provided us 

with documents of EUL sites with differing information. Initially, VA 

provided us with a document entitled “Draft BURR Site Priority for 

Housing Reuse,” dated December 2010, which included basic information 

on 39 sites (rather than the final 38), such as square footage, physical 

potential for housing, need for housing, and financing availability.

However, this document did not include 21 of the 38 lease agreements. 

Subsequently, they provided us with a BURR project list from the third 

quarter of 2011 that did not mention 19 of the 38 lease agreements. 

Further, since the time that VA identified the 38 sites, some of those sites 

are no longer on the list, and additional sites are now categorized as 

BURR projects, making it difficult to reconcile the original list with 

subsequent updates. Federal Standards for Internal Control states that 

documentation is required for the effective design, implementation, and 

operating effectiveness of a federal program, and that management 

considers the impact of deficiencies identified in achieving documentation 

requirements.58 In addition, management clearly documents internal 

control and all transactions and other significant events in a manner that 

allows the documentation to be readily available for examination. Further, 

management designs control activities so that all transactions are 

completely and accurately recorded. This type of readily available, clear, 

and complete documentation of the EUL projects could have allowed VA 

to more effectively implement the supportive-housing EUL program by 

 58GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C: September 2014).
Page 24 GAO-17-101 Homeless Veterans

excluding sites that it later found it could not develop. We discuss 

examples of such cases in the next section of this report.

In 2014, VA conducted a second nationwide housing-needs analysis to 

determine whether any additional opportunities existed to develop 

supportive-housing EULs. However, according to officials this 

assessment did not identify any new properties. Additionally, they told us 

that, after further research, they found that some of the properties initially 

identified as part of the BURR process were not suitable for housing for 

homeless veterans or were not available for development. As such, the 

Department may not have property available for repurposing as 

supportive-housing in a particular location even where they have 

identified a need for housing based on the homeless veterans’ population 

in that area or where they have initially identified unused or underutilized 

property for that purpose, for example:

• Castle Point, New York, more than 30 months after VA announced it 

would develop supportive-housing at the site, VA discontinued its 

plans because additional analysis found that the site contained six 

unofficial and unauthorized landfills, making the property unsuitable.

• Chicago, Illinois: VA identified a 26,500 square foot building on the 

North Chicago VA campus and, in June 2011, announced it would 

develop a supportive-housing project at that site. Based on additional 

analysis, officials found that the VAMC was using part of the building 

for other purposes and, as such, the officials could not develop the 

property.

• Long Beach, California: VA identified 2 parcels of land totaling 10 

acres at the VAMC Campus in Long Beach, California, part of Los 

Angeles county, which has the highest number of homeless 

veterans—approximately 2,700—in the United States. VA officials 

announced in June 2011 that they would develop a supportivehousing EUL on the Long Beach site, but later found that, due to the 

extent of other construction projects on the campus, there were no 

longer any underutilized facilities.

• Spokane, Washington: VA officials discovered that the land identified 

for development belonged to the State of Washington, and not VA, 30 

months after they had announced plans for a supportive-housing EUL 

on the property, and they had to cancel the project.

Additional properties initially identified as part of the BURR process 

remain on hold because they may not be suitable for development for 

VA Faces a Challenge in 

Identifying Available and 

Suitable Properties for 

Additional EULs
Page 25 GAO-17-101 Homeless Veterans

supportive-housing. VA officials stated that they would let the interim 

leases expire at the end of the term in December 2016, for example:

• Bath, New York: The property VA selected for development was 

located in a flood plain with a 1 percent chance of flooding. As a 

result, the developer could not obtain financing for the project. VA 

subsequently offered a second property, not located in the flood plain, 

to the developer; however, the local community withdrew its support 

for the project because of concerns about the cost of the project and 

about formerly homeless veterans moving into the area. 

Subsequently, the project could not move forward because it did not 

obtain state funding.

• Salem, Virginia: After entering into a lease agreement, VA found there 

was an insufficient homeless veteran population in the area to support 

the project as envisioned.

Our findings echo those of the VA’s Office of Inspector General (OIG) in 

February 2012—that major decisions were not always documented in 

EUL project files or populated in the VA’s database, as required by VA 

policy.

59 For these reasons, the OIG reported that it was unable to 

determine whether the selection process was appropriate and fair.60

Moreover, without clear and complete records that can provide 

institutional knowledge to inform future decisions, VA cannot be sure that 

it is making the best decisions in identifying real property for use as 

supportive-housing for homeless veterans.

According to VA officials and lessees we interviewed, stakeholder support 

is crucial to developing supportive-housing EULs, and opposition has 

prevented or delayed some EUL projects. Our prior work has consistently 

found stakeholder resistance to locating federal homelessness programs 

in some communities.61 Stakeholders for supportive-housing EULs 

represent many different groups, including veterans, local and national 

 59The Capital Asset Management System (CAMS). 

60VA, Office of Inspector General, Office of Audits and Evaluations, Audit of the 

Enhanced-Use Lease Program, (Washington, D.C.: Feb. 29, 2012).

61See, for example, GAO, Federal Real Property: More Useful Information to Providers 

Could Improve the Homeless Assistance Program, GAO-14-739 (Washington, D.C.: Sept. 

30, 2014) and GAO, Rural Homelessness: Better Collaboration by HHS and HUD Could 

Improve Delivery of Services in Rural Areas, GAO-10-724 (Washington, D.C.: July 20, 

2010).

VA Faces Challenges with 

Stakeholder Opposition to 

Some Supportive-Housing 

EULs
Page 26 GAO-17-101 Homeless Veterans

veteran support organizations, the local community, state and local 

government, and developers. VA officials told us that reaching agreement 

with all stakeholders can be challenging, and objections from any one of 

these groups could delay or prevent a project from going forward. The 

officials provided us with several examples of cases in which the local 

community did not want formerly homeless individuals living nearby (in 

Perry Point, Maryland, and Los Angeles, California). Or veterans wanted 

VA to improve the medical facilities on the campus rather than lease the 

property to a private developer for supportive-housing for veterans and 

their families (in Queens, New York, and West Los Angeles). In some 

cases, legislation was introduced to stop supportive-housing EUL 

projects.62 Additionally, in West Los Angeles, a 2007 law prohibited VA 

from selling or exchanging land on the medical campus.63 According to 

VA officials, this prohibition resulted largely from veterans’ opposition to 

VA’s use of property for any purpose but direct services to veterans. 

According to VA officials, VA could not proceed with its draft master plan 

for 1,200 units of supportive-housing without a change in this law. VA 

officials also provided us with examples of approaches they used to 

address stakeholder opposition. For example, in the case of the West Los 

Angeles campus, they held an estimated 100 town hall meetings with 

various community groups to hear their concerns about locating 

supportive-housing EULs on-site. VA officials also said they collected 

more than 1,000 comments on the draft master plan and, in response to 

these comments, modified the plan to add a town center, redesign the 

flow of traffic, and increase the planned housing units from 900 to 1,200. 

Subsequently, the West Los Angeles Act of 2016 was enacted, which 

authorizes VA to enter into enhanced-use leases at the West Los Angeles 

VAMC for the purposes of providing supportive-housing to benefit 

veterans and their families, and permits VA to proceed with its draft 

master plan.64

 62H.R. 1799, 112th Cong. (2011). 

63Pub. L. No. 110-161, § 224(a)(2007).

64Pub. L. No. 114-226 (2016).
Page 27 GAO-17-101 Homeless Veterans

Lessees rely on multiple funding sources for both capital and operational 

financing, including, the Low Income Housing Tax Credit (LIHTC) 

program,65 government grants, low-interest federal loans, and rental 

subsidies for residents. According to a senior official of the National 

Equity Fund—an organization that specializes in financing affordable 

housing with LIHTCs—these resources play a key role in creating 

affordable rental housing for veterans. VA officials told us that HUDVASH project-based vouchers are important to EUL projects for rental 

payments as they are attached to the project for a period of 15 years. The 

process of obtaining funding for supportive-housing projects can be highly 

competitive, and the EUL lessees have to meet program requirements for 

each funding source from government and private entities, such as the

HUD-VASH or LIHTC. In other cases, however, lessees have 

successfully obtained a range of financing sources to develop a 

supporting-housing EUL. Figure 4 illustrates the complexity of financing 

necessary for a supportive-housing EUL in Minnesota.

 65Under the Low Income Housing Tax Credit (LIHTC), state and local agencies issue tax 

credits to individuals and corporate investors in order to encourage the investment of 

private equity in the acquisition, rehabilitation, or new construction of rental housing 

targeted to lower-income households.

Obtaining Financing for 

Supportive-Housing EULs

Poses Challenges
Page 28 GAO-17-101 Homeless Veterans

Figure 4: Example of Financing for a Supportive-Housing Enhanced-Use Lease at 

Fort Snelling in Minneapolis, Minnesota

VA’s existing policies for the EUL program are outdated and reference the 

EUL authority from 1991, which is no longer in effect.66 As discussed 

earlier, prior to 2012, VA’s EUL authority allowed it to develop a wide 

range of projects where the EUL contributed to VA’s mission, enhanceduse of the property, and would not adversely affect VA’s mission. In 

August 2012, legislation was enacted that limited VA’s EUL authority to 

the development of supportive-housing for homeless veterans.67 VA’s 

policy does not discuss the current program mission—to provide 

 66VA’s policies includes VA, VA Handbook 7415 Enhanced-Use Leasing Program

(Washington, D.C: Dec. 21, 2011); VA, VA Directive 7415 Enhanced-Use Leasing 

Program (Washington, D.C: Dec. 21, 2011); VA, VA Directive 7454 (Washington, D.C: 

June 29, 2012), and VA, VA Handbook 7454 (Washington, D.C: June 29, 2012). 

6738 U.S.C. § 8162. 

VA’s EUL Policies and 

Procedures Are Outdated 

and Are Not Specific to 

Supportive-Housing for 

Homeless Veterans
Page 29 GAO-17-101 Homeless Veterans

supportive-housing for homeless veterans—or outline specific 

considerations—such as addressing stakeholder opposition and obtaining 

financing for supportive-housing EULs. Identifying and developing real 

property to meet the housing and supportive service needs of homeless 

veterans is different from identifying and developing real property for 

other types of EULs, such as administrative offices, parking, hospice 

centers, and child-care facilities. Federal Standards for Internal Control

state that management should periodically review policies, procedures, 

and related control activities for continued relevance and effectiveness in 

achieving the entity’s objectives or addressing related risks.68 VA reported 

that it updated its policy Directive and Handbook 7454 in June 2012.69

However, that update did not address the current EUL authority, 

specifically the inclusion of the provision that EULs can only provide for 

housing for homeless veterans. Further, the update did not revise the 

development phase of its process to address relevant needs for 

supportive-housing for homeless veterans, such as the type of housing 

needed for the local area or the space configuration or square footage 

needed for supportive-housing as compared with available VA property. 

VA officials told us that they had not updated the policy Handbook to 

address the changes in the current law because they were anticipating an 

amendment to its EUL authority that would again allow the use of EULs 

for purposes other than supportive-housing for homeless veterans.

As of October 2016, VA officials told us that they were in the process of 

revising the Handbook to address the current EUL authority and related 

information such as financing options, which may be useful for lessees, 

and that they expected to complete it by December 2016. VA officials said 

they expect to update other EUL policies during fiscal year 2017. The 

draft that VA shared with us requires an analysis of the local market, 

including current and anticipated supply and demand conditions affecting 

the project. However, it does not specifically provide direction on how to 

determine whether a proposed supportive-housing EUL meets the need 

for homeless veteran housing in the local area or discuss VA’s limited 

authority to provide housing for homeless veterans. VA officials told us 

that they do assess whether the homeless veteran population can benefit 

from supportive-housing in the area of a proposed EUL. For example, 

 68GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C: September 2014). 

69VA, Enhanced-Use Leasing with the Annual Consideration Report, (Volume 4 of the 

2014 Budget Submission) Fiscal Year 2012 (Washington, D.C. April 2013).
Page 30 GAO-17-101 Homeless Veterans

since 2013, VA has conducted a gap analysis as part of its effort to 

determine the need for homeless veteran programs such as HUD-VASH, 

SSVF, and GPD. However, this assessment is not included in the draft 

Handbook. Without policies and procedures that address needs specific 

to supportive-housing for homeless veterans, VA may not be well 

positioned to identify viable supportive-housing EUL projects and help 

ensure that those projects are successfully developed. As a result, VA 

may not be making the most effective use of public resources to serve 

homeless veterans.

HUD-VASH, GPD, and SSVF each differs in its eligibility requirements 

and the population it serves (see app. III). Program eligibility, resource 

availability, and veteran choice determine veteran program participation. 

USICH, VA, and HUD have advocated placing veterans and their families 

in permanent housing through HUD-VASH and SSVF and using GPD’s 

service-intensive transitional housing only if veterans refused permanent 

housing. However, USICH officials stated that they recognize that 

veterans should be provided meaningful choices, and USICH guidelines 

on ending veteran homelessness recognize that some veterans may 

decline permanent housing and choose to enter GPD or other transitional 

housing.

Each of the three programs provides a range of supportive services to 

veterans (see table 4). Case management services, which vary by the 

level of veteran engagement and need, are required in the HUD-VASH 

program and generally required in the SSVF program.70 VA officials 

stated that veteran participation in other supportive services provided by 

HUD-VASH, GPD, and SSVF is voluntary and dependent on program 

design and veteran needs. Eligible veterans may use any of the three 

programs, but there are limits on the extent to which they may do so 

concurrently. For example, generally an SSVF participant cannot receive 

rental assistance as part of SSVF’s temporary financial assistance 

payments while also receiving a housing subsidy through a HUD-VASH 

voucher.71 VA officials stated that VA tracks the number of veterans 

 70VA officials stated that generally the SSVF program requires case management. There 

are however, exceptions to requiring case management, such as when the SSVF program 

assists HUD-VASH program participants solely for move-in. In such instances, HUDVASH provides the case management.

71However, there are instances when SSVF may provide rental assistance for HUD-VASH 

participants who are in arrears on their rent and facing homelessness due to an impending 

eviction. SSVF can also assist HUD-VASH participants with move-in expenses. 

VA Uses Three 

Additional Key 

Programs to Provide 

Housing Assistance 

and Supportive 

Services to Homeless 

Veterans
Page 31 GAO-17-101 Homeless Veterans

participating in HUD-VASH, GPD, and SSVF, but generally does not track 

the number of veterans using the individual services in association with 

each program.72

Table 4: Services Available for Homeless Veterans from the Three Key Veterans 

Housing Programs, as of September 2016

HUD-VASH GPD SSVF

Permanent housing subsidies 

Case management   

Temporary financial assistance payments (e.g., 

utility, childcare, security deposits, moving 

costs)a



Homeless prevention 

Outreach   

Assistance in obtaining permanent housing   

Coordinate or provide primary health care, 

mental health care, and substance abuse 

treatmentb

  

Food assistancec  

Educationd  

Employment assistancee   

Transportation  

Assistance in obtaining other federal, state, and 

local assistance

  

Source: GAO review of documents from Department of Veterans Affairs. | GAO-17-101

Note: HUD-VASH is Department of Housing and Urban Development and Department of Veterans 

Affairs Supportive-Housing, GPD is Grant and Per Diem, and SSVF is Supportive Services for 

Veteran Families.

a

Eligible financial assistance payments in SSVF consist of rental assistance; utility-fee payment 

assistance; deposits; moving costs; transportation; general housing stability assistance; and 

childcare.

b

Veterans in the HUD-VASH program may receive referrals to Department of Veterans Affairs 

medical centers (VAMC) for primary health care, mental health care, sand substance abuse treatment 

services. GPD service providers may directly provide health care, mental health, and alcohol abuse 

treatment and other substance abuse services; they may additionally help veterans obtain other types 

of assistance for these services. SSVF service providers connect participants to primary health care, 

mental health treatments, and substance abuse service through the local VAMCs.

c

GPD is the only program that may provide food directly to veterans. Veterans participating in HUDVASH and SSVF may receive referrals to other food assistance programs; however, SSVF service 

providers can provide food on a temporary basis to address an emergency.

 72VA officials stated that the HUD-VASH program can track who participates in case 

management, but not the intensity of those services.
Page 32 GAO-17-101 Homeless Veterans

d

GPD is the only program that may provide education directly. SSVF provides limited assistance for 

expenses related to education. Additionally, HUD-VASH and SSVF service providers may refer 

participating veterans to other education programs.

e

SSVF provides limited assistance for expenses related to employment. Additionally SSVF service 

providers refer veterans to services that foster job readiness and workforce participation.

From fiscal year 2012 to fiscal year 2016, almost twice as many 

chronically homeless and vulnerable veterans used HUD-VASH vouchers 

to find housing, from about 37,000 in fiscal year 2012 to about 72,500 in 

fiscal year 2016, as reported by VA (see table 5).73 VA’s data showed that 

as of September 30, 2016, 72,481 formerly homeless veterans were living 

in HUD-VASH supported housing; this number represents about 92.3 

percent of the vouchers that HUD authorized, exceeding VA’s target of a 

92 percent utilization rate.74 In addition, public-housing authorities issued 

about 5,100 (6.5 percent) vouchers to veterans who were still trying to 

find housing and about 1,300 (1.7 percent) vouchers were reserved for 

veterans undergoing public-housing-authority application processing. VA 

also targets the percentage of veterans housed within 90 days of 

admission to the HUD-VASH program at 65 percent and reported the 

fiscal year-to-date measurement for September 30, 2016 as 58 percent.75

Table 5: Department Of Housing and Urban Development’s and Department Of Veterans Affairs’ Supportive-Housing (HUDVASH) Program Reported Housing Outcomes (Fiscal Years 2012 through 2016)

Fiscal Year

2012 2013 2014 2015 2016

Total number of veterans housed through 

HUD-VASH

37,265 45,153 51,913 63,039 72,481

HUD-VASH utilization rate (percentage)a 92 92 91 92 92

Percentage of veterans housed within 90 

daysb — — 63 66 58

Source: GAO review of documents from Department of Veterans Affairs. | GAO-17-101

a

For fiscal years 2012 and 2013, the performance target was 90 percent. From fiscal year 2014 to 

present, the performance target is 92 percent.

 73VA officials stated that the voucher usage at any point in time may not be 100 percent 

due to turnover in program participants and because veterans could not yet find housing. 

74VA officials stated that HUD-VASH data for fiscal year 2016 are based on voucher 

allocations for fiscal years 2008 through 2015; fiscal year 2016 vouchers are not counted 

in performance until fiscal year 2017.

75The calculation for days to moving into housing starts when VA admits a veteran to case 

management.

Each Year Since 2012, 

HUD’s and VA’s 

Supportive-Housing 

Vouchers Have Housed 

More Chronically 

Homeless and Vulnerable 

Veterans, but Locating 

Housing in Some Markets 

Is Difficult
Page 33 GAO-17-101 Homeless Veterans

b

The Department of Veterans Affairs created the performance measure in fiscal year 2014. The 

performance target is 65 percent for 2014 to present. Data were not available for fiscal years 2012 

and 2013.

Service providers at several supportive-housing EULs we interviewed 

said that they accept tenant-based HUD-VASH vouchers or have some 

residents who hold these vouchers.76 The total number of veterans 

subsidized by tenant-based HUD-VASH vouchers at supportive-housing 

EULs is unknown because VA does not specifically track the usage of 

tenant-based vouchers at these locations. However, VA does track the 

number of project-based HUD-VASH vouchers allocated to EULs. From 

fiscal years 2010 through 2016, HUD allocated 942 project-based HUDVASH vouchers through HUD’s set-aside award process to 22 

supportive-housing EULs.

According to VA and HUD officials, as well as officials from the National 

Alliance to End Homelessness, some veterans may not be able to use 

their HUD-VASH vouchers because they face difficulties finding 

affordable and suitable housing in certain housing markets. For example, 

the maximum allowable amount of HUD-VASH housing assistance 

payments may be inadequate in some areas, and low rental vacancy 

rates in some markets have resulted in a lack of housing availability for 

veterans.77 National Alliance to End Homelessness officials stated while 

the housing assistance payments from HUD-VASH were supposed to 

keep up with increasing rental rates, this has not been the case. To 

address this issue, HUD officials stated that HUD has granted permission 

for some public-housing authorities to increase the housing assistance 

payments for housing in some high cost cities.78 Officials in the city of Los 

Angeles stated that the city received an increase in housing assistance 

payments in February 2016 and that as of August 2016, about half of the 

veterans found housing using the higher housing assistance payment 

 76As discussed above, tenant-based vouchers move with the tenants as they move to 

different residences. In contrast, project-based vouchers are tied to the housing project 

awarded and do not move with the tenants. HUD awarded set-aside project-based HUDVASH vouchers in fiscal years 2010, 2014, and 2015.

77Public-housing authorities establish payment standards that fall within 90 to 110 percent 

range of HUD’s Fair Market Rent schedule for different areas of the country. The Fair 

Market Rent is the cost of standard, non-luxury housing in the community. The payment 

standard is the maximum subsidy a public-housing authority can pay on behalf of a family 

receiving HUD-VASH voucher.

78Public-housing authorities can apply for exception payment standards that go above the 

110 percent threshold of HUD’s Fair Market Rent for an area, up to 120 percent.
Page 34 GAO-17-101 Homeless Veterans

amount. However, the low vacancy rate in Los Angeles still presents a 

challenge for the time it takes to find housing using HUD-VASH vouchers. 

Los Angeles county officials stated that as compared to the prior year, the 

average number of HUD-VASH voucher holders who found housing 

increased. However, in addition to housing assistance payments, Los 

Angeles county officials pointed to other efforts, such as providing 

incentives to landlords to hold vacant units for veterans and increasing 

the number of staff and housing locators for HUD-VASH, as contributing 

to the increase. According to VA officials we interviewed, some veterans 

may also have difficulty finding housing that complies with HUD’s housing 

quality standards. HUD and VA officials stated that they are working to 

raise landlords’ awareness of the HUD-VASH program.

Agency data and studies we reviewed indicate that HUD-VASH vouchers, 

which veterans may use for as long as needed, are associated with stable 

housing and staying with the program for several years. One study, 

published in 2010, found that veterans who used the vouchers tended to 

participate in the program for over 2 years and another academic study, 

published in 2013, found that 93 percent of veterans who used the 

vouchers stayed in housing for at least 1 year.79 HUD estimated that 

HUD-VASH voucher turnover was about 8,400 for calendar year 2015, 

which may include veterans who no longer needed the vouchers, as well 

as those veterans who “negatively exited” the program.80 One of the 

studies cited earlier, for example, found that about half of the veterans 

who left the program left because they were over the income limit or no 

longer needed the program.81 VA data indicated that for fiscal year 2016, 

the percentage of veterans negatively exiting from the program was 16.4 

percent, meeting VA’s target of 18 percent or less.82 Representatives 

 79Maria O’Connell, Wesley Kasprow, and Robert A. Rosenheck, “National Dissemination 

Of Supported Housing in the VA: Model Adherence Versus Model Modification,”

Psychiatric Rehabilitation Journal, vol.33, no. 4 (2010) and Ann Elizabeth Montgomery, 

Lindsay Hill, Vincent Kane, and Dennis P. Culhane, “Housing Chronically Homeless 

Veterans: Evaluating the Efficacy of a Housing First Approach to HUD-VASH,” Journal of 

Community Psychology, vol.41, no.4 (March 2013).

80VA officials stated that negative exits include instances where veterans violated program 

rules, failed to comply with program requirements, or left without consultation with staff.

81O’Connell, Kasprow, and Rosenheck, “National Dissemination of Supported Housing in 

the VA,” 308.

82VA calculates the negative exit rate by dividing the number of exits from the HUD-VASH 

program in which a housed veteran had a negative discharge by the total number of 

veterans with an exit date from the HUD-VASH program.
Page 35 GAO-17-101 Homeless Veterans

from three locations USICH certified as having ended veteran 

homelessness (Virginia, Las Vegas, and Houston) stated that the HUDVASH program was instrumental in ending chronic veteran homelessness 

in their communities.

From fiscal years 2012 through 2016, the number of veterans served by 

the GPD program, as reported by VA, remained relatively steady (see 

table 6). In the same period, the number of beds available through the 

program increased in fiscal years 2013 and 2014, but fell in 2015 and 

2016, with a decline of about 700 beds in fiscal year 2016 as compared to 

fiscal year 2015. VA reported that from fiscal years 2012 through 2016, 

the average length per stay for GPD participants ranged from 183 to 201 

days. As of August 2016, service providers at five supportive-housing 

EUL sites provided GPD program services, including 214 transitional 

beds.

Table 6: Grant and Per Diem (GPD) Program Reported Transitional Housing Outcomes (Fiscal Years 2012 through 2016)

Fiscal Year

2012 2013 2014 2015 2016

Number of veterans served through GPDa 41,572 45,690 45,232 44,090 44,695

Number of GPD beds 14,792 15,546 15,656 14,577 13,859

Percentage of GPD participants exiting to 

permanent housingb 60 65 70 70 72

Number of participants exiting directly to 

permanent housing

11,656 13,057 13,868 14,418 15,399

Number of participants exiting from GPD 

programc 19,106 19,984 20,132 20,579 21,437

Source: Department of Veterans Affairs’ data. | GAO-17-101

a

This is the unduplicated count of veterans that received a homeless service related to GPD, 

including at least one day of transitional housing.

b

This percentage was calculated using “the number of participants exiting directly to permanent 

housing” and the “number of participants exiting the GPD program.”

c

The number of participants exiting from the GPD program excludes veterans who (1) had a length of 

stay for 7 days or less; (2) were ineligible for VA health care; (3) were deceased prior to discharge; 

(4) were readmitted to another GPD program within one day of discharge; and (5) transferred to 

another residential program for administrative reasons.

As part of VA’s plan to end veteran homelessness, VA called for 

transitional housing programs to focus on discharging veterans directly to 

permanent housing. The GPD program set a target of 65 percent for 

The Number of Veterans 

Served by the Grant and 

Per Diem Program has 

Remained Relatively 

Steady, and VA Is 

Encouraging Program 

Modifications to Better 

Support Permanent 

Housing
Page 36 GAO-17-101 Homeless Veterans

veterans that entered transitional housing to leave the program for 

permanent housing in fiscal year 2014 and reported that it exceeded 

those targets in fiscal years 2014 through 2016 (see table 6). In fiscal 

year 2014, VA also set the target for negative exits from the program at 

30 percent; VA reported that GPD negative exits were below the target 

rate for fiscal years 2014 through 2016. Those negative exits included 

instances where veterans violated program rules, failed to comply with 

program requirements, or left without consultation with staff.

In March 2016, VA issued guidance encouraging GPD service providers 

to adjust their provision of transitional housing by allocating some of their 

GPD beds toward bridge housing. Bridge housing generally provides 

beds for short-term stays (up to 90 days) when a veteran (who may not 

be in the GPD program) has been offered and accepted permanent 

housing assistance, but that housing is not yet available. VA stated in its 

guidance that adding bridge housing would help the GPD program to 

better align with VA’s strategy of quickly placing homeless veterans into 

permanent housing without encountering barriers. Officials from USICH 

and representatives from the city and county of Los Angeles and the 

Commonwealth of Virginia, stated that some GPD programs have 

historically placed restrictions on entering the program, such as requiring 

veterans to obtain substance abuse treatment prior to obtaining housing. 

In conjunction with VA’s guidance, USICH has encouraged communities 

to limit the use of GPD service-intensive transitional housing and to use 

transitional housing as “bridge housing” whenever possible to limit 

restrictions to entry.

Veterans and their family members participating in the SSVF program 

increased from about 33,000 in fiscal year 2012 to about 157,000 in fiscal 

year 2015, then declined by about 8,500 in fiscal year 2016, as reported 

by VA (see table 7). VA officials explained that the program’s expansion 

had coincided with increased fiscal year funding. VA officials additionally 

stated that, while the number of participants served in fiscal year 2015 

declined, placements into permanent housing through the program 

increased mostly due to rapid re-housing efforts. For SSVF’s 

homelessness prevention efforts, VA reported that in fiscal year 2016, the 

program prevented about 92 percent of at-risk program participants from 

becoming homeless. The program rules also require service providers to 

use at least 60 percent of SSVF resources toward rapid re-housing 

Supportive Services for 

Veteran Families Program 

Participation and Rental 

Assistance Have 

Increased Substantially in 

the Past 4 Years
Page 37 GAO-17-101 Homeless Veterans

intervention but set a goal of 70 percent.83 VA reported that in fiscal year 

2016, about 70 percent of veteran households that SSVF served received 

rapid re-housing interventions, resulting in 78 percent of the participating 

households being discharged to permanent housing. Factors such as a 

veteran’s income and existence of disability affect the placement rate. 

VA’s data showed that those with higher monthly incomes were more 

likely to move into permanent housing upon leaving the program. 

Conversely, VA stated that disability could be a barrier to housing 

placement. In fiscal year 2014, VA found that more than half (55 percent) 

of the veterans participating in the program had a disabling condition.

Table 7: Reported Outcomes for the Program of Supportive Services for Veteran Families (SSVF) Fiscal Years 2012 through 

2016

Fiscal Year

2012 2013 2014 2015 2016

Number of Supportive Services for 

Veteran Families’ participants (including 

family)

32,676 65,303 127,829 157,416 148,885

Percentage of participating homeless 

veteran families rapidly re-houseda 79 80 74 73 78

Percentage of participating veteran 

families at risk for homelessness 

prevented from becoming homeless

91 90 88 85 92

Source: Department of Veterans Affairs’ data. |GAO-17-101

a

VA officials stated that Supportive Services for Veteran Families (SSVF) does not set a target for 

rapid re-housing efforts because that may discourage service providers from serving high-barrier, 

homeless households, however, VA does monitor program outcomes.

Rental assistance made up the majority of the temporary financial 

assistance provided through SSVF, followed by funding for housing 

security deposits (see table 8). At several supportive-housing EUL sites, 

service providers we spoke with stated that SSVF provided assistance, 

such as security deposits to veterans. However, the number of veterans 

that received SSVF assistance in conjunction with supportive-housing 

EULs is unknown because VA does not specifically track how many 

veterans access SSVF at supportive-housing EUL sites. SSVF focuses 

on short-term interventions. For example, VA officials stated that from 

 83VA officials stated that SSVF does not set a target for discharges to permanent housing 

as a result of rapid re-housing efforts because that may discourage service providers from 

serving high-barrier, homeless households; however, VA does monitor program 

outcomes. 
Page 38 GAO-17-101 Homeless Veterans

fiscal year 2012 through 2015, participants received rental assistance 

ranged from 93 to 109 days.

Table 8: Temporary Financial Assistance Provided through Supportive Services for Veteran Families (Fiscal Years 2012 

through 2015, Dollars in Millions)

Fiscal Year

2012 2013 2014 2015

Rental assistance 10.6 19.7 63.6 63.1

Housing security deposit 5.3 8.5 19.9 20.8

Utilities 1.0 2.0 5.9 5.8

Other types of financial assistancea 1.6 2.1 11.6 11.2

Total 18.5 32.3 101.0 100.9

Source: GAO presentation of Department of Veterans Affairs’ data. |GAO-17-101

a

Other types of financial assistance include transportation, emergency housing assistance, moving 

costs, purchase of emergency supplies, childcare, and other costs.

Two studies found the SSVF program helped veterans to maintain 

housing. A 2014 VA study found that the vast majority of veterans who 

participated in SSVF did not experience an episode of homelessness 1 

year subsequent to the program.84 Another research study, published in 

2015, found that a majority of veterans had either maintained their 

housing (in the case of prevention efforts) or obtained housing (in the 

case of rapid-re-housing efforts) 2 years after exiting the SSVF 

program.85 Representatives we interviewed from New Orleans and the 

Las Vegas metropolitan area said that the SSVF program was 

instrumental for rapidly re-housing veterans. Additionally, representatives 

from Houston stated that SSVF created new resources outside of existing 

programs that helped in ending veterans’ homelessness. Representatives 

from New Orleans stated that most of the currently homeless veterans in 

their area are recently homeless or transient, and generally have less 

severe health or disability issues in comparison to populations of 

 84Thomas Byrne, VA National Center on Homelessness Among Veterans, U.S. 

Department of Veterans Affairs, Housing Outcomes of Veterans Following Exit from the 

Supportive Services for Veteran Families Program, (Philadelphia, PA: February 2014). 

85VA jointly conducted this study with academics from University of Pennsylvania and 

Boston University. Thomas Byrne, Dan Treglia, Dennis P. Culhane, John Kuhn and 

Vincent Kane, Housing Policy Debate, Predictors of Homelessness Among Families and 

Single Adults After Exit From Homelessness Prevention and Rapid Re-Housing Programs: 

Evidence From the Department of Veterans Affairs Supportive Services for Veteran 

Families Program (Sept. 14, 2015).
Page 39 GAO-17-101 Homeless Veterans

homeless veterans that received housing in the past. They anticipate that 

SSVF, more than other programs, will help recently homeless veterans.

VA has collaborated with other federal agencies, lessees, and homeless 

service providers to increase the number of supportive-housing EULs and 

help veterans obtain housing, health care, and other services through 

HUD-VASH, GPD, and SSVF programs. Within a 2-year time frame, the 

BURR initiative identified and VA executed interim leases for 38 sites for 

development as supportive-housing EULs. However, VA officials did not 

completely document their decision-making process for selecting 

properties, or other key information, as required by standards for internal 

control and their own policy. Without such documentation, VA cannot 

systematically make use of the knowledge gained from this initiative to 

help identify and develop future properties as supportive-housing EULs. 

In the future, documenting the steps taken to identify and develop these 

sites, as well as the additional information required by VA policy, could 

help VA ensure that the properties it identifies are viable for meeting 

veterans’ needs for supportive-housing. Further, VA has not updated its 

policy to reflect the 2012 change in its EUL authority limiting it to solely 

developing supportive-housing EULs for veterans. Federal Standards for 

Internal Control state that management should periodically review policies 

and related control activities for relevance and effectiveness in achieving 

the entity’s objectives. At the completion of our audit work, VA officials 

told us that they were in the process of updating their policy and expected 

to complete it by the second quarter of 2017. In addition to the lack of 

consistency with the current authority, VA has not specified in its policy 

how identifying properties for use as supportive-housing EULs for 

veterans differs from other types of EULs the agency has used in the 

past. Incorporating these changes into its policy may better position VA to 

identify feasible projects as well as potential delays in completing those 

projects, thereby allowing the VA to expedite development of additional 

supportive-housing EULs. With improved documentation and policies, VA 

may make a greater contribution toward ending veterans’ homelessness.

To improve VA’s supportive-housing EUL program and meet the needs of 

homeless veterans, we recommend that the Secretary of Veterans Affairs 

should direct the Office of Asset Enterprise Management to take the 

following two actions:

• clearly and completely document the selection process for all 

supportive-housing EULs from pre-development through completion 

Conclusions

Recommendations for 

Executive Action
Page 40 GAO-17-101 Homeless Veterans

of VA’s development phase in keeping with internal control standards 

and VA policy, and;

• update its EUL policy to (1) address the current authority for 

developing supportive-housing; and (2) specify how to identify 

properties for supportive-housing EULs to meet the needs of 

homeless veterans.

We provided a draft of this report to HUD, USICH, and VA for review and 

comment. We also provided a draft of the relevant EUL profile in 

Appendix V to lessees and service providers for each of the 13 

supportive-housing EULs we visited. We received technical comments 

from HUD, USICH, and VA, as well as several of the lessees, and we 

incorporated those comments where applicable. In addition, both USICH 

and VA provided written responses to our report (reproduced in 

appendixes VI and VII respectively). 

USICH agreed with our report’s perspective that the EUL program is 

among the key strategies that meaningfully contribute to the supply of 

supportive-housing opportunities needed to end veterans’ homelessness 

and to meet the needs of veterans in the future. USICH’s comments also 

noted the importance of the other programs discussed in our report—

HUD-VASH, SSVF, and GPD—in contributing to and sustaining the 

progress in ending veterans’ homelessness. 

VA concurred with both of our recommendations, and discussed planned 

actions to address them; however, VA disagreed with some of our 

findings. With respect to our finding that VA did not fully document the 

decision-making process in selecting supportive-housing EULs in keeping 

with internal control standards and VA policy, VA stated that it believes it

did document the selection process for the supportive-housing EUL 

agreements. However, VA acknowledged that stakeholders could have 

benefited from a single formal report as an effective communication tool 

and to help ensure the transfer of institutional knowledge. VA stated that, 

going forward, it will continue to enhance its documentation process to 

keep in line with internal control standards. 

VA also stated that we conclude that the lack of a single formal report to 

document how it selected the BURR sites means that it missed key 

factors to choose optimal sites. In fact, we do not point to the lack of a 

single formal report, nor do we specify the type of documentation VA 

should prepare for the selection of supportive-housing EULs going 

forward. Rather, we discuss the difficulty we had in reconciling the 

Agency Comments

and Our Evaluation
Page 41 GAO-17-101 Homeless Veterans

multiple lists with different EUL sites VA provided to us at different points 

in time. We made over 10 formal requests for information and clarification 

on the sites selected, and VA did not provide us with comprehensive 

documentation on the reasons why they selected certain properties over 

others for development. We discuss the importance of clear 

documentation in the context of maintaining sufficient internal controls for 

program management and informing future decisions. In addition, we do 

provide several illustrative examples of sites that VA initially selected that 

missed key factors that prevented the development of the site. For 

example, VA later learned that one site was not located on VA property, 

another site was already used for other purposes, and another no longer 

had underutilized facilities. We point out that additional documentation 

could have allowed VA to more effectively implement the program by 

excluding sites such as these.

With regard to our second recommendation, VA stated that it is in the 

process of updating its EUL policy and guidance to specifically document 

requirements, which are detailed in the agency’s comment letter (see 

app. VII), and it expects to complete the update by the end of the second 

quarter of 2017. Among the requirements, it refers to a review of market 

conditions, such as homeless populations to be served and the services 

they may require. However, VA does not specifically state that it will 

address how to identify properties that can meet the needs of homeless 

veterans. We continue to believe that VA should include this objective in 

its policy because, as discussed in our report, not all properties are 

suitable for housing the population the EUL program is required to serve. 

In its comments, VA noted some additional points they felt we should 

include in our report. However, we did cover these points to the extent 

applicable. In particular, VA raised an overall concern that the theme of 

our report does not take into account the entrepreneurial spirit and private 

sector dependency that are fundamental to the EUL program. To the 

contrary, we make these points clear throughout our report, by discussing

the multiple parties (e.g., public housing authorities, private development 

corporations, non-profit lessees, and service providers) that play key roles 

in the success of the EUL program. We discuss the range of services 

provided and the benefits to VA, lessees, developers, and the local 

community through participation in the program. We note that VA 

reported that its ability to retain EUL lease proceeds provides it with an 

incentive to be creative and aggressively pursue opportunities to 

collaborate with both private and non-profit entities. Further, we describe 

some of the key challenges that come with providing services through 

multiple parties—such as transportation, mail delivery, and law 
Page 42 GAO-17-101 Homeless Veterans

enforcement. And, we acknowledge the complexity of financing 

supportive-housing EULs through multiple funding sources. 

In sum, our report acknowledges VA’s successful development of 35 

active supportive-housing EULs, 6 under construction and 16 in 

development, notwithstanding the challenges faced with identifying 

suitable properties, stakeholder coordination, and obtaining sufficient 

financing. We believe that the improvements in documentation and 

updated policy that we recommended and VA has agreed to make will 

help to ensure that the supportive-housing EUL program continues to 

make an important contribution toward ending veterans’ homelessness.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Veterans Affairs, the Secretary of Housing 

and Urban Development, the Executive Director of the United States 

Interagency Council on Homelessness, points of contact from the 13 

EULs we visited, and other interested parties. In addition, the report is 

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

If you or your staff have any questions, please contact David Wise at 

(202) 512-2834 or Wised@gao.gov or 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 report. GAO staff who made major contributions to this report are 

listed in appendix VIII.

David J. Wise

Director, Physical Infrastructure

Alicia Puente Cackley

Director, Financial Markets and Community Investment
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-17-101 Homeless Veterans

This report examines: (1) how the U.S. Department of Veteran’s Affairs 

(VA) uses enhanced-use leases (EUL) to provide supportive-housing and 

services; (2) VA’s plans to develop additional supportive- housing through 

EULs and how past plans have been implemented, and (3) how the 

Department of Housing and Urban Development and Department of 

Veterans Affairs Supportive-Housing (HUD-VASH) program; the Grant 

and Per Diem (GPD) program; and the Supportive Services for Veteran 

Families (SSVF) program have helped support the goal of ending 

veterans’ homelessness. This report focuses on VA’s supportive-housing 

EULs.1

To examine how VA uses its EUL authority to provide supportive-housing 

to veterans, we collected and analyzed data from VA on the 35 active and 

other supportive-housing EULs from July 1998 to September 2016 and 

reviewed VA’s annual “EUL Consideration Report.”2 The data included 

project location, project status, housing type, the award date for the lease, 

number of housing units, and the year the facility began operating. We 

analyzed the number of EULs by housing type to determine what 

percentage of the housing units were permanent housing. We assessed 

the reliability of the data through interviews with knowledgeable VA 

officials and a review of the data for completeness and potential outliers. 

We determined that the data were sufficiently reliable for the purposes of 

providing summary information about supportive-housing EULs. Of the 35 

active supportive-housing EULs, we conducted site visits to 13 

supportive-housing EULs located on VA medical center (VAMC) 

campuses. Specifically, we visited the following supportive-housing EULs: 

one in Lyons, New Jersey; four in Dayton, Ohio; one in St. Cloud and two 

in Minneapolis, Minnesota; three in Hines, Illinois; and two in Sepulveda, 

California.3 We judgmentally selected these 13 supportive-housing EULs 

to include a range of geographic locations, a variety of stakeholders (e.g., 

 1

For the purpose of this report, supportive-housing is defined as housing that engages 

tenants in on-site and community-based support services for the veterans or their families 

who are at risk of homelessness or are homelessness. 

2

VA’s Fiscal Year 2017 “EUL Consideration Report,” indicates that VA has 30 active EULs 

that do not provide supportive-housing. These EULs include administrative offices, 

parking, hospice centers, mental health facilities, and childcare facilities, among others. 

For the purpose of this report, we limited our scope to supportive-housing EULs. 

3

Some supportive-housing EULs are located on the same VAMC campus. For example, 

VA entered into four separate EUL agreements on the VAMC campus in Dayton, Ohio. 

Additionally, a supportive-housing EUL can have several buildings or facilities under the

same lease. 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-17-101 Homeless Veterans

public, private, and non-profit lessees and service providers); housing 

types (e.g., transitional and permanent housing); and with leases 

spanning a range of years. At these site visits, we interviewed VA officials 

from the Office of Asset Enterprise and Management (OAEM), Office of 

General Counsel, local VAMC officials, lessees (some of which were 

developers), and service providers to understand factors involved in 

developing the EULs, the supportive services provided, and the benefits 

of developing supportive-housing through the EUL program.4 The 

information from our site visits is illustrative of issues affecting particular 

sites and cannot be generalized to VA sites agency-wide. To understand 

how VA’s EUL authority has supported housing for homeless veterans, 

we interviewed officials from the U.S. Interagency Council on

Homelessness (USICH)—an independent federal agency composed of 

19 Cabinet secretaries and agency heads, and not-for-profit veterans 

organizations concerned with veterans’ homelessness: The National 

Alliance to End Homelessness, National Coalition for Homeless Veterans, 

U.S. Vets, Vietnam Veterans of America, and the National Equity Fund.

To examine VA’s plans to develop additional supportive-housing and how 

VA implemented past plans, we analyzed VA data from July 1998 to 

September 2016 for projects under construction, development, and on 

hold. We assessed the reliability of the data through interviews with 

knowledgeable VA officials and a review of the data for completeness and 

potential outliers. We determined that the data were sufficiently reliable 

for the purposes of providing summary information about supportivehousing EULs. We also interviewed VA headquarters, local VAMC 

officials, lessees, and service providers as part of our 13 site visits. Five 

of the six VAMC campuses that we visited had supportive-housing EULs 

under development or construction. These VAMC campuses are located 

in Hines, IL; Lyons, NJ; Dayton, OH; and Minneapolis, and St. Cloud, MN. 

Additionally, we spoke to OAEM officials and local VAMC officials in Los 

Angeles, where VA is planning additional supportive-housing EULs. We 

also analyzed information on VA’s Building Utilization Review and 

Repurposing (BURR) initiative to identify VA’s proposed plans for and 

completed supportive-housing EULs.5 Additionally, we reviewed VA’s 

policies on EULs, including VA Handbook 7415 and VA Directive 7415, 

 4

For example, veterans receive rental subsidies from different federal programs.

5

Under the BURR initiative, VA evaluated unutilized and underutilized land and buildings 

on existing VA property for potential homeless housing projects for veterans through both 

public-private collaboration and VA’s EUL program.
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-17-101 Homeless Veterans

which contain EUL policies and procedures; and VA Handbook 7454 and 

VA Directive 7454, which contain policies and procedures for oversight 

and management of EULs.6 To understand potential challenges in 

developing EULs, we interviewed OAEM officials, local VAMC officials, 

lessees, and service providers at the 13 operating supportive-housing 

EULs about the challenges of developing an EUL. We reviewed and 

analyzed leasing agreement documents, directives, agency policy, 

guidance, and VA reports. We also reviewed VA’s Strategic Plan, VA 

Office of Inspector General’s (OIG) work, and our prior work related to 

EULs and lease agreements. We also reviewed the Standards for Internal 

Control in the Federal Government.7

To describe how VA leverages key programs to support the goal of 

ending veterans’ homeless, we examined three key housing programs: 

HUD-VASH, GPD, and SSVF.8 For each program, we asked VA for 

information about its performance targets and outcomes for fiscal year 

2012 onward and the role these programs play in providing rent subsidies 

and services for supportive-housing EULs. We assessed the reliability of 

the data through interviews with knowledgeable VA officials and a review 

of the data for completeness and potential outliers. We selected fiscal 

year 2012 because we had conducted a review of the HUD-VASH 

program that captured its performance for 2012—the year in which SSVF 

began operation. Selecting fiscal year 2012 also allowed us to capture the 

program outcomes in the years after VA and other agencies announced 

their goal to end veterans’ homelessness. We conducted a literature 

review to identify available and relevant research on the effects of the 

three programs on homeless veterans. We identified relevant studies, 

 6

VA, VA Handbook 7415, Enhanced-Use Leasing Program (Washington, D.C.: Dec. 21, 

2011); VA, VA Directive 7415, Enhanced-Use Leasing Program (Washington, D.C.: Dec. 

21, 2011); VA, VA Directive 7454, Enhanced-Use Leasing Post Transaction (Washington, 

D.C.: June 29, 2012); and VA, VA Handbook 7454, Enhanced-Use Leasing Post 

Transaction. (Washington, D.C.: June 29, 2012)

7

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C: September 2014).

8

This report focus exclusively on VA’s programs that provide housing or financial housing 

support to homeless veterans or veterans at risk of becoming homeless, in addition to 

other supportive services. It does not include all programs that VA administers that may 

support homeless veterans (i.e., the Health Care for Homeless Veterans Program and 

other such programs). In 2012, we found that 14 federal programs (including VA and other 

federal agencies) specifically targeted homeless veterans. See GAO, Homelessness: 

Fragmentation and Overlap in Programs Highlight the Need to Identify, Assess, and 

Reduce Inefficiencies, GAO-12-491 (Washington, D.C.: May 10, 2012).
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-17-101 Homeless Veterans

surveys, and analyses published by industry associations, academics or 

research entities, and federal agencies. A GAO social scientist assessed 

the design and methods of each study and determined they were 

sufficient to support the findings we cite in this report. Additionally, we 

interviewed VA’s Veterans Heath Administration Homeless Program 

Office and HUD officials about relevant studies. We reviewed HUD and 

VA guidance and policies on HUD-VASH, including notices HUD issued 

on set-aside funding availability for project-based HUD-VASH vouchers; 

VA’s Veterans Health Administration’s (VHA) Handbook 1162.05 on the 

procedures for the HUD-VASH program, and VA’s Resource Guide on 

HUD-VASH. Additionally, we reviewed guidance and policies VA has 

published on GPD and SSVF, including the VHA Handbook 1162.01 on 

the procedures for the GPD program and VA’s SSVF Program Guide. To 

understand how these programs have supported housing for homeless 

veterans and supportive-housing EULs we visited, we interviewed officials 

from the following organizations: VA’s VHA; the Department of Labor; 

USICH; National Alliance to End Homelessness; National Coalition for 

Homeless Veterans; EUL lessees and service providers; and officials 

from the city and county of Los Angeles, which has the largest population 

of homeless veterans in the United States. Furthermore, to understand 

the roles the programs played in ending veteran homelessness in specific 

areas, we interviewed officials from Houston, Texas; New Orleans, 

Louisiana; the Las Vegas metropolitan area; and the Commonwealth of 

Virginia—all areas USICH certified as having ended veteran 

homelessness. We selected Houston, New Orleans, and the Las Vegas 

metropolitan area because, among the areas that ended veteran 

homelessness, they had the highest number of homeless veterans in 

2011—the first year of the national effort to end veteran homelessness. 

We selected Virginia because it had a higher number of homeless 

veterans in 2011, as compared to Connecticut, the other state that had 

ended veteran homelessness at the time of our review. In Houston, we 

spoke with representatives from the local VA medical center, the Houston 

mayor’s office, and representatives involved in the local SSVF and HUDVASH program. Similarly, in New Orleans, we spoke with representatives 

from the local VA medical center and three service providers involved 

with the local SSVF and HUD-VASH programs. In the Las Vegas 

metropolitan area, we spoke with the Combined Working Group to End 

Veteran Homelessness, which included representatives from VA, HUD, 

city of Las Vegas, and several service providers. In Virginia, we 

interviewed representatives of the Governor’s Coordinating Council on 
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-17-101 Homeless Veterans

Homeless Veterans. We also reviewed USICH’s criteria and benchmarks 

for ending veteran homelessness.9 Additionally, we reviewed our prior 

work on veteran homelessness and the HUD-VASH program.10

We conducted this performance audit from October 2015 to December 

2016 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.

 9

USICH, Achieving the Goal of Ending Veteran Homelessness. Version 3 (Washington 

D.C.: Oct. 1, 2015). USICH adopted a set of criteria for ending veteran homelessness. 

The criteria are: (1) the community has identified all veterans experiencing homelessness; 

(2) the community provides shelter immediate to any veteran experiencing unsheltered 

homelessness who wants it; (3) the community only provides service-intensive transitional 

housing in limited instances; (4) The community has capacity to assist veterans to swiftly 

move into permanent housing; and (5) the community has resources, plans, and system 

capacity in place should any veteran become homeless or be at risk of homelessness in 

the future.

10See GAO, Federal Homelessness Programs: Fragmentation and Overlap in Programs 

Highlight the Need to identify, Assess, and Reduce Inefficiencies, GAO-12-491 

(Washington, D.C.: May 10, 2012), and GAO, Veteran Homelessness: VA and HUD Are 

Working to Improve Data on Supportive-Housing Program, GAO-12-726 (Washington, 

D.C.: June 26, 2012)
Appendix II: The Population of Homeless 

Veterans in the United States, by State, 2016

Page 48 GAO-17-101 Homeless Veterans

Table 9: Department of Housing and Urban Development’s Population of Homeless Veterans in the United States in 2016

State Homeless Veteran 

Population by State

1 –

500

501 –

1,000

1,001 –

1,500

1,501 –

3,000

3,001 –

10,000

Alabama 373 X

Alaska 168 X

Arizona 1,036 X

Arkansas 222 X

California 9,612 X

Colorado 1,181 X

Connecticut 216 X

Delaware 107 X

District of Columbia 350 X

Florida 2,902 X

Georgia 1,055 X

Guam 21 X

Hawaii 670 X

Idaho 267 X

Illinois 949 X

Indiana 663 X

Iowa 170 X

Kansas 169 X

Kentucky 512 X

Louisiana 400 X

Maine 146 X

Maryland 555 X

Massachusetts 949 X

Michigan 822 X

Minnesota 279 X

Mississippi 144 X

Missouri 575 X

Montana 165 X

Nebraska 219 X

Nevada 851 X

New Hampshire 123 X

New Jersey 556 X

New Mexico 214 X

New York 1,248 X

Appendix II: The Population of Homeless 

Veterans in the United States, by State, 2016
Appendix II: The Population of Homeless 

Veterans in the United States, by State, 2016

Page 49 GAO-17-101 Homeless Veterans

State Homeless Veteran 

Population by State

1 –

500

501 –

1,000

1,001 –

1,500

1,501 –

3,000

3,001 –

10,000

North Carolina 888 X

North Dakota 116 X

Ohio 930 X

Oklahoma 358 X

Oregon 1,341 X

Pennsylvania 1,136 X

Puerto Rico 146 X

Rhode Island 89 X

South Carolina 738 X

South Dakota 120 X

Tennessee 831 X

Texas 1,768 X

Utah 335 X

Vermont 110 X

Virgin Islands 32 X

Virginia 515 X

Washington 1,484 X

West Virginia 143 X

Wisconsin 415 X

Wyoming 87 X

Total 39,471

Source: GAO analysis of Department of Housing and Urban Development 2016 point-in-time count of homeless persons on a single night in January. | GAO-17-101

Note: To access an interactive version of this information, see http://www.gao.gov/products/gao-17-

101.
Appendix III: Participant Program Eligibility for 

Three Key Veterans’ Housing Programs

Page 50 GAO-17-101 Homeless Veterans

Table 10: Participant Program Eligibility for Three Key Veterans’ Housing Programs, as of September 2016

Department of Housing and 

Urban Development and 

Department of Veterans Affairs 

Supportive-Housing (HUDVASH)

Grant and Per Diem (GPD) Supportive Services for Veteran 

Families (SSVF)

Targeted population Homeless veterans, prioritizing 

chronically homeless or other 

vulnerable veterans and their 

familiesa

Any homeless veteran Very low income veterans and 

their families at risk of becoming 

“literally” homeless or are “literally”

homeless, prioritizing the latter 

group.b

Qualifying veteransc Veterans must qualify for VA 

health care as determined by the 

VAd

All veterans except those with 

dishonorable discharge; veterans 

must have served in active 

servicee

All veterans except those with 

dishonorable discharge; veterans 

must have served in active 

servicee

Income eligibility Household income not exceeding 

80 percent of area median income

No stated income limit Household income not exceeding 

50 percent of area median income 

Veteran’s rent Generally no more than 30 percent 

of monthly income

No more than 30 percent of 

monthly incomef Amount of rental assistance determined by the service provider

Limits on length of use No limit Generally up to 24 months, with a 

maximum three total stays unless 

waived by the VAg

6 to 12 months for rental 

assistance depending on incomeh

Source: GAO analysis of Department of Veterans Affairs’ documents. | GAO-17-101

a

HUD defines chronically homeless to mean a homeless individual with disability who has not been 

living in a place meant for human habitation, in an emergency shelter, or in a safe haven for at least 

12 months continuously or on at least four occasions in the last 3 years where those occasions 

cumulatively total at least 12 months.

b

A very low income veteran family is a veteran family whose annual income does not exceed 50 

percent of the median income for an area or community. “Literally” homeless is defined as (1) an 

individual or family that has a primary night-time residence that is a public or private place not 

designed for or ordinarily used as regular sleeping accommodation for human beings; (2) living in a 

supervised publicly or privately operated shelter designed to provide temporary living arrangements; 

or (3) an individual exiting an institution where he or she resided for 90 days or less and who met the 

first two criteria immediately prior to entering that institution. SSVF serves veterans and their families 

who are (1) “literally” homeless, but who are scheduled to become residents of permanent housing 

within 90 days; (2) “literally” homeless and exited permanent housing within the previous 90 days in 

order to seek housing more responsive to their needs and preferences; or (3) currently residing in 

permanent housing but at risk of becoming “literally” homeless.

c

38 U.S.C. §101(2); 38 C.F.R. § 3.1(d). A veteran is defined in statute as a person who served in the 

active military, naval or air service, and was discharged or released under conditions other than 

dishonorable. 38 U.S.C. § 101(2). There are currently five types of discharges: (1) honorable; (2) 

general; (3) other than honorable conditions or undesirable; (4) bad conduct; and (5) dishonorable.

d

Eligibility for VA healthcare includes having a discharge of any condition other than dishonorable, 

active duty service.

e

Active service generally means full time service in a branch of the armed services for purposes other 

than training.

f

Monthly income after deducting medical expenses, child care expenses, court-ordered child support 

payments, or other court-ordered payments, it also may not exceed the program’s set maximum rate 

or the HUD’s Fair Market Rent for that type of housing and its location, whichever is less,

g

A veteran may extend past 24 months if permanent housing has not been located or if the veteran 

requires additional time to prepare for independent living. 38 C.F.R. § 61.80(d).

Appendix III: Participant Program Eligibility 

for Three Key Veterans’ Housing Programs
Appendix III: Participant Program Eligibility for 

Three Key Veterans’ Housing Programs

Page 51 GAO-17-101 Homeless Veterans

h

For households with income below 30 percent of the area median income, up to 9 months in a 12-

month period and 12 months in a 2-year period. For households with an area median income 

between 30 and 50 percent, up to 6 months in a 12-month period and 10 months in a 2-year period.
Appendix IV: Department of Veterans Affairs’ 

(VA) 70 Supportive-Housing Enhanced-Use 

Leases (EULs) as of September 2016

Page 52 GAO-17-101 Homeless Veterans

Table 11: Department of Veteran Affairs’ (VA) Enhanced-Use Lease (EUL) Sites by Status as of September 2016

EUL location 

name

State EUL status Housing type Date lease 

awarded

Lessee Number of 

housing 

units

Building 

Utilization 

Review and 

Repurposing 

(BURR) or 

Legacy

1. Vancouver WA Active Permanenta 7/14/1998 Public — Housing 

Authority of the City of 

Vancouver

124 Legacy

2. Bedford MA Active Permanent 9/10/2004 Private — Vietnam 

Veterans Workshop, Inc.

60 Legacy

3. Dayton OH Active Permanent 12/30/2004 Nonprofit — Miami Valley 

Housing Opportunities

34 Legacy

4. St. Cloud MN Active Permanent 5/24/2005 Public — St. Cloud 

Housing and 

Redevelopment Authority

61 Legacy

5. Minneapolis MN Active Permanent 9/1/2005 Public — Hennepin 

County Housing and 

Redevelopment Authority

140 Legacy

6. Sepulveda CA Active Permanent 12/21/2007 Private — New 

Directions Sepulveda I 

L.P.

73 Legacy

7. Sepulveda CA Active Permanent 12/21/2007 Private — New 

Directions Sepulveda II 

L.P.

76 Legacy

8. Bedford MA Active Permanent 12/27/2011 Private - Bedford Place, 

LLC (Peabody 

Properties)

69 BURR

9. Hines IL Active Permanent 12/27/2011 Private — Hines 

Veterans Residences 

L.P. (Communities for 

Veterans)

72 BURR

10. Kerrville TX Active Permanent 12/27/2011 Private - Freedoms Path 

at Kerrville (Communities 

for Veterans)

49 BURR

11. Lyons NJ Active Permanent 12/27/2011 Private — Valley Brook 

Village I, LLC (Peabody 

Properties)

61 BURR

12. Menlo Park CA Active Permanent 12/27/2011 Nonprofit - Willow 

Housing, LLC

60 BURR

13. Minneapolis MN Active Permanent 12/27/2011 Nonprofit - Common 

Bond Communities

58 BURR

14. Newington CT Active Permanent 12/27/2011 Private — Victory 

Gardens Housing, LLC

74 BURR

15. Roseburg OR Active Permanent 12/27/2011 Private — Eagle Landing 

Associates, LLC

54 BURR

Appendix IV: Department of Veterans Affairs’

(VA) 70 Supportive-Housing Enhanced-Use 

Leases (EULs) as of September 2016
Appendix IV: Department of Veterans Affairs’ 

(VA) 70 Supportive-Housing Enhanced-Use 

Leases (EULs) as of September 2016

Page 53 GAO-17-101 Homeless Veterans

EUL location 

name

State EUL status Housing type Date lease 

awarded

Lessee Number of 

housing 

units

Building 

Utilization 

Review and 

Repurposing 

(BURR) or 

Legacy

16. Tuscaloosa AL Active Permanent 12/27/2011 Private - Map 

Development

50 BURR

17. Vancouver WA Active Permanent 12/27/2011 Private - Vancouver 

Veterans Residences, LP 

(Communities for 

Veterans)

50 BURR

18. Walla Walla WA Active Permanent 12/30/2011 Nonprofit - WWVA 

Housing, LLC

40 BURR

19. Barbers Point HI Active Permanent and 

Transitionalb 3/17/2003 Private — Cloudbreak, Hawaii, LLC

244 Legacy

20. Leavenworth KS Active Permanent and 

Transitional

8/5/2005 Private — Eisenhower 

Ridge Association 

(Pioneer Group, Inc.)

94 Legacy

21. Canandaigua NY Active Permanent and 

Transitional

12/27/2011 Private — Cazenovia 

Recovery Systems, Inc.

33 BURR

22. Northampton MA Active Permanent and 

Transitional

12/27/2011 Nonprofit - Soldier On 60 BURR

23. Viera FL Active Assisted 

Livingc 12/13/2011 Private — PVII Viera Manor

86 BURR

24. Danville IL Active Seniord 4/27/1999 Private — Danville VA 

L.P.

44 Legacy

25. Hines IL Active Senior 7/30/2004 Nonprofit — Goedert 

Senior Housing 

Corporations

71 Legacy

26. Batavia NY Active Senior 12/22/2008 Private — Havenwood 

Associates L.P.

32 Legacy

27. Dayton OH Active Senior 12/30/2011 Nonprofit — St. Mary 

Development Corp

55 BURR

28. Roseburg OR Active Transitionale 8/1/2000 Public — Housing 

Authority of Douglas 

County, OR

63 Legacy

29. Batavia NY Active Transitional 5/24/2002 Nonprofit - Cazenovia 

Recovery Systems, Inc

18 Legacy

30. Hines IL Active Transitional 8/22/2003 Private — Shelters for 

the Homeless and 

Cooke’s Manor, LLCf

42 Legacy

31. Butler PA Active Transitional 4/17/2007 Public — County of 

Butler, PA

20 Legacy

32. Dayton OH Active Transitional 4/19/2007 Private — Ohio Avenue 

Commons, LLC

27 Legacy
Appendix IV: Department of Veterans Affairs’ 

(VA) 70 Supportive-Housing Enhanced-Use 

Leases (EULs) as of September 2016

Page 54 GAO-17-101 Homeless Veterans

EUL location 

name

State EUL status Housing type Date lease 

awarded

Lessee Number of 

housing 

units

Building 

Utilization 

Review and 

Repurposing 

(BURR) or 

Legacy

33. Dayton OH Active Transitional 11/5/2008 Nonprofit — Volunteers 

of America of Greater 

Ohio

50 Legacy

34. Battle Creek MI Active Transitional 12/22/2008 Private — Medallion 

Management, Inc.

175 Legacy

35. Salt Lake City UT Active Transitional 8/30/2011 Public — Housing 

Authority of Salt Lake 

City

72 Legacy

36. Brockton MA Construction Permanent 12/27/2011 Private - Howard House, 

LLC (Peabody 

Properties)

14 BURR

37. St. Cloud MN Construction Permanent 12/27/2011 Nonprofit - CBVA St 

Cloud, LP

37 BURR

38. Chillicothe OH Construction Permanent 12/30/2011 Private - Chillicothe 

Veterans Residences, LP 

(Communities for 

Veterans)

60 BURR

39. Danville IL Construction Permanent 12/30/2011 Nonprofit - Mercy 

Housing Lakefront

65 BURR

40. Grand Island NE Construction Permanent 12/30/2011 Private - Grand Island, 

LLC (Pioneer Group)

26 BURR

41. Minneapolis II MN Construction Permanent N/Ag CHDC Veterans Limited 

Partnership

100 BURR

42. Augusta I GA Development Permanent 12/27/2011 Private - Augusta 

Veterans Residences 

(Communities for 

Veterans)

70 BURR

43. Fort Harrison MT Development Permanent 12/27/2011 Private - Fort Harrison 

Veterans, LLP 

(Communities for 

Veterans)

42 BURR

44. Fort Howard MD Development Permanent 12/27/2011 Public - Fort Howard 

Development

50 BURR

45. Lyons II NJ Development Permanent 12/27/2011 Private — Valley Brook 

Village I, LLC (Peabody 

Properties)

50 BURR

46. Togus ME Development Permanent 12/27/2011 Non-Profit - Volunteers of 

America Northern New 

England

21 BURR
Appendix IV: Department of Veterans Affairs’ 

(VA) 70 Supportive-Housing Enhanced-Use 

Leases (EULs) as of September 2016

Page 55 GAO-17-101 Homeless Veterans

EUL location 

name

State EUL status Housing type Date lease 

awarded

Lessee Number of 

housing 

units

Building 

Utilization 

Review and 

Repurposing 

(BURR) or 

Legacy

47. Hines II IL Development Permanent 12/28/2011 Private — Hines 

Veterans Residences 

L.P. (Communities for 

Veterans)

52 BURR

48. Augusta II GA Development Permanent 12/30/2011 Private - Augusta 

Veterans Residence, LPs 

(Communities for 

Veterans)

28 BURR

49. Cheyenne WY Development Permanent 12/30/2011 Private - America First 

Real Estate Group

52 BURR

50. Lincoln NE Development Permanent 12/30/2011 Nonprofit - Seniors 

Foundation

70 BURR

51. Perry Point MD Development Permanent 12/30/2011 Nonprofit - Help USA 75 BURR

52. Northport NY Development Permanent and 

Transitional

12/27/2011 Private - Northport 

Seniors, LLC 

(Communities for 

Veterans)

110 BURR

53. Viera Memory 

Care

FL Development Memory Careg 12/13/2011 Private — PVII Viera 

Manor

51 BURR

54. Battle Creek II MI Development Transitional 12/22/2008 Private — Medallion 

Management, Inc.

75 Legacy

55. Dayton II OH Development Transitional 12/30/2011 Communities for 

Veterans-Dayton

66 BURR

56. Leestown KY Development TBDh N/Ai AU Associates BURR

57. Milwaukee WI Development TBD N/A Private — Alexander 

Company

BURR

58. Battle Creek III MI PreDevelopmentN/A No developer selected BURR 

59. Dublin GA PreDevelopmentN/A No developer selected BURR

60. Bath NY On Hold Permanent 12/27/2011 Loyola Recovery 

Foundation

41 BURR

61. Salem VA On Hold Permanent 12/30/2011 Private - Robra 

Construction, Inc

29 BURR

62. Topeka KS On Hold Permanent 12/30/2011 Private - Pridon, LLC 30 BURR

63. Alexandria LA On Hold Transitional 12/27/2011 Private - Westar 

Development, LLC

65 BURR

64. Knoxville IA On Hold Transitional 12/27/2011 Private - Knoxville 

Veterans Alliance

75 BURR

65. Butler IL On Hold N/A No developer selected BURR
Appendix IV: Department of Veterans Affairs’ 

(VA) 70 Supportive-Housing Enhanced-Use 

Leases (EULs) as of September 2016

Page 56 GAO-17-101 Homeless Veterans

EUL location 

name

State EUL status Housing type Date lease 

awarded

Lessee Number of 

housing 

units

Building 

Utilization 

Review and 

Repurposing 

(BURR) or 

Legacy

66. Castle Point NY On Hold N/A No developer selected BURR

67. Martinsburg WV On Hold N/A No developer selected BURR

68. Montrose NY On Hold N/A No developer selected BURR

69. White City OR On Hold N/A No developer selected BURR

70. Fort Howard MD Terminated Terminated 9/28/2006 Legacy

Source: Department of Veterans Affairs’ data as of September 2016. | GAO-17-101

Note: To access an interactive version of this information, see http://www.gao.gov/products/gao-17-

101.

a

Permanent facilities provide long-term housing with supportive services for people experiencing or at 

risk of homelessness, including those with disabilities.

b

Permanent and Transitional facilities provide both types of housing.

c

Assisted Living facilities provide permanent housing with services for the frail elderly and people with 

disabilities who can live independently but need assistance with activities of daily living.

d

Senior facilities provide permanent supportive-housing for seniors age 62 and over.

e

Transitional facilities provide time-limited housing that aims to facilitate the movement of homeless 

individuals and families to permanent housing within a reasonable amount of time (usually 24 

months).

f

After the completion of our audit work, we learned from VA that, as of October 2016, Cooke’s Manor 

remains an EUL but has no residents, and Catholic Charities is working on options for its future use.

g

Memory care facilities provide specialized long-term care services in a secured environment for 

individuals with dementia.

h

TBD stands for to be determined.

i

N/A stands for not applicable.
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 57 GAO-17-101 Homeless Veterans

Table 12: New Directions Sepulveda (I L.P., Building 4, and II L.P., Building 5), Department of Veterans Affairs Sepulveda 

Ambulatory Care Center, Los Angeles, California

Housing type Permanent

Number of units 149 studio units

Supportive services offered Counseling, case management, crisis management, service coordination, job 

training and placement, and legal services 

Veteran prioritization Veterans only

Housing assistance programs Department of Housing and Urban Development (HUD) and Department of 

Veterans Affairs Supportive-Housing, and HUD Housing Choice Voucher

Annual income eligibility Up to 30 percent area median income 

Lessee and organization typea New Directions Sepulveda I, L.P., and New Directions Sepulveda II, L.P., private 

Contracted service providerb New Directions Inc., nonprofit

Enhanced-use lease 75-year lease of 2.44 acres

New construction or rehabilitation Rehabilitation

Lease awarded December 2007

Facility opening 2013

Source: GAO Analysis. | GAO-17-101

Note: For the purpose of this report, New Directions Sepulveda (NDS) I L.P., Building 4, and New 

Directions Sepulveda II L.P., Building 5 were combined into one case profile.

a

Two nonprofits, A Community of Friends and New Directions, Inc., formed the private NDS I, L.P., 

and NDS II, L.P.

b

Veteran residents receiving HUD-VASH receive services from the Department of Veterans Affairs 

Sepulveda Ambulatory Care Center.

Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 58 GAO-17-101 Homeless Veterans

Table 13: Cooke’s Manor, Department of Veterans Affairs Medical Center, Hines, Illinois

Housing type Transitional

Number of units 40 private rooms with access to a common area that includes a kitchen, recreation 

room, and laundry facilities

Supportive services offered Counseling, addiction counseling, case management, on-site recovery groups, 

education and employment training, budget planning, and aftercare

Veteran prioritization Male veterans only

Housing assistance programs Department of Veterans Affairs Grant and Per Diem

Annual income eligibility For 2016, up to $26,950 per person

Lessee and organization type Shelters for the Homeless and Cooke’s Manor, LLC, private

Contracted service provider Catholic Charities of the Archdiocese of Chicago, nonprofit

Enhanced-use lease 32-year enhanced lease of 0.50 acres 

New construction or rehabilitation Rehabilitation

Lease awarded August 2003

Facility opening 2005

Source: GAO Analysis. | GAO-17-101
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 59 GAO-17-101 Homeless Veterans

Table 14: Bishop Goedert Residence, Department of Veterans Affairs Medical Center, Hines, Illinois

Housing type Senior housing

Number of units 71 one-bedroom units

Supportive services offered Case management and service referrals to the Illinois Department of Aging and 

public benefits like Medicaid and food stamps

Veteran prioritization Priority placement

Housing assistance programs Department of Housing and Urban Development Section 202 Supportive-Housing 

for the Elderly

Annual income eligibility In 2016, up to $26,950 (one person) or $30,800 (two persons)

Lessee and organization type Goedert Senior Housing Corporation, nonprofit

Contracted service provider Catholic Charities of the Archdiocese of Chicago, nonprofit

Enhanced-use lease 75-year lease of 1.84 acres

New construction or rehabilitation Rehabilitation

Lease awarded July 2004

Facility opening 2006

Source: GAO Analysis. | GAO-17-101
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 60 GAO-17-101 Homeless Veterans

Table 15: Freedom’s Path I, Department of Veterans Affairs Medical Center, Hines, Illinois

Housing type Permanent housing

Number of units 72 efficiency and one-bedroom units 

Supportive services offered Case management, counseling, crisis management employment assistance, and 

support groups like Alcoholics Anonymous

Veteran prioritization Veterans only

Housing assistance programs Departments of Housing and Urban Development and Department of Veterans 

Affairs Supportive-Housing 

Annual income eligibility 2 units up to 80 percent area median income (AMI); 34 units up to 50 percent AMI, 

and 36 units up to 30 percent AMI

Lessee and organization type Hines Veterans Residences L.P. (Communities for Veterans), private

Contracted service provider Pinnacle Property Maintenance, private

Enhanced-use lease 75-year lease of 4.7 acres

New construction or rehabilitation New construction

Lease awarded December 2011

Facility opening 2015

Source: GAO Analysis. | GAO-17-101
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 61 GAO-17-101 Homeless Veterans

Table 16: Al Loehr Veterans and Community Studio Apartments, Department of Veterans Affairs Medical Center, St. Cloud, 

Minnesota

Housing type Permanent

Number of units 61 studio units 

Supportive services offered Case management and other supportive services

Veteran prioritization Priority placement into 51 percent of the units

Housing assistance programs No veterans-specific housing assistance programs

Annual income eligibility 20 units up to 30 percent of the area median income (AMI) for Hennepin County; 

40 units up to 50 percent statewide income or AMI, whichever is greater

Lessee and organization type St. Cloud Housing and Redevelopment Authority, public

Contracted service provider Catholic Charities of the Diocese of St. Cloud, nonprofit

Enhanced-use lease 50-year lease of 5.62 acres 

New construction or rehabilitation New construction

Lease awarded May 2005

Facility opening 2006

Source: GAO Analysis. | GAO-17-101
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 62 GAO-17-101 Homeless Veterans

Table 17: Veterans and Community Housing, Department of Veterans Affairs Medical Center, Minneapolis, Minnesota

Housing type Permanent

Number of units 140 units

Supportive services offered No services offered onsite, but service referral available

Veteran prioritization Priority placement into 51 percent of the units

Housing assistance programs Department of Veterans Affairs Grant and Per Diem, Department of Housing and 

Urban Development Housing Choice Vouchers

Annual income eligibility Up to 30 percent area median income (AMI) or 50 percent AMI

Lessee and organization type Hennepin County Housing and Redevelopment Authority, public

Contracted service provider Community Housing Development Corporation, nonprofit

Enhanced-use lease 60-year lease of 4.34 acres

New construction or rehabilitation New construction and rehabilitation

Lease awarded September 2005

Facility opening 2006

Source: GAO Analysis. | GAO-17-101
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 63 GAO-17-101 Homeless Veterans

Table 18: Upper Post Veterans Community, Department of Veterans Affairs Medical Center, Fort Snelling Upper Post, 

Minnesota

Housing type Permanent

Number of units 58 studio, one-, two-, and three-bedroom units

Supportive services offered Case management, referrals, educational and employment services, health and 

wellness activities, financial literacy, and transition services at move out

Veteran prioritization Priority placement

Housing assistance programs Department of Housing and Urban Development (HUD) and Department of 

Veterans Affairs Supportive-Housing, HUD Housing Choice Vouchers, and other 

programs 

Annual income eligibility Up to 50 to 60 percent area median income (AMI), or $1,374 per month for other 

programs 

Lessee and organization type Common Bond Communities, nonprofit

Contracted service providera Common Bond Communities Advantage Services, nonprofit

Enhanced-use lease 50-year lease with the option of a 25-year extension of 5.76 acres 

New construction or rehabilitation Rehabilitation

Lease awarded December 2011

Facility opening 2015

Source: GAO Analysis. | GAO-17-101

a

Common Bond Communities Advantage Services, a department within Common Bond Communities, 

is the supportive service provider.
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 64 GAO-17-101 Homeless Veterans

Table 19: Valley Brook Village Phase I, Department of Veterans Affairs Medical Center, Lyons, New Jersey

Housing type Permanent

Number of units 61 furnished units

Supportive services offered In-home counseling, recovery planning, medication education and monitoring, onsite and 24/7 on-call crisis prevention and intervention, mental health education, 

assistance applying for benefits, financial literacy skills, computer and vocational 

training center on site

Veteran prioritization Priority placement

Housing assistance programs Department of Housing and Urban Development and Department of Veterans 

Affairs Supportive-Housing 

Annual income eligibility Up to $36,400 or 50 percent area median income 

Lessee and organization type Valley Brook Village I, LLC (controlled by Peabody Properties, Inc.), private

Contracted service provider Community Hope, nonprofit

Enhanced-use lease 75-Year lease of 12.88 acres 

New construction or rehabilitation New construction

Lease awarded December 2011

Facility opening 2013

Source: GAO Analysis. | GAO-17-101
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 65 GAO-17-101 Homeless Veterans

Table 20: Iowa Avenue—Building 412, Department of Veterans Affairs Medical Center, Dayton, Ohio

Housing type Permanent 

Number of units 34 units

Supportive services offered Case management, service referral and skills training

Veteran prioritization Priority placement for male veterans

Housing assistance programs Department of Health and Human Services Projects for Assistance in Transition 

from Homelessness, and Department of Housing and Urban Housing Choice 

Vouchers

Annual income eligibility Up to 30 percent area median income, or $12,950 annual income

Lessee and organization type Miami Valley Housing Opportunities, nonprofit

Contracted service provider Homefull, nonprofit

Enhanced-use lease 50-year lease of 2.20 acres 

New construction or rehabilitation Rehabilitation

Lease awarded December 2004

Facility opening 2005

Source: GAO Analysis. | GAO-17-101
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 66 GAO-17-101 Homeless Veterans

Table 21: Ohio Avenue Commons—Building 402, Department of Veterans Affairs Medical Center, Dayton, Ohio

Housing type Transitional

Number of units 27 units

Supportive services offered Case management and service referral

Veteran prioritization Priority placement

Housing assistance programs Department of Housing and Urban Development (HUD) Continuum of Care, and 

HUD and Veterans Affairs Supportive-Housing 

Annual income eligibility Up to 30 percent area median income, or $12,950 annual income

Lessee and organization type Ohio Avenue Commons, LLC, private

Contracted service provider Homefull, nonprofit

Enhanced-use lease 65-year lease of 0.6 acres

New construction or rehabilitation Rehabilitation

Lease awarded April 2007

Facility opening 2008

Source: GAO Analysis. | GAO-17-101
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 67 GAO-17-101 Homeless Veterans

Table 22: Building 400, Department of Veterans Affairs Medical Center, Dayton, Ohio

Housing type Transitional

Number of units 50 “dorm style” beds—residents share rooms and common areas including 

bathrooms and a cafeteria

Supportive services offered Case management, counseling, three meals per day, employment assistance, 

substance abuse counseling, and mental and physical health referrals

Veteran prioritization Veterans only

Housing assistance programs Department of Veterans Affairs Grant and Per Diem

Annual income eligibility No set income limit 

Lessee and organization typea Volunteers of America of Greater Ohio, nonprofit

Contracted service provider Volunteers of America of Greater Ohio, nonprofit

Enhanced-use lease 30-year lease of 1.50 acres

New construction or rehabilitation Rehabilitation

Lease awarded November 2008

Facility opening 2010

Source: GAO Analysis. | GAO-17-101

a

Volunteers of America of Greater Ohio serves as the lessee and contracted service provider.
Appendix V: Profiles of the 13 Selected 

Supportive-Housing Enhanced-Use Leases

Page 68 GAO-17-101 Homeless Veterans

Table 23: Lyons Place II, Department of Veterans Affairs Medical Center, Dayton, Ohio

Housing type Senior

Number of units 55 one- and two-bedroom units

Supportive services offered Case management and referral services

Veteran prioritization Priority placement

Housing assistance programs Department of Housing and Urban Development (HUD) Section 202 SupportiveHousing for the Elderly, and HUD Housing Choice Vouchers 

Annual income eligibility Up to 60 percent area median income or $22,100 (for units with a HUD subsidy) or 

$25,920 (for units without a HUD subsidy)

Lessee and organization type St. Mary’s Development Corporation, nonprofit

Contracted service provider National Church Residences, nonprofit

Enhanced-use lease 75-year lease of 6 acres 

New construction or rehabilitation New construction 

Lease awarded December 2011

Facility opening 2015

Source: GAO Analysis. | GAO-17-101
Appendix VI: Comments from the United 

States Interagency Council on Homelessness

Page 69 GAO-17-101 Homeless Veterans

Appendix VI: Comments from the United 

States Interagency Council on 

Homelessness
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 70 GAO-17-101 Homeless Veterans

Appendix VII: Comments from the 

Department of Veterans Affairs
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 71 GAO-17-101 Homeless Veterans
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 72 GAO-17-101 Homeless Veterans
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 73 GAO-17-101 Homeless Veterans
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 74 GAO-17-101 Homeless Veterans
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 75 GAO-17-101 Homeless Veterans
Appendix VII: Comments from the Department 

of Veterans Affairs

Page 76 GAO-17-101 Homeless Veterans
Appendix VIII: GAO Contacts and Staff 

Acknowledgments

Page 77 GAO-17-101 Homeless Veterans

David J. Wise, (202) 512- 2834 or wised@gao.gov

Alicia Puente Cackley, (202) 512-8678 or cackleya@gao.gov

In addition to the contacts named above, Amelia Shachoy (Assistant 

Director), Marshall Hamlett (Assistant Director), Nelsie Alcoser (Analyst in 

Charge), Russell Burnett, Delwen Jones, Joshua Ormond, Ernest Powell, 

Susmita Pendurthi, Kelsey Sagawa, Jessica Smith, Crystal Wesco, 

Daniel Will, and Weifei Zheng made key contributions to this report.

Appendix VIII: GAO Contacts and Staff 

Acknowledgments

GAO Contacts

Staff 

Acknowledgments

(100337)
The Government Accountability Office, the audit, evaluation, and investigative 

arm of Congress, exists to support Congress in meeting its constitutional 

responsibilities and to help improve the performance and accountability of the 

federal government for the American people. GAO examines the use of public

funds; evaluates federal programs and policies; and provides analyses, 

recommendations, and other assistance to help Congress make informed 

oversight, policy, and funding decisions. GAO’s commitment to good government 

is reflected in its core values of accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no cost is 

through GAO’s website (http://www.gao.gov). Each weekday afternoon, GAO 

posts on its website newly released reports, testimony, and correspondence. To 

have GAO e-mail you a list of newly posted products, go to http://www.gao.gov

and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of production and 

distribution and depends on the number of pages in the publication and whether 

the publication is printed in color or black and white. Pricing and ordering 

information is posted on GAO’s website, http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, MasterCard, 

Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube.

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.

Visit GAO on the web at www.gao.gov.

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-4400, 

U.S. Government Accountability Office, 441 G Street NW, Room 7125, 

Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

James-Christian Blockwood, Managing Director, spel@gao.gov, (202) 512-4707

U.S. Government Accountability Office, 441 G Street NW, Room 7814, 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Strategic Planning and 

External Liaison

Please Print on Recycled Paper.