MANAGEMENT CASE STUDY

Public Housing Management Assessment Program
U.S. Department of Housing and Urban Development

Office of Policy Development and Research

May 9, 1996
Case Study Cover Sheet

This case study of the Public Housing Management Assessment

Program (PHMAP) was prepared by the Office of Policy Development

and Research (PD&R) in the U.S. Department of Housing and Urban

Development (HUD). Margery A. Turner, Deputy Assistant Secretary

for Research, Evaluation and Monitoring, PD&R, and MaryAnn Russ,

Director, Office of Assisted Housing, Office of Public and Indian

Housing (PIH) directed the preparation of this paper. The

following staff contributed: Roger Braner (PIH), John Carson

(PD&R), Wanda Funk (PIH), Kevin Neary (PD&R), Jean Lin Pao

(PD&R), William Thorson (PIH), and Elena Van Meter (PD&R).

This paper was requested by the Office of Management and

Budget and the American Society for Public Administration (ASPA)

Government Accomplishment and Accountability Task Force.

The PHMAP case study illustrates a Federal management

initiative to improve performance by local government partners. 

Many Federal programs involve the local administration of Federal

funds. Such programs pose the administrative challenge of

ensuring effective management while permitting local discretion. 

HUD's PHMAP program provides an example that may be of interest

Federal agencies, such as Labor, Health and Human Services,

Commerce, and others seeking to promote effective local

administration of Federal resources.
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PUBLIC HOUSING MANAGEMENT ASSESSMENT PROGRAM

Context

The Public Housing Management Assessment Program (PHMAP,

pronounced FEE-map) resulted from an effort by the Department of

Housing and Urban Development (HUD) to improve the management of

public housing. The public housing program operates more than

1.4 million housing units around the country. The Federal

government, through HUD, is the major funder of the program, but

the actual day to day operations of public housing are

administered by about 3,200 local public housing agencies (PHAs).

Within HUD, the public housing program is administered by

the Office of Public and Indian Housing (PIH). PIH has

approximately 1,300 full time equivalent employees. In addition

to the public housing program, PIH is responsible for

administering the Section 8 housing assistance program. Overall,

the fiscal year 1995 funding level for program administered by

PIH was about $14.5 billion. The principal programs for public

housing were funded in fiscal year 1995 as follows: 

modernization, $2.9 billion; operating subsidies, $2.9 billion;

drug elimination, $290 million; Indian housing, $282 million; and

revitalization of distressed public housing, $500 million.

Most of the public housing stock was constructed between the

1950s and the 1980s, and very little public housing has been

constructed in recent years. The primary costs associated with

public housing now are those necessary to operate and modernize

the existing stock. Since most public housing residents have

very low incomes, the rents they pay result in revenues that are

far less than the costs of operating the units they live in. 

Thus, HUD provides funding to the PHAs to subsidize program

operations and modernization.

The PHAs themselves own and manage public housing. They

collect rents, maintain waiting lists, fill vacancies, perform

maintenance, provide tenant services, and carry out the other

tasks necessary to manage rental housing. HUD has an oversight

responsibility, however. HUD needs to ensure that its subsidies

are well-used and that the public housing program provides

low-income Americans with the decent, safe, and sanitary housing

that Congress intended.
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Historically, HUD has performed this oversight function

through regulation and monitoring. By regulation, HUD specifies

how PHAs must act in administering the programs that subsidize

public housing. HUD field staff located in offices throughout

the country, make monitoring visits to PHAs. In these visits,

they inspect units and review documents to make sure that the 

PHAs are administering the program effectively.

This traditional approach to managing Federal programs has

some drawbacks. For one thing, in a national program it can be

difficult to ensure that HUD is applying the same standards to

PHAs in different parts of the country. PHMAP originally was

developed as a means of providing uniform objective standards for

PHAs across the country. 

The approach that emphasizes monitoring also tends to be

expensive, because it requires significant staff preparation and

travel for intensive reviews of PHA operations. And, this

expense may be misplaced. As regulations proliferate, the

monitoring approach sometimes may overemphasize process at the

expense of performance. In public housing, monitors and PHAs

often spent a great deal of energy in making sure that rather

minor regulations were complied with rather than in ensuring that

the housing was managed well.

During the 1980's, HUD began a "risk assessment" approach to

monitoring. The theory behind risk assessment is that if you

have limited staff resources, it is better to focus the resources

where you think you are most likely to have problems rather than

to spread them evenly across the board. In about 1987, HUD began

an administrative approach known as the Decontrol Program as a

means of furthering the risk assessment approach. In the

Decontrol Program, PHAs that were determined to be

well-performing were subject to less frequent intensive

monitoring.

To be determined to be well-performing in the Decontrol

Program, a PHA had to perform well on management criteria, many

of which are similar to those currently used in PHMAP. The

Decontrol Program was successful in focusing resources on the

PHAs that were at high risk of mismanagement. However, the

program did have some problems. Notably, an audit by the

Inspector General uncovered some fraud in some PHAs that had been

determined to be good performers. This caused the program to be

suspended and for the Department to re-examine this approach. 

This re-examination led to the development of PHMAP.
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Development of Indicators

During the late 1980's, HUD convened a working group of

public housing practitioners to reappraise the criteria used in

the Decontrol Program and to identify ways of better identifying

and tracking well-performing PHAs. HUD used the criteria and

procedures that emerged from this working group as the basis for

a legislative proposal that became PHMAP.

PHMAP was authorized by Section 502 of the National 

Affordable Housing Act (NAHA) of 1990. The legislation

identified seven specific indicators:

1. number and percent of vacancies

2. amount and percent of modernization funds unspent

3. percentage of rents uncollected

4. energy consumption

5. average turnaround time for vacant units

6. proportion of work orders outstanding 

7. percent of units inspected.

These seven statutory indicators emphasized performance with

regard to maintaining high levels of occupancy, maintaining and

modernizing the stock, collecting the rents, and conserving

energy. Notably, all of these indicators are objective and

capable of being quantified. They also all are strictly

management issues and avoid compliance issues. The legislation

also specified that the Secretary of HUD could identify other

indicators.

The Department published a proposed rule on April 17, 1991. 

That proposed rule contained 32 PHA performance indicators and

numerous sub-indicators. Much of the comment on the proposed

rule, primarily by PHAs and interest groups, was that HUD had

proposed too many indicators and that many of the indicators were

designed to assess compliance with program policies and

regulations rather than measure operational effectiveness. 

Congress then amended Section 502(a) by including language

in HUD's 1992 Appropriations Act that limited PHMAP to the seven

indicators in the NAHA Act, plus a maximum of five others. To

implement PHMAP, the Department published an Interim Rule on

January 17, 1992. It required PHAs with 500 or more units to

submit a PHMAP certification to HUD by March 2, 1992, based on

the PHA's 1991 operations. Participation by smaller PHAs was
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phased in. The final group of PHAs was required to submit

certifications covering the fiscal year that began in April 1992. 

This interim rule continues to govern the program.

The Department has continued informally to receive a lot of

public comments on the Interim Rule. PHAs and public housing

interest groups have made suggestions for revising the

indicators. In preparing a final rule the Department has taken

these comments into account and also has convened a working group

of interested parties, including PHAs of all sizes and

performance levels. As part of the process of preparing the

proposed rule, HUD undertook major consultation with

representatives of public interest groups and public housing

agencies in November 1993 and again in January 1994. The

Department then produced and tested a revised PHMAP in about 45

PHAs around the nation.

This process has resulted in a proposed rule, which was

published in the Federal Register on May 6, 1996.
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Indicators of Outcome/Results

The PHMAP Indicators . PHMAP has been operating under an

interim rule that was published on January 17, 1992. That rule

established indicators related to 12 aspects of public housing

management:

 1. Maintaining a high occupancy rate 

 2. Modernizing the stock 

 3. Collecting Rents 

 4. Using Energy efficiently

 5. Preparing and leasing vacant units

 6. Responding to requests for maintenance

 7. Inspecting units and systems annually 

 8. Keeping Tenant accounts receivable low

 9. Maintaining appropriate levels of operating reserves

10. Keeping operating expenses within resources

11. Carrying out a program of Resident Initiatives 

12. Maintaining a capacity to develop additional units

As currently implemented, three of these 12 indicators are

divided into components so that in all there are 22 separate

variables that make up the PHMAP score. The various indicators

and components are given different weights in compiling an

overall PHMAP score. The following table summarizes the

indicators, components, and weights. 

TABLE 1

PHMAP Indicators and Components

1. Number and percentage of vacant units (indicator weight = 3)

2. Modernization (indicator weight = 2)

a. unexpended funds more than 3 years old (component

weight = 2)

b. timeliness of obligation of funds (component weight =

1)

c. contract administration (component weight = 1)

d. quality of physical work (component weight = 3)

e. budget controls (component weight = 1)

3. Rents Uncollected as a percent of total rents (indicator

weight = 3)
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4. Annual energy consumption compared with 3 year rolling

average (indicator weight = 1)

5. Unit turnaround -- average time to repair and rent vacant

units (indicator weight = 2)
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TABLE 1 (continued)

PHMAP Indicators and Components

6. Outstanding work orders -- percent of workorders outstanding

and reduction in time to respond to workorder requests (indicator

weight = 1)

7. Annual inspection and condition of units and systems

(indicator weight = 3)

a. System to track inspection and repair (component weight

= 1)

b. percent of units inspected last year (component weight

= 1)

c. correction of unit deficiencies (component weight = 3)

d. inspection and repair of systems (component weight = 3)

8. Tenant Accounts receivable -- percent uncollected for the

period (indicator weight = 1)

9. Operating expenses as % of maximum allowed (indicator weight

= 1)

10. Routine operating expenses less than operating income and

subsidy (indicator weight = 1)

11. Resident initiatives -- has PHA undertaken a series of

initiatives to support resident safety and improvement?

(indicator weight = 3)

12. Development (indicator weight = 1)

a. quality of contract administration (component weight =

1)

b. timeliness of development (component weight = 2)

c. quality of work (component weight = 3)

d. budget controls (component weight = 1)

The indicators vary somewhat in quality. Most are

quantitative and outcome-oriented, as the average percent of

units that are vacant, whether modernization funds are unexpended

after three years, and the average time to turn around a vacant

unit. But some of the indicators are qualitative and

process-oriented, as whether the PHA has a system to track unit

inspections, whether it has undertaken resident initiatives, and

the quality of its administration of development contracts. The

data to support PHMAP come from the PHA management systems, and

PHAs must certify to their accuracy.
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The weights for the indicators are somewhat arbitrary, but

rational. They did not result from a statistically-oriented

quantitative management review, but rather through a reasoned

discussion by the public housing community. In essence, the
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process was one that determined, for example, that turning around

vacant units and collecting the rents were three times as

important as energy conservation.

In calculating PHMAP scores, each PHA receives a grade on a

scale of "A" to "F" on each of the 22 variables, based on its

actual performance data. For example, a PHA with a vacancy rate

below 1% would receive a grade of "A." A PHA with a vacancy rate

of more than 8% would receive an "F." This letter grade then is

converted to a numeric score as follows:

A = 10.0 points, vacancy rate 1% or less

B = 8.5 points, vacancy rate of 1 to 2%

C = 7.0 points, vacancy rate of 2 to 3%

D = 5.0 points, vacancy rate of 3 to 6%

E = 3.0 points, vacancy rate of 6 to 8%

F = 0.0 points, vacancy rate greater than 8%.

(This description is somewhat simplified. See Attachment A which

contains that PHMAP regulations for a complete description of how

the scores are calculated.)

In the modernization, annual inspection, and development

indicators, the components then are weighted and summed to

generate an overall score for the indicator. Then the scores on

the 12 indicators are weighted and summed to generate a total

score. The maximum possible score for a PHA is 220 points. Each

PHA's PHMAP total score is then expressed as a percentage of the

total possible points. PHAs that score 90 percent or higher are

considered to be high performers. Those that score between 60

and 90 percent are considered standard, and those that score

below 60 percent are considered to be troubled. Figure 2 shows

the proportion of PHAs in different size categories by their

PHMAP rating.

TABLE 2

PHMAP Rating by PHA Size

 Number of units managed 

 Less than 4,000 

PHMAP Rating 500 500-1,249 1,250-3,999 or More

High performer 54% 52% 42% 41%

Standard 44% 44% 55% 41%

Troubled 2% 6% 3% 18%
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Number of PHAs 2,668 225 96 32
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Regardless of its overall PHMAP score, a PHA that scores

below 60 percent on the modernization indicator is considered to

be "mod-troubled." Managing the process of improving the housing

stock is considered to be of such importance that HUD tries to

ensure that every PHA has the capacity to carry out

modernization.

Does PHMAP Work? . The foregoing described how PHMAP scores

are generated and generally how PHAs score on PHMAP. PHMAP's

effectiveness as a management tool, however, depends on its

accuracy and its ability to provide incentives to improve. Among

the questions related to assessing its effectiveness, then, are:

o Is it reliable -- are the data upon which PHMAP scores

are based accurate and consistently reported?

o Does it provide the right incentives -- do PHAs improve

their management by trying to improve their PHMAP scores?

o Is it valid -- are PHAs with higher scores better

managed than those with lower scores?

PHMAP has not yet been the subject of a comprehensive

evaluation, so HUD has no definitive answer to these questions. 

Feedback from PHAs, informal assessments, and one small study by

the Office of the Inspector general have suggested some problems

with PHMAP. However, the general working conclusion in HUD is

that PHMAP is successful in identifying the PHAs with management

problems so that they can receive remedial treatment.

The data upon which PHMAP are based are gathered by the PHAs

themselves. Thus, the overall reliability of the system depends

on whether PHAs gather and report information accurately and

consistently (HUD field staff are required to conduct

confirmatory reviews with regard to PHMAP data, so the data are

subject to verification.) HUD's Office of the Inspector General

reviewed PHMAP scores for 12 PHAs in FY 1992 and found some

problems with the data that resulted in inaccurate and

inconsistent scores. Although this audit was done during PHMAP's

first year and although reporting has undoubtedly improved,

incorrect data continue to be a matter of concern for HUD.

PHAs have an incentive to have high PHMAP scores. They make

the executive director and the PHA look good and earn the PHA

some regulatory relief. Self-certified PHMAP data are subject to
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confirmatory reviews by HUD field staff, but resources prevent

staff from reviewing most PHAs in any year. Moreover, the HUD

field may have an incentive to want to boost PHMAP scores. 

Having too many PHAs on the troubled list may suggest a 

management problem in the field office and may also increase the

field office's work load resulting from the need to develop a

memorandum of agreement or improvement plan with additional PHAs. 

However, before PHAs can be taken off of the troubled list, they

now must have a confirmatory review. This represents a

significant effort to discourage the reporting of erroneous data.

A related problem with the reliability of the data is

whether PHMAP indicators are susceptible to "gaming." For

example, the base against which vacant units are calculated

excludes units that are scheduled for modernization. It could be

possible for a PHA to show a good occupancy rate by manipulating

its modernization schedule. 

Similar to the gaming issue is the types of incentives that

PHMAP provides. Ideally, a PHA with a low score would want to

improve its score and by so doing will improve its management. 

The above modernization example, provides an example of PHMAP's

possibly providing the wrong type of incentive. To maintain a

high occupancy rate, a PHA might be tempted to keep units in

modernization status, which is contrary to good management. Or,

to achieve a good score with regard to maintenance workorders, a

PHA might be tempted to keep some types of work off the workorder

system, thus losing valuable management information.

And finally, there are questions with regard to PHMAP's

validity -- that is, are PHAs that score higher better managed

than PHAs that score lower? One issue here is whether PHMAP

contains all of the relevant variables. For example, it does not

contain an outcome indicator on crime control, procurement, or

customer satisfaction. If these aspects of operations are

thought to be the sort of thing that a well-managed PHA cannot

fail to address, then PHMAP could be deficient. PHMAP also

focuses on management, rather than on some important compliance

issues. Thus, a PHA could offer well-managed housing, but still

perform rather poorly with regard to some compliance issues. 

Also, PHMAP is not an absolute management performance standard. 

"Well-managed" means a well-managed PHA. Because the PHMAP

standards do not take into account the management performance of

private housing, there is no way to tell whether a well-managed

PHA is actually well-managed housing relative to comparable

housing in the private sector.
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Use and Impact of Information on Outcomes/Results

The primary use of PHMAP is to provide uniformity in

evaluating PHA performance. Through PHMAP, HUD can hold PHAs in

different parts of the country to the same standard and can

assess individual PHA's over time to determine whether they are

improving. The considerations noted above suggest some possible 

problems with PHMAP. HUD recognizes these potential problems and

is working to improve them. It expects to monitor and adjust the

system over time. However, the general consensus is that as

currently constituted, PHMAP works pretty well to identify the

well- and poorly-performing PHAs. The Department currently uses

PHMAP in its overall management of public housing and believes

that it has been a valuable resource.

PHMAP also lends itself to a risk assessment approach to

monitoring PHA performance. If PHMAP correctly identifies the

PHAs that are poor, standard, and good performers, HUD can then

concentrate monitoring and technical assistance in ways that can

help the poor performers improve. Those that are poor performers

("troubled" in PHMAP terms) are monitored intensely. They also

must work with HUD to improve their performance and are the focus

of technical assistance efforts. Those that are high performers

receive some benefits, including public recognition as good

performers, some reduction in their reporting burdens, reduced

monitoring, and other incentives. 

Every month the Department generates a PHMAP report. This

report is distributed to the field and the PHAs. The most

significant use is that PHAs that are on the "troubled" or

"mod-troubled" list need to work with their field offices to

improve their performance. Specifically, they are required to

enter into a Memorandum of Agreement (MOA) with the field office,

which is a binding contractual agreement between HUD and the PHA

designed to bring about significant improvements to the PHA's

management. The MOA is updated annually as long as the PHA

remains troubled. Failure to improve can result eventually in

HUD's taking over management of the agency.

The MOAs for PHAs that are "mod-troubled" frequently

restrict agency discretion with regard to the Comprehensive Grant

Program (Comp Grant) and the Comprehensive Improvements

Assistance Program (CIAP). Comp Grant is a block grant that HUD

uses to fund public housing modernization in larger PHAs. CIAP
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is a categorical program that funds modernization in small PHAs. 

Being in the mod-troubled category may cause a PHA to suffer such

sanctions as the imposition of budgetary limitations and denial

of program participation.

PHAs that are neither troubled nor mod-troubled, but which

receive a failing score on any PHMAP indicator must prepare an

improvement plan, which specifies the actions and timetables it

will take to correct the deficiencies that led to its receiving a

failing grade. 

HUD gives priority to troubled and mod-troubled PHAs in

providing them with technical assistance to correct their

deficiencies.

At the other end of the spectrum, being considered a high

performer is considered as high praise by many executive

directors. It makes the PHA and consequently the Board of

Directors, the Mayor, and perhaps the community look good. There

is evidence that PHAs do strive to be considered high performers. 

Some PHAs generate their own PHMAP scores several times a year

and present them to their Board of Directors as evidence of how

the PHA is being managed. PHAs may even make too much of a high

PHMAP score, perhaps citing it as evidence of overall excellence. 

HUD notes that PHMAP just measures management performance in the

areas covered by PHMAP. While it is important, a high-scoring

PHA still can be deficient in many important areas of compliance.

PHMAP does not provide incentives to PHAs to improve beyond

the "high-performer" level. Thus, a PHA that scores a 90 on

PHMAP really has no incentive for improving to the 92 or 95

level. 

PHMAP certainly plays a role in determining how HUD manages

its own resources. Key decisions with regard to the types of

technical assistance to be provided and who will receive it hinge

on PHMAP scores. The PHMAP scores of PHAs in the jurisdiction of

specific HUD field offices may provide important management

information about the quality of work being done in the field. 

One current example is that the New Orleans field office is under

close control by HUD headquarters in part because of the low

PHMAP scores earned by the PHAs within Louisiana. Within field

offices, PHMAP also influences resource allocation. Troubled

PHAs require and receive greater staff attention. 
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Costs

The principal costs of PHMAP involve the staff time needed

to implement it. PHMAP is administered by one staff person in

HUD headquarters, who works full time on it. This person's

supervisor also devotes a portion of his time to PHMAP. 

Additionally, HUD field staff review certifications, develop

figures on the indicators that are not provided by the PHAs, and

send out the scores and conduct confirmatory reviews. While it

is not possible to estimate the workload in terms of full time

equivalents, there are about 58 field staff who spend a

significant portion of their time on PHMAP. And these staff have

supervisors who spend lesser amounts of time on the program. Of

course, the system requires additional staff support for data

processing and general Departmental overhead.

PHMAP appears to be a fairly cost effective system. The

principal financial costs are in HUD staffing and the data

collection and reporting costs incurred by the PHAs. While these 

costs are not insignificant, they probably represent a savings

over alternative management procedures. Essentially, even though

HUD staff must generate PHMAP scores, conduct confirmatory

reviews, and negotiate MOAs, this is probably a significant staff

saving over having to do more hands-on assessments to identify

poor performers on a case by case basis. 

Similarly, with regard to PHAs, gathering and reporting data

is not without cost. Under the Paperwork Reduction Act, HUD

reported to OMB that the total estimated PHA burden for PHMAP

requirements is 8,515 hours. But the requirement to collect and

track the management information required in PHMAP undoubtedly

represents a significant management improvement for many PHAs. 

Those that already had good management systems in place incurred

fewer costs to comply with PHMAP. And on balance, PHMAP has

resulted in more autonomy for well-performing PHAs, which means a

reduction in their compliance costs. The troubled PHAs must

incur the costs necessary to improve their systems, but they

would have to do that in any system.

PHMAP has been a generally popular system for all of the

parties involved in it. There has been on-going negotiation

within the public housing community about the details of PHMAP,

but there is consensus that the PHMAP concept is sound and that

the system works reasonably well.
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Lessons Learned

PHMAP has and will continue to change based on HUD's

experience with it. There has been learning, and the Department

expects this to be ongoing. Probably the most important lesson

is that a PHMAP-like system will work. It has been successful

enough to prompt HUD to pursue a similar system, Section Eight

Management Assessment Program (SEMAP), for use in the Section 8

rental assistance program.

HUD has also learned some things about the details of PHMAP. 

The draft proposed rule, which is being considered within the

government today, would modify several of the PHMAP indicators

and weights. This is based on experience and represents minor

tinkering to improve the system. For example, one change would

be to eliminate tenant accounts receivable as an indicator. This

would be justified on the grounds that it measures the same

financial management concept as other indicators, such as

uncollected rents and the size of cash reserves.

Another of the proposed adjustments would lessen the

presence of some qualitative indicators, such as the presence of

a system to track unit inspections. Instead, more emphasis would

be placed on quantitative indicators, such as the percent of 

units actually inspected. This change would reduce the influence

of subjective differences among field office reviewers and ensure

that all PHAs nationally receive equal treatment.
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Another proposed change would make it more difficult for a

PHA to earn the "high-performer" rating. Over time, PHMAP scores

have improved, in part because their management has improved and

in part because they have learned to do the things needed to

generate higher scores. As nearly 50 percent of PHAs get to be

"high performers," it is appropriate to reconsider the standard. 

In the current system, a high performer is just one that scores

90 percent across all indicators. The Department proposes that

in the future no PHA will be considered a high performer if it

has not scored at least a "C" on all indicators.

Finally, the process of developing and administering PHMAP

has helped teach HUD how to rate the administration of public

housing. While everyone knew that a well-managed PHA would be

one that maintained low vacancy rates and responded to requests

for maintenance, for example, no one knew exactly how to measure

whether a PHA was doing a good job with these and other critical

management operations. In the process of administering PHMAP,

the Department has learned better ways to count the units that

ought to be included in the base for calculating vacancy rates

and for tracking the response times appropriate for different

types of workorders. These actions have informed public housing

management standards that go beyond just generating a PHMAP

score.

Next Steps

The direction of the Public Housing program has been the

focus of an important policy debate. Legislation may change the

nature of public housing, as well as the resources that are

available to HUD to manage it. PHMAP already is well-established

as a HUD management tool, and it is very likely that PHMAP will

continue to evolve as policy takes shape.

The Department has a proposed final rule that would modify

and improve some of the PHMAP indicators. As compared with the

current Interim Rule, the major changes in the proposed rule are

that it drops some indicators and changes some weights. For

example, it drops that tenant accounts receivable indicator

because it is considered to overlap rent collection and other

financial indicators. It also drops the development indicator

because so few PHAs are doing new development. While it is

difficult to predict when a proposed rule will become final,

perhaps this rule will take effect early in 1997.
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The Department will continue to refine PHMAP. If changes in

the public housing system make new indicators necessary or render

current indicators obsolete, HUD will adjust PHMAP. If

monitoring, audits, and informal feedback suggest that

adjustments are needed, they will be made.
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The Department also expects to conduct a formal evaluation

of PHMAP to determine its validity and the effect it has on PHA

performance. Such an evaluation could produce findings that lead

to adjustments in the program. However, this evaluation will not

begin until the proposed rule is final and has been implemented. 

The Department does not believe it would be useful to evaluate

PHMAP presently, because the current system will be superseded in

about a year.

It is important to note, too, that although the Department

views PHMAP as an important step in improving PHA management,

PHMAP is not the only activity in this respect. PHMAP is

designed only to assess PHA management. It is not intended to

assess compliance. A salient example is the Vidor, Texas PHA,

which HUD recently took over. According to PHMAP, Vidor was a

standard performer. That is, they collected the rents, performed

modernization, handled maintenance, inspected the units, and did

the rest of the things that PHMAP measures. However, they were

in violation of Fair Housing requirements, and this necessitated

HUD intervention. It is possible for other well-managed PHAs to

be out of compliance with these and other Federal requirements.

Similarly, customer satisfaction is an important HUD goal. 

In the case of the public housing program, it is possible that a

PHA with high PHMAP scores might still have low levels of tenant

satisfaction. HUD has been pursuing efforts to survey residents

of public housing to assess both the condition of their housing

and their satisfaction with it. This type of information is seen

as a necessary supplement to PHMAP, although HUD is not planning

to add a customer service component to PHMAP. PHMAP seeks to

measure objectively whether the agency is well-managed. 

Important as customer satisfaction is, HUD sees tenants'

subjective opinions as something different from PHMAP.
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ATTACHMENT A

This attachment contains a copy of the PHMAP regulations

from 24 CFR, Part 901. It is difficult to describe PHMAP is a

brief case study because of two basic complexities: (1) the

intricacies of public housing management and (2) the fact that

PHMAP is a mathematical formula involving 22 variables. The

regulations presented here describe in precise detail the

definitions of the PHMAP indicators as well as the calculations

that go into generating a PHMAP score.

This attachment also contains a table that shows recent

PHMAP scores for some of the larger PHAs. For example,

Birmingham had an overall PHMAP score of 83.7. This was

calculated from its score on the 12 indicators, which also are

presented in this table. 
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ATTACHMENT B

This case study was developed by HUD's Office of Policy

Development and Research (PD&R). The principal source of data

was conversations with officials in HUD's Office of Public and

Indian Housing (PIH) who developed and administer the PHMAP

program, as well as officials in PD&R who have done research on

public housing management and who helped to develop PHMAP.

In addition, this study relied on the following written

sources:

o 24 CFR, Part 901 (interim rule)

o HUD Handbook, 7460.5, PHMAP Handbook

o HUD Handbook, 7460.7, REV-2, The Field Office

Monitoring of PHAs Handbook

o HUD, Office of Inspector General Audit Report,

93-HQ-101-0006, February 4, 1993, "Limited Review of the PHMAP

Program."

o 24 CFR, Part 901, proposed rule. Published for comment

on May 6, 1996.