Testimony 

Before the Special Committee on Aging, 

U.S. Senate

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 10:00 a.m. EDT 

Tuesday, June 17, 2003 ELDERLY HOUSING 

Project Funding and Other 

Factors Delay Assistance to 

Needy Households 

Statement of David G. Wood, Director 

Financial Markets and Community Investment 

GAO-03-807T 
As the only federal housing program that targets all of its rental units to very 

low income elderly households, HUD’s Section 202 program provides a 

valuable housing resource for these households. Although they represent a 

small share of all elderly households, very low income elderly renters have 

acute housing affordability problems because of their limited incomes and 

need for supportive services. The Section 202 program offers about 260,000 

rental units nationwide and ensures that residents receive rental assistance 

and access to services that promote independent living. However, even with 

the program’s exclusive focus, Section 202 has only reached an estimated 8 

percent of very low income elderly households. 

More than 70 percent of Section 202 projects in GAO’s analysis did not meet 

HUD’s time guideline for gaining approval to start construction. These 

delays held up the delivery of housing assistance to needy elderly 

households by nearly a year compared with projects that met HUD’s 

guideline. Several factors contributed to these delays, particularly capital 

advances that were not sufficient to cover development costs. Project 

sponsors reported that because of insufficient capital advances, they often 

had to spend time seeking additional funds from HUD and other sources. 

Although HUD’s policy is to provide sufficient funding to cover the cost of 

constructing a modestly designed project, HUD has acknowledged that its 

capital advances for the Section 202 program sometimes fall short. Other 

factors affecting the timeliness of the approval process include inadequate 

training and guidance for field staff responsible for the approval process, 

inexperienced project sponsors, and local zoning and permit requirements. 

Housing Cost Burdens of Very Low Income Elderly Renter Households in 2001 

In 2001, an estimated 2 million 

elderly households with very low 

incomes (50 percent or less of area 

median income) did not receive 

housing assistance. The 

Department of Housing and Urban 

Development (HUD) considered 

most of these households to be 

“rent burdened” because they spent 

more than 30 percent of their 

incomes on rent. The Section 202 

Supportive Housing for the Elderly 

Program provides capital advances 

(grants) to nonprofit organizations 

to develop affordable rental 

housing exclusively for these 

households. Based on a report 

issued in May 2003, this testimony 

discusses the role of the Section 

202 program in addressing the need 

for affordable elderly housing and 

factors affecting the timeliness of 

approving and constructing new 

projects. 

In its report, GAO made 

recommendations designed to 

reduce the time required for 

projects to receive approval from 

HUD to start construction. 

Specifically, GAO recommended 

that HUD assess the effectiveness 

of the methods it uses to calculate 

the size of the Section 202 capital 

advances and make any 

appropriate changes to them. GAO 

also made other recommendations 

to improve HUD’s administration 

and oversight of the 202 program’s 

performance. 

HUD concurred with the 

recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-03-807T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact David G. Wood 

at (202) 512-8678 or WoodD@gao.gov. 

Highlights of GAO-03-807T, a testimony 

before the Special Committee on Aging, 

U.S. Senate 

June 2003

ELDERLY HOUSING 

Project Funding and Other Factors Delay 

Assistance to Needy Households 
Page 1 GAO-03-807T 

Mr. Chairman and Members of the Committee: 

I appreciate the opportunity to be here today to discuss the Department of 

Housing and Urban Development’s (HUD’s) Section 202 Supportive 

Housing for the Elderly Program. The Section 202 program provides funds 

to nonprofit organizations to develop affordable rental housing exclusively 

for very low income elderly households that do not receive other forms of 

housing assistance. In 2001, there were an estimated 2 million such 

households in the nation, most of which HUD considered “rent burdened” 

because their rents exceeded 30 percent of their household incomes. 

Section 202 provides two types of financial support. First, HUD provides a 

project sponsor with a capital advance—essentially a grant—to cover land 

and construction costs. HUD’s policy is to have the capital advance cover 

the total development costs of the project, which must be of modest 

design and must comply with HUD’s minimum property standards. HUD 

uses a competitive process to select projects for funding and has 

guidelines calling for project sponsors and the agency’s field offices to 

accomplish project processing activities—such as completing and 

approving design plans—within 18 months so that construction may 

commence. (HUD’s field offices may grant extensions of up to 6 months 

without headquarters’ approval.) Second, after the project is completed, 

HUD provides the sponsor with monthly rental assistance payments to 

defray some of the operating expenses. For fiscal year 2002, Congress 

appropriated about $783 million for the Section 202 program to fund the 

construction of over 6,000 new units, multiyear rental assistance contracts, 

and other authorized activities. 

My statement today is based on the report on the Section 202 program that 

you requested and are releasing today.1

 Specifically, my statement 

discusses: (1) the role of the Section 202 program in meeting the housing 

needs of elderly renter households with very low incomes, (2) the extent 

to which Section 202 projects meet HUD’s time guideline for approving 

projects to start construction, and (3) the factors that keep Section 202 

projects from meeting the time guideline. In preparing the report, we 

analyzed data from HUD and other sources on the housing needs of very 

low income elderly households. In addition, we reviewed HUD program 

and budget data, surveyed all 45 HUD field offices that process Section 202 

 1

Elderly Housing: Project Funding and Other Factors Delay Assistance to Needy 

Households, May 30, 2003 (GAO-03-512). 
Page 2 GAO-03-807T 

projects, and surveyed and interviewed project sponsors and consultants 

experienced in working with the Section 202 program. Our analysis 

focused on Section 202 projects funded between fiscal years 1998 and 

2000.2

In summary: 

• As the only federal housing program that targets all of its rental units to 

very low income elderly households, Section 202 is an important source of 

affordable housing for these households. Section 202 insulates tenants in 

housing units subsidized by the program from increases in housing costs 

by limiting their rents to 30 percent of household income. As of 2001, the 

program provided housing for an estimated one-fifth of the 1.3 million 

elderly renter households with very low incomes that received some form 

of government housing assistance. However, nationwide about 1.7 million 

elderly renter households with very low incomes did not receive 

government housing assistance and had a housing affordability problem—

that is, they paid over 30 percent of their incomes for rent. Even with the 

program’s exclusive focus, Section 202 has only reached an estimated 8 

percent of very low income elderly renter households. 

• More than 70 percent of Section 202 projects funded between 1998 and 

2000 were delayed—that is, they took longer than the 18 months set out in 

HUD’s guidelines to proceed from the date of the funding award to the 

date of HUD’s approval to start construction (the project processing 

period). However, a majority of projects were approved for construction 

within 24 months, or 18 months plus the 6-month discretionary extension. 

Projects located in metropolitan areas were more likely than projects in 

nonmetropolitan areas to exceed the 18-month guideline. Further, projects 

that exceeded the 18-month guideline ultimately took an average of 11 

months longer to finish than projects that met the time guideline, and 

these delayed projects contributed to the program’s unexpended fund 

balances. At the end of fiscal year 2002, 14 percent of the Section 202 

program’s $5.2 billion in unexpended appropriations was associated with 

projects that had not yet been approved for start of construction after 18 

months. 

• Several factors impeded the timely processing of projects, according to 

project sponsors, consultants, and HUD field office staff. First, despite 

 2

Lack of reliable program data prevented us from reviewing all Section 202 projects funded 

before fiscal year 1998. 
Page 3 GAO-03-807T 

HUD’s intent, capital advances have not always covered the cost of 

developing projects, and the resulting shortfalls often prolonged 

processing times, in part because sponsors needed to seek additional 

funding. Second, field office staff’s inconsistent implementation of 

procedures intended to streamline processing, as well as limited training 

and out-of-date guidance on processing policies and procedures, impeded 

timely processing. Third, HUD’s project monitoring system has limitations 

that may have hindered HUD’s ability to oversee project timeliness. 

Finally, other factors—including inexperienced sponsors and local permit 

and zoning requirements—prolonged processing time for some projects. 

Based on our findings, we recommended that HUD evaluate the 

effectiveness of the current methods for calculating capital advances and 

make any changes necessary to ensure that capital advances adequately 

cover development costs. We made three additional recommendations—

concerning HUD’s training of field office staff, handbook guidance, and 

data systems—directed at more timely processing of projects. In 

commenting on the report, HUD agreed with the recommendations. 

HUD defines elderly households as those in which the householder—the 

person whose name is on the lease, mortgage, or deed—or the 

householder’s spouse is at least 62 years old. Elderly households occupied 

about one-quarter (26 million) of the approximately 106 million housing 

units in the United States in 2001, according to the American Housing 

Survey.3

 A large majority of these elderly households were homeowners. A 

small share of elderly households, about 19 percent or 5 million, rented 

their homes (compared to about 36 percent of nonelderly households), 

and about 3.3 million of these elderly households were renters with very 

low incomes—that is, 50 percent or less of area median income. 

The Housing Act of 1959 (P.L. 86-372) established the Section 202 program, 

which began as a direct loan program that provided below-market interest 

rate loans to private nonprofit developers, among others, to build rental 

housing for the elderly and people with disabilities. In 1990, the CranstonGonzalez National Affordable Housing Act (P.L. 101-625) modified Section 

 3

As in other surveys, estimates from the American Housing Survey are subject to both 

sampling and nonsampling errors. All numerical estimates derived from the survey have 

sampling errors of ±10 percent or less of the value of those numerical estimates, unless 

otherwise noted. All percentage estimates have sampling errors of ±6 percentage points or 

less, unless otherwise noted. 

Background 
Page 4 GAO-03-807T 

202 by converting it from a direct loan program to a capital advance 

program. 

In its current form, Section 202 provides capital advances—effectively 

grants—to private nonprofit organizations (usually referred to as sponsors 

or owners) to pay for the costs of developing elderly rental housing. As 

long as rents on the units remain within the program’s guidelines for at 

least 40 years, the sponsor does not have to pay back the capital advance. 

HUD calculates capital advances in accordance with development cost 

limits that it determines annually, and HUD’s policy is that these limits 

should cover the reasonable and necessary costs of developing a project of 

modest design that complies with HUD’s project design and cost standards 

as well as meets applicable state and local housing and building codes. 

To be eligible to receive Section 202 housing assistance, households must 

have very low income and one member who is at least 62 years old. 

Section 202 tenants generally pay 30 percent of their income for rent. 

Because their rental payments are not sufficient to cover the property’s 

operating costs, the project sponsor receives rental assistance payments 

from HUD to cover the difference between the property’s operating 

expenses (as approved by HUD) and total tenant rental receipts.4

 In 

addition, the project sponsor can make appropriate supportive services, 

such as housekeeping and transportation, available to these elderly 

households. 

From year to year, Section 202 has carried significant balances of 

unexpended appropriated dollars for capital advances and rental 

assistance payments. In fiscal year 2002, the unexpended balance for 

Section 202 was approximately $5.2 billion. About 41 percent of this 

balance was in capital advance funds and 59 percent was in rental 

assistance funds. Some of these unexpended funds have not yet been 

awarded to projects, and others are for projects that have not begun 

construction. Once construction begins, funds are expended over several 

years during the construction phase and during the term of the rental 

assistance contracts. 

 4

The term on rental assistance contracts is 5 years, although HUD has authorized these 

contracts for as long as 20 years. After these contracts expire, HUD renews them for 5 

years, subject to the availability of funds. 
Page 5 GAO-03-807T 

Other federal programs can provide housing assistance to needy elderly 

households, albeit not exclusively. For example, low income housing tax 

credits and tax-exempt multifamily housing bonds provide federal tax 

incentives for private investment and are often used in conjunction with 

other federal and state subsidies in the production of new and 

rehabilitated rental housing. The Housing Choice Voucher Program 

supplements tenants’ rental payments in privately owned, moderately 

priced apartments chosen by the tenants. Currently, about 260,000 of the 

approximately 1.5 million voucher households are elderly. Other programs 

are discussed in an appendix to the report. 

Section 202 is the only federal housing program that targets all of its rental 

units to very low income elderly households. Because these households 

often have difficulty affording market rents, program funding is directed to 

localities based in part on their proportions of elderly renter households 

that have a housing affordability problem. Section 202 insulates tenants in 

housing units subsidized by the program from increases in housing costs 

by limiting rents to a fixed percentage of household income. The program 

is a significant source of new and affordable housing for very low income 

elderly households. Even with the program’s exclusive focus on the very 

low income elderly, Section 202 has reached only a small share of eligible 

households. 

Congress specifically intended the Section 202 program to serve very low 

income elderly households and to expand the supply of affordable housing 

that can accommodate the special needs of this group.5

 HUD takes into 

account the need for the kind of housing Section 202 provides when 

allocating program funds to the field offices. The criteria for allocating 

funds to the field offices include, among other things, the total number of 

very low income elderly renters in the area and the number in this group 

that pay more than 30 percent of their incomes for rent. According to the 

American Housing Survey, in 2001 about 1.7 of the 3.3 million elderly 

renters with very low incomes paid over 30 percent of their incomes for 

rent. 

The rent that tenants in Section 202 housing pay equals a percentage of 

their household incomes—generally 30 percent. This percentage remains 

 5

12 U.S.C. 1701q(a). 

Section 202 Is an 

Important Source of 

Housing for Elderly 

Households with Very 

Low Incomes 

Section 202 Targets Very 

Low Income Elderly 

Households and Makes 

Supportive Services 

Available 
Page 6 GAO-03-807T 

constant, so the amount of rent tenants pay increases only when 

household income rises, protecting them from rent increases that might be 

imposed by the private housing market when market conditions change. In 

contrast, very low income elderly renter households that do not receive 

this type of assistance are vulnerable to high rent burdens and increases in 

market rents. Most of these households have few or no financial 

resources, such as cash savings and other investments, and rely primarily 

on fixed incomes that may not increase at the same rate as market rents. 

Section 202 serves another important function, potentially allowing elderly 

households to live independently longer by offering tenants a range of 

services that support independent living—for example, meal services, 

housekeeping, personal assistance, and transportation. HUD ensures that 

sponsors have the managerial capacity to assess tenants’ needs, 

coordinate the provision of supportive services, and seek new sources of 

assistance. HUD pays a small portion of the costs of providing these 

services through its rental assistance payments. 

According to the American Housing Survey, in 2001 about 1.3 million, or 40 

percent, of elderly renter households with very low incomes received 

some form of rental assistance from a government housing program, 

including Section 202. According to our analysis of HUD program data, 

about 260,000 Section 202 units with rental assistance generally served 

very low income elderly households in 2001. Taken together, these two 

sources of data suggest that Section 202 served around one-fifth of the 1.3 

million assisted elderly households identified in the American Housing 

Survey.6

While Section 202 is an important source of affordable elderly housing, the 

program has reached a relatively small fraction of very low income elderly 

renter households. Between 1985 and 2001, Section 202 reached no more 

than about 8 percent of elderly households eligible for assistance under 

the program. Also, during this period, many of the elderly renter 

households with very low incomes—ranging from about 45 to 50 

percent—had housing affordability problems. Other federal programs that 

develop rental housing generally target different income levels, serve other 

populations in addition to the elderly (including families with children and 

 6

Because this estimate is derived from two different sources, we cannot give a precise 

percentage; thus, this estimate is intended to be illustrative. 

Section 202 Provides an 

Estimated One-Fifth of All 

Government-Subsidized 

Housing for Very Low 

Income Elderly Renters 
Page 7 GAO-03-807T 

people with disabilities) and do not require housing providers to offer 

supportive services for the elderly. 

Most of the Section 202 projects funded between fiscal years 1998 and 

2000 did not meet HUD’s guideline for approving the start of construction 

within 18 months. However, a slight majority of the projects were 

processed and approved to start construction within 24 months. 

Timeliness varied both across HUD’s field offices and by project location 

(metropolitan versus nonmetropolitan areas). As well as taking longer to 

complete than other projects and thus delaying benefits to very low 

income elderly households, projects that were not approved for 

construction after the 18-month time frame increased the Section 202 

program’s year-end balances of unexpended appropriations. 

HUD’s guidelines state that within 18 months of the funding award date, 

field offices and project sponsors must complete various task before 

construction can commence (fig.1). Altogether, 73 percent of the Section 

202 projects funded from fiscal years 1998 through 2000 did not meet this 

18-month processing time guideline. These projects accounted for 79 

percent of the nearly $1.9 billion in funding awarded to projects during this 

period. Also during this period, 78 percent of projects located in 

metropolitan areas exceeded the 18-month guideline as opposed to 61 

percent of projects located in nonmetropolitan areas. 

Figure 1: Section 202 Project Processing 

HUD field offices may grant an extension of up to 6 months after the 18-

month guideline for projects needing more time to gain approval to start 

Section 202 Projects 

Generally Did Not 

Meet Guidelines for 

Timeliness 

HUD Took Longer Than 18 

Months to Approve Most 

Projects for Construction 
Page 8 GAO-03-807T 

construction, and many projects were approved within that 6-month time 

frame. Of the projects funded from fiscal years 1998 through 2000, HUD 

approved 55 percent for construction within 24 months of the funding 

award—27 percent within 18 months and 28 percent within 19 to 24 

months. The remaining 45 percent of projects took longer than 24 months 

to be approved. 

We looked at the performance of HUD’s 45 field offices that process 

Section 202 projects and found that they had varying degrees of success in 

meeting the 18-month guideline. We evaluated their performance by 

estimating the percentage of projects approved for construction within 18 

months for each field office. Among these offices, the median project 

approval rate for construction within 18 months was 22 percent, but their 

performance varied widely. Eight field offices had no projects that met the 

18-month guideline, while at one office more than 90 percent of projects 

met the guideline. Field offices’ performance varied by region, with those 

located in the northeast and west being least likely to approve projects 

within 18 months of the funding award. 

Meeting processing time guidelines is important because most of the 

delays in total production time—that is, the time between funding award 

and construction completion—stem from the project processing phase. 

When we compared the average total production times for completed 

projects that did not meet HUD’s 18-month processing guideline and those 

that did, the delayed projects took 11 months longer than other projects to 

proceed from funding award to construction completion. Since the 

average time taken for the construction phase was very similar for all 

projects, most of the 11-month difference in total production time was 

attributable to the extra 10 months that delayed projects took to complete 

the processing phase. 

Delayed processing of Section 202 projects also affected the Section 202 

program’s overall balances of unexpended appropriations. At the end of 

fiscal year 2002, for example, HUD had a total of $5.2 billion in 

unexpended Section 202 funds. A relatively small part of these 

unexpended funds—about 14 percent—was attributable to projects that 

had not yet been approved to start construction and had exceeded HUD’s 

18-month processing time guideline. Consequently, none of the funds 

reserved for these projects had been expended. By contrast, the remaining 

86 percent of unexpended funds were associated with projects for which 

HUD was in the process of expending funds for construction or rental 

assistance. For example, almost half of the unexpended balances—about 

Delayed Projects Affected 

the Program’s Production 

Times and Expenditures 
Page 9 GAO-03-807T 

48 percent—resulted from projects that had already been completed but 

were still drawing down their rental assistance funds as intended under 

the multiyear project rental assistance contract between HUD and the 

project sponsor. 

Our review of projects funded from fiscal years 1998 through 2000 shows 

that several factors impeded Section 202 projects from meeting the 18-

month processing time guideline, including insufficient capital advances, 

limited training and guidance for HUD field office staff on processing 

policies and procedures, and limitations in HUD’s project monitoring 

system. Factors external to HUD, such as sponsors’ level of development 

experience and requirements established by local governments, also 

hindered processing. 

Although HUD policy intends for capital advances to fund the cost of 

constructing a modestly designed project, capital advances have not 

always been sufficient to cover these expenses.7

 HUD field office staff, 

project sponsors, and consultants reported that program limits on capital 

advances often kept projects from meeting HUD’s time guideline for 

approving projects for construction. Most field offices, and every sponsor 

and consultant that we surveyed, reported that insufficient capital 

advances negatively affected project processing time, and a substantial 

majority of respondents indicated that this problem occurred frequently. 

Many respondents also reported that securing secondary financing to 

supplement the capital advance amount often added to processing time. 

According to nearly all sponsors and consultants, the capital advance 

amounts set by HUD were frequently inadequate to cover land, labor, and 

construction costs as well as fees imposed by local governments. As a 

result, sponsors had to seek secondary financing from other federal, state, 

and local sources—including other HUD programs—or redesign projects 

to cut costs, or both. According to a HUD official, the agency is currently 

initiating steps to study the sufficiency of capital advances in covering 

project development costs. 

 7

See 66 Fed. Reg. 6647 (Jan. 22, 2001). 

Various Factors Can 

Delay the Approval of 

Projects for 

Construction 

Insufficient Capital 

Advances Caused Some 

Sponsors to Seek Other 

Funding 
Page 10 GAO-03-807T 

In 1996, to help ensure that field office staff and project sponsors could 

complete project processing requirements within the 18-month time 

guideline, HUD adopted changes that were intended to streamline 

processing procedures.8 One of the key changes included requiring field 

office staff to accept sponsor-provided certifications of architectural 

plans, cost estimates, and land appraisals. Previously, field office staff 

performed detailed technical reviews of these items. 

According to our survey, differences in the procedures field offices used to 

approve projects for construction and the lack of staff training and 

experience affected project processing time. For example, most 

consultants and sponsors in our survey responded that inconsistent 

implementation of streamlined processing procedures by field offices 

caused delays, as did insufficient training for and inexperience of field 

office staff. Some consultants and sponsors whom we interviewed told us 

that some field offices continued to conduct much more detailed and timeconsuming technical reviews of project plans than HUD’s current policies 

require. 

HUD has provided limited guidance for field office staff on the current 

processing policies and procedures. At the time of our review, most field 

office staff had not received any formal training on Section 202 project 

processing. According to HUD, in 2002, the agency required 

representatives from each field office to attend the first formal training on 

project processing for field office staff since at least 1992. Although HUD 

headquarters expected those who attended to relay what they had learned 

to other staff members in their own offices, our survey showed that by 

November 2002 no on-site training had occurred at about a quarter of the 

field offices. We also found that HUD’s field office staff was relying on outof-date program handbooks that did not reflect the streamlined processing 

procedures. 

HUD’s project monitoring system was not as effective as it could have 

been and may have impeded HUD’s oversight of project processing. HUD 

officials told us that headquarters periodically uses its Development 

Application Processing (DAP) system to identify projects that have 

exceeded the 18-month processing time guideline. In addition, 

headquarters contacts field offices on a quarterly basis to discuss the 

 8

HUD Notice H 96-102. 

Varying Field Office 

Practices and Inadequate 

Staff Training and 

Guidance Affected Timely 

Processing 

Administrative and 

Oversight Weaknesses at 

HUD Headquarters 

Contributed to Delays 
Page 11 GAO-03-807T 

status of these delayed projects. Nevertheless, HUD officials have 

acknowledged that there are data inaccuracies in the DAP system. The 

lack of reliable, centralized data on the processing of Section 202 projects 

has limited HUD headquarters’ ability to oversee projects’ status, 

determine problematic processing stages, and identify field offices that 

may need additional assistance. HUD officials indicated that enhancing the 

DAP system is a priority, but that a lack of funding has hindered such 

efforts. 

Finally, other factors outside of HUD’s direct control kept some projects 

from meeting the time guideline, according to field office representatives 

and sponsors and consultants responding to our survey. Almost all survey 

respondents agreed that project processing time was negatively affected 

when sponsors were inexperienced in project development. Nearly 60 

percent of field offices, and almost 40 percent of sponsors and 

consultants, indicated that this problem occurred frequently. A majority of 

survey respondents reported that local government permitting and zoning 

requirements prolonged project processing, although we found differences 

of opinion on whether these problems occurred frequently. Community 

opposition and environmental issues were also reported to negatively 

affect project processing time, but not frequently. 

Mr. Chairman, this concludes my prepared statement. I would be happy to 

answer any questions at this time. 

For further information on this testimony, please contact David G. Wood 

at (202) 512-8678 or Paul Schmidt at (312) 220-7681. Individuals making 

key contributions to this testimony included Emily Chalmers, Mark Egger, 

Daniel Garcia-Diaz, William Sparling, and Julianne Stephens. 

Contacts and 

Acknowledgments 

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