Detailed Information on the
Bureau of Indian Affairs - Housing Improvement Assessment

Assess the feasibility of consolidating this program with HUD's program.

Develop measures of program effectiveness.

Measure: Percent of funding going to actual construction or repair of housing.

Explanation:

Measure: Percent of construction schedules met within the established project timeframe. (New measure, added August 2007)

Explanation:

Is the program purpose clear?

Explanation: The program provides housing to Indian families who have no other resources for housing. It is a grant program, and recipients are not expected to repay the Federal Government. While it is clear that families need a suitable living environment, it is not clear why recipients receive a house if they have no ability to repay some portion of the cost of construction, although the lack of rental properties may be a contributing factor.

Evidence: 25 CFR Part 256.3(a) states: "The BIA Housing Improvement Program policy is that every American family should have the opportunity for a decent home and suitable living environment.

Does the program address a specific and existing problem, interest, or need?

Explanation: There is a need for quality and affordable housing for Native Americans living on or near reservations due to poor economic opportunities, remote conditions and the lack of basic infrastructure.

Evidence: HIP Application Pool of qualified recipients. BIA could not provide statistics on the overall need in Indian Country.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: There is eligibility overlap with the HUD program. HUD allows the tribes to determine and address their low-income housing needs through a block grant program that must meet HUD's approval. Often the Tribe will require recipients to repay the cost of the housing provided. This allows the Tribe to keep the program self-financing. The BIA program serves as a safety net for the neediest of the needy who do not qualify for even minimum annual income requirements and are not expected to repay the Government. There is, however, nothing in the law or HUD's regulations that would prevent the Tribe for including these individuals under their HUD plans.

Evidence: Native American Housing Assistance and Self-Determination Act of 1996 (25 U.S.C. 4104)

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The HIP funds are distributed to the regions by formula which means that a recipient from one region may receive housing even though his/her score is below a recipient in another region. Therefore, the neediest may not be served due to geograpic location.

Evidence: Samples of fund distribution documents, forms, checklists, and instructions to the regions.

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: Despite concerns that this program is duplicative of the HUD program, recipients are ranked to ensure funds are distributed to only those Tribes that provide confirmation of eligible applicants, the category of assistance needed, the estimated project costs for each eligible applicant, and a report of prior year accomplishments. The BIA regional and/or agency housing staff verify individual HIP eligibility at the time of service through the established HIP funding methodology process each fiscal year.

Evidence: Evidence includes copies of HIP verification checklists completed by each regional/agency housing officer, specialist or coordinator that are performed prior to the completion of the regional plan. Samples of fund distribution documents, forms, checklists, flow charts and instructions that are included in the BIA HIP processing manual are included as evidence. Turndown letters from other housing programs are required to be eligible for HIP program services.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The Housing long-term goal ensures that the percentage of eligible Housing Improvement Program (HIP) applicants whose need for safe and sanitary housing in Indian Country is met.

Evidence: See Measures Tab

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: Measures are underdevelopment.

Evidence: OMB and BIA are still meeting to discuss.

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: Measures are underdevelopment.

Evidence: BIA and OMB staff are still negotiating on the measures.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: Targets and baselines have not been established.

Evidence: OMB and BIA are still meeting to discuss measures.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: The tribes actively solicit the applications of eligible individuals and help the individuals complete the application. Quarterly reporting of data is required for the Tribe and all tribal contracts are being modified to include GPRA reporting language. However, since performance measures are under-development, it is not possible at this time to determine if all the partners are working towards the goals.

Evidence: Tribal and Regional reports; GPRA reporting language

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: There are reviews, such as housing inspections as required under each individual contract/grant; however, there have been no independent evaluations by the IG, GAO, or other entity on the effectiveness of the program.

Evidence: No reports are available.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Budget requests specifically outline how many of the applicants will be served and how the program supports the Department's strategic objective of Serving Communities. The total FY 2004 overhead and/or administrative costs associated with the operation of this program was $2,433,000 of HIP funds to support the tribal administrative functions and $2,600,000 of Housing Development funds to support the BIA administrative functions. However, budget justifications do not reflect this information nor does the program report on indirect costs to the program, such as retirement benefits.

Evidence: Budget Justifications

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The program has identified specific items that will improve program management functions, such as the BIA housing processing manual to improve the administrative functions for both BIA and tribal housing staff. The ultimate goal is to establish bureau-wide program functions and standards that will maintain program consistency and integrity, which is now lacking at some regions. There has not been sufficient time to determine if these steps will correct deficiencies.

Evidence: Copy of the Director, BIA memorandum approving the housing manual that became effective on April 11, 2005, was provided for evidence.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The annual accomplishments report includes information on HIP recipients, tribal enrollment number of recipients, location of project, category of housing assistance provided, and overall cost of each project. The Government Performance and Results Act report is completed on a quarterly basis and identifies the number of newly constructed or renovated houses. Activity Based Costing (ABC) accounting specifying expenditures on major activities are reviewed and improvements are made. Reports are utilized as tools to identify and improve program challenges. However, the program has not collected baseline performance data necessary to set meaningful, ambitious performance targets.

Evidence: Annual Accomplishments Report 2004 GPRA Report ABC Report Fiscal Year Work Plans

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Each regional housng officer has GPRA measures incorporated into their individual performance standards and are held accountable for their performance. Tribal self-governance compacts and contracts are now being modified to include GPRA reporting language requirements.

Evidence: IPP of program managers; Standard GPRA reporting language. In addition, Housing staff verify individual HIP applicant eligibilitiy at time of service, review individual project work plans and perform on-site project inspections.

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: Carry over of funds is minimal. Funds are distributed to Tribes providing confirmation of eligible applicants, the category of assistance needed, the estimated project costs for each eligible applicant, and a report of prior year accomplishments. The BIA regional and/or agency housing staff verify individual HIP eligibility at time of service through the established HIP funding process each fiscal year. There are no indications that the funds are not been used for the intended purpose.

Evidence: Distribution documents for HIP.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: Cost efficiency procedures are included in the regulations and are routinely applied by housing officers. Sub-contracts are issued by a competitive bidding process to local contractors. The HIP Data Group has developed a Microsoft Access database to track program accomplishments and create standard forms for uniformity.

Evidence: HIP regulations Requests for bids Housing Access database report

Does the program collaborate and coordinate effectively with related programs?

Explanation: Establishment of water and septic capabilities prior to the construction of a house is the responsibility of the Indian Health Service, a bureau of the Department of Health and Human Services, through partnership with the HIP program. In addition, BIA works closely with Tribal Housing Authorities to ensure only eligible applicants receive funds.

Evidence: Copy of IHS Memorandum of Understanding.

Does the program use strong financial management practices?

Explanation: BIA has a material weakness for control over fund balances, and is in non-compliance with laws and regulations for the Single Audit Act and Federal Financial Management Improvement Act; however, there is no indication that the HIP program is not managed correctly.

Evidence: Annual Report on Performance and Accountability, FY 2004

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The program has had problems with management oversight and direction in the past and has begun efforts to improve. However, it is too early to determine if these steps have resulted in improvement. A handbook was approved on April 11, 2005. A training program is being provided by Housing Officers to tribal staff on program rules and regulations, as well as, project performance to improve the management of the program

Evidence: BIA Housing Processing Manual is included with the evidence. Copy of region's previously scheduled HIP workshops with agendas are included as evidence.

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The program continues to fulfill as many requests for repairs and new construction as possible with available funds.

Evidence: 2006 Performance Summary Table Goal Workshop documents

Does the program (including program partners) achieve its annual performance goals?

Explanation: Additional measures are being developed.

Evidence: OMB and BIA staff are still working on goals.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The program currently has a process outlined in the regulations that determines the cost efficiency for each individual job. In addition, the program is in the process of establishing an appropriate efficiency measure to track cost per square foot for housing projects. The variable to measure appropriate cost levels still needs to be worked out.

Evidence: Goals have not been established.

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: As pointed out in a previous response, the HIP and HUD programs are duplicative, but there is no evidence that the HIP program is not performing as well or better than any similar program at the state or local level.

Evidence: There is no concrete evidence to back up this claim; however, no reports exist to indicate that the program is not fulfilling its mission effectively.

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: There are currently no independent evaluations of the program.

Evidence: There have never been any IG or GAO reports performed on the program.