Rural Housing Service: Updated Guidance and Additional Monitoring Needed for Rental Assistance Distribution Process
Published: 2004-09-13T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Rural Housing Service's (RHS) Section 521 rental assistance program provides rental subsidies for about 250,000 rural tenants. Because the program has a waiting list of 80,000 eligible tenants and there are over 1.3 million rural low-income renters eligible for housing subsidies, it is important to effectively distribute resources to extend assistance to as many needy tenants as possible. Therefore, GAO was asked to assess (1) how RHS distributes rental assistance funds to properties and tenants, (2) how RHS monitors the use of rental assistance funds, and (3) whether there are sufficient internal controls in place to ensure that these funds are being effectively administered and used.
section_title: What GAO Found
paragraphs: RHS's national office pays rental assistance funds to property owners through a variety of contracts and transfers of unused rental assistance from one property to another. RHS staff calculate the payment amounts using information provided by tenants and verified by property owners. The current system requires RHS staff to enter payment data into the agency's database manually. However, RHS's national office is upgrading two systems to streamline the payment process. But some local RHS staff are concerned that the new process may eliminate a layer of review. RHS's national, state, and local offices share responsibility for monitoring the rental assistance program, with the local offices performing the primary review every 3 years. The national office outlines the monitoring activities for the rental assistance program in its Rural Development Instructions and provides other guidance, such as administrative notices and unnumbered letters. We found that state and local offices follow this guidance inconsistently and sometimes consider it unclear. National office staff are planning a number of initiatives to increase monitoring of the rental assistance program, but a number of key management positions in the national office are unfilled, which could limit the effectiveness of program monitoring. RHS's internal controls do not provide adequate oversight of rental assistance funds because RHS guidance is inadequate and tenants' incomes are not adequately verified. First, insufficient guidance on the transfer process limits RHS's ability to move unused rental assistance to properties that have tenants with the greatest unmet need. Second, the triennial supervisory review does not provide reasonable assurance that tenants income and assets, and ultimately rental assistance payments, are adequately verified. Alternate methods of verifying tenant information also have limited effectiveness but could help improve internal control if properly designed and implemented.

section_title: Letter
paragraphs: The Rural Housing Service (RHS) of the U. S. Department of Agriculture  (USDA) provides rental subsidies through the Section 521 rental assistance  program to about 250,000 low-income rural tenants living in federally  subsidized properties. The rental subsidies, which are provided to  property owners through multiyear contracts, are intended to limit tenants’  rent payments to 30 percent of the household’s adjusted monthly income.  With a fiscal year 2004 budget of almost $600 million, the program is RHS’s  largest line-item appropriation. Given its size, internal controls are a  significant factor in administering the program in order to distribute  resources effectively and reduce the possibilities for fraud, waste, and  abuse. Because the program already has a waiting list of 80,000 eligible  tenants and over 1.3 million low-income renters not receiving housing  subsidies reside throughout rural America, effectively distributing  resources is important in extending assistance to as many needy tenants as  possible.
We recently reported on the activity level of rental assistance contracts and  the accuracy of RHS’s budget estimates for the Section 521 rental  assistance program. To further assist you in your oversight of the program,  you also asked us to assess (1) how RHS distributes rental assistance funds  to properties and tenants, (2) how RHS monitors the use of rental  assistance funds, and (3) whether RHS has sufficient internal controls in  place to ensure that these funds are being effectively administered and  used.
To respond to these objectives, we collected written information from RHS  and talked with its representatives about the processes for distributing  rental assistance and the means of monitoring those processes. We  reviewed RHS’s guidance for the program and internal control standards  that apply to the processes. We also conducted a nationwide survey of all  RHS state and local offices with rental assistance responsibilities. Finally,  we visited RHS state and local offices and property owners or managers in  five states to obtain documentation related to specific aspects of the rental  assistance distribution process and to observe how RHS staff implement  the internal controls that RHS has established to oversee the program.  Details of our scope and methodology appear in appendix I, and  appendixes II and III contain state office responses to a number of survey  items. The survey and a more complete tabulation of the results can be  viewed at www.gao.gov/cgi-bin/getrpt?GAO-04-978SP.
We conducted our work from September 2003 through June 2004 in a  number of locations, including Connecticut, Massachusetts, Mississippi,  New York, South Carolina, Utah, and Washington, D.C., in accordance with  generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: The Section 521 rental assistance program, started in 1978, is administered  by RHS’s Multifamily Housing Portfolio Management Division. The  program provides rental assistance for tenants living in units created  through RHS’s Multifamily Direct Rural Rental Housing Loans and  Multifamily Housing Farm Labor Loans programs. These programs provide  loans subsidized with interest rates as low as 1 percent to help build rental  housing for rural residents and farm workers. Under the rental assistance  program, eligible tenants pay no more than 30 percent of their income  toward the rent, and RHS pays the balance to the property owner.
RHS allocates rental assistance subsidies through 5-year contracts with  property owners; 20-year contracts were also issued to units in newly  constructed properties from 1978 through 1982. In fiscal year 2004,  contracts were issued for a term of 4 years. The contracts specify that  owners will receive payments on behalf of tenants in a designated number  of units at the property. Contracts may be renewed as many times as funds  are made available, and additional rental assistance units may be allocated  if funds become available.
Property owners are required to follow RHS guidance in managing their  properties. Each month, they must document how many units designated  for rental assistance are occupied. If a unit is empty and rental assistance is  not being used, the property owner is required to assign another eligible  tenant. If no eligible tenants are waiting for the unit, the property owner  can work with RHS to transfer the rental assistance to another property.
As shown in figure 1, RHS’s national, state, and local offices share  administrative duties for the rental assistance program.
The national office develops and implements regulations for the rental  assistance program and other RHS programs (Rural Development  Instructions). The current Rural Development (RD) Instruction for the  rental assistance program has been in effect since the 1980s and was last  revised in 1993. Other subparts of the RD Instructions also outline  processes for monitoring RHS programs, including the rental assistance  program. A proposed rule designed to streamline and consolidate the RD  Instructions governing the multifamily grant, loan, and rental assistance  programs was published in the Federal Register in June 2003. The  proposed rule is intended to modify tenant recertification rules, relieve the  burden on property owners of recovering unauthorized rental assistance  from tenants, and reduce the amount of time RHS must wait before  transferring unused rental assistance.
The national office also distributes administrative notices and unnumbered  letters on an as-needed basis. Administrative notices clarify for state and  local offices activities outlined in RD Instructions. For example, the  national office plans to clarify the tenant income verification process and  provide further guidance on monitoring unused rental assistance for  transfer through forthcoming administrative notices. Unnumbered letters,  which address specific issues and are less formal than administrative  notices, relay important information to state and local offices, but they do  not pertain to policies and procedures. For example, an unnumbered letter  released in December 2003 included data aggregated at the national office  broken down by state and by rental assistance distribution goals, such as  percentage of supervisory reviews completed, unit vacancies, and unused  rental assistance.
The national office also estimates program budgets; allocates funds; and  tracks nationwide program statistics. State and local offices work directly  with property owners, property management companies, and tenants to  monitor the program. State and local offices are responsible for conducting  financial, management, and physical reviews of the properties; executing  rental assistance contracts with property owners; approving rent increases;  and processing rental assistance payments. State and local office staff also  collect and maintain property and tenant data for their areas.
Support for the program is also provided through two offices in St. Louis,  Missouri. The Rural Housing Service Branch of the Information Resources  Management Office maintains the database systems used to manage  program data. The Office of the Deputy Chief Financial Officer uses the  program data to generate and maintain the general ledger and financial  statements for the program. RHS uses two key database systems to manage  their multifamily housing programs, including the rental assistance  program. The Automated Multi-Housing Accounting System (AMAS) stores  data on rental assistance contract obligations, rental assistance payments  to property owners, and transfers of rental assistance. The Multi-Family  Housing Information System (MFIS) tracks property and tenant  information that determine the monthly request for rental assistance.
As mandated by the Federal Managers’ Financial Integrity Act of 1982, the  Comptroller General issues standards for internal control in the federal  government. These standards provide the overall framework for  establishing and maintaining internal control and for identifying and  addressing major performance and management challenges and areas at  greatest risk of fraud, waste, abuse, and mismanagement. According to  these standards, internal control comprises the plans, methods, and  procedures used to meet missions, goals, and objectives. It is the first line  of defense in safeguarding assets, and preventing and detecting fraud and  errors. Internal control, which is synonymous with management control,  helps government program managers achieve desired results through  effective stewardship of public resources. No matter how well designed  and operated, internal control cannot provide absolute assurance that all  agency objectives will be met, and thus, once in place, internal control  provides reasonable, not absolute, assurance of meeting agency objectives.
section_title: RHS Distributes Rental Assistance Funds through Contracts and Sets Per-Unit Payments Based on Tenants’ Verified Income Levels
paragraphs: RHS’s national office provides rental assistance funds to property owners  through a variety of contracts. Rental assistance can also be transferred,  under certain conditions, from one property to another. RHS calculates the  payments property owners receive using information supplied by tenants  and verified by property owners, who then use the information to create a  tenant certification form. Tenants’ income must be certified yearly on the  tenant certification form or whenever significant changes occur—for  instance, when income increases by a specified amount. Property owners  send the tenant certification form to the responsible state or local office,  where RHS staff review the information and calculate the amount of the  subsidy. In order to receive the monthly payments, property owners must  provide the appropriate RHS office with a project worksheet- a monthly  statement showing how many units that are eligible for subsidies are  occupied by tenants in the program. Figure 2 shows the steps that are  involved in the distribution process. Plans are under way to streamline the  payment process, although local office staff are concerned this may  eliminate their chance to review the information on the project worksheet.
subsections: section_title: Funds Are Distributed to Properties through Contracts and Transfers of Unused Rental Assistance
paragraphs: The rental assistance program provides four types of contracts: renewal,  construction, servicing, and preservation. RHS officials report that in the  last few years, 96 percent of annual rental assistance appropriations have  been used for renewal contracts—that is, contracts that renew expiring  obligations at existing properties. Construction contracts, which support  new units in recently constructed properties, account for only 1 percent.  The remaining 3 percent cover servicing and preservation contracts.  Property owners who take out loans to rehabilitate properties and then  raise rents to cover the servicing costs associated with the loan, for  example, are eligible for servicing contracts that provide additional rental  assistance to help tenants cope with the rent increase. Preservation  contracts are offered as an incentive to property owners who are  considering leaving the program and provide subsidies for additional units  on the property.
According to the authorizing statute, unused rental assistance is to be  transferred to properties where the assistance is needed. Transfers can  occur when state and local offices identify unused rental assistance at a  property or when a property owner requests such a transfer. For example, a  property owner may want to transfer unused rental assistance from a  property that has no eligible potential tenants to one that has many. During  fiscal year 2003 unused rental assistance on approximately 6,800 units, or  about 3 percent of all rental assistance units—with a total value of $67  million—were transferred through about 2,000 transactions. An RHS  national office official noted that a portion of these units were rental  assistance transfers accompanying a property transfer, during which an  eligible property owner assumes another property owner’s loan.
Property owners may initiate the transfer of unused rental assistance from  their properties at any time. If the property owner has not used the rental  assistance on one or more of the covered units for any consecutive 12- month period, RHS may transfer the unused rental assistance, as long as at  least one unit at the property remains covered. In either case, before the  transfer can occur, RHS must verify that the rental assistance has been  properly marketed by the owner and is not needed at the current property.  Property owners may appeal decisions to transfer rental assistance from  their properties by contacting USDA’s National Appeals Division, an  independent office within USDA.
section_title: RHS Makes Payments on the Basis of Information Provided by Tenants and Verified by Property Owners
paragraphs: As figure 2 shows, a number of steps take place between the time rental  assistance contracts are made or transferred and the time property owners  receive payments. The two key steps in this process involve certifying  tenants’ income information on the tenant certification form and using that  information to calculate the payments to property owners on the project  worksheet. (fig. 3).
RD Instructions require that tenants be certified at least annually so that  state and local office staff can document their income and determine their  rental contributions. Property owners certify tenants initially and then  every year, or when a tenant’s income rises by $40 or more per month ($480  per year) or decreases by $20 or more per month ($240 per year). In these  cases, the income must be verified again. According to RD Instructions, the  property owner must obtain verification of the tenant’s stated income, in  writing, from the tenant’s employer. If the owner is not able to immediately  obtain written verification, the tenant’s income may be temporarily verified  by examining income checks or check stubs. Income listed from other  sources, such as Social Security or public assistance, must be verified in  writing by those sources. Although tenant certifications and income  verifications help ensure accurate payments to property owners, errors can  occur when tenants do not accurately report all sources of income or when  property owners do not adequately verify them.
Calculating the amount of rental assistance and submitting the information  to RHS is the second key step. Project worksheets document the rent and  income levels of tenants for whom the property owner can request rental  assistance and calculate the amount of rental assistance due. Property  owners submit the project worksheets by mail to state or local offices,  where, according to RHS guidance, staff are to compare the worksheet  information with information from MFIS. Once a month, MFIS also  generates project worksheets, based on the previous month’s occupancy  reports and the tenant certifications in the system. RHS staff finish  processing the worksheets by entering the information into AMAS,  triggering payments to the property owners.
In over half of the states, individual local offices are responsible for  processing project worksheets. However, approximately 39 percent (17 out  of 44) of the state offices we surveyed have chosen to centralize their  processing function (fig. 4).
Program officials in one of these states told us their centralized processing  center promotes consistency in administering regulatory requirements. In  another centralized state, an official stated that their centralized payment  center had helped to cut costs and increase satisfaction, because property  owners had one place to call when questions or payment issues arose.  However, program officials in two decentralized states told us that they  believed that centralized payment systems distanced RHS staff from the  properties and property owners or managers.
section_title: RHS’s Plans to Streamline the Payment Process Have Raised Concerns about Eliminating a Layer of Review
paragraphs: RHS’s national office is upgrading two systems to streamline the payment  process. The Management Agency Interactive Network Connection (MINC)  is a Web-based electronic transmission process that will upgrade the  current modem-based process, known as the Industry Interface, that  property owners can use to transmit tenant certifications to RHS. RHS will  also be upgrading MFIS in order to create electronic project worksheets, so  that state and local offices will no longer be required to enter data from the  project worksheets manually into AMAS. Once the property owners  approve their electronic project worksheets through MINC, the  information will be transmitted automatically into AMAS to trigger rental  assistance payments. As of May 2004, five states have been using the MFIS  upgrade in conjunction with MINC to process payments and the national  office expects all states will be using it by the end of calendar year 2004.
Local office staff whom we spoke with during one of our site visits were  concerned that allowing property owners to approve and submit project  worksheets electronically will eliminate the local office’s chance to review  the information while entering it into AMAS. National office staff  overseeing these changes stated that electronic project worksheets would  not affect this review, because the property owner would not be able to  make any changes directly to the electronic project worksheet if he or she  did not agree with the amount of rental assistance calculated. Rather, any  modifications to the project worksheets would have to be submitted  separately to RHS.
section_title: RHS’s National and State Offices Monitor the Use Of Rental Assistance, with Local Offices Performing the Primary Review Every 3 Years
paragraphs: RD Instructions provide guidance for monitoring the use of rental  assistance funds. The guidance requires reviews at the national, state, and  local levels. However, the triennial supervisory review is the primary tool  for verifying the accuracy of rental assistance payments. National office  staff are planning a number of initiatives to increase rental assistance  monitoring, but a number of key management positions in the national  office have been unfilled, potentially limiting the effectiveness of  monitoring efforts.
subsections: section_title: Guidance from the National Office Establishes Monitoring Procedures but Is Used Inconsistently and Considered Unclear
paragraphs: Two main sets of RD Instructions establish procedures for distributing  rental assistance. These include:   RD Instruction 1930-C, Management and Supervision of Multiple Family  Housing Borrowers and Grant Recipients, particularly exhibits B and E,  which establishes criteria for tenant and property eligibility for rental  assistance, among other things.
RD Instruction 1951-K, Exhibit A, Processing Multiple Housing  Payments, which outlines the rental assistance payment process.
Although four offices we visited reported following RD Instruction 1930-C  to process tenant certifications, we found little consistency in the guidance  RHS offices used to process payments, specifically when processing  project worksheets. Three offices we visited reported using the AMAS  Online Cash Manual, which provides instructions on using the AMAS  database to process payments, but two of those offices also reported using  different parts of the RD Instructions issued by the national office. One of  these two offices reported using the RD Instruction 1951-K. One other  office was unaware of official guidance, and another office told us that they  referred questions to their AMAS coordinator in the state office.
Likewise, two sets of RD Instructions provide explicit procedures for  monitoring the rental assistance program, including the purpose,  frequency, content, and planning and follow-up procedures:  RD Instruction 2006-M, Management Control System, which outlines the  reviews used at the national and state office levels: the Management  Control Review and the State Internal Review; and   RD Instruction 1930-C, which outlines the triennial supervisory review  for local offices.
The national office conducts the Management Control Review on a 5-year  cycle to review rental assistance administration in randomly selected  states. A Management Control Advisory Group, which is made up of  national and local office employees, determines the time frames,  objectives, and work plan for the Management Control Review cycle.  Generally, the objectives are designed to assess state-level administrative  operations, including financial management, internal control, and  automated systems. RHS national office staff visit the selected properties  and review a sample of tenant household files from each. Based on the  results of the review, the national office has the authority to make  recommendations to the state offices for improving rental assistance  administration.
State offices are required to conduct the State Internal Review at least once  every 5 years. This review is designed to, among other things, ensure that  RHS local offices properly implement Rural Development policies and  procedures. During these reviews, state office staff evaluate program and  administrative functions at local offices. Reports on the findings from these  reviews are provided to the state director.
Local offices are to conduct supervisory reviews at least every 3 years,  examining a random sample of tenant household files at each property in  their portfolios, and RD Instructions mandate more frequent reviews for  delinquent or problem properties. Local office staff in one state we visited  told us that they conduct approximately one supervisory review per month  in order to review each property once every 3 years. To conduct the  review, staff are to pull a random sample of at least six tenant household  files at each property, or review all tenant household files if the property  has six units or fewer. RHS provides sample forms including a pre-visit  worksheet to help staff sample units, plan objectives, and assemble  required documentation for each visit. Table 1 shows the number of rental  assistance units subject to triennial supervisory review at each of the five  local offices we visited.
In written responses to survey questions, certain respondents cited issues  related to RHS guidance in the conduct of their rental assistance  responsibilities. For example, one survey respondent stated that RHS  guidance needed to be simplified and issued in a timely manner. Another  survey respondent stated that RHS guidance is sometimes unclear. This  respondent added that administrative notices helped to some degree but  added that the office was receiving more guidance from unnumbered  letters, which do not carry the same force as RD Instructions or  administrative notices.
Despite these comments, 80 percent of respondents considered national  administrative notices helpful or very helpful at clarifying policies and  procedures established by the national office. However, approximately 50  percent of respondents were unable to say how many notices the national  office had issued between January 2003 and January 2004.
section_title: Triennial Supervisory Reviews Are RHS’s Primary Monitoring Tool for the Rental Assistance Program
paragraphs: The triennial supervisory review is the chief activity RHS local offices use  to verify tenants’ income, assets, and expenses—that is, the information on  which the tenant certifications and project worksheets, and ultimately  rental assistance payments, are based. RHS staff look for supporting  documentation that confirms tenants’ eligibility and income during tenant  household file reviews and examine the property owner or manager’s  waiting list, rental rates, and budget. While property owners are required to  collect supporting documentation for tenants’ claims of income, assets, and  expenses —a process referred to as third party income verification—RHS  staff do not see the original documentation tenants provide at any time  other than during triennial supervisory reviews. Local office staff in all  five states selected for site visits told us that triennial supervisory reviews  were the mechanism they used to monitor the accuracy and completeness  of tenant certification data. Further information collected from the local  office staff emphasized the value of triennial supervisory reviews. For  example, four out of five local offices we visited recalled finding errors or  questionable tenant documentation during triennial supervisory reviews.
RHS uses the triennial supervisory review and other mechanisms to detect  unauthorized rental assistance payments but faces challenges recapturing  the unauthorized payments. Tenant household file reviews can help detect  erroneous claims that lead to unauthorized payments. For example, during  a triennial supervisory review, RHS staff in one state found that a property  owner had allowed a tenant to overstate medical expenses, which could  lower the tenant’s net income and thus increase the payment RHS makes  on the rental unit. Employers may also file erroneous third-party income  verification forms. According to a property owner we visited, such errors  can occur when employers falsify income information in order to maximize  rental assistance payments for their employees. RHS can detect such errors  through wage matching, the process of comparing statements of income by  tenants or employers to data collected by state wage information collection  agencies.
According to RHS officials, recapturing unauthorized rental assistance  payments once they have been made is difficult. Though RHS can report  false statements of income to state agencies, these agencies seldom have  recourse against tenants or employers. When surveyed, 49 percent of RHS  staff stated that they collect unauthorized rental assistance payments from  property owners. Owners can, in turn, attempt to collect the unauthorized  payments from tenants through a repayment agreement. Twenty-nine  percent of the RHS offices that indicated that their office is able to reclaim  unauthorized rental assistance reported that they had attempted to initiate  payment agreements with tenants. However, in written responses to survey  questions, one respondent noted that the office is not able to recapture  unauthorized rental assistance in over 95 percent of the cases. Another  survey respondent stated that the office is successful in recapturing  unauthorized rental assistance in about 30 to 50 percent of the cases.
Additionally, survey respondents stated that tenants typically vacated the  units before the debt was repaid.
section_title: Initiatives to Increase Monitoring of the Rental Assistance Program Could Be Hindered by the Lack of Key Managers in the National Office
paragraphs: Initiatives are under way at the national office to strengthen monitoring of  the rental assistance distribution process at all levels. In response to the  Improper Payments Information Act, the national office is conducting a  review of properties to determine a nationwide erroneous rental assistance  payments rate. The national office is also attempting to gain access to the  National Directory of New Hires, which is administered by the Department  of Health and Human Services. This database would give RHS state and  local offices access to national wage-matching data that could be used to  further verify tenants’ income.
A number of key positions in the Rural Development mission area,  particularly in the Multifamily Housing Division, have been unfilled since  approximately March 2003, and existing staff were filling two or more  administrative roles (fig. 5).
For example, as of July 2004 the Deputy Administrator of Multifamily  Housing and Assistant Deputy Administrator of Multifamily Housing  positions had been unfilled since March 2003 and August 2003,  respectively. Additionally, at times the Deputy Administrator for  Community Programs filled the roles of both acting Rural Housing Service  Administrator and acting Deputy Administrator of Multifamily Housing.  Finally, the Director of the Portfolio Management Division, which  administers the rental assistance program, had also at one time filled the  role of acting Assistant Deputy Administrator for Multifamily Housing. The  leadership gap could have a negative effect on program staff’s ability to  develop and administer new policies in a timely fashion. For example, the  national office planned to release administrative notices clarifying  procedures on, among other things, income verification in July 2004.  However, because of staffing constraints due to the consolidation of RHS  regulations, the issue date was extended.
section_title: RHS’s Internal Controls Do Not Provide Adequate Oversight of Rental Assistance Funds
paragraphs: RHS’s internal controls do not provide reasonable assurance that rental  assistance funds are used efficiently or that tenants’ incomes and assets are  adequately verified. First, RHS lacks sufficient guidance to oversee the  transfer process, creating difficulty in moving unused rental assistance  throughout the multifamily housing portfolio. Second, the triennial  supervisory review does not provide reasonable assurance that errors in  tenants’ income statements and thus in rental assistance payments will be  prevented or detected in a timely manner. The guidance is inconsistently  interpreted and the reviews are conducted infrequently using methods,  specifically the selection of an appropriate sample size to review, which  may be insufficient. Alternate methods of verification, such as internal  MFIS database checks and wage matching, could help improve RHS’s  existing internal controls if properly designed and implemented.
subsections: section_title: Insufficient Guidance on Transfers Limits Ability to Move Unused Rental Assistance to Properties with the Neediest Tenants
paragraphs: The majority of survey respondents (52 percent) very frequently or fairly  frequently encountered high vacancy rates as a cause of unused rental  assistance. Additionally, when asked to identify the three greatest  challenges to their offices, survey respondents most frequently listed  monitoring and filling unit vacancies as the greatest challenge facing RHS  state and local offices. The current lack of clear guidance on transferring  unused rental assistance may prevent RHS officials from using transfers as  a tool to fill vacancies within and outside of a state.
We found that RHS’s guidance on transfers was not sufficient to meet  GAO’s Standards for Internal Control in the Federal Government. GAO’s  standards state that for an entity to run and control its operations, it must  have relevant, reliable, and timely communications relating to internal as  well as external events. For communications to be effective, information  must flow down, across, and up the organization. RD Instructions state that  transferred rental assistance must be directed to properties with tenants or  applicants that have the greatest need, based on income level. However, RD  Instructions are silent on whether state and local offices should transfer  unused rental assistance to properties within their portfolios or redirect it  to properties outside their portfolios—either within or outside the state— where the need is greater. As a result, the guidance is interpreted  inconsistently, potentially preventing RHS from effectively transferring  rental assistance.
During our site visits, an RHS official in one state said that her office most  often conducted transfers within the property owners’ portfolios, but  officials in other states prioritized transfers to benefit the most needy  tenants throughout the state. An official noted that RD Instructions did not  explicitly prioritize such transfers. Further, because RD Instructions do not  state whether rental assistance is to be transferred only within states or  among states, three state offices interpreted the RD Instructions as  allowing the transfer of unused rental assistance to other states with a  greater need. However, 76 percent of survey respondents reported that  their office did not have, or they did not know if it had, formal procedures  for conducting state-to-state transfers.
In written responses to our survey questions, certain respondents noted  that RHS guidance on transferring unused rental assistance was  insufficient. For example, one survey respondent noted that states were  currently responsible for transferring unused rental assistance without a  great deal of guidance from the national office. Another respondent noted  that regulatory and instructional requirements for transferring rental  assistance were “not efficient.” Yet another noted that RD Instructions did  not outline procedures for transferring unused rental assistance among  properties or states.
Officials in the national office told us that one of their functions was to  encourage the transfer of rental assistance both within and among states.  One official stated that RD Instructions did offer guidance on where to  transfer rental assistance but could not point to specific details. The official  also stated that the goal of the transfer policy was to provide rental  assistance to the tenant with the greatest need. However, the current RD  Instruction on transfers does not provide the necessary control to ensure  that this goal is met. In addition, to determine where the greatest need  exists, RHS national office would have to consistently assess need within  portfolios, within states, and among states. RHS officials acknowledged  that they were reviewing the guidance on transfers and stated that RHS  planned to issue an administrative notice to clarify procedures for  transferring unused rental assistance.
The issue of unclear guidance on transfers is complicated by the fact that  RD Instructions give property owners certain protections that limit  transfers of unused rental assistance. While RHS can transfer unused rental  assistance on covered units after 12 months, at least one unit must remain  covered at the property. RHS must also notify property owners 30 days in  advance of its intent to make a transfer and ensure that the property  owners know their appeal rights. According to RHS officials in the states  we visited, property owners most often instigated transfers when they  occurred, typically to other properties they owned. An official in one state  estimated that property owners initiated 95 percent of transfers in that  area.
We found that RHS officials in one state hesitated to recommend  transferring unused rental assistance outside of the property owner’s  portfolio because of the appeals process. The State Director of Rural  Development in that state said that it could take at least 18 months to  transfer unused rental assistance to another property if the property owner  appealed, as the appeals process could take up to 6 months. Additionally,  one survey respondent would have liked to have the authority to transfer  unused rental assistance without giving the property owner appeal rights.  RHS national office officials noted that, since 2001, there had been only two  requests for review of a property owner’s appeal. In both cases, RHS’s  National Appeals Director decided against the property owner, and allowed  RHS to transfer the unused rental assistance to properties outside of the  property owner’s portfolios.
section_title: Triennial Supervisory Reviews Are Not Adequate as the Primary Monitoring Tool for the Rental Assistance Program
paragraphs: Approximately 56 percent of survey respondents reported that they were  able to verify the accuracy of information provided during the tenant  certification process. Of those, 56 percent said they did so during the  triennial supervisory review. Likewise, all of the local offices we visited  during our site visits stated that information provided for tenant  certifications was verified during or in preparation for triennial supervisory  reviews. And approximately 83 percent of survey respondents reported  that triennial supervisory reviews provided them with the information  necessary to effectively monitor properties in their portfolios to a great or  very great extent.
However, we found that the triennial supervisory review was not a  sufficient means of detecting problems such as misreported income,  verification errors, and unauthorized rental assistance payments. GAO’s  standards state that internal control should generally be designed to assure  that ongoing monitoring occurs in the course of normal operations, is  performed continually, and is ingrained in the agency’s operations. RHS’s  triennial supervisory reviews did not meet this standard because they are  conducted infrequently using a sample size that may be too small to  provide reasonable assurance that all tenant certifications are reviewed at  least once or more than once every several years. RD Instructions require a  sample of at least six tenant household files from a property with more  than six units, and all tenant household files for properties with six units or  fewer. With a sample size this small, however, tenants could move from a  unit they had rented before the local office has a chance to sample their  household file during a supervisory review.
Local offices in the states we visited said that they interpreted RD  Instructions as requiring a 20- or 25-percent sample of tenant household  files. However, we found that staffing and time limitations did not allow  staff to conduct the reviews this way. For example, an official in one local  office stated that her office reviewed six tenant household files for every  property, even if 20 percent of the property comprised a greater number of  units. Furthermore, about 20 percent of survey respondents reported not  having sufficient staff to conduct reviews, and about 27 percent reported  not having sufficient time to conduct the reviews according to the RD  Instructions. A local office official in another state we visited said that staff  reviewed either six tenant household files or 10 percent of the total-  whichever was greater. Even if the local offices consistently used a 20  percent or 25 percent sample of tenant household files, however, as figure 6  shows a rental assistance unit could go without review for 12 to 15 years.
RHS’s national office does not have a basis for determining whether  sampling a minimum of six tenant household files per property is sufficient  to provide reasonable assurance that errors in tenant and payment  information are adequately detected. In order to design a cost efficient  sampling strategy that can provide reasonable assurance with respect to  tenant income and rental assistance payments, RHS needs information on  the overall error rates. One way to determine an overall error rate is to  conduct a national statistically valid random sample of tenant household  files. Information gathered from this sample would provide RHS with a  better idea of the level of erroneous income tenants were reporting and  enable RHS to estimate the level of improper rental assistance payments  that are being made throughout the program. In addition, it would provide  RHS officials with valuable information on how to structure future  supervisory reviews in a more efficient and effective manner.
In a June 2003 report assessing controls over the tenant certification  process and accuracy of rental subsidies conducted by the USDA Office of  Inspector General, the audit team found that in Florida, tenant  certifications for an estimated 20.8 percent of the 14,705 units contained  errors that resulted in households receiving an estimated $4.7 million in  improper rental subsidies. This finding emphasizes the importance of  being able to detect errors in tenant information in a timely manner.
In March 2004, RHS began a review of properties to determine an overall  error rate for rental assistance payments to comply with the Improper  Payments Information Act. RHS officials selected a sample of 539 assisted  units in 321 RHS properties, and the national office expects to report their  findings by the end of September 2004. Until RHS determines an overall  error rate using a statistically valid sample, RHS will not be able to  determine an appropriate sampling strategy for use with supervisory  reviews to estimate error rates and compliance with internal controls.
GAO’s internal control standards also state that agencies should evaluate  their monitoring activities, and the evaluations should depend on the  assessment of risks and the effectiveness of the monitoring procedures.  RHS officials in the states we visited said that they found errors or  questionable tenant documentation during triennial supervisory reviews.  For example, RHS officials in one state said that they would follow up with  the property owner if they found errors in the data that are being verified.  The official added that property owners might be given a 15- or 30-day  period to correct any deficiencies. An RHS official in another state said that  RHS staff sometimes found questionable supporting documents during  triennial supervisory reviews. The official explained that the staff note the  problem in the triennial supervisory review report and request that the  property owner obtain the correct documentation. These examples suggest  that, if properly designed and implemented, the triennial supervisory  review can be valuable in detecting tenant and payment errors.
section_title: Alternate Controls Used by RHS to Verify Tenant and Payment Information Have Had Limited Effectiveness
paragraphs: RHS staff use alternate controls, such as MFIS database checks and wage  matching, to verify tenant and payment information. According to RHS  officials, the MFIS system has internal checks that help RHS officials avoid  and catch errors. When tenant certifications are submitted electronically  through the Industry Interface, MFIS automatically rejects those that are  problematic. For example, a tenant certification would be rejected if it  showed that the tenant might already reside at another property—that is, if  the tenant’s Social Security number already existed within the system.
Also, MFIS allows RHS officials to reject tenant certifications for certain  reasons and thus flag them for review. For example, as we have seen  tenants must recertify their eligibility for rental assistance if their income  increases by $40 a month ($480 a year) or decreases by $20 a month ($240 a  year). MFIS allows each office to compare incoming tenant certifications to  the prior batch of tenant certifications. RHS staff in each office can then  establish a threshold in MFIS to reject tenant certifications that show a  change in income of more than an established amount, for example, 20  percent, and hold them for further review.
Although RD Instructions determine income changes in terms of dollar  amounts, the MFIS database check has been implemented to use  percentages to set the threshold for rejecting tenant certifications.  However, setting the threshold in terms of dollar amounts would be  consistent with the RD Instruction that describes how to determine  changes in income. For example, if a tenant reported zero income on an  initial certification, any subsequent increase in income would be more than  20 percent, thereby triggering a rejection, although the dollar increase  could be less than $40. Likewise, if a tenant’s reported income increased  from $30 to $40 per month, for example, the MFIS system would also reject  this certification because the percentage increase is greater than 20  percent. However, a $10 increase in income is not enough to warrant  recertification. But if a tenant’s reported income increased from $300 to  $345 per month, MFIS would accept this certification because the  percentage increase in income is less than 20 percent, although the dollar  increase is more than $40.
An RHS official in the national office stated that the MFIS database check  could be designed to use dollar amounts instead of percentages to establish  the threshold. In either case, however, the national office does not  currently have an established percentage benchmark in MFIS for all offices  to use, and RHS local offices are not setting the thresholds consistently. In  one local office we visited, RHS staff established their threshold to reject  tenant certifications that change by 20 percent. However, in another state  we visited, local office staff set MFIS to reject changes in income of 25  percent or more. Setting the threshold higher than an established  benchmark would make this control less effective at detecting changes in  income. Setting a threshold lower than an established benchmark would  make this control more effective but would result in a higher number of  pending certifications that would likely require more staff resources.
Although the RHS national office has established the MFIS database check  as a control, we identified and were told of errors on tenant certifications.  For example, in one state we identified a tenant certification that listed two  dependents as living in a unit receiving rental assistance. However, the  dependents were not listed in MFIS. RHS local office officials stated that, in  such a situation, the two dependents would not change the amount of rent  owed by the tenant or the amount of rental assistance due to the property  owner. But because rental assistance payments are based on household  size, among other things, the presence or absence of dependents could  influence rental assistance payments. For example, if a tenant got married  an additional person would be living in the unit and would possibly have an  additional source of income. If a tenant gave birth, the tenant would receive  an income deduction for the newborn, decreasing the amount of income  used in determining the amount of the rental assistance payment.
Further, RHS officials in four of the states we visited stated that, following  RHS guidance, they verified the accuracy of rental assistance payments by  comparing property owners’ project worksheets with project worksheets  generated using MFIS. According to an RHS official, any errors on the  property owners’ project worksheets should be detected during the  comparison with the MFIS-generated project worksheet. But since the  MFIS project worksheet is generated with the same information from  tenant certifications that property owners used to generate their project  worksheets, RHS is essentially comparing duplicate data from the same  source (see fig. 7).
According to GAO Standards for Internal Control in the Federal  Government, such a check is not sufficient. Internal control calls for  comparisons and assessments using different sets of data so that  relationships can be analyzed and appropriate actions taken. In order for  RHS to have a meaningful reconciliation, MFIS data would need to be  compared with a different data source to identify differences in reported  tenant and payment information.
An RHS official in the national office believed that this internal control  standard is not applicable to this situation. The official stated that  discrepancies between the MFIS-generated project worksheet and the  property owner’s project worksheet often arise because the property  owner may not send complete information. For example, if a property  owner did not submit a form indicating that a tenant had vacated a unit, or  if the owner did not perform a calculation correctly, a discrepancy would  occur that RHS would look into. We agree that this system can catch errors  of inconsistency. But a property owner could consistently be submitting  complete, but inaccurate, information reported by the tenant. In such  cases, RHS would not be able to detect errors or improper rental assistance  payments by comparing the two project worksheets. RHS would need to  consult another source of information, such as data on earned income that  could be used for wage matching, to verify that information reported by the  tenant and submitted by the property owner is accurate. Wage matching  would allow staff to verify tenant’s reported income using wage  information collected by the state.
RHS was told by the USDA Office of the Inspector General over 5 years ago  to continue their efforts to ensure that RHS state and local offices utilize  wage matching to detect misreported tenant income. In a February 1999  report, the Inspector General’s audit team evaluated methods RHS and  property owners used to ensure that tenants’ incomes were properly  reported on tenant certifications. The audit team found that 47 percent of  tenant certifications in six states (29,238 out of 62,815) were incorrect due  to inaccurately reported income, income changes, and property managers  that did not properly verify income reported by tenants. Further, the audit  team found that about 93 percent of the income errors involved tenants  that had reported earned income. The Inspector General recommended  that RHS be more aggressive in expanding its wage-matching efforts.
Some RHS state offices are granted access to wage-matching data through  agreements between the offices and wage collection agencies, such as state  labor departments. These agreements follow state laws. Our survey results  showed that 64 percent of RHS state offices (28 of 44 RHS state offices that  responded) had access to state employment information to conduct wage  matching (see fig. 8.)
However, some RHS officials believe that state-based wage matching has  limitations. For example, officials in one state we visited noted that their  office did not place much emphasis on wage matching because their area  bordered other states and many individuals worked across state lines.  Without access to wage-matching data in the bordering states, RHS staff  were not able to adequately certify reported income. Further, officials  noted that state wage data were often outdated and did not capture all  sources of income.
RHS is attempting to acquire access to the Department of Health and  Human Services’ National Directory of New Hires by contacting the U. S.  Department of Housing and Urban Development (HUD) to discuss the  language originally proposed by HUD for the authority to use the  directory. The National Directory of New Hires, which includes  centralized sources of state wage, unemployment insurance, and new hires  data for all 50 states, would provide nationwide data for wage matching.  Access to this directory would likely help solve the problem of verifying  income for tenants who work across state lines. Also, wage data from the  National Directory of New Hires is more recent than state data and  captures all earned income.
section_title: Conclusions
paragraphs: RHS’s internal controls do not provide reasonable assurance that rental  assistance resources are used effectively. RHS national office transfer  guidance is insufficient and RHS local offices have inconsistently  interpreted what is available. As a result, rental assistance funds may not  be directed to the most needy tenants or may go unused. Additionally, the  infrequency of the triennial supervisory reviews using a sampling  methodology that may be insufficient cannot reasonably ensure that  tenants’ income and assets, and ultimately rental assistance payments, are  adequately verified. RHS does not have a basis for determining what  constitutes a sufficient sample size for the triennial supervisory reviews  without establishing an overall error rate for rental assistance payments.  These shortcomings increase the risk that RHS will provide rental  assistance to tenants that may not be eligible.
RHS currently uses alternate methods of income verification, including  MFIS database checks that, if properly designed and implemented, could  provide reasonable assurance that errors in tenant and payment  information are detected in a timely manner. However, the effectiveness of  these alternate methods is limited because of their faulty design and  implementation. RHS officials stated that access to the National Directory  of New Hires would help with income verification and has made efforts to  gain access to this information.
section_title: Recommendations for Executive Action
paragraphs: To ensure that rental assistance funds are effectively distributed to  properties that have tenants with the greatest need, GAO recommends that  the Secretary of Agriculture require program officials to (1) establish  centralized guidance on transferring unused rental assistance, (2) improve  sampling methods to ensure that a sufficient number of tenant household  files are selected for supervisory reviews and (3) improve verification of  tenant information including more effective use of alternate methods of  income verification.
section_title: Matter for Congressional Consideration
paragraphs: Congress may wish to consider adding RHS to Section 453 (j)(7) of the  Social Security Act, “Information comparisons for housing assistance  programs.” This action would grant RHS access to the Department of  Health and Human Services’ National Directory of New Hires for wage- matching purposes. If such access were granted, RHS and the Department  of Health and Human Services would have to develop specific procedures  to facilitate it.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided USDA with a draft of this report for review and comment. The  Acting Undersecretary for Rural Development provided written comments  that are presented in appendix IV. The letter included a summary of  activities that were planned or had recently begun at RHS that the Acting  Undersecretary said were designed to improve the oversight, monitoring,  and guidance of the multifamily housing program.
In response to our recommendation on establishing centralized guidance  on transferring unused rental assistance, the Acting Undersecretary for  Rural Development agreed to establish this guidance in an administrative  notice. Concerning our recommendation that RHS improve sampling  methods to ensure that a sufficient number of tenant files are selected for  supervisory reviews, the Acting Undersecretary responded that USDA  would instead revamp the supervisory review process to improve its  effectiveness and consistency. We agree that the supervisory review  process should be revised to improve its effectiveness and consistency and  are encouraged that USDA is taking steps to accomplish this. However, to  make this process an effective control to ensure that the rental assistance  payments are correct, or that incorrect payments are discovered in the  normal course of business, USDA must also improve its sampling  methodology as we described in the report. In particular, RHS must  determine an overall error rate using a statistically valid sample to  determine how many tenant household files are sufficient to detect errors.  Unless this methodology is improved in conjunction with the supervisory  review process, USDA will continue to lack any assurance as to the  propriety of the rental assistance payments that are not reviewed. The  Acting Undersecretary agreed with our recommendation that RHS improve  its methods for verifying tenant information, including using alternate  income verification methods. He stated that USDA would institute broader  use of alternate income verification methods, such as improved access to  wage matching and new hires data, but noted that USDA needed to be able  to share this data with third parties, particularly the property owners. As  noted in this report, if RHS were granted access to data from the National  Directory of New Hires, RHS and the Department of Health and Human  Services would have to develop specific procedures to facilitate such  access.
The Acting Undersecretary also noted that GAO said in the report that  streamlining and automating borrower’s requests for rental assistance  payments could remove an important layer of agency review. However,  GAO did not take a position on this issue. We merely summarized concerns  expressed by RHS local office staff we visited, attributing the comments  appropriately. We also noted that national office staff overseeing the  changes had told us that streamlining the payment process would not  eliminate this review and that not all states were currently using the  streamlined process. Finally, we incorporated updated information USDA  provided on RHS staffing.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to interested  Members of Congress and congressional committees. We will also send  copies to the Secretary of the Department of Agriculture and the Director  of the Office of Management and Budget and make copies available to  others upon request. In addition, this report will be available at no charge  on the GAO Web site at http://www.gao.gov. Our survey of RHS state and  local offices administering Section 521 rental assistance and a more  complete tabulation of the survey results (GAO-04-978SP) will also be  available on the GAO Web site at www.gao.gov/cgi-bin/getrpt?GAO-04- 978SP.
Please contact me at (202) 512-4325, or Andy Finkel at (202) 512-6765, if  you or your staff have any questions concerning this report. Key  contributors to this report are listed in appendix V.
section_title: Scope and Methodology
paragraphs: To determine how RHS distributes rental assistance funds and monitors the  rental assistance program, and to identify the internal controls RHS has  established to ensure that rental assistance funds are administered and  used effectively, we collected written and testimonial information from  agency officials in the national office and in the Office of the Deputy Chief  Financial Officer in St. Louis, Missouri on the rental assistance distribution  process and the guidance governing the distribution process. We consulted  GAO’s Standards for Internal Control in the Federal Government  (GAO/AIMD-00-21.3.1) to review control activities that apply to RHS’s  distribution of rental assistance funds. We used these standards to assess  whether RHS’s current internal controls were sufficient to effectively  monitor the rental assistance program.
We also surveyed RHS state and local offices that were identified as having  rental assistance responsibilities by their respective State Directors or the  appropriate designee. We identified 248 state and local offices with rental  assistance responsibilities. These consisted of 46 RHS state offices and 202  local offices in existence as of December 2003. To ensure security and data  integrity, we provided each of the 248 offices with a web address, a unique  identification number, and a password to allow the office access to one  questionnaire.
The questionnaire covered topics related to the rental assistance program.  Specifically, the questions covered general office and staff information,  renewal contracts, unused rental assistance, transfers, tenant  certifications, project worksheets, rent setting, reserve accounts, and  technology and resources. To prepare for the survey, we conducted  interviews in three state offices: the combined state office of Maryland and  Delaware, and the Texas and Illinois state offices, and interviewed RHS  local offices in Texas and Illinois. Of these, Maryland and Delaware and  Texas had centralized their processing of rental assistance payments. We  also pretested the questionnaire with state and local offices in  Pennsylvania and Wisconsin to determine whether respondents would  understand questions the way we intended. Since the questionnaire was  administered via the Internet, we conducted a usability pretest with yet  another RHS local office in Virginia to observe respondents answering the  questionnaire as it would appear when activated.
We took the following steps to increase the response rate for all sectors of  the population. We sent one reminder notice via e-mail and conducted  follow-up telephone calls to those offices that did not respond to our  survey by the initial deadline. Collection of survey data ended on May 3,  2004. We received responses from 230 offices, providing an overall  response rate of 92.7 percent. Specifically, 44 state offices and 186 local  offices responded, resulting in response rates of 95.7 percent and 92.1  percent, respectively. We did not independently verify the information  obtained through the survey.
The practical difficulties of conducting any survey may introduce certain  types of errors, commonly referred to as nonsampling errors. For example,  differences in how a particular question is interpreted, the sources of  information available to respondents, or the types of people who do not  respond can introduce unwanted variability into the survey results. Steps  such as pretesting and follow-up contacts to increase response rates serve  to minimize nonresponse error. In addition, steps such as performing  statistical analyses to identify inconsistencies and having a second  independent reviewer for the data analysis can further minimize such error.
Data from the Web survey were entered electronically by participants and  imported into an electronic data file. Close-ended questionnaire items were  analyzed using statistical software. A coding scheme was developed, and  open-ended questionnaire items were content analyzed by two trained  coders, who revised their codes until 100 percent agreement was reached.  The results of the content analysis apply only to those survey participants  who provided responses. We only content analyzed open-ended responses  that were discussed in this report. We conducted our survey work from  April 2003 through July 2004 in accordance with generally accepted  government auditing standards.
To obtain more in-depth information, we conducted site visits to RHS state  and local offices in five states: Utah; South Carolina; New York; Mississippi;  and the Connecticut, Massachusetts, and Rhode Island state grouping. We  designed a site visit interview guide that enabled the team to follow the  distribution process beginning with the property owner or manager and  proceeding to the local office, and finally, to the state office. Using the  interview guide, we observed and discussed with RHS staff the tenant  certification, project worksheet, and transfer processes, among others.
To determine the states where we would conduct the site visits, we  conducted a stratified random sample. Two centralized and three  decentralized states were randomly selected from a list of state offices,  after eliminating the offices we visited to prepare and pretest the survey.  After the state offices were selected, we randomly selected one local office  from the local offices available in that state. We judgmentally selected the  property owners based on their distance from the local office and their  most recent rental assistance transfer. However, the experiences of these  states are not necessarily representative of the experiences of any other  state.
During each of the site visits, we interviewed a property owner or manager,  RHS officials in a local office, and RHS officials in the state office. Using  the interview guide, we also obtained key documents related to the three  processes that were being discussed. Specifically, the interview guide  required the team to obtain from the property owner or manager the most  recent, completed project worksheet; tenant certifications associated with  certain rental assistance units; tenant applications corresponding to the  tenant certifications; a current waiting list; and documentation of a recent  transfer of rental assistance. We tracked these documents through the local  offices and the state offices to observe internal controls at each level. After  all site visits were completed, we interviewed officials from RHS’s Office of  the Deputy Chief Financial Officer to obtain information on their role in the  rental assistance distribution process. Last, we interviewed the RHS  national office to determine its role in monitoring the rental assistance  distribution process and to assess the internal controls they have  established to oversee rental assistance funds.
We also consulted GAO’s Standards for Internal Control in the Federal  Government to review control activities that apply to RHS’s distribution  and monitoring of rental assistance funds. We reviewed site visit  documents to provide examples of RHS’s internal controls. We performed  our site visit work from March through May 2004 in accordance with  generally accepted government auditing standards.
section_title: State Office Survey Responses for Rural Rental Housing (RRH) Properties
paragraphs: DC = Don’t collect DK = Don't know We surveyed only state offices with rental assistance responsibilities. Also, in certain instances, RHS  has a single state office for selected groupings of states. For these selected groupings, this chart only  displays the state name where the state office is located. Thus, the total number of state offices is less  than 50. See appendix I for more details on RHS's selected state groupings.
This chart displays survey responses for RHS state office respondents only, if they indicated that they  had Rural Rental Housing (Section 515) properties in its portfolio and if they provided data other than  Don't Collect, Don't Know, or No Response for at least one of the above questions.
section_title: State Office Survey Responses for Off Farm Labor Housing (FLH) Properties
paragraphs: Off FLH properties Off FLH units DK = Don't know We surveyed only state offices with rental assistance responsibilities. Also, in certain instances, RHS  has a single state office for selected groupings of states. For these selected groupings, this chart only  displays the state name where the state office is located. Thus, the total number of state offices is less  than 50. See appendix I for more details on RHS's selected state groupings.
This chart displays survey responses for RHS state office respondents only, if they indicated that they  had Off Farm Labor Housing (Section 514/516) properties in its portfolio and if they provided data  other than Don't Collect, Don't Know, or No Response for at least one of the above questions.
section_title: Comments from the U.S. Department of Agriculture
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to those named above, William Bates, Emily Chalmers, Jamila  Jones, Austin Kelly, Alison Martin, Marc Molino, and Julie Trinder made key  contributions to this report.
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