MOVING TO WORK 

DEMONSTRATION

Opportunities Exist to 

Improve Information 

and Monitoring

Report to Congressional Requesters

April 2012

GAO-12-490

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-490, a report to 

congressional requesters 

April 2012 

MOVING TO WORK DEMONSTRATION 

Opportunities Exist to Improve Information and 

Monitoring 

Why GAO Did This Study

HUD’s MTW demonstration program

gives participating PHAs the flexibility 

to create innovative housing strategies 

through their fiscal year 2018. MTW 

agencies must create activities linked 

to three statutory purposes—reducing

costs, providing incentives for selfsufficiency, and increasing housing 

choices—and meet five statutory 

requirements. Congress is considering 

expanding MTW and has asked GAO 

to examine what is known about (1) the 

program’s success in addressing the

three purposes, (2) HUD’s monitoring 

efforts, and (3) the potential benefits of 

and concerns about expansion. GAO 

analyzed the most current annual 

reports for 30 MTW agencies; 

compared HUD’s monitoring efforts

with internal control standards; and 

interviewed agency officials, 

researchers, and industry officials. 

What GAO Recommends

GAO makes eight recommendations to 

HUD: that HUD improve its guidance

on reporting performance information,

develop a plan for identifying and 

analyzing standard performance data, 

establish performance indicators, 

systematically identify lessons learned, 

clarify key terms, implement a process 

for assessing compliance with statutory 

requirements, do annual assessments 

of program risks, and verify the 

accuracy of self-reported data. HUD 

generally or in part agreed with seven 

of them. HUD disagreed with our 

recommendation that it create overall 

performance indicators. GAO believes, 

however, that they are critical to 

demonstrating program results and 

thus maintains its recommendation.

What GAO Found

Public housing agencies (PHA) that participate in the Moving to Work (MTW) 

program report annually on the performance of their activities, which include 

efforts to reduce administrative costs and encourage residents to work. But this 

performance information varies, and the Department of Housing and Urban 

Development’s (HUD) guidance does not specify that it be quantifiable and 

outcome oriented. Further, HUD has not identified the performance data that 

would be needed to assess the results of similar MTW activities or the program 

as a whole and has not established performance indicators for the program. The 

shortage of such analyses and indicators has hindered comprehensive 

evaluation efforts, although such evaluations are key to determining the success 

of any demonstration program. Further, while HUD has identified some lessons 

learned from the program, it has no systematic process to identify them and thus 

has relied primarily on ad hoc information. The absence of a systematic process 

for identifying lessons learned limits HUD’s ability to promote useful practices 

that could be more broadly implemented to address the purposes of the program. 

HUD generally follows its MTW monitoring policies and procedures, but they could be 

strengthened. HUD staff review and approve each MTW agency’s annual plan to 

ensure that planned activities are linked to program purposes and visit each MTW 

agency annually to provide technical assistance. But HUD has not taken key 

monitoring steps set out in internal control standards, such as issuing guidance that 

defines program terms or assessing compliance with all of the requirements. Without 

clarifying key terms and establishing a process for assessing compliance with 

statutory requirements, HUD lacks assurance that agencies are actually complying

with the statute. Additionally, HUD has not done an annual assessment of program 

risks despite its own requirement to do so and has not developed risk-based 

monitoring procedures. Without taking these steps, HUD lacks assurance that it has 

identified all risks to the program. Finally, HUD does not have policies or procedures 

in place to verify the accuracy of key information that agencies self-report. For 

example, HUD staff do not verify self-reported performance information during their 

reviews of annual reports or annual site visits. Without verifying at least some 

information, HUD cannot be sure that self-reported information is accurate. 

Expanding the MTW program may offer benefits but also raises questions. 

According to HUD, affordable housing advocates, and MTW agencies, expanding 

MTW to additional PHAs would allow agencies to develop more activities tailored 

to local conditions and result in more lessons learned. However, data limitations 

and monitoring weaknesses raise questions about expansion. HUD recently 

reported that expansion should occur only if newly admitted PHAs structured 

their programs to permit high-quality evaluations and ensure that lessons learned 

could be generalized. Until more complete information on the program’s 

effectiveness and the extent to which agencies are adhering to program 

requirements is available, it will be difficult for Congress to know whether an 

expanded MTW would benefit additional agencies and the residents they serve.

Some researchers and MTW agencies suggested alternatives to expansion, 

including implementing a program that was more limited in scope. View GAO-12-490. For more information, 

contact Mathew J. Scirè at (202) 512-8678 or 

sciremj@gao.gov. 
Page i GAO-12-490 Moving to Work Demonstration

Letter 1 

Background 3

HUD Has Not Identified Standard Performance Data and Indicators 

Needed to Evaluate the Program 9

HUD Generally Follows Its Monitoring Policies and Procedures, 

but Could Strengthen Them 22

Expanding MTW May Offer Benefits but Also Raises Questions 31

Conclusions 39

Recommendations for Executive Action 41

Agency Comments and Our Evaluation 42

Appendix I Scope and Methodology 46

Appendix II Comments from the Department of Housing and Urban 

Development 51

Appendix III GAO Contact and Staff Acknowledgments 62

Table

Table 1: Examples of MTW Activities, by Statutory Purpose 10

Figures

Figure 1: Timeline of Public Housing Agencies Entering and Exiting 

the MTW Demonstration Program 6

Figure 2: Number of Reported MTW Activities Linked to Each of 

the Statutory Purposes 12

Contents
Page ii GAO-12-490 Moving to Work Demonstration

Abbreviations

AHSSIA Affordable Housing and Self-Sufficiency Improvement Act 

 of 2012

HUD Department of Housing and Urban Development

MTW Moving to Work 

MTW-PIC Moving to Work section of the Public and Indian Housing 

 Information Center

PHA public housing agency

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

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

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Page 1 GAO-12-490 Moving to Work Demonstration

United States Government Accountability Office 

Washington, DC 20548

April 19, 2012

The Honorable Charles Grassley

Ranking Member

Committee on the Judiciary

United States Senate

The Honorable Judy Biggert

Chairman

Subcommittee on Insurance, Housing 

 and Community Opportunity

Committee on Financial Services

House of Representatives

The Honorable Shelley Moore Capito

Chairman

Subcommittee on Financial Institutions 

 and Consumer Credit

Committee on Financial Services

House of Representatives

The Department of Housing and Urban Development (HUD) provides 

over $25 billion each year to public housing agencies (PHA) to make 

rental housing affordable to about 3.2 million low-income households 

through a variety of programs.1

 

1

This amount includes funding for public housing capital and operating expenditures and 

tenant-based rental assistance. HUD provides separate funding for project-based rental 

assistance, which is not included in this dollar amount. A PHA is typically a local agency 

created under state law that manages housing for low-income residents at rents they can 

afford. 

As of January 2012, 35 of the 

approximately 3,300 PHAs operating in the United States were 

participating in the Moving to Work (MTW) demonstration program until 

the end of their fiscal year 2018. The MTW program has three statutory 

purposes: to reduce costs and achieve greater cost-effectiveness in 

federal housing expenditures, to give families with children incentives to 

obtain employment and become self-sufficient, and to increase housing 

choices for low-income families. It gives participating PHAs the flexibility 

to design and test innovative strategies for providing and administering 

housing assistance in their communities. The agencies (MTW agencies) 

 
 

Page 2 GAO-12-490 Moving to Work Demonstration

must implement activities that are linked to one or more of the program’s 

statutory purposes but that are also designed specifically for the 

communities the agencies serve. In fiscal year 2011, MTW agencies 

received combined funding of $3.3 billion for housing activities.2

In response to your request for information on the effectiveness of the 

MTW program, this report discusses (1) what is known about the extent to 

which the MTW demonstration program is addressing the program’s 

statutory purposes, (2) HUD’s monitoring of MTW agencies’ efforts to 

address these purposes and meet statutory requirements, and (3) the 

potential benefits of and concerns about expanding the number of PHAs 

that can participate in the demonstration program.

This 

represented more than 13 percent of HUD’s affordable housing 

expenditures. Legislation has recently been proposed to expand the 

number of MTW agencies. However, researchers and organizations that 

advocate on behalf of residents, including legal aid groups, have raised 

concerns about expanding it due to the lack of information on the effect of 

the program as well as concerns about residents.

To determine what is known about the extent to which the MTW program 

is addressing statutory purposes, we analyzed the most recent annual 

reports as of January 2012 for 30 agencies.3

 

2

Two of the 35 MTW agencies did not begin participating in the MTW program until fiscal 

year 2012 and are therefore not included in this dollar amount. 

We assessed the reliability 

of selected information in the reports by reviewing supporting 

documentation for a sample of seven MTW agencies and interviewing 

officials responsible for preparing and reviewing this information. (We 

selected the sample of MTW agencies to provide diversity in factors such 

as geography, agency size, and length of time participating in the 

program.) We determined that the reports were sufficiently reliable for the 

purposes of our review. We analyzed these reports and corresponding 

annual plans to determine the number of ongoing activities and the 

statutory purpose(s) to which each activity was linked. We compared 

HUD’s guidance for MTW agencies on the type of performance 

information they should report with the GPRA (Government Performance 

and Results Act) Modernization Act of 2010. We also reviewed 

3

According to HUD data, as of January 2012 35 agencies were participating in the MTW 

program. Of these, 30 had submitted an annual report to HUD. The other five agencies 

had not been in the program long enough to report on their accomplishments. 
 

Page 3 GAO-12-490 Moving to Work Demonstration

evaluations of the program and summarized the challenges that HUD and 

others have faced in conducting such evaluations. Finally, we assessed 

HUD’s past efforts to identify lessons learned from the MTW program.

To assess HUD’s monitoring of MTW agencies’ efforts to address the 

program’s statutory purposes and meet requirements, we reviewed 

relevant policies and procedures, including HUD’s desk guide for the 

program, the Standard Agreement that HUD executed in 2008 to govern 

participation in the program, and documentation of the steps HUD had 

taken to help ensure compliance with its policies and procedures. We 

also examined the relevant internal control standards that apply to federal 

agencies and HUD’s guidance on internal controls and compared HUD’s 

monitoring policies and procedures with these standards. To discuss the 

potential benefits and concerns associated with expanding the number of 

PHAs that can participate in the program, we reviewed studies, reports, 

and testimonies by researchers, affordable housing advocates, and 

resident advocates. For all three objectives, we interviewed HUD officials, 

officials from our sample of seven MTW agencies, research 

organizations, affordable housing advocates, and organizations that 

advocate on behalf of residents of federally subsidized housing.

We conducted this performance audit from July 2011 to April 2012 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Appendix I contains additional 

information on our scope and methodology.

The MTW demonstration program was authorized by the Omnibus 

Consolidated Rescissions and Appropriations Act of 1996.4

 

4

Pub. L. No. 104-134, 110 Stat. 1321, 1321-281.

The program 

is intended to give participating agencies the flexibility to design and test 

innovative strategies for providing and administering housing assistance. 

To implement such strategies, participating agencies may request 

waivers of certain provisions in the United States Housing Act of 1937, as 

Background
 

Page 4 GAO-12-490 Moving to Work Demonstration

amended.5

1. serve substantially the same total number of eligible low-income 

families that they would have served had funding amounts not been 

combined;

For example, agencies may request to waive certain 

provisions in order to combine the funding they are awarded annually 

from different programs into a single, authoritywide funding source. 

Requirements outside of the 1937 Housing Act, such as fair housing 

rules, cannot be waived under MTW. In addition, certain sections of the 

act, including those that cover labor requirements and the demolition and 

disposition of public housing, cannot be waived. The 1996 act that 

created the program requires participating agencies to address three 

purposes and meet five requirements. Specifically, the three statutory 

purposes are to (1) reduce costs and achieve greater cost-effectiveness 

in federal housing expenditures, (2) give families with children incentives 

to obtain employment and become self-sufficient, and (3) increase 

housing choices for low-income families. For example, to reduce 

administrative costs MTW agencies can reduce the frequency of income 

verifications for households with fixed incomes. In making these changes, 

MTW agencies must

2. maintain a mix of families (by family size) comparable to those they 

would have served without the demonstration;

3. ensure that at least 75 percent of households served are very low 

income;6

4. establish a reasonable rent policy to encourage employment and selfsufficiency; and

5. assure that the housing they provide meets HUD’s housing quality 

standards.

The program’s ultimate goal is to identify successful approaches that can 

be applied to PHAs nationwide.

 

5

42 U.S.C. 1437 et seq.

6

Section 3 of the 1937 Housing Act, as amended, defines very low-income families as 

families whose incomes do not exceed 50 percent of the median family income for the 

area.
 

Page 5 GAO-12-490 Moving to Work Demonstration

The 1996 act authorized MTW for 30 agencies. HUD invited PHAs to 

apply for the program and selected an initial cohort of 24 PHAs from 

among the respondents. Six more were added as a result of the JobsPlus initiative.7 Since then, some agencies have opted not to participate, 

and additional agencies have been added to replace them. Other 

agencies have been added through specific appropriations language (see 

fig. 1). In addition, some agencies have completed their participation and 

exited the program.8

 

7

The Jobs-Plus initiative was a welfare-to-work demonstration aimed at significantly 

increasing employment and income among the residents of selected PHAs. HUD 

considers Jobs-Plus a subset of the MTW demonstration.

As of January 2012, a total of 39 PHAs were 

authorized to participate, and 35 were participating.

8

According to HUD, 3 of the original 24 MTW agencies completed their participation in 

2004 and were terminated from the program based on the terms of their MTW 

agreements.
 

Page 6 GAO-12-490 Moving to Work Demonstration

Figure 1: Timeline of Public Housing Agencies Entering and Exiting the MTW Demonstration Program

a

The act specified that the additional agencies must be considered “high performers” (as designated 

by HUD’s Public Housing Assessment System) with current HOPE VI grants and no more than 5,000 

units. HUD’s Public Housing Assessment System assigns a performance designation to each PHA 

that is based on the physical condition of the properties, the agency’s financial condition and 

management operations, and a survey of residents’ satisfaction with services provided. HOPE VI 

grants fund the revitalization of severely distressed public housing. 

b

MTW agencies do not receive special funding allocations. Rather, they 

receive funds from the three traditional primary funding sources (public 

housing capital funds, public housing operating funds, and Housing 

Choice Vouchers).

The 2010 and 2011 Appropriations Acts specified that the additional agencies must be considered 

“high performers” with no more than 5,000 units. 

9

 9

For additional information on these funding sources, see Congressional Research 

Service, Introduction to Public Housing, R41654 (Washington, D.C.: Feb. 24, 2011) and 

Congressional Research Service, Section 8 Housing Choice Voucher Program: Issues 

and Reform Proposals, RL34002 (Washington, D.C.: Jan. 6, 2011). 

Traditionally, PHAs have been required to use the 

Source: HUD.

1996 1999 2000 2003 2004 2008 2009 2010 2011

MTW authorized by the 

Omnibus Consolidated 

Rescissions and Appropriations 

Act of 1996; the act authorized 

30 MTW agencies (24 PHAs 

were selected and 6 slots were 

filled through HUD’s Jobs-Plus 

initiative)

HUD selected 6 MTW agencies 

through a competitive selection 

process; 1 MTW agency added 

as authorized by 1996 statute

MTW implemented; 5 of the 24 

PHAs originally selected opted 

not to participate; 1 Jobs-Plus 

selectee opted not to 

participate; 2 agencies 

specifically named and 

authorized to join in the 1999 

Appropriations Act

3 MTW agencies 

completed participation 

3 PHAs added by HUD 

through a competitive 

selection process (the 2009 

Appropriations Act authorized 

the addition of 3 more MTW 

agencies, expanding the total 

number of authorized 

agencies to 33)a

3 MTW agencies 

authorized (the 2011 

Continuing Appropriations Act authorized 

the addition of 3 more 

agencies, expanding 

the total number of 

authorized agencies 

to 39)b

6 (Jobs-Plus) selectees 

completed participation 

HUD = Department of Housing and Urban Development

MTW = Moving to Work

PHA = public housing agency

1 MTW agency added as authorized by 

1996 statute (slot available from Jobs-Plus); 

1 former MTW agency returned; 4 PHAs 

specifically named and authorized to join in 

the 2008 Appropriations Act

2 MTW agencies selected through a competitive 

process (the 2010 Appropriations Act authorized 

the addition of 3 more agencies, expanding the 

total number of authorized agencies to 36)b
 

Page 7 GAO-12-490 Moving to Work Demonstration

funds from each separate source only for specific purposes, but MTW 

agencies may combine the money from the three sources and use them 

for a variety of HUD-approved activities. This fungibility is intended to give 

MTW agencies greater flexibility. For example, public housing operating 

funds are traditionally used to make up the difference between the rents 

charged for units and the actual cost of operating them. Capital funds are 

used for modernization efforts and management improvements, while 

voucher funds provide rental assistance in the private market. However, 

by combining funds an MTW agency may use public housing capital 

funds to issue additional vouchers or use voucher funds to develop more 

public housing to better fit the needs of its community. MTW agencies 

also have the authority to use their funds to implement innovative 

activities that differ from traditional housing assistance. For instance, an 

MTW agency can use funds to replace public housing with mixed-income 

communities or reach special-needs populations, such as the homeless, 

using vouchers paired with supportive services.

A Standard Agreement, executed in 2008 to replace individual contracts 

between HUD and participating PHAs, governs the conditions of 

participation in the program.10

The agreement requires all MTW agencies to submit an annual MTW 

plan to HUD for approval and an annual MTW report for acceptance.

HUD enters into this agreement with each 

MTW agency. HUD created the agreement to standardize the language in 

its contracts and its reporting requirements and to help create a more 

operationally sound program. The Standard Agreement includes a 

termination date (the end of each agency’s 2018 fiscal year) and an 

attachment that sets out reporting requirements (Attachment B). While 

much of the Standard Agreement is the same for all MTW agencies, two 

sections are tailored to individual agencies: a description of the formulas 

for determining the amounts of funding each agency will receive and an 

optional section that may include some agency-specific authorizations.

11

 10Earlier agreements varied across participants and had terms that ran from 5 to 7 years. 

Amendments to extend the terms or add additional exceptions and flexibilities were 

common, and over time the changes made the agreements difficult for HUD to monitor. 

While the format may vary, HUD has established a standard table of 

11MTW agencies with less than 10 percent of their housing stock in the MTW program 

continue to submit the 5-Year and annual plans required by Section 5A of the 1937 

Housing Act. Only information not included in these documents would need to be included 

in a supplemental annual MTW plan.
 

Page 8 GAO-12-490 Moving to Work Demonstration

contents that lists the information that agencies must include in their 

annual plans and reports. For example, the plan must include, among 

other things, a description of how each planned activity relates to at least 

one of the three purposes of the program; baselines, proposed 

benchmarks, and proposed metrics for assessing the outcomes of each 

activity; citations of the authorizations that give the agency the flexibility to 

conduct the activity; and descriptions of required rent reform activities.12

As well as meeting the requirements in the Standard Agreement, MTW 

agencies must submit tenant-related data into the Moving to Work section 

of the Public and Indian Housing Information Center (MTW-PIC). 

According to HUD officials, the MTW-PIC module was created because 

the standard PIC system that non-MTW agencies use to report tenant 

data could not accommodate some of the activities allowed under MTW, 

such as less frequent tenant income recertifications and rent calculations 

that vary from HUD’s standard calculations. The MTW-PIC module was 

created in 2007, and most MTW agencies had transitioned to it by 2008.

In addition, the plan must include a certification that the agency published 

a notice of plans to hold a public hearing on the plan, made the agency’s 

annual plan available for public inspection, and conducted a public 

hearing to discuss the annual plan prior to its approval. Similarly, the 

Standard Agreement outlines the information that MTW agencies are 

required to include in annual MTW reports. These reports must include, 

for example, detailed information on the impact of each activity, including 

comparisons of actual outcomes to the benchmarks proposed in the 

annual plan. If the agencies do not achieve the benchmarks or the 

activities are determined to be ineffective, the MTW agency is required to 

describe the challenges, and, if possible, identify alternative activities that 

may be more effective. MTW agencies also are required to self-certify 

that they are in compliance with three statutory requirements: assisting 

substantially the same total number of eligible low-income families that 

they would have served had funding amounts not been combined; 

maintaining a mix of families (by family size) comparable to those they 

would have served had funding amounts not been combined under the 

demonstration; and ensuring that at least 75 percent of households 

served are very low income.

 12In training materials for the MTW program, HUD defines “baseline” as the performance 

level that was being achieved prior to the implementation of the MTW activity, 

“benchmark” as the anticipated outcome of a MTW activity, and “metric” as the specific 

measure that quantifies the changes from an activity. 
 

Page 9 GAO-12-490 Moving to Work Demonstration

The Office of Public Housing Investments within the Office of Public and 

Indian Housing at HUD headquarters is the designated program office for 

the MTW demonstration program. Within the Office of Public Housing 

Investments is an MTW Office that includes a program director and four 

coordinators who are each assigned to a specific group of MTW 

agencies. The MTW Office is responsible for, among other things, 

processing, reviewing, and approving all annual plans submitted by MTW 

agencies; establishing guidelines for MTW agencies; monitoring approved 

activities and accomplishments; and accepting annual reports. Individual 

MTW coordinators facilitate the reviews of planned and implemented 

activities and are responsible for coordinating with other HUD offices, 

including local HUD field offices, to obtain additional input on MTW 

agencies’ planned activities and accomplishments. In January 2011, the 

Office of Public Housing Investments signed a Memorandum of 

Understanding with HUD’s Office of Field Operations to increase 

collaboration and formally describe the roles and responsibilities of the 

MTW Office and HUD field office staff. Per this memorandum, field office

staff assist the MTW Office by reviewing and providing input on annual 

plans and reports, ensuring that agencies are reporting tenant 

information, and participating in annual site visits.

MTW agencies provide descriptions of their activities and performance 

information in their annual reports to HUD. They show how the activities 

link to the program’s statutory purposes in their annual plans, as required, 

and sometimes also in their annual reports. However, the type of 

performance information they provide varies, and HUD has provided 

limited guidance. While varied information on individual activities is 

available, a comprehensive evaluation of the MTW program is lacking, in 

part because HUD does not have a plan for identifying and analyzing 

standard performance data and has not established performance 

indicators for the MTW program as a whole.13 Further, HUD does not 

have a systematic process for identifying lessons learned by individual 

MTW agencies that can be replicated at other PHAs.

 13For purposes of this report, we are defining “performance indicators” as programwide 

measures of impact.

HUD Has Not 

Identified Standard 

Performance Data 

and Indicators 

Needed to Evaluate 

the Program
 

Page 10 GAO-12-490 Moving to Work Demonstration

MTW agencies report information on specific activities, including 

descriptions, in their annual reports. Agencies are required in their annual 

plans to link each of their proposed activities to one of the program’s 

three statutory purposes, and some agencies also show links between 

ongoing activities and statutory purposes in their annual reports. The 

three statutory purposes are to reduce costs and achieve greater costeffectiveness in federal housing expenditures, give families with children 

incentives to obtain employment and become self-sufficient, and increase 

housing choices for low-income families. According to the most recently 

available annual reports, 30 agencies have over 360 ongoing activities, 

including rent reform initiatives and work requirements (see table 1).14

Table 1: Examples of MTW Activities, by Statutory Purpose

Activity Description (example)

Purpose 1: Reduce costs

Biennial recertifications Allow elderly and disabled residents, who have minimal income and experience 

few changes in family composition, to be recertified every other year instead of 

annually.

New inspections protocol Replace annual inspections of all properties in the tenant- and project-based 

voucher programs with inspections of a certain percentage of participating 

properties.

Standard deductions for medical expenses 

(rent reform) 

Replace itemized medical and child care deductions with a standard deduction 

in determining rent payments.

Purpose 2: Encourage self-sufficiency

Minimum rents (rent reform) Require residents to pay at least a minimum rent (MTW agencies can exceed

the statutory limit of $50).

Work requirement Require residents to work or engage in a learning or training activity, meet a 

minimum income level to receive housing assistance, or enter and adhere to a 

local welfare-to-work program. In some cases, residents may not be 

unemployed for more than 90 days.

Enhanced supportive services Offer residents supportive services, such as on-site employment counseling 

and skill building, classes in household budgeting and parenting, and child-care 

and transportation services. 

Purpose 3: Increase housing choices

Fund affordable housing development activities Leverage funds to preserve affordable housing resources and create new 

affordable housing opportunities.

 14Of the 35 participating agencies, 30 had issued an annual report for 2011 as of January 

2012. The other five agencies had not been in the program long enough to report on their 

accomplishments. 

Although Information on 

Activities Is Generally 

Available at the Agency 

Level, It Varies Due to 

HUD’s Limited Guidance
 

Page 11 GAO-12-490 Moving to Work Demonstration

Activity Description (example)

Sponsor-based voucher program Provide vouchers to service providers who work with hard-to-house households 

to provide intensive supportive services.

Site-based waiting list Allow residents to apply for the waiting list for specific sites or communities 

where they want to live.

Source: Most recent MTW annual reports as of January 2012.

Note: The links between the activities and statutory purposes were determined by MTW agencies. 

According to the most recent annual reports (and corresponding plans) 

for 30 MTW agencies, agencies associated the largest percentage of 

ongoing activities (41 percent) with the statutory purpose of reducing 

costs and improving cost-effectiveness (see fig. 2). For example, 

agencies associated changes in certification schedules, inspection 

protocols, and medical deductions with reduced costs. The agencies 

linked 30 percent of their ongoing activities to the statutory purpose of 

increasing housing choices and 24 percent to encouraging selfsufficiency. The agencies did not link 4 percent of their ongoing activities 

to any purpose in either their most recent annual plan or report.15

 

15According to HUD officials, once an activity is approved, agencies may not continue to 

report its linkages to statutory purposes in subsequent plans or reports. 
 

Page 12 GAO-12-490 Moving to Work Demonstration

Figure 2: Number of Reported MTW Activities Linked to Each of the Statutory 

Purposes

Note: Numbers do not add to 100 percent because of rounding. 

In its Standard Agreement, HUD requires agencies to include in their 

annual reports performance information on the impact of each 

implemented activity, including describing the metrics used to assess 

outcomes and comparing actual performance with proposed 

benchmarks.16

 16For purposes of this report, we are defining “performance information” as information 

that MTW agencies include in their annual reports on the impact of a specific MTW 

activity. 

While HUD did not define these terms in the agreement, it 

defined them in 2009 training materials. In these materials, HUD defined 

a metric as the “unit of measure that quantifies the changes that might 

occur as a result of the MTW activity” and a benchmark as the “projected 

outcome of the MTW activity.” Further, in these 2009 training materials 

HUD defined an outcome as the “actual, measured result of the 

implemented activity.” As examples, the training materials stated that a 

metric could be the hours of staff time saved, a benchmark could be the 

number of anticipated staff hours saved, and the outcome could be staff 

hours actually saved. HUD directs agencies to develop their own metrics 
 

Page 13 GAO-12-490 Moving to Work Demonstration

and benchmarks for each activity based on local and community 

standards.17 Our analysis of the most recent annual reports for 30 MTW 

agencies showed that the agencies reported performance information for 

91 percent of the ongoing activities included in the reports and used over 

1,000 metrics to assess these activities.18 MTW agencies collectively met 

the benchmarks associated with 40 percent of these metrics and fell short 

of meeting 17 percent of them.19

While MTW agencies are generally devising their own metrics for 

activities and reporting performance information, the usefulness of this 

information is limited because, in some cases, it is not outcome-oriented. 

Our analysis of the most recent annual reports for 30 MTW agencies 

showed that the type of information that agencies reported on the impact 

of their activities varied. For example, for similar activities designed to 

promote family self-sufficiency, one MTW agency reported only the 

number of participants, which is generally considered an output, and 

another did not provide any performance information.

For 30 percent of the metrics, it was too 

soon to determine if the benchmarks had been met because the activities 

were not yet completed. For the remaining 13 percent, information (either 

the benchmark or performance data) was lacking to determine whether 

the benchmark was met.

20

 

17HUD has made some exceptions to its requirement for the reporting of impact 

information. For example, some MTW agencies identified the use of funding flexibility as 

an activity and noted that they were not required by HUD to report information on the 

impact. According to the Director of the MTW Office, this exception applies in some 

instances.

In contrast, a third 

agency reported on, among other things, the average income of program 

graduates, which we consider an outcome.

18Agencies often had more than one metric for a single activity.

19HUD does not penalize agencies for not meeting their self-determined benchmarks. 

However, if the benchmarks were not achieved or if the activity was determined 

ineffective, HUD requires agencies to describe the challenges and, if possible, identify 

new strategies that might be more effective in their annual report. For our analysis, we 

compared the actual, reported performance information with the proposed benchmark to 

determine if the agency met its goal.

20For example, see GAO, Neighborhood Stabilization Program: HUD and Grantees Are 

Taking Actions to Ensure Program Compliance but Data on Program Outputs Could be 

Improved, GAO-11-48 (Washington, D.C.: Dec.17, 2010).
 

Page 14 GAO-12-490 Moving to Work Demonstration

Internal control standards state that good guidance (information and 

communication) is a key component of a strong internal control 

framework and that there is a need for clear documentation.21 To be 

consistent with the GPRA Modernization Act of 2010, HUD’s guidance on 

reporting performance information should indicate the importance of 

outcome-oriented information.22 Specifically, the act states that an agency 

should establish efficiency, output, and outcome indicators for each 

program activity. Furthermore, Office of Management and Budget 

guidance on implementation of the act states that quantitative and 

outcome-focused measures are preferred.23

At the time of our review, HUD’s guidance did not specify that agencies 

should report quantifiable and outcome-oriented performance information. 

According to the Director of the MTW Office, Attachment B of the 

Standard Agreement is the most current guidance on the information that 

agencies should report in their annual reports. It simply states that 

agencies are to provide detailed information on the impact of the activity 

and compare it against the proposed benchmarks to assess outcomes, 

including whether an activity is on schedule. The attachment does not 

define terms or set expectations for the type of information to be reported. 

After the Standard Agreement was executed in 2008, HUD conducted 

training for participating agencies. As previously discussed, the 2009 

training materials defined key terms such as a metric and outcome and 

outlined steps agencies could take to evaluate their activities. HUD also 

encouraged the MTW agencies to use metrics and benchmarks that did 

not focus on the number of individuals participating in an activity but 

rather on the objectives of the activity and to report quantifiable 

information. While HUD has posted the 2009 training materials on its 

website, these materials have not been incorporated into Attachment B of 

the Standard Agreement.

According to the Director of the MTW Office, HUD has not made its 

guidance more specific because agencies are implementing a wide 

 

21GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

22Pub. L. No. 111-352, 124 Stat. 3866 (2011). The GPRA Modernization Act of 2010 

amends GPRA, Pub. L. No. 103-62, 107 Stat. 285 (1993).

23OMB Circular A-11, Part 6 (“Preparation and Submission of Strategic Plans, Annual 

Performance Plans, and Annual Program Performance Reports”), Section 220.7.IV.
 

Page 15 GAO-12-490 Moving to Work Demonstration

variety of activities and thus require some reporting flexibility. We 

acknowledge the need for flexibility, but it is important that HUD require 

agencies to report at least some outcome-oriented performance 

information. Without more specific guidance on the reporting of 

performance information, HUD cannot be assured of collecting 

information that reflects the outcomes of individual activities. Such 

information would help HUD assess the demonstration program and 

whether the activities are furthering program purposes.

As we have previously reported, obtaining performance information from 

demonstration programs that are intended to test whether an approach 

(or any of several approaches) can obtain positive results is critical.24 This 

information is needed to help determine whether the program has led to 

improvements consistent with its purposes. HUD has sponsored three 

broad reviews of the MTW program, but these studies are not 

comprehensive evaluations because of data limitations, among other 

things.25 A 2004 Urban Institute evaluation of the MTW program found 

that most MTW agencies reported modest benefits from activities related 

to administrative streamlining and that these results were often not as 

dramatic as the agencies had anticipated.26

 

24See GAO, Program Evaluation: Improving the Flow of Information to the Congress, 

The study also noted the 

difficulty in determining whether MTW activities related to employment 

GAO/PEMD-95-1 (Washington, D.C.: Jan. 30, 1995).

25We also identified five studies that looked at a specific MTW agency or activity. See 

Thomas Boston and Linje Boston, Monitoring and Evaluating the Atlanta Housing 

Authority’s MTW Program: Comprehensive Final Report Covering 2004, 2007 and 2010

(Atlanta, GA: Euquant, 2010); Quadel Consulting Corporation, Performance 

Benchmarking of the Rent Simplification Initiative in the Cambridge Housing Authority’s 

Moving to Work Program – Final Report (Cambridge, MA: Cambridge Housing Authority, 

2008); Building Changes, The South King County Housing First Pilot Innovations and 

Lessons Learned (Seattle, WA: Building Changes, May 2010); Sarah Delaney Rosendahl,

Housing Readiness Program Year One Evaluation for the Housing Authority of the County 

of San Mateo (Oakland, CA: Mills College, May 2010); and Thomas D. Boston, Impact of 

the Mixed-Income Revitalization of Grady Homes: Atlanta Housing Authority, 2011 

(Atlanta, GA: Housing Authority of the City of Atlanta, July 2011). 

26Martin D. Abravanel, Robin E. Smith, Margery A. Turner, Elizabeth C. Cove, Laura E. 

Harris, and Carlos A. Manjarrez, Housing Agency Responses to Federal Deregulation: An 

Assessment of HUD’s “Moving to Work” Demonstration (Washington, D.C.: The Urban 

Institute, 2004).

Design and Data 

Weaknesses Have 

Prevented a 

Comprehensive Evaluation 

of MTW
 

Page 16 GAO-12-490 Moving to Work Demonstration

and income had any independent effect and that MTW activities resulted 

in both greater and more limited housing choice.27

A second study, conducted in 2007 by Applied Real Estate Analysis, Inc. 

and the Urban Institute, reviewed eight MTW agencies that had placed 

limits on the length of time that residents could receive housing 

assistance.28 The study found that each of the approaches varied and 

concluded that only limited information was available with which to 

evaluate outcomes or establish cause-and-effect relationships between 

agencies’ policies and recipients’ experiences. It noted that there were 

significant limitations to what could be learned from these experiences 

because no evaluative framework had been built into the program. 

Finally, a 2010 HUD Report to Congress found that the effects of many 

MTW activities, especially as they related to residents, could not be 

conclusively identified because of the variety of and differences in the 

activities and metrics that MTW agencies were implementing. However, 

the report did identify some results concerning agencies’ ability to more 

efficiently allocate resources and engage in strategic long-term 

planning.29

These three studies of the MTW program and our work have identified 

several challenges that have hindered evaluation efforts. These 

challenges include the way the program was initially designed and the 

resulting lack of standard performance data as well as the lack of 

performance indicators for the program as a whole.

For instance, the study noted that some agencies had seen 

positive effects from combining their traditional sources of funding and 

streamlining their operations—for example, by simplifying their housing 

quality inspections.

 

27Because of the program’s design and lack of controls, the study’s authors had difficulty 

isolating the effects of the MTW program from other factors that may affect outcomes.

28Robert Miller, Martin D. Abravanel, Helene Berlin, Elizabeth Cove, Maria-Alicia 

Newsome, Carlos A. Manjarrez, Lipi Saikia, Robin E. Smith, and Maxine V. Mitchell, The 

Experiences of Public Housing Agencies That Established Time Limits Policies Under the 

MTW Demonstration (Applied Real Estate Analysis, Inc. and The Urban Institute, May 

2007). 

29HUD, Office of Public and Indian Housing and Office of Policy Research and 

Development, Moving to Work: Interim Policy Applications and the Future of the 

Demonstration, a report to Congress (Washington, D.C.: 2010).
 

Page 17 GAO-12-490 Moving to Work Demonstration

HUD has taken steps to address the problems noted with MTW’s initial 

design and the lack of standard data; however, it has not analyzed the 

data it currently collects or determined whether these data are sufficient 

to evaluate similar activities and the program as a whole. As we have 

previously reported, comparable data are essential to a full analysis of 

programs that incorporate a variety of activities.30 We also noted that 

obtaining performance information from demonstration programs that are 

intended to test whether an approach (or any of several approaches) can 

obtain positive results is critical. Finally, we have reported that agencies 

need to identify any data that will be needed to assess the effectiveness 

of program regulations.31

Researchers and others have noted the limitations that the program’s 

initial design posed to evaluation. In the early years of MTW, rigorous 

evaluation strategies were not required, and the program lacked a 

research design that would have helped in determining baseline 

information.32 The 2004 Urban Institute review of MTW concluded that 

there were limits to what could be learned from its review for a variety of 

reasons, such as the inability to separate individual components of 

agencies’ MTW activities for analysis.33 As a result, the report is mainly 

descriptive and qualitative.34 HUD’s 2010 Report to Congress noted that 

because rent reform activities varied greatly and were not implemented 

using a controlled experimental methodology, the authors were unable to 

recommend specific reforms as best practices.35

 

30GAO/PEMD-95-1. 

31GAO, Reexamining Regulations: Opportunities Exist to Improve Effectiveness and 

Transparency of Retrospective Reviews, GAO-07-791 (Washington, D.C.: July 16, 2007).

32In its 2009 training materials, HUD defined a baseline as the performance level that was 

being achieved prior to the implementation of the MTW activity.

33Abravanel and others, An Assessment of HUD’s Moving to Work Demonstration (2004).

34Researchers from the Urban Institute told us that if very specific reporting requirements 

were established and reliable data were available, the program could be rigorously 

assessed. 

35HUD, Moving to Work (2010). A controlled experimental methodology is a research 

design that randomly assigns participants to treatment and control groups in order to 

rigorously analyze the effects of the studied activity. 

Lack of Program Evaluation 

Design and Standard 

Performance Data
 

Page 18 GAO-12-490 Moving to Work Demonstration

To help evaluate aspects of the MTW program moving forward, MTW 

officials have added requirements for new agencies. According to HUD’s 

2010 Report to Congress, the three agencies admitted to the MTW 

program in 2009 had strong evaluation components.36

Likely due to the absence of an evaluation framework for the MTW 

program, researchers have noted the lack of standard performance data 

needed to evaluate similar activities and the program as a whole. The 

2004 Urban Institute study noted that the lack of consistent data on 

resident characteristics, incomes, and rent payments prevented the 

authors from being able to determine whether individual agencies were 

able to achieve the goal of increasing self-sufficiency.

Two of these 

agencies have commitments from local universities to evaluate their 

programs. Additionally, HUD has required the two newest agencies to 

participate in a controlled rent reform study. However, these 

improvements will not help evaluate the program as a whole or the 

activities implemented by the 30 other MTW agencies.

37 Similarly, the 

HUD Inspector General reported in 2005 that HUD lacked the empirical 

data needed to assess the program as a whole.38

Since these reports, HUD has started collecting some additional data 

from MTW agencies, but it has not yet analyzed the data. HUD created 

the MTW-PIC module to collect tenant characteristics such as household 

size, income, and educational attainment. However, according to MTW 

officials, HUD has not used these data to analyze the program’s effects, 

such as changes in resident income. In addition, HUD’s Standard 

Agreement has required agencies since 2009 to provide information in 

their annual reports on the impact of activities, including benchmarks and 

metrics. While these reports are informative, they do not lend themselves 

to quantitative analysis because the reporting requirements do not call for 

standardized data, such as the number of residents that found 

employment.

 

36HUD, Moving to Work (2010).

37Abravanel and others, An Assessment of HUD’s Moving to Work Demonstration (2004).

38HUD, Office of Inspector General, Design and Implementation of the Public 

Housing/Section 8 Moving to Work Demonstration Program, 2005-SE-001 (Seattle, WA: 

Apr. 12, 2005).
 

Page 19 GAO-12-490 Moving to Work Demonstration

In addition, whether these data are sufficient to assess similar activities 

and the program as a whole is not clear, and HUD has not identified the 

data it would need for such an assessment. For example, neither MTWPIC nor annual reports capture standard data on implemented activities. 

Further, according to the Director of the MTW Office, MTW-PIC does not 

include information on individuals who receive nontraditional services 

from an MTW agency, such as homeless assistance or case 

management. Representatives from MTW agencies have suggested that 

HUD should collect some standard data for similar activities. For 

example, they noted that if HUD required all agencies that implemented 

rent reform activities to report standard data, the results of these efforts 

could be analyzed even if the specific activities varied. The Director of the 

MTW Office also noted that MTW-PIC was a potential tool for collecting 

and analyzing standard demographic data.

The MTW Office has recently developed a statement of work for an 

evaluation of the program, but HUD has not allocated funding for the 

study, according to the Director of the MTW Office. Among other things, 

the proposed evaluation is intended to assess the current state of the 

MTW demonstration and determine the extent to which the three statutory 

purposes have been addressed. The study is also expected to include an 

analysis of outcomes associated with specific activities and the 

demonstration as a whole to identify which MTW activities are appropriate 

for expansion to all PHAs. However, the approach envisioned may be 

limited because it would primarily rely on existing data sources. Until HUD 

develops and implements a plan (that includes the identification of 

standard data) to quantitatively assess similar activities and the MTW 

program as a whole, HUD cannot determine their effectiveness. While 

such analyses may be challenging, they would enhance HUD’s ability to 

rigorously assess the demonstration.

HUD has not established performance indicators for the MTW program as 

a whole. The GPRA Modernization Act of 2010 requires that federal 

agencies establish efficiency, output, and outcome indicators for each 

program activity as appropriate.39 Internal control standards also require 

the establishment of performance indicators.40

 39Pub. L. No. 111-352, 124 Stat. 3866 (2011). 

In addition, we have 

previously reported that successful performance indicators demonstrate 

40GAO/AIMD-00-21.3.1. 

Lack of Performance Indicators
 

Page 20 GAO-12-490 Moving to Work Demonstration

results and provide useful information for decision making in order to 

track how programs and activities can contribute to attaining an 

organization’s goals and mission, among other things.41

As previously discussed, MTW agencies set their own performance 

metrics for activities, but HUD has not established performance indicators 

for the program as a whole. HUD’s Fiscal Year 2011 Annual Performance 

Plan established agencywide performance indicators but did not explicitly 

connect the MTW program to any of them.42 Although there are no 

specific targets for the program, the Director of the MTW Office noted that 

the program’s activities support some of the agencywide indicators. 

Specific performance indicators for the MTW program could be based on 

the statutory purposes. For example, agencies could report on the 

savings achieved (reducing costs) and the number of additional 

households served (increasing housing choices). Without performance 

indicators for the MTW program, however, HUD cannot demonstrate the 

results of the program as a whole.

While HUD has identified some lessons learned on an ad hoc basis, it 

does not have a systematic process in place for identifying such lessons. 

We have previously reported that obtaining impact information from 

demonstration programs that are intended to test whether an approach 

(or any of several approaches) can obtain positive results is critical.43

Since 2000, HUD has identified some activities that could potentially be 

replicated by other PHAs. A HUD-sponsored contractor developed five 

case studies from 2000 to 2002 that were intended to describe some of 

the issues, successes, and challenges involved in implementing the MTW 

demonstration. Four of the case studies were developed around specific 

MTW sites, while the fifth provided an overview of the block grant 

approach. Further, from June 2008 to April 2009 HUD identified practices 

that, with statutory or regulatory changes, could be replicated at other 

 This 

information should be gathered to help determine whether programs have 

led to improvements consistent with their purposes.

 41GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002).

42HUD, Fiscal Year 2011 Annual Performance Plan (Washington, D.C.: 2011). 

43GAO/PEMD-95-1. 

HUD Lacks a Systematic 

Process for Identifying 

Lessons Learned
 

Page 21 GAO-12-490 Moving to Work Demonstration

PHAs nationwide. These practices, which are posted on HUD’s website, 

included implementing savings accounts for public housing and voucher 

recipients to promote resident savings. Most recently, HUD’s 2010 Report 

to Congress described promising policies, practices, and concerns.44

However, these efforts have shortcomings. In most cases, the practices 

chosen were based on the opinions of HUD or contracted staff and 

largely involved anecdotal (or qualitative) data rather than quantitative 

data. The lack of standard performance data has affected HUD’s ability to 

systematically identify lessons learned. In its 2005 report on the MTW 

program, the HUD Inspector General noted that the lack of data on the 

program made it difficult to identify activities that could be considered 

models for addressing the three statutory purposes or that could be used 

to show the importance of individual policy changes.

In 

addition, officials from some of the MTW agencies we interviewed noted 

that HUD officials had shared information on activities that had shown 

positive effects during site visits, quarterly phone calls, newsletters, and 

annual conferences. Finally, HUD’s statement of work for its proposed 

evaluation of the MTW program includes the creation of five case studies 

that would review MTW flexibilities.

45 Further, HUD has 

not established criteria, such as demonstrated performance, for 

identifying lessons learned. Finally, HUD has not made regular efforts to 

review and identify lessons learned. Because HUD does not currently 

have a systematic process for identifying lessons learned, it is limited in 

its ability to promote useful practices that could be implemented more 

broadly.

 

44HUD, Moving to Work (2010).

45HUD, Office of Inspector General, 2005-SE-001.
 

Page 22 GAO-12-490 Moving to Work Demonstration

HUD has policies and procedures in place to monitor MTW agencies. 

First, HUD requires program staff to review and comment on agencies’ 

annual plans and reports. Second, staff review tenant data submitted by 

MTW agencies. Third, program staff conduct annual site visits at each 

participating agency to provide technical assistance and program 

updates. HUD generally follows these policies and procedures, which 

focus on technical assistance rather than compliance. Due in part to this 

focus, HUD’s policies and procedures have several key weaknesses. 

Specifically, HUD has not clarified program terminology, ensured that 

each MTW agency is meeting statutory requirements, performed an 

annual risk assessment, or developed policies and procedures to verify 

the accuracy of key information that MTW agencies self-report.

HUD’s monitoring policies and procedures for the MTW program are 

contained in a desk guide, which describes the roles and responsibilities 

of HUD staff in reviewing annual plans and reports and data submissions, 

making site visits, and performing other monitoring activities. In January 

2011, HUD’s Office of Public Housing Investments and Office of Field 

Operations signed a Memorandum of Understanding documenting the 

framework for headquarters and field staff to follow in overseeing MTW 

agencies. According to the memorandum, the MTW Office (within the 

Office of Public Housing Investments) is responsible for oversight of the 

MTW program. In many cases, the MTW Office works with field offices to 

jointly develop responses to MTW agency issues. Further, a MTW 

Working Group—consisting of representatives from Public and Indian 

Housing programs, the Real Estate Assessment Center, and the Office of 

Policy Development and Research—was established to assist with the 

annual plan and report review process.46

HUD staff from the MTW Office and field offices and the MTW Working 

Group share responsibility for reviewing and commenting on participating 

agencies’ annual plans and reports. The Standard Agreement 

As part of the memorandum, the 

Offices of Public Housing Investments and Field Operations agreed to the 

protocols set forth in the desk guide.

 

46HUD’s Real Estate Assessment Center administers physical inspections of HUD’s public 

and multifamily housing properties. The Office of Policy Development and Research is 

responsible for maintaining current information on housing needs, market conditions, and 

existing programs, as well as for conducting research on priority housing and community 

development issues.

HUD Generally 

Follows Its 

Monitoring Policies 

and Procedures, but 

Could Strengthen 

Them

HUD Reviews Agency 

Information and Conducts 

Annual Site Visits
 

Page 23 GAO-12-490 Moving to Work Demonstration

(Attachment B) outlines the requirements for annual plans and reports 

that agencies must submit. MTW coordinators, who are each responsible 

for a specific number of MTW agencies, have the lead role in reviewing 

annual plans and reports to determine if they meet the requirements of 

Attachment B and obtaining input from other HUD staff, including field 

offices and the MTW Working Group. Field offices are required to review 

the annual plans and reports submitted by the MTW agencies in their 

jurisdictions and provide their assessment to the MTW coordinator. 

Similarly, the MTW Working Group reviews and provides comments to 

the MTW coordinator. Coordinators summarize the comments from the 

field offices and MTW Working Group and send them to the agencies. 

The coordinators and field office staff work with MTW agencies to resolve 

any outstanding issues. Once such issues have been resolved, the MTW 

Office approves annual plans and accepts annual reports.47

In 2009, the MTW Office developed review procedures and checklists for 

the coordinators and field office staff to use when reviewing annual plans 

and reports. The checklists provide a framework for MTW coordinators to 

determine whether the annual plans and reports are complete and 

consistent with the requirements of Attachment B. More specifically, 

coordinators are to review plans to ensure that they include how 

proposed activities relate to at least one of the statutory purposes and 

show the anticipated impact on the related purpose; corresponding 

baselines, benchmarks, and metrics; and information on rent reform 

initiatives, among other items. In addition, they are to ensure that the 

plans include a certification that the agency published a notice of plans to 

hold a public hearing to discuss its annual plan, made the agency’s 

annual plan available for public inspection, and conducted a public 

hearing to discuss the annual plan prior to its approval, among other 

things.48

 47According to HUD officials, HUD staff “accept” rather than approve annual reports 

because, unlike the annual plans, the reports do not include a request to conduct certain 

activities.

Further, coordinators are to review reports to ensure that they 

describe the impact of each implemented activity, explain any 

benchmarks that were not achieved and any revised benchmarks or 

metrics, and include the agency’s certification that it has met three of the 

48Soliciting public comments on the plan is important because, unlike other PHAs, MTW 

agencies are not subject to the Public Housing Assessment System, which includes a 

customer satisfaction survey that promotes resident participation. 
 

Page 24 GAO-12-490 Moving to Work Demonstration

five statutory requirements.49

Interviews with MTW coordinators and field staff and documentation for 

our sample of seven MTW agencies indicated that HUD generally 

followed these procedures. Documentation we reviewed for the agencies 

in our sample showed that the coordinators generally completed 

checklists while reviewing annual plans and reports. For example, 

coordinators verified that all ongoing activities were reported, ensured the 

agency included its certification that it had met three of the five statutory 

requirements, and made certain the agency certified that it had held a 

public hearing on its annual plan, among other requirements. 

Coordinators also provided comments to agency staff on annual plans 

and reports.

However, these procedures do not require 

MTW coordinators to verify each agency’s certification that it has met the 

three statutory requirements.

50

HUD field staff also monitor MTW agencies’ compliance with data 

submission requirements, including the requirement to report information 

on resident characteristics in MTW-PIC. HUD requires MTW agencies to 

report timely, accurate, and complete data on at least 95 percent of the 

families receiving housing assistance.

Once it had determined that the agency had addressed all 

of the comments, the MTW Office notified the agency in writing that its 

plan had been approved and report accepted.

51

 49MTW agencies certify that they are assisting substantially the same total number of 

eligible low-income families that they would have served in the absence of MTW; 

maintaining a mix of families (by family size) comparable to those they would have served 

without the demonstration; and ensuring that at least 75 percent of households served are 

very low income. MTW agencies are not required to certify that they meet the other two 

requirements—that MTW agencies establish a reasonable rent policy and assure that 

housing provided meets HUD’s quality standards.

To monitor compliance, field staff 

review monthly reports from MTW-PIC that summarize each participating 

agency’s tenant data reporting rates. The reports we reviewed indicated 

that agencies were complying with the reporting requirements. For 

50Field office staff that we interviewed said that they reviewed annual plans and reports 

and sent their comments and concerns to MTW coordinators.

51MTW agencies are subject to a variety of other reporting requirements. For example, 

MTW agencies are required to report voucher utilization in the Voucher Management 

System. They also must procure a public accountant to perform an Office of Management 

and Budget Circular A-133 compliance audit and submit unaudited financial statements. In 

addition, they are subject to HUD physical and management inspections of public housing 

and on-site monitoring reviews related to voucher reporting.
 

Page 25 GAO-12-490 Moving to Work Demonstration

example, in January 2012, MTW agencies overall achieved a 100-percent 

tenant data submission rate.

In addition, HUD conducts annual site visits to provide technical 

assistance to each MTW agency. The MTW Office and the local field 

office conduct these visits jointly.52

Our analysis of documentation of site visits to participating agencies 

indicated that MTW Office and field staff generally followed HUD’s annual 

site visit procedures. Specifically, analysis of site visit reports indicated

that HUD officials generally discussed the effectiveness of activities and 

helped resolve any outstanding issues. For example, as a result of site 

visits, HUD staff recommended that an agency include cost-saving 

measures in its annual plan, requested clarification of output measures, 

and encouraged one agency to submit articles to the MTW newsletter to 

share its experiences on how rent reform encouraged self-sufficiency.

The MTW Office (in particular the 

coordinator assigned to the agency) takes the lead role in conducting the 

visit, including preparing the agenda, coordinating with the local HUD field 

office, and working with the MTW agency to select properties to visit. 

According to HUD officials, the primary objective of the site visit is to 

provide technical assistance and build a working relationship with the 

participating agencies, not to assess compliance with statutory 

requirements. However, HUD officials stated that if compliance issues 

with statutory purposes are found, HUD staff address these issues during 

the site visit, and coordinators often develop timelines for the agency to 

come into compliance.

Interviews with our sample of MTW agencies and corresponding field 

office officials also indicated that HUD was following its policies and 

procedures for annual site visits. MTW agency officials we spoke with 

indicated that the site visits were generally beneficial because they 

provided an opportunity for in-person discussions that helped facilitate 

communication with HUD. HUD’s field office staff noted their active 

involvement over the years, which had become more defined with the 

issuance of the desk guide in 2011. According to the Director of the MTW 

Office, the office is considering conducting future site visits using a risk-

 52According to HUD officials, the nature of MTW site visits has changed since the 

implementation of the Standard Agreement in 2008. Prior to implementation of the

Standard Agreement, HUD hired contractors to conduct site visits and provided monitoring 

guidance.
 

Page 26 GAO-12-490 Moving to Work Demonstration

based approach. Using this approach, HUD would conduct site visits less 

frequently but would focus on larger agencies that had implemented a 

wide range of complex activities and newly admitted agencies that were 

implementing new activities.

To foster information sharing across agencies and provide technical 

assistance, HUD employs a number of additional strategies. For example, 

HUD hosts annual conferences to share information with MTW agencies 

and facilitate information sharing among agencies. The conferences 

cover a variety of topics, and all participating MTW agencies are invited to 

attend. For example, the 2011 conference focused on effectively 

managing funds in a challenging budgetary environment. HUD also has 

engaged participating agencies in quarterly conference calls and other 

training related to program changes such as the conversion from PIC to 

MTW-PIC and the transition to the Standard Agreement. Further, HUD 

issues notices on various topics, such as MTW reporting requirements, 

and publishes quarterly newsletters that highlight activities relating to 

each statutory purpose, among other topics. HUD also publishes each 

agency’s annual report and researchers’ evaluations of MTW activities on 

its website.

Although HUD follows the policies and procedures that it has in place, it 

could do more to ensure that MTW agencies are demonstrating 

compliance with statutory requirements and to identify possible risks 

relating to activities implemented by each agency, among other things. 

First, HUD has not issued guidance to participating agencies clarifying 

key program terms, including definitions of the purposes and statutory 

requirements of the MTW program. Internal control standards require the 

establishment of clear, consistent goals and objectives.53

 53

As previously 

noted, MTW authorizing legislation established three purposes for the 

program, and agencies must link each of their activities to one of these 

purposes. However, HUD has not clearly defined what the language in 

some of these purposes means, such as “increasing housing choices for 

low-income families.” MTW agencies have linked activities to this purpose 

that range from using block grant funding to support homeownership 

programs to requiring applicants to complete a renter education program 

to establishing a prisoner re-entry housing program. HUD noted the lack 

GAO/AIMD-00-21.3.1. 

HUD’s Monitoring Policies 

and Procedures Have 

Several Key Weaknesses
 

Page 27 GAO-12-490 Moving to Work Demonstration

of a clear definition in its 2010 Report to Congress but continued to 

require that MTW agencies link activities to this purpose.54

HUD has recently taken steps to clarify some terminology, explaining how 

agencies can certify that at least 75 percent of the families they serve 

have very low incomes and that they are serving substantially the same 

number of households under MTW as they did before the program. In 

addition, HUD is revising its reporting requirements for MTW agencies. As 

part of this process, HUD officials told us that they plan to update their 

guidance to more completely collect information related to the program’s 

statutory purposes and requirements. They acknowledged that the 

guidance could be strengthened to require MTW agencies to provide their 

agency-specific definition for the three statutory purposes. As a first step, 

they noted that they planned to require agencies to define “selfsufficiency” by either choosing one of the definitions provided by HUD or 

creating their own. Similarly, the officials stated that they would consider 

requiring MTW agencies to choose between using HUD’s definition of 

increasing housing choices or creating their own definition. Although a 

step in the right direction, allowing MTW agencies to create their own 

definitions of key terms would make it difficult to assess the effectiveness 

of efforts to address statutory purposes. HUD officials also said that the 

revised guidance would provide standardized tables for agencies to report 

data related to the requirement to serve a comparable mix of families. 

Until HUD clearly defines what is meant by all of the statutory purposes 

and requirements of the MTW program, HUD cannot effectively determine 

According to 

MTW officials, they have not defined what is meant by “increasing 

housing choices” so that agencies have the ability to define this term in a 

manner that fits their local needs. In addition, HUD has not clarified what 

is meant by “serving a comparable mix of families” but also requires 

agencies to comply with this requirement. MTW agencies we spoke with 

described varying interpretations of this requirement. For example, 

officials from one agency told us that they observed how family sizes 

changed in their community and compared those changes to changes in 

families within the MTW program, using community survey data and data 

from the agency’s internal system. Officials from another agency we 

spoke with said that over time it had become increasingly difficult to 

determine compliance with this statutory requirement.

 54This requirement is contained in Attachment B of the Standard Agreement. As 

previously noted, an agency can associate an activity with more than one purpose.
 

Page 28 GAO-12-490 Moving to Work Demonstration

whether agencies are addressing these purposes and meeting 

requirements.

Second, HUD has only recently assessed agencies’ compliance with two 

self-certified requirements and has not assessed compliance with the 

third. Internal control standards require control activities to be in place to 

address program risks.55 In addressing these risks, internal control 

guidance states that management should formulate an approach for 

assessing compliance with program requirements.56 While HUD has 

recently made efforts to assess agencies’ compliance with two of the 

three self-certified requirements, it does not have a process in place to 

systematically review compliance with all three requirements. In 2011, 

HUD for the first time assessed participating agencies’ compliance with 

the requirement to assist “substantially the same” number of eligible 

families that would have been served in the absence of MTW. HUD 

collected data from MTW-PIC, the Voucher Management System, and 

each participating agency’s most recent annual report on the number of 

public housing units occupied, vouchers utilized, and other families 

housed and used a formula to compare these data with similar data 

reported before MTW.57

While HUD has taken steps to assess compliance with these two 

statutory requirements, it has not yet developed a methodology for 

HUD and MTW agency staff we interviewed told 

us that they worked together to discuss discrepancies in the calculations. 

According to the Director of the MTW Office, agencies were in 

compliance with this requirement if they were serving at least 95 percent 

of the number of families in their baseline figure. HUD’s recent review of 

each agency’s baseline calculation indicated that all but one of the 

agencies were in compliance. Also in 2011, HUD reviewed MTW-PIC 

data for the first time to determine agencies’ compliance with the 

requirement that at least 75 percent of assisted residents be very low 

income. HUD’s analysis of MTW-PIC data showed that, as of September 

2011, 91 percent of the residents served by MTW agencies fell into this 

category.

 

55GAO/AIMD-00-21.3.1. 

56GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, 

D.C.: August 2001).

57The baseline calculation also adjusts for any incremental vouchers that the agency may 

have been awarded over time. 
 

Page 29 GAO-12-490 Moving to Work Demonstration

assessing agencies’ compliance with the requirement to maintain a 

comparable mix of families. The Director of the MTW Office 

acknowledged that self-certifications were not the best means of ensuring 

compliance and told us that the planned revisions to the reporting 

requirements for MTW agencies would help assess compliance with the 

requirements to maintain a comparable mix of families and ensure that at 

least 75 percent of families assisted are very low income. Without a 

process for systematically assessing compliance with statutory 

requirements, HUD lacks assurance that agencies are complying with 

them.

Third, HUD has not performed an annual assessment of program risks. 

Internal control standards state that an agency should have a risk 

assessment plan that considers internal and external risk factors and 

establishes a control structure to address those risks.58 The standards 

also state that managers should focus on control activities to address 

risks that may involve verifications, performance reviews, and 

documentation, among other things. HUD’s own internal control 

standards also require its program offices to perform an annual risk 

assessment of their programs or administrative functions using a HUD 

risk-assessment worksheet.59

In addition, HUD’s procedures for monitoring the MTW program are not 

risk-based, meaning that HUD has not tailored its monitoring efforts to 

reflect the perceived risk of each MTW agency.

These standards also stress the 

importance of performing a risk assessment when there are significant 

program changes. According to the Director of the MTW Office, the office 

has not performed an annual risk assessment for the MTW program 

because it was not aware of this requirement.

60

 58

MTW agencies, unlike 

other PHAs, are exempt from receiving performance scores that reflect 

GAO/AIMD-00-21.3.1. 

59HUD, Office of the Chief Financial Officer, Departmental Management Control Program, 

Handbook 1840.1 Rev-3 (Washington, D.C.: 1999). 

60MTW agencies are exempt from scoring in the Public Housing Assessment System and 

the Section 8 Management Assessment System. However, MTW agencies are subject to 

physical inspections conducted by the Real Estate Assessment Center under HUD 

guidelines and issued a score. This score is entered into the Public Housing Assessment 

System and can be viewed by MTW staff at any time. A score of 22 or below is flagged by 

the Real Estate Assessment Center (the maximum score is 30) and reported to the 

appropriate field office.
 

Page 30 GAO-12-490 Moving to Work Demonstration

their perceived level of risk. While monitoring procedures are not riskbased, the Director of the MTW Office stated that his office would become 

aware of risks from HUD’s field office staff, which have routine 

responsibility for reviewing financial audits and Office of Management and 

Budget compliance audits. As previously discussed, HUD is considering 

moving toward conducting risk-based site visits.61

Finally, HUD does not have policies or procedures in place to verify the 

accuracy of key information that MTW agencies self-report. Internal 

control standards and guidance emphasize the need for federal agencies 

to have control activities in place to help ensure that program participants 

report information accurately.

In addition, according 

to HUD officials, the office is considering other methods to more 

rigorously analyze MTW agency risk factors. By not performing an annual 

risk assessment and implementing a risk-based approach to monitoring 

MTW agencies, HUD lacks assurance that it has properly identified and 

addressed risks that may prevent participating agencies from addressing 

program purposes and meeting statutory requirements. HUD also lacks 

assurance that it is efficiently using its limited monitoring resources.

62

 61Under this approach, the MTW Office would focus first on agencies that were 

implementing new activities or significant changes and visit these sites.

HUD requires agencies to report on 

benchmarks, metrics, and performance information in their annual reports 

but does not have policies or procedures in place to verify the accuracy of 

this self-reported data. Further, MTW coordinators do not verify this 

information during their annual site visits or during their annual report 

review process, preventing HUD from efficiently using its limited 

monitoring resources. As previously noted, HUD relies on the 

participating agency to submit accurate information. We requested 

documentation from our sample of MTW agencies that supported the 

outcomes they reported in their most recent annual report for a selected 

activity and received various types of support. While this information was 

sufficient for our own review, HUD has not taken similar steps to collect 

evidence to substantiate agencies’ self-reported information. According to 

HUD officials, the MTW Office is considering ways to verify the accuracy 

of key information that MTW agencies self-report. Although verifying all of 

the self-reported information may be challenging, GAO guidance on data 

reliability recommends tracing a sample of data records to source 

documents to determine whether the data accurately and completely 

62GAO/AIMD-00-21.3.1 and GAO-01-1008G. 
 

Page 31 GAO-12-490 Moving to Work Demonstration

reflect the source documents.63 Because HUD does not verify the 

accuracy of any reported performance information, it lacks assurance that 

this information is accurate. To the extent that HUD relies on this 

information to assess program compliance with statutory purposes and 

requirements, its analyses are limited.

Legislation has been proposed to expand the number of PHAs that can 

participate in the MTW program, and a recent HUD report recommended 

expanding the program up to twice its size. As of March 2012, a 

maximum of 39 PHAs could participate in the program, but a 2011 Senate 

bill would direct HUD to increase that number up to 250.64 In addition, 

legislation has been drafted that would establish MTW as a permanent 

program and eliminate the current restrictions on the number of agencies 

that can participate.65 HUD’s 2010 Report to Congress recommends 

increasing the number of participating agencies to about 60.66 HUD and 

some stakeholders believe that expansion could provide the needed 

information on the effect of the MTW program and allow more PHAs to 

test innovative ideas, but questions remain about the lack of performance 

information on current MTW activities. In addition, alternatives to 

expansion exist, including implementing a more narrowly focused 

program.

 63GAO, Assessing the Reliability of Computer-Processed Data, GAO-09-680G

(Washington, D.C.: July 2009).

64Moving to Work Charter Program Act of 2011 (S. 117). 

65Moving to Work Improvement, Expansion, and Permanency Act of 2011 (draft 

legislation); Affordable Housing and Self-Sufficiency Improvement Act of 2012 (AHSSIA) 

(draft legislation). 

66HUD, Moving to Work (2010).

Expanding MTW May 

Offer Benefits but 

Also Raises Questions
 

Page 32 GAO-12-490 Moving to Work Demonstration

According to HUD, some affordable housing advocates, and MTW 

agencies we interviewed, expanding the MTW program could help 

demonstrate the program’s effect and increase the number of lessons 

that can be learned from the program. HUD has reported that doubling 

the number of MTW agencies with the use of strategic criteria and 

program implementation could help demonstrate the effects of MTW on a 

broader scale and enable the housing industry to learn even more from 

the demonstration.67

In addition, information from a private research organization, affordable 

housing advocates, and MTW agencies that we met with suggests that 

allowing additional PHAs to participate in the program could result in 

additional opportunities for PHAs to test innovative ideas, in part by using 

the flexibilities provided to tailor their housing programs and activities to 

meet local conditions. In 2004, the Urban Institute reported that the local 

flexibility and independence permitted under MTW appeared to allow 

strong, creative PHAs to experiment with innovative solutions to local 

challenges.

For example, expansion could provide more 

information on how MTW flexibilities would affect a broader group of 

PHAs. The Director of the MTW Office noted that some MTW activities, 

specifically those related to administrative streamlining, had influenced 

the draft Affordable Housing and Self-Sufficiency Improvement Act of 

2012 (AHSSIA). Some affordable housing advocates that we met with 

emphasized the value of the changes, such as decreases in concentrated 

poverty, that have occurred in some of the communities affected by the 

MTW program and indicated that expansion could enable more PHAs to 

address local needs and therefore benefit additional communities. 

Similarly, officials from MTW agencies that we contacted stated that 

expansion of the program would provide a broader testing ground for new 

approaches and best practices.

68

 67HUD, Moving to Work (2010).

It noted that these PHAs were able to be more responsive 

to local conditions and priorities because they were not as limited by 

program requirements as they might have been before MTW. For 

example, one agency used MTW to increase the proportion of projectbased units relative to tenant-based assistance. Through MTW, this 

adjustment was done to an extent that would not have been permissible 

under standard rules. The Urban Institute concluded that further 

deregulation of PHAs could yield benefits in terms of design and 

68Abravanel and others, An Assessment of HUD’s Moving to Work Demonstration (2004).

Current MTW Participants 

and Affordable Housing 

Advocates Indicated that 

Expanding MTW Could 

Help Demonstrate the 

Program’s Effect and 

Increase Innovation
 

Page 33 GAO-12-490 Moving to Work Demonstration

implementation innovations. Officials from an organization that advocates 

on behalf of large PHAs and supports expansion noted that affordable 

housing needs varied by locality and that the MTW program enabled 

participating agencies to design effective approaches based on local 

needs. Similarly, another affordable housing advocacy organization told 

us that they supported expanding MTW not only because it enabled 

participating agencies to tailor activities to local needs but also because it 

involved local communities in the process.

Officials from several of the MTW agencies we interviewed also noted 

that the MTW program had empowered them to create and implement 

strategies that addressed local issues and said that expanding the 

program would give more PHAs the same flexibility. For example, in one 

northeastern state where the housing stock was relatively old, the MTW 

agency was able to focus on developing new affordable housing. Another 

MTW agency in a western state with mostly newer housing stock chose to 

reduce the frequency of inspections of its properties and focus its efforts 

on administrative streamlining and the disposition of its older units. 

Further, several MTW agencies that we interviewed described how they 

implemented the requirement to establish a rent policy that encouraged 

employment and self sufficiency. For example, officials from one MTW 

agency told us that they believed the traditional requirement that 

residents pay 30 percent of their adjusted income in rent was a 

disincentive to work, because as resident income increases so would the 

payment toward rent. To encourage residents to seek work, this agency 

implemented work requirements and a minimum rent. Additionally, some 

agencies have used their MTW status to establish programs that focus on 

specific populations, including working families with children, the elderly 

and disabled, and the homeless.

Some proponents of expansion that we interviewed also noted that 

expanding the MTW program could provide more PHAs with the ability to 

use funding from different sources more flexibly than possible without 

MTW status. Agencies without MTW status have to implement their 

activities while adhering to the regulations associated with three different 

funding streams, evidence of the fragmented nature of housing 
 

Page 34 GAO-12-490 Moving to Work Demonstration

assistance.69 As we have seen, MTW agencies may request waivers of 

certain provisions of the 1937 Housing Act in order to combine annual 

funding from separate sources into a single authoritywide funding source. 

HUD field office staff with responsibility for monitoring MTW agencies 

observed that the single-fund flexibility was beneficial because it enabled 

participating agencies to develop supportive service programs, such as 

job training or educational programs, which help move families toward 

self-sufficiency. One HUD field office official stated that this flexibility 

would be a significant benefit for other PHAs. An affordable housing 

advocate we met with also noted that this ability to use different kinds of 

funds interchangeably was beneficial because it enabled MTW agencies 

to shift funds based on local priorities. Further, officials from the MTW 

agencies we interviewed agreed that this flexibility was beneficial. For 

example, officials from one MTW agency stated it had been able to use 

the single fund to organize itself as a business organization, develop a 

strategic plan based on the housing needs of low-income families in the 

community, leverage public funds and public and private partnerships, 

and develop mixed-income communities. Two of the MTW agencies that 

we interviewed also stated that the single-fund flexibility had enabled 

them to fund programs that encouraged self-sufficiency among residents. 

For example, officials explained that they had used funding for coaching 

and counseling services, job training support, and education programs. 

Finally, officials from three of the MTW agencies we interviewed noted a 

related benefit of participation. They said that their MTW status had 

enabled them to respond more quickly to real estate opportunities 

because they do not have to wait for HUD approvals to purchase 

properties.

A lack of performance information, limited HUD oversight, and concerns 

about the program’s impact on residents raise questions about expanding 

the MTW program. As we noted previously, conclusive information about 

the effectiveness of the MTW program is limited in part because HUD 

does not have a plan for identifying and analyzing standard performance 

data, has not established performance indicators for the program as 

 

69We recently reported that there were 160 different programs, tax expenditures, and 

other tools that supported homeownership and rental housing in fiscal year 2010, 

including multiple programs that provided funding for PHAs. See GAO, 2012 Annual 

Report: Opportunities to Reduce Duplication, Overlap and Fragmentation, Achieve 

Savings, and Enhance Revenue, GAO-12-342SP (Washington, D.C.: Feb. 28, 2012).

Lack of Performance 

Information and Other 

Issues Raise Questions 

about Expansion
 

Page 35 GAO-12-490 Moving to Work Demonstration

whole, and does not have a systematic process for identifying lessons 

learned.

HUD’s 2010 Report to Congress noted that the conclusive impacts of 

many MTW activities, particularly as they relate to residents, could not yet

be known.70

Similarly, affordable housing advocates and legal aid organizations that 

we interviewed stated that because lessons had not been learned from 

MTW, there was no basis for expanding the program. For example, 

officials from a national affordable housing advocacy organization stated 

that some MTW agencies have used their flexibility to establish limits on 

the length of time someone can live in assisted housing, but there is little 

research on the effect of such efforts. The officials stated that there was 

no evidence that this policy had helped anyone become self-sufficient and 

move out of public housing. The officials added that data were not 

available on the extent to which MTW agencies have provided incentives 

for residents to become self-sufficient or have increased housing choices. 

Similarly, an official from a national housing law advocacy organization 

stated that data were not available to determine the effect of the MTW 

program, particularly at the national level.

For example, the report noted that the rent reforms 

implemented under MTW varied greatly and were not implemented using 

a controlled experimental methodology. As a result, which aspects of rent 

reforms should be recommended for all PHAs were not clear. The report 

also noted the limitations that exist when evaluating the outcomes of 

MTW—limitations that stem from the weak initial reporting requirements 

and lack of a research design. The report concluded that, given these 

limitations, expansion should occur only if newly admitted PHAs structure 

their programs for high-quality evaluations that permit lessons learned to 

be generalized beyond a single PHA experience.

In addition, our own work, some research organizations, and affordable 

housing advocates question HUD’s ability to effectively manage an 

expanded MTW program. As previously noted, HUD’s current monitoring 

procedures have several key weaknesses, including the lack of a 

systematic process for assessing agencies’ compliance with statutory 

requirements and an assessment of program risks. Some research 

organizations also have questioned HUD’s capacity to oversee additional 

 70HUD, Moving to Work (2010).
 

Page 36 GAO-12-490 Moving to Work Demonstration

MTW agencies. For example, the Urban Institute reported that the 

approval process that HUD was using at the time of the institute’s 2004 

review would not be feasible for an expanded program because of the 

administrative burden involved.71 At the time of the 2004 study as well as 

our review, HUD reviewed each individual request to waive specific 

provisions of the 1937 Housing Act before approving annual plans. Staff 

from another research organization questioned whether HUD has the 

capacity to oversee additional agencies. Similarly, one affordable housing 

advocate that we interviewed stated that HUD’s capacity to oversee an 

expanded program is not clear, in part because current monitoring 

activities are not transparent. At the time of our review, HUD had four fulltime MTW coordinators, who each managed from 6 to 10 MTW 

agencies.72

Researchers and several of the affordable housing advocates and legal 

aid agencies that we met with also raised concerns that the current 

program, and therefore also an expanded program, could negatively 

affect residents of MTW agencies. For example, two research 

organizations have stated residents could be negatively affected by MTW 

agencies that implement voucher policies that reduce portability—that is, 

residents’ ability to use their vouchers in an area outside of the area 

where they received it. One of these research organizations stated that 

the differences in the way voucher programs were implemented across 

MTW agencies could reduce residents’ ability to use vouchers outside of 

the area where they received the assistance. Officials from the other 

organization noted that some MTW agencies had instituted policies that 

prohibited vouchers from being transported out of the originating 

jurisdictions, thereby limiting housing choices. According to HUD officials, 

MTW agencies with policies that limit portability can make exceptions. For 

example, these agencies have made exceptions for residents seeking 

employment opportunities.

According to the Director of the MTW Office, it takes more 

resources for HUD to oversee MTW agencies than non-MTW agencies. 

Thus, if additional agencies were added under the current program 

design, HUD would likely need additional resources.

 

71Abravanel and others, An Assessment of HUD’s Moving to Work Demonstration (2004).

72There are three additional coordinators who are each responsible for a single MTW 

agency as designated in the agency’s MTW agreement. These coordinators have other 

responsibilities within HUD and are not assigned to the MTW Office.
 

Page 37 GAO-12-490 Moving to Work Demonstration

Legal aid organizations that have worked with residents of MTW agencies 

as well as affordable housing advocates told us some of the requirements 

that MTW agencies have implemented, such as work requirements, were 

potentially harmful to residents.73 For example, legal aid representatives 

from one community told us that the work requirement was not 

consistently enforced across various mixed-income properties that 

included public housing as well as market-rate units. According to these 

officials, they have had clients who have been evicted for not working, 

even though the client was in school or disabled—both exceptions to the 

work requirement. These officials also stated that property managers in 

the city’s various mixed-income developments did not implement MTW 

policies consistently. For example, the officials stated that residents have 

been told by property managers that they would be in compliance with the 

work requirement if they were in school or another training program, only 

to have the MTW agency determine that they were not in compliance. 

According to HUD officials, inconsistent enforcement of policies is not 

unique to MTW agencies, and residents would have recourse. Legal aid 

representatives that worked with residents of another MTW agency also 

told us that the work requirement was a punitive policy that negatively 

affected the poorest residents. The officials stated that there were better 

methods for encouraging work and self-sufficiency, such as job training. 

Officials from a national affordable housing advocacy organization agreed 

that work requirements are punitive and stated that they disagreed with a 

policy of making housing assistance contingent on other factors, such as 

having a job. In their view, housing assistance should be a stable form of 

assistance for low-income households.

Alternatives to expansion include implementing a program that is targeted 

more to specific activities and waiving some regulations for all PHAs as 

described in proposed legislation. According to the Urban Institute, an 

alternative to expanding MTW could be to systematically test a limited 

number of programmatic alternatives—such as flat rents, time limits, or 

debt financing of capital improvements.74

 

73Work requirements can be met by attending job training programs as well as working.

This approach would not allow 

individual agencies as much discretion to design combinations of reforms 

around local conditions and priorities. However, this approach could yield 

more systematic evidence about the costs and benefits of particular 

74Abravanel and others, An Assessment of HUD’s Moving to Work Demonstration (2004).

Alternatives Exist to 

Expanding the MTW 

Program
 

Page 38 GAO-12-490 Moving to Work Demonstration

program reforms if it included a rigorous evaluation design and mandatory 

data collection on key outcomes, such as the number and characteristics 

of participating households. Collection of such information in a 

standardized format would need to be a minimum requirement for 

participation if the point was to learn from the experiences of those testing 

activities. In addition, an official from an affordable housing advocacy 

organization that we met with stated that testing the effectiveness of 

discrete activities on a smaller scale would be useful. HUD also noted 

that altering the scope of the demonstration for new participants could 

improve what was learned from specific activities. For example, its 2010 

Report to Congress stated that data on MTW could be strengthened if the 

scope of the demonstration were altered for new participants by selecting 

agencies committed to testing a particular activity, such as rent reform, 

and requiring rigorous evaluation.75

In addition, according to researchers, PHAs could be allowed some level 

of deregulation, so that they could implement the same sort of 

administrative streamlining activities that MTW agencies implement. The 

Urban Institute has reported that further deregulation of PHAs may yield 

benefits in terms of program design and implementation innovations but 

that such deregulation could entail risks and should be evaluated.

In December 2011, HUD issued a 

request for proposals for a demonstration that would test alternatives to 

the current rent structure in the voucher program. According to the 

proposal, the demonstration would most likely be undertaken at select 

MTW agencies. In addition, HUD’s 2012 appropriations act authorized a 

Rental Assistance Demonstration that would enable HUD to authorize 

and evaluate new approaches to preserving affordable rental housing, 

including converting public housing to project-based rental assistance. 

AHSSIA includes authorization for a revised version of the Rental

Assistance Demonstration. 

76

 

75HUD, Moving to Work (2010).

Some 

of the MTW agencies that we met with were supportive of the 

administrative streamlining authorities allowed by MTW and described in 

proposed legislation such as AHSSIA. As proposed, AHSSIA would allow 

PHAs to reduce the frequency of income certifications for the elderly and 

disabled to save on administrative costs, among other things. According 

to the Director of the MTW Office, the experiences of MTW agencies 

informed this policy proposal. In addition, HUD’s 2010 Report to 

76Abravanel and others, An Assessment of HUD’s Moving to Work Demonstration (2004).
 

Page 39 GAO-12-490 Moving to Work Demonstration

Congress supported allowing more PHAs to participate in the program. 

Finally, we recently reported on cost savings that could be realized from 

allowing additional housing authorities to implement some of the reforms 

MTW agencies have tested.77

The MTW demonstration is designed to provide participating agencies 

with the flexibility to develop and test activities that achieve costefficiency, encourage residents with children to obtain employment and 

become self-sufficient, and increase housing choices for low-income 

families. While this flexibility has allowed participating agencies to 

implement hundreds of activities, HUD has not done all that it can to 

evaluate the program’s effectiveness, identify successful approaches that 

could be applied to public housing agencies more broadly, or ensure that 

MTW agencies comply with program requirements. Because Congress is 

considering expanding the program to many more PHAs, the absence of 

information needed to conduct a comprehensive program evaluation and 

compliance reviews is significant. HUD has recognized the importance of 

rigorous evaluation by requiring newly admitted agencies to have strong 

evaluation components. However, these improvements will not help 

evaluate the program as a whole. Without more complete knowledge of 

the program’s effectiveness and the extent to which agencies are 

adhering to program requirements, it is difficult for Congress to know 

whether an expanded MTW will benefit additional agencies and the 

residents they serve.

Recognizing that it needed to do more to improve what was known about 

the program’s effectiveness, HUD started requiring MTW agencies to 

describe the impact of each implemented activity in their annual reports 

beginning in 2009. However, the information that MTW agencies reported 

did not always reflect outcomes, and HUD’s guidance does not require 

that information on activities be quantifiable and outcome-oriented to the 

extent possible. Without more specific guidance on reporting performance 

information, HUD cannot be assured of collecting data that reflects the 

outcomes of activities.

 

77GAO, Housing Choice Vouchers: Options Exist to Increase Program Efficiencies, 

GAO-12-300 (Washington, D.C.: Mar. 19, 2012).

Conclusions
 

Page 40 GAO-12-490 Moving to Work Demonstration

Further, challenges such as the lack of analysis of standard data and the 

absence of performance indicators have prevented comprehensive 

evaluations of similar activities and the overall MTW program. HUD has 

recently started collecting additional information through MTW-PIC and 

annual reports, but has not yet analyzed the data. Further, whether the 

data collected are sufficient to assess similar activities and the program 

as a whole is not clear, and HUD has not identified the performance data 

it needs to undertake such analysis. Until HUD has a plan (that includes 

the identification of standard data) to quantitatively assess similar 

activities and the MTW program as a whole, HUD cannot determine their 

effectiveness. Additionally, HUD has not established performance 

indicators specific to MTW. Indicators linked to the statutory purposes of 

reducing costs, encouraging self-sufficiency, and increasing housing 

choices would help HUD demonstrate that the program has produced 

desired results.

Similarly, HUD does not have a systematic process in place to identify 

lessons learned from the MTW demonstration. Identifying activities that 

could be replicated more broadly is a goal of the MTW program and could 

be aided by the analysis of some standard performance data. The 

absence of a criteria-based, regular process for identifying lessons 

learned complicates efforts to determine which MTW activities are most 

effective and should be replicated more broadly.

At the same time, HUD’s monitoring efforts are not as strong as they 

could be. First, because HUD has not clarified key terms related to the 

three statutory purposes and five requirements, it cannot effectively 

determine whether MTW agencies are actually addressing these 

purposes and meeting requirements. Second, HUD does not have a 

process in place to systematically review compliance with all 

requirements. Such a review is especially important to a program like 

MTW that allows participants to self-certify their compliance with some 

program requirements. HUD has begun assessing compliance with two of 

the MTW requirements that call for self-certification, but not the third, and 

thus lacks assurance that agencies are complying with all three.

Moreover, HUD’s procedures for monitoring MTW agencies are not riskbased. It does not conduct an annual assessment of risks and provides 

the same level of monitoring for all agencies, even though some may 

pose greater risks than others. A risk-based approach to monitoring 

would provide greater assurance that HUD has addressed all risks, 

particularly those that may prevent participating agencies from addressing 

program purposes and meeting statutory requirements. Further, unless it 
 

Page 41 GAO-12-490 Moving to Work Demonstration

implements a risk-based approach (such as that currently being 

considered for annual site visits) to monitoring MTW agencies, HUD 

cannot be assured that it is using its limited monitoring resources most 

efficiently. Finally, just as HUD does not assess compliance with all three 

self-certified requirements, it does not verify the accuracy of key 

information that agencies self-report, including information on the impact 

of MTW activities. Annual site visits have been used primarily to provide 

technical assistance rather than to assess self-reported information. By 

not verifying the accuracy of any performance information, HUD lacks 

assurance that this information is accurate.

To improve what is known about the effectiveness of the MTW program, 

we recommend that the Secretary of the Department of Housing and 

Urban Development

• improve HUD’s guidance to MTW agencies on providing performance 

information in their annual reports by requiring that such information 

be quantifiable and outcome-oriented to the extent possible;

• develop and implement a plan for quantitatively assessing the 

effectiveness of similar activities and the program as a whole 

including the identification of standard performance data needed; and

• establish performance indicators for the MTW program as a whole.

To enhance the ability to identify MTW practices that could be applied 

more broadly, we recommend that the Secretary of the Department of 

Housing and Urban Development create a process to systematically 

identify lessons learned.

To improve HUD’s oversight of the MTW program, we recommend that 

the Secretary of the Department of Housing and Urban Development

• issue guidance that clarifies key program terms, such as the three 

statutory purposes of the program and the five statutory requirements 

that MTW agencies must meet;

• develop and implement a systematic process for assessing 

compliance with statutory requirements;

Recommendations for 

Executive Action
 

Page 42 GAO-12-490 Moving to Work Demonstration

• conduct an annual risk assessment for the MTW program and 

implement risk-based monitoring policies and procedures such as 

those currently being considered for site visits; and

• implement control activities designed to verify the accuracy of a 

sample of the performance information that MTW agencies self-report.

We provided a draft of this report to HUD. The Assistant Secretary for 

Public and Indian Housing provided written comments, which are 

reprinted in appendix II. HUD disagreed with our recommendation that the 

agency develop performance indicators for the MTW program as a whole, 

was in partial agreement with four recommendations, and generally 

agreed with three. The agency said that developing programwide 

performance measures could be difficult and might be contrary to the 

nature of the demonstration. In addition, HUD emphasized the 

improvements that it had made to its reporting requirements in order to 

collect more consistent, outcome-oriented data. We acknowledged these 

improvements in the draft report, but as our recommendations indicated, 

we saw opportunities for additional improvements. HUD also noted that 

some of our recommendations might be a good fit for the existing 

program but that others might be more appropriate for a future expanded 

demonstration. 

In disagreeing with our recommendation that it establish performance 

indicators for the MTW program as a whole, HUD emphasized the 

difficulty of measuring all activities against the same standard. The 

agency noted that because each MTW agency had implemented a unique 

combination of activities, developing programwide performance measures 

would make determining the impacts of specific activities unclear and 

prevent the identification of individual policies that could be applied more 

broadly. However, the purpose of programwide indicators would not be to 

isolate the impact of individual activities but to demonstrate programwide 

results—including showing the extent to which the program was 

addressing its statutory purposes of achieving greater cost-effectiveness 

in federal housing expenditures, giving families with children incentives to 

obtain employment and become self-sufficient, and increasing housing 

choices for low-income families. HUD also stated that applying 

programwide performance measures would be complicated by the fact 

that activities that advance one statutory purpose might conflict with other 

purposes. We agree that it is important to evaluate similar activities and 

have a separate recommendation addressing this need. But, the purpose 

of programwide assessment is to demonstrate whether the provision of 

Agency Comments 

and Our Evaluation
 

Page 43 GAO-12-490 Moving to Work Demonstration

flexibility in itself results in the intended benefits of the MTW program, 

such as cost savings or increased family self-sufficiency. Demonstrating 

that the increased flexibility the program offers has produced the intended 

results is critical, particularly as Congress considers whether to expand 

the program. We continue to believe in the importance of demonstrating 

program results and therefore continue to recommend that HUD develop 

performance indicators for the MTW program as a whole. 

HUD was in partial agreement with four recommendations. 

• First, HUD said that proposed revisions to the reporting requirements 

for MTW agencies had addressed our recommendation that the 

agency improve its guidance to MTW agencies on providing 

performance information in annual reports. HUD’s draft guidance is in 

line with our recommendation that HUD require agencies to report 

quantifiable and outcome-oriented information. However, because 

these proposed revisions have yet to be finalized, we did not revise 

our recommendation. 

• Second, HUD agreed that quantitatively assessing the effectiveness 

of similar activities was an important step but noted the difficulties 

associated with assessing the effectiveness of the program as a 

whole. However, as noted above, we continue to believe in the 

importance of demonstrating program results. Consequently, we did 

not revise our recommendation. 

• Third, HUD stated that providing a menu of standard metrics may be 

the best way to clarify the program’s statutory purposes and that it 

had made progress in recent years in addressing our 

recommendation that it issue guidance that clarifies the statutory 

requirements. HUD also noted that the proposed revisions to the 

reporting requirements would provide additional clarification on the 

statutory requirements. These efforts, which were acknowledged in 

the draft report, are a step in the right direction, and we encourage 

HUD to continue finalizing this guidance. As noted above, because 

these proposed revisions have yet to be finalized, we did not revise 

our recommendation.

• Fourth, HUD described recent efforts to assess compliance with two 

statutory requirements and analysis that it could conduct once 

proposed revisions to reporting requirements for MTW agencies were 

finalized. Because the process used to assess compliance with one of 

the requirements has not been formalized in policy and the proposed 

revisions have not been finalized, we did not revise our 
 

Page 44 GAO-12-490 Moving to Work Demonstration

recommendation that HUD develop and implement a systematic 

process for assessing compliance with statutory requirements.

HUD generally agreed with the three remaining recommendations. For 

example, HUD agreed that it should proactively identify lessons learned 

and described some of its recent efforts to do so. We acknowledged 

these efforts in our draft report but noted the absence of a criteria-based, 

regular process for identifying lessons learned. HUD also described plans 

to develop a formal risk-based strategy for monitoring and, when we 

asked for further clarification, stated that it agreed with our 

recommendation to conduct an annual risk assessment for the MTW 

program. Finally, HUD discussed potential strategies for verifying the 

information that MTW agencies report using existing or planned HUD 

systems. 

HUD also requested that we consolidate four separate recommendations 

into two, but we continue to believe that maintaining distinctions between 

the separate recommendations is important. First, HUD requested that we 

combine two recommendations: that it create a plan to quantitatively 

assess the effectiveness of similar activities and the program as a whole 

(including identifying the standard performance data needed), and that it 

establish performance indicators for the program as a whole. Although 

related, the two recommendations are distinct because the first focuses 

on the need for program evaluation and the second on performance 

measurement. Program evaluations typically examine a broad range of 

information on program performance, while performance measurement

generates outcomes that show whether a program has achieved specific

objectives.78

Second, HUD requested that we combine the recommendation that it 

issue guidance clarifying key program terms (such as the three statutory 

purposes and five statutory requirements) with the recommendation that it 

implement a systematic process for assessing compliance with statutory 

requirements. However, defining program requirements and assessing 

them are separate and distinct activities. Therefore, we did not combine 

the recommendations.

As a result, we did not combine the recommendations.

 

78GAO, Performance Measurement and Evaluation: Definitions and Relationships, 

GAO-11-646SP (Washington, D.C.: May 2011). 
 

Page 45 GAO-12-490 Moving to Work Demonstration

As agreed with your offices, 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 to the Secretary of Housing 

and Urban Development and other interested committees. In addition, the 

report will be available at no charge on the GAO website at 

http://www.gao.gov.

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

contact me at (202) 512-8678 or sciremj@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix III.

Mathew J. Scirè

Director, Financial Markets

 and Community Investment
Appendix I: Scope and Methodology

Page 46 GAO-12-490 Moving to Work Demonstration

Our objectives were to examine (1) what is known about the extent to 

which the Moving to Work (MTW) demonstration program is addressing 

the program’s statutory purposes, (2) the Department of Housing and 

Urban Development’s (HUD) monitoring of MTW agencies’ efforts to 

address these purposes and meet statutory requirements, and (3) 

potential benefits of and concerns about expanding the number of public 

housing agencies (PHA) that can participate in the demonstration 

program.

To evaluate what is known about the extent to which the MTW program is 

addressing the program’s statutory purposes, we reviewed the most 

recent annual reports as of January 2012 for 30 MTW agencies.1 We 

reviewed these annual reports and the corresponding annual plans to 

identify the ongoing activities that the agencies were implementing, 

determine the extent to which these activities were linked with one or 

more of the program’s statutory purposes, and assess the performance 

information provided for each activity.2 To assess the performance 

information provided by MTW agencies, we examined HUD’s reporting 

guidance and compared it with internal control standards for federal 

agencies.3

• Cambridge Housing Authority (Cambridge, Massachusetts),

We assessed the reliability of selected information in the 

reports by reviewing supporting documentation from a sample of seven 

MTW agencies and interviewing the officials responsible for preparing 

and reviewing this information. These seven agencies were

• Chicago Housing Authority (Chicago, Illinois),

• Housing Authority of the City of Atlanta (Atlanta, Georgia),

• Housing Authority of the City of Pittsburgh (Pittsburgh, Pennsylvania),

 1

Of the 35 participating agencies, 30 had issued an annual report for 2011 as of January 

2012. The other five agencies had not been in the program long enough to report on their 

accomplishments. 

2

We reviewed the annual reports to identify ongoing activities. For these activities, we 

reviewed the reports to determine whether the activity was linked to a statutory purpose 

and the corresponding annual plan if that information was not available in the report. The 

results from the two analyses were combined.

3

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 47 GAO-12-490 Moving to Work Demonstration

• Housing Authority of the County of Santa Clara/Housing Authority of 

the City of San Jose (Santa Clara County and San Jose, California),

• Lawrence-Douglas County Housing Authority (Lawrence, Kansas), 

and

• Vancouver Housing Authority (Vancouver, Washington).4

We selected these agencies to provide diversity in geography, agency 

size, and length of time participating in the program. We determined that 

the reports were sufficiently reliable for the purposes of our review.

Through interviews and a literature search, we identified three studies of 

the MTW program as a whole. We reviewed these studies to identify 

information on the program’s effectiveness and any challenges 

associated with assessing it. We determined that these studies were 

methodologically sound and reliable for our purposes. We examined 

HUD’s recent efforts to collect data from MTW agencies, including 

documentation on the reporting requirements for MTW agencies. In 

addition, we reviewed HUD’s fiscal year 2010-15 strategic plan and Fiscal 

Year 2011 Annual Performance Plan for any performance indicators for 

the MTW program. We also reviewed the GPRA (Government 

Performance and Results Act) Modernization Act of 2010, Office of 

Management and Budget guidance, internal control standards, and a 

GAO report on attributes of successful performance measures.5

To assess HUD’s monitoring of MTW agencies’ efforts to address the 

program’s statutory purposes and meet requirements, we obtained and 

reviewed documentation of monitoring policies and procedures, including 

the Standard Agreement that HUD executed with MTW agencies in 2008, 

 Further, 

we identified five studies of specific MTW agencies or activities identified 

by HUD and representatives of the sample of MTW agencies we 

interviewed. Finally, we reviewed published reports and HUD’s website 

for information on HUD’s efforts to identify lessons learned.

 4

The Housing Authority of the County of Santa Clara and the Housing Authority of the City 

of San Jose are consolidated. We considered them as one MTW agency in our sample, as 

they report the information to HUD jointly.

5

See GAO/AIMD-00-21.3.1 and GAO, Tax Administration: IRS Needs to Further Refine Its 

Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 

2002).
Appendix I: Scope and Methodology

Page 48 GAO-12-490 Moving to Work Demonstration

the MTW Desk Guide, a 2011 Memorandum of Understanding between 

HUD’s Office of Public Housing Investments and Office of Field 

Operations, and other HUD guidance. Based on these documents and 

interviews with HUD staff, we identified three key monitoring processes: 

the review of annual plans and reports, reviews of data entered into the 

Moving to Work section of the Public and Indian Housing Information 

Center (MTW-PIC), and annual site visits to each MTW agency.

To assess the extent to which HUD staff were following these monitoring 

policies and procedures, we reviewed documentation of monitoring 

activities for our sample of seven MTW agencies. For example, to verify 

the steps HUD had taken to review annual plans and reports, we 

reviewed the checklists that the MTW coordinators used to document 

their review of these plans and reports. We also reviewed HUD’s 

comment letters for fiscal year 2011. To verify the steps HUD had taken 

to review data submitted into the MTW-PIC system, we reviewed monthly 

reports that showed the degree to which MTW agencies overall complied 

with reporting requirements from August 2011 through January 2012. 

Finally, to verify that both headquarters and field office staff made site 

visits and the extent to which they made annual visits, we reviewed the 

most recently available site visit reports completed by the MTW Office for 

all agencies as of October 2011. In addition, we interviewed the MTW 

agencies in our sample and the corresponding HUD field office officials to 

discuss the annual site visits.

We also compared HUD’s monitoring policies and procedures to internal 

control standards for the federal government and HUD’s own program 

management guidance.6

 6

See 

As a part of this analysis, we compared HUD’s 

guidance to MTW agencies with the internal control requirement for clear 

goals and objectives. We also reviewed information on HUD’s efforts to 

clarify how agencies could certify compliance with the requirement to 

assist “substantially the same” number of eligible families that would have 

been served in the absence of MTW. In addition, we compared HUD’s 

efforts to assess agencies’ compliance with statutory requirements with 

the internal control standard related to assessing compliance with 

program requirements. Further, we reviewed internal control standards for 

GAO/AIMD-00-21.3.1; GAO, Internal Control Management and Evaluation Tool, 

GAO-01-1008G (Washington, D.C.: August 2001); and HUD, Office of the Chief Financial 

Officer, Departmental Management Control Program, Handbook 1840.1 Rev-3 

(Washington, D.C.: 1999).
Appendix I: Scope and Methodology

Page 49 GAO-12-490 Moving to Work Demonstration

the federal government and HUD’s own internal control standards and 

identified the requirement that programs have an annual risk assessment. 

We interviewed HUD regarding any risk assessment performed for the 

MTW program. Finally, we interviewed HUD officials to determine 

whether any of the performance information that MTW agencies reported 

had been verified. We compared HUD’s lack of verification with the 

internal control standards and guidance that emphasized the need for 

control activities to ensure that program participants report information 

accurately.

To discuss the potential benefits and concerns associated with expanding 

the number of PHAs that can participate in the program, we reviewed 

studies, reports, and testimonies by researchers, affordable housing 

advocates, resident advocates, and the HUD Office of Inspector General. 

For all three objectives, we interviewed officials from the seven MTW 

agencies in our sample and representatives from affordable housing 

advocacy organizations such as the Council of Large Public Housing 

Agencies, the National Association of Housing and Redevelopment 

Officials, the National Leased Housing Association, and the Public 

Housing Authorities Directors Association. We spoke with resident 

advocacy organizations such as the National Low-Income Housing 

Coalition, the National Housing Law Project, and legal aid agencies that 

represented residents serviced by five of our sample MTW agencies.7

We conducted this performance audit from July 2011 to April 2012 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

We 

also interviewed staff from the Center for Budget Policy and Priorities, a 

research organization that has studied and written about the MTW 

program; researchers who had evaluated the MTW program; and HUD 

officials from the MTW office and the field offices that corresponded to our 

sample of agencies. During our interviews, we discussed the potential 

benefits of expansion and the concerns of these organizations. Based on 

our review of available studies and reports and interviews with the above 

mentioned stakeholders, we identified key benefits and concerns. We 

also made observations based on our findings related to the availability of 

performance information for the program and HUD’s monitoring efforts.

 

7

Two legal aid agencies did not respond to our requests for interviews.
Appendix I: Scope and Methodology

Page 50 GAO-12-490 Moving to Work Demonstration

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 51 GAO-12-490 Moving to Work Demonstration

Appendix II: Comments from the Department 

of Housing and Urban Development 
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 52 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 53 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 54 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 55 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 56 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 57 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 58 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 59 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 60 GAO-12-490 Moving to Work Demonstration
Appendix II: Comments from the Department 

of Housing and Urban Development

Page 61 GAO-12-490 Moving to Work Demonstration
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 62 GAO-12-490 Moving to Work Demonstration

Mathew J. Scirè, (202) 512-8678 or sciremj@gao.gov

In addition to the contact named above, Paige Smith (Assistant Director), 

Anna Carbino, Emily Chalmers, John McGrail, Marc Molino, Lisa Moore, 

Daniel Newman, Lauren Nunnally, and Andrew Stavisky made key 

contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(250626)
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