U. S. Department of Housing and Urban Development

Office of Inspector General for Investigation

Inspections and Evaluations Division

Recovery Accountability and Transparency Board

Survey of Contracts and Grants Workforce

Staffing and Qualifications

Evaluation of Reported Staffing Levels

March 2010

IED‐09‐006
ii 

Executive Summary 

The Office of Inspector General, Inspections and Evaluations Division, conducts independent, 

objective examinations of U.S. Department of Housing and Urban Development (HUD) 

activities, programs, operations, and organizational issues. 

We evaluated HUD’s September 2009 response to questions in the Recovery Accountability and 

Transparency Board’s (Board) survey of staff resources dedicated to American Reinvestment 

and Recovery Act of 2009 (Recovery Act or ARRA) activities. Thirteen HUD offices and/or 

program areas responded to the survey questions by entering data on total actual hours spent on 

ARRA activities from April 1 through June 30, 2009 (3rd quarter, fiscal year (FY) 2009), and 

forecasted to be spent from July 1 through December 31, 2009, and January 1 through June 30, 

2010. We wanted to know whether the reported number of HUD contract and grant personnel 

responsible for ARRA funding and oversight could be validated and relied on for public 

disclosure. 

We determined that the full-time equivalent (FTE) staffing levels submitted in response to the 

Board survey could not be validated and reflected “informed estimates” by headquarters program 

management of ARRA activities. Documentation, such as ARRA timesheets, was not available 

to support the estimates because HUD does not track workforce time and activity directly, pay 

period by pay period. Managers reported the FTEs based on counts, when possible, of specific 

staff working on ARRA and, when staff activity was not specifically known, used a “best 

estimate” of the time needed to complete ARRA workload requirements. 

We attempted to test the reasonableness of the FTE estimates by comparing data from the survey 

for the 3rd quarter of FY 2009 to ARRA activity reported in HUD’s Total Estimation and 

Allocation Mechanism (TEAM)1

 for the same period. The comparison disclosed material and 

unexplained differences in the staffing data reported by the Office of Community Planning and 

Development (CPD) and the Office of Public and Indian Housing (PIH). CPD and PIH are 

responsible for awarding and monitoring $11.26 billion (83 percent) of HUD’s $13.62 billion in 

Recovery Act funding. 

HUD’s oversight of Recovery Act activities can be improved through implementation of a 

verifiable process to account for staff time. A documented count of FTEs provides information 

to senior management for use in decision making concerning HUD’s responsibilities under 

ARRA. It also serves as a control process consistent with the guidelines set out in Office of 

Management and Budget Circular A-123. Further, any future responses to ARRA requests 

should be supported by information that can be validated. 

We provided a draft copy of the report to the Senior Program Manager for Program Recovery, 

HUD’s Recovery Act Implementation Team (Recovery Team), on February 16, 2010, and 

received written comments on March 5, 2010. The response contains planned corrective actions 

to address the observations and recommendations in the report. The complete text of the 

Recovery Team’s comments is included in appendix A. 

 

1

 TEAM is an automated information system used by HUD to capture workload and time use data as recorded by 

employees on a quarterly basis for a specified 2-week period. 
iii 

Table of Contents

Introduction ......................................................................................................................................4 

Scope and Methodology ..................................................................................................................5 

Observations 

Survey Results ...........................................................................................................................6 

Validation Results ......................................................................................................................9 

Recommendations ..........................................................................................................................11 

HUD Comments and OIG Response .............................................................................................11 

Appendix A – HUD’s Recovery Act Implementation Team Comments ......................................12 

 
4 

Introduction 

The Act 

Congress appropriated, through the American Recovery and Reinvestment Act of 2009 

(Recovery Act or ARRA), approximately $13.62 billion in economic stimulus funds that the U.S. 

Department of Housing and Urban Development (HUD) is responsible for obligating, disbursing, 

and tracking over the next 2 years. The Recovery Act also established an independent entity, the 

Recovery Accountability and Transparency Board (Board),2 to report on HUD and other 

agencies’ progress in awarding Recovery Act-related contracts and grants to government and 

private-sector entities. Among the responsibilities of the Board, Section 1523 directed that it 

determine 1) “whether there are sufficient qualified acquisition and grant personnel overseeing 

covered funds” and 2) “whether personnel whose duties involve acquisitions or grants made with 

covered funds receive adequate training.” 

The Survey 

To comply with Section 1523, the Board directed 29 Offices of Inspector General (OIG) to 

collect data at their respective agencies using a survey instrument to determine the adequacy of 

staffing levels, qualifications, and training of personnel responsible for Recovery Act contracts 

and grants. The survey instrument—at the request of and in consultation with the Board—was 

developed by the U.S. Department of Commerce OIG and tested by the U.S. Departments of 

Transportation, Homeland Security, Agriculture, and Commerce OIGs. 

At HUD, the survey was conducted in August 2009 by the Senior Program Manager for 

Economic Recovery and staff, it recorded responses from 13 offices and/or program areas 

(reporting offices), and its execution was administratively overseen by OIG. The survey 

instrument captured staffing data on Recovery Act contract and grant activities. Specifically, the 

survey asked HUD to report ARRA contracting activities in four categories: contracting officers, 

contracting officer technical representatives (COTR)/contracting officer representatives (COR), 

acquisition program/project managers, and contracting support personnel.3 The survey also 

captured ARRA grant activities in three categories: grant officers, grant program/project 

managers (GPM), and grant support specialists (GS). Program managers were also asked to 

comment on the level of staff qualifications, as reflected by certifications and training. 

HUD completed the survey on September 4, 2009. Our office reviewed the summarized data for 

consistency and completeness and submitted the survey results to the U.S. Department of 

Commerce OIG on September 11, 2009, the required deadline. 

 

2

 Publ. L. No. 111-5, § 1522. The Board is comprised of 12 Inspectors General representing the U.S. Departments 

of Agriculture, Commerce, Defense, Education, Energy, Health and Human Services, Homeland Security, the 

Interior, Justice, Transportation, and the Treasury and the Internal Revenue Service. 3

 The contract staff categories reflect workforce definitions established by the Office of Federal Procurement Policy 

(OFPP) in OFPP Policy Letter 05-01, dated April 15, 2005. There is no corresponding government-wide definition 

for the grants workforce. 
5 

Scope and Methodology 

Inspectors General were not required to validate the accuracy and reliability of the data collected 

and reported by the respective agency on the survey instrument. We elected independently to 

review the collection process and assess the survey results on staff resources. We focused on the 

total hours and related full-time equivalent (FTE) levels dedicated to ARRA activities, as 

captured by the survey instrument and reported to the Board. 

To evaluate the accuracy and reliability of the data collected, we reviewed the data-gathering 

processes with the Senior Manager for Economic Recovery and staff as the survey was rolled 

out. We then analyzed the survey summary data to ensure the completeness of the survey entries 

and the reasonableness of the reported workforce numbers. To further validate data accuracy 

and reliability, we interviewed headquarters program managers and responsible staff for 7 of the 

13 reporting offices that awarded and administered the ARRA contracts and grants. We asked 

specifically how they developed their staffing counts and responses to the questions posed on 

qualifications and training. 

We also compared the survey results to reported ARRA staffing levels (FTEs) during the 3rd 

quarter of fiscal year (FY) 2009 that were captured in HUD’s Total Estimation and Allocation 

Mechanism (TEAM), an automated information system designed to support departmental 

resource management. Its purpose is to capture and project information on workload and time 

use by employees on a quarterly basis for a specified 2-week period. TEAM was implemented 

in 2002 to provide HUD with a systematic and verifiable method of collecting data on HUD staff 

activities nationwide. TEAM workload and time codes were developed for ARRA and captured 

data from staff input beginning in January 2009. Among the uses of TEAM data are budget 

formulation and execution, FTE management, and input to departmental initiatives. 

We asked the program managers to describe the credentialing and training of contract and grant 

oversight personnel. Contract oversight personnel must meet specific training and certification 

requirements. However, there are no equivalent government qualifications or training 

requirements for grant oversight personnel. We did not include independent verification of the 

credentialing and training in the planned scope of our validation. 

We conducted the evaluation in accordance with the Quality Standards for Inspections issued by 

the President’s Council on Integrity and Efficiency. 

 
6 

Observations 

In September 2009, HUD completed the Board’s survey instrument designed to determine the 

adequacy of staffing levels, qualifications, and training of personnel responsible for Recovery 

Act contracts and grants. Thirteen HUD reporting offices responded to the survey questions by 

entering data on total actual hours spent on ARRA activities from April 1 through June 30, 2009 

(3rd quarter, FY 2009), and forecasted to be spent from July 1 through December 31, 2009, and 

January 1 through June 30, 2010. 

It should be recognized that HUD managers and staff at every level contributed markedly to the 

challenges of the Recovery Act by developing policy, meeting funding deadlines, and making 

system changes to allow for the Administration’s promise of accountability and transparency. 

To that end, HUD completed the Board survey instrument in a timely manner. However, staffing 

data reflected undocumented “informed estimates” by headquarters’ management of ARRA 

activities, rather than hard data based on formal FTE and workload tracking. Therefore, the 

FTE-reported survey results could not be independently validated and warrant, if publicly 

disclosed, a disclaimer on reliability.4

Survey Results 

FTE Levels – ARRA 

Thirteen HUD reporting offices responsible for the administration of $13.62 billion in ARRA 

funding responded to the survey. The survey asked the responders to report the total “actual” 

hours spent and “forecasted” hours to be spent on ARRA activities. HUD reported FTE levels 

for the following periods at 

HUD’s ARRA workload by period

FTE levels

April 1, 2009 ‐ June 30, 2009 130.79 Actual

July 1, 2009 ‐ December 31, 2010 365.10 Forecasted

January 1, 2010 ‐ June 30, 2010 345.61 Forecasted

Total for survey period 841.50

The Offices of Community Planning and Development (CPD) and Public and Indian Housing 

(PIH) were responsible for the majority of ARRA-dedicated FTEs. The chart on the following 

page provides the office or program area breakdown of the FTE estimates for the entire survey 

period—April 1, 2009, through June 30, 2010. 

 

4

 Office of Management and Budget Circular No. A-123, June 21, 1995, has long served as guidance to Federal 

agencies on management accountability and control to include ensuring that “reliable and timely information is 

obtained, maintained, reported and used for decision making.” 
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8 

The ARRA workload burden was heavily weighted on grant administration, rather than contract 

personnel. HUD’s response to the survey instrument recorded ARRA workload by labor unit at 

the following FTE levels: 

HUD ARRA workload by labor unit (FTE)

Actual Forecasted Forecasted

04/01/09‐ 

06/30/09

07/01/09‐

12/31/09

01/01/10‐

06/30/10 Total

Contracting officers 1.07 0.89 0.89 2.85

COTR/COR 0.58 1.66 1.74 3.98

Contract program/project managers 0.40 1.30 1.30 3.00

Contracting support personnel 0.00 0.00 0.00 0.00

Grant officers 5.38 7.28 3.30 15.96

GPM 32.60 82.69 93.93 209.22

GS 90.76 271.28 244.45 606.49

Total 130.79 365.10 345.61 841.50

FTE Impact - ARRA

Interviews with headquarters program directors and staff for 7 of the 13 reporting offices 

disclosed that ARRA particularly impacted the workload of key senior and special assistant staff, 

requiring extra hours or overtime to meet goals and deadlines. Five offices reported insufficient 

staff resources to adequately address the increased workload related to the Recovery Act as well 

as normal program activities. The survey reported an estimated staffing shortfall of 153 FTEs. 

HUD office or program area COTR/COR GPM GS Total

Office of Affordable Housing Programs 2 2 4

Office of Healthy Homes & Lead Hazard Control 2 2

PIH:  Office of Public Housing Investment 1 2 3

CPD:  Office of Block Grant Assistance 65 4 69

PIH:  Office of Field Operations 75 75

Total FTEs 1 71 81 153

Staff explanations of how the ARRA work was accomplished matched the commentary 

submitted on the survey instrument. 

To explain how the shortfall in staffing was being mitigated, CPD’s Office of Block Grant 

Assistance stated in the comments section of the survey instrument that staff was 

“just now beginning to catch up with regular FY 2009 business . . .” 

PIH’s Office of Field Operations said that 
9 

“the majority of the [ARRA] workload is concentrated in the first twelve months of the 

allocation which spans all three time periods and we estimate approximately 75 FTE 

would have been optimal in order to complete all necessary work. However, due to 

limited resources there was not adequate funding for that level of FTE. To ensure that 

the work is completed, a management decision was made to re-allocate and re-prioritize 

staff resources.” 

Other program offices, especially those with more limited ARRA funding and oversight 

responsibilities, reported lesser adverse effects. 

The Office of Housing’s Office of Affordable Housing Programs expected 

“minimal impact; the shift of focus from non-Recovery work to Recovery work will 

temporarily reduce the level of oversight on non-Recovery work, and may slow some 

rehab completions under non-Recovery programs.” 

Validation Results 

We determined that the FTE data reported on the survey instrument to the Board by HUD in 

September 2009 were not sufficiently reliable for public disclosure purposes as the data could 

not be validated. Staffing data submitted in response to the Board survey instrument reflected 

undocumented “informed estimates” by headquarters program management of ARRA activities. 

Managers and staff explained that HUD does not track workforce time and activity directly, pay 

period by pay period. Therefore, to respond to the survey questions, HUD elected to provide an 

estimate based on counts, when possible, of specific staff working on ARRA, and, when staff 

activity was not specifically known, HUD surveyed field office program directors and/or used a 

“best estimate” of the time staff needed to complete ARRA workload requirements. 

Data accuracy and reliability could not be independently validated, particularly the FTE data 

provided by CPD and PIH. Estimated FTEs for these two offices reflected differing ARRA 

workload levels at more than 40 HUD locations across the Nation and the addition of ARRAfunded activities to normal staff workloads and were made without supporting documents such 

as daily staff timesheet records. 

We attempted to validate the FTE data reported by HUD for the 3rd quarter of FY 2009 by 

comparing the data to ARRA activity reported in TEAM for the same period. TEAM workload 

and time codes were developed for ARRA and captured data from staff input beginning in 

January 2009. The comparison of FTE data disclosed material differences in the data reported 

by CPD and PIH. HUD’s response to the Board survey reported ARRA activity for these two 

offices involving 126.16 FTEs, while TEAM calculated ARRA activity for the offices at 51.4 

FTEs. See chart on the following page. 
10 

Until explained, the variance of 74.76 FTEs (126.16 less 51.4) places the reliability of HUD’s 

response to the Board survey in question, particularly since these two offices are responsible for 

awarding and monitoring $11.26 billion (83 percent) of HUD’s $13.62 billion in Recovery Act 

funding. 

We discussed our inability to validate the reported FTE levels and the differences between the 

survey and TEAM with the Senior Program Manager for Economic Recovery and staff. They 

explained that drawing a direct correlation between TEAM data and the staffing estimates 

provided for ARRA work by the program areas warranted caution, stating: “The third quarter 

TEAM report (April - June 30, 2009) was the first time that program offices were using the 

ARRA reporting code...staff may be attributing the work under another code, and therefore 

unintentionally under reporting ARRA workload.” We agree that the differences require further 

review. 

 

64.03 62.13

126.16

31.50

19.90

51.40

CPD PIH Total

Survey Results vs. TEAM

FTEs for Period

4/1/09‐6/30/09   

Survey FTEs TEAM FTEs
11 

Recommendations 

HUD’s oversight of Recovery Act activities can be improved through implementation of a 

verifiable process to account for staff time. A documented count of FTEs provides information 

to senior management for use in decision making concerning HUD’s responsibilities under 

ARRA. It also serves as a control process consistent with the guidelines set out in Office of 

Management and Budget Circular A-123. Further, any future responses to ARRA requests 

should be supported by information that can be validated. 

We recommend that HUD’s Recovery Act Implementation Team 

1. Working with the respective HUD offices/program areas, implement a verifiable process to 

account for Recovery Act staff time. 

2. Ensure that future responses to ARRA requests are supported by information that can be 

validated. 

HUD’s Comments and OIG Response 

We discussed the observations with the Senior Program Manager for Economic Recovery, 

HUD’s Recovery Act Implementation Team (Recovery Team), and provided a copy of the draft 

report on February 16, 2010. Proposed corrective actions include adjustments to the TEAM 

process to provide verification of Recovery Act staff time to include: staff training on defining 

and reporting time in TEAM, modification of codes in TEAM, and validation of reported 

Recovery Act hours. Further, the Recovery Team intends to provide instruction to all reporting 

offices “...to provide information that can be validated to the extent feasible, in accordance with 

the nature of the given IG request.” 

We anticipate that HUD may also be asked to respond to future Board or Congressional requests 

for staffing and other information related to the Recovery Act. Therefore, future official 

responses involving staffing or other data must be supported by verifiable documentation. OIG 

agrees with the planned corrective actions indicated in the memorandum dated March 5, 2010 

(appendix A). 

 
12 

Appendix A – HUD’s Recovery Act Implementation Team Comments