HUD’s Office of the Inspector General (OIG) issued an audit, “HUD’s Section Eight Management Assessment Program,” on March 6 indicating that HUD has an opportunity to improve the Section Eight Management Assessment Program (SEMAP), which is the process for evaluating public housing agencies’ (PHAs) use of Housing Choice Vouchers (HCVs). The OIG audit includes two basic findings: (1) the information PHAs reported in SEMAP may not have accurately represented their HCV performance, and (2) the process used by HUD’s Office of Public and Indian Housing (PIH) to verify PHAs’ SEMAP reporting did not effectively help PIH evaluate and identify aspects of PHAs’ HCV programs in need of improvement.
The OIG audit states that these conditions occurred because SEMAP uses performance indicators based on PHAs’ self‐certifications and self‐reported data. Without an effective performance measurement process, PIH lacked assurance that PHAs’ HCV programs met their intended objectives, which include helping the maximum number of eligible households obtain affordable and decent rental units at the correct subsidy cost. In addition, PIH may have missed opportunities to identify PHAs experiencing difficulties managing their HCV program.
In assessing a PHA’s performance, SEMAP uses 14 indicators and one bonus indicator. Each PHA’s overall SEMAP score is determined by dividing the PHA’s total points earned by a total of 150 possible points. PHAs with SEMAP scores of at least 90% are rated “high performers,” PHAs with scores between 60% and 89% are rated “standard performers,” and PHAs with scores less than 60% are rated “troubled performers.”
Of the 14 key indicators, seven are based on a PHA’s self‐certifications (e.g., Did the PHA ensure that landlords promptly corrected housing quality standards deficiencies?), and another seven indicators are based on information supplied by the PHA (e.g., the PHA’s HCV payment standard). For the seven self-certification indicators, a PHA certifies with a “yes” or “no” response, which can yield a maximum of 80 points – more than 50% of the 150 maximum points available. A PHA needs a score of 60% of the total possible points to be considered a standard performer.
For the seven indicators based on information provided by PHAs, a PHA can receive up to 70 points. PHAs maintain supporting documentation for these indicators, and PIH generally does not verify the accuracy of the data or whether the PHAs applied the information correctly.
OIG recommends that PIH improve SEMAP or develop a new performance measurement process that would identify PHAs with underperforming HCV programs. OIG also recommended PIH provide training and guidance to its program staff on SEMAP scoring, rating, and verification procedures such as confirmatory reviews and quality control reviews, along with any future adjustments to the current or revised SEMAP processes.
The OIG audit reported that in early 2022, PIH created a working group to revamp SEMAP with a focus on creating new indicators and enhancing existing indicators, with an emphasis on increasing “utilization.” (HCV utilization is a measure of how completely a PHA spends its annual HCV funding allocation.) In the fall of 2022, HUD held a series of eight listening sessions to present its proposed new framework for SEMAP and gather feedback on it from PHAs and other stakeholders. NLIHC and other policy advocates participated in one of those listening sessions. An additional listening session was held in February 2023 with tenant leaders, facilitated by NLIHC. PIH anticipates publishing proposed SEMAP changes by the end of calendar year 2023, with a final rule being released in late 2024.
Read the OIG audit, “HUD’s Section Eight Management Assessment Program,” at: https://bit.ly/3JzpwIh
The PIH SEMAP webpage is at: https://bit.ly/3yYElPD
Read more about Housing Choice Vouchers on page 4-1 of NLIHC’s 2023 Advocates’ Guide