Federal Real Property: More Useful Information to Providers Could Improve the Homeless Assistance Program
Published: 2014-09-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Title V of the McKinney-Vento Homeless Assistance Act enacted in 1987 created a program to assist the homeless, in part, by identifying unused federal real property and making it available to homeless assistance providers.
GAO was asked to review the implementation of Title V of the McKinney-Vento Homeless Assistance Act. This report examines: (1) the identification and transfer of federal real property to homeless assistance providers and (2) the benefits and challenges homeless assistance providers and national advocacy organizations reported in identifying, acquiring, and using federal real property, and the potential actions that could help to address these challenges. GAO obtained information and data from HUD and the Department of Health and Human Services (HHS) on the properties reported since the program's inception and interviewed officials from GSA, HHS, and HUD. GAO also obtained views on the program from officials at (1) nine federal agencies, representing a range of size in their real property portfolios; (2) eleven homeless assistance providers (including eight that received property), representing a range of locations, size of property, and services provided; and (3) national homeless-advocacy organizations.
section_title: What GAO Found
paragraphs: Since inception in 1987, the nationwide Title V homeless-assistance program has transferred 122 properties from federal agencies to homeless assistance providers. Of these properties, 81 are currently being used to provide a range of homeless assistance services nationwide. Such services include transitional housing, referral services, and emergency shelter. However, few of the properties that the Department of Housing and Urban Development (HUD) has listed as suitable and available since the program's inception received applications from homeless assistance providers. In most cases, the properties may not have actually been practical for homeless service providers to use. For example, in 2013 about 80 percent of these properties were for off-site use only—meaning that a provider would need to physically move the property in order to use it. HUD officials told us that they would prefer that agencies not be required to report certain types of properties at all, such as those for off-site use only. The current statutory requirement for agencies to report all properties that fall within four broad categories—excess, surplus, underutilized, and unutilized—may not be effective for certain types of properties. Such exclusion could allow HUD officials to focus on the suitable and available properties that may be more likely to assist the homeless.
Of the 11 homeless assistance providers we interviewed, the eight case study providers that acquired property cited benefits from the Title V homeless assistance program, such as expanding services and obtaining real property at no cost. These benefits notwithstanding, the providers identified challenges, such as identifying available properties. These findings are consistent with reports from national homeless advocacy organizations. HUD reports properties in the Federal Register multiple times a year as required. The United States Interagency Council on Homelessness (USICH), which plays a coordination role, provides a link on its website to the HUD reports. Nonetheless, according to national homeless advocates, many homeless assistance providers remain unaware of the availability of properties because the Federal Register is not user-friendly. Further, HUD lists many of the same properties more than once in the Federal Register , as required, even though they may not be useful to homeless assistance providers. In the past, some in Congress and the executive branch have raised issues about reporting requirements; the basic issue has been that some requirements result in reports that may be burdensome to produce, or not very useful. Modifying reporting requirements to reduce the frequency of reporting related to properties that are less likely to be useful to homeless providers could help, while also allowing HUD to continue to fulfill its responsibilities.
section_title: What GAO Recommends
paragraphs: Congress should consider changing (1) the scope of properties to be reported to HUD with respect to the types of properties that may be less likely to be useful to assist the homeless and (2) the frequency of Federal Register reporting.

section_title: Letter
paragraphs: Estimates of the homeless population in the United States vary widely.  According to the Department of Housing and Urban Development (HUD)  610,042 people in the United States were homeless on a single night in  January 2013, and more than a third of these people were living in  unsheltered locations, such as under bridges, in cars, or in abandoned  buildings. According to the National Law Center on Homelessness and  Poverty, the numbers of Americans experiencing homelessness is  estimated between 1.5 million to 3.5 million in a given year. At the same  time, we have previously reported that federal agencies continue to hold  thousands of unneeded and underutilized properties that annually cost  the government over a billion dollars to operate. As a result of this and  other long-standing problems, we have designated federal real property  as a high-risk area. Title V of the McKinney-Vento Homeless Assistance  Act (the Act), as amended, created a program to assist the homeless, in  part, by using public resources and programs—including unused federal  real property—in a more coordinated manner to meet the needs of  homeless Americans.
In general, Title V of the Act requires federal landholding agencies to  identify and make available for homeless assistance real property under  their control that they are not fully utilizing or no longer need before  properties are disposed through other means. If a property is published  by HUD as suitable and available, eligible applicants, such as homeless  assistance providers and local governments, may apply to obtain the real  property at no cost for the provision of a broad range of services for the  homeless, including shelter, job training, and storage.
However, implementing the Title V homeless assistance program  requirements has presented challenges. Our prior work has found that  legal and budgetary challenges continue to hamper agencies’ disposal  efforts. Since much of the unneeded federal real property may have no  remaining useful life, may require extensive environmental remediation,  may be located within secure compounds, or require off-site removal, it,  for example, may not be useful to assist the homeless.determine how this program is performing both in terms of government  operations and for homeless assistance providers. This report addresses  two objectives:  1.  The identification and transfer of federal real properties for homeless  assistance under the Title V homeless assistance program.  2.  The benefits and challenges homeless assistance providers and  national advocacy organizations reported in identifying, acquiring, and  using federal real property, and potential actions that could help  address these challenges.
To determine what is known about the identification and transfer of  federal real properties for homeless assistance under Title V, we  reviewed the requirements of Title V of the Act as they apply to the  General Services Administration (GSA), the Department of Health and  Human Services (HHS), HUD, and the U.S. Interagency Council on  Homelessness (USICH). We obtained estimates from HUD of the number  of underutilized, unutilized, excess, and surplus properties reported by  landholding agencies and the number that HUD determined to be suitable  and published as available for homeless use since the program’s  inception in 1987 through March 31, 2014—the date of the most recently  available information. To assess the reliability of these estimates, we  interviewed officials from HUD about how the estimates were derived and  determined that the information provided by the agency provides a  reasonable basis, with caveats, for reporting the number of properties that  have been screened and found suitable and available. In addition, to  determine the types of properties reported, we analyzed HUD’s annual  reports of suitable/available and suitable/unavailable properties for years  2008 through 2013. This time frame was selected to include the 5 years  prior to this audit. When HUD’s annual report for 2013 became available,  we added it to the analysis to include the most recent information. From  HHS, we also obtained documents and data on the number of notices of  interest and applications it received for properties made available for  homeless assistance from the program’s inception in 1987 through March  31, 2014. To assess the reliability of these data, we interviewed officials  from HHS about how the data are collected and maintained, and the  importance to the agency of ensuring the completeness of this data, and  we determined that the data were sufficiently reliable for the purposes of  our report. To understand how federal landholding agencies identify and  report real property to HUD pursuant to the Act’s requirements, we  selected nine landholding agencies to include a range of size among real  property portfolios of land and buildings, including GSA, HHS, the three  Department of Defense service branches––the U.S. Army, U.S. Air Force,  and U.S. Navy––the Department of Energy (DOE), the Department of the  Interior (DOI) and the Department of Veterans Affairs (VA), and the  Environmental Protection Agency (EPA).from GSA, HHS, HUD, and USICH to understand how they process  properties reported under Title V homeless assistance program   We interviewed agency officials  requirements. We also interviewed agency officials from the nine  landholding agencies to obtain their views on how they meet the Act’s  requirements and their impact on each agency’s disposal process. To  determine the benefits and challenges that homeless assistance  providers and national advocacy organizations report in identifying,  acquiring, and using federal real property and potential actions that could  help address those challenges, we selected eight homeless assistance  organizations that acquired federal real property under the program  based on criteria such as the size of the real property acquired under the  program, the services provided, geographic distribution, range of  experiences, and suggestions from agencies and homeless advocacy  organizations. We interviewed representatives from each of the selected  organizations, reviewed documentation, and conducted site visits to two  properties transferred under the Title V homeless assistance program.  We also convened a virtual discussion panel comprised of  representatives from three homeless assistance organizations whose  applications for federal real property were not approved and interviewed  representatives from two national homelessness-advocacy organizations   We  (see app. 1 for more information on our scope and methodology).conducted this performance audit from September 2013 to September  2014 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The McKinney-Vento Homeless Assistance Act created over a dozen  programs intended to comprehensively address the needs of homeless  Americans. Among these, the Title V homeless assistance program  requires federal landholding agencies to make available real property that  they identify as excess, surplus, unutilized, or underutilized for possible  use to assist the homeless. Title V of the Act designated GSA, HHS, and  HUD to administer the program. In addition, Title II of the Act created  what is now known as USICH, an independent establishment within the  Executive Branch whose mission is to coordinate the federal response to  homelessness. The mission of USICH is to create a national partnership  to act as a coordinating body between the federal government and the  private sector to end homelessness nationally. Title V specifies a number  of steps that federal landholding agencies, the three federal agency  administrators of the program, and USICH must take to make federal real  property—including land and buildings, or both—available for homeless  assistance. Figure 1 summarizes key steps in the process and the time  frames required to perform those steps.
HUD canvass: HUD surveys the landholding agencies that must identify  and report to HUD on a quarterly basis real property that is excess,  surplus, underutilized, or unutilized (see table 1).
Once landholding agencies (currently 25 in total) receive HUD’s quarterly  canvassing letter, they have 25 days to respond. To collect such  information, HUD asks landholding agencies to complete a “Title V  checklist” for each of the excess, surplus, underutilized, or unutilized  properties that they have identified and are required to report. The  checklist is a HUD document that requires the landholding agency to  provide a variety of summary information about the real property,  including its utilization status, accessibility (e.g., in a remote location or  behind a secure perimeter), environmental condition, agency contacts,  and other information (see app. II for an example of this checklist).
Suitability determination: HUD assigns each reported real property a  unique identification number and enters the checklist information into an  electronic database. Based on the checklist, HUD must determine the  suitability of each real property for homeless assistance. According to  implementing regulations, all real property––land, buildings, or both––are  suitable unless a property’s characteristics include one or more of the  following conditions: national security concerns, meaning a property is located in an area  where the general public is denied access in the interest of national  security;  flammable or explosive materials within 2000 feet of the property;  located in an airport runway clear zone or military airfield clear zone;  located in a floodway; documented deficiencies, meaning a property with a documented and  extensive condition(s) that represents a clear threat to personal  physical safety, including structural damage or certain types of  environmental contamination; or  inaccessible, meaning a property is not accessible by road.
After HUD makes a suitability determination, it is to provide this  information to the reporting landholding agencies for review, as well as for  the Federal Register listing that briefly describes the property’s condition  and status (e.g., underutilized, unutilized, excess, or surplus).  Landholding agencies then have 45 days to make any edits, as noted in  figure 1, such as changes in the property’s status. In addition, landholding  agencies must transmit to HUD a statement of the availability of real  property, declaring for example that a property is available for homeless  assistance or explaining why a property cannot be made available for  homeless assistance, such as in the case of a further compelling federal  need for the property.
HUD also communicates with GSA, the federal government’s real-  property disposal agent, to identify excess real properties that landholding  agencies have reported to GSA for disposal. If, however, a landholding  agency reports real property to GSA that has not been submitted to HUD  for a Title V suitability determination, GSA is required to create a Title V  checklist and forward it to HUD.
Publication of properties and holding period: Title V requires HUD to  publish in the Federal Register all properties it reviewed. HUD’s Federal  Register listings typically classify these properties as: 1) suitable and  available for homeless assistance; 2) suitable but unavailable for  homeless assistance; or 3) unsuitable for homeless assistance. Once  published, homeless assistance providers––including state and local  governments or eligible private non-profit organizations––have 60 days  to submit a “notice of interest” for suitable and available properties, and  then 90 days from the date of the “notice of interest,” to submit an  application to HHS. The real property is not available for any other  purpose during the 60-day or 90-day period or during the period in which  HHS reviews the application. Interested parties also have 20 days to  challenge the suitability determination of real property HUD found  unsuitable for homeless assistance. If a notice of interest is not filed for a  suitable and available real property within 60 days of its listing in the  Federal Register, the disposal agency may then proceed with its routine  disposal process, in accordance with applicable law.
In addition to publication in the Federal Register, the requirements of Title  V require GSA, HHS, and HUD to make such efforts as are necessary to  ensure the widest possible dissemination of the listing information of  available properties. For example, HUD is required to forward lists of all  real property published in the Federal Register to USICH, which then  must distribute relevant portions of the list to state and regional homeless  coordinators. Also, when HUD determines an excess real property is  suitable and publishes it in the Federal Register as available, the  implementing regulations require GSA to concurrently notify HHS, HUD,  and state and local governments, in addition to homeless assistance  providers that have expressed interest in the particular real property, and  other organizations, as appropriate, concerning suitable properties.
Notices of interest and application: HHS is to evaluate applications of  homeless assistance providers on a first-come, first-serve basis using five  criteria defined in HHS implementing regulations.additional criteria for the application package for a given real property if it  deems it necessary. The criteria are as follows:
Proposed service offering: the extent and range of proposed services,  such as meal, shelter, job training, and counseling.
Need: the demand for the program and the degree to which the  available real property will be fully utilized.  Implementation time: the amount of time necessary for the proposed  program to become operational.
Experience: demonstrated prior success in operating similar programs  and attestations by federal, state and local authorities.
Financial ability: the adequacy of funding that will likely be available to  fully run the proposed program and operate the facility.
HHS review of application, application approval, and transfer of  property: HHS is to review applications for completeness and, in some  cases, may request additional information from the applicant, as  necessary. Evaluations must be completed in 25 days from the receipt of  the completed application.
If HHS approves an application for underutilized or unutilized real  property, the landholding agency can execute a lease of the property to  the applicant. In the case of surplus real property, the disposal agency   “assigns” the property to HHS, which then becomes the sponsoring  agency and transfers the deed to the applicant. Grantees of federal  properties under the Title V homeless assistance program must utilize the  property in accordance with the approved application for the length of the  lease or, in the case of deed conveyances, for 30 years.
Pursuant to HHS policies and procedures, HHS is to perform compliance  oversight and ensure that the grantee uses the real property according to  the terms in the approved application. To accomplish this, grantees are  required to submit annual utilization reports to HHS, and HHS is to  conduct site visits of the properties at least once every 5 years. In the  event that a grantee is not implementing or is unable to implement the  program consistent with the approved application, the property title may  revert back to the federal government.
Pub. L. No. 103-421, 108 Stat. 4346.
Several court orders resulting from a 1988 lawsuit filed by the National  Law Center on Homelessness and Poverty (National Law Center) and  other advocates for the homeless have also shaped the implementation  requirements of the Title V homeless assistance program. The 1988  lawsuit alleged, and the court found, that the federal government was not  fully complying with some Title V requirements. The court issued an order  in 1993 imposing requirements beyond those mandated by the statute  and implementing regulations, such as more comprehensive reporting  requirements and expanded outreach. Unlike the 1993 District Court  order, a more recent 2013 order does not require widespread changes to  operational administration of the Title V homeless assistance program but  rather seeks to better educate the landholding agencies about canvassing  their real property and improving the quality of data reported by these  agencies for Title V requirements and the Federal Real Property Profile.
section_title: 122 Properties Transferred Have Provided a Range of Homeless Assistance Services, but Many Properties Reported and Deemed Suitable for Homeless Assistance May Not Be Useful for That Purpose
paragraphs: Under the Title V homeless assistance program, providers have used  over 100 transferred properties since program inception through March  31, 2014, to deliver a range of services across the country. However, few  of the properties that HUD has determined to be suitable and were  available for homeless assistance since the program’s inception received  applications from homeless assistance service providers. In most cases,  properties screened and determined as suitable and available may not  have actually been practical for homeless service providers to use. For  example, our analysis of HUD’s annual reports from 2008 through 2013  found most of the properties published as suitable and available were for  off-site use only—meaning that a provider would need to physically move  the property in order to use it.
subsections: section_title: Homeless Assistance Providers Currently Use 81 Title V Properties for a Range of Services across the Country
paragraphs: The Title V homeless assistance program has provided properties with  useful facilities. As of March 2014, of the 122 properties transferred since  the program’s inception in 1987, 81 properties are currently in use by  providers. For the other 41 properties, there are several explanations as  to why they are no longer in use for homeless assistance. For example,  leases for 9 properties were rescinded for failure to use the properties for  the agreed upon purposes, and deeds for 8 properties reverted to the  government for reasons such as non-compliance or by request of the  grantee. Across the country homeless assistance providers use the 81  properties to provide a range of homeless assistance services, such as  supportive services, referral services, various forms of temporary or more  permanent housing, administrative offices, and clothing or food  distribution. The 81 active properties include approximately 470 buildings  of about 1.5-million square feet and over 500 acres of land. The  properties include a variety of facilities ranging in size from 1900 square  feet to 512,000 square feet and vacant land ranging from almost two  tenths of an acre to over 96 acres. Of the 81 currently active properties,  not-for-profit organizations––such as the Salvation Army, Samaritan  House, and Volunteers of America––acquired 69, and local governments  acquired 12. A few local governments formed public/not-for-profit  collaborations to develop the properties. Figure 2 shows the geographic  distribution of the properties.
Providers at 60 of the 81 currently active properties offer multiple services  to homeless individuals. For example, one provider said it offers support  services such as substance abuse counseling, mental health services,  case management, job training and placement. Another provides  emergency, transitional, and permanent supportive housing; a health  clinic; and daycare services. A third uses a former army depot to  distribute goods and clothing (see table 2 for more information on the  types of services provided and app. IV for more information on the  services provided at each of the 81 locations). According to the National  Law Center’s 2011 estimate, more than 2.4 million homeless Americans  each year have received assistance through the Title V homeless  assistance program since its inception.
section_title: Few Properties Deemed Suitable and Available for Homeless Assistance Were of Interest or Received Applications from Service Providers
paragraphs: Of the at least 10,000 properties determined to be suitable and available,  approximately 1,200 properties received notices of interest, and we  estimate that fewer than 400 properties received applications from  homeless assistance providers, resulting in the transfer of 122 properties  to assist the homeless in the 26 years since Title V’s inception through  March 2014 (see fig. 3).
According to HHS data, since the inception of the program in 1987, most  properties deemed by HUD to be suitable and which are available for  homeless assistance have not received notices of interest or applications  from homeless service providers. In addition, we found that in many  cases, suitable and available properties may not have been practical for  homeless service providers to use. Our analysis of HUD’s 2013 annual  report published in the Federal Register found 630 properties published  as suitable and available including buildings ranging from a 12 square  foot storage shed to a 75,720 square foot building in a restricted area,  and vacant land ranging from about one hundredth of an acre to over 15  acres. These properties may be inconveniently located at a distance from  existing communities or public transportation, within a military installation,  or in poor condition––conditions consistent with what we found in our  prior work (see table 3).
As noted above, HUD is required to evaluate the properties and applies  criteria that are defined in implementing regulations. A landholding  agency may indicate on the Title V checklist, for example, that a property  has extensive deterioration, but according to HUD officials, if the  landholding agency does not provide supporting documentation, HUD  may deem the property suitable for homeless assistance. As a result,  HUD designates many properties as suitable with deficiencies that may  therefore make them less desirable to homeless assistance providers.  The suitability criteria in HUD’s regulation for implementing the Title V  homeless assistance program include provisions for excluding properties  with deficiencies such as contamination, structural damage or extensive  deterioration that are documented, extensive, and considered by HUD as  representing a clear threat to personal safety. For example, while HUD  did not determine conditions to rise to the level of a “documented  deficiency,” our analysis of the 630 suitable and available properties  reported in the HUD’s 2013 annual report found properties with conditions  described as “deteriorated” (35 properties) and in “very poor condition”  (18 properties).
Moreover, almost 80 percent of the properties published as suitable and  available in 2013 were for “off-site use only.” These properties refer to  buildings and other removable structures that are located on land that is  not surplus and, therefore, must be removed and relocated. According to  officials from the National Law Center, the costs of moving the building,  preparing the land on which to relocate the building, and making  improvements needed to convert the building to provide services are  often beyond the budget of the homeless-assistance service providers.
Officials from four of our nine selected landholding agencies told us they  believe that properties for off-site use only are not practical for homeless  assistance services. In addition, although an HHS official with  responsibility for the Title V program told us that four of the 122 properties  transferred under the Title V homeless assistance program were made  available for off-site use only, these properties were trailers, which are  designed to be easily moved, as opposed to other types of off-site  properties described below, which may not be easy to move. For 2013,  the most recent year reported, of the 630 properties HUD listed as  suitable and available in the annual report, 78 percent were for “off-site  use only” (see table 4).
Since the majority of properties reported as suitable and available in 2013  were for off-site use only, as a result, they may be impractical for  homeless assistance. For example, according to U.S. Army officials,  since most of the Army’s properties reported under Title V are located on  secured installations and do not involve the transfer of land, these  properties are often made available to homeless assistance providers for  “off-site use only.” In addition, because most buildings in the Army’s  inventory consist of masonry and steel, the removal of these properties is  costly. As a result, U.S. Army officials said that very few homeless  assistance providers have expressed interest in Army properties  designated for “off-site use” since the program’s inception. Similarly,  DOI officials told us that because the agency does not relinquish federal  park lands, the buildings published as suitable and available located  within federal parks are also designated for “off-site use only.” Many  federal park lands are in remote areas, and moving a building from those  locations can be costly.
USICH’s 2011 agency annual report stated that, because of the wide  latitude in the suitability standard, a clear majority of the properties HUD  finds “suitable” are not actually practical for homeless assistance. noted above, HUD considers all property suitable for homeless  assistance unless a property’s characteristics meet one or more of six  conditions, such as national security concerns or location in a floodway.  The relatively large numbers of properties deemed by HUD to be suitable  and that were available may give homeless assistance providers, the  public, and other stakeholders a false impression as to what properties  are of practical use for homeless assistance because they included a  large proportion of properties that have substantial deficiencies. In turn,  this may mislead stakeholders about the extent to which the federal  government is providing federal real property for homeless assistance.
United States Interagency Council on Homelessness. Opening Doors: Appendix:  Programs for People Experiencing Homelessness 2011 (Washington, D.C.: 2011). determinations. However, HUD’s database does not have the capability  to generate reports on properties or data for the purpose of analyzing the  properties reported for the Title V homeless assistance program. For  example, when we asked HUD for reports from the database in order to  perform our own analysis, such as the total number of properties  reviewed for suitability and the total number published as suitable and  available since program inception, the agency was unable to provide  these data to us. The database was designed, and is primarily used, to  generate listings of properties for publication in the Federal Register. The  PDF format of the Federal Register reports poses challenges for  automated analysis, and as a result, we had to manually count numbers  of properties in specific categories to ensure the validity of our analysis,  such as those for off-site use only reported in table 4. Standards for  Internal Control in the Federal Government states that managers are  responsible for providing reliable, useful, and timely information for  transparency and accountability of programs and their operations.  Reliability also means that for any computer processing of the data  elements used, the results are reasonable, complete, and accurate. In  addition, federal information technology guidance for publicly available  data states that accessible data should be made available in convenient,  modifiable formats that can be retrieved, downloaded, indexed, and  searched. As the database cannot produce reports on the properties,  HUD relies on hard-copy record keeping, which limits HUD’s ability to  make information on properties readily available, requiring labor intensive  use of resources to find needed data. This capability is important because  Title V requires HUD to make available to the public upon request all  information in its possession about all properties reviewed and not  identified as suitable for the homeless—about 30,000 properties  according to HUD’s estimate—including the reasons such properties were  not so identified.litigation, the plaintiffs hired a contractor to make copies of the requested   Moreover, HUD officials told us that during the recent  data from HUD’s hard copy files, and it took three individuals several  weeks to complete the task. Without a comprehensive database that  maintains this information, HUD would need to respond to such a request  on up to 30,000 properties by manually looking through files, which would  not be an efficient use of resources. Because HUD uses the database  primarily for generating listings, it has not assessed the extent to which  the benefits of modifying the database to generate electronic reports for  the purposes of responding to information requests or performing  analysis, or if developing a new database to do so would outweigh the  costs. Modifying its database, or developing a new one that is  electronically searchable, would better position HUD to respond to  information requests.
section_title: Landholding Agencies Report Many Properties That May Not Be Useful to Assist the Homeless, and Do Not Report Some Properties
paragraphs: While it is HUD’s role to assess the suitability of properties for use to  assist the homeless, some federal landholding agencies report many  properties to HUD that may not, in the landholding agencies’ estimation,  be useful to assist the homeless. However, a few landholding agencies’  officials told us that they do not report such properties or other surplus,  underutilized, and unutilized properties because the reporting  requirements are labor intensive or the properties may not be useful to  the homeless. As noted above, the Title V homeless assistance program  requires quarterly reporting and completion of a checklist for each  property. The following examples illustrate the variety of Title V reporting  practices among the agencies we reviewed.
U.S. Navy officials told us that they report only excess properties to  HUD because of the size of their real property portfolio— approximately 85 installations, and over 65,000 buildings and  structures. According to these officials, the Navy does not have the  resources to report on underutilized and unutilized property, which  they said would require constant monitoring. Furthermore, the Navy  also does not report some properties within Navy installations that do  not allow public access within certain areas.
US Army officials said that they report eligible Title V property to HUD  but noted that the Title V process is time-intensive for several  reasons. They noted that the Army may report up to 500 properties to  HUD each quarter and that HUD requires submission of each property  checklist in hard copy. In addition, U.S. Army officials said that the  Army has to submit a Title V checklist each time it wants to demolish  an installation building and that the Title V homeless-assistance  program-reporting requirements could add about 6 months to the  demolition process.
DOE officials said that they report to HUD the property they are  required to report, but believe that completing the Title V reporting  requirement was not an efficient use of their resources since much of  the agency’s reported real property has documented deficiencies,  including environmental contamination requiring remediation, and is  located within secured boundaries and HUD determines many of  these unsuitable for homeless assistance. For example, DOE  properties typically include radiological contaminants commingled with  other metals and chemicals associated with nuclear research and  production. In our prior work, DOE also told us that the department  understood the need to screen excess real property, but that much of  its portfolio to be disposed had no remaining useful life and was most  often located within a secure compound.
DOI officials said that they are required to––and do––report to HUD  on numerous small, remotely located properties in National Parks that  they have decided to dispose. For example, many cabins are not  accessible by road or may be accessible only by water and only  during certain times of the year. Officials also told us that in 2013, 73  properties, mainly small houses on National Park lands were  determined suitable but for off-site use only, yet the majority of these  properties were in such poor condition that they could not be moved.  In addition, DOI officials said that they do not report to HUD real  property that is only used seasonally as unutilized or underutilized  because the agency will use the properties again in the following  season. The Title V homeless assistance program checklist, however,  expressly asks whether an underutilized property is used seasonally  (see app. II: HUD Title V Checklist Submitted to Landholding  Agencies, item 6B).
EPA officials noted that although some of its laboratories are only  partially used, they do not report these as underutilized real property  for HUD’s Title V canvas because they do not believe they are  required to do so. Rather, EPA’s practice has been to report that it  does not have any underutilized or unutilized properties for each  quarterly canvass because the space is laboratory space that agency  officials do not think is practical for homeless assistance programs.  EPA officials said that they are currently conducting a space utilization  study for laboratories, and after the study is completed, they will  determine whether to report underutilized and unutilized properties  identified through the study.
GSA officials told us that as a provider of space to other federal  agencies, GSA properties are sometimes temporarily or partially  vacant as the space needs of tenant agencies fluctuate. GSA officials  said that they do not consider these properties to be underutilized and  unutilized because the agency plans to use them to house future  federal tenants. GSA officials said that if they identified underutilized  and unutilized property in the portfolio that was not to be reported as  excess, they would report these to HUD’s canvass. However, GSA  could not identify any such properties that it had reported to HUD in  the 6 years from 2008 through 2013. Nonetheless, even if GSA  identified a future need for temporarily or partially vacant space, it, like  other agencies, has two opportunities to inform HUD as to why  reported properties may not be available: first, the HUD Title V  checklist asks reporting landholding agencies to provide information  on any current or anticipated limitations for using the property to assist  the homeless for a period of one year or more; second, landholding  agencies are required to provide statements to HUD on the availability  of properties determined suitable, including reasons why the property  cannot be declared excess or made available for use to assist the  homeless.
HUD officials told us that they review and make a suitability determination  only for those properties reported to them by landholding agencies and  that they do not have a way of knowing how many properties should be,  but are not reported. In 2013, the U.S. District Court for the District of  Columbia noted that many landholding agencies appeared to be “failing to  fairly and accurately” report Title V homeless assistance program-eligible  properties as required under both the statute and Order. Further, the  court noted that there was a significant discrepancy between the numbers  of properties reported to HUD under Title V and the much larger number  of federal properties listed as “excess” or “underutilized” in other  government reports and surveys. The District Court ordered several steps  to ensure the proper reporting of properties including that GSA and HUD  develop a plan for additional improved training programs for landholding  agencies. To address the court order, GSA and HUD officials told us they  conducted a joint webinar with HHS in November 2013 for landholding  agencies.
HUD officials told us that they would prefer that agencies not be required  to report certain types of properties at all because they may not be useful  to assist the homeless. Requiring agencies to report all properties that fall  within the four broad categories—excess, surplus, underutilized, and  unutilized—may not be effective for certain types of properties. While  there are discretionary elements in HUD’s suitability criteria that are  applied to properties submitted by the landholding agencies, HUD does  not have the authority to release agencies from their statutorily required  reporting of certain types of properties. Excluding certain types of  properties such as “off-site use only properties” could enable HUD  officials to focus on the suitable and available properties that may be  more likely to assist the homeless and could help address issues of  landholding agencies not reporting certain properties. In 2013, HUD  proposed a revision to the law that would limit some of the types of  properties agencies report, such as those that are located in high security  areas and any building or structure that is made available for off-site use  only. No action has been taken on that proposal.
section_title: Homeless Assistance Providers Expanded Services, but Some Reported Encountering Challenges in Identifying, Applying for, and Using Real Property
paragraphs: Of the 11 homeless assistance providers we interviewed, the eight case  study providers that acquired property cited benefits from the Title V  program, such as expanding services and obtaining real property at no  cost. These successes notwithstanding, the providers identified  challenges such as locating information on available properties, a  complex application, difficulty altering the approved use of transferred  properties, and competing stakeholder interests. For example, although  HUD reports properties in the Federal Register multiple times a year, and  USICH provides links to them on its website, many homeless assistance  providers may be unaware of the availability of properties. This may be  because homeless assistance stakeholders have said the Federal  Register is not user-friendly. Further, HUD’s Federal Register reports list  many of the same properties more than once. This may make listings  even less user-friendly to providers. Homeless assistance providers and  advocates we interviewed identified a number of actions that could  address these challenges.
subsections: section_title: The Title V Homeless Assistance Program Enabled Selected Providers to Expand Services and Obtain Real Property at No Cost
paragraphs: Of the 11 homeless assistance providers we interviewed, the eight case  study providers that acquired property cited a variety of benefits resulting  from the acquisition of real property under the Title V homeless  assistance program.  Representatives of the providers responsible for  the eight case study properties we reviewed either said that the Title V  program enabled them to expand their program or service capacity (five  providers) or acquire real property at no cost (four providers).  Representatives of two providers cited both types of benefits (see app. V  for a description of each of the case study properties).
For example, the following providers spoke of how they were able to  expand their programs through the Title V homeless assistance program:
The acquisition of the former Boyle Heights Social Security  Administration Building in Los Angeles enabled Volunteers of America  of Los Angeles (VOALA) to offer services for the homeless, including  referral services, food and clothing distribution, and job training in Los  Angeles. VOALA reported serving more than 1,000 persons at this  facility in 2013.
The acquisition of an 84-acre portion of the former Homestead Air  Force Base in Homestead, Florida, enabled Miami-Dade County to  provide comprehensive services, including emergency shelter,  transitional housing, and permanent supportive housing, in addition to  job training, medical care, and clothing, among other services. In  2013, the Miami-Dade County Homeless Trust reported serving 2,143  homeless adults and minors at this facility.
Other providers described how the Title V homeless assistance program  enabled them to acquire property otherwise not affordable:
Prior to acquiring four homes located in residential neighborhoods on  Maryland’s Eastern Shore, Crossroads Community, Inc. rented real  property to provide rehabilitative services to individuals with mental  illness in residential settings. Through the Title V homeless assistance  program, the provider was able to replace rental property at a  relatively low renovation cost with four homes that it acquired through  the program. In addition, the program property allowed the provider to  locate clients closer to its other service programs. According to  Crossroads Community, Inc., the acquisition of the four houses  currently saves the organization about $62,000 in rent on an annual  basis.
According to a representative of the City of Redmond, Washington,  the greatest benefit of the Title V homeless assistance program lies in  providing opportunities for non-profit organizations to acquire real  property at minimal or no cost. The city acquired at no cost about half  of a 10.2 acre site under the program that included 16 housing units  formerly used to house U.S. Coast Guard personnel. The City of  Redmond purchased the remainder of the real property through a  negotiated sale with GSA. From the outset, the city planned to  redevelop the Title V homeless assistance program portion of the real  property into a larger facility to assist the homeless and 1-acre park,  and develop the non-Title V portion into affordable housing units.  Leveraging its resources, the city redeveloped the Title V homeless  assistance program portion of the real property with 59 housing units  that provided emergency, transitional, and permanent supportive  housing for 319 households in 2013.
In addition to enabling homeless assistance providers to expand their  services and obtain property they would likely have to pay for otherwise,  the National Law Center stated that the Title V homeless assistance  program also benefits the taxpayers by repurposing and reusing real  property no longer needed by the federal government, helping the  government––and by extension, the taxpayers––avoid and eliminate the  maintenance and operation costs of retaining these properties.
section_title: Selected Homeless Assistance Providers Reported a Range of Challenges in Identifying, Acquiring, and Using Federal Real Property
paragraphs: These successes notwithstanding, homeless assistance providers we  interviewed identified challenges such as locating information on available  properties, a complicated application, difficulty altering the approved use  of transferred properties, and competing stakeholder interests.
subsections: section_title: Most Selected Homeless Assistance Providers Were Unaware of Federal Register Notices
paragraphs: Although HUD reports regularly in the Federal Register for the purpose of  informing homeless assistance providers about properties, among the 11  homeless assistance providers we interviewed, one said it was initially  unaware of the program or the availability of real property in its area, and  eight told us they eventually learned about the program through third  parties rather than through the Federal Register. Title V requires HUD to  publish, in the Federal Register, a list of real property it has evaluated for  suitability. This occurs multiple times each year: four quarterly reports and  a summary annual report. In addition, to comply with the 1988 court  order, as modified in 1993, HUD publishes a weekly notice in the Federal  Register of properties that are suitable and available, unavailable, and  unsuitable (see table 5).
HUD shares the Federal Register notices of suitable and available  properties with the U.S. Interagency Council on Homelessness (USICH)  multiple times a year, and USICH provides links to the list on its agency  website. Nonetheless, according to national homeless advocates, many  providers remain unaware of the availability of properties. For example,  the National Law Center reported that despite the Title V homeless  assistance program’s having been in existence for 25 years, too few local  government and homeless providers are aware that they are eligible to  receive property free.Coalition for the Homeless told us that in general, homeless assistance  providers do not have the staff resources to check the Federal Register  consistently.
Moreover, a representative from the National  In addition, HUD’s Federal Register reports list many of the same  properties more than once, as required, and that may make listings more  confusing and less useful for providers to use. For example, for the period  from 2008 through 2013, 59 percent of the properties appeared in more  than one annual report. Because, under Title V, suitable properties must  be reported on an ongoing basis until they are disposed of––regardless of  their availability status––HUD reports some properties in the Federal  Register multiple times, in some cases over several years, even though  homeless assistance providers have not expressed interest in these  properties. Our analysis of HUD’s annual reports for calendar years 2008  through 2013 found that of the 1,677 properties reported over the 6 years,  982 (59 percent) appeared in more than one annual report and 288 (17  percent) appeared in each of the six annual reports. For example, we  found one property in Baltimore, Maryland, that was listed in three annual  reports from 2011 through 2013. In another case in Macon, Alabama, a  property was listed in HUD’s annual reports each year from 2008 through  2011. In the past, some in Congress and the executive branch have  expressed concern about reporting requirements; the basic concern has  been that some requirements result in reports that may be unnecessarily  burdensome to produce or, in some instances, not very useful. Our prior  work at other federal agencies has reviewed reporting requirements, the  limited usefulness of some reports, duplicative reporting, and has found  that less frequent reporting could allow agencies to continue to fulfill their  responsibilities.
HUD officials told us that, instead of publishing suitable and available  properties in the Federal Register, they believe it would be more efficient  and beneficial to homeless providers to publish the information on their  Community Planning and Development “OneCPD” website, which serves  as a resource exchange and provides technical assistance to  stakeholders for a wide variety of programs including the Title V homeless  assistance program. Further, both the National Law Center and the  National Coalition for the Homeless suggested that available properties  should be listed on the Internet in an easily accessible format, unlike the  Federal Register, which they said is not user-friendly. Some stakeholders  suggested that the federal government could make information more  accessible by establishing a single web-based source of information on  the program. However, if HUD were to report Title V properties on its  OneCPD website, this would add to HUD’s other reporting requirements if  the Title V reporting requirements remained unchanged, and HUD  officials do not believe they have the resources to do both.
section_title: Complex Application
paragraphs: Five of the homeless assistance providers we interviewed noted  challenges with the application. Two providers reported that completing  the application required additional resources and was time consuming,  particularly in obtaining technical reports such as environmental  assessments. For example, one organization hired a contractor to  prepare the application, which was nearly 300 pages long and required  extensive technical documentation. In another case, the representative  said that the application process was time consuming because of the  large volume of supporting documentation required. Among the homeless  assistance providers we interviewed, one reported obtaining the  environmental reports from GSA, while others paid a consultant to obtain  the documentation or used their resources to collect it for the purpose of  the application. Another provider noted that GSA responded slowly to  requests for both access to the site and for documentation, such as site  blueprints. According to this representative, GSA took nearly 60 days of  the 90-day application period to provide access and documentation that  had been requested at the beginning of the application process.on our work, we believe the large difference, discussed above, between  the number of notices of interest and the number of applications may be,   Based  in part, due to the complexity and resources required to complete the  application within a 90-day period. These case study results are  consistent with the National Law Center’s findings, which state that the  application is lengthy and cumbersome, making it difficult for a homeless  assistance provider to complete in the short time frame imposed under  the law. In addition, the application calls for homeless assistance  providers to collect information that is already in the government’s  possession, such as a description of the easements on the property.
The HHS Title V official told us that several years ago, the Department  modified the application packet to address some of these stakeholder  concerns. Two homeless assistance providers we interviewed suggested  that HHS consider providing examples of model applications on a public  website. HHS officials told us that they believe posting examples of  successful applications on the Internet may lead to homeless assistance  applicants using examples that may not be relevant to their particular  circumstances.
section_title: Difficulty Altering Approved Real Property’s Use to Meet Changing Client Needs
paragraphs: HHS, as the agency responsible for ensuring that homeless providers use  the transferred real properties according to the approved application, also  approves any changes to the original program of use for the properties.  Two of the selected case study providers told us that they found it difficult  to alter the original program of use for their properties. According to the  two providers, the needs of the homeless clientele they serve had  changed since their applications were approved. For example, one  provider told us that the homeless population the organization currently  serves largely consists of persons recently released from incarceration  and, unlike the population it served when the property was first  transferred in 2002, is perhaps better educated than the previous  population. This provider stated that due to the changing population,  workforce training has become more of a need than it was in the past.  The provider noted that it took many letters to convince HHS that  workforce training was a necessary part of the organization’s homeless  assistance. Another provider obtained a property for use as transitional  housing for mentally ill homeless adults and wanted to alter the program  to provide permanent housing to this population; a representative for that  provider told us that the organization has thus far decided not to pursue  its request to HHS because it understands that it would have to restart the  application process. HHS Title V homeless assistance program  representatives told us, that while much of the information requested for  the original application would need to be resubmitted, the provider would  not need to resubmit a full application.
section_title: Competing Stakeholder Interests
paragraphs: Our literature review and case study interviews found that homeless  assistance organizations often reported meeting resistance from local  interests and groups when attempting to acquire federal properties.  Further, USICH’s 2011 annual report noted that, in some cases, local  opposition to the use of the property by homeless providers has caused  them to withdraw their applications to the Title V homeless assistance  program. Two of the homeless providers we interviewed for our case studies reported meeting strong community opposition, which, according  to one provider, related to concerns about safety, number of homeless  assistance facilities within a given area, and the impact on real property  values, for example:
One case study provider, whose real property is located in an  industrial, non-residential area, told us that the organization changed  its original plan from providing shelter services to providing job  training and social services instead of shelter in response to local  opposition from neighboring businesses.
Another case study provider encountered strong local opposition to its  proposal to use the four residential properties as locations for clients  undergoing mental health rehabilitation. The provider said its  organization mitigated the resistance over the course of a year by  holding multiple informational community meetings and conducting a  workshop on removing the stigma associated with mental illness and  homelessness at a local community college. Since the program has  been in place, the organization has not experienced any further  opposition to the program.
Another case study provider described how the organization  successfully addressed and minimized the potential for local  opposition. In this case, the City of Redmond, Washington, worked  with an inter-local government organization– A Regional Coalition for  Housing (ARCH)–in acquiring the Title V real property. The City and  ARCH then worked with a consortium of homeless providers in  developing a homeless assistance program. Anticipating concerns,  particularly from nearby residents, ARCH and the city staff reached  out to the neighborhood to ensure that neighborhood interests were  represented during the planning phase of the program, including a  series of meetings.
Our prior work has found similar competing stakeholder interests. For  example, state and local governments, business interests in the  communities where the assets are located, private sector construction  and leasing firms, various advocacy groups, and the public in general  have an interest in how the federal government carries out its real  property management practices. We have raised this concern as an  underlying problem in our biennial high-risk area updates on federal real  property. In addition, we recommended to the Office of Management  and Budget (OMB) in 2012, the development of a cohesive national  strategy for managing federal excess and underutilized real property that  would also address competing stakeholder interests. OMB did not directly  state whether it agreed or disagreed with our recommendation.  Moreover, OMB has not taken action on our recommendation as of the  time of this report.
All four federal agencies—GSA, HHS, HUD and USICH—bear some  responsibility for addressing challenges homeless assistance providers  face with the Title V homeless assistance program, such as identifying  and acquiring properties and developing a web-based source of  information on the program. By collaborating to address these concerns,  the federal agencies could provide information that would be more useful  to homeless providers and thereby more effectively manage agency  resources to contribute to the goal to end homelessness. Our prior work  has found that many of the meaningful results that the federal  government seeks to achieve require the coordinated efforts of more than  one federal agency and often more than one sector and level of  government. We have reported about the importance of collaboration  among federal agencies for many years. In its 2011 annual report, USICH  noted that the Title V homeless assistance program process for  identifying properties, determining suitability, determining availability by  landholding agencies, and leasing or deeding surplus properties involves  at least three federal agencies and can appear quite confusing and  cumbersome to homeless providers. USICH is composed of  representatives from 19 federal agencies—including GSA, HHS, and  HUD. While not having the authority to ensure compliance, USICH  monitors, evaluates, and recommends improvements in federal and state  homeless assistance programs and is required by law to meet at least  four times a year. USICH is supported by the Council Policy Group, which  provides a regular forum for coordinating policies and programs,  collecting data, developing special initiatives, and preparing  recommendations for consideration by USICH members. Unlike other  interagency groups, although USICH is a very small agency, it receives  an appropriation from Congress and employs full-time staff in  Washington, D.C., and five regional posts. As such, resources and a  process for addressing some of the stakeholder concerns are already in  place.
section_title: Conclusion
paragraphs: HUD has evaluated at least 40,000 underused, unused, and unneeded  federal real property assets for the Title V homeless assistance program  since it began in 1987. However, only a small fraction of the properties  HUD determined suitable and that were available have been transferred  to homeless assistance providers since the program’s inception—likely  because the majority of the properties were not useful to them. The 81  active properties transferred have provided needed services to the  homeless population across the nation. While HUD lists information on  the properties it evaluates in the Federal Register multiple times each  year, as required by law, many of the listings are duplicative, and many  service providers are not even aware of the Title V homeless assistance  program. Given that all underutilized, unutilized, excess, and surplus  federal real property is subject to Title V homeless assistance program  reporting requirements––including buildings, land, or both, without regard  to location, size, or practicality—the scope of properties reported (with  particular attention to the usefulness of the property and the frequency of  reporting) is crucial to helping HUD make the program more useful to  homeless assistance providers. In addition, a reliable, searchable  electronic database of the properties HUD has reviewed would improve  HUD’s ability to provide information to meet required reporting needs.  While homeless assistance providers benefitted from obtaining federal  real property otherwise not affordable to them and expanded their  services, addressing the challenges they face in identifying properties  would improve program effectiveness. Collective efforts by all four  responsible federal agencies—GSA, HHS, HUD, and USICH—could help  to address these concerns. Without these changes, the Title V homeless  assistance program may not be making the best use of its resources to  make progress toward ending homelessness in the nation.
section_title: Matter for Congressional Consideration
paragraphs: To ensure that properties determined as suitable and available are more  likely to be practical for homeless assistance and that Federal Register  reporting is not redundant, Congress should revisit the scope of  properties to be reported to HUD with respect to the types of properties  that may be less likely to be useful to assist the homeless and the  frequency of Federal Register reporting.
section_title: Recommendations for Executive Action
paragraphs: To improve HUD’s database on Title V homeless assistance  properties, HUD should modify its existing database or create an  electronic, searchable database to meet reporting needs to the extent  that the benefits outweigh the costs.
HUD, GSA, HHS, and USICH should work together to address the  challenges that homeless assistance providers face with the Title V  homeless assistance program by  identifying what kinds of properties are most practical for homeless  assistance, and developing a web-based source of information on the program for  homeless assistance providers.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report for review and comment to the four  agencies with a role in administering the Title V homeless assistance  program: GSA, HHS, HUD, and USICH. We also provided a draft of this  report to the landholding agencies we included in our review: the EPA,  the DOD service branches—the U.S. Air Force, the U.S. Army and the  U.S. Navy––DOE and DOI. We received written comments from GSA,  HHS, and USICH, which are summarized below and reprinted in  appendixes of this report. HUD’s agency liaison provided comments via  e-mail on September 18, 2014, which are summarized below. In addition,  GSA, HHS, HUD, the U.S. Army and the DOE provided technical  comments, which we incorporated as appropriate. The EPA, U.S. Air  Force, U.S. Navy, and DOI did not provide any comments.
GSA concurred with the findings of the report and the recommendation  that it work with HHS, HUD, and USICH to address the challenges that  homeless assistance providers face by identifying what kinds of  properties are most practical for homeless assistance and developing a  web-based source of information on the program for providers. GSA  stated that it will continue to work with both HUD and HHS on this effort.  GSA noted that it has taken steps to enhance its website with additional  information and resources about the Title V homeless assistance program  and provide additional information about how to locate available  properties. The agency stated that it has also provided the opportunity for  interested homeless assistance providers to subscribe to receive  automatic e-mail notifications as properties are posted to its website.  These are positive steps to provide additional information on the  homeless assistance program. GSA’s comments can be found in  appendix VI.
HHS did not concur with our recommendation that it should work together  with GSA, HUD, and USICH to address the challenges that homeless  providers face by identifying what kinds of properties are most practical  for homeless assistance. HHS stated that this was outside of the scope of  its legal authority and noted that under the authorizing statute and the  regulation, HUD, is solely authorized to identify suitable property and  apply the suitability criteria to properties reported by landholding agencies  pursuant to Title V requirements. We recognize that under the statute,HUD is solely authorized to make determinations regarding whether  properties are suitable for use to assist the homeless. However, the  McKinney-Vento Homeless Assistance Act, as amended, required GSA,  HHS, and HUD to promulgate implementing regulations. In response,  GSA, HHS, and HUD promulgated a joint interim final rule that set out,  among other things, the criteria to be applied by HUD in making its  suitability determinations. The interim final rule putting the joint regulation  in place explained that the suitability criteria have been developed with  the intent of excluding only those properties that are clearly unsuitable for  use to assist the homeless. The issuing agencies of the joint rule may  revisit the scope of such regulatory exclusions of clearly unsuitable  property to assess if they merit adjustment. Given that the rule was a joint  issuance by GSA, HHS, and HUD, our recommendation that the agencies  work together to identify what kinds of properties are most practical for  homeless assistance is directed to the four agencies with responsibility  for implementing the program. HHS concurred with the second part of the  recommendation that it should work together with GSA, HUD, and USICH  to develop a web-based source of information on the program for  homeless assistance providers, and noted that it is in the process of  refurbishing its federal real property assistance website and will consult  with the other three agencies to discuss options relating to web-based  sources of information on the Title V homeless assistance program.   HHS’s comments can be found in appendix VII.
HUD also concurred with the report’s overall findings, and with the  recommendation that it modify its database or create a searchable,  electronic database on the Title V homeless assistance properties to  meet its reporting needs. HUD officials noted that its proposed legislative  changes included the development of an improved database that would  be searchable and would allow HUD stakeholders to view profiles of  those properties that are suitable and available to be used to assist the  homeless. HUD also concurred with the recommendation that it work  together with GSA, HHS and USICH to address challenges providers face  with identifying the kinds of properties that are most practical for  homeless assistance, and to develop a web-based source of information  on the program. HUD noted that it had already proposed legislative  changes to create a web-based source of information on available  properties in place of publishing properties in the Federal Register.  Although we support a legislative change to address certain aspects of  the law, as stated in our Matter for Congressional Consideration, our  recommendations to HUD are not contingent upon legislative changes.  As noted in our report, because HUD uses its Title V database primarily  for generating listings for the Federal Register, it has not assessed the  extent to which the benefits of modifying it to generate electronic reports,  or developing a database to do so, would outweigh the costs. In addition,  as one of the four federal agencies responsible for the program, HUD  shares responsibility for addressing the challenges that homeless  assistance providers face, such as identifying and acquiring properties  and developing a web-based source of information on the program.
USICH agreed that the scope of properties that agencies are required to  report under Title V include large numbers of properties that could not  viably be used for homeless assistance. However, it did not agree with  our recommendation that it work together with GSA, HHS, and HUD to  identify the kinds of properties that are most practical for homeless  assistance. USICH stated that improving the identification of properties  that are practical for homeless assistance cannot occur through  collaboration alone and that a legislative fix is an essential prerequisite.  We continue to believe that, as one of the agencies responsible for  implementing the Title V homeless assistance program, USICH shares  responsibility for addressing challenges homeless assistance providers  face, such as identifying and acquiring properties. As noted in our report,  by collaborating to address these concerns, the federal agencies could  provide information that would be more useful to homeless providers.  USICH concurred with the recommendation on developing a web-based  source of information on the program for homeless assistance providers  and stated that it may be beneficial for disseminating information on  available federal real properties to interested stakeholders. USICH’s  comments can be found in appendix VIII.
As agreed with your offices, 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 to the Administrators of the  Environmental Protection Agency and the General Services  Administration; the Executive Director of the U.S. Interagency Council on  Homelessness; and the Secretaries of Defense, Energy, Health and  Human Services, Housing and Urban Development, and the Interior. We  are also sending copies of this report to the House Committee on  Oversight and Government Reform. In addition, this report will be  available at no charge on GAO’s website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-2834 or wised@gao.gov. Contact points for our Office of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made key contributions to this report are  listed in appendix IX.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine what is known about the identification and transfer of  federal real properties for homeless assistance under Title V, we  reviewed the requirements of Title V of the Act as they apply to the  General Services Administration (GSA), the Department of Health and  Human Services (HHS), the Department of Housing and Urban  Development (HUD), and the United States Interagency Council on  Homelessness (USICH). We reviewed these agencies’ internal policies,  procedures and other documents on how they implement the  requirements of the programs. HUD does not maintain electronic records  of all the properties reported under Title V since the inception of the  program. Thus, due to the lack of available data in a format that allowed  analysis, HUD provided us with estimates of the number of underutilized,  unutilized, excess, and surplus properties reported by landholding  agencies and the number that HUD determined to be suitable and were  available for homeless use from the early 1990s through March 31, 2014.  These estimates are based on the number of properties that were entered  into HUD’s Title V database, developed in the early 1990s, several years  after the McKinney-Vento Act was implemented. Further, HUD officials  are not certain of the extent to which the database includes the Title V  homeless assistance program properties reported prior to its creation.  Due to the lack of available data in a format conducive to analysis, we  could not verify the reliability of these estimates. We interviewed officials  from HUD about how the estimates were derived and could not verify the  reliability of these estimates. To assess the reliability of these estimates,  we interviewed officials from HUD about how the estimates were derived  and determined that the information provided by the agency provides a  reasonable basis, with caveats, for reporting the number of properties that  have been screened and published as suitable and available. In addition,  to determine the number of properties reported in these categories and  the number and percentage of these that were available for “off-site use  only,” we analyzed HUD annual reports of suitable/available and  suitable/unavailable properties for years 2008 through 2013. This time  frame was selected to include the 5 years prior to the audit, and when  HUD’s annual report for 2013 became available we added it to the  analysis to include the most recent information. Our analysis of the  Federal Register notices relied on identifying properties by the unique  Property Identification (ID) number published with each property listing.  We also obtained from HHS documents and data on the number of  notices of interest and applications received for federal real property  made available for homeless assistance and on the number, location, and  use of properties transferred from the program’s inception in 1987  through March 31, 2014—the date of the most recently available  information.
To assess the reliability of these data, we interviewed officials from HHS  about how the data are collected and maintained and the steps taken by  the agency to ensure the completeness of these data. Based on this  discussion, we determined that the data were sufficiently reliable for the  purposes of this report. In order to assess the number of properties that  received notices of interest and applications from interested providers, we  also manually reviewed data on notices of interest and applications  received to identify potential duplicate properties by GSA number,  property name, location, and description. To understand how federal  landholding agencies identify and report real property to HUD pursuant to  the Act’s requirements, we selected nine landholding agencies to include  a range of size among real property portfolios of land and buildings.  These agencies were GSA; HHS; the Departments of Defense’s U.S.  Army, U.S. Air Force, and U.S. Navy; the Departments of Energy; the  Interior and Veterans Affairs; and the Environmental Protection Agency.  When combined, these nine landholding agencies accounted for almost  90 percent of the buildings held by the federal government in 2012.  We  collected documents from these agencies to understand how each  agency manages and fulfills its reporting requirements under Title V, the  extent to which it collaborates with other agencies, and to obtain views on  how Title V requirements impact the federal real property disposal  process. We interviewed agency officials from the GSA, HHS, and HUD  to understand how they process properties reported under Title V  homeless assistance program requirements, and we interviewed officials  from USICH to understand its role with Title V. We also interviewed  agency officials from the nine landholding agencies to obtain their views  on how they meet the Act’s requirements and the impact of those  requirements on each agencies disposal process.
To determine the benefits and challenges selected homeless assistance  providers and national advocacy organizations reported in identifying,  acquiring and using federal real property, and the potential actions that  could help address those challenges, we selected eight homeless  assistance organizations that acquired federal real property under the  program. The providers were: the City of Redmond, Washington;  Crossroads Community, Inc.; Samaritan House; The Miami-Dade County  Homeless Trust; Third Way Center; Urban Renewal Corporation;  Veterans Coming Home/New Life Evangelistic Center; and Volunteers of  America, Los Angeles. We made our selection using criteria such as the  size of the real property acquired under the program, the services  provided, geographic distribution, range of experiences with the Title V  program, and suggestions from agencies and homeless advocacy  organizations (GSA, HUD, HHS, USICH, the National Law Center on  Homelessness and Poverty, and the National Coalition for the Homeless).  In addition, to assist the selection, we also used information from news  reports and our literature review to identify high-profile properties. We  interviewed representatives from each of the selected organizations,  reviewed their annual utilization reports, and conducted site visits to two  properties transferred under Title V. While information from case studies  is not generalizable, the perspectives of the homeless service providers  provided us with examples of the benefits and challenges associated with  the program. Further, to gain additional perspectives on experiences with  the federal agencies and the application process, and identify potential  improvements to the process, we convened a virtual discussion panel  comprised of representatives from homeless assistance organizations  whose Title V applications were not approved. We selected and recruited  seven organizations, of which three agreed to participate in the panel.  These organizations were selected from HHS’s Title V homeless  assistance program applicant data from 2006 through 2013 based on  their geographic locations and proposed use of the properties. We  selected the particular time frame to ensure that the information provided  was reasonably up to date. Since the virtual discussion panel was  selected using a non-probability sample of homeless assistance  applicants whose Title V applications were declined by HHS, like the case  studies, their experiences cannot be generalized to all homeless service  providers. In addition, we reviewed the reports and interviewed  representatives of two national advocacy organizations—the National  Law Center on Homelessness and Poverty and the National Coalition for  the Homeless.
We conducted this performance audit from September 2013 to  September 2014 in accordance with generally accepted government  auditing standards. Those standards require that we plan and perform the  audit to obtain sufficient, appropriate evidence to provide a reasonable  basis for our findings and conclusions based on our audit objectives. We  believe that the evidence obtained provides a reasonable basis for our  findings and conclusions based on our audit objectives.
section_title: Appendix II: Sample Title V Checklist Submitted by Landholding Agencies to HUD
section_title: Appendix III: List of Landholding Agencies HUD Canvasses for Title V
section_title: Appendix IV: Services Provided at 81 Active Properties Transferred under Title V, by State
paragraphs: As of March 2014, 81 Title V properties were currently in use by  homeless assistance providers across the country to provide a range of  homeless assistance services. The table below presents the services  provided at each location by state.
section_title: Appendix V: Eight Homeless Assistance Case-Study Properties
section_title: Appendix VI: Comments from the General Services Administration
section_title: Appendix VII: Comments from the Department of Health and Human Services
section_title: Appendix VIII: Comments from the U.S. Interagency Council on Homelessness
section_title: Appendix IX: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Amelia Shachoy, Teresa Spisak  (Assistant Directors), Lindsay Bach, Jennifer Clayborne, Kathleen  Gilhooly, Geoffrey Hamilton, Delwen Jones, Rosa Leung, John Mingus,  Josh Ormond, Amy Rosewarne, and Elizabeth Wood made key  contributions to this report.