Over the years we have reported on a wide variety of grant formula issues. During the 1970s and 1980s, we issued a number of reports on the funding formulas used to direct Revenue Sharing funds to local communities based on both their capacity and willingness to utilize local resources to address local needs. In anticipation of the 2000 census, we examined the potential effect of the decennial census population undercount on the distribution of federal grant funds for 25 large formula grant programs, including Medicaid. Over the years we have also assisted the Congress in revising the funding formulas under the Ryan White CARE Act, the Older Americans Act, Substance Abuse and Mental Health Block grants, and Title I education grants so that program funding would be more responsive to changes in program needs. This wide range of experience provides us with an in-depth understanding of the issues associated with the equitable and efficient targeting of federal grant dollars. Based on our past experience, I would like to offer a number of observations on the design of grant funding formulas. First, grant formulas reflect an intergovernmental partnership that structures how costs are to be shared among the various levels of government. When federal resources represent a declining share of the cost of meeting national goals, a greater effort to target high-need communities is necessary if federal funding is to make a significant contribution to closing the fiscal gap between high- and low-need communities. Second, targeting grant funding involves two key decisions: 1) determining which communities are eligible for assistance and 2) how to distribute funding among eligible communities. A clear statement of policy goals and objectives is essential as a guide for establishing grantee eligibility standards and identifying a manageable number of statistical indicators that can reliably direct formula funding to communities with the greatest need. Because the CDBG program has a wide variety of policy goals — the elimination of slums, historic preservation, and promoting more rational land use, among others — identifying eligibility standards and a reasonable set of indicators to represent program need is especially challenging. For example, the CDBG program’s goal of improving the physical infrastructure of economically distressed communities is reflected in several of the need indicators used in the program’s formula, such as poverty and older housing. However, there are no indicators for historic preservation or rational land use. In addition to program needs, consideration of fiscal equity or fairness suggests additional targeting factors beyond need indicators. Here there are two issues: 1) wide differences in communities’ ability to meet local needs with local resources and 2) geographic differences in the cost of financing local development projects. Regarding local resources, high income communities generally have stronger tax bases from which to fund program needs without relying on federal assistance compared to lower income areas. Accordingly, the allocation of scarce resources might reflect variations in local funding capacity. In addition, the cost issue arises for areas faced with a high cost-of-living since they would need to pay more for the workers who actually deliver services at the local level. Performance indicators are sometimes considered as a targeting factor though they present challenges as well. Ideally, performance indicators would reflect only grantee performance and not program outcomes that result from factors local officials have little ability to control. For example, it makes little sense to reward a state that has substantially reduced welfare dependence because it enjoyed a particularly strong economy but did no better than other grantees in terms of efficiently managing its welfare programs. Accurate performance indicators are particularly difficult to develop, especially as they pertain to goals that may take literally decades to realize. As a consequence, they require an even higher degree of scrutiny than needs-based indicators before being incorporated into funding formulas. For this reason a more common approach to promoting accountability is to require grantees to provide matching funds for projects funded under the program. Grantees are likely to be more vigilant in screening and funding individual projects if they must put a significant portion of their own resources at risk. While often difficult to enforce, at a minimum, such a requirement forces public discussion of how grant funds are to be employed. Before I turn to discussing the HUD study and its findings, I would first like to provide a brief description of the eligibility standards and funding formulas now used to target CDBG funding. To obtain entitlement status, a city must be the principal city of a metropolitan statistical area, as designated by the Office of Management and Budget (OMB), or have a population of at least 50,000 residents. An urban county must have a population of at least 200,000 residents. The formulas used to distribute funding among eligible communities reflect several broad dimensions of need. Originally, CDBG funding was distributed to entitlement communities based on a simple three-factor formula that took into account: the number of residents (population), the number of residents living in poverty, and the number of overcrowded housing units. Beginning in fiscal year 1978, Congress added a second three-factor formula that included the following need indicators: the number of residents living in poverty, the number of older housing units, and slow population growth or decline. Under this dual formula approach, grantees receive the larger amount allocated by either the first formula, commonly referred to as formula A, or the second formula, commonly referred to as formula B. The use of two formulas, each with three factors, results in allotments exceeding the funds available for distribution. To avoid this outcome, all grantee allotments are proportionally reduced to conform to the amount available for distribution by formula. Since the advent of the entitlement portion of the program, the number of participating communities has nearly doubled, increasing from 606 in fiscal year 1975 to more than 1,100 in fiscal year 2004. This trend can be expected to continue both because population will continue to grow and because new standards for designating metropolitan areas, as promulgated by OMB and utilized by the program, are also likely to increase the number of eligible communities. Since 1978 program funding has declined to roughly half its peak of $10.2 billion when measured in purchasing power of today’s dollars. When population growth is factored in, the decline in real per capita spending has declined by two-thirds, as illustrated in the accompanying figure. The policy implication of these trends is that with more limited resources, narrowing the gap between high- and low-need communities can only be realized by concentrating this more limited funding on high-need communities. This requires a new look at the program’s eligibility standards and funding formulas. The HUD study relies on two generally accepted equity or fairness principles to evaluate the targeting of CDBG funding: 1) equals should be treated equally and 2) those with greater needs should receive more than those with lesser needs. The first principle is based on the idea that communities with similar needs should receive roughly similar per capita funding amounts. The second standard is based on the idea that to reduce the gap between high- and low-need communities, additional funding must be targeted to communities with greater needs. This criterion is especially pertinent because, as the HUD report observes, Congress designed a formula intended to allocate CDBG funds according to variations in community needs. However, determining the extent to which program funding is disproportionately allocated to communities with the highest needs involves value judgments that are the responsibility of policymakers rather than technicians and administrators. The HUD study measures the extent to which funding is targeted to high-need communities and leaves it to policymakers to decide the appropriate degree of needs-based targeting. Before I address the conclusions reached in the HUD study, I first want to spend a couple of moments discussing the factors underlying the study’s need criterion, since all conclusions rest upon its validity. One of the criticisms directed at the CDBG program in the administration’s fiscal year 2006 budget proposal is that there is a “lack of clarity in the program’s purpose,” a statement which is supported by the long list of specific program objectives cited in HUD’s report. Given the broad and diffuse goals established for the program, it is difficult to identify a few clear and succinct indicators of program need appropriate for this program. Though HUD’s need criterion is not immune from criticism, it is, in our view, reasonable given the program’s diverse objectives. HUD’s criterion is strongly related to poverty and older housing occupied by low-income households and a number of other variables related to local poverty conditions such as education, crime, and racial segregation. These variables represent 80 percent of HUD’s overall index of need. This, I feel, represents a reasonable approach for distinguishing between high- and low-need communities. Other indicators included in HUD’s need criterion may be more questionable. For example, overcrowded housing, one of the elements in the current formula, may be more indicative of a strong local economy that reflects strong demand pressures in the local housing market rather than economic decline. In addition, low population densities and strong population growth, both reflected in HUD’s need criterion, may be more indicative of strong rather than weak economic conditions. However, to the extent that these indicators may be problematic, they represent a comparatively small part of the overall need criterion. Consequently, even if these factors were eliminated from the need index it is unlikely that they would affect their main conclusions to any significant degree. The HUD study reaches a number of valid conclusions regarding the targeting performance of the program’s funding formulas. I will just mention their conclusions to echo the more detailed analysis presented in the HUD report: The primary reasons entitlement communities with similar community development needs receive wide differences in funding are 1) using two formulas rather than a single formula and 2) the factor that reflects older housing in formula B results in especially large disparities in funding among communities with similar needs because units occupied by higher income residents typically are not in need of rehabilitation at public expense. Formula A is most responsible for reducing the extent to which funding is targeted to high-need communities, because its reliance on general population precludes greater targeting based on community development needs. Changing the poverty measure to one based on the poverty status of households rather than individuals would avoid awarding large grants to low-need college towns.