June 2012 — GAO's Comments on the Latest Round of Recipient Reporting

What GAO Found

To meet our mandate to comment on reports made by direct recipients of Recovery Act funding, we continued to monitor data that recipients reported from February 2009 through December 31, 2011. For this report, we focused our review on the quality of FTE data reported on FederalReporting.gov by PHAs, which were the prime recipients of the Public Housing Capital Fund formula and competitive grant programs, and HFAs, which were the prime recipients of TCAP. Following Office of Management and Budget guidance, recipients reported on FTEs directly paid for with Recovery Act funding and not the employment impact on suppliers of materials (indirect jobs) or on the local communities (induced jobs). In those circumstances where Recovery Act dollars are blended with funds from other sources, Office of Management and Budget also provided instructions on how to calculate FTEs. Recipients are generally required to file reports after each quarter until they complete expenditure of Recovery Act funds, are no longer counting FTEs, and have met all of HUD’s requirements.

According to information provided by HUD officials, the quality of jobs data submitted by HUD for the Public Housing Capital fund formula and competitive grants and TCAP has improved over time. Each quarter, HUD officials continue to perform quality assurance steps on the data that recipients submit to FederalReporting.gov to identify potential reporting errors, such as overcounts of FTEs, before the data are publicly posted on Recovery.gov . Officials also told us that their data quality reviews of recipient reports continued to include automated data checks to flag values in specific fields that were incorrect or that fell outside of parameters that HUD had defined as reasonable and to generate comments notifying housing agencies of the potential errors and work with them to make corrections. The HUD staff member responsible for assessing TCAP data quality did note that for TCAP recipient reporting differs from that for the Public Housing Capital Fund formula and competitive programs because the grant recipients (the HFAs) rely on information submitted to them by the grant subawardees (i.e., the project developers). According to the HUD TCAP reviewer, these grant recipients have to gather data and payroll information from each subawardee, and calculate the total number of FTEs. Assessment of TCAP data quality includes quarterly reviews of over 800 subawardee reports, each of which has a varying number of projects. According to HUD staff, the time period available for agency review before the data are posted on Recovery.gov was too short to fully review the sub-awardee reporting and some errors in reporting may not have been detected in time for correction.

Based on our analyses and interviews with agency officials, we determined that the recipient reported data appeared to be sufficiently reliable for the purpose of providing summary, descriptive information about FTEs and other information submitted on grantees’ recipient reports. HUD officials for the Recovery Act Public Housing Capital Fund grants also noted that their reporting rate for the tenth reporting period (from October 1, 2011 to December 31, 2011) was high and there have been no significant changes in data quality.

As shown in the figure below, the FTEs funded by the formula grant program and TCAP peaked in 2010. The number of funded FTEs by competitive grant peaked later, in 2011 because the Recovery Act required that nearly $1 billion in funds be awarded to PHAs based on a competitive for priority investments. Accordingly, HUD obligated the formula grants in March 2009 and the competitive grants in September 2009. Also, HUD was able to award the formula grants quickly using the formula that it typically uses to award Public Housing Capital Funds and PHAs generally selected projects that were already in their planning documents.

FTEs That Recipients Reported for Recovery Act Housing Funds, October 2009 through December 2011

Note: We did not include FTE data for the quarter ending September 2009 because of concerns about comparability with subsequent quarters of FTE reporting.

All of the PHAs responding to our question on quality procedures that they were able to describe procedures and controls that they had in place to help ensure the timely reporting, accuracy, and completeness of FTEs. For example, several PHAs reported that they had processes in place to help ensure that contractors and subcontractors were in compliance with reporting requirements in submitting data on hours worked. In addition, 6 of the 11 PHAs we interviewed specifically said that they used HUD’s “job calculator” to help calculate FTEs. HUD made this calculator available to PHAs during the first round of Recovery Act reporting and later updated it to conform with OMB guidance. To help ensure that housing agencies used the revised jobs calculator, we recommended that HUD tell housing agencies to discontinue using the outdated jobs calculator for subsequent rounds of reporting.

According to HUD officials, they were not aware of any plans that the agency has to use recipient-reported data internally. However, HUD converted a system it developed to track Recovery Act accomplishments—RAMPS—into a permanent system known as the Energy and Performance Information Center (EPIC) that it deployed in March 2012. This system would allow HUD to collect, aggregate, and report results of its capital investments made through the Public Housing Capital fund program and its two largest Native American programs. According to a HUD official, EPIC essentially replicates the key RAMPS function of collecting high-level information about Public Housing Capital Fund activity (for example, the numbers of units rehabilitated or developed with capital funds) and specific data about the installation of certain energy conservation measures. In addition, to leverage HUD’s investment in RAMPS, EPIC also carries over RAMPS infrastructure, such as login identification number and password, and system administration.

HUD officials recommended that any system similar to that implemented at FederalReporting.gov that is required in the future should be prepopulated with existing data from agency databases to reduce errors caused when recipients enter data. A HUD official estimated that HUD already collected much of the information that recipients entered into FederalReporting.gov. For example, HUD already tracks grant identification numbers and amounts of money awarded and disbursed in its Line of Credit Control System (LOCCS). He said that asking recipients to reenter data already tracked in HUD data systems resulted in many typographical errors that HUD then had to track and correct. Early on in the program, for instance, many PHAs entered incorrect grant identification numbers, putting in a “dash” before the last two numbers of the grant that signified the grant year. HUD officials made a great effort to correct these errors because, for the first several quarters, RATB could not cross check the recipient reported data with masters lists of Recovery Act awards provided by the agencies. HUD officials said that the system would have been more manageable if the fields had been prepopulated with data they had replaced or the number of parking lots it may have repaved.

What GAO DidBack to top

The recipient reporting section of this report responds to the Recovery Act’s mandate that GAO comment on the estimates of jobs created or retained by direct recipients of Recovery Act funds. For our review of the tenth submission of recipient reports which covers the period from October 1, 2011, through December 31, 2011, we built on findings from our nine prior reviews of these reports, which covered the period from February 2009 through September 31, 2011. To understand the quality of jobs data reported by housing program recipients, we compared the 10 quarters of recipient reporting data that were publicly available at Recovery.gov as of January 31, 2012; performed edit checks; and conducted other analyses on housing recipients’ reports for the Recovery Act. Our reliability assessment included interviewing HUD program officials and funding recipients and conducting logic tests for key variables. Our matches showed a high degree of agreement between HUD’s assessments of full-time equivalent (FTE) positions reported and our analyses of information recipients reported directly to FederalReporting.gov. In general, the recipient data used in this report appears to be sufficiently reliable for the purposes of providing summary descriptive information about FTEs or other information submitted on grantees’ recipient reports for the three housing programs—Public Housing Capital Fund formula and competitive grants, and TCAP.