NATIVE AMERICAN 

HOUSING

Additional Actions 

Needed to Better 

Support Tribal Efforts

Report to Congressional Committees

March 2014

GAO-14-255

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-255, a report to 

congressional committees

March 2014

NATIVE AMERICAN HOUSING

Additional Actions Needed to Better Support 

Tribal Efforts

Why GAO Did This Study

More than 570 federally and staterecognized Indian tribes receive about 

$667 million in housing assistance 

annually under the IHBG program. The 

IHBG program recognizes the tribes’ 

right to self-determination and selfgovernance in addressing their 

affordable housing needs. Conference 

Report 112-284 mandates that GAO 

study tribal housing challenges. 

Building on past work that raised 

discussion about some challenges, this 

report examines common housing 

challenges tribes face and actions that 

could address them. GAO interviewed 

HUD and other agencies, a tribal 

advocacy group, and 23 tribal entities 

that were selected using input from 

HUD and other factors such as tribe 

funding, and conducted two site visits 

where challenges appeared to be 

unique.

What GAO Recommends

Agencies involved in Native American 

housing should develop and implement 

a coordinated environmental review 

process. HUD should also seek input 

from all tribes about the new training 

and technical assistance procedures. 

Finally, HUD should share promising

housing approaches among tribes. The 

agencies generally agreed with GAO’s 

recommendations, but HUD disagreed 

with the recommendation about 

creating a feedback mechanism 

because it said it already had one. 

However, HUD’s existing mechanism 

does not include outreach to tribes that 

have yet to use the new procedures. 

What GAO Found

Indian tribes and tribally designated housing entities face both external and 

internal challenges in carrying out affordable housing activities under the Indian 

Housing Block Grant (IHBG) program, which was authorized by the Native 

American Housing Assistance and Self-Determination Act of 1996 (NAHASDA). 

The most commonly identified external challenges included the often remote 

location of tribal lands and lack of infrastructure such as running water and sewer 

systems. Meeting these challenges can significantly increase development costs. 

For example, one Arizona tribe saw its costs double because materials had to be 

brought in by helicopter. Tribes also identified differing federal agency 

requirements, particularly for environmental reviews, as a challenge that delayed 

projects and increased costs when IHBG and other funds were combined. 

Further, tribes were concerned that recent changes in federally authorized 

training and technical assistance could reduce their quality and frequency, in part 

because of the reduced role of a longstanding provider. The most commonly 

identified internal challenges were recipients’ limited administrative capacity, 

conflicts within tribes that impact housing priorities and planning, and cultural 

preferences for certain types of housing. The Navajo Nation’s housing entity, the 

largest IHBG recipient, has experienced all of these challenges and had a 

backlog of nearly $500 million in unspent IHBG funds, which it has begun to 

address.

Opportunities exist to support tribes’ affordable housing efforts. First, a federal 

infrastructure task force focused on facilitating tribes’ water and wastewater 

projects has recommended that participating agencies, including Housing and 

Urban Development (HUD), develop a coordinated environmental review process 

to address the issue of inefficient and costly multiple reviews. A similarly 

coordinated process specific to tribal housing would help tribes to plan and build 

affordable housing more quickly and efficiently. Until such an effort is developed 

and implemented, tribes will continue to lose valuable time and spend IHBG 

resources completing overlapping reviews. Second, HUD instituted new training 

and technical assistance procedures according to revised language in the 

NAHASDA appropriation legislation, which changed the way that HUD makes 

funds available to provider organizations. HUD has solicited feedback from tribes 

that have received training and technical assistance under the new system, but 

opportunities remain to reach out to tribes that have not used the new system 

and remain concerned that their needs will not be met. Third, IHBG recipients 

could also benefit from having HUD disseminate promising approaches that other 

tribes have used to address housing challenges. In May 2013, HUD recognized 

22 tribes that were incorporating resource-efficient elements into their affordable 

housing projects. However, HUD has not shared promising housing practices 

more generally across tribes in a way that would make them easily accessible. 

Information about successful approaches could help tribes use their IHBG 

funding in the most efficient and effective ways to provide affordable housing in 

their communities.

View GAO-14-255. For more information, 

contact William Shear at (202) 512-8678 or 

shearw@gao.gov. 
Page i GAO-14-255 Native American Housing

Letter 1 

Background 4

Indian Tribes Face External and Internal Housing Challenges 10

Addressing Some Tribal Housing Challenges Would Require 

Fundamental Changes, but Other Opportunities Exist 28

Conclusions 33

Recommendations for Executive Action 34

Agency Comments and Our Evaluation 35

Appendix I Objectives, Scope, and Methodology 37

Appendix II Navajo Housing Authority Case Study 42

Appendix III Comments from the Department of Housing and Urban

Development 52

Appendix IV Comments from the Department of Health and Human Services 54

Appendix V GAO Contact and Staff Acknowledgments 56

Figures

Figure 1: Funding for Indian Housing from Fiscal Year 1993 to 

2013 and Key Native American Housing Assistance and 

Self-Determination Act of 1996 (NAHASDA) Program 

Legislative and Regulatory Changes from Implementation 

to Present 7

Figure 2: Two Ways into the Havasupai Tribe’s Village in a Side 

Canyon of the Grand Canyon, 8-Mile Trail or Helicopter 11

Figure 3: Examples of Traditional Indian Homes, Navajo Nation 

(left) and Hopi Tribe (right) 27

Figure 4: Housing in the Former Bennett Freeze Area, Arizona 39

Figure 5: Vandalized NHA Development in Shiprock, New Mexico 47

Contents
Page ii GAO-14-255 Native American Housing

Figure 6: Unoccupied Housing Units Awaiting Resolution of Land 

Ownership Issue, Navajo Reservation 48

Figure 7: Examples of Traditional Federally Funded Housing 

Developments, Navajo Reservation 49

Figure 8: Rendering of NHA Contractor’s Sustainable Community 

Concept 50

Figure 9: Recent NHA Housing Projects, Navajo Technical 

University Dormitory and Factory-Built House 51
Page iii GAO-14-255 Native American Housing

Abbreviations

 

BIA Bureau of Indian Affairs

CEQ Council on Environmental Quality

FEMA Federal Emergency Management Agency

HEARTH Act of 2012 Helping Expedite and Advance Responsible 

 Tribal Home Ownership Act of 2012

HHS Department of Health and Human Services

HUD Department of Housing and Urban 

 Development

IHBG Indian Housing Block Grant

IHS Indian Health Service

NAHASDA Native American Housing Assistance and 

Self-Determination Act of 1996 

NAIHC National American Indian Housing Council

NEPA National Environmental Policy Act of 1969 

NHA Navajo Housing Authority

ONAP Office of Native American Programs 

TDHE tribally designated housing entity

USDA U.S. Department of Agriculture

VA Department of Veterans Affairs

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

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Page 1 GAO-14-255 Native American Housing

441 G St. N.W.

Washington, DC 20548

March 27, 2014

The Honorable Patty Murray

Chairman

The Honorable Susan Collins

Ranking Member

Subcommittee on Transportation, Housing and Urban Development, and 

Related Agencies

Committee on Appropriations

United States Senate

The Honorable Tom Latham

Chairman

The Honorable Ed Pastor

Ranking Member

Subcommittee on Transportation, Housing and Urban Development, and 

Related Agencies

Committee on Appropriations

U.S. House of Representatives

Native American tribes primarily receive assistance for low-income 

housing through the Indian Housing Block Grant (IHBG) program under 

the Native American Housing Assistance and Self-Determination Act of 

1996 (NAHASDA) program. Tribes largely view NAHASDA and the IHBG, 

which has provided tribes on average about $667 million annually from 

1998 through 2013 (funding varied from $600 million to about $1.15 billion 

over this period), as a success because the program has given them the 

ability to identify and address the housing needs of their low-income 

members in a manner that recognizes tribal priorities and tribes’ unique 

government-to-government relationship with the United States. But 

housing activities on tribal lands, including those designed to provide 

affordable housing, involve overcoming a number of challenges. These 

include external factors such as the location and characteristics of tribal 

lands, which are frequently remote and lacking in infrastructure, such as 

water and sewer lines. Some challenges specifically affect tribes’ 

affordable housing activities, including issues related to requirements for 

federally funded housing projects, conflicts among tribal members with 

differing perspectives, and cultural preferences for certain types of 

housing.

We last reported on the IHBG program in February 2010 in response to 

the 2008 reauthorization of NAHASDA. That report looked at the 
 

Page 2 GAO-14-255 Native American Housing

program’s effectiveness in meeting the needs of tribes of various sizes, 

especially relatively small tribes and those receiving the smallest grants.1

Conference Report 112-284 requires that we study challenges associated 

with tribal housing activities, including those faced by tribes that are 

struggling to spend their funds in a timely manner.2

In conducting this work, we reviewed NAHASDA and its implementing 

regulations, studies, testimonies, prior GAO reports, and other relevant 

sources. We reviewed budget data from the Department of Housing and 

Urban Development (HUD), which administers NAHASDA through its 

Office of Native American Programs (ONAP), showing NAHASDA 

recipients’ annual IHBG allocations and expenditures through 2013. On 

the basis of our analysis of the funding data and explanations that HUD 

provided, we determined that the data were sufficiently reliable for the 

purposes of this report. We interviewed representatives of the National 

American Indian Housing Council (NAIHC), a nonprofit housing advocacy 

organization that represents American Indians, Alaska Natives, and 

Native Hawaiians. Our interviews included NAIHC executives and 

members of NAIHC’s board who served as housing officials for individual 

tribes and tribally designated housing entities (TDHE) participating in 

NAHASDA. We interviewed housing officials from 23 tribes or TDHEs 

participating in NAHASDA that we selected primarily on the basis of 

housing challenges identified by ONAP or the tribe or TDHE. We 

interviewed 21 of these recipients by telephone and made two site visits, 

one to the Navajo Nation’s reservation and one to the Hopi Tribe’s 

In this report, we 

examine (1) the kinds of challenges that Indian tribes have faced in 

administering housing activities under the IHBG program and (2) federal 

or tribal actions, if any, that could help to address these challenges.

 

1

GAO, Native American Housing: Tribes Generally View Block Grant Program as 

Effective, but Tracking of Infrastructure Plans and Investments Needs Improvement, 

GAO-10-326 (Washington, D.C.: Feb. 25, 2010). This report focused on tribes’ use of the 

IHBG program to address their communities’ affordable housing needs. In the report, we 

highlight the importance of HUD’s collecting information on tribes’ use of grant funds to 

develop housing-related infrastructure. HUD has taken actions to address our 

recommendations on helping tribes identify and address infrastructure deficiencies and 

report on addressing them. 

2

Conference Report 112-284 accompanied the Consolidated and Further Continuing 

Appropriations Act of 2012, Pub. L. No.112-55. 
 

Page 3 GAO-14-255 Native American Housing

reservation, in part because they are in close proximity to each other.3

In addition, we interviewed and obtained relevant documents from 

officials in ONAP. We contacted HUD staff with responsibility for an 

ongoing study on Indian tribes’ housing needs and interviewed officials at 

four other federal agencies whose programs targeted or served Indian 

tribes and their members.

The Navajo Nation’s TDHE, the Navajo Housing Authority, was the 

largest recipient of IHBG funds and was one of several recipients that had 

contributed to a large backlog of unexpended IHBG funds. The Hopi Tribe 

remains a highly traditional and independent tribe. 

4 In general, we asked HUD and other agency 

officials about housing challenges they had identified among Indian tribes. 

We used our prior work on NAHASDA and other sources to inform this 

effort.5

We conducted this performance audit from March 2013 to March 2014 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.

For example, we attended NAIHC’s 2013 convention, where 

representatives from NAIHC, tribes and TDHEs, and federal agencies 

provided perspectives on tribal housing. We considered input from the 

tribes, federal agencies, and other sources and existing knowledge. We 

analyzed this information to determine actions, if any, which could 

potentially address the challenges identified. See appendix I for a more 

detailed discussion of our scope and methodology.

 

3

ONAP regional offices identified tribes and TDHEs facing certain challenges and NAIHC 

helped with outreach to tribes and TDHEs that self-identified challenges. The nonrepresentative sample of 23 recipients included tribes and TDHEs from HUD’s six ONAP 

regions that varied in size and amount of annual NAHASDA grant funding. 

4

These agencies included the U.S. Department of Agriculture (USDA) Rural Development, 

Bureau of Indian Affairs (BIA) within the Department of the Interior, Indian Health Service 

(IHS) within the Department of Health and Human Services, and the Department of 

Veterans Affairs (VA). We met with VA officials to discuss the department’s efforts to 

increase access for Native American veterans to assistance under VA’s home loan and 

housing programs.

5

See GAO-10-326. 
 

Page 4 GAO-14-255 Native American Housing

Historically, Native Americans in the United States have faced worse 

housing conditions than other socioeconomic groups. Native Americans 

disproportionately experience socioeconomic challenges, including high 

unemployment and extreme poverty that impact housing conditions on 

Indian reservations and in other Indian areas. The U.S. Census Bureau 

reported in 2013 that American Indians and Alaska Natives were almost 

twice as likely to live in poverty as the rest of the population—27 percent 

compared with 14.3 percent.6 Over 40 percent of Native Americans in 

North Dakota and South Dakota live below the poverty line, and in seven 

other states (Arizona, Maine, Minnesota, Montana, Nebraska, New 

Mexico, and Utah) Native American poverty rates are about 30 percent or 

more. In addition, overcrowding, substandard housing, and homelessness 

are far more common in Native American communities. For example, a 

Housing Assistance Council analysis of 2010 U.S. Census and 2005-

2009 American Community Survey data found that 5.3 percent of homes 

on Native American lands lacked complete plumbing and 4.8 percent 

lacked complete kitchens. The comparable nationwide figures were 0.5 

and 0.7 percent, respectively.7 The Housing Assistance Council also 

noted that household crowding in rural areas, such as most Native 

American communities, tended to be invisible, with households moving in 

with relatives or friends in reaction to adverse economic or social 

conditions or to escape substandard housing conditions. HUD officials 

noted that such “doubling up” and subsequent overcrowding in Native 

American communities was often tied to a tradition of extended family 

dwellings and made it difficult to quantify homelessness in Native 

American communities. 8

 

6

The terms Native American and Indian generally refer to American Indians and Alaska 

Natives. In this report, we use Native American and Indian interchangeably. 

7

Housing Assistance Council, Housing on Native American Lands (Washington, D.C.: 

September 2013). The Housing Assistance Council is a nonprofit corporation that 

supports the development of rural low-income housing. HUD contributed to the funding for 

this study. 

8

HUD officials told us that individuals living with family members in overcrowded 

conditions were considered to be at risk for homelessness rather than homeless. The 

officials added that this status prevented these individuals from qualifying for most 

homeless programs. 

Background

Native Americans’

Housing Needs
 

Page 5 GAO-14-255 Native American Housing

The U.S. government’s relationship with Native American tribes has 

historically been troubled, making it difficult to address the needs of lowincome Native Americans. Since 1961, the government has sought to 

address the need for safe, decent, and affordable housing for Native 

Americans by allowing tribes access to several housing programs, 

including those authorized under the U.S. Housing Act of 1937 (1937 Act) 

and administered by HUD.9 In October 1996, Congress created a housing 

program for Native Americans that recognized the tribes’ right to selfdetermination and self-governance (see fig. 1). NAHASDA reorganized 

the system of housing assistance that HUD provided to Native Americans 

by eliminating or incorporating several separate programs into a single 

block grant program—known as the IHBG program—and created the Title 

VI Loan Guarantee (Title VI) program to assist grant recipients with 

private market financing.

10

Size, operation, and land jurisdictional authority vary among Indian tribes. 

As of December 2013, there were more than 300 reservations in the 

lower 48 states and 1 in Alaska. Tribes sometimes lack clearly defined 

land areas, however, and may have more than one reservation or share a 

reservation with another tribe.

As figure 1 indicates, NAHASDA was first 

funded in fiscal year 1998. Today, 566 federally recognized and 5 staterecognized Indian tribes with membership levels ranging from a few 

hundred to a few hundred thousand are eligible to receive IHBG funds 

annually to provide their members with adequate and affordable housing.

11

 

9

The 1937 Act, as amended, created programs to provide decent, safe, and sanitary 

housing for low-income families. Native American housing entities did not receive federal 

housing funds under the 1937 Act until 1961. 

The remaining more than 200 Indian 

tribes do not have reservations or other lands. For example, the majority 

of Alaska’s more than 200 federally recognized tribes—the largest 

10Title VI of NAHASDA enables HUD to provide a 95-percent loan guarantee to private 

lenders or investors that make loans to NAHASDA grant recipients to develop housing 

and community facilities. A Title VI loan is secured by a recipient’s pledge of its current 

and future IHBG funds. 

11A federal Indian reservation constitutes land that has been reserved for a tribe or tribes 

under treaty or other agreement with the United States, executive order, or federal statute 

or administrative action as a permanent tribal homeland. 

Federal Role in Native 

American Housing 

Assistance
 

Page 6 GAO-14-255 Native American Housing

number in any U.S. state—reside in rural villages.12 According to the 2010 

Census, of the 2.4 million people in the United States who reported their 

sole race as American Indian or Alaska Native, 23 percent lived on Native 

American lands.13

 

12In December 1971 the Alaska Native Claims Settlement Act was enacted to resolve 

longstanding aboriginal land claims and foster economic development for Alaska Natives. 

Among other objectives, the act was intended to conform with the economic and social 

needs of Alaska Natives without creating a reservation system. Pub. L. No. 92-203, 85 

Stat. 688 (1971), codified as amended at 43 U.S.C. §§ 1601-1629h. 

NAHASDA allows tribes to serve members of other 

tribes residing within their service area.

13According to HUD, single-race population figures significantly underreport the number of 

American Indians and Alaska Natives in the United States because these counts exclude 

persons who are Native American and another race and identify as such. 
 

Page 7 GAO-14-255 Native American Housing

Figure 1: Funding for Indian Housing from Fiscal Year 1993 to 2013 and Key Native American Housing Assistance and SelfDetermination Act of 1996 (NAHASDA) Program Legislative and Regulatory Changes from Implementation to Present

a

Includes supplemental funding under the American Recovery and Reinvestment Act of 

2009.

Funding levels include rescissions.
 

Page 8 GAO-14-255 Native American Housing

The IHBG program, authorized under NAHASDA, is a formula grant 

program that provides funding for affordable housing activities to Native 

American tribes or TDHEs. With the enactment of NAHASDA, federally 

recognized Indian tribes or their TDHEs and a limited number of staterecognized tribes that were funded under the 1937 Act became eligible 

for the IHBG program. Tribes may choose to receive housing funds 

directly or may designate a TDHE to administer the housing program on 

their behalf.14 Families eligible for NAHASDA-funded assistance must be 

low-income Indian families—those whose income does not exceed 80 

percent of the area median income—residing on a reservation or in an 

Indian area.15

The amount of IHBG funding that Indian tribes receive is based on an 

allocation formula that has two components: (1) the costs of operating 

and modernizing pre-NAHASDA, HUD-funded units and (2) the need to 

provide new affordable housing. Need is based on seven factors that 

include the grant recipient’s American Indian/Alaska Native population 

and the number of households within that population that fall in certain 

low-income categories. Allocation amounts are adjusted for local 

construction costs and rents. Because population impacts all need factors 

in the IHBG allocation, larger recipients (larger tribes operating their own 

housing programs or the TDHEs representing those tribes) receive larger 

allocations. Recipients that own and operate pre-NAHASDA housing units 

and that have existing housing needs receive both portions of the IHBG, 

while those without such units receive only the need portion.

In creating NAHASDA, Congress recognized Indian tribes’ right to selfdetermination and self-governance through (1) negotiated rulemaking, (2) 

direct funding (to the tribes or their designated entities), and (3) authority 

to determine the details of their housing programs. Negotiated rulemaking 

takes place when an agency that is considering drafting a rule brings 

 

14A TDHE is either (1) a former Indian Housing Authority that managed Native American 

housing programs under the 1937 Act that continued operations to meet the requirements 

of NAHASDA or (2) a new nontribal government entity authorized by one or more tribes to

receive grants and provide affordable housing assistance for Native Americans under 

NAHASDA. 

15Under specific circumstances, Indian and non-Indian families that are not low income 

and that reside on a reservation or in an Indian area are also eligible to receive 

assistance. 

Indian Housing Block 

Grant Program

Self-Determination

for Indian Tribes
 

Page 9 GAO-14-255 Native American Housing

together agency representatives and affected parties for consultations. In 

accordance with Section 106 of NAHASDA, HUD developed the 

regulations with active tribal participation, using the procedures of the 

Negotiated Rulemaking Act of 1990, as amended.16 ONAP consults with 

tribes on various matters, and in conducting past work on NAHASDA, we 

learned that a primary reason for recipients’ positive views of the program 

was its recognition of self-determination.17

Under NAHASDA, tribes are able to determine (1) whom they serve (for 

example, giving preference to members of the participating tribe); (2) the 

types of eligible activities they offer; and (3) the method of delivering their 

programs and projects. Those programs and projects must fall under one 

of several eligible activities, including:

1. Indian housing assistance (i.e. modernization or operating assistance 

for 1937 Act units);

2. housing development, including the acquisition, new construction, and 

reconstruction or rehabilitation of affordable housing;

3. housing services, such as housing counseling and assistance to 

owners, tenants, and contractors involved in eligible housing activities;

4. housing management services for affordable housing, including loan 

processing, inspections, and tenant selection;

5. crime prevention and safety;

6. model activities that provide creative approaches to solving affordable 

housing problems; and

7. reserve accounts for administrative and planning activities related to 

affordable housing.

 

165 U.S.C. 561-570a.

17See GAO-10-326. For this review, we interviewed 12 NAHASDA recipients (two in each 

of HUD’s six ONAP regions) and surveyed all tribes and TDHEs that received a grant in 

fiscal year 2008, obtaining a 66 percent response rate. 
 

Page 10 GAO-14-255 Native American Housing

We used a number of sources to identify common housing challenges 

that tribes were facing, including our interviews with NAIHC executives, 

tribal housing officials on NAIHC’s board and at the 23 selected tribes and 

TDHEs, HUD and other agency officials, and our prior work on 

NAHASDA.18 Those challenges were largely related to remoteness and 

other geographical factors, land use regulations, lack of adequate 

infrastructure, differing federal agency requirements, potential reduction in 

training opportunities and program support, limited administrative 

capacity, conflict within tribes, and cultural factors. Some IHBG recipients, 

such as the Navajo Housing Authority (NHA), faced a combination of 

these challenges (see app. II).

Many of the tribal housing officials we interviewed told us that tribes’ 

remote locations or lack of adequate infrastructure to support housing led 

to higher development costs. For example, officials from a Utah tribe 

explained that there was no airport service to the area and that driving to 

a nearby town for needed materials required at least a 60-mile trip each 

way, mostly on maintained but rugged dirt roads. The officials said that 

purchasing major housing construction supplies from other areas, some 

of them a few hours away, drove delivery costs up to as much as $1,000 

per trip, in addition to the cost of the materials.

The remoteness of some Indian reservations and other tribal lands has 

contributed to poor socioeconomic conditions that underscore the need 

for affordable housing. Limited economic activity in tribal areas can hinder 

the potential of tribal members to find gainful employment and earn 

livable wages that would allow them to rent or purchase market-rate 

housing. A representative of a nonprofit that had partnered with NHA to 

provide financial and homebuyer education pointed out that having an 

economy that was dependent on tribal enterprise stifled the potential of 

tribes to grow through entrepreneurship and other means. 

 

18We used a standard set of questions to interview housing officials at tribes and TDHEs 

to ensure that we consistently captured their views. With a few exceptions, the 23 

recipients we interviewed responded to all of our questions. To categorize tribal housing 

officials’ views throughout this report, we defined modifiers to quantify the housing 

officials’ views. For example, “most” represents 15 to 19 housing officials, “many” 

represents 10 to 14 housing officials, “several” represents 8 to 9 housing officials, and “a 

few” represents 2 to 4 housing officials. 

Indian Tribes Face 

External and Internal 

Housing Challenges

External Challenges

Remoteness and Other 

Geographical Factors
 

Page 11 GAO-14-255 Native American Housing

Some remote areas where tribal lands are located can present unique 

logistical challenges, including a lack of buildable land and infrastructure. 

For example, the housing coordinator of an Arizona tribe whose 

reservation is located along the Grand Canyon in an area vulnerable to 

floods explained that having a limited amount of land that could be 

developed had led to overcrowding in the tribe’s village. According to the 

housing official, the tribe had about 700 enrolled members, 500 of whom 

lived at the base of the canyon in 112 housing units. In lieu of 

development, the housing department had focused on rehabilitating 

members’ homes, some of which were 40 and 50 years old. However, 

these projects had to factor in the cost of having construction materials 

dropped by helicopter into the canyon where the village was located. The 

housing official told us that these deliveries could add $30,000 to the cost 

of a typical $20,000 rehabilitation project (see fig. 2).

Figure 2: Two Ways into the Havasupai Tribe’s Village in a Side Canyon of the Grand Canyon, 8-Mile Trail or Helicopter

At another tribe in Washington state, the housing director told us that the 

tribe had a moratorium on expanding water use on the reservation except 

to serve new development. However, buildable land in the tribe’s main 

residential area was lacking, pushing new development into remote 

timberland where expensive infrastructure, such as running water and 
 

Page 12 GAO-14-255 Native American Housing

utilities, would need to be developed. Further, she stated that it was 

difficult to recruit qualified and affordable contractors because of the 

limited housing activity in the area. According to the official, the housing 

department’s waiting list has had hundreds of names on it since the 

1970s because of the lack of land that can be developed and the cost of 

providing infrastructure.

In some regions, tribes faced challenges related to both remoteness and 

lack of adequate infrastructure, such as roads and water and sewer 

systems. For example, officials from a Nevada tribe told us that the tribe’s 

land base was undeveloped, requiring them to invest resources to put 

infrastructure in place before building homes for tribal members. 

According to the officials, sewer pipes in one of the tribe’s communities 

were failing and in need of upgrades. They said that another community 

had significant bedrock that likely would require blasting before 

infrastructure could be added to the area and that the nearest main road 

was 5 miles away. The housing director for a North Dakota tribe told us 

that the tribe would need to build new sewer facilities and add on to the 

existing water systems to support additional development.

In our past work on Native American housing, we highlighted the 

importance of tribes’ ensuring that housing was supported by adequate 

sanitation facilities such as running water and sewer systems.19

Housing officials from all of the seven Alaska recipients we spoke with 

told us that they paid expensive transportation, fuel, or labor charges 

because of their remote locations and cold climate. Three housing 

officials also described their villages’ inadequate infrastructure. One 

housing director told us that construction costs were significantly 

impacted by the area’s remoteness and long and severely cold winters, 

when temperatures could reach 70 below. He said that high fuel costs 

impacted charges for freight and subsequently for lumber and other 

building materials. He observed that winters had been lasting longer and 

During 

our current review, it was apparent that some of the housing officials we 

met with were focused on providing homes with access to adequate 

infrastructure. More specifically, some housing officials indicated that they 

did not intend to start housing construction without first having basic 

infrastructure systems in place to support the homes.

 

19See GAO-10-326. 

Lack of Adequate 

Infrastructure
 

Page 13 GAO-14-255 Native American Housing

that weather had been less predictable in recent years. Similarly, another 

housing director stated that, on average, there were 230 days out of the 

year when temperatures fell below freezing, limiting outdoor construction 

to only 3 or 4 months. A third housing official explained that construction 

costs were already high for properties with existing infrastructure and that 

building infrastructure on an undeveloped property—that is, properties 

lacking basic amenities such as roads and running water—could add $1 

million to the costs. He said that because his TDHE received just over $1 

million annually from the IHBG, such a project would require that grant 

funds be accumulated over several years. 

One of the Alaska housing officials we interviewed expressed frustration 

that federal officials in Washington, D.C. generally did not understand the 

realities of construction in remote areas of Alaska and were skeptical of 

the region’s high construction costs. He explained that his construction 

materials were delivered by barge and that he needed to place orders for 

materials 2 to 3 months in advance. Missing the barge meant flying 

materials in at a higher cost. He noted that, with one exception, all of the 

villages served by his TDHE lacked connecting roads, and several 

villages lacked running water and sewer facilities.

Having a land base is essential for tribal economic development activities, 

including agricultural, energy-related, and housing activities. Since the 

late 1800s, Indian lands have diminished significantly, in large part 

because of federal policy.20

 

20Congress enacted the General Allotment Act of 1887, which divided some reservation 

lands among individual Indian tribal members, with other lands sold as surplus. The 

resulting individual allotments made to tribal members are commonly referred to as 

“individual Indian trust lands” or “individual allotted lands”. Many Indian lands were 

dramatically reduced through various transactions in subsequent years and during the 

allotment period from 1887 to 1934, American Indian land holdings in the lower 48 states 

decreased from 138 million acres to 48 million acres, leaving many reservation Indians in 

poverty. The Indian Reorganization Act of 1934 halted further allotment of tribal lands. 

Today, under this and other legislation, tribal governments are working to consolidate or 

rebuild their tribal land base. 

The Indian Reorganization Act of 1934 

changed the government’s Indian policy to encourage tribal selfgovernance, and Section 5 of the act provided the Secretary of the 

Interior with discretionary authority to take land in trust on behalf of tribes 

or their members. Under the Bureau of Indian Affairs’ (BIA) trust 

regulations, tribes or tribal members who purchase or own property on 

which they pay property taxes can submit a written request to the 

Land Use Regulations
 

Page 14 GAO-14-255 Native American Housing

Secretary of the Interior to have the land taken in trust. If approved, the 

ownership status of the property is converted from taxable status to 

nontaxable Indian trust status. In addition, tribes or their members 

seeking to lease land that is held in trust status to pursue residential, 

commercial, or energy activities on the land must receive approval from 

BIA. 

However, in a 2006 report, we found that BIA did not have deadlines for 

making decisions on land in trust applications, and in 2010 we found that 

lease approval decisions could take several years.21 BIA officials told us 

that every land trust transaction was unique and that localities with 

jurisdiction over the land—such as counties and townships—often 

scrutinized and opposed the transactions. ONAP officials also stated that 

the process of applying to BIA to have land taken into trust could be 

complicated and contentious and that there was no guarantee of 

approval. They agreed with BIA that localities often scrutinized and 

opposed the transactions because of concerns about how tribes would 

use the converted land. We later found that the often complicated 

ownership status of Indian trust lands was partly the reason that BIA often 

takes several years to process lease approvals for land parcels identified 

for development.

22

 

21See Indian Issues: BIA’s Efforts to Impose Time Frames and Collect Better Data Should 

Improve the Processing of Land in Trust Applications,

For example, a land parcel may be held in trust for 

multiple descendents of the tribal member to whom the land was 

originally allotted. When the allottee dies, the allotment passes to the 

heirs. Ownership of some allotted land has been divided among 

generations of heirs, so that large numbers of individuals hold interest in 

the land. In some cases, such “fractionated lands” have up to several 

hundred ownership interests that have different ideas about how the land 

GAO-06-781 (Washington, D.C: 

July 28, 2006) and GAO-10-326. BIA’s process for reviewing land in trust applications 

includes notifying affected state and local governments and providing a 30-day comment 

period for them to submit information on potential tax and jurisdictional impacts. 

22See GAO, Flood Insurance: Participation of Indian Tribes in Federal and Private 

Programs, GAO-13-226 (Washington, D.C.: Jan. 4, 2013). 
 

Page 15 GAO-14-255 Native American Housing

should be used.23

The legal restrictions associated with trust lands have acted as an 

impediment to individuals seeking a mortgage and to lending institutions 

that might otherwise promote homeownership to Indian tribes—a 

challenge that affects both market-rate and affordable housing. In a 

February 2010 report, we found that banks were reluctant to do business 

on tribal lands because of cumbersome procedures, such as BIA’s 

process of issuing land title or trust status reports for mortgages involving 

trust lands.

In addition, BIA officials explained that actions on trust 

lands were subject to requirements such as environmental reviews that 

added to BIA’s processing time. The officials said that because of the 

federal government’s fiduciary trust in managing these lands, BIA took a 

conservative approach to managing them.

24 BIA acknowledged these limitations recently in developing 

new policies for lease transactions, noting that the regulations were 

outdated and unworkable in the current economy and hindered 

homeownership and economic development on tribal lands. In January 

2013, BIA began implementing new policies for several of its land leasing 

procedures that were intended to expedite approvals—for example, 

establishing separate, simplified processes for different types of leases 

and adding time limits for BIA to issue decisions.25

 

23To consolidate ownership of highly fractionated trust lands, in 2012 the Department of 

the Interior created a land buy-back program for tribal nations to implement the land 

consolidation component of the Cobell v. Salazar settlement. This settlement resulted 

from a class action lawsuit regarding the U.S. government’s trust management of more 

than 300,000 individual American Indian trust accounts. The settlement provided for a 

$1.9 billion fund to be established for the Interior Department to purchase and consolidate 

fractionated interests in trust or restricted land. Consolidated parcels will be transferred to 

tribal governments for uses benefiting the tribes. The settlement was confirmed by the 

Claims Resolution Act of 2010, Pub. L. 2010, Pub. L. 111-291, § 101(c).

For example, BIA must 

now provide decisions on residential leases and subleases within 30 

days. The practicability of these changes and their impact on housing 

development have not yet been determined. In addition to BIA’s new 

regulations, in 2012 Congress enacted the Helping Expedite and 

24See GAO-10-326. Most private landholders in the United States hold title to their land in 

fee simple status—that is, they own the land outright, with no restrictions, and may 

mortgage or sell it on their own initiative. Modern real estate transactions have become 

dependent on land as collateral and the free transfer of title between parties. NAHASDA 

funds can be used to provide eligible tribal members with down payment assistance to 

purchase a home.

2577 Fed. Reg. 72440 (December 5, 2012).
 

Page 16 GAO-14-255 Native American Housing

Advance Responsible Tribal Home Ownership (HEARTH) Act. The 

HEARTH Act of 2012 includes a provision that allows tribes to lease 

restricted lands for public, religious, educational, residential, or business 

purposes without BIA’s prior approval. Its goal is to help expedite the 

land-lease process for tribes.

26

USDA officials serving as Native American coordinators in several states 

agreed that lenders had limited interest in providing mortgages on trust 

lands using a USDA single-family housing loan guarantee program, even 

when tribal members sought them. For example, they said that it was 

difficult to persuade lenders to participate in the program, in part because 

it is limited to a 90-percent guarantee on all mortgages, including for 

homes on trust lands. In contrast, HUD’s Section 184 Loan Guarantee 

program provides a 100-percent guarantee.27

Several recipients seeking to combine funding for their housing projects 

said that differing federal agency requirements, particularly mandatory 

environmental review requirements, posed a significant challenge. Among 

the tribes and TDHEs we interviewed for this review, some told us that 

having to follow different requirements for federal agencies was 

burdensome and costly. In our past NAHASDA work, which included 

surveying all tribes and TDHEs that received grant funds in fiscal year 

2008, 68 percent of respondents cited incompatible federal funding 

programs or lack of coordination among agencies, including the 

environmental review process, as a hindrance to leveraging multiple 

programs.

The Section 184 program 

was one of several legislative actions Congress took to spur the lending 

market on Indian lands.

28

 

26The HEARTH Act of 2012, Pub. L. 112-55, authorizes federally recognized tribes to 

develop and implement their own regulations governing certain leasing on Indian lands. 

Upon approval of these regulations by the Secretary of the Interior, tribes have the 

authority to process land leases without BIA approval. 

Several of the housing officials whom we interviewed for this 

study also cited environmental reviews as a primary area in which 

27The goal of the Section 184 Loan Guarantee program, which was created by the 

Housing and Community Development Act of 1992, is to provide homeownership 

opportunities to Native Americans living on trust or restricted lands or land located in an 

Indian or Alaska Native area. Eligible borrowers include Indian and Alaska Native families, 

Alaska Native Villages, TDHEs, Indian housing authorities, and tribes. 

28See GAO-10-326. 

Differing Federal 

Environmental Reviews

and Other Requirements
 

Page 17 GAO-14-255 Native American Housing

differing federal agency requirements delayed housing development or 

increased the associated costs.

NAHASDA regulations state that the environmental effects of activities 

carried out with assistance from the program must be evaluated in 

accordance with the National Environmental Policy Act of 1969 (NEPA), 

as amended (42 U.S.C. §§ 4321-4347) and related authorities. Under 

NEPA, agencies evaluate the likely environmental effects of projects they 

are proposing using an environmental assessment or, if the project is 

more likely to significantly affect the environment, a more detailed 

environmental impact statement. Under NAHASDA regulations, an Indian 

tribe may choose to assume environmental review responsibilities.29 In 

addition, when tribes combine IHBG and other federal funds on a 

project—something NAHASDA allows—they must follow each agency’s 

separate requirements.30

For example, housing officials from one TDHE told us that environmental 

reviews could cost between $2,000 and $4,000 for each agency involved. 

They observed that various agencies that assisted tribes, including 

USDA, BIA, Department of Energy, HUD, IHS, and the U.S. Department 

of the Treasury (for low-income housing tax credits) had different 

environmental review requirements. The officials said that they 

considered the multiple reviews to be a communication and coordination 

deficiency among the agencies and that it would be helpful for the 

agencies to recognize a single review process. The housing director for 

another TDHE told us that his TDHE had used funds from USDA, the 

Economic Development Administration, HUD, and local sources on a 

project and had completed four separate environmental reviews that took 

approximately 2 years. Although IHBG recipients can use their grant 

funds to cover the cost of environmental reviews, paying for multiple 

reviews can pose a financial obstacle, particularly for recipients with fewer 

 

29Should a tribe decline to accept the responsibilities, HUD will perform the environmental 

review. In general, a HUD environmental review must be completed for any NAHASDAassisted activity before a recipient may acquire, rehabilitate, convert, lease, repair, or 

construct property. Should a tribe assume environmental review responsibilities, no funds 

may be committed to a grant activity before the tribe’s completion of the environmental 

review, HUD’s approval of the request for release of funds, and certification by a certifying 

officer of the tribe that the tribe, among other things, has fully carried out its environmental 

review responsibilities.

30While this practice, known as leveraging, provides recipients with additional funding to 

meet their housing needs, it can also trigger a complicated and costly exercise for them. 
 

Page 18 GAO-14-255 Native American Housing

resources, and reduces the funding available for housing activities. 

Federal agency officials told us that the cost of environmental reviews 

varied on a case-by-case basis. For example, an IHS official explained 

that each review could range from an estimated 1 to 30 percent of the 

total project cost. According to BIA, an assessment of broad 

environmental effects for subdivisions and larger multifamily projects 

could range from $4,000 to $50,000, while a survey to identify hazardous 

chemical deposits on land chosen for development could range from 

$1,000 to $10,000. HUD did not provide cost estimates but said that the 

agency followed the Council on Environmental Quality’s (CEQ) 

regulations in allowing tribes that were the responsible entities for 

environmental reviews to adopt other agencies’ environmental reviews.31

A few housing officials explained that the current funding environment 

made it difficult to develop a housing project without going to several 

sources and that the agencies’ different standards were a hindrance to 

their housing efforts. For example, one housing director told us that in 

addition to conducting separate environmental reviews for HUD and the 

Department of Energy, his TDHE had difficulty with differing qualifications 

for federal agencies’ rural programs. He cited inconsistencies among 

federal programs’ definitions of rural areas, noting that some agencies 

used only population data, while others incorporated additional factors.

HUD also said that it encouraged cooperating agency agreements when 

multiple federal funding agencies were involved specifically to avoid 

having multiple reviews for the same project.

32

 

31CEQ is part of the Executive Office of the President and coordinates federal 

environmental efforts, working closely with agencies and with offices within the White 

House to develop environmental policies and initiatives. 

Another housing director said that his TDHE had tried to rehabilitate older 

buildings that had formerly been controlled by the federal government and 

had found several structural hazards, including dilapidated roofs and lead 

paint. In attempting to make the buildings usable, the TDHE sought 

assistance from HUD and the Environmental Protection Agency and 

faced different requirements for lead paint remediation. Because the 

32See GAO, Rural Housing: Changing the Definition of Rural Could Improve Eligibility 

Determinations, GAO-05-110 (Washington, D.C.: Dec. 3, 2004). In this report, we 

suggested that Congress consider taking certain actions that could improve consistency in 

defining communities’ eligibility for Rural Housing Service programs. A related USDA

report that primarily focused on programs authorized through the Farm Bill—non-housing 

programs—has as one of its key recommendations using a population limit of 50,000 for 

all non-housing programs targeted to rural businesses and communities. 
 

Page 19 GAO-14-255 Native American Housing

TDHE considered HUD’s requirements to be cost prohibitive, remediation 

efforts stalled, and the project was abandoned.

In addition to ongoing external challenges, several housing officials were 

concerned about changes in the delivery of training and technical 

assistance they received under the IHBG program. As part of their 

participation in the program, tribes and TDHEs benefit from training and 

technical assistance opportunities facilitated by ONAP. Training topics 

may include, among other things, NAHASDA policies and procedures, 

housing development basics, procurement, leveraged financing, and 

partnerships and resources. Technical assistance provides recipients with 

a more hands-on experience to help them build administrative capacity. 

Some housing officials told us that training for their staff was essential. 

For example, one housing official emphasized that such training 

contributed to the long-term success of tribal housing organizations. 

Another housing official indicated that frequent political changes within 

tribes caused housing entities to lose qualified personnel, requiring that 

new staff be trained quickly. Similarly, two officials said that tribal housing 

boards and councils could benefit from training tailored to assist them in 

mitigating conflicts between tribes and their housing entities.

Some housing officials were skeptical about changes that reduced 

NAIHC’s role in delivering training and technical assistance. Until fiscal 

year 2012, Congress appropriated approximately $2 million to $3.5 million 

annually as part of a set-aside in the NAHASDA appropriation to NAIHC, 

which served as the primary provider of external training and technical 

assistance to IHBG recipients. ONAP also provided some training and 

technical assistance directly and some through contractors, but several 

tribal housing officials found ONAP’s training to be more specific to 

NAHASDA and less tailored to their individual needs. In fiscal year 2012, 

Congress stopped appropriating the set-aside to NAIHC and directed 

HUD to provide grants on a competitive basis to national and regional 

organizations.33

 

33NAHASDA authorized funds to be appropriated annually through 2012 to “a national 

organization representing Native American housing interests to provide training and 

technical assistance to tribal housing entities.” However, starting in fiscal year 2012, 

Congress changed its appropriation language, and HUD officials told us that they changed 

the way training and technical assistance funds were awarded on the basis of the new 

language. 

HUD awarded eight organizations, including NAIHC, 

training and technical assistance grants under cooperative agreements in 

Potential Reduction in 

Training Opportunities 

and Program Support
 

Page 20 GAO-14-255 Native American Housing

2012. NAIHC did not receive a training and technical assistance award for 

2013. According to ONAP officials, NAIHC attempted to apply for a 2013 

award but missed the deadline for consideration. The organizations that 

enter into cooperative agreements with HUD to provide training and 

technical assistance become part of a cadre of providers that HUD calls 

on to fulfill requests from IHBG recipients.

Some housing officials told us that when NAIHC was the primary provider 

they could request training and technical assistance directly from NAIHC. 

For example, the housing officials said that the prior procedures allowed 

them to contact NAIHC and request an individual trainer whom they 

recognized as having expertise in the area in which they needed 

assistance. With that input, NAIHC made a determination on the type of 

training that would be provided at a particular location. NAIHC’s 

leadership told us that the organization’s approach was to identify an 

expert in a given area and send that person where the assistance was 

needed. Under HUD’s new procedures, some housing officials told us 

that waiting for regional ONAP staff to schedule training could delay 

training. One official said that she often received notifications about 

training that ONAP was offering in her region but was not given enough 

lead time to take advantage of these opportunities. For example, she 

explained that she received the information about 2 weeks in advance 

and thus did not have time to obtain approval to attend from the tribe or to 

make appropriate travel arrangements without paying prohibitively high 

costs. Yet another housing official noted that tribes’ training and technical 

assistance needs varied within regions and suggested that a more handson approach from ONAP and other providers could help identify 

recipients’ needs. According to HUD, under the new procedures, tribes 

and TDHEs submit a request for training or technical assistance through 

their regional ONAP offices or directly to headquarters. Once HUD 

headquarters staff approve the request, the tribes coordinate with the 

relevant training provider. 

Officials at one TDHE said that under HUD’s new system, the tribes 

would have no control over who provided the training or technical 

assistance, when it would be offered, or whether ONAP headquarters 

would even agree that it was necessary. The housing officials said that 

ONAP responded to their training request by offering to deliver the 

training on-site within 6 months but later postponed the session because 

of insufficient travel funds. The housing officials told us that they had 

wanted to have new staff trained on HUD’s Section 184 program, which 

could be used along with the IHBG program, but said that they had so far 

been unable to get the needed training. ONAP officials stated that ONAP 
 

Page 21 GAO-14-255 Native American Housing

had not yet declined a training request under the current procedures but 

noted that scheduling and finding the right trainers had been challenging. 

In terms of external providers, ONAP officials said that the new approach 

was intended to be more streamlined than the federal procurement 

system in identifying training and technical assistance providers. They 

explained that ONAP was creating a database of trainers and subjectmatter experts that they expected would expedite the process of 

identifying the right provider to fulfill each request. Regarding the TDHE’s 

example of requesting training on the Section 184 program, ONAP 

officials said that this involved a misunderstanding. The TDHE had 

understood that training for non-NAHASDA programs could be requested 

as part of NAHASDA training and technical assistance procedures, but in 

fact training for other programs was paid for with a separate set of funds.

A few tribal housing officials expected that the on-site technical 

assistance that NAIHC had provided to individual tribes and TDHEs upon 

request would be available less often under the new procedures. A 

number of tribal housing officials also said that they had previously relied 

on training scholarships from NAIHC to attend national training events. 

NAIHC used funds from its annual appropriation to provide scholarships 

for Indian housing staff that covered tuition, if applicable, and travel costs. 

NAIHC expected that it would be offering fewer scholarships under the 

new system because it would no longer be the primary provider of 

external training and technical assistance to IHBG recipients.34

 

34Because NAIHC offered training scholarships that were paid for using NAHASDA setaside funds, NAIHC did not expect to continue the scholarships as prior set-aside funds 

were exhausted. 

Some

housing officials told us that without this support, recipients with limited 

resources would have fewer opportunities to send housing staff to training 

events, such as national events that one official pointed out allowed tribes

to network with and learn from each other. These recipients’ concerns 

largely stemmed from their experience with NAIHC. For example, a few 

said that the organization’s knowledge of tribes and their unique 

circumstances resulted in training and technical assistance that was 

relevant and practical for their needs. ONAP officials indicated that under 

the new procedures, tribes and TDHEs would have more opportunities for 

regional training events that were located closer to them than national 

events. In addition, they stated that tribes and TDHEs would still be able 

to request the technical assistance they needed and have it delivered by 

a knowledgeable provider on-site. ONAP officials also said that technical 
 

Page 22 GAO-14-255 Native American Housing

assistance requests were being developed jointly with the tribes, along 

with a work plan for the provider. The officials explained that several onsite visits were scheduled to allow sufficient time for the tribe to receive 

hands-on services and that there were ongoing remote communications 

to allow for any needed follow-up.

Generally, ONAP officials said that they believed the housing officials’ 

views about future training and technical opportunities were largely based 

on past experiences with ONAP that required tribes and TDHEs to wait 

for HUD to contract with training and technical assistance providers. The

ONAP officials acknowledged that there were inherent delays in obtaining 

HUD-contracted assistance with the old training and technical assistance 

procedures in place before 2012, in part because of the steps the federal 

procurement process required, and said that the new procedures using 

cooperative agreements were intended to allow for more selfdetermination. For example, they said that the goal was to offer tribes and 

TDHEs training that was more specific to their needs than prior offerings.

Many of the IHBG recipients we contacted described having positive 

relationships with their regional ONAP offices. For example, several 

housing directors in Alaska gave examples of the support they received 

from the regional office. Two of the housing officials said that they could 

rely on Alaska ONAP staff to help them interpret program policy and 

directives that they received from ONAP headquarters. Another housing 

official said that she was comfortable asking Alaska ONAP staff for 

informal feedback on draft housing plans, particularly when the TDHE 

was undertaking a new housing program or activity. But a few recipients 

also expressed concerns. Those recipients said that ONAP did not notify 

them about changes in regional staff, that key ONAP staff whom they 

relied on to handle inquiries were not responsive, and that new staff did

not provide them with adequate guidance. For example, one housing 

official said that ONAP routinely advised tribal housing staff to consult the 

program guidance instead of providing a definitive response to questions 

or helping to interpret it. Some tribal housing officials agreed that 

insufficient support from and partnerships with the regional ONAP offices 

could contribute to a recipient’s administrative challenges. They also said 

that the lack of a strong relationship with the regional ONAP office could 

result in the type of inactivity that had caused some recipients to fall 

behind the timeline for using their grant funds and thus to miss 

opportunities to provide needed housing for their members (see app. II).

ONAP officials, in turn, recognized some of these concerns but cited low 

staffing levels as a contributing factor. They explained that staffing for 
 

Page 23 GAO-14-255 Native American Housing

regional offices that directly interacted with the tribes had decreased by 

about 40 percent in recent years, in some cases due to retirements and 

subsequent unfilled vacancies. From 2009 to 2013, ONAP staff, most of 

whom are in the regional offices, decreased from an estimated 212 to 

159. According to ONAP officials, the 2012 federal sequester negatively 

impacted HUD’s workforce, contributing to department-wide furloughs 

and limiting HUD’s ability to refill vacant positions. They said that ONAP 

had not hired any staff from June 2012 to September 2013. Further, they 

told us that while HUD had given ONAP authority to appoint temporary 

directors among existing staff, several specialist positions remained open 

without a timeline for being filled. These specialists play an important role 

in helping IHBG recipients carry out housing activities, respond to 

program requirements, and remain compliant. For example, the

specialists are responsible for ensuring that funds are awarded when a 

recipient meets the IHBG program requirements. They also provide 

technical assistance and project support, review recipients’ performance, 

and initiate enforcement procedures when necessary. Without sufficient 

attention from ONAP in these areas, recipients are more likely to 

experience prolonged administrative issues that can delay the provision 

of services to members and require increased monitoring by HUD.

Finally, tribes in the same region sometimes had different characteristics 

and carried out different activities. For example, one housing official 

explained that the tribe she worked with received federal recognition after 

NAHASDA’s implementation and therefore did not own pre-NAHASDA 

(1937 Act) units, lacked reservation land, and had not yet built any IHBGfunded units. As a result, the tribe had focused on nonconstruction 

activities such as providing tenant-based rental assistance for members 

that was similar to HUD’s Section 8 program and was trying to identify 

other tribes using this approach.35 At the time we spoke, the official had 

not identified comparable tribes in the region that could share IHBG 

strategies, and she had reached out to ONAP but had not yet received 

the requested information.

 

35Under the tenant-based Section 8 program, an assisted household pays 30 percent of 

its adjusted monthly income in rent; the remainder of the rent is paid by HUD and is 

generally equal to the difference between (1) the lesser of the unit’s gross rent (generally, 

rent plus utilities) or a local “payment standard” and (2) the household’s payment.
 

Page 24 GAO-14-255 Native American Housing

We previously concluded that limited administrative capacity could hinder 

the success of tribes and TDHEs participating in NAHASDA.36

Yet another housing director with 20 years of experience had been in his 

current position only a few months, and other staff members had been in 

their positions less than 2 years. The housing director explained that the 

housing entity receiving the tribe’s NAHASDA funds had transitioned from 

a TDHE to a housing department within the tribe and that housing 

leadership had changed at least 8 times in fewer than 3 years, making it 

difficult to plan with confidence. In the case of the largest IHBG recipient, 

NHA, several factors contributed to administrative capacity issues in 

recent years, including noncompliance by subrecipients and changes in 

the TDHE’s leadership.

At the 

time, we noted that this challenge likely was more common among 

recipients whom we contacted with smaller annual IHBG allocations and 

fewer staff. During this review, a few housing officials told us that they 

had experienced or were still experiencing administrative capacity issues. 

Size remained a factor, but frequent staff turnover and other 

administrative changes also had a negative impact on recipients’ ability to 

successfully administer the IHBG. For example, one tribal housing 

department had only two staff members, including the director. The 

director, who had been in her position for 4 years, said that because of 

the department’s size, any staffing changes would have a significant 

impact on continuing operations. Another housing director told us that she 

had served in the position for about 1 year and also had one additional 

staff member and that before she started, the TDHE had been closed for 

some time after ONAP found that certain procedures had not been 

carried out. ONAP officials stated that ONAP did not initiate the TDHE’s 

closure.

Successful administration of the IHBG program, including the ability to 

plan and execute eligible housing initiatives and to adhere to program 

requirements, requires dedicated and knowledgeable staff and some 

measure of operational consistency. In a few cases, housing officials told 

us the tribe or TDHE they worked for initially began participating in the 

IHBG program without allocating sufficient personnel and ramped up over 

 

36See GAO-10-326. 

Internal Challenges

Limited Administrative 

Capacity
 

Page 25 GAO-14-255 Native American Housing

time to more adequately administer the grant. Moreover, HUD officials 

explained that while the IHBG program was not onerous on the front end 

because it was not competitive, tribes could be unprepared for the 

sophistication and systems required to administer housing activities under 

the program and to remain compliant with its requirements. HUD officials 

said they were aware, for instance, that turnover in tribal housing staff 

and housing directors could result in the loss of expertise that was difficult 

to replace. Further, they said that because of tribes’ often remote 

locations, quality contractors that could supplement the housing staff’s 

knowledge were hard to find.

Internal conflict on housing issues within tribal entities can take various 

forms, such as disagreement between a tribe and its independent TDHE 

or between the TDHE and other departments related to housing, such as 

planning and environmental offices. We found that internal conflicts could 

affect the priority housing was given, or whether housing activities were 

carried out in a timely manner. One housing director in North Dakota 

whose tribe had experienced such conflicts said that he had convened a 

working group that was intended to, among other things, help resolve 

conflicts between the tribal government and the TDHE. Past tribal 

leadership had not wanted to divert some of the tribe’s gaming revenues 

to community needs, such as housing, according to the official, who 

added that a lack of housing and the associated overcrowding led to other 

social and health issues. He expressed hope that new tribal leadership 

would prioritize housing needs. A Nevada housing official also told us that 

the tribe’s environmental department had differed with the TDHE over 

adherence to some housing development codes and that delays in 

reaching agreements had impacted the timeline of tribal housing projects.

In addition, the housing director of a South Dakota tribe explained that the 

tribe had only recently begun zoning efforts. As a result, members 

seeking home sites were waiting to find out where there was buildable 

land, which areas might be flood plains, and which sites were barred from 

development by the tribe.37

 

37See 

Because work we had previously conducted 

found that the Federal Emergency Management Agency’s (FEMA) 

mapping of rural communities, including tribal lands, was limited, we 

asked whether FEMA had visited the tribe to begin flood mapping. The 

official said that FEMA had mapped the surrounding county, and while the 

GAO-13-226. 

Conflict within Tribes
 

Page 26 GAO-14-255 Native American Housing

tribe’s housing department had wanted the tribe to be included, the tribal 

government had not made mapping a priority.

In some cases, housing development challenges are exacerbated by 

cultural considerations or tribal governments’ inaction, and as a result 

Indian tribes often face a dilemma in combining their desire for progress 

with a need to maintain certain tribal traditions. For example, a few 

housing officials said that tradition played a role in how some of their 

members preferred to live and that some tribal members’ preferences 

were at odds with new ideas for development (see fig. 3). Several of our 

interviews and another source indicated that Native American tribes often 

do not see living in populous areas in general and in cluster housing in 

particular as being in line with their traditional systems and values. Some 

members want to live in residences or family compounds that are several 

miles from their closest neighbor, for instance. Likewise, members do not 

always want to move to more developed areas if it entails moving away 

from certain traditions. The Housing Assistance Council noted in its 

September 2013 report that HUD introduced cluster housing in the 1960s 

as a means of providing cost-effective modern housing and utilities on 

Indian reservations.38

 

38Housing Assistance Council (Washington, D.C.: September 2013).

However, the report added that many now view 

these cluster homes as “reservation ghettos” that are more prone to 

increased criminal activity because they disrupted original social networks 

and important aspects of many Native American communities.

Cultural Factors
 

Page 27 GAO-14-255 Native American Housing

Figure 3: Examples of Traditional Indian Homes, Navajo Nation (left) and Hopi Tribe (right)

Some of the ways in which tribal members prefer to live make it difficult 

for tribes that want to make infrastructure available to more of their 

members. For example, housing officials at one TDHE told us that the 

TDHE faced restrictions on large portions of land because some 

members would not negotiate rights-of-way for utility services across land 

parcels or held historic grazing permits that exempted the land from 

development. The housing officials explained that while the grazing 

permits, originally intended to accommodate livestock held by families, 

did not provide actual title to the land, members were emotional about the 

land and did not want to see traditional federally-funded homes built on it 

because they perceived the developments as breeding crime. In 

deference to tribal members, the TDHE had foregone needed 

development in some areas and proposed a sustainable communities 

plan, beginning with pilot communities in the hope of overcoming tribal 

members’ reluctance to support planned developments. The TDHE plans 

to seek input from tribal members on building pilot communities that 

incorporate tribal systems and values. The hope is that building homes 

with community input will result in tribal members prioritizing housing and 

economic development over traditional grazing rights (see NHA case 

study in app. II).
 

Page 28 GAO-14-255 Native American Housing

These types of internal issues, which can impact how housing plans are 

carried out and have the potential to stall needed development, can only 

be addressed among tribal officials. Self-determination allows tribes the 

autonomy to determine their own housing priorities and to address them 

in the manner that best serves their members.

Addressing some of the housing challenges that Indian tribes face 

requires sustained, long-term coordination and a shared commitment to 

removing fundamental barriers to affordable housing development in 

Indian communities. Among these challenges is the issue of land 

ownership, which is complicated on tribal lands and can hinder housing 

activities. Moreover, traditional housing markets do not exist on some 

tribal lands. For example, a nonprofit representative whose organization 

had been trying for years to develop a housing market for the Navajo 

reservation noted that it had only recently succeeded in helping to create 

one development with an actual market. We have seen that for the 

Navajo, as for other tribes, there may be a dilemma between the desire 

for progress and the need to maintain cultural traditions.

We noted earlier that some progress was being made at the federal level 

to deal with such challenges—for example, the BIA has recently begun 

efforts to implement new leasing procedures for certain types of land in 

order to expedite approvals. HUD has also been encouraging more 

sustainable Native American homes and communities that may 

incorporate tribal culture. We have identified additional targeted federal 

actions that could expedite efforts tribes already are making to deliver 

affordable housing in their communities.

CEQ has issued regulations that are, in general, binding on all federal 

agencies for implementing the procedural provisions of NEPA. The CEQ 

regulations admonish agencies to reduce excessive paperwork by, 

among other things,

• incorporating material into an environmental impact statement by 

reference if the material is otherwise reasonably available, and

• eliminating duplication with other federal procedures by allowing an 

agency to adopt appropriate environmental documents prepared by 

another agency.

Addressing Some 

Tribal Housing 

Challenges Would 

Require Fundamental 

Changes, but Other 

Opportunities Exist

Establish a Coordinated 

Environmental Review 

Process for Tribal Housing 

Development
 

Page 29 GAO-14-255 Native American Housing

The regulations further require that, where appropriate, a lead agency be 

appointed when several agencies are involved.

As we have seen, several of the tribal housing officials we spoke with told 

us that it was time-consuming and costly to complete separate 

environmental review processes for multiple agencies when a tribe 

combined funding sources for a project. For example, some agreed that it 

would be reasonable for federal agencies to establish a single process 

that met the requirements of each agency. A few suggested that the 

requirements should be determined by a lead agency. For example, one 

housing official stated that a more efficient approach would be to identify 

one agency as the cognizant entity whose review process would be 

adequate to cover the requirements of the other agencies.

Federal agencies that work with Indian tribes and their members were 

aware of this obstacle.39 A preconstruction paperwork streamlining 

workgroup convened by a federal infrastructure task force noted in a 

February 2011 report that the environmental review process for water and 

wastewater projects on tribal lands could be improved if funding agencies 

coordinated their processes.40

 

39Both USDA and BIA stated that the environmental review process could be more 

efficient if CEQ allowed an agency to adopt another agency’s categorical exclusion. A 

categorical exclusion is a category of actions that do not individually or cumulatively have 

a significant effect on the human environment and that have been found to have no such 

effect in procedures adopted by a federal agency. Actions that fall within a categorical 

exclusion are exempt from requirements to prepare an environmental assessment or 

environmental impact statement. See 40 C.F.R. § 1508.4. 

The task force’s report noted that while all 

federal agencies must comply with NEPA and other related regulations, 

their requirements could—and did—differ significantly. The report also 

pointed out that environmental review forms across agencies requested 

similar information and that many agencies used different checklists to 

evaluate environmental issues. Much like the tribal housing officials, the 

report suggested that a checklist be developed with a first section that 

covered common requirements across all agencies, followed by a 

separate section tailored to meet the needs of individual funding 

40 Streamlining Preconstruction Paperwork Workgroup as Requested by the Infrastructure 

Task Force to Improve Access to Safe Drinking Water and Basic Sanitation in Indian 

Country, Overview of Tribal Water Infrastructure Funding Application Processes and 

Recommended Paperwork Streamlining Opportunities (February 2011). The workgroup 

compiling this report included task force members—the Environmental Protection Agency, 

HUD, USDA, IHS, Interior’s Bureau of Reclamation—and the Alaska Native Tribal Health 

Consortium. 
 

Page 30 GAO-14-255 Native American Housing

agencies. In addition, the report suggested that selecting a lead agency 

on a project-by-project basis could help the process. We previously 

concluded that the lack of a lead federal agency to coordinate certain 

tribal environmental efforts impeded much needed progress.41

Although a coordinated review process for tribal housing development 

would require significant agency collaboration as it was implemented, it 

has the potential to benefit tribes by saving them valuable IHBG funds 

and other resources and by expediting the time frames for much-needed 

development. Coordinating environmental review activities for housing 

projects could also save federal agency resources in the long term and 

avoid duplication of effort among funding agencies. The task force 

report’s observation, that changing environmental review policies for 

water and wastewater could require legal reviews within the coordinating 

agencies, likely would apply to housing as well. 

As discussed earlier, starting in fiscal year 2012, changes made in the 

appropriation of training and technical assistance funds have reduced the 

role of NAIHC as a provider of training and technical assistance to IHBG 

recipients. HUD’s new procedures using cooperative agreements for 

IHBG recipient training and technical assistance were also instituted in 

fiscal year 2012. However, our selected interviews suggested that some 

tribes and TDHEs remained unfamiliar with the new procedures and were 

concerned about having their training and technical assistance needs 

met. Under HUD’s new procedures, ONAP and IHBG recipients must 

work more closely together to ensure that the tribes’ training and technical 

assistance needs are being met. As we have said previously,

collaboration among entities with a common goal is most effective when 

mechanisms such as a means of collecting input from all stakeholders are

in place.42

As a result, it is important that tribes and TDHEs impacted by changes in 

how they will receive training and technical assistance work with ONAP to 

better ensure that the new delivery system meets their needs. As 

 

41GAO, Alaska Native Villages: Limited Progress Has Been Made on Relocating Villages 

Threatened by Flooding and Erosion, GAO-09-551 (Washington, D.C.: June 3, 2009). 

42GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012).

Seek and Incorporate 

Feedback from IHBG 

Recipients on New 

Training and Technical 

Assistance Procedures
 

Page 31 GAO-14-255 Native American Housing

previously noted, ONAP officials told us that concerns expressed by 

some IHBG recipients about the new system likely reflected recipients’ 

past experiences with HUD-provided training and technical assistance. 

Further, ONAP officials said that the concerns of some IHBG recipients 

who had used the new procedures to obtain assistance had not been 

realized. For example, the officials explained that ONAP solicited 

feedback under the new procedures from tribes and TDHEs immediately 

following technical assistance visits and again 60 and 120 days 

thereafter. In response to reviewing a draft of this report, they also 

provided us with copies of a technical assistance work plan and 60-day 

follow-up evaluation for the same recipient and 32 completed evaluation 

forms from a NAHASDA training course held in January 2014. Finally, 

ONAP officials stated that they had begun incorporating suggestions from 

recipients on process improvements. 

However, given recipients’ concerns and ONAP’s awareness of them, 

opportunities remain for ONAP to seek input from IHBG recipients who 

have not yet used the new procedures in order to address their concerns 

with the overall process for providing training and technical assistance. 

Although some recipients provided ONAP with positive feedback on 

specific training events, others told us that they were skeptical of the new 

training and technical assistance procedures and were unsure that these 

procedures would continue to meet their needs. Some recipients believed 

that barriers existed to obtaining the assistance they needed. For 

example, some recipients told us that the new procedures may result in a 

lengthier wait to receive the services requested due to the time their 

regional offices took to communicate training requests to ONAP 

headquarters and the time for ONAP to contract for services. ONAP has 

not reached out to these IHBG recipients to suggest alternative ways to 

request services that could help address tribes’ concerns. For example, in 

responding to the draft report, ONAP officials told us that recipients could 

go directly to headquarters to request training services. In addition, ONAP 

had begun a thorough follow-up process with technical assistance 

providers to ensure that those providers delivered the type of assistance 

that will benefit tribes in their housing efforts, which could help reassure 

tribes. Without additional outreach, some recipients could remain 

disengaged from and skeptical of the new system and thus miss 

opportunities to build the capacity of their housing programs and meet 

their housing goals. 
 

Page 32 GAO-14-255 Native American Housing

As part of its efforts to provide IHBG recipients with capacity-building 

technical assistance, ONAP could help IHBG recipients share 

approaches they have used to address housing challenges. Under the 

new training system, recipients may find that they have limited 

opportunities for sharing IHBG-related strategies during national training 

and other events because NAIHC played a significant role in providing 

scholarships that facilitated tribes’ attendance at such events. Further, as 

we have seen, the circumstances of tribes within a region may differ, and 

it can be difficult for tribal housing officials to learn about innovative 

approaches to housing issues. HUD already has recognized Native 

American communities for initiatives such as innovative housing practices 

through the Sustainable Construction in Indian Country initiative. HUD 

highlighted 22 communities through this initiative in May 2013. However, 

HUD has not shared promising housing practices more generally across 

tribes in a way that would make them easily accessible. In 2013, the 

National Congress of American Indians also released a report illustrating 

how tribes were using innovative strategies to make progress in areas 

such as education, workforce development, food production, and 

housing.43 A similar document on IHBG strategies could consolidate 

promising approaches that tribal housing officials may communicate oneon-one, supplement existing training and technical assistance programs, 

and require few resources.44

Promising practices for Indian housing might include successful strategies 

for competing for funding opportunities; strategies for addressing issues 

related to remoteness, such as high fuel, transportation, and development 

costs; and creative and resourceful ways of delivering housing programs 

in a more efficient manner. To maximize distribution, HUD could consider 

making IHBG successful practice documents available on the website 

used by recipients. While we recognize that Indian tribes differ in 

important ways, a guide that describes practical methods that IHBG 

 

43National Congress of American Indians, Securing Our Futures (Washington, D.C.: 

February 2013). 

44HUD has created a best practices document in another area (the HUD-VA Supportive 

Housing Program) that could be used as a model. With input from public housing agencies 

and VA medical centers, HUD shared effective strategies and highlighted specific efforts—

for example, practices that several public housing agencies used to help homeless 

veterans transition to permanent housing. See GAO, Veteran Homelessness: VA and 

HUD Are Working to Improve Data on Supportive Housing Program, GAO-12-726

(Washington, D.C.: June 26, 2012). 

Disseminate Promising 

Housing Approaches 

among IHBG Recipients
 

Page 33 GAO-14-255 Native American Housing

recipients have used to solve known challenges or to increase their 

success in the program could be adapted to address specific situations. 

Wider dissemination of these approaches could help tribes improve their 

delivery of needed housing and related services to their members.

The lack of adequate housing in Native American communities is widely 

known, and the federal government has committed to helping Indian 

tribes address their communities’ need for affordable housing and related 

services. Several federal agencies have programs that assist Indian tribes 

and their members, but NAHASDA and the IHBG were created for this 

purpose, while also giving tribes flexibilities that they lacked as recipients 

of earlier housing programs. As we have seen, some of the housing 

challenges that tribes continue to face are not easily resolved, such as 

the often remote locations of tribal lands, intratribal conflicts, and cultural 

preferences. However, certain targeted actions could help mitigate two 

challenges identified in our work.

First, tribes using housing funds from multiple agencies face multiple 

environmental reviews, since each funding agency has its own 

requirements. These reviews not only cost tribes needed resources but 

can delay the implementation of needed housing projects and, in some 

cases, can halt them. A federal infrastructure task force focused on 

facilitating tribes’ water and wastewater projects has recommended that 

task force participants, including HUD, develop a coordinated 

environmental review process that would address the issue of costly 

multiple reviews. A similarly coordinated process for tribal housing would 

help tribes to plan and build affordable housing more quickly and 

efficiently. Further, it would be appropriate for agencies that assist tribes 

with affordable housing to designate a lead agency as part of this effort. 

Until such an effort is developed and implemented, tribes will continue to 

expend time and IHBG resources completing overlapping reviews, 

reducing the funding available for the development of needed affordable 

housing.

Second, HUD has made changes to training and technical assistance

procedures funded through a NAHASDA set-aside that significantly 

changes the way these services are provided. HUD made these changes 

in keeping with the language of NAHASDA’s appropriation legislation, 

which no longer recognizes a single national-level provider, and HUD 

believes that the changes should streamline the process of providing 

training and technical assistance. HUD has established a mechanism to 

obtain feedback from IHBG recipients who receive training and technical 

Conclusions
 

Page 34 GAO-14-255 Native American Housing

assistance under the new procedures, but some IHBG recipients who 

have not yet used them remain concerned that their training and technical 

assistance needs will not be met. The tribes play a significant role in 

helping HUD assess the impact of the new procedures, and it is important

that all tribes participating in NAHASDA have opportunities to request and 

receive assistance and to provide HUD with feedback. A more 

comprehensive feedback mechanism would include input from tribes that 

have not yet used HUD’s new procedures so that their concerns can be 

addressed. 

ONAP could, as part of seeking feedback from IHBG recipients, collect 

and disseminate among recipients promising approaches that they have 

used to address their housing challenges. We found that tribes and 

TDHEs could face challenges in providing affordable housing that others 

in their region with which they might have contact do not face. HUD is in a 

position to gather information on promising approaches to tribal housing 

challenges and disseminate them nationwide. In May 2013, for example, 

HUD recognized 22 tribes that were incorporating resource-efficient 

elements into their affordable housing projects. Expanding this kind of 

dissemination effort could help tribes and TDHEs identify ways to use 

their IHBG funding in the most efficient and effective ways in their 

communities.

To increase consistency and reduce time and predevelopment cost for 

NAHASDA grant recipients, we recommend that an interagency effort 

similar to that of the federal infrastructure task force but specific to tribal 

housing be initiated with participants from IHS, HUD, Interior, and USDA 

to develop and implement a coordinated environmental review process 

for all agencies overseeing tribal housing development. In addition, the 

agencies should determine if it would be appropriate to designate a lead 

agency in this effort. 

To better ensure that NAHASDA grant recipients receive adequate 

training, technical assistance, and support, we recommend that the 

Deputy Assistant Secretary of Native American Programs take the 

following actions:

• As ONAP finalizes new training and technical assistance procedures 

for NAHASDA grant recipients, ONAP should expand its existing

mechanism to seek and incorporate feedback and input from all 

recipients, including input from recipients that have not yet used the 

Recommendations for 

Executive Action
 

Page 35 GAO-14-255 Native American Housing

new procedures, in order to better ensure that its training and 

technical assistance procedures meet recipients’ needs.

• ONAP should collect and disseminate promising approaches that 

recipients have used to address housing challenges.

We provided a draft of this report to the Department of Health and Human 

Services (HHS), HUD, Department of the Interior (Interior), and USDA for

their review and comment. We received written comments from HUD and 

HHS that are reproduced in appendixes III and IV, respectively. HUD, 

Interior, and USDA also provided technical comments, which we 

incorporated into the report as appropriate. The agencies generally 

agreed with our recommendations, although HUD did not agree with our 

recommendation that it should create a mechanism to seek and 

incorporate feedback from IHBG recipients.

HUD agreed with our recommendation that all agencies involved in Native 

American housing programs develop a coordinated environmental review 

process but strongly suggested that the effort be initiated by an 

organization, such as CEQ, that has the power to bring the relevant 

parties together. Our recommendation is supportive of actions that the 

agencies may take to develop a coordinated environmental review 

process, including seeking guidance from CEQ on how to proceed with 

this collaborative effort. HUD also agreed with our recommendation that 

the agency collect and disseminate to IHBG recipients’ promising 

approaches to address housing challenges. HUD highlighted its efforts to 

promote sustainable construction practices in Native American 

communities, and we had noted these efforts in the draft of this report. 

For example, HUD mentioned that its initiatives include a website that 

contains best practices and case studies on sustainable Native American 

housing projects. As previously noted, HUD did not agree with our 

recommendation that the agency create a mechanism to seek and 

incorporate feedback from IHBG recipients on its new training and 

technical assistance procedures. HUD mentioned its postcourse 

evaluation forms and the follow-up that takes place after a recipient 

receives technical assistance and HUD provided us with examples of 

completed evaluation forms from January 2014 and technical assistance 

follow-up documents. We recognize that these practices exist, but our 

suggestion that HUD seek feedback from all recipients would include 

obtaining input from recipients who have not yet used the new procedures 

and remain skeptical that their training and technical assistance needs 

will be met. We added language in relevant sections of the report to 

Agency Comments 

and Our Evaluation
 

Page 36 GAO-14-255 Native American Housing

reflect the information that HUD provided and changed the 

recommendation language to clarify that we recommend that HUD obtain 

feedback from all IHBG recipients, including those that have not used the 

new training and technical assistance procedures.

HHS agreed with our recommendation that agencies involved in Native 

American housing programs act to implement a coordinated 

environmental review process. The audit liaison for USDA Rural 

Development provided USDA’s concurrence with the intent of the 

recommendation in an email dated March 7, 2014. In technical 

comments, HUD and USDA asked us to clarify that the federal 

infrastructure task force’s recommendation for agencies to develop a 

coordinated environmental review process for tribes was limited to water 

and wastewater infrastructure projects and did not include housing. We 

revised the relevant language in our conclusions and the first 

recommendation to reflect the agencies’ input. The audit liaison for 

Interior provided the Department’s concurrence with the revised 

recommendation in an email dated March 7, 2014.

We are sending copies of this report to appropriate congressional 

committees and HHS, HUD, Interior, and USDA. In addition, the report is 

also available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-8678 or shearw@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made major contributions to this report 

are listed in appendix IV.

William B. Shear

Director, Financial Markets and Community Investment
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-14-255 Native American Housing

Our objectives were to examine (1) the kinds of challenges that Indian 

tribes have faced in administering housing activities under the Indian 

Housing Block Grant (IHBG) program and (2) federal or tribal actions, if 

any, that could help to address these challenges.

To address both objectives, we reviewed the Native American Housing 

Assistance and Self-Determination Act of 1996 (NAHASDA) and its 

implementing regulations, testimonies by Department of Housing and 

Urban Development (HUD) and tribal representatives, prior GAO reports, 

and other relevant sources such as studies by nonprofit housing and tribal 

advocacy organizations and a report by federal agencies working to 

improve water and sanitation access on tribal lands.1 We interviewed 

representatives of the National American Indian Housing Council 

(NAIHC), which represents American Indian, Alaska Native, and Native 

Hawaiian housing interests. Our interviews included NAIHC executives 

and members of NAIHC’s board who served as housing officials for 

individual tribes and tribally designated housing entities (TDHE) 

participating in NAHASDA. We interviewed housing officials from 23 

selected tribes or TDHEs participating in NAHASDA and conducted site 

visits with two of the recipients. One of these site visits was to the Navajo 

Nation’s reservation to meet with officials of the Navajo Housing Authority 

(NHA). We selected this location to visit because NHA was the largest 

IHBG recipient. NHA also was one of several recipients that contributed 

to a large backlog of obligated yet unexpended IHBG funds.2

 

1

Streamlining Preconstruction Paperwork Workgroup, Overview of Tribal Water 

Infrastructure Funding (February 2011). 

NHA has 

experienced longstanding administrative challenges and had a backlog of 

nearly $500 million in unexpended IHBG funds as of July 2013. We 

discussed with NHA officials their plans to use this backlog and observed 

how IHBG funds had been used in the past. Because of the Hopi 

reservation’s proximity to the Navajo reservation and because the Hopi 

Tribe remains a highly traditional, clan-based, independent tribe, we also 

visited with Hopi Tribal Housing Authority officials. On both reservations, 

we toured traditional tribal housing and more recent construction projects. 

2

Conference Report 112-284 noted that some tribes and TDHEs had not spent block grant 

funding for several years, resulting in large accumulated balances and reduced housing 

activities on tribal lands. The report also noted that almost half of the unexpended balance 

belonged to one tribe. Our analysis of IHBG budget data as of July 2013 found that the 

cumulative amount of obligated and unexpended IHBG funds totaled more than $1 billion 

and that NHA contributed approximately 42 percent to that balance.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-14-255 Native American Housing

For example, on the Navajo reservation, we visited a traditional dwelling 

(called a “hooghan”) and homes in the former Bennett Freeze area of the 

reservation that were barred from improvements since the 1960s because 

of a historic land dispute between the Navajo Nation and the Hopi Tribe 

(see fig. 4).3

 

3

The Hopi Tribe is located in northeastern Arizona and the Hopi reservation is surrounded 

by the Navajo reservation. The tribes have had a longstanding dispute over adjoining land 

that led to BIA imposing a decades-long moratorium on construction and improvements 

for homes existing on the contested land. The area came to be known as the Bennett 

Freeze area after BIA commissioner Robert Bennett, who enacted the moratorium in the 

1960s. In May 2009, President Obama signed a law repealing the Bennett Freeze. In the 

intervening years, the Navajo and Hopi worked together to agree on land division, but the 

area and homes in it remain in extreme disrepair. 

We visited pre-NAHASDA HUD-funded homes and IHBGfunded homes. In addition, we visited NHA housing developments that 

were not being used because of issues related to NHA’s subcontractors 

and to land ownership (see app. II for additional information). We also 

visited more successful developments, including college housing and a 

96-unit rental community that used IHBG, USDA, and other funding. On 

the Hopi reservation, we visited a number of sites, including traditional 

villages on two of three mesas (high plateaus with steep sides) and an 

IHBG-funded community building that was intended for youth activities. 

We interviewed the other 21 IHBG recipients by telephone. In addition, 

we interviewed and obtained relevant documents from officials in HUD’s 

Office of Native American Programs (ONAP), which administers 

NAHASDA, and interviewed officials at other federal agencies whose 

programs targeted or served Indian tribes and their members. These 

agencies included the U.S. Department of Agriculture (USDA) Rural 

Development, Bureau of Indian Affairs (BIA) within the Department of the 

Interior, Indian Health Service (IHS) within the Department of Health and 

Human Services, and the Department of Veterans Affairs (VA). We met 

with VA officials to discuss the department’s efforts to increase access for 

Native American veterans to assistance under VA’s home loan and 

housing programs.
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-14-255 Native American Housing

Figure 4: Housing in the Former Bennett Freeze Area, Arizona

To address the first objective, we asked tribal housing officials about 

challenges they were experiencing and the impact of those challenges on 
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-14-255 Native American Housing

their housing efforts. In selecting the non-representative sample of IHBG 

recipients we contacted, we asked ONAP regional offices for help with 

identifying tribes in each region that were facing certain challenges and 

NAIHC helped with outreach to tribes and TDHEs that self-identified the 

challenges they were facing. The 23 recipients we interviewed included 

tribes and TDHEs from HUD’s six ONAP regions that varied in size and 

the amount of annual NAHASDA grant funding.4

We used a standard set of questions to interview housing officials at 

tribes and TDHEs to ensure that we consistently captured their views on 

various aspects of each of our objectives. We analyzed the results of 

these interviews and related documents to identify the main themes and 

develop summary findings. With a few exceptions, the 23 recipients we 

interviewed responded to all of our questions. To categorize tribal housing 

officials’ views throughout this report, we defined modifiers to quantify the 

housing officials’ views as follows:

We interviewed HUD 

and other agency officials about housing challenges they had identified 

among Indian tribes. We also contacted HUD staff with responsibility for 

an ongoing study on Indian tribes’ housing needs to learn more about 

HUD’s methodology and timeline for the study. In addition, we used our 

prior work on NAHASDA and other sources to inform this effort. For 

example, we attended NAIHC’s 2013 convention, where representatives 

from NAIHC, tribes and TDHEs, and federal agencies provided 

perspectives on tribal housing. Finally, we reviewed budget data from 

HUD, showing NAHASDA recipients’ annual IHBG allocations and 

expenditures through 2013, to assess the extent of unexpended recipient 

balances. On the basis of our analysis of the funding data and 

explanations that HUD provided, we determined that the data were 

sufficiently reliable for our purposes.

“most” represents 15 to 19 housing officials,

“many” represents 10 to 14 housing officials,

“several” represents 8 to 9 housing officials,

 

4

The 23 recipients whom we interviewed received a total of more than $160 million in 

IHBG funds for fiscal year 2013. Individual allocations among the 23 recipients ranged 

from approximately $206,000 to approximately $82 million. However, some recipients 

were “umbrella” TDHEs serving multiple tribes or villages that received smaller individual 

allocations.
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-14-255 Native American Housing

“some” represents 5 to 7 housing officials, and

“a few” represents 2 to 4 housing officials.

We categorized the challenges that tribal housing officials identified, in no 

particular order, as follows:

• limited administrative capacity (e.g., new to the program, lack of 

expertise, high staff turnover)

• lack of basic infrastructure to begin new housing development

• internal conflicts between the tribe and TDHE that impact housing 

priorities and investments

• conflicting or inflexible federal program requirements when combining 

IHBG and other funds

• lack of communication and coordination among federal agencies

• tribal ordinances that may impede development

• remoteness, climate, or other geographical factors

• small IHBG allocation

• other (specify)

To address the second objective, we asked tribal housing officials about 

government actions that they believed could mitigate the challenges they 

described and about actions their tribe or TDHE had taken to address 

these challenges. Because tribal housing officials raised concerns about

training and technical assistance changes at NAIHC’s 2013 convention, 

we also asked for their perspectives on the training and technical 

assistance they received and whether interactions with other IHBG 

recipients had been helpful. We considered input from the tribes, federal 

agencies, and other sources and existing knowledge. We analyzed this 

information to determine what actions, if any, could potentially address 

the challenges identified.

We conducted this performance audit from March 2013 to March 2014 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 II: Navajo Housing Authority

Case Study

Page 42 GAO-14-255 Native American Housing

The Navajo Housing Authority (NHA), the Navajo Nation’s TDHE, is 

facing pressure to expeditiously use a backlog of unexpended IHBG 

funds totaling nearly $500 million as of July 2013.1 The Navajo Nation 

reservation consists of about 27,000 square miles across portions of 

Arizona, New Mexico, and Utah. The tribe has an estimated 300,000 

members and 110 communities served under local government entities 

called chapters. A Navajo housing needs assessment conducted by NHA 

from 2008 to 2011 found that 34,000 new housing units were needed on 

the Navajo reservation and an additional 34,000 homes were in need of 

major rehabilitation. However, NHA has experienced longstanding 

administrative challenges. As previously noted, we visited NHA to better 

understand the TDHE’s plan to address its large IHBG backlog and to

observe how grant funds had been spent. We also learned more about 

the circumstances that contributed to the TDHE’s backlog.

NHA’s housing challenges cannot be generalized to all IHBG recipients

but some challenges appear to be similar to those that other tribes and 

TDHEs we interviewed experienced. However, unlike many tribes and 

TDHEs that experienced one or more similar challenges, NHA 

experienced them all. These challenges included the remote setting of 

some communities and related poor socioeconomic conditions, differing 

requirements for federal agencies, and internal administrative difficulties.

• NHA officials told us that because of their remoteness, Navajo 

communities (which were separated by up to 100 or more miles) had 

little to no basic infrastructure to connect new homes with water, 

power, paved roads, and other services such as broadband for 

internet access. For example, NHA’s recent housing needs 

assessment found that 50 percent of homes on the reservation had no 

or incomplete plumbing and kitchens. According to NHA officials, 

remote locations impacted the costs of delivering and constructing 

infrastructure systems. In fact, they stated that without combining 

IHBG and other funds, it was difficult to meet community infrastructure 

needs. They also pointed out that the sheer size of the Navajo 

reservation meant that the topography and terrain differed and could 

impact engineering design for housing.

 

1

NHA’s balance as of July 2013 included the recipient’s fiscal year 2013 IHBG allocation 

of $82 million. As of February 2014, NHA’s IHBG balance was $384 million.

Appendix II: Navajo Housing Authority

Case Study

NHA Faced Challenges 

Similar to Those Faced

by Other Recipients
Appendix II: Navajo Housing Authority

Case Study

Page 43 GAO-14-255 Native American Housing

• Poor socioeconomic conditions on the Navajo reservation have 

persisted while residents’ limited incomes are spent off the reservation 

in more urban areas nearby. For example, a Navajo Nation 2012 

study reported that over 80 percent of the Navajo Nation’s residents 

purchased their groceries off the reservation, typically in towns 

bordering the reservation.2

• NHA was challenged by varying requirements when combining IHBG 

and other funding on housing related projects. NHA used multiple 

programs to leverage funding for housing activities, and NHA officials 

cited certain barriers to leveraging IHBG funds, such as having to 

conduct multiple environmental reviews. They also said that because 

the Navajo reservation was located in three states—Arizona, New 

Mexico, and Utah—they had to navigate the qualified allocation plans, 

funding announcements, and relevant timeframes for all three states’ 

low-income housing tax credit programs.

In addition, 75 percent of them drove at 

least 50 miles to purchase food, clothing, and household items. For 

example, many travel to Gallup, New Mexico, a border town to the 

Navajo reservation, which has a number of major retailers, including a 

high volume Walmart Supercenter. 

3

• Administratively, NHA has faced significant challenges in recent 

years. In 2007, there was a change in the TDHE’s leadership and a

subsequent internal assessment determined that internal controls 

were insufficient. According to NHA officials, NHA went through a 

reorganization to address outstanding program violations stemming 

back to the late 1990s and the new Chief Executive Officer inherited 

a backlog of unspent IHBG funds that had accumulated from 1998 to 

2007 and totaled more than $300 million. NHA was also critical of the 

level of support it received from ONAP during this time. In fact, NHA 

The officials noted that they 

had to be knowledgeable about each state’s requirements when they 

were combining IHBG and other funds with low-income housing tax 

credits for one of the three states.

 

2

Navajo Nation Division of Economic Development, Navajo Economic Data Bulletin 001-

0212, February 2012.

3

State housing finance agencies allocate low-income housing tax credits to owners of 

qualified rental properties who reserve some of their units for tenants at or below certain 

income limits. The owners must restrict tenant rents in these units to 30 percent of the 

income limit, adjusted for the number of bedrooms. Once awarded tax credits, owners 

attempt to sell them to investors to obtain funding for their projects. Investors then can 

claim tax credits for 10 years if the property continues to comply with program 

requirements for 15 years.
Appendix II: Navajo Housing Authority

Case Study

Page 44 GAO-14-255 Native American Housing

officials stated that ONAP issued major deficiency reports that took 

nearly 4 years to resolve but had not been sufficiently involved with 

the TDHE before the crisis. ONAP disagreed that it had provided 

insufficient support to NHA prior to 2007, noting that the regional 

office worked diligently with NHA to provide technical assistance and 

to address the findings. NHA officials explained that it also could be 

difficult for tribal leadership to understand the complexities faced by 

the TDHE as an entity subject to federal requirements and standards 

not faced by other tribal departments. They stated that tribal and 

TDHE priorities related to housing were often different and that tribal 

leadership did not always understand the TDHE’s limitations, leading 

to conflict. In June 2013, the Navajo Nation’s tribal council voted to 

retain NHA, which has undergone significant reorganization since 

2007, as the tribe’s TDHE, in lieu of replacing it with an as yet 

unformed housing entity. NHA’s Chief Executive Officer stated that 

the decision should help in providing stability and continuity for the 

tribe’s ongoing housing efforts.

ONAP stated that NHA’s current management had been doing better 

planning and noted that it had taken some time for organizational 

changes to be implemented. ONAP further acknowledged that NHA 

had a difficult task in working with the Navajo Nation’s many chapters 

to pursue new development. While obtaining land for new 

development remained a challenge on the Navajo reservation, as we 

discuss later, ONAP suggested that NHA could focus on rehabilitating 

privately owned homes and HUD-funded units. ONAP officials 

indicated that doing this would allow NHA additional time to obtain 

land for development while spending funds that are currently in the 

pipeline.

NHA also experienced challenges that appeared to be unique to the 

Navajo Nation’s size and structure. For example,

• NHA officials told us that some Navajo tribal ordinances could impede 

development. For example, they pointed out that NHA provided 

housing programs and services to a large number of chapters, each 

with its own approval processes, and that NHA had to work within the 

timelines for each chapter when IHBG funds were approved and 

allocated for certain projects within a chapter’s jurisdiction. In addition, 

a chapter could have its own development challenges that could 

further delay development. Further, while Indian tribes have faced 

longstanding issues pertaining to the status of their lands (such as 

limited interest by banks to offer mortgages because they would 

Some Challenges That 

NHA Faced Were Unique
Appendix II: Navajo Housing Authority

Case Study

Page 45 GAO-14-255 Native American Housing

generally be unable to foreclose on land held in trust), the availability 

of land for housing development on the Navajo reservation was a 

particular issue because each of the Navajo’s 110 chapters could 

have different development priorities and were sometimes reluctant to 

make land available for housing.4

NHA cannot begin development in a community without the buy-in of 

the relevant chapter. The chapter must be willing to withdraw trust 

land for the project, as applicable. NHA officials explained that prior to 

any development on open range, grazing permit holders had to 

consent in writing to the planned project. The officials described 

grazing permit laws as the prime impediment for land availability to 

develop housing and related utility infrastructure across the 

reservation. Grazing permits frequently presented a challenge as 

permit holders were often unwilling to relinquish what they viewed as 

a cultural right to hold land in favor of housing development that they 

perceived as negatively impacting their communities.

Also, according to NHA, 89 percent 

of the land was tribal trust or fee land that was encumbered by historic 

grazing permits and leases held by individuals and families that 

received the permits and leases decades ago to graze their livestock. 

Given the size of the reservation, the unavailability of land to develop 

housing appeared to be unique.

5

According to an NHA official, even with fee simple land, a 

development within the Navajo Nation could take up to 5 years, in part 

because there were nearly 10 departments needing to sign off before 

a project could get off the ground. With other types of land, the official 

said that development could take 7 to 10 years. As an example, he 

said that a nursing home that NHA had been trying to rehabilitate

NHA officials 

told us that many of the grazing permit holders no longer had cattle or 

sheep to graze and that they needed to overcome the perception that 

federal tract housing breeds criminal activity.

 

4

See GAO-13-226. Even tribes with reservations have limited authority over land within 

the reservation boundaries. In addition, lands allotted to individual tribal members under 

the General Allotment Act of 1887, may have fractionated ownership because the 

allotments have been passed down to and divided among heirs. Fractionated ownership 

could require that large numbers of heirs holding interest in a parcel of land agree on 

decisions pertaining to the land. Indian General Allotment Act, 24 Stat. 388 (1887).

5

The challenges related to grazing rights on the Navajo reservation were separate from 

challenges that could result from trust land parcel disputes on the Navajo reservation and 

on other Indian lands. 
Appendix II: Navajo Housing Authority

Case Study

Page 46 GAO-14-255 Native American Housing

since 2011 could lose qualified professionals if the project faced 

further delays.

• NHA also relied on partnerships with local nonprofit organizations to 

develop housing. The organizations acted as subrecipients of IHBG 

funds and NHA had responsibility for ensuring that they met certain 

criteria. An NHA official with oversight for NHA’s partners explained

that in the past, some subrecipients had issues with compliance, and 

in more serious cases, subrecipients failed to deliver on contracts or 

had operating or building practices that resulted in abandoned 

developments, homeless families, and wasted IHBG funds. For 

example, the NHA official told us that a former subrecipient became 

defunct and left two families that were awaiting major rehab work on 

their homes homeless. He explained that NHA was working with 

another partner to house the families. In another example, around

2004 a development was started to build approximately 90 homes that 

NHA funded with $14.7 million in IHBG funds provided to an 

independent nonprofit housing provider. After HUD found that the 

general contractor for the project failed to follow appropriate building 

codes and other requirements, the project was discontinued and the 

homes have remained unoccupied and at various stages of 

completion for almost a decade. Because of the extent of vandalism 

done to the interior and exterior of the units and NHA’s discovery that 

the general contractor used substandard building materials, NHA 

officials told us that the homes would be demolished (see fig. 5). As of 

February 2014, NHA planned to pursue environmental review 

procedures that were applicable before demolition of the units could 

take place. In addition, NHA cannot plan any new development on the 

site before determining whether the land withdrawal process for the 

initial development has been carried out appropriately.
Appendix II: Navajo Housing Authority

Case Study

Page 47 GAO-14-255 Native American Housing

Figure 5: Vandalized NHA Development in Shiprock, New Mexico
Appendix II: Navajo Housing Authority

Case Study

Page 48 GAO-14-255 Native American Housing

According to NHA officials, in 2002, NHA also funded 36 units in a remote 

area to house teachers for a planned new school. However, the school 

that was planned to replace a smaller facility was never built. Additionally, 

after the subrecipient failed to complete the project, NHA infused $2.5 

million in 2008 to repair and complete the homes with a goal of renting 

them to low-income members, but as of November 2013 the homes were 

unoccupied because of a land ownership issue (see fig. 6).

Figure 6: Unoccupied Housing Units Awaiting Resolution of Land Ownership Issue, 

Navajo Reservation

NHA had a plan to use the backlog of unexpended IHBG funds while 

providing housing in a manner to address tribal members’ concerns and 

be more sustainable in the long-term. In 2012, NHA contracted with an 

architectural and design firm to help address the new housing needs 

identified in its recent study. With input from tribal members across the 

Navajo reservation, the firm helped NHA develop a multiyear community 

master plan. The process of developing the plan involved community 

meetings to engage tribal members in the planning process. The 

meetings took place in various settings on the reservation.

Representatives from the contracted firm told us that in soliciting 

members’ input, they considered cultural living preferences and members’ 

existing perceptions about planned housing developments. They became 

aware that members were skeptical of NHA’s earlier developments in part 

because they perceived traditional federally funded cluster housing 

NHA Has Taken Steps

to Use Existing

IHBG Funds
Appendix II: Navajo Housing Authority

Case Study

Page 49 GAO-14-255 Native American Housing

developments as breeding crime (see fig. 7). A Navajo representative of 

the firm told us that the new project had also highlighted the Navajo 

chapters’ responsibility to make land available for development if they 

wished to address the tribe’s severe housing shortage.

Figure 7: Examples of Traditional Federally Funded Housing Developments, Navajo Reservation
Appendix II: Navajo Housing Authority

Case Study

Page 50 GAO-14-255 Native American Housing

According to the firm’s representatives, they have planned five 

neighborhood demonstration pilots that will be strategically located across 

the reservation (see fig. 8). The hope is that building sustainable homes 

based on community input will give tribal members a positive sense for 

the new neighborhoods. If the result is tribal members prioritizing housing 

and economic development over traditional grazing rights, the pilots could 

help overcome the traditional housing versus economic development 

conundrum. As of January 2014, NHA was securing a developer for the 

first community pilot and working with the architectural and design firm to 

consult with communities and stakeholders on two additional pilots.

Figure 8: Rendering of NHA Contractor’s Sustainable Community Concept

In addition to this planned demonstration, NHA officials told us that they 

had more than 180 projects in various stages of planning, predevelopment, construction, and close-out. Due to limited available land 

and titling issues, NHA had targeted funds to areas where land was not 

an issue. Recent developments included a new housing office building, 

college dormitories, and factory-built homes that were then moved to 

available lots (see fig. 9). NHA officials said that they expected to be on 

track with incoming IHBG funds by 2016. Moreover, they said that the 

tribal government might need to revise some of its land policies in order to 

aid future development.
Appendix II: Navajo Housing Authority

Case Study

Page 51 GAO-14-255 Native American Housing

Figure 9: Recent NHA Housing Projects, Navajo Technical University Dormitory and Factory-Built House
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 52 GAO-14-255 Native American Housing

Appendix III: Comments from the 

Department of Housing and Urban 

Development
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 53 GAO-14-255 Native American Housing
Appendix IV: Comments from the Department 

of Health and Human Services

Page 54 GAO-14-255 Native American Housing

Appendix IV: Comments from the 

Department of Health and Human Services
Appendix IV: Comments from the Department 

of Health and Human Services

Page 55 GAO-14-255 Native American Housing
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 56 GAO-14-255 Native American Housing

William B. Shear, (202) 512-8678, shearw@gao.gov. 

In addition to the individual named above, Andy Finkel (Assistant 

Director), Bernice Benta-Jackson, Emily Chalmers, Jeffery Malcolm, John 

McGrail, Jena Sinkfield, and Andrew Stavisky made key contributions to 

this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(250712)
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