Detailed Information on the
University Partnership Grants: Historically Black Colleges and Universities Assessment

Obtaining more accurate performance data.

Linking performance measures with budget request.

Requesting an independent program evaluation.

Establishing an adminstrative cost cap to ensure program efficiency.

Measure: Percentage of grantees that successfully implement 90 percent or more of their proposed housing and/or economic development activities within the grant's lifespan.

Explanation:This measure evaluates a grantee's ability to complete all proposed goals and objectives in a timely manner. Numbers for 2005 and 2006 are estimates, as the Logic Model - which underlies program reporting - was not yet implemented in its current state until 2004, meaning the 2007 cohort will be the first grant closeouts using the model.

Measure: Percentage of grantees that provide a comprehensive set of performance goals to improve program effectiveness, management, and accountability, in-line with HBCU program goals.

Explanation:The purpose of this measure is to ensure high standards of management and accountability, in support of the HBCU program's and HUD's strategic goals. An electronic performance management accountability system implemented in FY 2005 assists applicants in developing effective, quantifiable, outcome-oriented evaluation plans to measure their program's performance and determine if goals and objectives are achieved by the end of their grant performance period.

Measure: Percentage of HBCU grantees that leverage at least 15 percent or more of their total HBCU grant amount from other sources.

Explanation:This measure evaluates applicants' ability to secure resources, and develop and coordinate partnerships, increase program effectiveness, and become self-sustaining. The baseline years are considered estimates due to the nature of the data collected during those years.

Measure: Percentage of grants that are closed out within 90 days after the end of the grant performance period.

Explanation:This measure helps ensure that grant funds are utilized in a timely manner and that HUD is an effective steward of government resources. OUP hopes to attain a 10% annual increase in the percentage of timely close-outs.

Measure: Reduce the percentage of HBCU grant funds used for administrative expenses.

Explanation:By reducing the percentage of grant funds used for administrative expenses, HUD will ensure that a greater proportion of funds are directed to the program's target population in the community.

Is the program purpose clear?

Explanation: The purpose of HUD's Historically Black Colleges and Universities (HBCU) program is to expand the role and effectiveness of HBCUs in addressing community development needs in their localities. Eligible activities include neighborhood revitalization, housing assistance, and economic development, primarily benefiting persons of low-and moderate-income, consistent with Title I of the Housing and Community Development Act of 1974, as amended. All activities funded under this program must meet both Community Development Block Grant (CDBG) program eligibility requirements and at least one of the following three objectives: Benefit low- and moderate-income persons; Aid in the prevention or elimination of slums or blight; and/or Meet other community development needs having a particular urgency because existing conditions pose a serious and immediate threat to the health and welfare of the community and other financial resources are not available to meet such needs. In addition, 51% of the aggregated expenditures of the grant must specifically benefit low- and moderate-income persons.

Evidence: The purpose of the program is established under 24 CFR part 570.404, which is available at: http://a257.g.akamaitech.net/7/257/2422/10apr20061500/edocket.access.gpo.gov/cfr_2006/aprqtr/24cfr570.404.htm.; The program is implemented according to FY 2007 HBCU Notice of Funding Availability (NOFA) available at http://www.oup.org . The Funding section of the document also outlines the program's purpose.

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

Explanation: The HBCU program continues to address the need to increase homeownership, support community development provide access to affordable housing free from discrimination, neighborhood revitalization and economic development needs. The HBCU program provides a support system and a framework that motivates HBCUs and their communities to solve problems together, using unique and mutually determined methods. The program also addresses the Department's commitment to the President's Executive Order to increase Federal opportunities to HBCUs. In 1980, President Carter signed Executive Order 12232 to strengthen the capacity of historically black colleges and universities to provide the highest quality education, and to increase opportunities for these institutions to participate in and benefit from Federally-sponsored efforts. President Bush renewed the Federal government's commitment to HBCUs pursuant to Executive Order 13256 of February 12, 2002.

Evidence: HBCUs have longstanding historical ties to their communities and have taken aggressive steps to improve their neighborhoods and help local residents improve their lives. As illustrated by the Joint Center for Housing Studies of Harvard University, the HBCU program targets significant and ongoing problems: " In just the three years from 2001 to 2004, the number of households with severe cost burdens increased by nearly 2 million to a record 15.8 million. Nearly two-thirds of the increase in severe cost burdens fell on households with incomes below $22,540. In addition, deteriorating and/or abandoned housing, high-poverty neighborhoods are plagued by a number of social and economic problems, including high rates of unemployment, school dropouts and teen pregnancies." Joint Center for Housing Studies of Harvard University, The State of the Nation's Housing 2006, Housing Challenges, pg. 25-27, Joint Center for Housing Studies of Harvard University, 2006, available at http:// www.jchs.harvard.edu. The Presidents Executive Order 13256 of February 12, 2002 is available at http://www.ed.gov/about/inist/list/whhbcu/edlite-index.html.; Minority-Serving institutions developing partnerships to revitalize communities, Department of Housing and Urban Development, Minority-Serving Institutions of Higher Education: Developing Partnerships to Revitalize Communities., January 2003, Chapter 1, pg 2, available at http://www.oup.org/files/pubs/minority-report.pdf; HUD's mission located at http://www.hud.gov/library/bookshelf12/hudmission.cfm.

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

Explanation: While HBCU programs are established in other Federal agencies (such as the Department of Education) and have peers in other sectors, HUD's HBCU program is unique in its design, which provides assistance to HBCUs in support of the Department's goals: increase homeownership, support community development, and provide access to affordable housing free from discrimination. The program is also unique in its approach and methodology. The program permits HBCUs to address a broad set of housing and community needs by developing and implementing economic development activities, such as job training, micro-enterprises, etc., as well as bricks and mortar projects such as, but not limited to, acquisition of real property, clearance and demolition, and rehabilitation of residential structures. HBCUs can also provide assistance to community-based development organizations (CBDOs) to carry out CDBG neighborhood revitalization, community economic development, or energy conservation projects. In addition, HUD utilizes a competitive Notice of Funding Availability (NOFA) selection process that addresses the issue of providing funding for redundant or duplicative efforts. All applicants are required at the time of application submission to provide a statement ensuing that the activities they propose do not duplicate current or previously funded activities conducted by the institution or others in the proposed target area, unless they can demonstrate through documentation that there is a population in need that is not being served.

Evidence: FY 2007 HBCU Notice of Funding Availability (NOFA), pg. 11469, section C, Other, columns 1 and 2 provide examples of eligible activities and on page 11473, column 2, number 2, letter c describes the duplication criteria. The document is available at http://www.oup.org under the Funding section. HUD's mission is available at http://www.hud.gov/library/bookshelf12/mission.cf.

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

Explanation: No major design flaws have been identified that would limit the program's effectiveness or efficiency. The program's authorizing legislation strictly prescribes who is eligible to apply for this program and the types of activities that can be funded. The fact that there is no cap on the proportion of funds that can be used for administrative costs may lead to some instances of relatively high administrative spending, but there is little evidence that this has greatly impacted program effectiveness. Program administration, as defined under the CDBG regulations, involves not only the administrative costs but includes charges related to the planning and execution of community development activities, which is in line with the purpose of the program. However, it does not include staff and overhead cost directly related to carrying out project activities. Therefore, having this type of flexibility is imperative for the HBCU grantees under this type of program. The amount of the each grant awarded is small (applicants can not request more than $600,000 for a three year grant performance period); the grantees have sole responsibility for the implementation of their project; and the nature of the projects being proposed make this flexibility necessary. Unlike the CDBG entitlement program, the HBCU program is funded through a competitive process and all activities proposed are outlined in the application that is submitted for funding. Activities are described in detail with specific tasks and timelines for completion. In addition, OUP's peer review process and the HUD Reform Act of 1989 (which has stringent requirements) ensure that funding decisions are based upon the factors identified in the NOFA. Therefore, an application awarded funding under this program must be responsive to the requirements outlined in the Factors and receive a minimum score of 75 points to even be considered for funding. These strict requirements and guidelines would make it unlikely for an application that was 100% administrative to be funded. As issues and concerns occur, the NOFA process provides OUP with an opportunity to make sure that funds are awarded to HBCUs to address the specific needs of their targeted communities; that they propose activities that will positively impact those needs and have the capacity to be successful; and refine program policies and guidelines. The program also has in place strong management oversight procedures. All applicants awarded funding under this program are assigned a HUD Government Technical Representative (GTR). The GTR is responsible for the day-to-day administration of the grant, including monitoring grantee performance, ensuring program compliance, reviewing quarterly progress reports and providing technical assistance to improve program performance. The HBCU program also encourages IHE to link their activities to local Consolidated Plans, and to work with other HUD funded programs, such as Community Development Block Grant, and HOME. HBCU programs have leveraged resources from non-profit organizations, foundations, financial institutions, states and local governments, as well as other federal agencies.

Evidence: Program authorization, which can be found at 24 CFR part 570.404, accessible at: http://a257.g.akamaitech.net/7/257/2422/10apr20061500/edocket.access.gpo.gov/cfr 2006/aprqtr/24cfr570.404.htm.

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

Explanation: The HBCU program is designed such that program resources directly and effectively address community development needs in targeted communities through such activities as neighborhood revitalization, housing, and economic development principally for persons of low-and moderate-income. The program defines who is eligible to apply for this program and the types of activities that can be funded. The program NOFA also contains a clear description of the purpose of the program, the target audience and the type of activities that can be conducted. All activities funded under this program must meet both Community Development Block Grant (CDBG) program eligibility requirements and at least one of the following three national objectives: Benefit low- and moderate-income persons; Aid in the prevention or elimination of slums or blight; and/or Meet other community development needs having a particular urgency because existing conditions pose a serious and immediate threat to the health and welfare of the community and other financial resources are not available to meet such needs, and are therefore not subsidized. In addition, 51% of the aggregate grant expenditures must benefit low- and moderate-income persons.

Evidence: FY 2007 HBCU NOFA is available at http://www.oup.org under the Funding section, page 11468 Funding Opportunity Description outlines the purposed and the intended beneficiaries. The purpose is also consistent with the Title I of the Housing and Community Development Act of 1974, as amended; The purpose of the program is also provided under 24 CFR part 570.404, which can be accessed at: http://a257.g.akamaitech.net/7/257/2422/10apr20061500/edocket.access.gpo.gov/cfr2006/aprqtr/24cfr570.404.htm

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: Yes, the HBCU program has a limited number of long-term output performance measures: (1) by 2010, 98% of grantees will successfully implement 90% or more of their housing and/or economic development activities by the end of the grant performance period, and (2) by FY 2010, at least 90 percent of all grantees will provide a completed outcome-focused logic model report to measure program effectiveness, management, and accountability by the end of their grant performance period. In the case of the HBCU program, output measures alone are appropriate because of the diversity of the program's grantees (making outcome measures across the program difficult to formulate) and because the cost/resources required would be significant to adequately measure outcomes relative to the program's size. These performance measures are linked to the purpose of the program, which is to expand the roles and effectiveness of HBCUs in addressing community development needs in their localities, including neighborhood revitalization, housing, and economic development, principally for persons of low- and moderate-income, and to HUD's strategic goal -- Strengthening Communities and Embracing High Standards of Ethnics, Management and Accountability.

Evidence: FY 2005-2007 NOFAs are available at http://www.oup.org under the Funding section, see Rating Factor 5: Achieving Results and Programs Evaluation; Performance Measure Analysis Chart ; Annual Performance Plan Fiscal Year 2007, August 2006, pg 6 and 7, available at, HUD's website, http://www.hud.gov/offices/cfo/reporst/cforept.cfm.

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

Explanation: OUP has established ambitious targets and timeframes for the program's long-term output measures. The targets and timeframes were selected based on a review of program history (baseline data collected from grantees awarded in FY 2000-2003 and closed in FY 2005-2006) and because prior year performance suggest a need for grantee improvement: (1) by 2010, 98% of the grantees that close out annually will achieve 90% of their program's performance measures by the end of the grant performance period, and (2) by 2010, at least 90 percent of all applicants will provide a completed outcome-focused logic model by the end of the grant performance period. OUP will strengthen the goals as needed to sustain continuous improvement in program outcomes.

Evidence: Performance Measure Analysis Chart.

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: Yes, the HBCU program has annual goals that have a direct relationship to the program's long-term objective to expand the roles and effectiveness of HBCUs in addressing community development needs in their localities, including neighborhood revitalization, housing, and economic development, principally for persons of low- and moderate-income. The annual goals illustrate progress in the development of output measurement, output reporting, and program improvement needed to carry out the HBCU program. In the case of the HBCU program, output measures alone are appropriate because of the diversity of the program's grantees (making outcome measures across the program difficult to formulate) and because the cost/resources required would be significant to adequately measure grantees outcomes relative to the program's size. The output measures help illustrate improved grantee performance in terms of accomplishing grant objectives, improving reporting, and operating more efficiently.

Evidence: Quarterly progress reports; Performance Measure Analysis Chart.

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

Explanation: OUP has established baseline data collected from grantees awarded in FY 2000-2003 and closed in FY 2005-2006 for all annual performance measures. The targets are ambitious and reflect increasing expectations in terms of program effectiveness, accountability, and successful implemenation of program activities. All targets are tied to program history/prior year performance.

Evidence: FY 2005 -2007 HBCU NOFAs, which are available at http://www.oup.org; Proposals which provide information; Quarterly progress reports; HUD's FY 2006-2011 Strategic Plan; Performance Measure Analysis Chart.

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: All grantees are required to have signed letters of commitment, memoranda of understanding and/or agreements from all parties that will be involved with the project. The document must outline the roles and commitment of all partners to the grant. All documents are required to include the cash amount contributed or dollar value of the in-kind goods and/or services committed; a specific description of how the resources is to be used toward the proposed program activities; the date the resources will be made available and a statement that describes the duration of the contribution; any terms or conditions affecting the commitment, other than receipt of a HUD grant; and the signature of the appropriate executive officer authorized to commit the funds and/or goods and/or services. As part of the award process, each grantee signs a grant agreement that includes Terms and Conditions that specify the responsibilities of the grantee and their sub-grantees. This agreement commits the grantee to adhere to the goals and requirements of the program and also incorporates by reference their proposal, which outlines the involvement of all parties in the grant. The Logic Model is one of the core elements of the program's accountability framework, as it aligns each grantee's activities with objectives and performance goals. Each grantee has to report on its individual annual performance measures to demonstrate progress toward achieving the project's long-term goals. All grantees are required to submit quarterly progress reports that include a narrative section containing a description of the activities undertaken during the reporting period; significant accomplishments made during the reporting period; progress made toward the achievement of established goals and objectives; identification of any significant problems and their impact; corrective actions taken or planned; effect that such actions will have on the successful implementation/completion of the grant, as well as the logic model; and leveraged/match funds and/or in-kind services/contributions that were obtained in support of the recipient's project. On an annual basis, grantees are required to submit a logic model report that outlines progress toward achieving major tasks and project goals.

Evidence: FY 2007 HBCU NOFA is available at http://www.oup.org under the Funding section, page 11473 column 4, Rating Factor 4, Leveraging, outlines the responsibilities of the partners; Grant agreement is a legal contract between HUD and the grantee that outlines the requirements of the grant, including sub recipients.

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: At this time, an independent evaluation of sufficient scope and quality has not been completed. However, HUD's Office of Policy Development and Research, Program Evaluation Division has contracted with an independent evaluator, to conduct a study intended to describe the program, document its performance, and provides best practices that other HBCUs can emulate. This study examined HBCU records and selected eight for more detailed consideration. Because resources were limited, three HBCUs were selected for intense scrutiny and will be the subject of the in-depth case study analysis in the final report. Final results from this effort are expected in October 2007. OUP will request that the Office of Policy Development and Research include an evaluation of the effectiveness of the HBCU program in the FY'08 research agenda subject to the availability of funding, and other HUD priorities. The HBCU program will not be evaluated annually due to the size of the program. However, OUP will conduct periodically updates internally.

Evidence: Statement of Work for the Study of Historically Black Colleges and Universities Grant Program.

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: Although HUD's 2008 HBCU program request for funds and FTEs is specifically linked to HUD's strategic goal "Strengthening Communities" it is not tied specifically to the accomplishment of the HBCU program's annual and long-term performance goals. However, OUP does looks at the percentage of grantees that close out annually, the number of projects that achieve established goals and objectives, and national interest in the program, as evidenced by grantee application levels. In addition, the amount of funding requested for TA activities each year is linked to the need for the program to provide assistance that is demonstrated in the increase number of participants that attend training workshops. In the future budget requests will also be linked to performance measures.

Evidence: 2008 OMB Budget Justification for HBCU under PD&R's Research and Technology account includes the link to Strategic Goal C (Strengthening Communities). HUD's budget request for this program is linked to the program's goals and accomplishments. The amount of funding requested for TA activities each year is linked to the need for the program to provide assistance that is demonstrated in the increase number of participants that attend training workshops and the increase in the scores of applicants.

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

Explanation: The OUP uses information collected from a variety of sources that provide substantial feedback that is considered and used to implement improvements to the HBCU program. Examples of those sources are annual peer reviews meetings, annual conferences, program listservs, technical assistance workshops, quarterly grantee progress reports and reports from HUD Field Offices. These sources provide information that will increase program efficiency and effectiveness and are incorporated in the NOFA. The HBCU program is implemented through the NOFA that is published each fiscal year, and the policies governing its operation are contained therein. Therefore, modifications and enhancements can be made annually. In addition, OUP is finalizing the development of a new internal risk assessment tool to be used in assisting staff to prioritize program monitoring. This tool will be utilized with the FY'07 funding cycle of grantees (see document). In addition, in the FY'08 NOFA, HUD will require all applicants to report via the new electronic performance management accountability system, the Logic Model. This will be a requirement outlined in the NOFA. Currently applicants are utilizing the system to provide baseline data to develop individualized performance measures and determine if goals and objectives have been achieved by the end of their grant performance period. Grantees will also be required to provide information on the Return on Investments to assess the impact of the project on the targeted community being served. Applicants will report on their progress annually using the Logic Model.

Evidence: The risk assessment tool is used to assist staff to prioritize program monitoring.

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: Grantees are required to submit quarterly progress reports that reflect project activities undertaken during each reporting period through the life of the grant. This information is used by the Government Technical Representative (GTR) to mange the program and improve program performance. The GTR is the HUD official responsible for the day-to-day administration of the grant, including monitoring grantee performance, ensuring program compliance, reviewing progress reports and providing technical assistance to improve program performance. The GTR also utilizes periodic contacts to monitor grantee performance. To the extent travel funds are available, the GTR conducts on-site monitoring visits to review grantee performance, and compliance with program requirements, and to see the impact the project is having on the community.

Evidence: The quarterly progress report consists of a narrative and a financial section. The narrative section of the report contains a description of the activities undertaken during the reporting period; significant accomplishments made during the reporting period; progress made toward the achievement of established goals and objectives; identification of any significant problems and their impact; corrective actions taken or planned; and the effect that such actions will have on the successful implementation/completion of the project. In addition, the narrative addresses leveraged/match funds and/or in-kind services/contributions that were obtained in support of the recipient's project, as well as requests for any technical assistance required from HUD. The financial component of the report reflects costs incurred during the reporting period and cumulative costs (SF-269A, Financial Status Report).

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: Federal managers/GTRs are rated on performance based on proactive grant monitoring, creative problem solving, provision of technical assistance and knowledge of and adherence to departmental rules. GTRs monitor grantees to ensure compliance with all applicable program requirements. Federal managers/GTRs determine that all costs are allowable, allocable and reasonable in accordance with the principles outlined in applicable OMB Circulars. If HUD determines that costs are ineligible, they are disallowed and these costs are borne entirely by the grantee. All costs incurred by the grantee must be in conformance with the approved budget. Failure to comply with the requirements established in the grant agreement will result in the GTR taking appropriate corrective action(s), up to and including suspending or terminating the agreement for non-performance. In addition, when a previously funded applicant applies for a new grant their past performances is evaluated and scored. An applicant will lose up to five points as a result of poor performance on a previously awarded grant. Verification of past performance is validated from program and financial reports, monitoring reports, Logic Model submission and amendments. The deduction of points under the past performance rating section could cause the applicant not to be selected for award.

Evidence: Grantees submit quarterly progress reports consisting of a narrative and financial section. Grantees report costs for the reporting period cumulatively utilizing an SF-269A, Financial Status Report. HUD's employee performance appraisals; Terms and Conditions and the OMB circulars A-21 and A-110, which are available on OUP's website at http://oup.org/ta/ta_main.asp; SF-269A. The Program FY'07 NOFA, which is available at page 11472, column 3 under Rating Factor 1, Past Performance, discusses the deduction of points.

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

Explanation: Funds appropriated for the HBCU program are committed in a timely manner before the end of each fiscal year. Once applicants are selected for award they are formally notified in writing and the winners are published in the Federal Register, as required by the HUD Reform Act. Grants are awarded to IHEs and the winners are announced in late August when institutions are beginning the Fall session. The majority of the grants are obligated within three months of the award announcement. Once an applicant is selected for award, budgets are reviewed and negotiated to ensure project efficiencies and that the project will be implemented in a cost effective manner. Funds are then set up in HUD's Line of Credit Control System (LOCCS). The LOCCS system contains hard and soft financial controls and is used for fiscal management of HUD grants. The GTR monitors the Grantee's draw down of funds from HUD's LOCCS payment system and determines that all costs are allowable, allocable and reasonable in accordance with the cost principles, as outlined in OMB Circular A-21, and the purpose of the program outlined in the application. Costs and progress in implementing and achieving results are further monitored by the GTR. Grantees report costs for the reporting period and cumulatively each reporting period, utilizing the SF-269A, Financial Status Report.

Evidence: Each year in the Federal Register the announcement of the applicants selected for awards is published; OMB circulars A-21 is available on OUP's website at http://oup.org/ta/ta_main.asp; Terms and Conditions.

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: The HBCU program uses an administrative cost measure (as a percentage of total grant award) to track increased efficiency and effectiveness. Several processes and policies contribute to achieving efficiency goals. The competitive program is governed by policies and procedures outlined in the NOFA. Grants awarded under the NOFA are governed by the provisions set forth in 24 CFR 570.201 - 206 (Community Development Block Grants) 24 CFR part 84 (Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations), OMB Circulars A-21 (Cost Principles for Educational Institutions) and A-133 (Audits of States, Local Governments, and Non-Profit Organizations). The cost effectiveness of implementing a project is evaluated during the peer review process. OUP utilizes the panel review format. Once an applicant is selected for award, budgets are reviewed and negotiated to ensure project efficiencies and cost effectiveness. Costs and progress in implementing and achieving results are further reviewed by the GTR through the quarterly progress reports. OUP will also be utilizing the new electronic performance management accountability system, the Logic Model. The system provides baseline data to applicants and helps them develop effective, quantifiable, outcome oriented evaluation plans to measure performance and determine if goals and objectives have been achieved by the end of their grant performance period, as well as provide information on the Return on Investments to access the impact of the project on the targeted community being served. In addition, the program has a program efficiency measure that assists in ensuring that grant funds are utilized in a timely manner and that HUD is an effective steward of the government's resources. The measure looks at the percentage of grants that are closed out within 90 days after the end of the grant performance period.

Evidence: OMB Circular A-21, Terms and Conditions, OMB circulars are available on OUP's website at http://oup.org/ta/ta_main.asp ; Eligible activities outlined in 24 CFR 570.201 - 206; Risk Assessment Form.

Does the program collaborate and coordinate effectively with related programs?

Explanation: The HBCU program collaborates with and builds upon other HUD programs such as: the HOME Program; the Community Development Block Grant (CDBG) Program; and the HOPE VI Program. For example, the HOME Program offers benefits to Community Housing and Development Organizations (CHDOs). A number of HBCUs have become CHDOs and have received funding from the HOME program. Through collaboration with Housing Authorities in various cities, HBCUs have been able to obtain space for setting up computer labs and/or neighborhood network centers. In addition, partnerships developed with state and local governments have assisted HBCUs' to receive CDBG funding from these entities. The HBCU Program also collaborates with other Federal agencies such as the Corporation for Service Learning; Labor Department; Justice Department and Department of Health and Human Services through participation in conferences and workshops and the White House Initiative. At these events, information and technical assistance are provided on each agency's program and performance, which helps OUP to better serve the needs of the HBCUs. Training such as Grant Writing/Proposal Development helps grantees present better applications; Basic training on the rules and regulations of the CDBG Program assures that grantees apply for eligible activities and meet other applicable requirements of the CDBG Program; and Basic Housing and Economic Development Opportunities training assists grantees in undertaking community development and economic development projects. HBCU staff also attend monthly cluster meetings called by the White House Initiative/HBCUs in order to network and collaborate about agency programs as well as provide each agency with support, as appropriate to better implement their programs. In addition, HBCU program grantees collaborate with financial institutions; state and local governments; non-profit organizations and community organizations that have a similar interest in community development. Additionally, the HBCU Program collaborated with the Corporation for Service Learning to provide aid to victims of hurricanes Katrina and Rita. In 2005, a special grant program, Universities Rebuilding America Partnerships (URAP) Program was developed to award funds to HBCUs to assist in the hurricane-related rebuilding process.

Evidence: Grantee proposals; Close Out Reports, Porter, Michael Proter, A Joint Study by the Initiative for Competitive Inner City (CIC) and CEOs for Cities, Leveraging Colleges and Universities for Urban Economic Revitalization: Am Action Agenda, Initiative for a Competitive Inner City and CEOs for Cities, April 2002; FY 2005 Universities Rebuilding America Partnerships (URAP) Program NOFA, which is available at http://www.oup.org.

Does the program use strong financial management practices?

Explanation: OUP requires all grantees to comply with the provisions of 24 CFR part 84 (Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations), OMB Circulars A-21 (Cost Principles for Educational Institutions) and A-133 (Audits of States, Local Governments, and Non-Profit Organizations). Once grantees have been selected for award they receive the Assistance Award/Amendment (HUD-1044) form with accompanying terms and conditions and negotiated budget. Prior to award, HUD verifies the grantee's indirect rates and that the institution has a current audit on file. Each grant is assigned a GTR. The grant funds are set up in HUD's Line of Credit Control System (LOCCS). The LOCCS system is used for fiscal management of HUD grants. The GTR monitors the grantee's draw down of funds from LOCCS. Prior to approval of a LOCCS draw down, a determination is made that all costs are allowable, allocable and reasonable and in accordance with eligible program activities and the cost principles outlined in OMB Circular A-21. Grantees report costs for each reporting period and cumulatively utilizing an SF-269A, Financial Status Report. If a budget revision is required, upon approval, the GTR will issue an amendment to the grant agreement. In the event that the Grantee incurs costs in excess of the grant amount, all excess costs shall be borne entirely by the grantee. The grantee may not co-mingle any funds committed under this award with any other existing or future operating accounts held by the grantee. An institutional accounting system must ensure that HUD funds are not co-mingled. Funds specifically budgeted/received for one program may not be used to support another program. If the grantee fails to comply with the requirements established in the award and these provisions, including failure to submit reports on time and in accordance with the requirements contained in these provisions, the GTR will take action to reject a payment request and or/limit grantee's access to program funds. Actions by the GTR include, but are not limited to, requiring the submission of reports and financial statements to the GTR for approval prior to drawing down any funds; and/or suspending or terminating the agreement for non performance. Upon completion of the grant, the grantee submits the final narrative and financial report along with other required close out documentation and final Logic Model report.

Evidence: OMB circulars are available on OUP's website at http://oup.org/ta/ta_main.asp; Terms and Conditions; Grant agreements; FY 2007 HBCU NOFA available at http://www.oup.org.

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

Explanation: OUP utilizes information collected from a variety of sources to address internal management deficiencies. Examples of those sources are the annual peer review, annual conferences, program listserv, and reports submitted by grantees. For example, this year, OUP is finalizing the development of a new internal risk assessment tool that will be used to help staff prioritize program monitoring. This tool will be utilized with the FY07 funding cycle of grantees and will assist OUP in looking at its annual efficiency measure that addresses the percentage of grants that are closed out within 90 days after the end of the grant performance period. This measure assists in ensuring that grant funds are utilized in a timely manner and that HUD is an effective steward of the government resources. In addition, in the FY08 NOFA, HUD will require all applicants to report via the new electronic performance management accountability system, the Logic Model, on OUP's new established performance measures. This will be a requirement outlined in the NOFA. Currently applicants are utilizing the system to provide baseline data to develop individualized performance measures and determine if goals and objectives have been achieved by the end of their grant performance period. Grantees will also be required to provide information on the Return on Investments to access the impact of the project on the targeted community being served. Grantees will report on project progress annually.

Evidence: Quarterly progress report; Risk assessment tool.

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: Under this program, HUD competitively awards all grants to Historically Black Colleges and Universities that meet the definition of Historically Black Colleges and Universities as determined by the Department of Education in 34 CFR 608.2 in accordance with that Department's responsibilities under Executive Order 13256, dated February 12, 2002. Applicants must be institutions of higher education accredited by a national or regional accrediting agency recognized by the U.S. Department of Education. The program funding opportunity is announced each year through HUD's SuperNOFA. Awards under this program are not renewable; each grant is awarded for a three-year grant performance period. However, an applicant can reapply for another grant as long as they meet the requirements outlined in the NOFA. Each year, OUP conducts significant outreach to ensure new applicants each year. The HUD Reform Act of 1989 has stringent requirements ensuring the NOFA identifies factors for award and the basis upon which funding decisions will be made. OUP conducts two types of reviews, a threshold review and a technical review. All applications submitted for funding first undergo a threshold review to determine compliance with the threshold requirements defined in HUD's General Section of the NOFA and the specific program requirements. Applicants that meet those requirements are forwarded to the next level of review, the technical review. During the technical review, OUP utilizes the panel review format. The panel review format ensures that three individuals with diverse experience and knowledge review each application. The role of a peer reviewer is to evaluate proposals in accordance with the degree to which it is responsive to the Factors for Award published in the NOFA. After the peer review process, HUD funds applications in rank order until all available program funds are awarded. In order to be considered for funding, an applicant must receive a minimum score of 75 points. If two or more applications have the same number of points, the application with the most points for Factor 3, Soundness of Approach shall be selected. If there is still a tie, the application with the most points for Factor 1, Capacity of the Applicant and Relevant Organizational Experience, shall be selected. If there is still a tie, the application with the most points for Factor 2, 4 and then 5 shall be selected in that order until the tie is broken. HUD reserves the right to make selections out of rank order to provide for geographic distribution of grantees.

Evidence: FY 2007 NOFA (see Factor 3, see page 11473, column 1 ) and HUD's General Section are available on OUP website available at http://www.oup.org; OUP's Peer Review Handbook; HBCU Peer Review Program Evaluation Guide; HUD Reform Act of 1989.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: Once an applicant is selected for award, a written notification of award that includes the name of the GTR that will assist the grantee with program requirements and responsibilities during the life of the grant. The GTR is responsible for the technical administration of the grant, evaluation of performance under the grant, acceptance of technical reports to mange the program and improve performance. Grantees are required to submit quarterly progress reports that reflect progress toward accomplishing the project objectives and goals as stated in their application. The quarterly progress report consists of a narrative and financial section. The GTR also utilizes phone calls, and e-mail contacts to monitor grantee performance. The GTR also coordinates with HUD's Field Offices when possible to monitor program activities. The GTR uses program reporting data to assess risk and conduct on-site monitoring and technical assistance visits to the extent travel funds are available, review grantee performance and compliance with program requirements and see the impact the project is having on the community.

Evidence: Terms and Conditions; FY 2007 HBCU NOFA is available at http://www.oup.org; HUD's General Section of the 2007 SuperNOFA is available on the OUP website http://www.oup.org.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: Currently grantee performance data and information are not available to the public in a transparent manner through OUP's program website. However, annual announcements of funded applicants, grantee contact information, abstracts of what each program proposed, and other published documents such as newsletters and case studies that reflect individual grantee accomplishments are posted for easy access by the public. As the Logic Model improves the outcome information will be available. At which time, OUP will also make results data available to inform the public of grantee performance. Grantees are required to submit quarterly progress reports that reflect project activities undertaken during the reporting period. The quarterly progress report consists of a narrative and financial section. The narrative section of this report describes the activities undertaken during the reporting period; significant accomplishments made during the reporting period; progress made toward the achievement of established goals and objectives; identification of any significant problems and their impact; corrective actions taken or planned, and the impact that such actions will have on the successful implementation/completion of the grant. The financial component of the report reflects detailed costs incurred during the reporting period, and cumulatively (SF-269A, Financial Status Report).

Evidence: Quarterly progress reports; Terms and Conditions; OUP website http://www.oup.org .

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

Explanation: The program's long-term measures were developed utilizing baseline information collected from grantees awarded in FY 2000-2003 (this is a three-year grant program) and closed in FY 2005 and 2006. The program has not yet demonstrated progress in achieving its long-term measures, as these measures rely on newly-available performance data. Grants awarded in the baseline years did not utilize the logic model, meaning the completion of grantee goals is represented as an estimate.

Evidence: Performance Measure Analysis Chart

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

Explanation: There is some indication that the program is making progress in achieving its annual performance goals; evidence contained in closeout reports estimates improved performance. The innovative design of this program allows applicants to take unique and varied approaches to neighborhood revitalization customized to the community's particular needs. Therefore, each project's performance goals are individualized to demonstrate progress toward achieving its short- and long-term performance goals, which are then linked to the HBCU program's long-term performance measures. All grantees are required to have an approved project management plan that serves as the baseline against which the grantees' performance is measured. Grantees are required to submit quarterly progress reports that reflect project activities undertaken during the reporting period and the leveraged/resources funds and/or in-kind services/contributions that were obtained in support of the recipient's project. GTR's can use this information to assist grantees to measure and refine their annual performance goals, if warranted. Though HBCU's performance measures are new, the establishment of baseline targets and demonstrated improvement warrant some credit.

Evidence: FY 2005-2007 HBCU NOFAs, which are available at: http://www.oup.org; Quarterly progress reports; Performance Measure Analysis Chart.

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

Explanation: The HBCU program has established a quality efficiency measure but has yet to show progress toward the measure's goals due to the novelty of the measure and its associated performance goal. It is worth noting, however, that OUP has enhanced general program implementation, monitoring, and process efficiency using technology. For example, OUP has streamlined its program peer review process. All peer reviewers are now utilizing an electronic platform that allows applicants to receive substantial feedback on their applications in a timely manner. This process has reduced the man-hours required to conduct reviews. OUP has also increased the utilization of technology to provide information to all interested parties about activities, accomplishments and achievements of the program. The public can access the OUP website to find general information, as well as, specific program information, such as the name of institutions awarded funding in a particular year or particular state, and project description. The web provides information about funding opportunities. OUP publications are available via the website. Utilization of the website also allows the public to contact program representatives directly in a seamless manner to ask questions and/or make suggestions. In addition, in FY' 07, OUP is implementing a new procedure that will accelerate the obligation of funds. The new procedure will make funds available to all grantees by the end of each fiscal year, allowing access to grant funds more quickly to accomplish goals and objectives and thereby lead to more timely project closeouts. OUP grantees have also demonstrated a marked ability to leverage funds above and beyond the grant amounts, making the federal dollar go further. The efficiencies generated by these improvements, however, require improved data support, warranting partial credit.

Evidence: The OUP website http://www.oup.org provides general information, call for peer reviewers, publications, etc. Performance Measure Analysis Chart.

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

Explanation: There are other Federal, state, local, and private programs that have missions similar to that of the HBCU program. However, few - if any - of these peer programs collect data that is substantially comparable to HBCU's data, as the program's flexibility and scope make side-by-side evaluation difficult. Therefore, it is not reasonable to compare programs with distinctly different goals and objectives in the given time, and with reasonable cost.

Evidence: N/A

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

Explanation: To date, there has not been an evaluation of sufficient scope and quality conducted for the purpose of evaluating the HBCU program. In 2005, OUP commissioned an independent contractor, BCT Partners, Incorporated, to conduct a supplemental HBCU needs assessment of the program. The purpose of the assessment was to gain insight into specific factors that affect the ability of HBCUs to effectively obtain, implement, and manage HUD grants. Findings from the study recommended establishing a comprehensive technical assistance program, creating a system of ongoing evaluation, assembling an internal task force, and hiring an external consultant for guidance. As a result of that assessment, an evaluation of the HBCU program is currently underway. Data have been collected from eight sites. Of the eight reconnaissance sites, three sites were selected for in-depth case studies that are representative of the broad range of program activities that are being carried out. The final results are expected in October 2007.

Evidence: Statement of Work for the Study of Historically Black Colleges and Universities Grant Program.