Recommendation: The Council should further clarify and document its roles and responsibilities with regard to USICH matters requiring the Council's approval, the role of the Council Chair, and actions within the Executive Director's delegated authority. (Recommendation 1)

Agency: United States Interagency Council on Homelessness
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: HUD's Office of Special Needs Assistance Programs should conduct quality assurance checks on the PIT count methodology data it requires CoCs to submit and take actions as appropriate to ensure that HUD's standards for conducting valid and reliable PIT counts are met. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: HUD's Office of Special Needs Assistance Programs should provide more detailed instructions on using probability sampling techniques to complete the PIT count, such as by updating its Point-in-Time Count Methodology Guide to instruct CoCs on reporting measures of error and bias in PIT count results. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: HUD's Office of Special Needs Assistance Programs should assess and enhance the usefulness of its assistance to CoCs' data collection efforts. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: VA's Under Secretary for Health should provide additional information, such as best practices, about how VA medical centers and service providers participating in Coordinated Entry can collaborate with local partners on key activities (for example, making referrals and sharing data) and ensure that this information and other resources are accessible to VA medical center staff and service providers. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Assistant Secretary for DOL's Veterans' Employment and Training Service should document its data quality validation processes for performance data for the Homeless Veterans' Reintegration Program and disseminate these processes to service providers. (Recommendation 2)

Agency: Department of Labor
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: VA's Under Secretary for Health should clearly communicate with local VA staff and service providers about how it measures performance and how to obtain and provide feedback about performance measures. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Education should develop an online clearinghouse of sample documents from states and localities who wish to share them, past webinar recordings and their related documents, and links to other relevant resources that all SEAs can access. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation. The agency said that its Office of Elementary and Secondary Education will restructure its entire website to better organize its information, and create a new web page to house all foster care-related information and resources. Additionally, Education said this office will launch a virtual portal through which SEA foster care points of contact may collaborate and share resources. We will consider closing this recommendation when these efforts are complete.

Recommendation: The Director of OHS should perform a fraud risk assessment for the Head Start program, to include assessing the likelihood and impact of fraud risks it faces. (Recommendation 1)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open
Priority recommendation

Comments: In February 2020, HHS told us that the Administration for Children and Families (ACF) is developing a Fraud Risk Assessment template for all of its programs (including the Office of Head Start) and is on track to complete the initial Fraud Risk Assessment for its pilot program by June 30, 2020. Upon completion of the Fraud Risk Assessment for the ACF pilot program, ACF anticipates completing its initial Fraud Risk Assessment for OHS, by March 31, 2021. We will assess these actions once completed.

Recommendation: The Director of OHS should establish procedures to monitor and evaluate OHS's new internal workflows for monitoring reviews, to include establishing a baseline to measure the effect of these workflows and identify and address any problems impeding the effective implementation of new workflows to ensure timeliness goals for monitoring reviews are met. (Recommendation 3)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: HHS did not concur with this recommendation. In February 2020, HHS stated that OHS regularly evaluates its effectiveness of its workflows to determine how to best adjust the system to support effective follow-up. HHS also stated that, for Fiscal Year 2020, OHS has updated its internal workflow timelines to increase responsiveness to identified findings and ensure grantee support. We will continue to monitor HHS's efforts in this area.

Recommendation: The Director of OHS should provide program-wide guidance on when a student's slot should be considered vacant due to absenteeism. (Recommendation 5)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: In February 2020, OHS told us that it is finalizing program guidance that will address when a child's slot should be considered vacant due to absenteeism and what a program should do fill it. OHS stated that it anticipates having a final paper published by summer, 2020. We will continue to monitor OHS's efforts in this area.

Recommendation: The Director of OHS should develop and implement a method for grantees to document attendance and services under EHS pregnancy programs. (Recommendation 6)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: In February 2020, OHS told us that it is developing a toolkit of resources specifically designed to offer best practice tips for Early Head Start programs on how to track attendance and services to pregnant women. OHS is surveying the Head Start community to better determine what resources are already available and how programs in different regions and cities track services to pregnant women. OHS anticipates a rollout for the toolkit by summer, 2020.

Recommendation: To ensure that the financial benefits of EULs that the Department of Veterans' Affairs reports in its annual Consideration Report on the EUL program are transparent and reliable, the Secretary should revise its Enhanced-Use Leasing Post Transaction Handbook (Handbook 7454) and specify that VA will: (1) Report consistently the enhanced services benefits from its EULs separately from other financial benefits that directly affect VA's budget, and (2) Include an explanation in its reporting on estimated EUL enhanced services that its estimates may not adequately capture all benefits of the EUL project and that certain costs associated with providing such benefits that are incurred by parties outside VA are not included in the analysis.

Agency: Department of Veterans Affairs
Status: Open

Comments: In August 2020, VA stated that the handbook was out for concurrences and received significant feedback/edits. VA is currently working through those edits and plans on submitting the revised version for internal concurrences in the next two weeks. VA said it will follow back up with GAO to provide a status on the handbooks approval and subsequent publishing

Recommendation: To help college financial aid administrators more effectively implement eligibility rules for unaccompanied homeless youth, the Secretary of Education should make available an optional worksheet or form that college financial aid administrators can voluntarily use to document unaccompanied homeless youth status or encourage the use of existing forms that are available.

Agency: Department of Education
Status: Open

Comments: Education agreed that it would be helpful to make forms developed by outside organizations knowledgeable about homelessness issues available for financial aid administrators to use for documenting the status of unaccompanied homeless youth. Education also said that it plans to highlight the availability of these forms and provide guidance at its annual conference and in updates to the Federal Student Aid Handbook. Education noted that it will not endorse the use of a specific form but that it will highlight forms that already exist that may be useful to financial aid administrators. In July 2020, Education reported that it planned to update the Federal Student Aid Handbook by the spring of 2021 to inform financial aid administrators about the availability of such forms that have been developed by outside entities. We will close this recommendation when Education provides GAO with the updated handbook.

Recommendation: To help determine the effectiveness of BRAC homeless assistance conveyances, the Secretaries of Housing and Urban Development and Defense should update the BRAC homeless assistance regulations to require that conveyance statuses be tracked. These regulatory updates could include requiring DOD to track and share disposal actions with HUD and requiring HUD to track the status following disposal, such as type of assistance received by providers and potential withdrawals by providers.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with the recommendation to update the BRAC homeless assistance regulations to require that conveyance statuses be tracked, which could include requiring DOD to track and share disposal actions with HUD and requiring HUD to track the status following disposal. In a December 2017 follow up, DOD stated that it plans to address our recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. DOD added that it will work closely with the military Departments and HUD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To help determine the effectiveness of BRAC homeless assistance conveyances, the Secretaries of Housing and Urban Development and Defense should update the BRAC homeless assistance regulations to require that conveyance statuses be tracked. These regulatory updates could include requiring DOD to track and share disposal actions with HUD and requiring HUD to track the status following disposal, such as type of assistance received by providers and potential withdrawals by providers.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations to require that conveyance statuses be tracked, which could include requiring DOD to track and share disposal actions with HUD and requiring HUD to track the status following disposal. HUD stated that it is willing to update the BRAC homeless assistance regulations to track the conveyances of property for homeless assistance, but noted that it will require DOD agreement to do so because the regulations are joint. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include specific guidance that clearly identifies the information that should be provided to homeless assistance providers during tours of on-base property, such as the condition of the property.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include specific guidance that clearly identifies the information that should be provided to homeless assistance providers during tours of on-base property, such as the condition of the property. DOD stated that while it already provides generic information about the property, the LRAs and interested homeless assistance providers can undertake facility assessments following the tours. However, DOD did not provide additional detail or explanation about how it would provide information about the condition of the property or access to it. In a December 2017 follow up, DOD stated that it plans to address our recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. DOD added that it will work closely with the military Departments and HUD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include specific guidance that clearly identifies the information that should be provided to homeless assistance providers during tours of on-base property, such as the condition of the property.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include specific guidance that clearly identifies the information that should be provided to homeless assistance providers during tours of on-base property, such as the condition of the property. HUD stated that it will update its BRAC guidebook, website, and presentations to provide clarifying information for homeless assistance providers regarding what information should be included during tours of on-base property. HUD also noted in its response that this will require DOD and military department agreement to implement and that the provision of information about the condition of on-base property and access to that property is under the purview of the military department. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include information for homeless assistance providers to use for preparing their notices of interest.

Agency: Department of Defense
Status: Open

Comments: DOD did not concur with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include information for homeless assistance providers to use in preparing their notices of interest. In its response, DOD stated that the existing regulatory guidance is adequate for providers' expressions of interest, given that these expressions evolve as the redevelopment planning effort proceeds and they learn more about the property. In a December 2017 follow up, DOD officials stated that they will not take action because they believe this is a community-driven action. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include information for homeless assistance providers to use for preparing their notices of interest.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include information for homeless assistance providers to use in preparing their notices of interest. HUD stated that it will update its BRAC guidebook, website, and presentations to provide clarifying information for homeless assistance providers to use in preparing their notices of interest. HUD also stated that it considered the current regulations and BRAC guidebook sufficient to inform providers as long as LRAs did not place additional requirements, which may create an undue burden for providers. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include guidance for legally binding agreements and clarification on the implications of unsigned agreements.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include guidance for legally binding agreements and clarification on the implications of unsigned agreements. DOD did not commit to taking any actions to provide this information and instead noted that any action should ensure that a legally binding agreement does not bind DOD to disposal actions it is unable to carry out. Nothing in the recommendation requires DOD to sign an agreement it cannot carry out. DOD further noted that the purpose of the legally binding agreement is to provide remedies and recourse for the LRA and provider in carrying out an accommodation following property disposal. In a December 2017 follow up, DOD stated that it plans to address our recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. DOD added that it will work closely with the military Departments and HUD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include guidance for legally binding agreements and clarification on the implications of unsigned agreements.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include guidance for legally binding agreements and clarification on the implications of unsigned agreements. HUD stated that it will update its BRAC guidebook, website, and presentations to provide clarifying information for homeless assistance providers to use in preparing legally binding agreements and on the implications of unsigned agreements. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include specific information on legal alternatives to providing on-base property, including acceptable alternative options such as financial assistance or off-base property in lieu of on-base property, information about rules of sale for on-base property conveyed to homeless assistance providers, and under what circumstances it is permissible to sell property for affordable housing alongside the no-cost homeless assistance conveyance.

Agency: Department of Defense
Status: Open

Comments: DOD did not concur with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include specific information on legal alternatives to providing on-base property, including acceptable alternative options such as financial assistance or off-base property in lieu of on-base property, information about rules of sale for on-base property conveyed to homeless assistance providers, and under what circumstances it is permissible to sell property for affordable housing alongside the no-cost homeless assistance conveyance. In its response, DOD stated that providers may only be considered through specific expressions of interest in surplus BRAC property, and these suggested alternatives may only be considered within the context of what is legally permissible given the specific circumstances at each installation. Further, DOD noted in its response that HUD may provide examples of alternatives to on-base property that have been approved to date as part of a local accommodation to offer examples for LRAs and providers. In a December 2017 follow up, DOD officials stated that they will not take action because they believe this is a community-driven action. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To assist homeless assistance providers and LRAs in completing the steps of the BRAC homeless assistance process within required time frames, to provide additional information to reduce unfulfilled expectations about the decisions made in executing the homeless assistance agreements, and to promote a greater dissemination of this information, the Secretaries of Housing and Urban Development and Defense, for each of the following four elements, should update the BRAC homeless assistance regulations; establish information-sharing mechanisms, such as a website or informational pamphlets; or develop templates to include specific information on legal alternatives to providing on-base property, including acceptable alternative options such as financial assistance or off-base property in lieu of on-base property, information about rules of sale for on-base property conveyed to homeless assistance providers, and under what circumstances it is permissible to sell property for affordable housing alongside the no-cost homeless assistance conveyance.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to update the BRAC homeless assistance regulations, establish information-sharing mechanisms, or develop templates to include specific information on legal alternatives to providing on-base property, including acceptable alternative options such as financial assistance or off-base property in lieu of on-base property, information about rules of sale for on-base property conveyed to homeless assistance providers, and under what circumstances it is permissible to sell property for affordable housing alongside the no-cost homeless assistance conveyance. HUD stated that it will update its BRAC guidebook, website, and presentations to clarify that the use of off-base property and financial assistance are acceptable alternate means of homeless assistance accommodation in base redevelopment plans and to include examples of alternatives to on-base property that have been approved to date. HUD also stated that this will require DOD and military department agreement to implement. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.

Recommendation: To help improve the timeliness of the HUD review process, the Secretary of Housing Urban Development should develop options to address the use of staff resources dedicated to the reviews of bases during a BRAC round, such as assigning temporary headquarters staff or utilizing current field HUD staff.

Agency: Department of Housing and Urban Development
Status: Open

Comments: HUD generally concurred with the recommendation to develop options to address the use of staff resources dedicated to the reviews of bases during a BRAC round, such as assigning temporary headquarters staff or utilizing current field HUD staff. HUD stated that it temporarily assigned headquarters staff and utilized field office staff during the 2005 round of BRAC. HUD also stated that, in the event of another BRAC round the size of 2005, it would encourage Congress to allocate funding for appropriate temporary staff resources to assist the department in meeting important timelines. In a March 2018 follow up, HUD stated it will address GAO recommendations regarding the BRAC homeless assistance process when Congress provides BRAC authorizing legislation. HUD added it would be premature to make any changes to current implementing policies or regulations which could be impacted by new BRAC authorizing legislation. HUD stated it will work closely with the military departments and DOD staff in the process of revising the implementing regulation. As of May 2019, Congress has not authorized another round of BRAC.