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Interagency Council on Homelessness: Written Policies for Implementing Statutory Requirements Are Needed

GAO-22-105110 Published: Jun 23, 2022. Publicly Released: Jun 23, 2022.
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Fast Facts

The U.S. Interagency Council on Homelessness, which consists of a full-time staff and representatives from 19 federal agencies, coordinates federal efforts and partnerships to prevent and end homelessness.

We found that this agency didn't have documented policies and procedures to meet its statutory requirements—including those related to annually updating its strategic plan and communicating with Congress and other stakeholders.

We recommended that the agency develop written policies and procedures to help ensure it meets its statutory obligations.

Homeless encampment in downtown Miami, Florida

tents on a sidewalk in front of a chain link fence

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What GAO Found

The United States Interagency Council on Homelessness (USICH), which includes 19 federal agencies and its own full-time staff, coordinates the federal response to homelessness. In 2017–2021, activities USICH performed corresponded to duties and functions set forth in its governing statute. For example, as part of its duty to provide technical assistance to nonfederal entities, USICH provided written guidance and regional knowledge-sharing workshops. As part of its duty to recommend improvements in programs, USICH worked with the Departments of Veterans Affairs and Housing and Urban Development to increase voucher use for supportive housing (housing combined with other services, such as healthcare and job training and placement).

Homeless Encampment in Downtown Los Angeles, California

Homeless Encampment in Downtown Los Angeles, California

However, USICH did not have documented policies that specified how it would meet the statutory requirements GAO reviewed and did not consistently perform some obligations, such as annually updating its strategic plan. To monitor how the agency meets some statutory requirements, USICH staff use a spreadsheet (action plan) that briefly describes planned or completed activities. But USICH did not always update the plan or specify the steps staff should take to meet requirements. The plan also did not address some requirements, such as a reporting requirement in an annual appropriations act.

Staff also could not clearly describe if or how USICH met certain requirements in prior years. For example, USICH consulted with the Office of Management and Budget and congressional appropriations staff on meeting certain reporting obligations, but could not describe related decisions (prior staff had not documented them). Federal internal control standards note the importance of documenting responsibilities through written policies. USICH staff told GAO they relied on informal processes used by their predecessors, but said written documentation would be beneficial, especially when facing staff turnover. By developing and documenting policies and procedures for meeting statutory requirements, USICH could help ensure it consistently performs statutory obligations and furthers its mission to prevent and end homelessness. Doing so also could help USICH communicate timely information to other stakeholders, including Congress and federal, state, and local partners.

Why GAO Did This Study

The mission of USICH is to coordinate the federal response to homelessness and partner with the private sector and state and local governments to prevent and end homelessness. Under its governing statute, the McKinney-Vento Homeless Assistance Act, USICH must perform certain duties and functions, such as annually updating its national strategic plan to end homelessness, providing technical assistance to state and local governments and nonprofit organizations, and recommending improvements to programs that assist homeless individuals.

House Report No. 116-452 includes a provision for GAO to review USICH's policies and procedures to ensure compliance with certain statutory requirements.

This report addresses policies and procedures USICH used in fiscal years 2017–2021 to perform duties and functions under its governing statute and comply with certain appropriations requirements. GAO reviewed relevant statutes and agency documents (such as action plans, performance reports, and a charter) and interviewed senior USICH staff and agency representatives.


GAO is recommending that USICH establish written policies and procedures for meeting its statutory requirements. USICH concurred with the recommendation.

Recommendations for Executive Action

Agency Affected Recommendation Status
United States Interagency Council on Homelessness The Executive Director of USICH should establish written policies and procedures for meeting statutory requirements, including duties and functions in its governing statute and reporting obligations in annual appropriations acts, and for routinely updating and documenting the implementation of such policies and procedures. (Recommendation 1)
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

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Agency evaluationsFederal assistance programsHomelessnessHousingInteragency relationsNonprofit organizationsPolicies and proceduresStrategic planUrban developmentCompliance oversight