GAO

United States General Accounting Office

Report to the Secretary of Housing and 

Urban Development

November 2000 HUD INSPECTIONS

Steps Needed to 

Address Uncertainty 

in Inspection Scores

GAO-01-109

Page 1 GAO-01-109 HUD Inspections

United States General Accounting Office

Washington, D.C. 20548 Letr

November 8, 2000

The Honorable Andrew M. Cuomo

The Secretary of Housing and

Urban Development

Dear Mr. Secretary:

In 1997, the Department of Housing and Urban Development (HUD) 

created the Real Estate Assessment Center (REAC) to, among other things, 

administer physical inspections of HUD’s public and multifamily housing 

properties. REAC’s new inspection system uses data gathered by 

inspectors to calculate scores that measure the physical condition of HUD’s 

properties—that is, the extent to which the properties are safe, decent, and 

in good repair. REAC then uses these scores, which range from 0 to 100, to 

determine what follow-up is needed to address the problems identified 

during the inspections. Soon, REAC will also use these scores to determine 

when properties should be reinspected. The new system does not require 

the inspection of all units and buildings within each property because 

HUD’s housing inventory is large and its resources for inspections are 

limited; instead, for most properties, the system provides for inspecting 

samples of units and buildings. Sampling introduces a degree of 

uncertainty, called sampling error, which statisticians commonly express as 

a range associated with numerical results, such as REAC’s property 

inspection scores. Sampling error is a routine and accepted outcome of 

sampling.

We reported on various aspects of REAC’s physical inspection program in 

July 2000.1

 Although we found that REAC’s system improved on HUD’s 

previous inspection systems, we also found that weaknesses in the 

system’s quality assurance procedures limited REAC’s effectiveness in 

ensuring the reliability of the inspections. We also found some sampling 

and statistical issues that affect the reliability of the inspection scores. As 

agreed with the requesters of our July report, we are transmitting this 

report to you on the impact of sampling on inspection scores. Specifically, 

this report examines (1) how REAC accounts for sampling error when 

calculating and reporting inspection scores and (2) whether the formula 

1

HUD Housing Portfolios: HUD Has Strengthened Physical Inspections but Needs to Resolve 

Concerns About Their Reliability (GAO/RCED-00-168, July 25, 2000).
Page 2 GAO-01-109 HUD Inspections

that REAC uses to calculate inspection scores is consistent with the 

sampling procedures it uses to select buildings and units.

Results in Brief Although REAC uses sampling to select units and buildings for inspection, 

it did not, at the time of our review, routinely calculate the sampling error 

associated with the physical condition score assigned to each property. 

REAC did, however, study the effects of sampling for about 8,800 out of 

40,000 properties. Our analysis of these data indicates that the sampling 

error for about 71 percent of the properties was 3 or fewer points, but for 

less than 1 percent of the properties, it was much higher—from 8 to 19 

points. Further analysis identified instances when the sampling error was 

great enough to create uncertainty about whether the properties’ 

inspection scores fell above or below the administrative thresholds that 

HUD uses to determine what follow-up actions its field offices should take 

or when the property should be reinspected. For example, we found such 

uncertainty associated with about 8 percent of the multifamily properties 

whose inspection scores we analyzed. HUD recently agreed to take actions 

to address our concerns about its treatment of sampling error. These 

actions include routinely calculating the sampling error for each inspection 

score and revising the procedures for determining what key follow-up 

actions are needed when the sampling error would otherwise create 

uncertainty about the appropriate action for the property. When 

implemented, these actions should address our basic concerns.

Under the sampling procedure that REAC uses as part of its physical 

inspection process, buildings and units do not always have the same 

chance of being included in an inspection sample. This sampling procedure 

is acceptable, but the formula REAC uses to calculate inspection scores is 

not consistent with the procedure. As a result, some inspection scores are 

inaccurate. According to REAC’s analysis of data for about 5,000 

properties, correcting the formula to account for the probability of units’ 

and buildings’ inclusion in a sample changed the scores of about 30 percent 

of the properties inspected. For most of the properties whose scores 

changed, the change was minimal; however, for about 1.4 percent of the 

properties, the scores changed by 4 to 9 points—enough, potentially, to 

affect REAC’s decisions about the type of follow-up and the frequency of 

reinspection. HUD’s plans for changing its sampling and scoring processes 

should, when implemented, address our concerns.
Page 3 GAO-01-109 HUD Inspections

Background To ensure that families living in rental housing that is owned, insured, or 

subsidized by HUD have decent, safe, and sanitary accommodations, REAC 

conducts annual inspections of public housing and multifamily properties. 

For its first round (or baseline) of inspections, REAC inspected over 3,100 

public housing authorities with 13,607 properties and 26,528 privately 

owned multifamily properties—a total of 40,135 properties. Public housing 

serves low-income families, the elderly, and persons with disabilities and is 

operated by public housing authorities using funds provided by HUD. 

Privately owned multifamily housing includes properties that receive some 

form of rental assistance, including Section 8 assistance, from HUD; 

properties whose mortgages are insured or held by HUD; and properties 

that are financed by HUD.2

During an inspection, an inspector enters observations into a hand-held 

computer and then electronically submits the data to REAC for verification 

and calculation of a score ranging from 0 to 100. Using this scoring range, 

HUD establishes administrative thresholds to determine what follow-up 

actions its field offices need to take and how soon the properties need to be 

reinspected. The thresholds for multifamily and public housing properties 

differ somewhat. Multifamily properties with scores below 60 are subject 

to greater follow-up requirements than properties with scores of 60 or 

higher, and properties with scores of 30 or below are referred to the 

Departmental Enforcement Center. Furthermore, multifamily properties 

that score below a certain threshold will be reinspected annually, whereas 

properties with higher scores will be reinspected less frequently. In 

November 2000, HUD expects to issue a final rule with the thresholds for 

reinspections of multifamily properties.

The follow-up requirements for public housing are more complex. A public 

housing authority receives a physical condition score for each of its public 

housing properties. The properties’ scores are then combined into an 

overall indicator of the physical condition of the housing authority’s 

properties. The indicator for physical condition is then combined with 

three other indicators, derived from assessments of the housing authority’s 

financial health, management operations, and residents’ satisfaction, to 

arrive at an overall score for the housing authority. Starting June 30, 2000, 

2

Currently, HUD inspects housing that receives Section 8 project-based assistance (“projectbased” assistance is attached to the structure, whereas “tenant-based” assistance is attached 

to the resident).
Page 4 GAO-01-109 HUD Inspections

HUD’s policy has been to use this overall score to determine what followup actions its field offices need to take, as well as how soon the housing 

authority’s properties should be reinspected. (Previously, HUD treated the 

scores for public housing authorities as advisory—i.e., nonbinding.3

) When 

a housing authority receives an overall score below 70, HUD will generally 

require it to develop a formal improvement plan, and when an authority 

receives an overall score below 60, HUD will designate it as “troubled” and 

refer it to the Troubled Agency Recovery Center. Conversely, when a 

housing authority receives an overall score of at least 90, it may be 

designated as a “high performer.” High-performing housing authorities that 

also receive a physical condition score of at least 90 will be reinspected 

every other year, rather than annually. The purpose of the thresholds for 

both multifamily and public housing is to allow HUD to concentrate its 

monitoring resources on properties with lower scores.

Most physical inspection scores are based on inspections that cover a 

sample of units or buildings. The results for the sample of units or buildings 

are then used to estimate a score that represents the condition of the entire 

property. REAC’s protocol requires inspectors to inspect a statistical 

sample of units or buildings. HUD officials told us that sampling was the 

most cost-effective way to ensure that all properties get inspected. 

However, sampling introduces some uncertainty into the final inspection 

score. This uncertainty, or lack of precision, can be estimated using a 

measure called sampling error. 

Because REAC employs a sampling procedure (called probability 

sampling) to select the sample of units and buildings used to estimate a 

property’s physical condition score, each property’s estimated score has a 

measurable precision, or sampling error, which may be expressed as a 

plus/minus figure. A sampling error indicates how closely HUD can 

reproduce from a sample the score that HUD would have obtained if all 

units and buildings at the property had been inspected. By adding the 

sampling error to and subtracting it from the estimate, HUD can develop 

upper and lower bounds for each property’s estimated physical condition 

score. This range is called a confidence interval. Sampling errors and 

confidence intervals are stated at a certain confidence level—for example, 

95 percent. A confidence interval, at the 95-percent confidence level, means 

3

Prior to June 30, 2000, HUD reported the scores to housing authorities for informational 

purposes, requiring only that they correct any life-threatening health and safety violations 

found during inspections.
Page 5 GAO-01-109 HUD Inspections

that in 95 out of 100 instances, the sampling procedures that REAC used 

would produce a confidence interval containing the physical condition 

score that would have been obtained if all units and buildings at the 

property had been inspected.

Sampling Leads to 

Uncertainty About 

Follow-up 

Requirements

Nearly all of the properties that HUD inspects using the new physical 

inspection protocol are subject to a sampling of units, and a much smaller 

percentage are subject to a sampling of buildings. However, we found that, 

in its baseline inspections, HUD did not routinely estimate or consider the 

sampling error for each score. Using the information that REAC provided 

for a subset of inspected properties, we found that the sampling error was 

generally no more than 3 points, but for less than 1 percent of the 

properties, it was much higher—from 8 to 19 points. As a result, sampling 

caused some uncertainty about the appropriate type of follow-up required 

for some properties.

Sampling Error Varies 

Widely

Under its new physical inspection protocol, HUD inspects a sample of units 

for about 95 percent of the 40,000 properties it inspects, and for about 20 

percent of the properties, it inspects a sample of buildings. We asked REAC 

for information on the sampling error of the physical condition scores it 

had estimated for inspected properties. REAC provided us with the data it 

had used to study the effects of its current sampling procedures on 8,813 

properties—6,291 multifamily and 2,522 public housing properties.4

 Using 

REAC’s information, we computed the sampling error for these properties. 

We determined that the sampling error was 3 or fewer points for about 70 

percent of the 8,813 properties. However, the sampling error varied 

widely—from 0 to 19 points—as shown in table 1.

4

HUD’s current sampling procedures require the inspection of no more than 27 units, when 

dwelling units are sampled, and no more than 27 buildings with dwelling units, when 

buildings are sampled. The actual number of units and buildings sampled depends on the 

number of units and buildings in the property. For example, any property with more than 

1,461 units would have 27 units sampled for inspection.
Page 6 GAO-01-109 HUD Inspections

Table 1: Sampling Error for 8,813 Physical Inspection Scores

Note: The sampling error, rounded to the nearest whole point, is calculated at the 95-percent 

confidence level for inspections using the current maximum sample size of 27. We multiplied the 

standard error, supplied by REAC, by a t-value of 2 to obtain the sampling error. REAC’s samples 

ranged from 5 to 27 units. The appropriate t-values were 2.776 and 2.056 when the numbers of units 

sampled were 5 and 27, respectively. Because we used a t-value that was consistently lower than 

appropriate, our estimates somewhat understate the sampling error. We could not use the appropriate 

t-value because the data we obtained did not include the number of units sampled.

Source: GAO’s analysis of REAC’s data. 

Sampling Caused 

Uncertainty About Followup for Some Multifamily 

Properties

Multifamily properties are placed in one of four categories, depending on 

their inspection scores. Properties with scores of 60 and above are required 

only to correct deficiencies found during inspection, whereas properties 

with lower scores have additional requirements. When a property’s 

physical condition score is from 31 through 59, a HUD field office imposes 

follow-up requirements. When the score is 30 or below, the property is 

referred to the Departmental Enforcement Center. Table 2 lays out the 

different requirements for multifamily properties.

Sampling error in points

Sampling error of score Frequency Percent

Cumulative

percent

0 1,884 21.4% 21.4%

1 1,497 17.0% 38.4%

2 1,543 17.5% 55.9%

3 1,341 15.2% 71.1%

4 1,130 12.8% 83.9%

5 782 8.9% 92.8%

6 441 5.0% 97.8%

7 143 1.6% 99.4%

8 28 0.3% 99.7%

9 11 0.1% 99.9%

10-19 13 0.1% 100.0%

Total 8,813 100%
Page 7 GAO-01-109 HUD Inspections

Table 2: Follow-up Requirements for Multifamily Properties Based on Their 

Inspection Scores

Note: At all properties, regardless of score, deficiencies found during inspection must be corrected. 

Moreover, life-threatening health and safety deficiencies are expected to be corrected within a certain 

time frame, usually within a few days of the inspection.

Using information provided by REAC on 6,291 of the over 26,000 

multifamily properties it inspected, we determined the follow-up category 

to which each property would have been assigned, given its reported 

physical inspection score. We then determined, after considering the 

sampling error of the estimated score, whether HUD could be confident 

that the property would have been placed in the same follow-up category if 

its score, based on a full inspection of all of its buildings and units, had 

been known. For example, if a property’s score, based on a sample, was 33 

and the sampling error for the estimated score was plus or minus 5, the 

resulting confidence interval would range from 28 through 38. HUD 

therefore could not be sure whether this property belonged in the “30 and 

below” or the “31-45” category. As shown in table 3, sampling produced 

uncertainty about the appropriate requirements for 7.6 percent of the 6,291 

multifamily properties tested.

Physical inspection 

score Follow-up requirement

60 and above No certification or corrective plan is required unless the field 

office requests one.

46 − 59 The HUD field office requires the property owner to inspect all 

units and buildings and develop a plan of correction. The plan 

should give the results of the owner’s own inspection, list 

corrections already made to identified deficiencies, discuss 

plans to correct the remaining deficiencies, and list the 

resources to be used by the owner to make repairs.

31- 45 In addition to complying with the requirements for properties 

that received scores from 46 through 59, the property owner 

must develop a management improvement plan and complete 

its goals for correcting deficiencies. The field office can require 

another inspection to confirm the completion of repairs.

30 and below The property is referred to the Departmental Enforcement 

Center (DEC) for evaluation. DEC conducts an evaluation to 

confirm that the property should be assigned to it. The property 

owner is required to develop a plan to correct deficiencies, and 

the field office is required to ensure that all health and safety 

deficiencies are corrected in a timely manner.
Page 8 GAO-01-109 HUD Inspections

Table 3: Follow-up Referrals for 6,291 Multifamily Properties

Note: For an additional 4 to 6 percent of the multifamily properties, we could not tell whether the scores 

were reliable enough to place the properties in the correct follow-up category. The sampling error for 

these properties appeared to be reported as 0 simply because no variation in physical condition was 

observed among the sampled units or buildings. In such cases, the sampling error cannot be 

calculated, and we could not tell whether the score could reliably be used to determine the appropriate 

follow-up actions for the property. We assumed that appropriate actions could be determined for these 

properties, but, in so doing, we may have understated the percentage of properties whose categories 

may be affected by sampling error.

Source: GAO’s analysis of REAC’s data.

Besides using the physical condition scores to determine the follow-up 

requirements for multifamily properties, HUD plans to use the scores to 

determine how soon the properties will be reinspected once it issues the 

scoring thresholds for reinspection. For some properties, such decisions 

will also be subject to uncertainty because of sampling error.

Sampling will also cause uncertainty for some public housing properties. 

Once the public housing scores become binding, HUD will use the scores to 

determine the follow-up and reinspection requirements for public housing 

properties. However, the effect of sampling may be lessened for two 

reasons. First, the thresholds will be based on the physical condition of all 

properties within an authority. Second, the thresholds will be based on a 

number of factors in addition to the physical inspection score, including 

the authority’s financial health and management.

Properties whose placement in category 

was questionable after sampling error 

was considered

Follow-up category 

based on physical 

inspection score of

Number of

properties placed

in category Number Percent

60 and above 5,684 157 2.8%

46-59 384 218 56.8%

31-45 150 90 60.0%

30 and below 73 16 21.9%

Total 6,291 481 7.6%
Page 9 GAO-01-109 HUD Inspections

REAC officials told us that REAC has established many safeguards to 

ensure that the physical inspection process is accurate and fair. These 

include quality assurance activities at various levels of the inspection 

process, technical reviews of inspections, appeals procedures, and 

postinspection reviews. They said that all of these processes can be used to 

help address concerns about the accuracy and reliability of inspections. 

However, none of these processes directly deal with uncertainties in 

inspection scores stemming from sampling error.5

In an August 2000 meeting, REAC’s Director told us that REAC was 

planning, on the basis of discussions with us about sampling issues, to 

calculate confidence intervals for all inspection scores for internal use. In 

addition, for properties whose scores are close to the administrative 

thresholds HUD uses in determining follow-up actions (30 and 60), REAC 

would request that HUD field offices consider other information on the 

condition of these properties to help ensure that they are placed in the 

appropriate follow-up category. Finally, for other properties whose scores 

are associated with unusually large sampling errors, REAC would examine 

the reasons for the large sampling errors and either take actions to reduce 

the errors or alert the appropriate HUD field offices if there is uncertainty 

about what follow-up actions should be taken.

In its October 13, 2000, letter commenting on our draft report, HUD stated 

that it plans to use an alternative approach for addressing our concerns 

about sampling error. HUD is now proposing that when the confidence 

interval for a property’s inspection score crosses one of its key 

administrative thresholds for determining follow-up actions (30 or 60 

points), it will adjust the score downward so that the property will be 

treated as if its score falls into the follow-up category requiring more 

intensive monitoring. While this approach differs somewhat from the 

approach that HUD proposed in the August 2000 meeting and that we had 

discussed with REAC officials, we believe that it should still address our 

basic concerns.6

5

Our July report discusses other concerns about the reliability of REAC’s inspection scores.

6

The approaches that we had discussed generally focused on having HUD program offices 

perform additional analyses for properties whose scores could not be relied on to ensure 

that appropriate follow-up actions were taken. For example, if there were uncertainty due to 

sampling error about whether a property’s score was above or below 60, staff might take 

into account the owner’s past responsiveness in addressing physical defects when 

determining whether a written corrective action plan should be required.
Page 10 GAO-01-109 HUD Inspections

We recognize that HUD’s proposal focuses on two key administrative 

thresholds (30 and 60 points) and does not specifically cover other 

administrative thresholds that HUD uses to determine follow-up or 

reinspection requirements. However, the fact that HUD will routinely 

calculate the sampling error for all inspection scores should help it 

determine the extent to which sampling may cause uncertainty about 

decisions in these areas as well. This should put HUD in a good position to 

continue identifying strategies and opportunities to mitigate the effects of 

uncertainty caused by sampling.

REAC’s Scoring 

Formula Is Not 

Consistent With Its 

Sampling Technique

REAC attempted to reduce the sampling error associated with its 

inspection scores by giving buildings with a large number of units a greater 

chance of being selected for inspection than other buildings. Although the 

use of such a sampling procedure is acceptable, the formula that REAC 

used to calculate the inspection scores was not consistent with this 

sampling approach. REAC used a formula that was appropriate only when 

all units and all buildings with dwelling units at a property had an equal 

chance of being inspected. As a result, HUD incorrectly calculated some 

inspection scores. HUD tested a method for calculating the score that 

corrected this problem, using data for 5,030 properties, and found that the 

revision changed the scores of about 30 percent of these properties (see 

table 4).

Table 4: Change in Physical Condition Score After Accounting for the Probability of 

Selection for Inspection

Source: GAO’s analysis of REAC’s tables.

Change in points

Change in score Number of properties

Percentage of

properties

0 3,561 70.8%

1 1,058 21.0%

2 258 5.1%

3 84 1.7%

4−9 69 1.4%

Total 5,030 100.0%
Page 11 GAO-01-109 HUD Inspections

While the scores of 97 percent of the properties tested changed by no more 

than 2 points, the scores for 69 (or 1.4%) of the 5,030 properties changed by 

4 to 9 points. As noted, when a score changes by even one point, the followup requirements can change. Among the 69 properties whose scores 

changed by 4 or more points, REAC identified 6 properties whose follow-up 

requirements could have been affected.7

 For example, one multifamily 

property in this analysis received a score of 64. Given this score, HUD 

would not have required a corrective plan for the property. However, when 

the differing probabilities of buildings’ and units’ selection for inspection 

were considered, the property received a score of 58 points. With this 

score, the HUD field office would require the owner to inspect all of the 

property’s units and buildings and develop a corrective plan to ensure the 

repair of all deficiencies.

REAC agrees that, for complete accuracy, the scores estimated from 

samples of units and buildings should account for differing probabilities of 

selection. In an August meeting, REAC officials told us they were 

introducing new sampling procedures that would nearly equalize the 

chance that each of a property’s dwelling units would be selected for 

inspection. They said that information obtained during the baseline 

inspections made the new sampling method feasible.

In its October 13, 2000, letter commenting on our draft report, HUD agreed 

to take further actions to address our concerns. HUD said it would change 

its sampling procedures to obtain a self-weighting sample of units and 

modify the inspection-scoring algorithm to include the probability of 

selection for sampled buildings. These actions, when implemented, should 

address our concerns in this area.

Conclusions We understand REAC’s need to sample buildings and units when 

performing physical inspections and recognize the inherent uncertainty 

associated with sampling. However, it is important for REAC to recognize 

both the extent to which this uncertainty affects its inspection scores and 

the need for appropriate procedures to mitigate the effects of the 

uncertainty. The actions that HUD is proposing to take in response to our 

concerns about its sampling procedures should, we believe, basically 

address these concerns.

7

REAC did not provide information on how frequently the changes in the scores for the 

other 1,400 properties affected their follow-up requirements.
Page 12 GAO-01-109 HUD Inspections

Agency Comments and 

Our Evaluation

We provided HUD with a draft of this report for its review and comment. 

HUD said that to resolve our concerns, it has revised its procedures to 

ensure that all inspected properties are properly and consistently 

monitored in accordance with risk management practices and it will alter 

scoring-related processes to increase precision.

More specifically, to address the recommendations we made in our draft 

report, HUD stated that it would begin calculating the confidence interval 

for every inspection score. In addition, HUD said that when the confidence 

interval for a property’s inspection score crossed one of the key 

administrative thresholds for determining follow-up actions (30 or 60 

points), it would adjust the score downward so that the property would be 

treated as if its score fell into the follow-up category requiring more 

intensive monitoring by HUD. According to HUD, this action would reduce 

or eliminate the risk of inadequate monitoring. HUD noted that it expected 

this action would affect only about 3 percent of its multifamily properties 

and that the benefits of increased scrutiny would exceed the inconvenience 

to a small number of property owners.

HUD also agreed to change its data collection, scoring, and reporting 

processes to incorporate new sampling procedures in its inspection data 

collection device to obtain a self-weighting sample of units, modify the 

inspection-scoring algorithm to include the probability of selection for 

sampled buildings, and modify its inspection summary report to show the 

probability of selection for sampled buildings.

We revised our report to include the actions HUD is proposing. We also 

dropped our draft report’s recommendations for improvements in these 

areas, since HUD’s actions, when implemented, should address our basic 

concerns about HUD’s sampling procedures. The complete text of HUD’s 

comments appears in appendix I.

Scope and 

Methodology

To determine whether REAC’s procedures were producing inspection 

scores that could reliably be used to determine the appropriate follow-up 

requirements for inspected properties, we reviewed REAC’s current 

sampling procedures and discussed these procedures with the appropriate 

REAC officials. We also obtained REAC’s calculations of standard errors 

and scores for 8,813 properties—including 6,291 multifamily and 2,522 

public housing properties—inspected using the current sampling 

procedures. We calculated the sampling error for each property using its 
Page 13 GAO-01-109 HUD Inspections

inspection score and standard error. From the 6,291 multifamily properties, 

we identified those for which the sampling error introduced uncertainty 

about the appropriate follow-up action.

To determine whether the method used to compute scores was correctly 

estimating the score a property would have received if the entire property, 

and not just a sample of its dwelling units or buildings, had been inspected, 

we reviewed REAC’s documentation for sampling procedures and formula 

for calculating scores. We obtained REAC’s analysis of how the scores for 

5,030 properties would change if the formula were changed. We also 

discussed REAC’s procedures and analysis with appropriate REAC 

officials. We conducted our work from December 1999 through October 

2000 in accordance with generally accepted government auditing 

standards. 

We are sending copies of this report to Honorable Rick Lazio, Chairman, 

and the Honorable Barney Frank, Ranking Minority Member, 

Subcommittee on Housing and Community Opportunity, House Committee 

on Banking and Financial Services, who requested our July 2000 report on 

HUD’s physical inspection system. We will also make copies of this report 

available to others on request. If you or your staff have any questions about 

this report, please call me at (202) 512-7631. Key contributors to this report 

were Karen Bracey, Martha Chow, and Richard Hale.

Sincerely yours,

Stanley J. Czerwinski

Director, Physical Infrastructure Issues 
Page 14 GAO-01-109 HUD Inspections

Appendix I

Comments From the Department of Housing Apendxies

and Urban Development ApendxiI
Appendix I

Comments From the Department of Housing 

and Urban Development

Page 15 GAO-01-109 HUD Inspections
Appendix I

Comments From the Department of Housing 

and Urban Development

Page 16 GAO-01-109 HUD Inspections

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