a

GAO

United States Government Accountability Office

Report to the Ranking Minority Member, 

Subcommittee on Agriculture, Rural 

Development, and Related Agencies, 

Senate Committee on Appropriations

September 2004 RURAL HOUSING 

SERVICE

Updated Guidance and 

Additional Monitoring 

Needed for Rental 

Assistance 

Distribution Process

GAO-04-937
www.gao.gov/cgi-bin/getrpt?GAO-04-937.

To view the full product, including the scope 

and methodology, click on the link above. To 

view the survey results, click on the following 

link www.gao.gov/cgi-bin/getrpt?GAO-04-

978SP. For more information, contact 

William B. Shear at (202) 512-4325 or 

shearw@gao.gov. 

Highlights of GAO-04-937, a report to 

Ranking Minority Member, Subcommittee 

on Agriculture, Rural Development, and 

Related Agencies, Senate Committee on 

Appropriations. 

September 2004

RURAL HOUSING SERVICE 

Updated Guidance and Additional 

Monitoring Needed for Rental Assistance 

Distribution Process 

The Rural Housing Service’s (RHS) 

Section 521 rental assistance 

program provides rental subsidies 

for about 250,000 rural tenants. 

Because the program has a waiting 

list of 80,000 eligible tenants and 

there are over 1.3 million rural lowincome renters eligible for housing 

subsidies, it is important to 

effectively distribute resources to 

extend assistance to as many needy 

tenants as possible. Therefore, 

GAO was asked to assess (1) how 

RHS distributes rental assistance 

funds to properties and tenants, (2) 

how RHS monitors the use of rental 

assistance funds, and (3) whether 

there are sufficient internal 

controls in place to ensure that 

these funds are being effectively 

administered and used. 

GAO recommends that the 

Secretary of Agriculture require 

that program officials establish 

centralized guidance on 

transferring unused rental 

assistance, improve sampling 

methods to select tenant household 

files for supervisory reviews, and 

improve verification of tenant 

information. To help the agency 

verify tenant information, Congress 

may wish to consider giving RHS 

access to the Department of Health 

and Human Services’ National 

Directory of New Hires. 

The Department of Agriculture 

generally agreed with GAO’s 

recommendations. 

RHS’s national office pays rental assistance funds to property owners 

through a variety of contracts and transfers of unused rental assistance from 

one property to another. RHS staff calculate the payment amounts using 

information provided by tenants and verified by property owners. The 

current system requires RHS staff to enter payment data into the agency’s 

database manually. However, RHS’s national office is upgrading two 

systems to streamline the payment process. But some local RHS staff are 

concerned that the new process may eliminate a layer of review. 

RHS’s national, state, and local offices share responsibility for monitoring 

the rental assistance program, with the local offices performing the primary 

review every 3 years. The national office outlines the monitoring activities 

for the rental assistance program in its Rural Development Instructions and 

provides other guidance, such as administrative notices and unnumbered 

letters. We found that state and local offices follow this guidance 

inconsistently and sometimes consider it unclear. National office staff are 

planning a number of initiatives to increase monitoring of the rental 

assistance program, but a number of key management positions in the 

national office are unfilled, which could limit the effectiveness of program 

monitoring. 

RHS’s internal controls do not provide adequate oversight of rental 

assistance funds because RHS guidance is inadequate and tenants’ incomes 

are not adequately verified. First, insufficient guidance on the transfer 

process limits RHS’s ability to move unused rental assistance to properties 

that have tenants with the greatest unmet need. Second, the triennial 

supervisory review does not provide reasonable assurance that tenants 

income and assets, and ultimately rental assistance payments, are adequately

verified. Alternate methods of verifying tenant information also have limited 

effectiveness but could help improve internal control if properly designed 

and implemented. 

How RHS Uses Information from Tenants to Determine Rental Subsidies 

Property owner

RHS state or 

local office

$

Source: GAO.

• Property owner verifies tenant 

 information and enters it into 

Tenant Certification form

• RHS processes 

 Project Worksheet

• RHS pays Rental 

 Assistance • Property owner uses same 

 information to create 

 Project Worksheet

Information

provided

by tenant

Project

Worksheet

Information

from Tenant

Certification
Page i GAO-04-937 Rental Assistance

Contents

Letter 1

Results in Brief 2

Background 4

RHS Distributes Rental Assistance Funds through Contracts and 

Sets Per-Unit Payments Based on Tenants’ Verified Income 

Levels 8

RHS’s National and State Offices Monitor the Use Of Rental 

Assistance, with Local Offices Performing the Primary Review 

Every 3 Years 14

RHS’s Internal Controls Do Not Provide Adequate Oversight of 

Rental Assistance Funds 21

Conclusions 32

Recommendations for Executive Action 33

Matter for Congressional Consideration 33

Agency Comments and Our Evaluation 33

Appendixes

Appendix I: Scope and Methodology 36

Appendix II: State Office Survey Responses for Rural Rental Housing 

(RRH) Properties 39

Appendix III: State Office Survey Responses for Off Farm Labor Housing 

(FLH) Properties 41

Appendix IV: Comments from the U.S. Department of Agriculture 42

Appendix V: GAO Contacts and Staff Acknowledgments 45

GAO Contacts 45

Staff Acknowledgments 45

Table Table 1: Triennial Supervisory Review Workload, Selected RHS 

Local Offices 17

Figures Figure 1: Duties of RHS National, State, and Local Offices 6

Figure 2: Rental Assistance Distribution Process 9

Figure 3: How RHS Uses Information from Tenants to Determine 

Rental Subsidies 11

Figure 4: Centralized and Decentralized Processing, by State 13

Figure 5: Key Management Positions in the Rural Housing Service, 

as of July 2004 20
Contents

Page ii GAO-04-937 Rental Assistance

Figure 6: Frequency of Supervisory Reviews of Tenant Household 

Files 25

Figure 7: Process Used to Verify the Accuracy of Rental Assistance 

Payments 29

Figure 8: States with Wage-Matching Agreements 31

Abbreviations

AMAS Automated Multi-Housing Accounting System

FLH Farm Labor Housing

HUD U.S. Department of Housing and Urban Development

MFIS Multi-Family Housing Information System

MINC Management Agency Interactive Network Connection

RD Rural Development

RHS Rural Housing Service

RRH Rural Rental Housing

USDA U.S. Department of Agriculture

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Page 1 GAO-04-937 Rental Assistance

United States Government Accountability Office

Washington, D.C. 20548

A

September 13, 2004 Letr

The Honorable Herbert Kohl

Ranking Minority Member

Subcommittee on Agriculture, Rural Development

and Related Agencies

Committee on Appropriations

United States Senate

Dear Senator Kohl:

The Rural Housing Service (RHS) of the U. S. Department of Agriculture 

(USDA) provides rental subsidies through the Section 521 rental assistance 

program to about 250,000 low-income rural tenants living in federally 

subsidized properties.1

 The rental subsidies, which are provided to 

property owners through multiyear contracts, are intended to limit tenants’ 

rent payments to 30 percent of the household’s adjusted monthly income. 

With a fiscal year 2004 budget of almost $600 million, the program is RHS’s 

largest line-item appropriation. Given its size, internal controls are a 

significant factor in administering the program in order to distribute 

resources effectively and reduce the possibilities for fraud, waste, and 

abuse. Because the program already has a waiting list of 80,000 eligible 

tenants and over 1.3 million low-income renters not receiving housing 

subsidies reside throughout rural America, effectively distributing 

resources is important in extending assistance to as many needy tenants as 

possible.2

We recently reported on the activity level of rental assistance contracts and 

the accuracy of RHS’s budget estimates for the Section 521 rental 

1

The Section 515 Multifamily Direct Rural Rental Housing Loans program provides 

subsidized loans to developers to build rental housing. The Section 514 Multifamily Housing 

Farm Labor Loans program provides grants and subsidized loans to build rental housing for 

farm laborers, either off or on the farmer’s property. Only “off-farm” labor housing is eligible 

for rental assistance subsidies. All properties must be established on a nonprofit or limited 

profit basis to receive rental assistance.

2

GAO analysis of the 2003 American Housing Survey. This figure excludes cash renters, and 

rural areas include rural parts of metropolitan areas and excludes urbanized parts of nonmetropolitan areas. The American Housing Survey is the largest, regular national housing 

sample survey in the United States. The U.S. Census Bureau conducts the American Housing 

Survey to obtain up-to-date housing statistics for the Department of Housing and Urban 

Development.
Page 2 GAO-04-937 Rental Assistance

assistance program.3 To further assist you in your oversight of the program, 

you also asked us to assess (1) how RHS distributes rental assistance funds 

to properties and tenants, (2) how RHS monitors the use of rental 

assistance funds, and (3) whether RHS has sufficient internal controls in 

place to ensure that these funds are being effectively administered and 

used.

To respond to these objectives, we collected written information from RHS 

and talked with its representatives about the processes for distributing 

rental assistance and the means of monitoring those processes. We 

reviewed RHS’s guidance for the program and internal control standards 

that apply to the processes. We also conducted a nationwide survey of all 

RHS state and local offices with rental assistance responsibilities. Finally, 

we visited RHS state and local offices and property owners or managers in 

five states to obtain documentation related to specific aspects of the rental 

assistance distribution process and to observe how RHS staff implement 

the internal controls that RHS has established to oversee the program. 

Details of our scope and methodology appear in appendix I, and 

appendixes II and III contain state office responses to a number of survey 

items. The survey and a more complete tabulation of the results can be 

viewed at www.gao.gov/cgi-bin/getrpt?GAO-04-978SP.

We conducted our work from September 2003 through June 2004 in a 

number of locations, including Connecticut, Massachusetts, Mississippi, 

New York, South Carolina, Utah, and Washington, D.C., in accordance with 

generally accepted government auditing standards.

Results in Brief Rental assistance funds are paid monthly to property owners through 

multiyear, renewable contracts that designate a set amount of funding per 

rental unit in RHS-subsidized properties. Property owners may also request 

that RHS transfer unused rental assistance from one property to another. 

The actual amount of the payments property owners receive is calculated 

using information provided by tenants, verified by property owners, and 

reviewed by staff at RHS state and local offices. Plans to streamline the 

payment process are under way, but some RHS staff are concerned that the 

new process may eliminate a layer of review.

3

Rural Housing Service: Standardization of Budget Estimation Processes Needed for 

Rental Assistance Program, GAO-04-424, (Washington, D.C.: March 25, 2004).
Page 3 GAO-04-937 Rental Assistance

Responsibility for monitoring the rental assistance program is divided 

among RHS’s national, state, and local offices, with the local offices 

performing the primary review of the rental assistance distribution 

process. The national office provides guidance on procedures for 

monitoring the distribution of rental assistance funds, but we found that 

state and local offices apply the guidance inconsistently and that some of 

these offices consider it unclear. Following the guidance, local offices 

conduct supervisory reviews every 3 years, and these reviews are RHS’s 

primary tool for detecting misreporting of tenant income, and ultimately, 

unauthorized rental assistance payments. Initiatives to increase monitoring 

of the rental assistance program are under way at the national office. 

However, unfilled management positions at the national level could limit 

RHS’s ability to effectively monitor the program.

RHS’s internal controls do not provide adequate oversight of rental 

assistance funds. First, insufficient and unclear guidance on the transfer 

process limits RHS’s ability to transfer unused rental assistance to 

properties with the most needy tenants. Second, RHS’s triennial 

supervisory reviews, the primary internal control activity to verify the 

information tenants and property owners submit, are conducted 

infrequently using samples that may be too small to effectively mitigate the 

risks associated with providing unauthorized rental assistance. RHS uses 

alternate methods, such as internal database checks and wage matching, to 

verify tenant and payment information. These methods have limited 

effectiveness in governing the rental assistance distribution process but 

could help to improve internal control if they were properly designed and 

implemented.

This report contains three recommendations for executive action and one 

matter for congressional consideration. 

• To ensure that rental assistance funds are effectively distributed to 

properties that have tenants with the greatest need in the multifamily 

housing portfolio, we recommend that the Secretary of Agriculture 

require program officials to (1) establish centralized guidance on 

transferring unused rental assistance, (2) improve sampling methods to 

ensure that a sufficient number of tenant household files are selected 

for supervisory reviews, and (3) improve verification of tenant 

information, including more effective use of alternate methods of 

income verification. 
Page 4 GAO-04-937 Rental Assistance

• To enable RHS to improve its verification of tenant income, this report 

includes a matter for congressional consideration. We recommend that 

RHS be added to Section 453 (j)(7) of the Social Security Act, 

“Information comparisons for housing assistance programs.”4

 This 

action would give RHS access to the National Directory of New Hires 

administered by the Department of Health and Human Services.

In response to our recommendations, RHS agreed to provide centralized 

guidance on transferring unused rental assistance through a new 

administrative notice and to institute broader use of alternate income 

verification methods, such as improved access to wage matching and new 

hires data. However, RHS did not agree to change its sampling methods for 

selecting tenant files when performing supervisory reviews. Instead, RHS 

said that it would revamp the supervisory review process to improve its 

effectiveness and consistency. We agree that the supervisory review 

process should be revised to improve its effectiveness and consistency and 

are encouraged that USDA is taking steps to accomplish this. However, to 

make this process an effective control to provide reasonable assurance that 

rental assistance payments are correct, RHS must also improve its 

sampling methodology, using a statistically valid sample to estimate an 

overall error rate. Thereby, RHS would have a firmer basis for determining 

an approximate sample size for its reviews. 

Background The Section 521 rental assistance program, started in 1978, is administered 

by RHS’s Multifamily Housing Portfolio Management Division. The 

program provides rental assistance for tenants living in units created 

through RHS’s Multifamily Direct Rural Rental Housing Loans and 

Multifamily Housing Farm Labor Loans programs. These programs provide 

loans subsidized with interest rates as low as 1 percent to help build rental 

housing for rural residents and farm workers. Under the rental assistance 

program, eligible tenants pay no more than 30 percent of their income 

toward the rent, and RHS pays the balance to the property owner.5

 

4

42 USC 653 (j)(7).

5

Eligible tenants are persons with very low and low incomes, the elderly, and persons with 

disabilities who are unable to pay the basic monthly rent within 30 percent of their adjusted 

monthly income. Very low income is defined as below 50 percent of the area median income; 

low income is between 50 and 80 percent of area median income. 
Page 5 GAO-04-937 Rental Assistance

RHS allocates rental assistance subsidies through 5-year contracts with 

property owners; 20-year contracts were also issued to units in newly 

constructed properties from 1978 through 1982. In fiscal year 2004, 

contracts were issued for a term of 4 years. The contracts specify that 

owners will receive payments on behalf of tenants in a designated number 

of units at the property. Contracts may be renewed as many times as funds 

are made available, and additional rental assistance units may be allocated 

if funds become available. 

Property owners are required to follow RHS guidance in managing their 

properties.6

 Each month, they must document how many units designated 

for rental assistance are occupied. If a unit is empty and rental assistance is 

not being used, the property owner is required to assign another eligible 

tenant. If no eligible tenants are waiting for the unit, the property owner 

can work with RHS to transfer the rental assistance to another property. 

As shown in figure 1, RHS’s national, state, and local offices share 

administrative duties for the rental assistance program. 

6

Rural Development Instructions allow property owners to delegate or assign management 

responsibilities, in full or in part, to a property manager. Therefore, the term “property 

owner” used throughout this report may also refer to a designated property manager, unless 

property manager is specifically stated.
Page 6 GAO-04-937 Rental Assistance

Figure 1: Duties of RHS National, State, and Local Offices 

The national office develops and implements regulations for the rental 

assistance program and other RHS programs (Rural Development 

Instructions). The current Rural Development (RD) Instruction for the 

rental assistance program has been in effect since the 1980s and was last 

revised in 1993. Other subparts of the RD Instructions also outline 

processes for monitoring RHS programs, including the rental assistance 

program. A proposed rule designed to streamline and consolidate the RD 

Instructions governing the multifamily grant, loan, and rental assistance 

programs was published in the Federal Register in June 2003. The 

proposed rule is intended to modify tenant recertification rules, relieve the 

burden on property owners of recovering unauthorized rental assistance 

from tenants, and reduce the amount of time RHS must wait before 

transferring unused rental assistance. 

National Office

State and local offices

Regulations Budgets Allocations Statistics

Properties

Property owner/

Management companies Tenants

Sources: GAO and Art Explosion (images).
Page 7 GAO-04-937 Rental Assistance

The national office also distributes administrative notices and unnumbered 

letters on an as-needed basis. Administrative notices clarify for state and 

local offices activities outlined in RD Instructions. For example, the 

national office plans to clarify the tenant income verification process and 

provide further guidance on monitoring unused rental assistance for 

transfer through forthcoming administrative notices. Unnumbered letters, 

which address specific issues and are less formal than administrative 

notices, relay important information to state and local offices, but they do 

not pertain to policies and procedures. For example, an unnumbered letter 

released in December 2003 included data aggregated at the national office 

broken down by state and by rental assistance distribution goals, such as 

percentage of supervisory reviews completed, unit vacancies, and unused 

rental assistance.

 The national office also estimates program budgets; allocates funds; and 

tracks nationwide program statistics. State and local offices work directly 

with property owners, property management companies, and tenants to 

monitor the program. State and local offices are responsible for conducting 

financial, management, and physical reviews of the properties; executing 

rental assistance contracts with property owners; approving rent increases; 

and processing rental assistance payments. State and local office staff also 

collect and maintain property and tenant data for their areas. 

Support for the program is also provided through two offices in St. Louis, 

Missouri. The Rural Housing Service Branch of the Information Resources 

Management Office maintains the database systems used to manage 

program data. The Office of the Deputy Chief Financial Officer uses the 

program data to generate and maintain the general ledger and financial 

statements for the program. RHS uses two key database systems to manage 

their multifamily housing programs, including the rental assistance 

program. The Automated Multi-Housing Accounting System (AMAS) stores 

data on rental assistance contract obligations, rental assistance payments 

to property owners, and transfers of rental assistance. The Multi-Family 

Housing Information System (MFIS) tracks property and tenant 

information that determine the monthly request for rental assistance.

As mandated by the Federal Managers’ Financial Integrity Act of 1982, the 

Comptroller General issues standards for internal control in the federal 
Page 8 GAO-04-937 Rental Assistance

government.7 These standards provide the overall framework for 

establishing and maintaining internal control and for identifying and 

addressing major performance and management challenges and areas at 

greatest risk of fraud, waste, abuse, and mismanagement. According to 

these standards, internal control comprises the plans, methods, and 

procedures used to meet missions, goals, and objectives. It is the first line 

of defense in safeguarding assets, and preventing and detecting fraud and 

errors. Internal control, which is synonymous with management control, 

helps government program managers achieve desired results through 

effective stewardship of public resources. No matter how well designed 

and operated, internal control cannot provide absolute assurance that all 

agency objectives will be met, and thus, once in place, internal control 

provides reasonable, not absolute, assurance of meeting agency objectives.

RHS Distributes Rental 

Assistance Funds 

through Contracts and 

Sets Per-Unit Payments 

Based on Tenants’ 

Verified Income Levels 

RHS’s national office provides rental assistance funds to property owners 

through a variety of contracts. Rental assistance can also be transferred, 

under certain conditions, from one property to another. RHS calculates the 

payments property owners receive using information supplied by tenants 

and verified by property owners, who then use the information to create a 

tenant certification form. Tenants’ income must be certified yearly on the 

tenant certification form or whenever significant changes occur—for 

instance, when income increases by a specified amount. Property owners 

send the tenant certification form to the responsible state or local office, 

where RHS staff review the information and calculate the amount of the 

subsidy. In order to receive the monthly payments, property owners must 

provide the appropriate RHS office with a project worksheet- a monthly 

statement showing how many units that are eligible for subsidies are 

occupied by tenants in the program. Figure 2 shows the steps that are 

involved in the distribution process. Plans are under way to streamline the 

payment process, although local office staff are concerned this may 

eliminate their chance to review the information on the project worksheet.

7

Internal Control: Standards for Internal Control in the Federal Government, GAO, 

(Washington, D.C.: November 1999). 
Page 9 GAO-04-937 Rental Assistance

Figure 2: Rental Assistance Distribution Process

Funds Are Distributed to 

Properties through 

Contracts and Transfers of 

Unused Rental Assistance

The rental assistance program provides four types of contracts: renewal, 

construction, servicing, and preservation. RHS officials report that in the 

last few years, 96 percent of annual rental assistance appropriations have 

been used for renewal contracts—that is, contracts that renew expiring 

obligations at existing properties. Construction contracts, which support 

new units in recently constructed properties, account for only 1 percent. 

The remaining 3 percent cover servicing and preservation contracts. 

Property owners who take out loans to rehabilitate properties and then 

raise rents to cover the servicing costs associated with the loan, for 

example, are eligible for servicing contracts that provide additional rental 

assistance to help tenants cope with the rent increase. Preservation 

contracts are offered as an incentive to property owners who are 

considering leaving the program and provide subsidies for additional units 

on the property. 

Property owner

Potential

tenants apply

RHS State or

local office

Renewal

contracts

Rental

assistance

transfers

Project

worksheet

submitted

Servicing

contracts

New

construction

contracts

Preservation

contracts

Rental

assistance

payment to

property owner

Tenants' 

income

certified

RHS

verifies

Project 

Worksheet

Property owner

State or local office

Potential tenants

National office

Source: GAO.
Page 10 GAO-04-937 Rental Assistance

According to the authorizing statute, unused rental assistance is to be 

transferred to properties where the assistance is needed. Transfers can 

occur when state and local offices identify unused rental assistance at a 

property or when a property owner requests such a transfer. For example, a 

property owner may want to transfer unused rental assistance from a 

property that has no eligible potential tenants to one that has many. During 

fiscal year 2003 unused rental assistance on approximately 6,800 units, or 

about 3 percent of all rental assistance units—with a total value of $67 

million—were transferred through about 2,000 transactions. An RHS 

national office official noted that a portion of these units were rental 

assistance transfers accompanying a property transfer, during which an 

eligible property owner assumes another property owner’s loan. 

Property owners may initiate the transfer of unused rental assistance from 

their properties at any time. If the property owner has not used the rental 

assistance on one or more of the covered units for any consecutive 12-

month period, RHS may transfer the unused rental assistance, as long as at 

least one unit at the property remains covered.8

 In either case, before the 

transfer can occur, RHS must verify that the rental assistance has been 

properly marketed by the owner and is not needed at the current property. 

Property owners may appeal decisions to transfer rental assistance from 

their properties by contacting USDA’s National Appeals Division, an 

independent office within USDA. 

RHS Makes Payments on 

the Basis of Information 

Provided by Tenants and 

Verified by Property Owners

As figure 2 shows, a number of steps take place between the time rental 

assistance contracts are made or transferred and the time property owners 

receive payments. The two key steps in this process involve certifying 

tenants’ income information on the tenant certification form and using that 

information to calculate the payments to property owners on the project 

worksheet. (fig. 3). 

8

The consecutive 12-month period can begin only after the end of the first year of the rental 

assistance agreement. RHS’s proposed rule to update the current RD Instructions gives the 

agency the authority to transfer rental assistance that has not been used for a 4-month 

period. (See 7 C.F.R. Part 3560.259, Proposed Rule).
Page 11 GAO-04-937 Rental Assistance

Figure 3: How RHS Uses Information from Tenants to Determine Rental Subsidies

RD Instructions require that tenants be certified at least annually so that 

state and local office staff can document their income and determine their 

rental contributions. Property owners certify tenants initially and then 

every year, or when a tenant’s income rises by $40 or more per month ($480 

per year) or decreases by $20 or more per month ($240 per year). In these 

cases, the income must be verified again. According to RD Instructions, the 

property owner must obtain verification of the tenant’s stated income, in 

writing, from the tenant’s employer. If the owner is not able to immediately 

obtain written verification, the tenant’s income may be temporarily verified 

by examining income checks or check stubs. Income listed from other 

sources, such as Social Security or public assistance, must be verified in 

writing by those sources. Although tenant certifications and income 

verifications help ensure accurate payments to property owners, errors can 

occur when tenants do not accurately report all sources of income or when 

property owners do not adequately verify them. 

Calculating the amount of rental assistance and submitting the information 

to RHS is the second key step. Project worksheets document the rent and 

income levels of tenants for whom the property owner can request rental 

Property owner

RHS state or 

local office

$

Source: GAO.

• Property owner verifies tenant 

 information and enters it into 

Tenant Certification form

• RHS processes 

 Project Worksheet

• RHS pays Rental 

 Assistance • Property owner uses same 

 information to create 

 Project Worksheet

Information

provided

by tenant

Project

Worksheet

Information

from Tenant

Certification
Page 12 GAO-04-937 Rental Assistance

assistance and calculate the amount of rental assistance due.9 Property 

owners submit the project worksheets by mail to state or local offices, 

where, according to RHS guidance, staff are to compare the worksheet 

information with information from MFIS. Once a month, MFIS also 

generates project worksheets, based on the previous month’s occupancy 

reports and the tenant certifications in the system. RHS staff finish 

processing the worksheets by entering the information into AMAS, 

triggering payments to the property owners. 

In over half of the states, individual local offices are responsible for 

processing project worksheets. However, approximately 39 percent (17 out 

of 44) of the state offices we surveyed have chosen to centralize their 

processing function (fig. 4).10

9

Rental assistance is used in conjunction with RHS loans, and is provided directly to the 

owners of some RHS-financed properties. The amount of rental assistance requested by the 

property owner is subtracted from the amount of the property owner’s monthly mortgage 

payment. If the expected amount of rental assistance exceeds the amount of the property 

owner’s monthly mortgage payment, then RHS will issue a rental assistance check to the 

property owner.

10We surveyed only RHS state offices with rental assistance responsibilities. Also, in certain 

instances RHS has a single state office for selected groupings of states. For example, the 

state office for Connecticut, Massachusetts, and Rhode Island is located in Massachusetts. 

Thus, the total number of state offices is less than 50.
Page 13 GAO-04-937 Rental Assistance

Figure 4: Centralized and Decentralized Processing, by State

Note: In certain instances, RHS has a single state office for selected groupings of states. To depict 

centralized status in these selected state groupings, this figure only shades the state where the state 

office is located. See appendix I for more details on RHS’s state groupings.

Program officials in one of these states told us their centralized processing 

center promotes consistency in administering regulatory requirements. In 

another centralized state, an official stated that their centralized payment 

center had helped to cut costs and increase satisfaction, because property 

owners had one place to call when questions or payment issues arose. 

However, program officials in two decentralized states told us that they 

believed that centralized payment systems distanced RHS staff from the 

properties and property owners or managers. 

Source: GAO.

Data not available

Decentralized states

Centralized states

Puerto Rico
Page 14 GAO-04-937 Rental Assistance

RHS’s Plans to Streamline 

the Payment Process Have 

Raised Concerns about 

Eliminating a Layer of 

Review

RHS’s national office is upgrading two systems to streamline the payment 

process. The Management Agency Interactive Network Connection (MINC) 

is a Web-based electronic transmission process that will upgrade the 

current modem-based process, known as the Industry Interface, that 

property owners can use to transmit tenant certifications to RHS. RHS will 

also be upgrading MFIS in order to create electronic project worksheets, so 

that state and local offices will no longer be required to enter data from the 

project worksheets manually into AMAS. Once the property owners 

approve their electronic project worksheets through MINC, the 

information will be transmitted automatically into AMAS to trigger rental 

assistance payments. As of May 2004, five states have been using the MFIS 

upgrade in conjunction with MINC to process payments and the national 

office expects all states will be using it by the end of calendar year 2004. 

Local office staff whom we spoke with during one of our site visits were 

concerned that allowing property owners to approve and submit project 

worksheets electronically will eliminate the local office’s chance to review 

the information while entering it into AMAS. National office staff 

overseeing these changes stated that electronic project worksheets would 

not affect this review, because the property owner would not be able to 

make any changes directly to the electronic project worksheet if he or she 

did not agree with the amount of rental assistance calculated. Rather, any 

modifications to the project worksheets would have to be submitted 

separately to RHS. 

RHS’s National and 

State Offices Monitor 

the Use Of Rental 

Assistance, with Local 

Offices Performing the 

Primary Review Every 

3 Years

RD Instructions provide guidance for monitoring the use of rental 

assistance funds. The guidance requires reviews at the national, state, and 

local levels. However, the triennial supervisory review is the primary tool 

for verifying the accuracy of rental assistance payments. National office 

staff are planning a number of initiatives to increase rental assistance 

monitoring, but a number of key management positions in the national 

office have been unfilled, potentially limiting the effectiveness of 

monitoring efforts. 
Page 15 GAO-04-937 Rental Assistance

Guidance from the National 

Office Establishes 

Monitoring Procedures but 

Is Used Inconsistently and 

Considered Unclear

Two main sets of RD Instructions establish procedures for distributing 

rental assistance. These include: 

• RD Instruction 1930-C, Management and Supervision of Multiple Family 

Housing Borrowers and Grant Recipients, particularly exhibits B and E, 

which establishes criteria for tenant and property eligibility for rental 

assistance, among other things. 

• RD Instruction 1951-K, Exhibit A, Processing Multiple Housing 

Payments, which outlines the rental assistance payment process. 

Although four offices we visited reported following RD Instruction 1930-C 

to process tenant certifications, we found little consistency in the guidance 

RHS offices used to process payments, specifically when processing 

project worksheets. Three offices we visited reported using the AMAS 

Online Cash Manual, which provides instructions on using the AMAS 

database to process payments, but two of those offices also reported using 

different parts of the RD Instructions issued by the national office. One of 

these two offices reported using the RD Instruction 1951-K. One other 

office was unaware of official guidance, and another office told us that they 

referred questions to their AMAS coordinator in the state office.

Likewise, two sets of RD Instructions provide explicit procedures for 

monitoring the rental assistance program, including the purpose, 

frequency, content, and planning and follow-up procedures:

• RD Instruction 2006-M, Management Control System, which outlines the 

reviews used at the national and state office levels: the Management 

Control Review and the State Internal Review; and 

• RD Instruction 1930-C, which outlines the triennial supervisory review 

for local offices. 

The national office conducts the Management Control Review on a 5-year 

cycle to review rental assistance administration in randomly selected 

states. A Management Control Advisory Group, which is made up of 

national and local office employees, determines the time frames, 

objectives, and work plan for the Management Control Review cycle. 

Generally, the objectives are designed to assess state-level administrative 

operations, including financial management, internal control, and 

automated systems. RHS national office staff visit the selected properties 

and review a sample of tenant household files from each. Based on the 
Page 16 GAO-04-937 Rental Assistance

results of the review, the national office has the authority to make 

recommendations to the state offices for improving rental assistance 

administration. 

State offices are required to conduct the State Internal Review at least once 

every 5 years. This review is designed to, among other things, ensure that 

RHS local offices properly implement Rural Development policies and 

procedures. During these reviews, state office staff evaluate program and 

administrative functions at local offices. Reports on the findings from these 

reviews are provided to the state director. 

Local offices are to conduct supervisory reviews at least every 3 years, 

examining a random sample of tenant household files at each property in 

their portfolios, and RD Instructions mandate more frequent reviews for 

delinquent or problem properties. Local office staff in one state we visited 

told us that they conduct approximately one supervisory review per month 

in order to review each property once every 3 years.11 To conduct the 

review, staff are to pull a random sample of at least six tenant household 

files at each property, or review all tenant household files if the property 

has six units or fewer. RHS provides sample forms including a pre-visit 

worksheet to help staff sample units, plan objectives, and assemble 

required documentation for each visit.12 Table 1 shows the number of rental 

assistance units subject to triennial supervisory review at each of the five 

local offices we visited.

11Based on a Connecticut local office portfolio of 34 properties and 920 rental assistance 

units.

12RD Instruction 1930-C, Exhibits F and F-1.
Page 17 GAO-04-937 Rental Assistance

Table 1: Triennial Supervisory Review Workload, Selected RHS Local Offices

Source: GAO. 

In written responses to survey questions, certain respondents cited issues 

related to RHS guidance in the conduct of their rental assistance 

responsibilities. For example, one survey respondent stated that RHS 

guidance needed to be simplified and issued in a timely manner. Another 

survey respondent stated that RHS guidance is sometimes unclear. This 

respondent added that administrative notices helped to some degree but 

added that the office was receiving more guidance from unnumbered 

letters, which do not carry the same force as RD Instructions or 

administrative notices. 

Despite these comments, 80 percent of respondents considered national 

administrative notices helpful or very helpful at clarifying policies and 

procedures established by the national office. However, approximately 50 

percent of respondents were unable to say how many notices the national 

office had issued between January 2003 and January 2004. 

Triennial Supervisory 

Reviews Are RHS’s Primary 

Monitoring Tool for the 

Rental Assistance Program

The triennial supervisory review is the chief activity RHS local offices use 

to verify tenants’ income, assets, and expenses—that is, the information on 

which the tenant certifications and project worksheets, and ultimately 

rental assistance payments, are based. RHS staff look for supporting 

documentation that confirms tenants’ eligibility and income during tenant 

household file reviews and examine the property owner or manager’s 

waiting list, rental rates, and budget. While property owners are required to 

collect supporting documentation for tenants’ claims of income, assets, and 

expenses —a process referred to as third party income verification—RHS 

staff do not see the original documentation tenants provide at any time 

State where local 

office is located

Number of rental 

assistance units

Number of dedicated 

office staff

Number of rental 

assistance 

units per staff

Connecticut 920 2 460

Mississippi 500 4 125

New York 480 2 240

South Carolina 2,149 2 1,075

Utah 368 2 184
Page 18 GAO-04-937 Rental Assistance

other than during triennial supervisory reviews.13 Local office staff in all 

five states selected for site visits told us that triennial supervisory reviews 

were the mechanism they used to monitor the accuracy and completeness 

of tenant certification data. Further information collected from the local 

office staff emphasized the value of triennial supervisory reviews. For 

example, four out of five local offices we visited recalled finding errors or 

questionable tenant documentation during triennial supervisory reviews.

RHS uses the triennial supervisory review and other mechanisms to detect 

unauthorized rental assistance payments but faces challenges recapturing 

the unauthorized payments. Tenant household file reviews can help detect 

erroneous claims that lead to unauthorized payments. For example, during 

a triennial supervisory review, RHS staff in one state found that a property 

owner had allowed a tenant to overstate medical expenses, which could 

lower the tenant’s net income and thus increase the payment RHS makes 

on the rental unit. Employers may also file erroneous third-party income 

verification forms. According to a property owner we visited, such errors 

can occur when employers falsify income information in order to maximize 

rental assistance payments for their employees. RHS can detect such errors 

through wage matching, the process of comparing statements of income by 

tenants or employers to data collected by state wage information collection 

agencies. 

According to RHS officials, recapturing unauthorized rental assistance 

payments once they have been made is difficult. Though RHS can report 

false statements of income to state agencies, these agencies seldom have 

recourse against tenants or employers. When surveyed, 49 percent of RHS 

staff stated that they collect unauthorized rental assistance payments from 

property owners. Owners can, in turn, attempt to collect the unauthorized 

payments from tenants through a repayment agreement. Twenty-nine 

percent of the RHS offices that indicated that their office is able to reclaim 

unauthorized rental assistance reported that they had attempted to initiate 

payment agreements with tenants. However, in written responses to survey 

questions, one respondent noted that the office is not able to recapture 

unauthorized rental assistance in over 95 percent of the cases. Another 

survey respondent stated that the office is successful in recapturing 

unauthorized rental assistance in about 30 to 50 percent of the cases. 

13In one local office we visited, RHS staff stated that they have augmented their review 

process to include spot checks of tenant documentation on an annual basis.
Page 19 GAO-04-937 Rental Assistance

Additionally, survey respondents stated that tenants typically vacated the 

units before the debt was repaid. 

Initiatives to Increase 

Monitoring of the Rental 

Assistance Program Could 

Be Hindered by the Lack of 

Key Managers in the 

National Office

Initiatives are under way at the national office to strengthen monitoring of 

the rental assistance distribution process at all levels. In response to the 

Improper Payments Information Act, the national office is conducting a 

review of properties to determine a nationwide erroneous rental assistance 

payments rate.14 The national office is also attempting to gain access to the 

National Directory of New Hires, which is administered by the Department 

of Health and Human Services. This database would give RHS state and 

local offices access to national wage-matching data that could be used to 

further verify tenants’ income. 

A number of key positions in the Rural Development mission area, 

particularly in the Multifamily Housing Division, have been unfilled since 

approximately March 2003, and existing staff were filling two or more 

administrative roles (fig. 5). 

14The Improper Payments Information Act of 2002 requires that agencies review all their 

programs and activities annually and identify those that may be susceptible to significant 

improper payments. The act further requires those agencies with improper payments 

exceeding $10 million to provide a report on the actions being taken to reduce the 

payments. 
Page 20 GAO-04-937 Rental Assistance

Figure 5: Key Management Positions in the Rural Housing Service, as of July 2004

For example, as of July 2004 the Deputy Administrator of Multifamily 

Housing and Assistant Deputy Administrator of Multifamily Housing 

positions had been unfilled since March 2003 and August 2003, 

respectively.15 Additionally, at times the Deputy Administrator for 

Community Programs filled the roles of both acting Rural Housing Service 

Administrator and acting Deputy Administrator of Multifamily Housing. 16

Finally, the Director of the Portfolio Management Division, which 

administers the rental assistance program, had also at one time filled the 

role of acting Assistant Deputy Administrator for Multifamily Housing. The 

leadership gap could have a negative effect on program staff’s ability to 

15The Deputy Administrator of Multifamily Housing position was filled in August 2004.

16Community Programs, a division of the Rural Housing Service, is part of USDA’s Rural 

Development mission area. Community Programs administers programs designed to 

develop essential community facilities for public use in rural areas.

Rural Housing Service

Administrator

(Position filled July 2004)

Multifamily Housing

Deputy Administrator

(Vacant since March 2003)

Assistant Deputy

Administrator

(Vacant since August 2003)

Processing Division

Director

Portfolio Management

Division Director

Community Programs

Deputy Administrator

Position permanently filled

Position currently vacant but being filled by another employee

Position currently vacant

Points to other positions employee held in an acting capacity (e.g., Portfolio Management

Division Director was also acting Assistant Deputy Administrator at one point)

Source: GAO.
Page 21 GAO-04-937 Rental Assistance

develop and administer new policies in a timely fashion. For example, the 

national office planned to release administrative notices clarifying 

procedures on, among other things, income verification in July 2004. 

However, because of staffing constraints due to the consolidation of RHS 

regulations, the issue date was extended. 

RHS’s Internal Controls 

Do Not Provide 

Adequate Oversight of 

Rental Assistance 

Funds

RHS’s internal controls do not provide reasonable assurance that rental 

assistance funds are used efficiently or that tenants’ incomes and assets are 

adequately verified. First, RHS lacks sufficient guidance to oversee the 

transfer process, creating difficulty in moving unused rental assistance 

throughout the multifamily housing portfolio. Second, the triennial 

supervisory review does not provide reasonable assurance that errors in 

tenants’ income statements and thus in rental assistance payments will be 

prevented or detected in a timely manner. The guidance is inconsistently 

interpreted and the reviews are conducted infrequently using methods, 

specifically the selection of an appropriate sample size to review, which 

may be insufficient. Alternate methods of verification, such as internal 

MFIS database checks and wage matching, could help improve RHS’s 

existing internal controls if properly designed and implemented. 

Insufficient Guidance on 

Transfers Limits Ability to 

Move Unused Rental 

Assistance to Properties 

with the Neediest Tenants 

The majority of survey respondents (52 percent) very frequently or fairly 

frequently encountered high vacancy rates as a cause of unused rental 

assistance. Additionally, when asked to identify the three greatest 

challenges to their offices, survey respondents most frequently listed 

monitoring and filling unit vacancies as the greatest challenge facing RHS 

state and local offices. The current lack of clear guidance on transferring 

unused rental assistance may prevent RHS officials from using transfers as 

a tool to fill vacancies within and outside of a state. 

We found that RHS’s guidance on transfers was not sufficient to meet 

GAO’s Standards for Internal Control in the Federal Government. GAO’s 

standards state that for an entity to run and control its operations, it must 

have relevant, reliable, and timely communications relating to internal as 

well as external events. For communications to be effective, information 

must flow down, across, and up the organization. RD Instructions state that 

transferred rental assistance must be directed to properties with tenants or 

applicants that have the greatest need, based on income level. However, RD 

Instructions are silent on whether state and local offices should transfer 

unused rental assistance to properties within their portfolios or redirect it 
Page 22 GAO-04-937 Rental Assistance

to properties outside their portfolios—either within or outside the state—

where the need is greater. As a result, the guidance is interpreted 

inconsistently, potentially preventing RHS from effectively transferring 

rental assistance.

During our site visits, an RHS official in one state said that her office most 

often conducted transfers within the property owners’ portfolios, but 

officials in other states prioritized transfers to benefit the most needy 

tenants throughout the state. An official noted that RD Instructions did not 

explicitly prioritize such transfers. Further, because RD Instructions do not 

state whether rental assistance is to be transferred only within states or 

among states, three state offices interpreted the RD Instructions as 

allowing the transfer of unused rental assistance to other states with a 

greater need. However, 76 percent of survey respondents reported that 

their office did not have, or they did not know if it had, formal procedures 

for conducting state-to-state transfers. 

In written responses to our survey questions, certain respondents noted 

that RHS guidance on transferring unused rental assistance was 

insufficient. For example, one survey respondent noted that states were 

currently responsible for transferring unused rental assistance without a 

great deal of guidance from the national office. Another respondent noted 

that regulatory and instructional requirements for transferring rental 

assistance were “not efficient.” Yet another noted that RD Instructions did 

not outline procedures for transferring unused rental assistance among 

properties or states. 

Officials in the national office told us that one of their functions was to 

encourage the transfer of rental assistance both within and among states. 

One official stated that RD Instructions did offer guidance on where to 

transfer rental assistance but could not point to specific details. The official 

also stated that the goal of the transfer policy was to provide rental 

assistance to the tenant with the greatest need. However, the current RD 

Instruction on transfers does not provide the necessary control to ensure 

that this goal is met. In addition, to determine where the greatest need 

exists, RHS national office would have to consistently assess need within 

portfolios, within states, and among states. RHS officials acknowledged 

that they were reviewing the guidance on transfers and stated that RHS 

planned to issue an administrative notice to clarify procedures for 

transferring unused rental assistance.
Page 23 GAO-04-937 Rental Assistance

The issue of unclear guidance on transfers is complicated by the fact that 

RD Instructions give property owners certain protections that limit 

transfers of unused rental assistance. While RHS can transfer unused rental 

assistance on covered units after 12 months, at least one unit must remain 

covered at the property. RHS must also notify property owners 30 days in 

advance of its intent to make a transfer and ensure that the property 

owners know their appeal rights. According to RHS officials in the states 

we visited, property owners most often instigated transfers when they 

occurred, typically to other properties they owned. An official in one state 

estimated that property owners initiated 95 percent of transfers in that 

area. 

We found that RHS officials in one state hesitated to recommend 

transferring unused rental assistance outside of the property owner’s 

portfolio because of the appeals process. The State Director of Rural 

Development in that state said that it could take at least 18 months to 

transfer unused rental assistance to another property if the property owner 

appealed, as the appeals process could take up to 6 months. Additionally, 

one survey respondent would have liked to have the authority to transfer 

unused rental assistance without giving the property owner appeal rights. 

RHS national office officials noted that, since 2001, there had been only two 

requests for review of a property owner’s appeal. In both cases, RHS’s 

National Appeals Director decided against the property owner, and allowed 

RHS to transfer the unused rental assistance to properties outside of the 

property owner’s portfolios. 

Triennial Supervisory 

Reviews Are Not Adequate 

as the Primary Monitoring 

Tool for the Rental 

Assistance Program 

Approximately 56 percent of survey respondents reported that they were 

able to verify the accuracy of information provided during the tenant 

certification process. Of those, 56 percent said they did so during the 

triennial supervisory review. Likewise, all of the local offices we visited 

during our site visits stated that information provided for tenant 

certifications was verified during or in preparation for triennial supervisory 

reviews. And approximately 83 percent of survey respondents reported 

that triennial supervisory reviews provided them with the information 

necessary to effectively monitor properties in their portfolios to a great or 

very great extent. 

However, we found that the triennial supervisory review was not a 

sufficient means of detecting problems such as misreported income, 

verification errors, and unauthorized rental assistance payments. GAO’s 

standards state that internal control should generally be designed to assure 
Page 24 GAO-04-937 Rental Assistance

that ongoing monitoring occurs in the course of normal operations, is 

performed continually, and is ingrained in the agency’s operations. RHS’s 

triennial supervisory reviews did not meet this standard because they are 

conducted infrequently using a sample size that may be too small to 

provide reasonable assurance that all tenant certifications are reviewed at 

least once or more than once every several years. RD Instructions require a 

sample of at least six tenant household files from a property with more 

than six units, and all tenant household files for properties with six units or 

fewer. With a sample size this small, however, tenants could move from a 

unit they had rented before the local office has a chance to sample their 

household file during a supervisory review. 

Local offices in the states we visited said that they interpreted RD 

Instructions as requiring a 20- or 25-percent sample of tenant household 

files. However, we found that staffing and time limitations did not allow 

staff to conduct the reviews this way.17 For example, an official in one local 

office stated that her office reviewed six tenant household files for every 

property, even if 20 percent of the property comprised a greater number of 

units. Furthermore, about 20 percent of survey respondents reported not 

having sufficient staff to conduct reviews, and about 27 percent reported 

not having sufficient time to conduct the reviews according to the RD 

Instructions. A local office official in another state we visited said that staff 

reviewed either six tenant household files or 10 percent of the totalwhichever was greater. Even if the local offices consistently used a 20 

percent or 25 percent sample of tenant household files, however, as figure 6 

shows a rental assistance unit could go without review for 12 to 15 years.18 

17A national office official stated that local offices likely interpret the Instructions this way 

because Exhibit F-1 in RD Instruction 1930-C uses 25 percent as an example sample size. 

Ultimately, according to the Instructions, the percentage of units a local office should 

review is based on that office’s “preference for sample size,” as long as local offices select at 

least six units for properties with six or more units. 

18This figure assumes a 20 percent or 25 percent sampling of tenant household files. The 

figure also assumes that RHS local staff sample tenant household files without replacement. 

That is, the portion of files selected on an initial supervisory review will not be selected for 

subsequent supervisory reviews.
Page 25 GAO-04-937 Rental Assistance

Figure 6: Frequency of Supervisory Reviews of Tenant Household Files 

Note: This figure assumes a 20 percent or 25 percent sampling of tenant household files. This figure 

assumes that RHS local office staff sample tenant household files without replacement. That is, the 

portion of files selected on an initial supervisory review will not be selected for subsequent supervisory 

reviews.

RHS’s national office does not have a basis for determining whether 

sampling a minimum of six tenant household files per property is sufficient 

to provide reasonable assurance that errors in tenant and payment 

information are adequately detected. In order to design a cost efficient 

sampling strategy that can provide reasonable assurance with respect to 

tenant income and rental assistance payments, RHS needs information on 

the overall error rates. One way to determine an overall error rate is to 

conduct a national statistically valid random sample of tenant household 

files. Information gathered from this sample would provide RHS with a 

better idea of the level of erroneous income tenants were reporting and 

enable RHS to estimate the level of improper rental assistance payments 

that are being made throughout the program. In addition, it would provide 

RHS officials with valuable information on how to structure future 

supervisory reviews in a more efficient and effective manner. 

In a June 2003 report assessing controls over the tenant certification 

process and accuracy of rental subsidies conducted by the USDA Office of 

Inspector General, the audit team found that in Florida, tenant 

certifications for an estimated 20.8 percent of the 14,705 units contained 

errors that resulted in households receiving an estimated $4.7 million in 

25% sample 25% sample 25% sample 25% sample

Total units

12 years

3 years

Time to review all units

Represents 1 supervisory review per every 3 years

20% sample 20% sample 20% sample 20% sample 20% sample

Total units

15 years

3 years

Source: GAO.
Page 26 GAO-04-937 Rental Assistance

improper rental subsidies.19 This finding emphasizes the importance of 

being able to detect errors in tenant information in a timely manner. 

In March 2004, RHS began a review of properties to determine an overall 

error rate for rental assistance payments to comply with the Improper 

Payments Information Act. RHS officials selected a sample of 539 assisted 

units in 321 RHS properties, and the national office expects to report their 

findings by the end of September 2004.20 Until RHS determines an overall 

error rate using a statistically valid sample, RHS will not be able to 

determine an appropriate sampling strategy for use with supervisory 

reviews to estimate error rates and compliance with internal controls. 

GAO’s internal control standards also state that agencies should evaluate 

their monitoring activities, and the evaluations should depend on the 

assessment of risks and the effectiveness of the monitoring procedures. 

RHS officials in the states we visited said that they found errors or 

questionable tenant documentation during triennial supervisory reviews. 

For example, RHS officials in one state said that they would follow up with 

the property owner if they found errors in the data that are being verified. 

The official added that property owners might be given a 15- or 30-day 

period to correct any deficiencies. An RHS official in another state said that 

RHS staff sometimes found questionable supporting documents during 

triennial supervisory reviews. The official explained that the staff note the 

problem in the triennial supervisory review report and request that the 

property owner obtain the correct documentation. These examples suggest 

that, if properly designed and implemented, the triennial supervisory 

review can be valuable in detecting tenant and payment errors. 

19The 95 percent confidence interval for the 20.8 percent estimate is from 11.3 to 30.2 

percent. The estimated $4.7 million, reported in “Rural Development, Rural Housing Service, 

Rural Rental Housing Program, Tenant Income Verification, Gainesville, Florida, Audit No. 

04004-3At,” consisted of estimated overpayments of $4.4 million and underpayments of $0.3 

million. The 95 percent confidence interval for this total amount extends from $2.4 to $7.0 

million.

20We did not assess the validity of RHS’s sample selection methods.
Page 27 GAO-04-937 Rental Assistance

Alternate Controls Used by 

RHS to Verify Tenant and 

Payment Information Have 

Had Limited Effectiveness

RHS staff use alternate controls, such as MFIS database checks and wage 

matching, to verify tenant and payment information. According to RHS 

officials, the MFIS system has internal checks that help RHS officials avoid 

and catch errors. When tenant certifications are submitted electronically 

through the Industry Interface, MFIS automatically rejects those that are 

problematic. For example, a tenant certification would be rejected if it 

showed that the tenant might already reside at another property—that is, if 

the tenant’s Social Security number already existed within the system. 

Also, MFIS allows RHS officials to reject tenant certifications for certain 

reasons and thus flag them for review. For example, as we have seen 

tenants must recertify their eligibility for rental assistance if their income 

increases by $40 a month ($480 a year) or decreases by $20 a month ($240 a 

year). MFIS allows each office to compare incoming tenant certifications to 

the prior batch of tenant certifications. RHS staff in each office can then 

establish a threshold in MFIS to reject tenant certifications that show a 

change in income of more than an established amount, for example, 20 

percent, and hold them for further review. 

Although RD Instructions determine income changes in terms of dollar 

amounts, the MFIS database check has been implemented to use 

percentages to set the threshold for rejecting tenant certifications. 

However, setting the threshold in terms of dollar amounts would be 

consistent with the RD Instruction that describes how to determine 

changes in income. For example, if a tenant reported zero income on an 

initial certification, any subsequent increase in income would be more than 

20 percent, thereby triggering a rejection, although the dollar increase 

could be less than $40. Likewise, if a tenant’s reported income increased 

from $30 to $40 per month, for example, the MFIS system would also reject 

this certification because the percentage increase is greater than 20 

percent. However, a $10 increase in income is not enough to warrant 

recertification. But if a tenant’s reported income increased from $300 to 

$345 per month, MFIS would accept this certification because the 

percentage increase in income is less than 20 percent, although the dollar 

increase is more than $40.

An RHS official in the national office stated that the MFIS database check 

could be designed to use dollar amounts instead of percentages to establish 

the threshold. In either case, however, the national office does not 

currently have an established percentage benchmark in MFIS for all offices 
Page 28 GAO-04-937 Rental Assistance

to use, and RHS local offices are not setting the thresholds consistently.21 In 

one local office we visited, RHS staff established their threshold to reject 

tenant certifications that change by 20 percent. However, in another state 

we visited, local office staff set MFIS to reject changes in income of 25 

percent or more. Setting the threshold higher than an established 

benchmark would make this control less effective at detecting changes in 

income. Setting a threshold lower than an established benchmark would 

make this control more effective but would result in a higher number of 

pending certifications that would likely require more staff resources.

Although the RHS national office has established the MFIS database check 

as a control, we identified and were told of errors on tenant certifications. 

For example, in one state we identified a tenant certification that listed two 

dependents as living in a unit receiving rental assistance. However, the 

dependents were not listed in MFIS. RHS local office officials stated that, in 

such a situation, the two dependents would not change the amount of rent 

owed by the tenant or the amount of rental assistance due to the property 

owner. But because rental assistance payments are based on household 

size, among other things, the presence or absence of dependents could 

influence rental assistance payments. For example, if a tenant got married 

an additional person would be living in the unit and would possibly have an 

additional source of income. If a tenant gave birth, the tenant would receive 

an income deduction for the newborn, decreasing the amount of income 

used in determining the amount of the rental assistance payment. 

Further, RHS officials in four of the states we visited stated that, following 

RHS guidance, they verified the accuracy of rental assistance payments by 

comparing property owners’ project worksheets with project worksheets 

generated using MFIS. According to an RHS official, any errors on the 

property owners’ project worksheets should be detected during the 

comparison with the MFIS-generated project worksheet. But since the 

MFIS project worksheet is generated with the same information from 

tenant certifications that property owners used to generate their project 

worksheets, RHS is essentially comparing duplicate data from the same 

source (see fig. 7). 

21A national office official stated that the benchmark was 10 percent when this database 

check was designed, but noted that MFIS had been redesigned to give local offices the 

flexibility to establish their own thresholds. 
Page 29 GAO-04-937 Rental Assistance

Figure 7: Process Used to Verify the Accuracy of Rental Assistance Payments

According to GAO Standards for Internal Control in the Federal 

Government, such a check is not sufficient. Internal control calls for 

comparisons and assessments using different sets of data so that 

relationships can be analyzed and appropriate actions taken. In order for 

RHS to have a meaningful reconciliation, MFIS data would need to be 

compared with a different data source to identify differences in reported 

tenant and payment information.

An RHS official in the national office believed that this internal control 

standard is not applicable to this situation. The official stated that 

discrepancies between the MFIS-generated project worksheet and the 

property owner’s project worksheet often arise because the property 

owner may not send complete information. For example, if a property 

owner did not submit a form indicating that a tenant had vacated a unit, or 

if the owner did not perform a calculation correctly, a discrepancy would 

Information

provided

by tenant

Information

provided

by tenant

Tenant

Certification

Property owner

MFIS

USDA/RHS

Local Office

Information

provided

by tenant

Property owner

Project Worksheet

Information

provided

by tenant

Property owner

Project Worksheet

Information

provided

by tenant

Tenant

Certification

MFIS

Project Worksheet

Owner

enters tenant

information

Calculations between the two

worksheets are compared monthly

Submitted yearly

(or when changes occur)

via electronic or paper copy

Submitted monthly

via paper copy

Sources: GAO and Art Explosion (images). 
Page 30 GAO-04-937 Rental Assistance

occur that RHS would look into. We agree that this system can catch errors 

of inconsistency. But a property owner could consistently be submitting 

complete, but inaccurate, information reported by the tenant. In such 

cases, RHS would not be able to detect errors or improper rental assistance 

payments by comparing the two project worksheets. RHS would need to 

consult another source of information, such as data on earned income that 

could be used for wage matching, to verify that information reported by the 

tenant and submitted by the property owner is accurate. Wage matching 

would allow staff to verify tenant’s reported income using wage 

information collected by the state. 

RHS was told by the USDA Office of the Inspector General over 5 years ago 

to continue their efforts to ensure that RHS state and local offices utilize 

wage matching to detect misreported tenant income.22 In a February 1999 

report, the Inspector General’s audit team evaluated methods RHS and 

property owners used to ensure that tenants’ incomes were properly 

reported on tenant certifications. The audit team found that 47 percent of 

tenant certifications in six states (29,238 out of 62,815) were incorrect due 

to inaccurately reported income, income changes, and property managers 

that did not properly verify income reported by tenants. Further, the audit 

team found that about 93 percent of the income errors involved tenants 

that had reported earned income. The Inspector General recommended 

that RHS be more aggressive in expanding its wage-matching efforts.

Some RHS state offices are granted access to wage-matching data through 

agreements between the offices and wage collection agencies, such as state 

labor departments. These agreements follow state laws. Our survey results 

showed that 64 percent of RHS state offices (28 of 44 RHS state offices that 

responded) had access to state employment information to conduct wage 

matching (see fig. 8.) 

22USDA Office of the Inspector General Evaluation Report No. 04801-0004-Ch, Rural 

Housing Service, Rural Rental Housing Program, Tenant Income Verification Process, 

Washington, D.C., Feb. 1999. 
Page 31 GAO-04-937 Rental Assistance

Figure 8: States with Wage-Matching Agreements

Note: In certain instances, RHS has a single state office for selected groupings of states. To depict 

wage-matching status in these selected state groupings, this figure only shades the state where the 

state office is located. See appendix I for more details on RHS’s state groupings.

However, some RHS officials believe that state-based wage matching has 

limitations. For example, officials in one state we visited noted that their 

office did not place much emphasis on wage matching because their area 

bordered other states and many individuals worked across state lines. 

Without access to wage-matching data in the bordering states, RHS staff 

were not able to adequately certify reported income. Further, officials 

noted that state wage data were often outdated and did not capture all 

sources of income.

RHS is attempting to acquire access to the Department of Health and 

Human Services’ National Directory of New Hires by contacting the U. S. 

Department of Housing and Urban Development (HUD) to discuss the 

Data not available

States without wage-matching agreements

Source: GAO.

States with wage-matching agreements

Puerto Rico
Page 32 GAO-04-937 Rental Assistance

language originally proposed by HUD for the authority to use the 

directory.23 The National Directory of New Hires, which includes 

centralized sources of state wage, unemployment insurance, and new hires 

data for all 50 states, would provide nationwide data for wage matching. 

Access to this directory would likely help solve the problem of verifying 

income for tenants who work across state lines. Also, wage data from the 

National Directory of New Hires is more recent than state data and 

captures all earned income. 

Conclusions RHS’s internal controls do not provide reasonable assurance that rental 

assistance resources are used effectively. RHS national office transfer 

guidance is insufficient and RHS local offices have inconsistently 

interpreted what is available. As a result, rental assistance funds may not 

be directed to the most needy tenants or may go unused. Additionally, the 

infrequency of the triennial supervisory reviews using a sampling 

methodology that may be insufficient cannot reasonably ensure that 

tenants’ income and assets, and ultimately rental assistance payments, are 

adequately verified. RHS does not have a basis for determining what 

constitutes a sufficient sample size for the triennial supervisory reviews 

without establishing an overall error rate for rental assistance payments. 

These shortcomings increase the risk that RHS will provide rental 

assistance to tenants that may not be eligible. 

RHS currently uses alternate methods of income verification, including 

MFIS database checks that, if properly designed and implemented, could 

provide reasonable assurance that errors in tenant and payment 

information are detected in a timely manner. However, the effectiveness of 

these alternate methods is limited because of their faulty design and 

implementation. RHS officials stated that access to the National Directory 

of New Hires would help with income verification and has made efforts to 

gain access to this information. 

23Through Section 453 (j)(7) of the Social Security Act, “Information comparisons for 

housing assistance programs,” 42 USC 653 (j)(7), HUD was given the authority to access 

nationwide tenant wage information through the National Directory of New Hires. 

According to RHS, its request for inclusion, however, came too late.
Page 33 GAO-04-937 Rental Assistance

Recommendations for 

Executive Action

To ensure that rental assistance funds are effectively distributed to 

properties that have tenants with the greatest need, GAO recommends that 

the Secretary of Agriculture require program officials to (1) establish 

centralized guidance on transferring unused rental assistance, (2) improve 

sampling methods to ensure that a sufficient number of tenant household 

files are selected for supervisory reviews and (3) improve verification of 

tenant information including more effective use of alternate methods of 

income verification. 

Matter for 

Congressional 

Consideration

Congress may wish to consider adding RHS to Section 453 (j)(7) of the 

Social Security Act, “Information comparisons for housing assistance 

programs.”24 This action would grant RHS access to the Department of 

Health and Human Services’ National Directory of New Hires for wagematching purposes. If such access were granted, RHS and the Department 

of Health and Human Services would have to develop specific procedures 

to facilitate it.

Agency Comments and 

Our Evaluation

We provided USDA with a draft of this report for review and comment. The 

Acting Undersecretary for Rural Development provided written comments 

that are presented in appendix IV. The letter included a summary of 

activities that were planned or had recently begun at RHS that the Acting 

Undersecretary said were designed to improve the oversight, monitoring, 

and guidance of the multifamily housing program.

In response to our recommendation on establishing centralized guidance 

on transferring unused rental assistance, the Acting Undersecretary for 

Rural Development agreed to establish this guidance in an administrative 

notice. Concerning our recommendation that RHS improve sampling 

methods to ensure that a sufficient number of tenant files are selected for 

supervisory reviews, the Acting Undersecretary responded that USDA 

would instead revamp the supervisory review process to improve its 

effectiveness and consistency. We agree that the supervisory review 

process should be revised to improve its effectiveness and consistency and 

are encouraged that USDA is taking steps to accomplish this. However, to 

make this process an effective control to ensure that the rental assistance 

2442 USC 653 (j)(7).
Page 34 GAO-04-937 Rental Assistance

payments are correct, or that incorrect payments are discovered in the 

normal course of business, USDA must also improve its sampling 

methodology as we described in the report. In particular, RHS must 

determine an overall error rate using a statistically valid sample to 

determine how many tenant household files are sufficient to detect errors. 

Unless this methodology is improved in conjunction with the supervisory 

review process, USDA will continue to lack any assurance as to the 

propriety of the rental assistance payments that are not reviewed. The 

Acting Undersecretary agreed with our recommendation that RHS improve 

its methods for verifying tenant information, including using alternate 

income verification methods. He stated that USDA would institute broader 

use of alternate income verification methods, such as improved access to 

wage matching and new hires data, but noted that USDA needed to be able 

to share this data with third parties, particularly the property owners. As 

noted in this report, if RHS were granted access to data from the National 

Directory of New Hires, RHS and the Department of Health and Human 

Services would have to develop specific procedures to facilitate such 

access. 

The Acting Undersecretary also noted that GAO said in the report that 

streamlining and automating borrower’s requests for rental assistance 

payments could remove an important layer of agency review. However, 

GAO did not take a position on this issue. We merely summarized concerns 

expressed by RHS local office staff we visited, attributing the comments 

appropriately. We also noted that national office staff overseeing the 

changes had told us that streamlining the payment process would not 

eliminate this review and that not all states were currently using the 

streamlined process. Finally, we incorporated updated information USDA 

provided on RHS staffing. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to interested 

Members of Congress and congressional committees. We will also send 

copies to the Secretary of the Department of Agriculture and the Director 

of the Office of Management and Budget and make copies available to 

others upon request. In addition, this report will be available at no charge 

on the GAO Web site at http://www.gao.gov. Our survey of RHS state and 

local offices administering Section 521 rental assistance and a more 

complete tabulation of the survey results (GAO-04-978SP) will also be 

available on the GAO Web site at www.gao.gov/cgi-bin/getrpt?GAO-04-

978SP.
Page 35 GAO-04-937 Rental Assistance

Please contact me at (202) 512-4325, or Andy Finkel at (202) 512-6765, if 

you or your staff have any questions concerning this report. Key 

contributors to this report are listed in appendix V.

Sincerely yours,

William B. Shear

Director, Financial Markets and 

Community Investment
Page 36 GAO-04-937 Rental Assistance

Appendix I

Scope and Methodology ApApenednxidexiIs

To determine how RHS distributes rental assistance funds and monitors the 

rental assistance program, and to identify the internal controls RHS has 

established to ensure that rental assistance funds are administered and 

used effectively, we collected written and testimonial information from 

agency officials in the national office and in the Office of the Deputy Chief 

Financial Officer in St. Louis, Missouri on the rental assistance distribution 

process and the guidance governing the distribution process. We consulted 

GAO’s Standards for Internal Control in the Federal Government

(GAO/AIMD-00-21.3.1) to review control activities that apply to RHS’s 

distribution of rental assistance funds. We used these standards to assess 

whether RHS’s current internal controls were sufficient to effectively 

monitor the rental assistance program. 

We also surveyed RHS state and local offices that were identified as having 

rental assistance responsibilities by their respective State Directors or the 

appropriate designee. We identified 248 state and local offices with rental 

assistance responsibilities.1

 These consisted of 46 RHS state offices and 202 

local offices in existence as of December 2003.2 To ensure security and data 

integrity, we provided each of the 248 offices with a web address, a unique 

identification number, and a password to allow the office access to one 

questionnaire. 

The questionnaire covered topics related to the rental assistance program. 

Specifically, the questions covered general office and staff information, 

renewal contracts, unused rental assistance, transfers, tenant 

certifications, project worksheets, rent setting, reserve accounts, and 

technology and resources. To prepare for the survey, we conducted 

interviews in three state offices: the combined state office of Maryland and 

Delaware, and the Texas and Illinois state offices, and interviewed RHS 

local offices in Texas and Illinois. Of these, Maryland and Delaware and 

Texas had centralized their processing of rental assistance payments. We 

also pretested the questionnaire with state and local offices in 

Pennsylvania and Wisconsin to determine whether respondents would 

1

Consistent with its use throughout this report, the term “local office” encompasses RHS 

local, area, servicing, and field offices.

2

The following state groupings have a combined state office: Delaware and Maryland; 

Florida and the Virgin Islands; Hawaii, American Samoa and the Western Pacific; 

Massachusetts, Connecticut and Rhode Island; and Vermont and New Hampshire. Also, we 

only surveyed state offices with rental assistance responsibilities. Thus, the number of state 

offices we surveyed was less than 50.
Appendix I

Scope and Methodology

Page 37 GAO-04-937 Rental Assistance

understand questions the way we intended. Since the questionnaire was 

administered via the Internet, we conducted a usability pretest with yet 

another RHS local office in Virginia to observe respondents answering the 

questionnaire as it would appear when activated. 

We took the following steps to increase the response rate for all sectors of 

the population. We sent one reminder notice via e-mail and conducted 

follow-up telephone calls to those offices that did not respond to our 

survey by the initial deadline. Collection of survey data ended on May 3, 

2004. We received responses from 230 offices, providing an overall 

response rate of 92.7 percent. Specifically, 44 state offices and 186 local 

offices responded, resulting in response rates of 95.7 percent and 92.1 

percent, respectively. We did not independently verify the information 

obtained through the survey. 

The practical difficulties of conducting any survey may introduce certain 

types of errors, commonly referred to as nonsampling errors. For example, 

differences in how a particular question is interpreted, the sources of 

information available to respondents, or the types of people who do not 

respond can introduce unwanted variability into the survey results. Steps 

such as pretesting and follow-up contacts to increase response rates serve 

to minimize nonresponse error. In addition, steps such as performing 

statistical analyses to identify inconsistencies and having a second 

independent reviewer for the data analysis can further minimize such error.

Data from the Web survey were entered electronically by participants and 

imported into an electronic data file. Close-ended questionnaire items were 

analyzed using statistical software. A coding scheme was developed, and 

open-ended questionnaire items were content analyzed by two trained 

coders, who revised their codes until 100 percent agreement was reached. 

The results of the content analysis apply only to those survey participants 

who provided responses. We only content analyzed open-ended responses 

that were discussed in this report. We conducted our survey work from 

April 2003 through July 2004 in accordance with generally accepted 

government auditing standards.

To obtain more in-depth information, we conducted site visits to RHS state 

and local offices in five states: Utah; South Carolina; New York; Mississippi; 

and the Connecticut, Massachusetts, and Rhode Island state grouping. We 

designed a site visit interview guide that enabled the team to follow the 

distribution process beginning with the property owner or manager and 

proceeding to the local office, and finally, to the state office. Using the 
Appendix I

Scope and Methodology

Page 38 GAO-04-937 Rental Assistance

interview guide, we observed and discussed with RHS staff the tenant 

certification, project worksheet, and transfer processes, among others. 

To determine the states where we would conduct the site visits, we 

conducted a stratified random sample. Two centralized and three 

decentralized states were randomly selected from a list of state offices, 

after eliminating the offices we visited to prepare and pretest the survey.3

After the state offices were selected, we randomly selected one local office 

from the local offices available in that state. We judgmentally selected the 

property owners based on their distance from the local office and their 

most recent rental assistance transfer. However, the experiences of these 

states are not necessarily representative of the experiences of any other 

state. 

During each of the site visits, we interviewed a property owner or manager, 

RHS officials in a local office, and RHS officials in the state office. Using 

the interview guide, we also obtained key documents related to the three 

processes that were being discussed. Specifically, the interview guide 

required the team to obtain from the property owner or manager the most 

recent, completed project worksheet; tenant certifications associated with 

certain rental assistance units; tenant applications corresponding to the 

tenant certifications; a current waiting list; and documentation of a recent 

transfer of rental assistance. We tracked these documents through the local 

offices and the state offices to observe internal controls at each level. After 

all site visits were completed, we interviewed officials from RHS’s Office of 

the Deputy Chief Financial Officer to obtain information on their role in the 

rental assistance distribution process. Last, we interviewed the RHS 

national office to determine its role in monitoring the rental assistance 

distribution process and to assess the internal controls they have 

established to oversee rental assistance funds. 

We also consulted GAO’s Standards for Internal Control in the Federal 

Government to review control activities that apply to RHS’s distribution 

and monitoring of rental assistance funds. We reviewed site visit 

documents to provide examples of RHS’s internal controls. We performed 

our site visit work from March through May 2004 in accordance with 

generally accepted government auditing standards.

3

During our site visits, we learned that one of the two centralized states selected was, in fact, 

a decentralized state for rental assistance payment processing.
Page 39 GAO-04-937 Rental Assistance

Appendix II

State Office Survey Responses for Rural 

Rental Housing (RRH) Properties ApendxiI

 State RRH properties RRH units

RRH units 

occupied by zero 

income tenants, as 

of 1/1/04

RRH units 

occupied by rentoverburdened 

tenants, as of 

1/1/04

RRH units receiving 

rental assistance

Alaska 42 897 32 44 784

Alabama 495 16,191 954 3,206 8,033

Arkansas 361 9,908 174 1,076 6,092

Arizona 118 3,775 140 217 3,080

Delaware 221 6,975 581 320 4,210

Georgia 478 15,427 233 4,134 7,972

Hawaii 22 903 3 3 680

Iowa 679 11,717 242 170 8,884

Kansas 409 6,651 111 613 3,858

Kentucky 456 12,284 291 525 6,437

Louisiana 415 12,637 347 2,360 7,537

Massachusetts 143 4,949 491 349 3,487

Michigan 723 18,653 NR NR 8,905

Minnesota 673 12,064 DC DC 6,389

Missouri 896 19,868 DK 1,964 8,493

Mississippi 564 16,416 669 1,252 8,825

Montana 168 2,634 87 184 1,939

North Dakota 253 3,365 187 102 2,147

Nebraska 280 3,908 197 141 2,566

New Jersey 83 3,347 78 445 2,009

New Mexico 116 4,005 347 211 3,072

Nevada 80 1,800 DK DK 1,100

New York 471 13,210 148 1,101 5,194

Ohio 402 14,912 553 1,429 8,905

Oklahoma 302 8,111 224 140 5,130

Pennsylvania 330 10,640 DC DC 6,840

South Carolina 352 12,309 430 2,847 5,880

South Dakota 503 6,844 DK 70 4,570

Tennessee 386 13,038 DK DK 6,539

Texas 804 26,466 707 4,046 14,397

Utah 93 2,095 DK DK 1,595

Virginia 272 10,498 DC DC 6,461
Appendix II

State Office Survey Responses for Rural 

Rental Housing (RRH) Properties

Page 40 GAO-04-937 Rental Assistance

Source: GAO.

Notes: 

DC = Don’t collect

DK = Don't know

NR = No response

We surveyed only state offices with rental assistance responsibilities. Also, in certain instances, RHS 

has a single state office for selected groupings of states. For these selected groupings, this chart only 

displays the state name where the state office is located. Thus, the total number of state offices is less 

than 50. See appendix I for more details on RHS's selected state groupings.

This chart displays survey responses for RHS state office respondents only, if they indicated that they 

had Rural Rental Housing (Section 515) properties in its portfolio and if they provided data other than 

Don't Collect, Don't Know, or No Response for at least one of the above questions.

Washington 298 8,989 97 909 6,205

West Virginia 255 7,221 281 977 4,240

Wyoming 62 1,655 118 252 1,188

(Continued From Previous Page)

 State RRH properties RRH units

RRH units 

occupied by zero 

income tenants, as 

of 1/1/04

RRH units 

occupied by rentoverburdened 

tenants, as of 

1/1/04

RRH units receiving 

rental assistance
Page 41 GAO-04-937 Rental Assistance

Appendix III

State Office Survey Responses for Off Farm 

Labor Housing (FLH) Properties ApendxiI

Source: GAO.

Notes: 

DK = Don't know

We surveyed only state offices with rental assistance responsibilities. Also, in certain instances, RHS 

has a single state office for selected groupings of states. For these selected groupings, this chart only 

displays the state name where the state office is located. Thus, the total number of state offices is less 

than 50. See appendix I for more details on RHS's selected state groupings.

This chart displays survey responses for RHS state office respondents only, if they indicated that they 

had Off Farm Labor Housing (Section 514/516) properties in its portfolio and if they provided data 

other than Don't Collect, Don't Know, or No Response for at least one of the above questions.

 State Off FLH properties Off FLH units

Off FLH units 

occupied by zero 

income tenants, as 

of 1/1/04

Off FLH units occupied by 

rent-overburdened tenants, 

as of 1/1/04

Off FLH units 

receiving rental 

assistance

Hawaii 1 31 0 0 10

Massachusetts 2 48 2 1 46

Michigan 2 44 0 0 43

New Mexico 5 111 19 5 103

Oklahoma 2 42 0 0 39

Texas 20 1,415 13 36 1,000

Virginia 2 46 DK DK 34

Washington 24 753 9 21 521
Page 42 GAO-04-937 Rental Assistance

Appendix IV

Comments from the U.S. Department of 

Agriculture ApendxiIV
Appendix IV

Comments from the U.S. Department of 

Agriculture

Page 43 GAO-04-937 Rental Assistance
Appendix IV

Comments from the U.S. Department of 

Agriculture

Page 44 GAO-04-937 Rental Assistance
Page 45 GAO-04-937 Rental Assistance

Appendix V

GAO Contacts and Staff Acknowledgments ApendxiV

GAO Contacts Andy Finkel (202) 512-6765 finkela@gao.gov

Katherine Trimble (202) 512-5033 trimblemk@gao.gov

Staff 

Acknowledgments

In addition to those named above, William Bates, Emily Chalmers, Jamila 

Jones, Austin Kelly, Alison Martin, Marc Molino, and Julie Trinder made key 

contributions to this report.

(250197)
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