AFFORDABLE 

RENTAL HOUSING

Assistance Is 

Provided by Federal, 

State, and Local 

Programs, but There 

Is Incomplete 

Information on

Collective 

Performance

Report to Congressional Addressee

September 2015

GAO-15-645

United States Government Accountability Office
Highlights of GAO-15-645, a report to

congressional addressee

September 2015

AFFORDABLE RENTAL HOUSING

Assistance Is Provided by Federal, State, and Local 

Programs, but There Is Incomplete Information on

Collective Performance

Why GAO Did This Study

The federal government, states, and 

localities play a significant role in 

providing rental assistance and 

developing affordable rental housing 

for low-income households.

This report (1) identifies the federal, 

state, and local government funded 

programs that provide rental 

assistance to low-income households

and identifies indications of program 

fragmentation and overlap; (2) 

assesses the extent of 

intergovernmental collaboration for 

rental assistance; and (3) determines 

what is known about performance at 

the federal level, at selected state and 

local jurisdictions and for the collective

performance of the levels of 

government providing rental 

assistance. 

GAO partnered with 25 state and local 

audit offices to design an audit plan 

that 6 participating audit offices

conducted on rental assistance to lowincome households. GAO assessed 

the completed results, reviewed 

documentation, and interviewed 

officials from HUD, Treasury, and IRS.

What GAO Recommends

GAO recommends that HUD, in 

consultation with the RPWG, work with 

states and localities to develop an 

approach for compiling and reporting 

on the collective performance of 

federal, state, and local rental 

assistance programs. HUD disagreed 

with the recommendation as originally 

drafted because it did not believe that it 

was addressed to the appropriate 

party. GAO agreed and modified the 

recommendation to direct it to HUD, in 

consultation with the RPWG. Treasury 

and IRS did not comment on the 

recommendation. 

What GAO Found

The federal government and state and local entities provide both rental 

assistance and affordable housing through a wide variety of programs. The six 

participating audit offices that conducted coordinated audits on rental assistance 

reported that the programs they reviewed were funded solely through one level of 

government or were funded by a combination of resources, as shown in the 

figure below. In February 2012, GAO found instances of fragmentation and 

overlap among federal rental assistance programs. In this review, GAO and the 

participating audit offices found indications of fragmentation and overlap among 

programs reported in Oregon and Washington.

Government Funding for Low-Income Rental Assistance and Housing Development Programs

 

The Rental Policy Working Group (RPWG), which was established in 2010 by the 

White House Domestic Policy Council to better coordinate federal rental policy,

collaborates with state and local governments in multiple areas. The participating

audit offices found that their government collaborated with other jurisdictions. 

The Department of Housing and Urban Development (HUD), the Internal 

Revenue Service (IRS) and the participating audit offices reported on the

performance of rental assistance programs to varying extents. HUD reported on 

its performance for only one of its two rental assistance strategic objectives, but 

IRS had not set goals or assessed the performance of the Low Income Housing 

Tax Credit. The participating audit offices reported that most jurisdictions had 

performance information at both the jurisdictional and program levels. However, 

without information on the government-wide performance of rental assistance, 

the Congress, decision makers, and stakeholders at all levels of government are 

hampered in their ability to set priorities and allocate resources. While complete 

and reliable information is a vital component of assessing effectiveness, GAO 

recognizes it is difficult to identify relevant federal, state, and local programs;

collect performance information from multiple levels of government; and 

synthesize the information to reflect collective performance. HUD, the nation’s 

leading housing agency, in consultation with the RPWG, is well positioned to 

capitalize on its existing collaboration among federal agencies and with state and 

local jurisdictions.

View GAO-15-645. For more information, 

contact J. Christopher Mihm at (202) 512-6806 

or mihmj@gao.gov.

United States Government Accountability Office
Page i GAO-15-645 Affordable Rental Housing

Letter 1

Background 5

Federal, State, and Local Funds Are Used to Provide Rental 

Assistance, but Fragmentation and Overlap May Exist across 

All Levels of Government 6

The Rental Policy Working Group and Participating Audit Offices 

Reported Various Efforts to Collaborate, but Also Reported New 

Opportunities and Challenges 21

HUD, IRS and Participating Audit Offices Reported Varying Levels

of Performance Reporting, but There Is Incomplete Information 

on Collective Performance 32

Conclusions 40

Recommendation for Executive Action 41

Agency Comments and Our Evaluation 41

Appendix I Objectives, Scope, and Methodology 44

Appendix II State and Local Participating Audit Offices and 

Consulting Partners 50

Appendix III Comments from the Department of Housing and 

Urban Development 53

Appendix lV GAO Contact and Staff Acknowledgments 56

Related GAO Products 57

Tables

Table 1: Federal Programs Operating in Multiple Jurisdictions 11

Table 2: Washington State’s Low-Income Rental Assistance and 

Housing Development Programs 12

Table 3: King County Low-Income Rental Assistance and Housing 

Development Programs 14

Contents
Page ii GAO-15-645 Affordable Rental Housing

Table 4: Seattle Low-Income Rental Assistance and Housing 

Development Programs 15

Table 5: Low-Income Rental Assistance and Housing 

Development Programs in Oregon Jurisdictions 17

Table 6: Denver Low-Income Rental Development Program 18

Table 7: Agency Priority Goal Indicators, Reported Performance, 

and Targets for 2014 34

Figure

Figure 1: Government Funding for Low-Income Rental Assistance 

and Housing Development Programs 10
Page iii GAO-15-645 Affordable Rental Housing

Abbreviations

CDBG Community Development Block Grant

DPC Domestic Policy Council

ESG Emergency Solutions Grant

FHA Federal Housing Administration 

GPRAMA Government Performance and Results Act Modernization 

Act of 2010

HOME HOME Investment Partnerships Program

HUD U.S. Department of Housing and Urban Development

HFA Housing Finance Agencies

HTF Housing Trust Fund

INTOSAI International Organization of Supreme Audit Institutions

IRS Internal Revenue Service

LIHTC Low Income Housing Tax Credit 

MOU Memoranda of Understanding

NAHMA National Affordable Housing Management Association

NCHMA National Council of Housing Market Analysts

NCSHA National Council of State Housing Agencies

OMB Office of Management and Budget

PHA Public Housing Agencies

RPWG Rental Policy Working Group

RD Rural Development

RHS Rural Housing Service

SLR Subsidy Layering Review

Treasury U.S. Department of the Treasury

USDA United States Department of Agriculture 

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

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

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

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

necessary if you wish to reproduce this material separately.
Page 1 GAO-15-645 Affordable Rental Housing 

441 G St. N.W.

Washington, DC 20548

September 15, 2015

The Honorable Ron Johnson

Chairman

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Mr. Chairman,

In 2013, nearly half of the nation’s 41 million renters were paying more 

than 30 percent of their monthly income for rent, signifying a moderate 

rent burden under the federal standards for affordable housing.1

The federal government largely subsidizes rental payments for lowincome households and awards grants and tax credits to state and local 

governments for developing affordable housing that includes rental 

housing. In fiscal year 2014, HUD provided more than $36 billion in rental 

assistance to low-income households and in affordable housing 

development funding to state and local governments.

Furthermore, the nation’s leading housing agency, the U.S. Department 

of Housing and Urban Development (HUD), reported in April that more 

than 7.7 million very low-income families have “worst case housing 

needs” because they do not receive government housing assistance and 

paid more than half of their monthly income for rent, lived in severely 

substandard housing, or both. The federal government, states, and 

localities play a significant role in providing rental assistance and 

developing affordable rental housing for low-income households.

2

 1

Bipartisan Policy Center Housing Commission, Housing America’s Future: New 

Directions for National Policy (Washington, D.C.: Bipartisan Policy Center, Feb. 2013).

Funding for HUD’s 

largest rental assistance program—Housing Choice Vouchers—mostly 

increased prior to statutory budget reductions in 2013 and totaled 

approximately $19 billion in fiscal year 2014. However, the program’s 

ability to reach more households is limited by increasing costs in the 

rental housing market and there remain more eligible low-income 

households than there are available vouchers. The largest federal 

2

Congressional Research Service, Department of Housing and Urban Development: FY 

2015 Appropriations (Washington, D.C.: Feb. 11, 2015). 

Letter
Page 2 GAO-15-645 Affordable Rental Housing 

program for developing affordable rental housing—the Low Income 

Housing Tax Credit (LIHTC) program—cost an estimated $8 billion in 

forgone revenue in fiscal year 2014. However, other federal support for 

developing affordable housing—such as HOME Investment Partnerships 

(HOME)—has decreased and challenges remain for state and local 

governments to meet increasing demand for affordable rental housing. As 

a result, the need for affordable rental housing continues to outpace the 

ability of federal, state, and local governments to supply housing 

assistance.3

We performed our work under the authority of the Comptroller General to 

conduct evaluations on GAO’s initiative to assist Congress with its 

oversight responsibilities. Our objectives were to (1) identify the federal, 

state, and local government funded programs in selected jurisdictions that 

provide rental assistance to low-income households and identify 

indications of program fragmentation or overlap; (2) assess the extent of 

intergovernmental collaboration for the provision of rental assistance; and 

(3) determine what is known about performance at the federal level, at 

selected state and local jurisdictions, and for the collective performance of 

the levels of government providing rental assistance.

To conduct this work, we partnered with a group of state and local audit 

offices.4 Working as a group, we designed a coordinated audit approach 

involving multiple audit organizations performing similar audits during 

roughly the same time.5

 3

U.S. Department of Housing and Urban Development, Office of Policy and Development 

Research, Worst Case Housing Needs 2015 Report to Congress (Washington, D.C.: April 

2015).

Six of the state and local audit offices—the 

Washington State Auditor’s Office (Washington); the King County 

Auditor’s Office (King County), WA; the Oregon Secretary of State Office, 

Audits Division (Oregon); City of Portland, Office of the City Auditor, Audit 

Services Division (Portland), OR; the Multnomah County Auditor’s Office 

(Multnomah County), OR; and Office of the Auditor, City and County of 

Denver (Denver), CO—conducted these coordinated audits, focused 

4

See appendix II for a full list of the state and local participating audit offices and 

consulting partners.

5

This approach, along with several others, is described by the International Organization 

of Supreme Audit Institutions (INTOSAI) Working Group on Environmental Auditing. See 

INTOSAI Working Group on Environmental Auditing, Cooperation Between Supreme 

Audit Institutions: Tips and Examples for Cooperative Audits (November 2007).
Page 3 GAO-15-645 Affordable Rental Housing 

specifically on rental assistance programs for low-income households in 

their jurisdictions.6

To address the objectives of this report, we analyzed the information the 

participating audit offices provided as part of their coordinated audit 

results. Washington, Multnomah County, and Denver also published 

In addition to reporting on its own programs, 

Washington also reported low-income rental assistance programs found 

in the city of Seattle (Seattle), Seattle Housing Authority, and King County 

Housing Authority. For the purposes of this review, we refer to these six 

state and local volunteers and Seattle as the “participating audit offices”

and the remaining partners as consulting partners. The participating audit 

offices implemented the audit plan, which included compiling inventories 

of programs for the respective jurisdiction that address these low-income 

rental assistance goals, collecting data on key elements of the programs, 

and identifying performance and collaboration information. We and the 

participating audit offices worked together throughout our respective 

audits to answer questions about the audit program and to facilitate 

information sharing among the partners. We reviewed the results of the 

participating audit offices’ published audit reports and coordinated audit 

plan results to ensure that the programs reported met the definition for 

low-income rental assistance and that the information provided matched 

the questions in the coordinated audit plan and we determined that we 

could rely on their results. We did not validate the accuracy of the 

program information reported by the participating audit offices. However, 

we included questions related to data reliability in the coordinated audit 

plan implemented by the participating audit offices and we determined 

that the data were sufficiently reliable for the purposes of this report.

 6

For purposes of the report, we defined rental assistance for low-income households to 

include programs or initiatives with a primary goal of directly or indirectly subsidizing rents 

for low-income households. (Federal programs that provide direct subsidies include the 

Housing Choice Voucher and Public Housing programs, for example. Programs that 

provide indirect subsidies include the Low Income Housing Tax Credit and the Section 

202 Supportive Housing for the Elderly programs, for example.) Also for purposes of this 

report, rental assistance for low-income households excludes short-term or temporary 

programs (the Tax Credit Assistance Program and the Neighborhood Stabilization 

Program, for example), temporary shelter programs (Emergency Shelter Grants, for 

example), and programs targeted at special populations other than elderly and disabled 

households (Housing Opportunities for Persons with AIDS, for example).
Page 4 GAO-15-645 Affordable Rental Housing 

separate reports.7 To identify indications of program fragmentation and 

overlap, we and the participating audit offices analyzed the audit results 

of the participating audit offices using the definitions from our work on 

fragmentation and overlap.8

We performed our work under authority of the Comptroller General to 

conduct evaluations on GAO’s initiative to assist Congress with its 

oversight responsibilities. We conducted our work from February 2014 to 

September 2015 in accordance with generally accepted government 

auditing standards that are relevant to our objectives. Those standards 

require that we plan and perform the audit to obtain sufficient and 

appropriate evidence to meet our stated objectives and to discuss any 

limitations in our work. We believe that the information and data obtained, 

and the analysis conducted, provide a reasonable basis for any findings 

and conclusions based on our audit objectives.

For example, to identify indications of 

program overlap we and the participating audit offices analyzed the audit 

results of the participating audit offices located within the same general 

geographic area in which the programs were administered to determine 

whether the reported programs had similar goals or intended 

beneficiaries, and to determine which agencies, bureaus, or divisions had 

administrative responsibility for the programs. We also interviewed HUD, 

U.S. Department of the Treasury (Treasury), and Internal Revenue 

Service (IRS) officials who participate in the Rental Policy Working Group 

and reviewed documentation on the agency’s rental assistance 

performance information. For more information on our objectives, scope, 

and methodology, see appendix I.

 7

See Washington State Auditor’s Office, Program Understanding Low-Income Housing 

Rental Assistance Programs, (Olympia, WA: Aug. 14, 2014), retrieved from 

http://www.sao.wa.gov/state/Documents/GAO-WA-LIHRA-Data.pdf; Office of the 

Multnomah County Auditor, Housing Inventory Special Report fulfilling note from FY-2015 

Budget work session (Portland, OR: Oct. 22, 2014), retrieved from 

https://multco.us/file/36836/download; and City and County of Denver Office of the 

Auditor, Denver Affordable Housing Performance Audit, (Denver, CO: Nov. 2014), 

retrieved from 

http://www.denvergov.org/Portals/741/documents/Audits2014/Denver_Affordable_Housing

_Audit_20Report_11-20-14.pdf.

8

GAO, 2015 Annual Report: Additional Opportunities to Reduce Fragmentation, Overlap, 

and Duplication and Achieve Other Financial Benefits, GAO-15-404SP (Washington, D.C.: 

Apr. 14, 2015).
Page 5 GAO-15-645 Affordable Rental Housing 

Since the 1930s9, the federal government’s role in affordable rental 

housing has evolved from constructing government owned low-rent public 

housing to subsidizing rent payments for low-income households and 

financing the development of affordable housing, including low-income 

rental housing.10 Today’s federal system for providing these subsidies 

includes rental assistance programs and federal assistance to state and 

local governments for affordable rental housing development. The

Section 8 rental assistance programs are the largest of HUD’s rental 

assistance programs, and represented in recent years more than a third 

of HUD’s budget, approximately $18 billion. Vouchers, the largest Section 

8 rental assistance program, are generally used in the private rental 

housing market.11

Federal assistance to state and local governments for developing 

affordable rental housing includes broad flexible block grants, special 

purpose block grants, and programs based in the tax system that can be 

used for rental, homeownership, or community development purposes.12

As a result, state and local governments have flexibility and control in 

using federal resources to fund local housing and community 

development priorities. For example, HUD’s HOME Investment 

Partnerships program is the largest federal block grant for creating 

affordable housing for low-income households.13

 9

United States Housing Act of 1937, Pub. L. No. 75-412, 50 Stat. 888, September 1, 1937

The program provides 

grants to states and local governments to fund a wide range of activities 

10HUD defines the limits of low-income at 80 percent of the median income for the county 

or metropolitan area. Limits for very-low income and extremely low-income are defined 

respectively at 50 percent and 30 percent of the area median income. Actual limits may 

vary from area to area and are available at http://www.huduser.org/portal/datasets.

11Under the voucher program, an assisted household pays 30 percent of its monthly 

adjusted income in rent; the remainder of the rent is paid through a HUD-subsidized 

“voucher,” which generally is 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. “Adjusted income” means the annual income of the members of the 

family residing or intending to reside in the dwelling unit, after making a series of 

mandatory deductions. In the case of public housing, a Public Housing Authority (PHA) 

may also adopt additional deductions from annual income. 

12Block grants permit the use of funds for broader categories of activities, such as 

community development or public health, and give recipients discretion in identifying 

problems and using grant funds to design programs to address those problems. 

13In fiscal year 2014, HOME received appropriations totaling $1 billion.

Background
Page 6 GAO-15-645 Affordable Rental Housing 

including 1) building, buying, and/or rehabilitating housing for rent or 

homeownership or 2) providing direct rental assistance to low-income 

families.

In 2012, we reported that 20 federal government entities administered 

160 programs, tax expenditures, and other tools that supported 

homeownership and rental housing.14 Based on that housing program 

inventory, four federal programs represent approximately 92 percent of 

total obligations and estimated tax revenue losses for low-income rental 

assistance and affordable housing development programs.15

 14GAO, Housing Assistance: Opportunities Exist to Increase Collaboration and Consider 

Consolidation, GAO-12-554 (Washington, D.C.: Aug. 16, 2012).

These

programs included Section 8 rental assistance programs, Public Housing, 

and two affordable housing development programs—HOME Investment 

Partnerships Program and LIHTC.

15In comments on this report, HUD stated that a “deep subsidy” program can effectively 

assist households at the lowest end of the income scale and a “shallow subsidy” program 

can generally only provide much more modest levels of affordability.

Federal, State, and 

Local Funds Are 

Used to Provide 

Rental Assistance, 

but Fragmentation 

and Overlap May 

Exist across All 

Levels of Government

Primary Federal Rental 

Assistance Programs and 

Assistance to States and 

Local Governments for 

Affordable Housing 

Development
Page 7 GAO-15-645 Affordable Rental Housing 

Section 8 rental assistance includes Housing Choice Vouchers and 

various project-based rental assistance programs.16 The Housing Choice 

Voucher program pays subsidies to landlords so that low-income 

households can rent private apartments or houses available in the rental 

market and has provided approximately 2 million vouchers annually to 

low-income households. In general, households must have very-low 

incomes—not exceeding 50 percent of the area median income, as 

determined by HUD. At least 75 percent of new voucher program 

participants must have extremely-low incomes—not exceeding 30 percent 

of the area median income. Under the voucher program, an assisted 

household pays 30 percent of its monthly adjusted income in rent. The 

remaining portion of the rent is paid through a HUD-subsidized voucher. 

Public housing agencies (PHAs) can set payment standards (that is, pay 

subsidies) between 90 percent and 110 percent of the fair market rent for 

their areas. In order to receive a voucher, a low-income household 

applies to a local PHA and is placed on a waiting list, unless a household 

meets special admission requirements.

17

Another Section 8 program is project-based rental assistance in which 

HUD contracts with private property owners to rent housing units to 

eligible low-income tenants for an income-based rent. No new projectbased Section 8 contracts have been awarded since the mid-1980s; 

however, existing contracts may be renewed and approximately 1 million

project-based units remain under contract and receive assistance. In 

fiscal year 2014, Congress authorized HUD to spend approximately $19 

billion for tenant-based rental assistance that includes Housing Choice 

Vouchers and approximately $9.91 billion for project-based rental 

assistance. These programs combined to assist more than 3 million 

households.

Once a family receives a 

voucher, it may use the voucher anywhere a voucher program is 

administered.

 16For example, a project-based voucher program allows public housing agencies (PHAs) 

to set aside up to 20 percent of their housing assistance for specific housing units if the 

owner agrees to rehabilitate or construct the units. For more information on federal 

voucher programs see 

http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/program

s/hcv. 42 U.S.C. § 1437f; 24 C.F.R., Part 982.

17GAO, Housing Choice Vouchers: Options Exist to Increase Program Efficiencies, 

GAO-12-300 (Washington, D.C.: Mar. 19, 2012). Special admission requirements are for 

assistance targeted by HUD, 24 C.F.R. § 982.203.

Section 8 Rental

Assistance Programs
Page 8 GAO-15-645 Affordable Rental Housing 

HUD subsidizes and regulates low-rent public housing developments that 

are owned and operated by PHAs. Generally, eligible families living in 

federally subsidized public housing are low-income; however, 40 percent 

of available public housing units must be given to extremely low-income 

families (those with income at or below 30 percent of an area median 

income). Families living in public housing pay 30 percent of their adjusted 

income toward rent. PHAs receive several streams of funding from HUD 

to make up the difference in what tenants pay in rent and what it costs to 

maintain and modernize public housing. Congress authorized HUD to 

spend $6.27 billion in fiscal year 2014 and roughly 1 million units are

under contract with the federal government. The amount includes $1.87 

billion for the Public Housing Capital Fund and $4.4 billion for the Public 

Housing Operating Fund, which is meant to supplement rents and help 

meet the operation, maintenance, and capital needs of public housing.

The HOME Investment Partnerships Program (HOME) is administered by 

HUD’s Office of Community Planning and Development and is designed 

to expand the supply of decent, safe, sanitary, and affordable housing. 

HOME is the largest federal block grant that awards block grants to state 

and local governments exclusively to create affordable low-income 

housing. All HOME funds are required to benefit low-income families and 

at least 90 percent of funds used for rental housing activities or tenantbased rental assistance must benefit families with incomes at or below 60 

percent of area median income. Program funding may be used for four 

purposes: rehabilitation of owner-occupied housing, homebuyer 

assistance, rental housing construction and rehabilitation, and the 

provision of tenant-based rental assistance. HOME funds are allocated 

via formula: 60 percent of program funding is awarded to localities and 

the remaining 40 percent is awarded to states for areas not served by 

localities. The HOME formula considers factors related to a participating 

jurisdiction’s supply of substandard, unaffordable, and old rental units, as 

well as a jurisdiction’s population living below the poverty level. HOME 

grantees must match 25 percent of their HOME grants and submit a plan 

to HUD detailing their community housing needs and priorities. In fiscal 

year 2014, the actual obligation for the HOME program was about $1 

billion and provided funding to produce approximately 15,000 low-income 

units. In addition, over 9,500 units received HOME funded rental 

assistance.

The LIHTC is jointly administered by IRS and state housing finance 

agencies (HFA). Under this program, tax credits are awarded to 

developers of qualified projects. State HFAs are responsible for allocating 

the credit on a competitive basis to owners of qualified low-income rental 

Public Housing

HOME Investment 

Partnerships Program

The Low Income

Housing Tax Credit
Page 9 GAO-15-645 Affordable Rental Housing 

projects. The tax credits reduce the funds that a developer would 

otherwise have to borrow. As a result of the lower debt burden, a tax 

credit property can offer lower, more affordable rents. Provided the 

property maintains compliance with the program requirements, investors 

receive a dollar-for-dollar credit against their federal tax liability each year 

over a period of 10 years. Projects eligible for housing tax credits must 

meet one of the following two low-income occupancy threshold 

requirements:

• 20-50 Rule: At least 20 percent of the units must be rent restricted 

and occupied by households with incomes at or below 50 percent of 

the area median income (adjusted for household size).

• 40-60 Rule: At least 40 percent of the units must be rent restricted 

and occupied by households with incomes at or below 60 percent of 

the area median income (adjusted for household size).

LIHTC is the single largest activity (in terms of foregone revenue) for 

developing affordable rental housing. The annual cost of LIHTC in 

foregone revenue is an estimated $8 billion.

The participating audit offices reported a variety of rental assistance and 

development programs. The participating audit offices reported that 

federal, state, and local funds were used to fund the housing programs, 

as illustrated in figure 1. In some cases, the participating audit offices 

reported that these funds were combined; in others, only one funding 

stream was used.

Participating Audit Offices 

Reported Rental 

Assistance and 

Development Programs 

Funded Solely Through 

Federal, State or Local 

Dollars, and Also Reported 

Programs That Used a 

Combination of Resources
Page 10 GAO-15-645 Affordable Rental Housing 

Figure 1: Government Funding for Low-Income Rental Assistance and Housing 

Development Programs

The participating audit offices reported rental assistance programs that 

were funded solely through federal funds. For example, as shown in table 

1 below, participating audit offices reported federal public housing and 

rental assistance programs including the Housing Choice Voucher 

programs and other Section 8 programs at housing authorities in King 

County and Seattle, Multnomah County, Portland, and Denver. The 

housing authorities of King County, Seattle, and Portland are each 

designated as Moving to Work sites, a HUD designation that permits 

housing authorities to combine federal funding streams into an agencywide funding pool to allow greater flexibility in operation, and to test 

innovative approaches for providing housing assistance. In addition, 

nearly all of the jurisdictions for which programs were reported—except 

Multnomah County and Portland—used the federal LIHTC program as an 

incentive for developers of eligible projects to include affordable rental 

housing.
Page 11 GAO-15-645 Affordable Rental Housing 

Table 1: Federal Programs Operating in Multiple Jurisdictions

Program Jurisdiction Description

Federal Public 

Housing programs

City and County of Denver

King County Housing Authority

Multnomah County

Portland

Seattle Housing Authority

Provides decent and safe rental housing for eligible low-income families, 

the elderly, and persons with disabilities.

Section 8 Programs King County Housing Authority

City and County of Denver

Multnomah County

Oregon

Portland

Seattle Housing Authority

Includes tenant-based voucher and project-based rental assistance 

programs that provide rental subsidies to low-income families.

Low-Income Housing 

Tax Credits

Washington

King County Housing Authority

Seattle Housing Authority

Oregon

City and County of Denver

Provides federal tax incentives to invest in the development and 

rehabilitation of affordable rental housing.

Source: GAO analysis of information reported by participating audit offices. | GAO-15-645

Notes: Multnomah County and Portland public housing and Section 8 programs are administered by a 

quasi-governmental agency called Home Forward. Home Forward is the largest provider of affordable 

housing in the state of Oregon and oversees approximately 1,980 units of public housing, and 

approximately 9,390 Section 8 rent assistance vouchers.

Participating audit offices in multiple jurisdictions reported HOME 

Investment Partnerships (HOME) funding as a source of funding used in 

combination with state or local funding and is not included in this table.

Some of the programs were also funded solely by state or local funds. 

Two of the Washington State jurisdictions, Washington and Seattle, 

established dedicated state and local funding sources—a housing trust 

fund and a housing levy funded by variety of sources including property 

tax levies—for affordable housing. In addition, programs that provided 

incentives for affordable housing developers were identified in King 

County, Seattle, and Portland. For example, inclusionary zoning 

incentives in Seattle allow developers to build larger facilities than they 

would be able to otherwise. Developers in Seattle may receive a 

residential development bonus that provides additional floor area above a 

specified base height limit in exchange for including affordable housing in 

the development. Another type of bonus is also available for additional 
Page 12 GAO-15-645 Affordable Rental Housing 

non-residential floor area in hotel, office, and other developments, in 

exchange for housing and childcare affordable to low wage workers.

Developers may also receive these bonuses by making cash 

contributions to the City of Seattle for affordable housing development or 

childcare facilities.

Washington reported that state resources funded programs for local 

governments, nonprofits, and community agencies; provided assistance 

to low-income households at risk of homelessness; and offered financing 

for affordable housing developers. The Auditor’s Office reported that 

funding sources for Washington state programs included the state’s 

general fund as well as collected recording fees.18

Table 2: Washington State’s Low-Income Rental Assistance and Housing Development Programs

One of the programs 

reported by the Auditor’s Office was the Housing Trust Fund, which 

provided capital funding for developing and rehabilitating housing that 

served low-income households. The trust fund program combined state 

resources and has awarded nearly $1 billion in funding over the last 25 

years to build or maintain nearly 40,000 units of affordable housing. An 

estimated 70,000 state households are served per year by these units. 

Table 2 lists the state-level programs reported by Washington for lowincome rental assistance and rental housing development that included 

Washington state funding.

Program

Funding 

source Description

Housing Trust Fund (HTF) State Provides capital funding for the development and rehabilitation of low-income housing.

HTF Operations & 

Maintenance Fund

Program

State Provides an operating subsidy for HTF projects serving households earning 30% or 

less of the area median income.

Consolidated Homeless 

Grant

State Combines the state’s homeless resources into a single grant opportunity for county 

governments and other designated entities to serve households that are unsheltered, 

in temporary housing, or at-risk of becoming homeless.

Housing and Essential 

Needs

State Provides assistance to eligible residents referred by the Department of Social and 

Health Services. In addition to rent and utility assistance, the program may cover other 

essential needs such as personal hygiene and household cleaning supplies, laundry 

tokens, bus pass, or gas cards.

Source: GAO analysis of information reported by the Washington Auditor’s Office. | GAO-15-645

 18Washington State’s General Fund is the largest pool of funding in the state budget and 

consists of all major state tax revenues. The General Fund is the principal resource for 

supporting all state government operations.

Washington State, King 

County, and Seattle LowIncome Rental Assistance

and Housing Development 

Programs
Page 13 GAO-15-645 Affordable Rental Housing 

King County—Washington’s most populous county—reported programs 

that created and preserved affordable housing and made capital 

investments to improve low-income communities through relationships 

with community partners. King County’s programs combined federal, 

state, and local resources to fund grants to local nonprofit organizations, 

which in turn, provided assistance and services to low-income 

households at risk of homelessness, as well as providing capital funding 

to nonprofit developers of low-income housing. In addition, the county 

offered incentives to private developers to make low-income housing 

available in market rate projects. For example, King County’s Affordable 

Housing Incentives Program incentivized private housing developers to 

include affordable units of rental and ownership housing. The incentives 

program included density bonuses that encouraged developers to build 

affordable ownership and rental housing in certain areas of King County 

by allowing developers to build more market rate units than would 

otherwise be permitted by zoning regulations. In exchange for the bonus 

market rate units, developers include a specified number of affordable 

units in the property. The federal sources King County combined with 

state and local funding included the Emergency Solutions Grants

(ESG)19, Community Development Block Grant (CDBG) and HOME 

funding.20

 19The Emergency Solutions Grants program provides funding to (1) engage homeless 

individuals and families living on the street; (2) improve the number and quality of 

emergency shelters for homeless individuals and families; (3) help operate these shelters; 

(4) provide essential services to shelter residents; (5) rapidly re-house homeless 

individuals and families; and (6) prevent families/individuals from becoming homeless.

See the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 

(the HEARTH Act) enacted as part of Pub. L. No. 111-22, 123 Stat. 1632, 1678 (May 20, 

2009).

Table 3 lists the low-income rental assistance and rental 

housing development programs reported by King County that included 

state or local funding or incentives.

20The Community Development Block Grant (CDBG) program was enacted as part of the 

Housing and Community Development Act of 1974(Pub. L. No. 93-383, 88 Stat. 633, 

(Aug. 22, 1974), codified at 42 U.S.C. §§ 5301-5321), and is administered by HUD. The 

purpose of the CDBG program is to develop viable urban communities by providing 

decent housing, a suitable living environment, and expanding economic opportunities 

primarily for low and moderate-income persons. After allocating funds to other activities, 

the CDBG program distributes 70 percent of the remaining funds through formula grants 

to entitlement communities—central cities of metropolitan areas, cities with populations of 

over 50,000, and qualified urban counties—and the remaining 30 percent goes to states 

for use in non-entitlement communities. 42 U.S.C. § 5301(c).
Page 14 GAO-15-645 Affordable Rental Housing 

Table 3: King County Low-Income Rental Assistance and Housing Development Programs 

Program

Funding 

Source Description

Housing Finance Program Federal

Local

Preserves and expands the supply of affordable housing available to low and moderate 

income households, including households with special needs.

Affordable Housing 

Incentives Program

Incentives Provides incentives, such as density bonuses, to private housing developers to include 

affordable units of housing within their developments in partnership or in coordination 

with cities and community stakeholder organizations.

Housing Stability Program Federal

State

Local

Provides financial assistance to households for back rent/housing payment and 

utilities, and provides time-limited counseling to help households overcome a one-time 

emergency and avoid eviction or foreclosure. 

Source: GAO analysis of information reported by the King County Auditor’s Office. | GAO-15-645

Note: The King County Affordable Housing Incentives Program is a tool to encourage housing 

developers to include affordable homes or apartments in their developments and is not a source of 

funding.

The Washington Auditor’s Office reported on Seattle programs that 

supported rental assistance and affordable rental housing development 

with federal and local funds. Two of Seattle’s programs combined both

federal and local resources that provided grants to nonprofit organizations 

for rental assistance and funding developers of affordable housing. The 

programs for developers included capital funding, operations and 

maintenance funding, tax exemptions, and other financial incentives. For 

example, Seattle’s Rental Housing Program combined federal resources 

with local funding to develop 315 affordable rental apartments and to fund 

building improvements to preserve 130 affordable rental apartments. The 

federal resources used by Seattle were HOME and CDBG program 

funding. The local resources used in Seattle included the Seattle Housing 

Levy—a dedicated source of funding for affordable housing 

development.21

 21In November 2009, Seattle voters passed a seven-year, $145 million property tax levy to 

provide affordable housing opportunities for low-income Seattle residents. The levy has 

added nearly 2000 affordable rental units and rehabilitated over 400 additional units.

Table 4 lists low-income rental assistance and affordable 

rental housing development programs for low-income housing developers 

reported for Seattle that included local funds and incentives.
Page 15 GAO-15-645 Affordable Rental Housing 

Table 4: Seattle Low-Income Rental Assistance and Housing Development Programs

Program

Funding 

source Description

Rental Housing

Program

Federal

Local

Funds the development of affordable rental housing.

Multifamily Property Tax 

Exemption Program

Tax Exemption Promotes the development of mixed-income buildings by providing owners of multifamily 

properties with a property tax exemption of up to 12 years on residential improvements in 

exchange for income- and rent-restricting at least 20% of units.

Incentive Zoning 

Program

Incentive Allows developers to obtain more zoning capacity to develop additional units in exchange 

for making a portion of units available to low- income families. Developers may also make 

cash contributions to the city for low-income housing in exchange for more zoning 

capacity.

Operations and 

Maintenance Fund

Local Provides a subsidy to housing funded by the Seattle Housing Levy serving those with the 

highest needs and fewest resources to fill the gap between operating income and 

expenses.

Seattle Housing Levy 

Rental Assistance 

Program

Local Provides rental assistance—which is funded through the levy—to low-income families 

and individuals at risk of homelessness who need help due to a family crisis such as job 

loss, illness, divorce, or a death in the family.

Homeless Prevention

Programs

Federal

Local

Provides rental and legal assistance and support services to households at imminent risk 

of becoming homeless. The program is administered by seven local nonprofit 

organizations.

Rental Assistance 

Program

Local Provides direct assistance on behalf of very low-income households (50% area median 

income or less) in order to stabilize housing. Assistance may be one time or ongoing and 

the program is administered by three local nonprofit organizations.

Rapid Re-Housing 

Program

Local Provides direct assistance on behalf of very low-income households. Program is 

administered by five local not-for-profit organizations.

Source: GAO analysis of information reported by the Washington Auditor’s Office. | GAO-15-645

Note: Seattle’s incentive program is not a source of funding to private housing developers but rather

helps link opportunities for increased development potential with public benefits such as affordable 

housing. Similarly, the multifamily tax exemption encourages the development of affordable 

multifamily housing through foregone tax revenue and is also not a source of funding.

Oregon, Multnomah County, and Portland also reported programs that 

included federal, state, and local resources that provided payments to 

households, landlords, and utility companies, administrative activities for 

a public housing program, and financial incentives for the development, 

acquisition, and rehabilitation of low-income housing. Oregon used 

federal and state resources to help meet one of its goals to create and 

preserve opportunities for quality, affordable housing for lower and 

moderate income Oregonians. The state allocated federal low-income 

housing tax credits to encourage the construction and rehabilitation of

low-income rental housing and provides funding to community 

organizations for low-income rental assistance. For example, the state’s 

Low Income Rental Assistance program provided funding to assist lowOregon, Multnomah County, 

and Portland Low-Income 

Rental Assistance and 

Affordable Housing 

Development Programs
Page 16 GAO-15-645 Affordable Rental Housing 

income households in paying rent and security and utility deposits. This 

program was administered by community-based agencies that made 

payments directly to landlords on behalf of 136 very low-income 

households in 2013.

Multnomah County reported one program—the Short-Term Rental 

Assistance Program—that combined federal, state, county, and local 

resources to provide payments to households that were homeless or at 

risk of becoming homeless. The program was designed to assist 

residents facing short-term emergencies and at risk of homelessness with 

rent or mortgage payments, deposits and application fees, move-in costs, 

and support services. From 2006 through 2010, 6,700 households 

received an average of nearly 3 months of rental assistance through the 

program. More recently in 2013, 2,655 households received assistance 

through nongovernmental community agencies contracted to administer 

the program. The program consolidated four locally funded short-term 

housing programs to improve efficiency and results.

Portland combined federal and local resources in its efforts to help 

Portland residents find a safe, decent, and affordable home to rent or own 

in a livable neighborhood. To address these goals, Portland used tax 

increment financing, local tax and permit fees exemptions, and provided 

financial incentives to housing developers and nonprofits to develop or 

rehabilitate housing for low-income households. For example, the 

Housing Investment Program used federal HOME and CDBG funds with 

local tax increment financing to provide grants and loans to private and 

nonprofit developers to construct or rehabilitate affordable housing units. 

From 2011 through 2013, the program provided over $83 million to 36 

different development and rehabilitation projects. The projects ranged 

from remodeling older apartment buildings to constructing new buildings. 

Nearly all of the projects supported residents at or below 60 percent of 

median income and many projects also provided support services, such 

as transitions from homelessness or drug and alcohol treatment. Table 5 

shows the state and local low-income rental assistance and rental 

housing development programs reported by the participating audit offices 

in Oregon jurisdictions that included state or local funding and incentives.
Page 17 GAO-15-645 Affordable Rental Housing 

Table 5: Low-Income Rental Assistance and Housing Development Programs in Oregon Jurisdictions

Jurisdiction Program

Funding 

source Description

Oregon Low Income Rental 

Assistance

State

Federal

Assists very low-income households by providing rental assistance to those in 

danger of losing their rental unit because of unpaid rent.

Elderly Rental 

Assistance

State

Federal

Provides eligible taxpayers with rental assistance from the Department of Revenue.

Multnomah 

County

Short-Term Rental 

Assistance Program

Federal

State

Local

Provides time-limited financial assistance to households that are homeless or at risk 

of homelessness.

Portland Housing Investment 

Program

Federal

Local

Provides grants and loans to private and nonprofit developers to construct or 

rehabilitate affordable housing units.

System Development 

Charge Exemption 

Program

Fee 

Exemption

Exempts developers from fees that would otherwise be paid to city bureaus during 

project permitting to promote the development of affordable rental housing.

Residential Tax 

Exemption Program

Tax 

Exemption

Provides ongoing tax exemptions for nonprofit rental housing providers and up to 

10-year tax exemptions for new multifamily housing.

Source: GAO analysis of information reported by participating audit offices in Oregon. | GAO-15-645

Note: Portland’s fee and tax exemption program are financial incentives measured in foregone 

revenue and are not sources of funding for developers of affordable housing.

Denver reported one rental housing development program that was not 

solely funded by federal funds (see table 6). The program combined 

federal and local resources to address a shortage of affordable rental 

housing. The City and County of Denver Audit Office’s audit of affordable 

housing found that the city’s largest source of funding was CDBG; 

however, only a portion of that funding was used for affordable housing.22

 22City and County of Denver Office of the Auditor, Denver Affordable Housing 

Performance Audit: (Denver, CO: Nov. 2014.

Denver auditors noted that the HOME program is the primary federal 

source of funding for affordable housing. Denver’s Rental Development 

program combined HOME and CDBG resources with local resources to 

provide financing for affordable housing developers. In 2014, the program 

developed or preserved 506 affordable rental housing units. See table 6 

for the description of Denver’s program that includes local funding and 

provides financing for developers of affordable rental housing.

The City and County of

Denver Low-Income Rental 

Development Program
Page 18 GAO-15-645 Affordable Rental Housing 

Table 6: Denver Low-Income Rental Development Program 

Program Funding source Description

Rental Development Federal

Local

Provides funding to developers for the acquisition, rehabilitation, or new construction of 

rental housing. Other activities within this program include nonprofits applying to adapt 

existing housing so that it meets Americans with Disabilities Act standards.

Source: GAO analysis of information reported by Denver Audit Services. | GAO-15-645

As noted earlier, we found that 20 federal government entities 

administered 160 programs, tax expenditures, and other tools that 

supported homeownership and rental housing in fiscal year 2010.23 We 

also found instances of fragmentation and overlap throughout these 

programs.24 For example, there was overlap in 8 programs and tax 

expenditures that provided assistance for rental property owners, such as 

separate project-based rental assistance programs provided by HUD and 

the United States Department of Agriculture (USDA) Rural Housing 

Service (RHS) and a program that accelerated depreciation on rental 

housing administered by IRS.25

Senior HUD Policy Development and Research officials stated that there 

is fragmentation in developing and providing affordable rental housing 

because there are several programs that fund the development and 

provision of housing. Moreover, major affordable housing programs are 

overseen by three offices within HUD, IRS, and USDA RHS, which can 

Additionally, there was overlap in the 

products offered by RHS and HUD (rental assistance and mortgage 

credit), the functions they perform (portfolio management and 

preservation), and the geographic areas they serve. We concluded that 

examining the benefits and costs of housing programs and tax 

expenditures that address the same or similar areas, and potentially 

consolidating them, could help mitigate overlap and fragmentation and 

decrease costs.

 23GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings and Enhance Revenue, GAO-12-342SP (Washington 

D.C.: Feb. 28, 2012).

24Fragmentation occurs when more than one federal agency—or more than one 

organization within an agency—is involved in the same broad area of national need and 

there may be opportunities to improve how the government delivers these services. 

25Overlap is when there are programs that have similar goals, devise similar strategies 

and activities to achieve those goals, or target similar users.

Fragmentation and 

Overlap in Federal 

Housing Programs and 

Indications of 

Fragmentation and 

Overlap in Programs 

Reported by Participating 

Audit Offices May Lead to 

Inefficiencies
Page 19 GAO-15-645 Affordable Rental Housing 

also contribute to fragmentation, overlap, and duplication.26

In addition to the fragmentation and overlap we previously found among 

the federal programs discussed above, we and the participating audit 

offices also found indications of fragmentation and overlap in the lowincome rental assistance and housing development programs that 

participating audit offices in Oregon and Washington reported in their 

completed audits.

The officials 

also noted that there is fragmentation, overlap, and duplication among 

some of the rules that govern these programs, which the Rental Policy 

Working Group has tried to reconcile.

27 It is important to note that while fragmentation and 

overlap is often associated with inefficiencies or opportunities for cost 

savings, we have found that there are instances of positive effects. For 

example, positive effects may occur where the provisions of benefits, 

services, or products help meet program goals and objectives.28

In the programs reported by participating audit offices in Oregon 

jurisdictions, we and the participating audit offices found indications of 

fragmentation among programs that provided financial assistance to 

households at risk of being homeless, as well as indications of 

fragmentation and overlap among programs that provided financial 

incentives to affordable housing developers. First, Oregon and 

Multnomah County each had a program that included providing financial 

assistance to households that are at risk of becoming homeless, which 

may be an indication of fragmentation, as the jurisdictions are involved in 

the same broad area. Second, three Portland programs provided financial 

incentives to affordable housing developers—which may be an indication 

of fragmentation. While these programs included different types of 

financial incentives to housing developers, they may overlap, as they had 

 26Duplication occurs when two or more agencies or programs are engaged in the same 

activities or provide the same services to the same beneficiaries.

27Fragmentation, in the context of intergovernmental programs, occurs when more than 

one agency—or more than one organization within an agency—is involved in the same 

broad area and opportunities exist to improve service delivery.

28See GAO, Fragmentation, Overlap, and Duplication: An Evaluation and Management 

Guide GAO-15-49SP (Washington, D.C.: April 14, 2015). The guide highlights the 

additional steps to evaluate the indications of fragmentation and overlap found in the 

reported programs. For example, more work would be needed to determine whether there 

are any benefits or inefficiencies resulting from the existing indications of fragmentation or 

overlap in the programs reported by the participating audit offices.
Page 20 GAO-15-645 Affordable Rental Housing 

similar eligibility for households renting the units. There was 

fragmentation, overlap, and duplication in rental assistance programs 

administered by state agencies, according to an Oregon Secretary of 

State’s Audits Division report.29 The audits division reported that four 

state agencies had programs with a mission that focused on rental 

assistance, which is an indication of fragmentation. Also according to the 

report, three programs overlapped in providing rent assistance services 

and two of these programs also showed duplication, as both provided 

rental assistance to very low-income beneficiaries. In addition, a report by 

the Office of the Multnomah County Auditor stated that although the depth 

of services often differs, some of the programs in Multnomah County 

offered similar types of housing assistance. For example, 15 county 

programs included rental assistance. The report stated that multiple 

programs offered similar types of housing assistance, which indicates that 

there may be some opportunities to streamline services toward greater 

capacity.30

In the programs reported by participating audit offices in Washington 

jurisdictions, we and the participating audit offices also found that 

fragmentation and overlap may exist among several of the programs that 

provided rental assistance to low-income households at risk for 

homelessness. First, fragmentation may exist among the state, King 

County, and Seattle rental assistance programs for low-income families at 

risk of homelessness because each jurisdiction is generally involved in 

funding these types of programs. Each jurisdiction funded rental 

assistance programs implemented by local and community-based 

nonprofit organizations. Second, there may be overlap in each 

jurisdiction’s homeless prevention programs as these programs had 

similar goals—preventing low-income households from becoming 

homeless—and targeted similar low-income beneficiaries. Such overlap 

could impact the efficiency and delivery of services.

Fragmentation and overlap may also exist in programs that provided 

financial assistance to developers of affordable housing that targeted a 

 29Oregon Secretary of State’s Audits Division, Oregon Housing and Community Services 

Department: Program Duplication, Overlap and Fragmentation, Report 2013-16 (Salem, 

OR: July 2013).

30Office of the Multnomah County Auditor, Housing Inventory Special Report (fulfilling note 

from FY-2015 Budget work session), (Portland, OR: Oct. 22, 2014).
Page 21 GAO-15-645 Affordable Rental Housing 

similar range of low-income beneficiaries reported by participating audit 

offices in Washington. Fragmentation may exist because each jurisdiction 

was generally involved in providing funding for developing affordable 

rental housing. Such fragmentation could lead to less efficient delivery of 

affordable rental housing financing. Overlap may also exist because each 

jurisdiction had programs that provided funding for the development of 

low-income affordable housing. These programs had similar target 

beneficiaries and goals which were to develop affordable rental housing 

for low-income households. This potential overlap could also lead to 

inefficiencies and ineffective service delivery.

Inefficiencies as a result of fragmentation, overlap and duplication can 

result at multiple levels. Our body of work has found that agencies often 

can realize a range of benefits and savings from addressing issues 

related to fragmentation, overlap, and duplication, such as improved 

customer service and decreased administrative burdens and cost.31 We 

have also noted that interagency mechanisms or strategies to coordinate 

programs that address crosscutting issues may reduce potentially 

fragmented, overlapping and duplicative efforts.32

 31GAO, 2015 Annual Report, Additional Opportunities to Reduce Fragmentation, Overlap 

and Duplication and Achieve Other Financial Benefits, 

As previously 

GAO-15-404SP (Washington D.C.: 

Apr. 14, 2015).

32GAO, Managing for Results: Key Considerations for Implementing Interagency 

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

The Rental Policy 

Working Group and 

Participating Audit 

Offices Reported 

Various Efforts to 

Collaborate, but Also 

Reported New 

Opportunities and 

Challenges

The Rental Policy Working 

Group Collaborates with 

State and Local 

Governments in Multiple 

Areas
Page 22 GAO-15-645 Affordable Rental Housing 

discussed, one of the areas we have reviewed and found opportunities to 

reduce fragmentation and overlap in the area of housing assistance.33

The federal government plays a major role in ensuring the availability of 

decent, safe, and affordable rental housing through a variety of singleand multifamily programs that provide rental assistance, public housing, 

and tax expenditures. Numerous agencies administer fragmented 

programs, and previous assessments have shown that some programs 

overlap. For example (as we previously reported), twenty different entities 

administered 160 programs, tax expenditures, and other tools that 

supported homeownership and rental housing in fiscal year 2010.34

In order to better coordinate federal rental policy, the Rental Policy 

Working Group (RPWG) was established in July 2010 by the White 

House Domestic Policy Council (DPC) and is composed of 

representatives from DPC, HUD, Treasury, USDA

Selected rental assistance programs for tenants administered by HUD, 

Treasury, IRS, and USDA are discussed above.

35, National Economic 

Council, and Office of Management and Budget (OMB).36 The RPWG 

meets monthly or bimonthly under the auspices of the Domestic Policy 

Council to discuss its initiatives. The purpose of RPWG is to better align 

rental requirements across programs and tax expenditures, and thereby 

increase the effectiveness of federal rental policy and improve participant 

outcomes. In prior work we found that through interagency collaboration, 

agencies can improve outcomes and leverage each other’s’ resources to 

obtain additional benefits that would otherwise be unavailable.37

 33GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue, 

The 

RPWG does not receive a separate budget, and the agency 

GAO-12-342SP (Washington 

D.C.: Feb. 28, 2012). 

34GAO-12-554.

35HUD, USDA, and Treasury programs have the shared purpose of financing the 

development of new rental units or preserving existing units through refinancing or 

rehabilitation. 

36Established by Executive Order in 1993, the Domestic Policy Council (DPC) coordinates 

the domestic policy-making process in the White House, ensures that domestic policy 

decisions and programs are consistent with the President’s stated goals, and monitors 

implementation of the President’s domestic policy agenda. The DPC is chaired by the 

President and is composed of officials from Executive departments and agencies.

37GAO, Results-Oriented Government: Practices that Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
Page 23 GAO-15-645 Affordable Rental Housing 

representatives participate in the group’s activities as part of fulfilling their 

responsibilities at their respective agencies. According to the group’s 

established guiding principles, its efforts have centered on administrative 

changes that

• responded to the concerns of external stakeholders (rental housing 

owners, developers, and managers, and state and local housing 

agency officials);

• required minimal statutory action;

• were realizable at little or no cost or through education, outreach, or 

the issuance of new guidance or rules; and

• helped create cost and time savings for all parties.

In 2010, the working group solicited recommendations for improved rental 

policy coordination from external stakeholders, in which administrative 

changes could increase the effectiveness of federal rental policy and 

improve participant outcomes, such as overlapping and duplicative 

administrative property inspection requirements. Within the working 

group, interagency teams considered the recommendations, reviewed 

current policies, and identified opportunities for greater federal alignment, 

increased overall programmatic efficiency, and reduced costs and 

regulatory burdens. For example, stakeholders noted inefficiencies when 

a multifamily housing project has multiple layers of assistance (such as 

subsidies, tax expenditures, or mortgage insurance) from one or more 

federal agencies. The working group identified 10 initiatives aimed at 

reducing unnecessary program regulations, lessening administrative 

barriers so that developers and property owners more easily can 

participate in programs, reducing duplicative administrative actions to 

reduce costs for agencies and program participants, and increasing 

coordination to allow better targeting of agency resources.38

 38The ten initiatives includes: (1) physical inspections,(2) subsidy layering review, (3) 

income reporting and definitions, (4) market studies standards, (5) financial reporting; (6) 

common energy efficiency requirements, (7) appraisal primer, (8) capital needs 

assessment, (9) data sharing on owner defaults, and (10) fair housing compliance 

enforcement.

According to 

HUD officials, these initiatives are designed to improve states’ capacity to 

preserve affordable rental housing and the “work streams” under the 
Page 24 GAO-15-645 Affordable Rental Housing 

initiatives represent HUD’s current efforts to streamline processes and 

eliminate redundancies.

We have previously concluded that the efforts of the RPWG have been 

consistent with many key collaborative practices and we have highlighted 

specific examples of successful collaboration.39 For example, we 

highlighted the group’s efforts to develop an inventory of federal programs 

to promote a better understanding of government-wide rental programs 

and to make decisions about the coordination of related programs across 

agency lines and between levels of government.40 However, we have also 

concluded that the efforts of the group have not taken full advantage of 

opportunities to reinforce agency accountability for collaborative efforts 

through the agencies’ annual and strategic plans, nor has it expanded its 

guiding principles to evaluate areas requiring statutory action to generate 

savings and efficiencies.41 Methods to build accountability for 

collaborative efforts include documenting those efforts (and associated 

goals, strategies, roles and responsibilities, actions or measures to be 

taken, and timelines) in agencies’ annual and strategic plans. We 

recommended that to further improve HUD, USDA, and Treasury’s efforts 

through the RPWG to consolidate and align certain requirements in 

multifamily housing programs, the RPWG should take steps to document 

collaborative efforts in strategic and annual plans to help reinforce agency 

accountability for these efforts.42

 39We previously identified the following key collaborative practices that can help enhance 

and sustain collaboration among federal agencies: (1) define and articulate a common 

outcome; (2) establish mutually reinforcing or joint strategies; (3) identify and address 

needs by leveraging resources;(4) agree on roles and responsibilities; (5) establish 

compatible policies; (6) develop mechanisms to monitor, evaluate, and report on results;

(7) reinforce agency accountability for collaborative efforts through agency plans and 

reports; and (8) reinforce individual accountability for collaborative efforts through 

performance management systems. 

According to HUD officials, as of July 

2015, HUD’s strategic planning and annual performance plan and report 

referenced the RPWG and highlighted its work in improving interagency 

collaboration in reducing administrative requirements and complexity 

40GAO, Managing For Results: Implementation Approaches Used to Enhance 

Collaboration in Interagency Groups, GAO-14-220 (Washington, D.C.: Feb. 14, 2014).

41GAO-12-554.

42GAO-12-554.
Page 25 GAO-15-645 Affordable Rental Housing 

within and between federal rental housing programs to help achieve the 

larger goal of delivering more affordable housing at reduced cost.43

The RPWG has collaborated with states and localities on four of its 

initiatives: the Physical Inspections Pilot; Subsidy Layering Review (SLR) 

Pilot; income reporting and definitions; and market study standards. To 

achieve more immediate results, the RPWG started with those initiatives 

that required no statutory action. The physical inspection pilot and SLR 

pilot were implemented first as the redundancies were “glaringly obvious,”

according to HUD’s most recent progress report.44

Physical Inspections: The RPWG launched the physical inspections 

pilot in six states in November 2011 to test the feasibility of conducting a 

single, recurring physical inspection for jointly subsidized multifamily

housing to satisfy all agencies’ inspection requirements.

For example, multiple 

property inspections have been required when funding comes from two or 

more agencies. The purpose of the pilots is to allow federal, state, local, 

and private partners to support and test local solutions that lead to 

program efficiencies.

45 This pilot was 

designed to eliminate unnecessary physical inspections at rental housing 

projects subsidized by more than one housing agency, thereby saving 

scarce local, state, and federal resources while reducing the burden on 

affordable housing providers and low-income tenants. As we previously 

reported, USDA, HUD, and Treasury worked with their housing finance 

agency counterparts at the state level to eliminate duplicative physical 

inspections of rental housing subsidized through more than one public 

source.46

 43U.S. Department of Housing and Urban Development, FY 2013 Annual Performance 

Report, FY 2015 Annual Performance Plan (Washington: D.C.: July 2014).

According to a RPWG briefing, participation increased from 6 

states to 26 states in 2014 and the pilot avoided 871 duplicative 

44RPWG, Rental Alignment Pilots: Interim Progress Report (Washington, D.C.: August 

2012). 

45As part of the pilot, state-level teams in Michigan, Minnesota, Ohio, Oregon, 

Washington, and Wisconsin agreed to merge all required physical inspections into a single 

inspection protocol with a defined frequency at each multifamily property. The details of 

this agreement are included in a Memoranda of Understanding (MOU) signed in each 

state. In addition, the MOUs identify the lead agency for each inspection, determine which 

pilot properties to inspect, and establish inspection frequency, follow-up, and informationsharing protocols.

46GAO-14-220.
Page 26 GAO-15-645 Affordable Rental Housing 

inspections from 2013 to 2014. In 2014, state inspectors were provided 

with in-person and online training. In 2015, the RPWG is planning to 

expand the scope to 31 states, perform over 1,000 inspections and 

provide federal and state agencies the ability to share inspections 

electronically.47

Subsidy Layering Review: The RPWG launched the SLR pilot in seven 

states in 2011 to coordinate the subsidy layering reviews that various 

federal and state housing program administrators conduct with the aim of 

eliminating redundancy in the underwriting and review process.

According to Treasury and IRS officials they participate in 

biweekly pilot status meetings with federal, state, and local officials.

Treasury and IRS provide federal tax advice for the pilot, such as issuing 

a notice affirming that HUD (or its agent) could conduct inspections on 

behalf of the state housing finance agency (or its authorized delegate). In 

addition, IRS, Treasury, and HUD officials gave presentations that 

included the physical inspections pilot at state housing association 

conferences.

48 Nearly 

all federal housing programs have statutory requirements requiring the 

administering agencies to confirm that at the time of making a grant or 

subsidized loan, the total amount of subsidy being provided by public 

sources does not exceed eligible costs. According to HUD’s most recent 

progress report, an RPWG survey of participating states found that as of 

June 2012, two of the six states that responded to the survey had 

completed SLRs under the alignment MOU, and 24 SLRs had been 

conducted in those two states.49

 47The goal of the 2015 Physical Inspections Pilot is to build on the successes of 2014 

through the expansion to 31 states and through an increased focus on technology and 

policy solutions that will create the ability to scale-up in 2016 and sustain alignment. The 

31 states are: California, Colorado, Delaware, Georgia, Illinois, Indiana, Kansas, 

Kentucky, Louisiana, Massachusetts, Michigan, Minnesota, Missouri, Nevada, New 

Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, Rhode 

Island, South Carolina, Tennessee, Texas, Utah, Virginia, Vermont, Washington, 

Wisconsin, and West Virginia. 

According to this report, most 

respondents said their offices did not undergo or plan to make any 

staffing changes, either temporary or permanent, to conduct or review 

SLRs under the pilot program. Survey respondents reported they are 

48State-level teams in Michigan, Nevada, North Carolina, Ohio, Pennsylvania, South 

Carolina, and Wisconsin have implemented pilots to align subsidy layering reviews. 

49RPWG, Rental Alignment Pilots: Interim Progress Report (Washington, D.C.: August 

2012).
Page 27 GAO-15-645 Affordable Rental Housing 

satisfied with the current guidelines established in the SLR-MOU and the 

level of convenience or perceived convenience in conducting and 

reviewing SLRs under the SLR-MOU.

Income Reporting and Definitions: The RPWG has also solicited input 

from states on the income reporting and definitions and market study 

standards initiatives. Various federal programs that support affordable 

housing have slightly differing requirements for income certifications and 

require property managers and owners to submit information on different 

forms or through different processes, which may lead to inconsistencies 

in determinations of income and rents or administrative burden. The 

income reporting and definitions initiative intends to increase education 

and outreach, to develop a common form for tenant income certification, 

and to promote single (annual) recertification that would allow owners to 

coordinate recertifications and satisfy all program requirements at once.

For the income reporting and definitions initiative, according to HUD 

officials, they solicited input on differing federal affordable housing 

requirements for income certifications from 10 state housing agency 

officials, the National Council of State Housing Agencies (NCSHA), and 

the National Affordable Housing Management Association (NAHMA).50

Market Study Standards: The market study standards initiative was 

undertaken in 2010 from stakeholders concerns that there was no 

national standard of practice for market studies and no broadly 

NCSHA recommended further discussion of this issue to facilitate better 

access to income information. NAHMA supports the alignment of varying 

income definitions, as well as ways to reduce State-to-State variability in 

compliance requirements. For example, with respect to the LIHTC 

program, NAHMA members agree that “the absence of cohesive, specific, 

mandatory Federal guidance means that multi-State developers incur 

extra costs for, among other items, software and staff training.”

 50NCSHA represents state housing agencies and its work centers on three federal 

programs—Housing Bond programs, the Low Income Housing Tax Credit (LIHTC), and 

the HOME Investment Partnerships (HOME) program. NCSHA is the principal advocate 

for both Housing Bonds and the LIHTC and is the principal state advocate for HOME. 

NAHMA advocates on behalf of multifamily property managers and owners whose mission 

is to provide quality affordable housing. NAHMA’s mission is to support legislative and 

regulatory policy that promotes the development and preservation of decent and safe 

affordable housing. In addition NAHMA represents 20 regional, state and affordable 

housing management associations. 
Page 28 GAO-15-645 Affordable Rental Housing 

acknowledged “keeper” of such standards. The initiative intends to 

coordinate USDA and HUD guidance on market studies, provide ongoing 

support and assistance to the National Council of Affordable Housing 

Market Analysts and other industry advocates, and promote market study 

literacy among housing and community development practitioners. For 

the market study standards initiative, according to HUD officials, 

comments were solicited from state associations. According to a RPWG 

document, the absence of a fully developed national practice standard 

and guide for market analyses results in a wide disparity in the content, 

methodology, quality, and reliability of studies that are used for three 

primary purposes:

• By State Housing Finance Agencies (HFAs) to allocate Low Income 

Housing Tax Credits and to establish feasibility for new development 

of rental housing;

• By HUD-Federal Housing Administration (FHA) and USDA-Rural 

Development (RD) lenders and field staff to underwrite applications 

for mortgage insurance or direct loans; and

• By developers, investors, and lenders to identify investment 

opportunities in rental housing.

Among states, practice varies widely, with some states prescribing 

methodologies, while others have only loosely defined standards. In spite 

of existing guidance provided by HUD-FHA and USDA-RD, studies 

prepared in support of applications for Federal mortgage insurance and 

direct loan programs are inconsistent in content, methodology, quality, 

and reliability. According to RPWG documents, the effects of disparate 

market study practice and quality include confusion, loss of time and extra 

expense for developers and owners who pay for market studies (that may 

add little value to the quality of real estate decision making), and higher 

and/or unforeseen risks of failure, with losses for developers, investors, 

and lenders.

The initiative intends to coordinate USDA and HUD guidance on market 

studies, provide ongoing support and assistance to the National Council 
Page 29 GAO-15-645 Affordable Rental Housing 

of Housing Market Analysts (NCHMA)51

RPWG’s collaboration across federal, state, and local agencies has 

brought new opportunities to increase efficiencies and program 

performance. According to HUD officials, progress has been made under 

the current administration on intra- and interagency collaboration primarily 

through the RPWG. For example, the RPWG “pushed hard” on 

coordinating SLR’s and helped support state interagency agreements in 

Minnesota and Ohio. HUD officials also stated that the RPWG has 

eliminated a number of collaboration challenges at the federal level. For 

example, it created a venue and mechanism to bring uniformity to 

different approaches, where possible. HUD and Treasury officials stated 

that under the current administration, and primarily through the efforts of 

the RPWG, progress has been made toward improving intra- and 

interagency collaboration. They also stated HUD’s leadership has been 

very visible in streamlining efforts through the RPWG and has 

encouraged its field staff to engage with state and local administering 

agencies on streamlining and efficiency efforts. For example, Treasury 

officials stated, that there are significant interagency collaboration efforts 

occurring between Treasury, IRS, HUD, and USDA to develop potential 

legislative proposals for streamlining LIHTC requirements, and which will 

be included in Treasury’s annual “General Explanations of the 

and other industry advocates, 

and promote market study literacy among housing and community 

development practitioners. For the market study standards initiative, 

according to HUD officials, comments were solicited from state 

associations. These comments were mixed. For example, the NCHMA 

supports the RPWG assessment that the effects of disparate market 

study practices and quality can lead to an array of problems, running from 

confusion to a worst case scenario of financial failure. NCHMA also 

supports the RPWG’s assessment that an independent ‘keeper entity’ for 

market study practices standards would be beneficial to the industry. In 

contrast, the NCSHA does not support the adoption of a national standard 

of practice of market studies and urged the RPWG to refrain from 

imposing a “one size fits all” national model as it would not work in all 

markets.

 51The NCHMA, formerly the National Council of Affordable Housing Market Analysts, 

provides technical guidance and presents opportunities for market analysts and 

underwriting professionals to discuss current issues, develop professional networks, and 

gain cutting-edge information with the goal of improving the quality of residential real 

estate market studies.
Page 30 GAO-15-645 Affordable Rental Housing 

Administration’s Revenue Proposals” (also known as the “Green Book”).

In addition, IRS and Treasury officials stated that RPWG provides state 

associations with a single federal resource to communicate about lowincome housing issues.

All of the participating audit offices reported that they were collaborating 

with at least one level of government. Oregon, Portland, and Multnomah 

County all reported collaborating with local governments. For example, 

Multnomah County officials reported that they had an intergovernmental 

agreement with other local jurisdictions that outlined each jurisdiction’s 

roles in the Short Term Rental Assistance Program. The leaders of the 

local jurisdictions met once a month to discuss the program. As part of 

this arrangement, the jurisdictions shared information on outcomes, 

investment, management, and risk. For example, each jurisdiction has 

made a minimum funding commitment to the program and when one of 

the jurisdictions has trouble meeting this commitment, the group ensures 

that the funding remains stable through shared investment. Multnomah 

County officials also reported that this collaboration has resulted in more 

people served, in maximized resources and in better outcomes. In 

addition, Oregon also reported collaborating with other state departments 

to coordinate program eligibility.

Washington and King County reported collaborating with all three levels 

of government, and Washington reported that Seattle collaborated with 

the state and local levels. For example, Washington reported that Seattle 

and the King County Housing Authority centralized their intake and 

assessment process for families. This enabled families to fill out just one 

application, which was used by both jurisdictions. The information was 

stored in a shared database. In another example, Washington 

collaborated with federal, state, and local governments so that one 

agency conducted inspections and monitoring activities and wrote a 

report for each project, which was accepted by all of the funders. As a 

result, inspection and monitoring activities did not need to be done 

separately for each funder. In addition, Washington reported that Seattle 

officials stated that collaboration with other public and private agencies 

allowed for more resource sharing, innovative strategies, and better 

leveraging of limited available funding.

Denver reported collaborating with local, state, and federal levels of 

government. For example, officials reported that the Denver Housing 

Authority recently developed a 15-member Neighborhood Development 

Collaborative to lobby for affordable housing initiatives at the state and 

Participating Audit Offices 

Reported Various Efforts 

to Collaborate with Local, 

State, and Federal 

Jurisdictions
Page 31 GAO-15-645 Affordable Rental Housing 

federal levels. The officials also reported that Denver agencies 

collaborated with local, state, and federal agencies through a stakeholder 

group that met quarterly to discuss each jurisdiction’s upcoming housing 

projects to make sure that all participants were aware of the housing 

activities state-wide and to coordinate where necessary.

Oregon, Multnomah County, Washington, Seattle and Seattle Housing 

Authority, and King County and the King County Housing Authority also 

reported barriers to collaboration. These barriers are related to the 

absence of practices that we previously found can help enhance and 

sustain collaboration.52

 52

Oregon, King County, Washington, and Seattle 

and Seattle Housing Authority reported that incompatible policies, 

procedures and other means to operate across agency boundaries were 

barriers. For example, Oregon reported that the Oregon Housing and 

Community Services department systems did not communicate with other 

state systems. Hence the client has to navigate the bureaucracy 

themselves and interact with multiple departments. In addition, 

Multnomah County, Washington, and the King County Housing Authority 

reported that a lack of defining and articulating a common outcome or 

purpose was a barrier. For example, Multnomah County reported that 

there can be a lack of alignment among the collaborating jurisdictions’

priorities and core mission. Defining a common purpose is necessary to 

overcome significant differences in agency missions, cultures, and 

established ways of doing business.

GAO-06-15.
Page 32 GAO-15-645 Affordable Rental Housing 

At the federal level, HUD and IRS reported on the performance of rental 

assistance programs to varying extents. HUD established a strategic goal 

to meet the need for quality affordable rental homes in its Strategic Plan 

2014-2018.53 To help it meet this goal, HUD set two strategic objectives. 

The first of these objectives is to ensure sustainable investments in 

affordable rental housing. For this objective, in the FY 2013 Annual 

Performance Report, FY 2015 Annual Performance Plan (performance 

report), HUD has not established any related performance goals.54

 53U.S. Department of Housing and Urban Development, Strategic Plan 2014-2018

(Washington D.C: April 2014).

According to OMB guidance, strategic objectives are tracked through a 

suite of performance goals. The guidance defines a performance goal to 

include a performance indicator, a target and a timeframe. In its 

performance report, HUD identifies fiscal years as timeframes and three 

performance indicators: the number of households that experience “worst 

case housing needs,” the proportion of very low-income renters facing 

severe rent burdens, and the percentage of rental units built in the 

preceding 4 years that had rents below $800. However, HUD did not 

establish targets for these indicators in fiscal years 2014 and 2015 and 

states that these indicators are for tracking only. Without related targets, 

54U.S. Department of Housing and Urban Development, FY 2013 Annual Performance 

Report, FY 2015 Annual Performance Plan (July 2014).

HUD, IRS and 

Participating Audit 

Offices Reported 

Varying Levels of 

Performance 

Reporting, but There 

Is Incomplete 

Information on 

Collective 

Performance

HUD, IRS and 

Participating Audit Offices 

Reported Varying Levels 

of Performance Reporting
Page 33 GAO-15-645 Affordable Rental Housing 

agencies may be unable to demonstrate to key stakeholders, including 

the Congress, program partners, and the public, that they are tracking 

progress frequently enough to address any performance issues as they 

arise. In addition, the performance goals in the annual performance plans 

provide the Congress with a basis for comparing a program’s proposed 

level of performance against its actual program performance and can help 

the Congress strengthen government accountability.

The other strategic objective established in HUD’s Strategic Plan 2014-

2018 is to preserve quality affordable rental housing, where it is needed 

most, by simplifying and aligning the delivery of rental housing programs. 

For this objective, HUD has established an agency priority goal of 

preserving and expanding affordable rental housing programs to serve an 

additional 121,000 households between October 1, 2013 and September 

30, 2015. The performance report lists six performance indicators to track 

its performance on the agency priority goal: (1) number of families served 

through HUD rental assistance, (2) number of units converted using the 

Rental Assistance Demonstration: first component,55 (3) number of units 

converted using the Rental Assistance Demonstration: second 

component,56

HUD has recently reported on progress toward its strategic objectives and 

agency priority goal on Performance.gov. For the first strategic objective 

(to ensure sustainable investments in affordable rental housing), HUD 

reported that in consultation with OMB, HUD has highlighted this 

objective as a focus area for improvement. HUD reported that it is 

pursuing housing finance legislation, which could provide a substantial 

funding source for the Housing Trust Fund. However, the legislation is not 

moving forward, which is a significant challenge to HUD in achieving this 

objective, according to HUD. HUD reported that it is planning to refine the 

existing metrics to provide a better picture of rental housing availability. In 

(4) Housing Choice Voucher utilization rate, (5) Public 

Housing occupancy rate, and (6) Project Based Rental Assistance 

occupancy rate.

 55The first component of the Rental Assistance Demonstration allows projects funded 

under the public housing and Section 8 Moderate Rehabilitation programs to convert their 

assistance to long-term, project-based Section 8 rental assistance contracts.

56The second component of the Rental Assistance Demonstration allows owners of 

projects funded under the Rent Supplement, Rental Assistance Payment, and Mod Rehab 

programs to convert tenant protection vouchers to project-based vouchers.
Page 34 GAO-15-645 Affordable Rental Housing 

addition, HUD did not report on the performance of the three indicators 

related to this objective.

For the second strategic objective (to preserve quality affordable rental 

housing by simplifying and aligning the delivery of rental housing 

programs), HUD reported on Performance.gov that it served an additional 

36,128 households, which is 74 percent of its target for the agency priority 

goal for fiscal year 2014. HUD also reported on the actual performance 

for five of the six indicators.57

Table 7: Agency Priority Goal Indicators, Reported Performance, and Targets for 2014

As shown in table 6 below, HUD reported 

meeting or exceeding two of the five targets. HUD reported that for the 

three indicators that HUD did not meets its targets, challenges included 

an uncertain fiscal environment and slower than expected conversion 

activity.

Indicator Reported Target Met the Target

Number of families served through HUD rental assistance 5,511,132 5,523,223

Number of units converted using the Rental Assistance Demonstration: First Component 6,167 15,000

Number of units converted using the Rental Assistance Demonstration: Second 

Component

7,511 5,161 X

Public Housing Occupancy Rate 96% 96% X

Housing Choice Voucher budget utilization rate 96.93% 97.56%

Source: GAO analysis of information on performance.gov. | GAO-15-645

Note: All of the indicators are reported for fiscal year 2014, except for the Housing Choice Voucher 

budget utilization rate, which is calendar year.

However, HUD has not yet published a report on its 2014 performance 

results consistent with requirements in the GPRA Modernization Act of 

201058 and OMB guidance which required it to be published in February 

2015.59

 57The indicator that is not included is the Project Based Rental Assistance occupancy 

rate, which is the only indicator in the performance plan that does not have a target for 

fiscal year 2014.

According to HUD officials as of June 2015, the 2014 

58Pub. L No. 111-352, 124 Stat. 3866 (Jan. 4, 2011). The acronym “GPRA” in the act’s 

title refers to the Government Performance and Results Act of 1993. Pub. L. No. 103-62, 

107 Stat. 285 (Aug. 3, 1993).

59OMB, Circular No. A-11, Preparation, Submission and Execution of the Budget, pt 6, § 

260 (August 2012). OMB updated this guidance in its July 2013 and July 2014, and June 

2015 revisions to Circular No. A-11.
Page 35 GAO-15-645 Affordable Rental Housing 

performance report was being reviewed by OMB. Moreover, HUD’s 

performance report for fiscal year 2013 was not published until July 2014; 

it was required to be published in March 2014, concurrent with the 

publication of the budget, per OMB guidance. Measuring performance 

allows organizations to track their progress toward goals and gives 

managers crucial information on which to base decisions.

We reported in 2012 that information on the overall effectiveness of the 

CDBG and HOME programs is limited.60

In addition, we previously found that IRS does not set goals or assess 

performance for LIHTC.

HUD has faced difficulties in 

evaluating the impact of the CDBG and HOME block grant programs, 

because, among other things, such an evaluation would have to compare 

neighborhoods that received assistance with those that did not. In 

addition, according to HUD officials and researchers that we spoke with 

previously, the diversity of activities and lack of statutory targeting 

requirements makes it difficult to collect information to assess the overall 

impact of these programs. Our previous work has also identified the 

difficulties of evaluating the impact of block grant programs that do not 

have a uniform package of desired outcomes across the country and the 

common problem of attributing differences in communities’ outcomes to 

the effect of a program without controls for other explanations.

61 We also previously found that data availability 

was a challenge in assessing tax expenditure performance.62

 60GAO, HUD Has Identified Performance Measures for Its Block Grant Programs, but 

Information on Impact is Limited, 

IRS collects 

limited data that it needs to administer and enforce the code and does not 

use this information to assess the housing production program, such as 

number and location of LIHTC projects. Although HUD’s direct role in the 

LIHTC program is limited, they have collected project-level information on 

the program since 1996 because of the importance of LIHTC as a source 

of funding for affordable housing. We suggested that the Congress 

GAO-12-575R (Washington D.C.: May 15, 2012). 

61GAO, Low-Income Housing Tax Credit: Joint IRS-HUD Administration Could Help 

Address Weaknesses in Oversight, GAO-15-330 (Washington D.C.: July 15, 2015).

62GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save 

Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011).
Page 36 GAO-15-645 Affordable Rental Housing 

consider designating HUD as a joint administrator responsible for 

oversight of LIHTC.63

At the jurisdiction level, Washington, King County and the King County 

Housing Authority, Oregon, and Multnomah County reported having at 

least one performance goal.

As of September 2015, no action had been taken.

64

All of the participating audit offices reported challenges to assessing 

performance. Washington and Portland reported difficulties establishing 

outcome measures that can be quantified or reported. For example, 

Portland stated that a challenge was how to quantify and define the social 

outcome they were trying to achieve. Unlike the homelessness programs, 

housing retention may not be a good measure or outcome, because the 

programs want participants to increase their income and move out of 

subsidized housing, according to Portland. In addition, Seattle, King 

County Housing Authority, and Multnomah County reported that obtaining 

data could be difficult. For example, Multnomah County reported that data 

consistency can be a problem, as its data is gathered by 19 partner 

agencies.

For example, one of Oregon’s goals 

included increased housing stability as measured by the percentage of 

households served who maintain permanent housing for at least 6 

months after exiting a program. In addition, one of Multnomah County’s

goals was that 70 percent of households maintain housing stability at 12 

months after the subsidy ends. At the program level within the 

jurisdictions, most of the rental assistance programs within the 

jurisdictions had a performance goal and reported on their performance.

For example, Washington reported that one of its programs had a 

performance goal of every eligible person housed and reported that 100 

percent of eligible people who requested assistance were housed. King 

County also reported that one of its program’s performance goals was 

serving 280 new households in new units and reported that 486 

households were housed in new units.

 63GAO-15-330.

64A performance goal is a “target level of performance expressed as a tangible, 

measurable objective- against which actual achievement can be compared including a 

goal expressed as a quantitative standard, value, or rate.” See, GPRAMA, Pub. L No. 

111-352, 124 Stat. 3866, 3871 (Jan. 4, 2011).

Participating Audit Offices 

Reported Challenges to 

Assessing Performance
Page 37 GAO-15-645 Affordable Rental Housing 

Washington, Seattle Housing Authority, King County, Oregon, Multnomah 

County, and Denver also reported that differing policies or performance 

categories were a challenge. For example, Washington reported that a 

challenge for the Seattle Housing Authority was that different institutions

have differing privacy rules that the Seattle Housing Authority must 

contend with to gather necessary information. In addition, according to a 

Multnomah County Auditor Office report, some county programs use 

output measures such as the number served. The report noted that while 

these measures are useful for tracking program performance over time, 

they are not useful for making comparisons of effectiveness across 

programs. The report recommended a review of performance measures 

to better understand cost effectiveness and impact of housing assistance 

programs.65

Washington, Seattle, Oregon, Multnomah County, and Denver also 

suggested steps to enhance outcomes or gain program or process 

efficiencies. For example, Denver suggested that states and localities 

should not be required to disperse federal funding too quickly as this can 

lead to less efficient allocations because of the need to quickly assess 

conditions and make disbursement decisions. In addition, an Oregon 

Secretary of State’s Audit Division report suggested that inefficiencies 

could be decreased by establishing compatible policies and procedures 

and by pursuing collaborative efforts to increase data sharing among 

programs. The audit division also suggested aligning outcome measures 

and reporting and eligibility requirements. In addition, the report 

suggested clearly defining areas of responsibilities and improving 

evaluations of program effectiveness and efficiencies.

The Multnomah County Auditor Office plans to follow-up on 

the recommendation in December 2015 and a work group has been 

formed to review data related to housing.

66

 65Office of the Multnomah County Auditor, Housing Inventory Special Report (fulfilling note 

from FY-2015 Budget work session), (Portland, OR: Oct. 22, 2014).

The audit division 

plans to follow-up about the status in December 2015.

66Oregon Secretary of State’s Audits Division, Oregon Housing and Community Services 

Department: Program Duplication, Overlap and Fragmentation, Report 2013-16 (Salem, 

OR: July 2013).
Page 38 GAO-15-645 Affordable Rental Housing 

HUD, IRS, and the participating audit offices reported on their 

performance to varying degrees, and thus there is incomplete information 

at the federal and participating audit offices’ jurisdictions. In addition, 

HUD, Treasury and IRS officials that are part of the Rental Policy Working 

Group stated that there is no information on the collective performance of 

the federal, state, and local jurisdictions that provide rental assistance. 

Thus it is not known to what extent and how well the local, state and 

federal rental assistance programs work collectively, for example, to 

increase the number of households served. Complete and reliable 

information is a vital component to assessing effectiveness. Federal 

agencies are required by the Government Performance and Results Act 

Modernization Act of 2010 (GPRAMA) to describe in their strategic plans 

and performance plans how they are working together to achieve their 

goals.67 GPRAMA’s new requirements help drive collaboration and 

reduce fragmentation. However, the agency-by-agency focus does not 

provide an integrated perspective of the performance of federal rental 

assistance programs. GPRAMA further highlights the need for 

crosscutting68

In addition, an OMB policy memorandum that affects federal programs 

administered by state and local governments, tribes, and territories 

includes guidance on better results for states, local, and tribal 

governments. The memorandum states that agencies and their state, 

local, and tribal partners should review their capacity to generate accurate 

data to ensure accountability and improve decision making that leads to 

better outcomes. In addition, the memorandum reported that agencies 

and their partners should identify opportunities to consolidate and share 

performance planning for issues that involve multiple 

federal agencies and could provide the initial steps toward governmentwide performance information. In addition, crosscutting performance 

measures could be developed through interagency collaboration. 

Complementary and, where appropriate, common performance measures 

could permit comparisons of related programs’ results and the tools used 

to achieve those results.

 67GPRAMA is the statutory framework for performance management in the federal 

government and updates the Government Performance and Results Act of 1993 (GPRA).

68GPRAMA defines crosscutting as “across organizational (such as agency) boundaries”.

Pub. L No. 111-352, 124 Stat. 3866, 3870 (Jan. 4, 2011).

There Is a Lack of 

Reporting on the 

Performance of the 

Collective Levels of 

Government
Page 39 GAO-15-645 Affordable Rental Housing 

data across agencies and programs where there are similar reporting 

requirements.69

Compiling and reporting on the collective performance of crosscutting 

efforts is important in helping to provide a comprehensive picture of how 

well the different levels of government are providing a service as a 

whole—in this case, rental assistance. We recognize it is difficult to 

identify relevant federal, state, and local programs, collect performance 

information from multiple levels of government, and synthesize the 

information to reflect the collective performance. However, without 

information on the government-wide performance of rental assistance, the 

Congress, decision makers, and stakeholders at all levels of government 

are hampered in their ability to identify agencies and programs 

addressing similar missions. They are also hampered in the ability to set 

priorities, allocate resources, and restructure federal efforts, as needed, 

to achieve long-term goals. In addition, without such performance 

information, it is not clear and transparent to the public how governments 

are collectively providing rental assistance.

HUD has extensive experience with collecting data from state agencies 

through LIHTC databases that it administers.70 In addition, HUD is part of 

the RPWG which has continued to work to implement recommendations 

that would improve the coordination of government-wide oversight of 

subsidized rental housing properties. The RPWG has also worked to 

reduce the administrative burden on affordable housing owners and 

managers. We have previously reported on practices that help sustain 

and enhance collaboration among federal agencies.71

 69Office of Management and Budget, Memorandum for the Heads of Executive 

Departments and Agencies: Implementing the Presidential Memorandum “Administrative 

Flexibility, Lower Costs, and Better Results for State, Local, and Tribal Governments”, 

MS-11-21 (Washington D.C.: April 29, 2011).

These practices 

include defining and articulating a common outcome and developing 

mechanisms to monitor, evaluate, and report results. The RPWG has 

defined its own priorities and has reported on its progress. HUD, the 

nation’s leading housing agency, in consultation with the RPWG, is well 

positioned to capitalize on its existing collaboration among federal 

70HUD, Understanding Whom the LIHTC Program Serves: Tenants in LIHTC Units as of 

December 31, 2012 (December 2014).

71GAO, Results Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington D.C.: Oct. 21, 2005).
Page 40 GAO-15-645 Affordable Rental Housing 

agencies and with state and local jurisdictions. Thus, working with its 

state and local partners to develop an approach for compiling and 

reporting on the collective performance of federal, state, and local rental 

assistance programs could help pave the way for obtaining data on how 

well the different levels of government are providing rental assistance as 

a whole. This effort could start with one or more pilots to test an approach 

before it is implemented. For example, for one performance indicator,

HUD, in consultation with the RPWG, could conduct a pilot to compile and 

report on the collective performance of relevant federal, state, and local 

rental assistance programs. One possibility could be to start with one of 

the rental assistance indicators on which HUD currently reports.

The federal government, states, and localities play a significant role in 

providing rental assistance and developing affordable rental housing for 

low-income households. Numerous agencies administer these programs, 

which provide rental assistance, public housing, and tax benefits. In 

addition, states and localities use federal funds and their own funds to 

provide rental assistance programs. However, at all levels of government 

there are indications of program fragmentation or overlap.

HUD has extensive experience with collecting data from state agencies 

through LIHTC databases it administers. In addition, HUD is part of the

Rental Policy Working Group which has taken steps to identify specific 

areas in which to align sometimes conflicting and redundant 

requirements. In addition, the Rental Policy Working Group has worked 

with states and localities on a variety of initiatives to improve states’

capacity to preserve affordable rental housing, streamline processes, and 

eliminate redundancies. Although HUD, IRS and the participating audit 

offices reported on their performance to varying degrees, one challenge 

to building upon HUD and the RPWG’s successes is that there is 

incomplete information on the collective performance of the federal, state, 

and local rental assistance programs. This information would help provide 

HUD, as the nation’s leading housing agency, with important information 

for assessing and reporting progress on its strategic goal for rental 

assistance. Complete and reliable information is also a vital component 

for assessing effectiveness. Although obtaining it is not without 

challenges however, without information on the government-wide 

performance of rental assistance, the Congress as well as program 

managers, other decision makers, and stakeholders at all levels of 

government are hampered in their ability to identify agencies and 

programs addressing similar missions. They are also hampered in their 

ability to set priorities, allocate resources, and restructure efforts, as 

needed, to achieve long-term goals. In addition, without such 

Conclusions
Page 41 GAO-15-645 Affordable Rental Housing 

performance information, it is not clear and transparent to the public how 

governments are collectively providing rental assistance.

To build upon the Department of Housing and Urban Development and 

the Rental Policy Working Group’s efforts to improve coordination of 

rental assistance, the Secretary of the Department of Housing and Urban 

Development, in consultation with the Rental Policy Working Group,

should work with states and localities to develop an approach for 

compiling and reporting on the collective performance of federal, state, 

and local rental assistance programs. Such an effort may begin with one 

or more pilots to test approaches before they are considered for wider 

application.

We provided a draft of this report to the Secretary of HUD, Commissioner 

of IRS, and Secretary of the Treasury for review and comment. Written 

comments from HUD Assistant Secretary for Policy Development and 

Research are reproduced in appendix III. IRS had no comments on the 

report. Treasury provided technical comments, which we incorporated 

into the report.

In its letter, HUD disagreed with the recommendation in our draft report

directed to RPWG to work with states and localities to develop an 

approach for compiling and reporting on the collective performance of 

federal, state, and local rental assistance programs. HUD stated that the 

RPWG is not the proper vehicle for this recommendation because the 

RPWG is an inter-agency collaboration with no dedicated staff or funding.

We agreed. Thus, we have revised the recommendation to direct it to 

HUD, in consultation with the RPWG, given that HUD is the nation’s 

leading housing agency and is a member of the RPWG and that the 

RPWG collaborates with different levels of government.

HUD also stated that compiling and reporting collective performance 

information would require significant funding, staff resources, and 

information technology efforts. However, our recommendation is to 

develop an approach for compiling and reporting such data as a first step 

towards providing information on collective performance. In addition, 

although we provided one suggestion of how to design an approach by 

using an existing HUD performance indicator, the recommendation is 

purposefully not proscriptive, so that HUD, in consultation with the 

RPWG, can design an approach that is feasible.

Recommendation for 

Executive Action

Agency Comments

and Our Evaluation
Page 42 GAO-15-645 Affordable Rental Housing 

HUD stated that the report did not explain what was meant by rental 

assistance. However, the report defines rental assistance as programs or 

initiatives with a primary goal of directly or indirectly subsidizing rents for 

low-income households. In addition, HUD objected to our finding that no 

information exists on collective performance as being too broadly stated 

since information already exists on the performance of programs. We 

agreed. Thus we revised the draft to clarify our point that there is 

incomplete information on collective performance. 

HUD also stated that an analysis of fragmentation or overlap among the 

federal, state and local programs should include information on federal 

matching requirements and differentiate between “deep” and “shallow” 

subsidies. HUD pointed out that Congress enacted matching 

requirements in order to leverage additional investments and to provide 

increased local accountability for federal funds and that federal matching 

requirements should not be considered evidence of unintended 

fragmentation or overlap. We agree and did not include federal matching 

requirements in our analysis or consider it to be evidence of 

fragmentation or overlap. HUD also stated that the report refers to 

affordable housing without differentiating between programs that are 

considered to be “deep subsidy” versus “shallow subsidy” programs. HUD

stated that a “deep subsidy” program can effectively assist households at 

the lowest end of the income scale and a “shallow subsidy” program can 

generally only provide much more modest levels of affordability. HUD 

noted in an attachment to the letter that the federal government is the 

primary provider of funding for deep subsidy programs. In this report, our 

analysis included four federal programs representing 92 percent of total 

obligations and estimated tax losses for low-income assistance and 

affordable housing development programs – Section 8 rental assistance, 

Public Housing, the HOME Investment Partnerships Program, and the 

Low Income Housing Tax Credit – that provide varying levels of subsidies 

and are implemented along with state and local programs. For each of the 

four federal programs, we included information on income thresholds for 

eligibility. We also added a footnote on deep and shallow subsidies. Thus, 

we believe that our report now addressed the difference between deep 

and shallow subsidies. Moreover, we and the participating audit offices 

reviewed state and local programs using GAO’s definitions of 

fragmentation and overlap that we developed as noted in the report. In 

addition, at the federal level, the report refers to previously published 

work that assessed fragmentation and overlap among federal programs. 

HUD also stated that we did not include information on two recent reports 

on LIHTC—one from GAO and the other the result of a HUD-led effort 
Page 43 GAO-15-645 Affordable Rental Housing 

with assistance from State Housing Finance Agencies.72

In addition, in the attachment to HUD’s letter, HUD objected to our 

statement that HUD reported on its performance for only one of its two 

rental assistance strategic objectives. HUD stated that the worst case 

housing indicator is valuable as a tracking measure and that a 

performance measure has not been deemed advisable. However, as we 

stated in the report, the guidance states that there needs to be a target, 

which is not included. HUD also stated we ignore several basic issues 

with measuring housing affordability; however, the report includes HUD’s

definitions. We also incorporated HUD’s technical comments in the report, 

as appropriate.

 We added 

information from our LIHTC report, which found that IRS does not set 

goals or assess performance for LIHTC. The report suggested that

Congress should consider designating HUD as a joint administer of 

LIHTC. We also added information from HUD’s LIHTC report by noting 

that HUD has extensive experience with collecting data from state 

agencies through the LIHTC databases that it administers.

We are sending this report to the participating partners, agencies and 

congressional committees. In addition, the report is available at no charge 

on the GAO website at http://www.gao.gov.

If you or your staff members have any questions or wish to discuss the 

material in this report further, please contact me at (202) 512-6806 or 

mihmj@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 key contributions to this report are listed in appendix 

IV.

Sincerely yours,

J. Christopher Mihm

Managing Director, Strategic Issues

 72GAO, Low-Income Housing Tax Credit: Joint IRS-HUD Administration Could Help 

Address Weaknesses in Oversight, GAO-15-330 (Washington D.C.: July 15, 2015) and 

HUD, Understanding Whom the LIHTC Program Serves: Tenants in LIHTC Units as of 

December 31, 2012 (December 2014).
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-15-645 Affordable Rental Housing 

We partnered with jurisdictions to conduct a pilot effort to develop an 

approach for examining how federal, state, and local resources might be 

better coordinated to enhance outcomes and increase intergovernmental 

efficiency. We performed our work under the authority of the Comptroller 

General to conduct evaluations on GAO’s initiative to assist Congress 

with its oversight responsibilities. We designed a coordinated audit 

approach that involves two or more audit organizations performing 

synchronous audits leading to joint or separate reports. For this pilot 

effort, we chose to review rental housing assistance for low-income 

households. Below, we describe how we selected this issue area. Our 

objectives were to (1) identify the federal, state,, and local government 

funded programs in selected jurisdictions that provide rental assistance to 

low-income households and identify indications of program fragmentation 

and overlap; (2) assess the extent of intergovernmental collaboration for 

the provision of rental assistance; and (3) determine what is known about 

performance at the federal level, at selected state and local jurisdictions 

and for the collective performance of the levels of government providing 

rental assistance.

We conducted this work in partnership with 25 state and local volunteer 

audit offices.1

 1

See appendix II for a full list of the state and local participating and consulting partners.

Six of the state and local volunteers—the Washington State 

Auditor’s Office (Washington); the King County Auditor’s Office (King 

County), WA; the Oregon Secretary of State Office, Audits Division 

(Oregon), City of Portland, Office of the City Auditor, Audit Services 

Division (Portland), OR; the Multnomah County Auditor’s Office 

(Multnomah County), OR; and Office of the Auditor, City and County of 

Denver (Denver), CO—conducted these coordinated audits focused 

specifically on rental assistance programs for low-income households. In 

addition, to reporting on its own programs, Washington also reported on 

the city of Seattle’s (Seattle), Seattle Housing Authority and the King 

County Housing Authority’s programs. For the purposes of this review we 

refer to these six state and local volunteers and Seattle as the 

participating audit offices and the remaining partners as consulting 

partners. In addition, the pilot effort led to Washington, Multnomah 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-15-645 Affordable Rental Housing 

County, and Denver publishing separate reports.2

To identify a policy area for the pilot review, we collaborated with the 25 

participating audit offices and contributing partners to identify several 

potential policy areas using criteria that included

To solicit state and 

local auditors to participate in this effort, we collaborated with the National 

Association of State Auditors, Comptrollers, and Treasurers and the 

Association of Local Government Auditors. The associations’ leadership 

emailed their members a description of the intergovernmental pilot and 

asked for volunteers to participate.

• a mix of programs, funding mechanisms, and levels of government 

involved;

• the existence of earlier audits on the topic;

• the extent to which coordinated work on the issue would help build a 

relationship between the audit organizations, as well as the levels of 

government; and

• the capacity and willingness of each audit organization to work on the 

topic , which included issues of audit timing, resource commitment, 

and perceived benefits.

We identified three policy areas as the best fits for the pilot review: 

workforce training, affordable housing, and local economic development.

After conducting background research on the topics and consulting with 

the state and local volunteers and internal stakeholders, we selected 

affordable housing because it provided the best match for the criteria 

listed above. Affordable housing offered a comprehensive array of 

programs at the federal, state, and local levels that use a variety of 

funding mechanisms. In addition, there had been previous audits of 

affordable housing at the federal, state, and local levels.

 2

See Washington State Auditor’s Office, Program Understand Low-Income Housing 

Rental Assistance Programs (Olympia, WA: Aug. 14, 2014); Office of the Multnomah 

County Auditor, Housing Inventory Special Report fulfilling note from FY-2015 Budget 

work session (Portland, OR: Oct. 22, 2014); and City and County of Denver Office of the 

Auditor, Denver Affordable Housing Performance Audit (Denver, CO: Nov. 2014).
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-15-645 Affordable Rental Housing 

We narrowed the scope of the pilot to low-income rental assistance 

programs because affordable housing policy is a broad area and 

affordable housing programs involve many other issues (such as energy 

costs and weatherization, food assistance, job training, transportation, 

home ownership, foreclosure prevention, and neighborhood stabilization) 

and target various populations (such as the homeless, persons with 

disabilities, the elderly, veterans, and farm workers). For the purposes of 

this review, we defined low-income rental assistance to include any 

programs or initiatives with a primary goal of directly or indirectly 

subsidizing rents for low-income households. Examples of the federal 

programs that provide direct subsidies include the Housing Choice 

Voucher and Public Housing programs and programs that provide indirect 

subsidies include the Low-income Housing Tax Credit and the Section 

202 Supportive Housing for the Elderly programs. Also for purposes of 

this review, we focused on permanent housing and the federally funded 

programs that receive the bulk of funding and hence we excluded shortterm or temporary programs, temporary shelter programs, and programs 

targeted at special populations other than the elderly and households with 

disabilities. Examples of excluded programs include the Tax Credit 

Assistance Program, the Neighborhood Stabilization Program, 

Emergency Shelter Grants, and Housing Opportunities for Persons with 

AIDS.

In collaboration with the participating audit offices and consulting 

partners, we designed an audit plan for each of the participating audit 

offices to implement. The audit plan included questions on data reliability 

for any funding data collected. The audit plan consisted of four 

components:

1. Identify low-income rental housing assistance performance goals for 

outputs and outcomes for the respective jurisdiction.

2. Compile inventories of programs for the respective jurisdiction that 

address these low-income rental assistance output or outcome goals.

3. Collect data on key elements of the programs, such as how the 

assistance is provided, eligibility for the program, and the program’s 

performance metrics.

4. Examine whether barriers or challenges existed to achieving, 

establishing, and measuring performance outcomes and measures as 

well as the extent of intergovernmental collaboration.

The participating audit offices interviewed housing officials in their 

jurisdictions and submitted the completed audit plans to us. We assisted 
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-15-645 Affordable Rental Housing 

the participating audit offices in implementing the audit plans by 

answering questions and facilitating information sharing among the 

partners. We reviewed the results of the implemented audit plans to 

ensure that we could rely on their results. For example, we ensured that 

programs met the definition for low-income rental assistance and that the 

reported program information matched the questions in the coordinated 

audit plan. We did not validate or check the accuracy of the information 

provided by the participating audit offices. However, we included 

questions related to data reliability in the coordinated audit plan 

implemented by the participating jurisdictions and determined that the 

data were sufficiently reliable for the purposes of this report. Because 

participation in the pilot was voluntary, the coverage varied by state—for 

Oregon and Washington, we had data from the state, county, and city 

levels, but for Colorado we only had city and county level data. Further, 

Washington reported program information for Seattle, the Seattle Housing 

Authority and the King County Housing Authority.

To describe the programs that provide low-income rental assistance, we 

used information that the participating audit offices reported on their 

programs. To identify indications of program fragmentation and overlap, 

we and the participating audit offices analyzed the audit results reported 

by the participating audit offices and used definitions from our work on 

fragmentation and overlap.

3

 3

GAO, 2014 Annual Report: Additional Opportunities to Reduce Fragmentation, Overlap, 

and Duplication and Achieve Other Financial Benefits, 

For example, to identify indications of 

program overlap we analyzed the audit results of the participating audit 

offices located within the same general geographic area in which the 

programs were administered to determine whether the reported programs 

had similar goals or intended beneficiaries, and which agencies, bureaus, 

or divisions had administrative responsibility for the programs. Given that 

Oregon and Washington both had participating audit offices at multiple 

levels of government and Denver did not, we were unable to assess 

Denver’s programs for fragmentation or overlap. Our work has defined 

these terms. Fragmentation, in the context of intergovernmental 

programs, occurs when more than one agency—or more than one 

organization within an agency—is involved in the same broad area of 

national need and opportunities exist to improve service delivery. Overlap 

occurs when there are multiple agencies or programs that have similar 

goals, engage in similar activities or strategies and activities to achieve 

GAO-14-343SP (Washington, D.C.: 

Apr. 8, 2014).
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-15-645 Affordable Rental Housing 

those goals, or target similar beneficiaries. GAO’s fragmentation, overlap, 

and duplication evaluation and management guide includes four steps to 

conducting a fragmentation, overlap, and duplication review.4 We 

conducted the first step of identifying indications of fragmentation and 

overlap, but did not conduct the next three steps, and hence have stated 

that there are indications of fragmentation and overlap.5

To assess the extent of intergovernmental collaboration to provide rental 

assistance, we analyzed the collaboration information provided by the 

participating audit offices in the audit results. We also interviewed 

Housing and Urban Development (HUD), the U.S. Department of 

Treasury (Treasury), and the Internal Revenue Service (IRS) officials who 

participate in the Rental Policy Working Group (RPWG) and reviewed 

documentation on the RPWG’s collaboration with states and localities. 

Based on our most recent housing program inventory published 

electronically in 2012, HUD and IRS administer five federal programs that 

represent approximately 92 percent of total obligations and estimated tax 

revenue losses for low-income rental assistance and affordable housing 

development programs; thus, we decided to interview HUD, IRS, and 

Treasury. For our analysis we used our work on collaboration, which 

describes some of the necessary elements for a collaborative working 

relationship, such as defining and articulating a common outcome and 

compatible policies, procedures, and other means to operate across 

agency boundaries.

For example, we 

did not identify the positive and negative effects of fragmentation and 

overlap, such as how it can affect program implementation, outcomes, 

and cost-effectiveness.

6

To determine what is known about performance at the federal level and at 

selected state and local jurisdictions, we analyzed the performance 

 4

GAO, Fragmentation, Overlap and Duplication: An Evaluation and Management Guide, 

GAO-15-49SP (Washington D.C.: Apr. 14, 2015).

5

The next steps are as follows: 2) identify the potential effects of fragmentation, overlap, 

and duplication; 3) validate the effects and assess and compare federal programs; and 4) 

identify options to increase efficiency and reduce or better manage fragmentation, overlap, 

and duplication.

6

GAO, Managing for Results: Implementation Approaches Used to Enhance Collaboration 

in Interagency Groups, GAO-14-220 (Washington, D.C.: Feb. 14, 2014) and Managing for 

Results: Key Considerations for Implementing Interagency Collaborative Mechanisms,

GAO-12-1022 (Sept. 27, 2012).
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-15-645 Affordable Rental Housing 

information reported by the participating audit offices from the completed 

audit. We assessed this information using criteria identified in our prior 

work on performance management which discussed how performance 

information gives managers crucial information with which to make 

decisions and influences organizational behavior.7

We performed our work under authority of the Comptroller General to 

conduct evaluations on GAO’s initiative to assist Congress with its 

oversight responsibilities. We conducted our work on this report from 

February 2014 to September 2015 in accordance with generally accepted 

government auditing standards that are relevant to our objectives. Those 

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

and appropriate evidence to meet our stated objectives and to discuss 

any limitations in our work. We believe that the information and data 

obtained, and the analysis conducted, provide a reasonable basis for any 

findings and conclusions based on our objectives.

We also interviewed 

HUD, Treasury, and IRS officials who participate in the RPWG about the 

performance of the combined levels of government and reviewed 

documentation on the agency’s rental assistance performance 

information.

 7

GAO, Managing for Results: Executive Branch Should More Fully Implement the GPRA 

Modernization Act to Address Pressing Governance Challenges, GAO-13-518 

(Washington, D.C.: June 26, 2013) and Executive Guide: Effectively Implementing the 

Government Performance and Results Act, GAO/GGD-96-118 (Washington, D.C.: June, 

1996).
Appendix II: State and Local Participating 

Audit Offices and Consulting Partners

Page 50 GAO-15-645 Affordable Rental Housing 

Participating Audit 

Offices

States: Oregon Secretary of State Audits Division Jeanne P. Atkins

Secretary of State

Gary Blackmer

Director

Sheronne Blasi

Audit Manager

Amanda Lamb

Performance Auditor

Washington State Auditor’s Office Chuck Pfeil, CPA

Director of State and 

Performance Audit

Lou Adams, CPA

Deputy Director for 

Performance Audit

Nancy Dufoe

Principal Performance Auditor

Melissa Wade. CGAP

Senior Performance Auditor

Tania Y. Fleming

Performance Auditor

Counties: King County, WA Auditor’s Office Kymber Waltmunson

County Auditor

Ben Thompson

Deputy Auditor

David Dean

Senior Principal Management 

Auditor

Office of Multnomah County, OR Auditor Steve March

County Auditor

Fran Davison

Senior Auditor

Marc Rose

Performance Auditor

Cities: Office of the City Auditor (Portland, OR)—Audit Services Division Mary Hull Caballero

City Auditor

Drummond Kahn

Director of Audit Services

Kari E. Guy

Senior Management Auditor

Appendix II: State and Local Participating 

Audit Offices and Consulting Partners 
Appendix II: State and Local Participating 

Audit Offices and Consulting Partners

Page 51 GAO-15-645 Affordable Rental Housing 

Participating Audit 

Offices

City and County of Denver, CO Office of the Auditor—Audit Services 

Division

Dennis J. Gallagher

Auditor

Kip Memmott

Director of Audit Services

Audrey Donovan

Deputy Director

Dawn Wiseman

Audit Supervisor

Consulting Partners

States: California Office of the State Auditor Elaine M. Howle, CPA

State Auditor

Colorado Office of the State Auditor Monica Bowers

Deputy State Auditor

Florida Inspectors General Melinda M. Miguel

Chief Inspector General

Illinois Office of the Auditor General William G. Holland

Auditor General

Jim Schlouch

Director, Performance Audits

Mississippi Office of the State Auditor Sam Atkinson

Director, Performance Audit

Office of the Minnesota State Auditor Rebecca Otto

State Auditor

Office of the New York State Comptroller Tina Kim

Deputy Comptroller for State 

Government Accountability

Office of the Auditor of Public Accounts, Commonwealth of Virginia Jennifer P. Bell Schreck

Audit Director, Strategic Risk

Management

Counties: Mecklenburg County Department of Internal Audit Joanne Prakapas

Director

Milwaukee County Office of the Comptroller Audit Services Division Jerome J. Heer

Director of Audits
Appendix II: State and Local Participating 

Audit Offices and Consulting Partners

Page 52 GAO-15-645 Affordable Rental Housing 

Participating Audit 

Offices

Cities: City of Austin Office of the City Auditor Corrie Stokes

City Auditor

City of Dallas Office of the City Auditor Craig D. Kinton

City Auditor

City of New York Office of the Comptroller Edward Carey, Jr.

Assistant Comptroller, 

Management Audit

City of Orlando Office of Audit Services and Management Support George J. McGowan

Director

City of Phoenix City Auditor Department Bill Greene

City Auditor

Other Governmental 

Agencies:

The Los Angeles Police Department Internal Audits and Inspection 

Division

Captain Jodi Wakefield

Commanding Officer of Audit 

Division

San Joaquin Hills Transportation Corridor Agencies Greg Walker

Manager, Internal Audit 

Associations: National Association of State Auditors, Comptrollers and Treasurers R. Kinney Poynter, CPA

Executive Director

Association of Local Government Auditors Corrie Stokes

Past President
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 53 GAO-15-645 Affordable Rental Housing 

Appendix III: Comments from the 

Department of Housing and Urban 

Development
Appendix III: Comments from the Department 

of Housing and Urban Development

Page 54 GAO-15-645 Affordable Rental Housing 
Appendix III: Comments from the Department

of Housing and Urban Development

Page 55 GAO-15-645 Affordable Rental Housing 
Appendix lV: GAO Contact and Staff 

Acknowledgments

Page 56 GAO-15-645 Affordable Rental Housing 

J. Christopher Mihm (202) 512-6806 or mihmj@gao.gov

In addition to the contact named above, Stanley J. Czerwinski, Thomas 

M. James (Assistant Director), and Maya W. Chakko (analyst-in-charge), 

supervised this review and the development of the resulting report.

Sandra L. Beattie, Jehan A. Chase, Kisha Clark, Elizabeth H. Curda, 

Martin H. DeAlteriis, Daniel Garcia-Diaz, Maksim Glikman, Robert L. 

Gebhardt, Ellen Grady, George Guttman, Travis P. Hill, Shirley A. Jones, 

Benjamin T. Licht, Cory Marzullo, Donna L. Miller, Susan S. Sato, Paul J. 

Schmidt, and Sarah E. Veale made key contributions to this report.

Appendix lV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(451086)
Related GAO Products

Page 57 GAO-15-645 Affordable Rental Housing 

Housing Assistance

HUD Rental Assistance Demonstration: Information on Initial Conversions 

to Project-Based Vouchers. GAO-14-402. Washington, D.C.: April 24, 

2014.

Housing Assistance: Opportunities Exist to Increase Collaboration and 

Consider Consolidation. GAO-12-554. Washington, D.C.: August 16, 

2012.

Rental Housing Assistance: HUD Data on Self-Sufficiency Programs 

Should Be Improved. GAO-13-581. Washington, D.C.: July 9, 2013.

HUD Has Identified Performance Measures for Its Block Grant Programs, 

but Information on Impact is Limited. GAO-12-575R. Washington D.C.: 

May 15, 2012.

Housing Choice Vouchers: Options Exist to Increase Program 

Efficiencies. GAO-12-300. Washington, D.C.: March 19, 2012.

Fragmentation, Overlap, and Duplication

2015 Annual Report: Additional Opportunities to Reduce Fragmentation, 

Overlap, and Duplication and Achieve Other Financial Benefits.

GAO-15-404SP. Washington, D.C.: April 14, 2015.

Fragmentation, Overlap, and Duplication: An Evaluation and 

Management Guide. GAO-15-49SP. Washington, D.C.: April 14, 2015.

2014 Annual Report: Additional Opportunities to Reduce Fragmentation, 

Overlap, and Duplication and Achieve Other Financial Benefits. 

GAO-14-343SP. Washington, D.C.: April 8, 2014.

2013 Annual Report: Actions Needed to Reduce Fragmentation, Overlap, 

and Duplication and Achieve Other Financial Benefits. GAO-13-279SP. 

Washington, D.C.: April 9, 2013.

Managing for Results

Managing for Results: Implementation Approaches Used to Enhance 

Collaboration in Interagency Groups. GAO-14-220. Washington, D.C.: 

February 14, 2014.

Related GAO Products
Related GAO Products

Page 58 GAO-15-645 Affordable Rental Housing 

Managing for Results: Agencies Should More Fully Develop Priority Goals 

under the GPRA Modernization Act. GAO-13-174. Washington, D.C.: 

April 19, 2013.

Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms. GAO-12-1022. Washington, D.C.: September 

27, 2012.

Results Oriented Government: Practices That Can Help Enhance and 

Sustain Collaboration among Federal Agencies. GAO-06-15. Washington, 

D.C.: October 21, 2005.

Managing for Results: Barriers to Interagency Coordination. 

GAO/GGD-00-106. Washington, D.C.: March 29, 2000.

(451086)
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