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United States Government Accountability Office: 
GAO: 

Report to the Committee on Homeland Security and Governmental Affairs, 
U.S. Senate: 

September 2014: 

Federal Real Property: 

More Useful Information to Providers Could Improve the Homeless 
Assistance Program: 

GAO-14-739: 

GAO Highlights: 

Highlights of GAO-14-739, a report to the Committee on Homeland 
Security and Governmental Affairs, U.S. Senate. 

Why GAO Did This Study: 

Title V of the McKinney-Vento Homeless Assistance Act enacted in 1987 
created a program to assist the homeless, in part, by identifying 
unused federal real property and making it available to homeless 
assistance providers. 

GAO was asked to review the implementation of Title V of the McKinney-
Vento Homeless Assistance Act. This report examines: (1) the 
identification and transfer of federal real property to homeless 
assistance providers and (2) the benefits and challenges homeless 
assistance providers and national advocacy organizations reported in 
identifying, acquiring, and using federal real property, and the 
potential actions that could help to address these challenges. GAO 
obtained information and data from HUD and the Department of Health 
and Human Services (HHS) on the properties reported since the 
program's inception and interviewed officials from GSA, HHS, and HUD. 
GAO also obtained views on the program from officials at (1) nine 
federal agencies, representing a range of size in their real property 
portfolios; (2) eleven homeless assistance providers (including eight 
that received property), representing a range of locations, size of 
property, and services provided; and (3) national homeless-advocacy 
organizations. 

What GAO Found: 

Since inception in 1987, the nationwide Title V homeless-assistance 
program has transferred 122 properties from federal agencies to 
homeless assistance providers. Of these properties, 81 are currently 
being used to provide a range of homeless assistance services 
nationwide. Such services include transitional housing, referral 
services, and emergency shelter. However, few of the properties that 
the Department of Housing and Urban Development (HUD) has listed as 
suitable and available since the program's inception received 
applications from homeless assistance providers. In most cases, the 
properties may not have actually been practical for homeless service 
providers to use. For example, in 2013 about 80 percent of these 
properties were for off-site use only—meaning that a provider would 
need to physically move the property in order to use it. HUD officials 
told us that they would prefer that agencies not be required to report 
certain types of properties at all, such as those for off-site use 
only. The current statutory requirement for agencies to report all 
properties that fall within four broad categories—excess, surplus, 
underutilized, and unutilized—may not be effective for certain types 
of properties. Such exclusion could allow HUD officials to focus on 
the suitable and available properties that may be more likely to 
assist the homeless. 

Of the 11 homeless assistance providers we interviewed, the eight case 
study providers that acquired property cited benefits from the Title V 
homeless assistance program, such as expanding services and obtaining 
real property at no cost. These benefits notwithstanding, the 
providers identified challenges, such as identifying available 
properties. These findings are consistent with reports from national 
homeless advocacy organizations. HUD reports properties in the Federal 
Register multiple times a year as required. The United States 
Interagency Council on Homelessness (USICH), which plays a 
coordination role, provides a link on its website to the HUD reports. 
Nonetheless, according to national homeless advocates, many homeless 
assistance providers remain unaware of the availability of properties 
because the Federal Register is not user-friendly. Further, HUD lists 
many of the same properties more than once in the Federal Register, as 
required, even though they may not be useful to homeless assistance 
providers. In the past, some in Congress and the executive branch have 
raised issues about reporting requirements; the basic issue has been 
that some requirements result in reports that may be burdensome to 
produce, or not very useful. Modifying reporting requirements to 
reduce the frequency of reporting related to properties that are less 
likely to be useful to homeless providers could help, while also 
allowing HUD to continue to fulfill its responsibilities. 

What GAO Recommends: 

Congress should consider changing (1) the scope of properties to be 
reported to HUD with respect to the types of properties that may be 
less likely to be useful to assist the homeless and (2) the frequency 
of Federal Register reporting. 

View [hyperlink, http://www.gao.gov/products/GAO-14-739]. For more 
information, contact David J.Wise at (202) 512-2834 or wised@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

122 Properties Transferred Have Provided a Range of Homeless 
Assistance Services, but Many Properties Reported and Deemed Suitable 
for Homeless Assistance May Not Be Useful for That Purpose: 

Homeless Assistance Providers Expanded Services, but Some Reported 
Encountering Challenges in Identifying, Applying for, and Using Real 
Property: 

Conclusion: 

Matter for Congressional Consideration: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I:Scope and Methodology: 

Appendix II:Sample Title V Checklist Submitted by Landholding Agencies 
to HUD: 

Appendix III:List of Landholding Agencies HUD Canvasses for Title V: 

Appendix IV:Services Provided at 81 Active Properties Transferred 
under Title V, by State: 

Appendix V:Eight Homeless Assistance Case-Study Properties: 

Appendix VI:Comments from the General Services Administration: 

Appendix VII:Comments from the Department of Health and Human Services: 

Appendix VIII:Comments from the U.S. Interagency Council on 
Homelessness: 

Appendix IX:GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Categories of Real Property That Landholding Agencies Must 
Report to the Department of Housing and Urban Development (HUD): 

Table 2: Types of Homeless Assistance Services Offered at the 81 
Active Properties, as of March 31, 2014: 

Table 3: Examples of Suitable and Available Properties in 2013 That 
May Not be Practical for Homeless Assistance Use: 

Table 4: Number of Properties HUD Reported Suitable and Available for 
"Off-site Use Only": 

Table 5: Department of Housing and Urban Development's (HUD) Federal 
Register Reporting Requirements: 

Table 6: Services Provided at 81 Active Properties Transferred under 
Title V, by State: 

Figures: 

Figure 1: The Title V Homeless Assistance Program Process: 

Figure 2: Geographic Distribution of 81 Currently Active Properties as 
of March 31, 2014: 

Figure 3: Estimated Number of Properties Potentially Available for 
Homeless Assistance Compared to the Total Number of Properties 
Transferred under the Title V Homeless Assistance Program, 1987-2014: 

Figure 4: Former Social Security Administration Building: 

Figure 5: Former Lowry Air Force Base Building: 

Figure 6: Former Homestead Air Force Base: 

Figure 7: Former U.S. Coast Guard Family-Housing Site: 

Figure 8: Former Social Security Administration Building: 

Figure 9: Former Sonstelie Hall Army Reserve Center: 

Figure 10: Former Naval Reserve Center: 

Figure 11: Former U.S. Coast Guard Housing: 

Abbreviations: 

ARCHA: Regional Coalition for Housing: 

BRAC: Base Realignment and Closure Act: 

DOD: Department of Defense: 

DOE: Department of Energy: 

DOI: Department of the Interior: 

EPA: Environmental Protection Agency: 

GSA: General Services Administration: 

HHS: Department of Health and Human Services: 

HUD: Department of Housing and Urban Development: 

LRA: local redevelopment authority: 

OMB: Office of Management and Budget: 

NLEC: New Life Evangelistic Center: 

OneCPD: Community Planning and Development Web site: 

USICH: U.S. Interagency Council on Homelessness: 

VA: Department of Veterans Affairs: 

VOALA: Volunteers of America of Los Angeles: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

September 30, 2014: 

The Honorable Thomas R. Carper: 
Chairman: 
The Honorable Tom Coburn, M.D. 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Estimates of the homeless population in the United States vary widely. 
According to the Department of Housing and Urban Development (HUD) 
610,042 people in the United States were homeless on a single night in 
January 2013, and more than a third of these people were living in 
unsheltered locations, such as under bridges, in cars, or in abandoned 
buildings.[Footnote 1] According to the National Law Center on 
Homelessness and Poverty, the numbers of Americans experiencing 
homelessness is estimated between 1.5 million to 3.5 million in a 
given year.[Footnote 2] At the same time, we have previously reported 
that federal agencies continue to hold thousands of unneeded and 
underutilized properties that annually cost the government over a 
billion dollars to operate.[Footnote 3] As a result of this and other 
long-standing problems, we have designated federal real property as a 
high-risk area.[Footnote 4] Title V of the McKinney-Vento Homeless 
Assistance Act (the Act), as amended, created a program to assist the 
homeless, in part, by using public resources and programs--including 
unused federal real property--in a more coordinated manner to meet the 
needs of homeless Americans.[Footnote 5] 

In general, Title V of the Act requires federal landholding agencies 
to identify and make available for homeless assistance real property 
under their control that they are not fully utilizing or no longer 
need before properties are disposed through other means. If a property 
is published by HUD as suitable and available, eligible applicants, 
such as homeless assistance providers and local governments, may apply 
to obtain the real property at no cost for the provision of a broad 
range of services for the homeless, including shelter, job training, 
and storage. 

However, implementing the Title V homeless assistance program 
requirements has presented challenges. Our prior work has found that 
legal and budgetary challenges continue to hamper agencies' disposal 
efforts. Since much of the unneeded federal real property may have no 
remaining useful life, may require extensive environmental 
remediation, may be located within secure compounds, or require off-
site removal, it, for example, may not be useful to assist the 
homeless.[Footnote 6] You asked us to determine how this program is 
performing both in terms of government operations and for homeless 
assistance providers. This report addresses two objectives: 

1. The identification and transfer of federal real properties for 
homeless assistance under the Title V homeless assistance program. 

2. The benefits and challenges homeless assistance providers and 
national advocacy organizations reported in identifying, acquiring, 
and using federal real property, and potential actions that could help 
address these challenges. 

To determine what is known about the identification and transfer of 
federal real properties for homeless assistance under Title V, we 
reviewed the requirements of Title V of the Act as they apply to the 
General Services Administration (GSA), the Department of Health and 
Human Services (HHS), HUD, and the U.S. Interagency Council on 
Homelessness (USICH). We obtained estimates from HUD of the number of 
underutilized, unutilized, excess, and surplus properties reported by 
landholding agencies and the number that HUD determined to be suitable 
and published as available for homeless use since the program's 
inception in 1987 through March 31, 2014--the date of the most 
recently available information. To assess the reliability of these 
estimates, we interviewed officials from HUD about how the estimates 
were derived and determined that the information provided by the 
agency provides a reasonable basis, with caveats, for reporting the 
number of properties that have been screened and found suitable and 
available. In addition, to determine the types of properties reported, 
we analyzed HUD's annual reports of suitable/available and 
suitable/unavailable properties for years 2008 through 2013. This time 
frame was selected to include the 5 years prior to this audit. When 
HUD's annual report for 2013 became available, we added it to the 
analysis to include the most recent information. From HHS, we also 
obtained documents and data on the number of notices of interest and 
applications it received for properties made available for homeless 
assistance from the program's inception in 1987 through March 31, 
2014. To assess the reliability of these data, we interviewed 
officials from HHS about how the data are collected and maintained, 
and the importance to the agency of ensuring the completeness of this 
data, and we determined that the data were sufficiently reliable for 
the purposes of our report. To understand how federal landholding 
agencies identify and report real property to HUD pursuant to the 
Act's requirements, we selected nine landholding agencies to include a 
range of size among real property portfolios of land and buildings, 
including GSA, HHS, the three Department of Defense service branches--
the U.S. Army, U.S. Air Force, and U.S. Navy--the Department of Energy 
(DOE), the Department of the Interior (DOI) and the Department of 
Veterans Affairs (VA),[Footnote 7] and the Environmental Protection 
Agency (EPA).[Footnote 8] We interviewed agency officials from GSA, 
HHS, HUD, and USICH to understand how they process properties reported 
under Title V homeless assistance program requirements. We also 
interviewed agency officials from the nine landholding agencies to 
obtain their views on how they meet the Act's requirements and their 
impact on each agency's disposal process. To determine the benefits 
and challenges that homeless assistance providers and national 
advocacy organizations report in identifying, acquiring, and using 
federal real property and potential actions that could help address 
those challenges, we selected eight homeless assistance organizations 
that acquired federal real property under the program based on 
criteria such as the size of the real property acquired under the 
program, the services provided, geographic distribution, range of 
experiences, and suggestions from agencies and homeless advocacy 
organizations. We interviewed representatives from each of the 
selected organizations, reviewed documentation, and conducted site 
visits to two properties transferred under the Title V homeless 
assistance program. We also convened a virtual discussion panel 
comprised of representatives from three homeless assistance 
organizations whose applications for federal real property were not 
approved and interviewed representatives from two national 
homelessness-advocacy organizations (see appendix 1 for more 
information on our scope and methodology).[Footnote 9] We conducted 
this performance audit from September 2013 to September 2014 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

The McKinney-Vento Homeless Assistance Act created over a dozen 
programs intended to comprehensively address the needs of homeless 
Americans. Among these, the Title V homeless assistance program 
requires federal landholding agencies to make available real property 
that they identify as excess, surplus, unutilized, or underutilized 
for possible use to assist the homeless. Title V of the Act designated 
GSA, HHS, and HUD to administer the program. In addition, Title II of 
the Act created what is now known as USICH, an independent 
establishment within the Executive Branch whose mission is to 
coordinate the federal response to homelessness. The mission of USICH 
is to create a national partnership to act as a coordinating body 
between the federal government and the private sector to end 
homelessness nationally. Title V specifies a number of steps that 
federal landholding agencies, the three federal agency administrators 
of the program, and USICH must take to make federal real property--
including land and buildings, or both--available for homeless 
assistance. Figure 1 summarizes key steps in the process and the time 
frames required to perform those steps. 

Figure 1: The Title V Homeless Assistance Program Process: 

[Refer to PDF for image: process illustration] 

HUD canvass: 
HUD: HUD requests information from landholding agencies[A] on 
underutilized, unutilized, excess, and surplus real property on a 
quarterly basis. 
Landholding agencies: Report excess properties to GSA and HUD. 
GSA: Prepares Title V checklists for excess properties and reports 
them to HUD. 
Maximum of 25 days. 

Suitability determination: 
HUD: Determines suitability and notifies each agency for which 30 days 
maximum; 
Landholding agencies: Notify HUD if property is presently available 
or, if not, prepare a statement explaining why it is unavailable; 
GS: Screens excess properties for other federal use. If none, 
determines property is surplus and reports to HUD; 
45 days maximum for Landholding agencies and GSA; 
Maximum of 75 days. 

Publication of properties: 
HUD publishes a list of all properties reviewed in the Federal 
Register. The list is divided into 3 categories: suitable/available, 
suitable/unavailable, and unsuitable. HUD also provides the same list 
to the U.S. Interagency Council on Homelessness; Maximum of 15 days. 

Holding period: 
Suitable/available properties are not available for any other purpose 
for 60 days beginning with the date of publication. (Unsuitable 
properties are not available for any other purpose for 20 days to 
allow for appeals.) 
60 days. 

Notice of interest and application: 
State and local government and eligible non-profit homeless assistance 
providers may submit a notice of interest to HHS for any suitable and 
available property. Once a notice is submitted, the provider has 90 
days to submit an application to HHS. HHS may grant extensions with 
concurrence of landholding agency. 
Maximum of 90 days. 

HHS review of application: 
HHS reviews submitted applications and determines if application 
satisfies criteria for transfer. If more than one application is 
received, HHS evaluates them in the order in which they were received. 
Maximum of 25 days[B]. 

Application approval and transfer of property: 
When an application is approved, HHS requests assignment from GSA and 
transfers the property to the applicant at no cost. If the transfer is 
a deed conveyance, the applicant is required to use the property for 
the purposes approved in the application for 30 years.[C] 

Source: GAO analysis of HUD, GSA, and HHS information. GAO-14-739. 

[A] HHS has a maximum of 25 days from the date a completed application 
is received to evaluate the application. 

[B] HHS has a maximum of 25 days from the date a completed application 
is received to evaluate the application. 

[C] HHS has a process by which the approved program of use may be 
changed as needed. 

[End of figure] 

HUD canvass: HUD surveys the landholding agencies that must identify 
and report to HUD on a quarterly basis real property that is excess, 
surplus, underutilized, or unutilized (see table 1).[Footnote 10] 

Table 1: Categories of Real Property That Landholding Agencies Must 
Report to the Department of Housing and Urban Development (HUD): 

Property category: Excess property; 
Description: Property that an agency has determined is not required to 
meet the agency's needs or responsibilities; 
Where defined: 42 U.S.C. § 11411(i)(2) which incorporates by reference 
40 U.S.C. § 102(3)). 

Property category: Surplus property; 
Description: An excess property that GSA has determined is not 
required to meet the needs or responsibilities of all federal agencies; 
Where defined: 42 U.S.C. § 1411(i)(2) which incorporates by reference 
40 U.S.C. § 102(10). 

Property category: Underutilized property; 
Description: Property used only irregularly, intermittently, or 
partially for current agency mission needs; 
Where defined: Implementing regulations promulgated by HUD, GSA, and 
HHS (24 C.F.R. § 581.1; 45 C.F.R. § 12a.1; 41 C.F.R. § 101-47.801). 

Property category: Unutilized property; 
Description: Property not occupied for current program purposes; 
Where defined: Implementing regulations promulgated by HUD, GSA, and 
HHS (24 C.F.R. § 581.1; 45 C.F.R. § 12a.1; 41 C.F.R. § 101-47.801). 

Source: GAO analysis. GAO-14-739. 

[End of table] 

Once landholding agencies (currently 25 in total) receive HUD's 
quarterly canvassing letter, they have 25 days to respond. To collect 
such information, HUD asks landholding agencies to complete a "Title V 
checklist" for each of the excess, surplus, underutilized, or 
unutilized properties that they have identified and are required to 
report.[Footnote 11] The checklist is a HUD document that requires the 
landholding agency to provide a variety of summary information about 
the real property, including its utilization status, accessibility 
(e.g., in a remote location or behind a secure perimeter), 
environmental condition, agency contacts, and other information (see 
app. II for an example of this checklist). 

Suitability determination: HUD assigns each reported real property a 
unique identification number and enters the checklist information into 
an electronic database. Based on the checklist, HUD must determine the 
suitability of each real property for homeless assistance. According 
to implementing regulations, all real property--land, buildings, or 
both--are suitable unless a property's characteristics include one or 
more of the following conditions: 

* national security concerns, meaning a property is located in an area 
where the general public is denied access in the interest of national 
security; 

* flammable or explosive materials within 2000 feet of the property; 

* located in an airport runway clear zone or military airfield clear 
zone; 

* located in a floodway; 

* documented deficiencies, meaning a property with a documented and 
extensive condition(s) that represents a clear threat to personal 
physical safety, including structural damage or certain types of 
environmental contamination; or: 

* inaccessible, meaning a property is not accessible by road.[Footnote 
12] 

After HUD makes a suitability determination, it is to provide this 
information to the reporting landholding agencies for review, as well 
as for the Federal Register listing that briefly describes the 
property's condition and status (e.g., underutilized, unutilized, 
excess, or surplus).[Footnote 13] Landholding agencies then have 45 
days to make any edits, as noted in figure 1, such as changes in the 
property's status. In addition, landholding agencies must transmit to 
HUD a statement of the availability of real property, declaring for 
example that a property is available for homeless assistance or 
explaining why a property cannot be made available for homeless 
assistance, such as in the case of a further compelling federal need 
for the property. 

HUD also communicates with GSA, the federal government's real-property 
disposal agent, to identify excess real properties that landholding 
agencies have reported to GSA for disposal. If, however, a landholding 
agency reports real property to GSA that has not been submitted to HUD 
for a Title V suitability determination, GSA is required to create a 
Title V checklist and forward it to HUD.[Footnote 14] 

Publication of properties and holding period: Title V requires HUD to 
publish in the Federal Register all properties it reviewed. HUD's 
Federal Register listings typically classify these properties as: 1) 
suitable and available for homeless assistance; 2) suitable but 
unavailable for homeless assistance; or 3) unsuitable for homeless 
assistance. Once published, homeless assistance providers--including 
state and local governments or eligible private non-profit 
organizations[Footnote 15]--have 60 days to submit a "notice of 
interest" for suitable and available properties, and then 90 days from 
the date of the "notice of interest," to submit an application to HHS. 
[Footnote 16] The real property is not available for any other purpose 
during the 60-day or 90-day period or during the period in which HHS 
reviews the application. Interested parties also have 20 days to 
challenge the suitability determination of real property HUD found 
unsuitable for homeless assistance. If a notice of interest is not 
filed for a suitable and available real property within 60 days of its 
listing in the Federal Register, the disposal agency may then proceed 
with its routine disposal process, in accordance with applicable law. 

In addition to publication in the Federal Register, the requirements 
of Title V require GSA, HHS, and HUD to make such efforts as are 
necessary to ensure the widest possible dissemination of the listing 
information of available properties. For example, HUD is required to 
forward lists of all real property published in the Federal Register 
to USICH, which then must distribute relevant portions of the list to 
state and regional homeless coordinators. Also, when HUD determines an 
excess real property is suitable and publishes it in the Federal 
Register as available, the implementing regulations require GSA to 
concurrently notify HHS, HUD, and state and local governments, in 
addition to homeless assistance providers that have expressed interest 
in the particular real property, and other organizations, as 
appropriate, concerning suitable properties.[Footnote 17] 

Notices of interest and application: HHS is to evaluate applications 
of homeless assistance providers on a first-come, first-serve basis 
using five criteria defined in HHS implementing regulations.[Footnote 
18] HHS may specify additional criteria for the application package 
for a given real property if it deems it necessary. The criteria are 
as follows: 

* Proposed service offering: the extent and range of proposed 
services, such as meal, shelter, job training, and counseling. 

* Need: the demand for the program and the degree to which the 
available real property will be fully utilized. 

* Implementation time: the amount of time necessary for the proposed 
program to become operational. 

* Experience: demonstrated prior success in operating similar programs 
and attestations by federal, state and local authorities. 

* Financial ability: the adequacy of funding that will likely be 
available to fully run the proposed program and operate the facility. 

HHS review of application, application approval, and transfer of 
property: HHS is to review applications for completeness and, in some 
cases, may request additional information from the applicant, as 
necessary. Evaluations must be completed in 25 days from the receipt 
of the completed application. 

If HHS approves an application for underutilized or unutilized real 
property, the landholding agency can execute a lease of the property 
to the applicant. In the case of surplus real property, the disposal 
agency "assigns" the property to HHS, which then becomes the 
sponsoring agency and transfers the deed to the applicant. Grantees of 
federal properties under the Title V homeless assistance program must 
utilize the property in accordance with the approved application for 
the length of the lease or, in the case of deed conveyances, for 30 
years. 

Pursuant to HHS policies and procedures, HHS is to perform compliance 
oversight and ensure that the grantee uses the real property according 
to the terms in the approved application. To accomplish this, grantees 
are required to submit annual utilization reports to HHS, and HHS is 
to conduct site visits of the properties at least once every 5 years. 
In the event that a grantee is not implementing or is unable to 
implement the program consistent with the approved application, the 
property title may revert back to the federal government.[Footnote 19] 

Title V of the Act has been amended several times, including by the 
Base Closure Community Redevelopment and Homeless Assistance Act of 
1994[Footnote 20] (the Redevelopment Act or Act). According to HUD, 
this Act aimed to improve the process for disposing buildings and 
property at military installations under the existing base closure 
laws. Under the Act, which became effective shortly after the 
beginning of fiscal year 1995, Department of Defense (DOD) properties 
disposed under the Defense Base Closure and Realignment Act of 1990 
[Footnote 21] were no longer subject to the Title V homeless 
assistance program requirements. According to HUD, many individuals 
involved in military base reuse concluded that Title V did not 
adequately address the multiple interests related to large parcels of 
surplus federal properties such as military bases. In general, with 
respect to the disposal of buildings and property located at 
installations approved for closure or realignment, the Redevelopment 
Act substituted a community-based process for the Title V homeless 
assistance program, in which the local redevelopment authority 
prepares a reuse plan after consulting with representatives of the 
homeless and other community groups affected by the base closure, and 
HUD ensures that the plan appropriately balances the needs of the 
community for economic and other development with the needs of the 
homeless.[Footnote 22] We excluded from this report facilities on 
military bases closed after 1994 and subject to the provisions of the 
Redevelopment Act, as we are reviewing implementations of the Act's 
provisions separately and plan to report on the results in 2015. 

Several court orders resulting from a 1988 lawsuit filed by the 
National Law Center on Homelessness and Poverty (National Law Center) 
and other advocates for the homeless have also shaped the 
implementation requirements of the Title V homeless assistance 
program. The 1988 lawsuit alleged, and the court found, that the 
federal government was not fully complying with some Title V 
requirements. The court issued an order in 1993 imposing requirements 
beyond those mandated by the statute and implementing regulations, 
such as more comprehensive reporting requirements and expanded 
outreach. Unlike the 1993 District Court order, a more recent 2013 
order does not require widespread changes to operational 
administration of the Title V homeless assistance program but rather 
seeks to better educate the landholding agencies about canvassing 
their real property and improving the quality of data reported by 
these agencies for Title V requirements and the Federal Real Property 
Profile.[Footnote 23] 

122 Properties Transferred Have Provided a Range of Homeless 
Assistance Services, but Many Properties Reported and Deemed Suitable 
for Homeless Assistance May Not Be Useful for That Purpose: 

Under the Title V homeless assistance program, providers have used 
over 100 transferred properties since program inception through March 
31, 2014, to deliver a range of services across the country. However, 
few of the properties that HUD has determined to be suitable and were 
available for homeless assistance since the program's inception 
received applications from homeless assistance service providers. In 
most cases, properties screened and determined as suitable and 
available may not have actually been practical for homeless service 
providers to use. For example, our analysis of HUD's annual reports 
from 2008 through 2013 found most of the properties published as 
suitable and available were for off-site use only--meaning that a 
provider would need to physically move the property in order to use it. 

Homeless Assistance Providers Currently Use 81 Title V Properties for 
a Range of Services across the Country: 

The Title V homeless assistance program has provided properties with 
useful facilities. As of March 2014, of the 122 properties transferred 
since the program's inception in 1987, 81 properties are currently in 
use by providers. For the other 41 properties, there are several 
explanations as to why they are no longer in use for homeless 
assistance. For example, leases for 9 properties were rescinded for 
failure to use the properties for the agreed upon purposes, and deeds 
for 8 properties reverted to the government for reasons such as non-
compliance or by request of the grantee. Across the country homeless 
assistance providers use the 81 properties to provide a range of 
homeless assistance services, such as supportive services, referral 
services, various forms of temporary or more permanent housing, 
administrative offices, and clothing or food distribution. The 81 
active properties include approximately 470 buildings of about 1.5-
million square feet and over 500 acres of land. The properties include 
a variety of facilities ranging in size from 1900 square feet to 
512,000 square feet and vacant land ranging from almost two tenths of 
an acre to over 96 acres. Of the 81 currently active properties, not-
for-profit organizations--such as the Salvation Army, Samaritan House, 
and Volunteers of America--acquired 69, and local governments acquired 
12. A few local governments formed public/not-for-profit 
collaborations to develop the properties. Figure 2 shows the 
geographic distribution of the properties. 

Figure 2: Geographic Distribution of 81 Currently Active Properties as 
of March 31, 2014: 

[See PDF for image: illustrated U.S. map] 

Alaska: 3; 
Arizona: 4; 
Arkansas: 4; 
California: 18; 
Colorado: 1; 
District of Columbia: 1; 
Florida: 1; 
Georgia: 1; 
Illinois: 2; 
Kansas: 1; 
Louisiana: 2; 
Maine: 3; 
Maryland: 3; 
Massachusetts: 3; 
Michigan: 2; 
Minnesota: 1; 
Missouri: 2; 
Montana: 2; 
Nebraska: 1; 
New Jersey: 2; 
New Mexico: 1; 
New York: 3; 
Pennsylvania: 3; 
South Carolina: 1; 
Texas: 6; 
Vermont: 1; 
Virginia: 3; 
Washington: 2; 
West Virginia: 2; 
Wyoming: 1. 

Source: GAO analysis of HHS data. GAO-14-739. 

Note: Red "bulls-eyes" represent the geographical location of Title V 
homeless assistance program properties. There may be more than one 
Title V homeless assistance program real property at a given location. 
For example, seven Title V homeless-assistance program properties are 
located at Fort Ord in Monterey, California. 

[End of figure] 

Providers at 60 of the 81 currently active properties offer multiple 
services to homeless individuals. For example, one provider said it 
offers support services such as substance abuse counseling, mental 
health services, case management, job training and placement. Another 
provides emergency, transitional, and permanent supportive housing; a 
health clinic; and daycare services. A third uses a former army depot 
to distribute goods and clothing (see table 2 for more information on 
the types of services provided and app. IV for more information on the 
services provided at each of the 81 locations). According to the 
National Law Center's 2011 estimate,[Footnote 24] more than 2.4 
million homeless Americans each year have received assistance through 
the Title V homeless assistance program since its inception. 

Table 2: Types of Homeless Assistance Services Offered at the 81 
Active Properties, as of March 31, 2014: 

Services offered[A]: Supportive services[B]; 
Number of Providers offering services: 43. 

Services offered[A]: Transitional housing[C]; 
Number of Providers offering services: 42. 

Services offered[A]: Referral services; 
Number of Providers offering services: 37. 

Services offered[A]: Emergency shelter[D]; 
Number of Providers offering services: 19. 

Services offered[A]: Permanent supportive housing[E]; 
Number of Providers offering services: 12. 

Services offered[A]: Administrative offices; 
Number of Providers offering services: 11. 

Services offered[A]: Goods/clothing distribution; 
Number of Providers offering services: 8. 

Services offered[A]: Education/job training; 
Number of Providers offering services: 6. 

Services offered[A]: Daycare/day center; 
Number of Providers offering services: 5. 

Services offered[A]: Food distribution; 
Number of Providers offering services: 2. 

Services offered[A]: Mental Health; 
Number of Providers offering services: 2. 

Services offered[A]: Warehouse and storage; 
Number of Providers offering services: 2. 

Services offered[A]: Case management; 
Number of Providers offering services: 1. 

Source: GAO analysis of HHS information. GAO -14-739. 

[A] Many service providers offer multiple services at the same 
location based on HHS data. For example, 26 of the 81 service 
providers offer three different types of services. 

[B] Supportive services is a broad category that may include services 
such as child care; employment assistance; employment counseling; 
outreach, advocacy, life skills training, and housing search, and 
counseling services; outpatient health services; trauma counseling and 
victim services. 

[C] Transitional housing is designed to provide housing and 
appropriate supportive services to homeless persons to facilitate 
movement to independent living within 24 months, or a longer period as 
approved by HUD. 

[D] Emergency shelter is any facility with overnight sleeping 
accommodations, to provide temporary shelter for the homeless. 

[E] Permanent supportive housing is long-term, affordable, community-
based housing that is linked to appropriate supportive health and 
social services (e.g., substance abuse, mental health, case 
management, medical care services, and services for the disabled and 
frail elderly) that enable homeless individuals and homeless families 
with disabilities to maintain housing. There is no time limit to 
residency, provided a tenant meets the conditions of occupancy as 
established by the program. 

[End of table] 

Few Properties Deemed Suitable and Available for Homeless Assistance 
Were of Interest or Received Applications from Service Providers: 

Of the at least 10,000 properties determined to be suitable and 
available, approximately 1,200 properties received notices of 
interest, and we estimate that fewer than 400 properties received 
applications from homeless assistance providers, resulting in the 
transfer of 122 properties to assist the homeless in the 26 years 
since Title V's inception through March 2014 (see figure 3). 

Figure 3: Estimated Number of Properties Potentially Available for 
Homeless Assistance Compared to the Total Number of Properties 
Transferred under the Title V Homeless Assistance Program, 1987-2014: 

[Refer to PDF for image: illustration] 

Excess, surplus, underutilized, unutilized properties reported to HUD: 
Number since inception of program in 1987: unknown; at least 40,000 
properties since the early 1990's. 

Suitable and available properties for homeless assistance purposes: 
Number since inception: unknown; at least 10,000 properties since the 
early 1990's. 

Notices of Interest in properties submitted to HHS: 
2,533 notices regarding approximately 1,200 properties since inception. 

Applications submitted to HHS: 
489 applications regarding approximately less than 400 properties 
since inception. 

Transfer via deed/lease for homeless use: 
122 transfers since inception; 81 still being used by homeless
assistance providers. 

Source: GAO analysis of information from HUD officials and HHS data. 
GAO-14-739. 

[End of figure] 

According to HHS data, since the inception of the program in 1987, 
most properties deemed by HUD to be suitable and which are available 
for homeless assistance have not received notices of interest or 
applications from homeless service providers. In addition, we found 
that in many cases, suitable and available properties may not have 
been practical for homeless service providers to use. Our analysis of 
HUD's 2013 annual report published in the Federal Register found 630 
properties published as suitable and available including buildings 
ranging from a 12 square foot storage shed to a 75,720 square foot 
building in a restricted area, and vacant land ranging from about one 
hundredth of an acre to over 15 acres. These properties may be 
inconveniently located at a distance from existing communities or 
public transportation, within a military installation, or in poor 
condition--conditions consistent with what we found in our prior work 
(see table 3).[Footnote 25] 

Table 3: Examples of Suitable and Available Properties in 2013 That 
May Not be Practical for Homeless Assistance Use: 

Location: Dublin, CA; 
HUD Description of Property: Building, off-site use only: 30 square 
feet; control tower; poor conditions; restricted area; transferee must 
obtain real estate doc. to access/remove; contact Army for more 
information. 

Location: West Sacramento, CA; 
HUD Description of Property: Building: 3,840 square feet; 9 months 
vacant; poor conditions; restricted area; transferee will need an 
escort to access property. 

Location: St. George Island, FL; 
HUD Description of Property: Land: 0.34 acres; tower & fence needs to 
be removed; remote access; contact Air Force for more information. 

Location: Ft. Benning, GA; 
HUD Description of Property: Building, off-site removal only; 192 
square feet; Sep Toil/Shower; poor conditions; secured area; contact 
Army for info. on accessibility/removal. 

Location: Hawaii National Park, HI; 
HUD Description of Property: Building, off-site removal only; 100 
square feet; pollutant catch basin; poor conditions. 

Location: Wahiawa, HI; 
HUD Description of Property: Building, off-site use only: 512 square 
feet; storage; 46 yrs.-old; poor conditions. 

Location: Johnston, IA; 
HUD Description of Property: Building, remote/secured area: 3,076 
square feet; family housing; 816+months vacant; deteriorated; 
escort required; contact Army for accessibility requirements. 

Location: Mystic, IA; 
HUD Description of Property: Building, off-site removal only; 80 
square foot storage shed; one plus months vacant; deteriorated. 

Location: Ft. Riley, KS; 
HUD Description of Property: Building, off-site removal only; 128 
square feet; latrine; deteriorating conditions; located on controlled 
area; contact Army for more information. 

Location: Indian Head, MD; 
HUD Description of Property: Building, off-site use only: 480 square 
feet; chemical plant 20+yrs. vacant; contaminated; major renovations 
required for other use. 

Location: Smithville, MO; 
HUD Description of Property: Building, off-site use only: 100 square 
feet; toilet need extensive repairs. 

Location: Lawton, OK; 
HUD Description of Property: Building, off-site use only: 24,072 
square feet concrete block/w brick. 

Location: Stigler, OK; 
HUD Description of Property: Building, off-site removal only; 
24 square feet water well; poor conditions. 

Location: Valliant, OK; 
HUD Description of Property: Building, off-site removal only; 12 
square feet; storage; flammable materials; poor conditions. 

Location: Charleston, SC; 
HUD Description of Property: Land: 5.59 acres; contamination; 
contact Navy for more information. 

Location: Purdon, TX; 
HUD Description of Property: Building, off-site use only: 624 square 
feet; 30+ years; restroom. 

Source: GAO analysis of HUD's 2013 Title V Annual Report. GAO-14-739. 

[End of table] 

As noted above, HUD is required to evaluate the properties and applies 
criteria that are defined in implementing regulations. A landholding 
agency may indicate on the Title V checklist, for example, that a 
property has extensive deterioration, but according to HUD officials, 
if the landholding agency does not provide supporting documentation, 
HUD may deem the property suitable for homeless assistance. As a 
result, HUD designates many properties as suitable with deficiencies 
that may therefore make them less desirable to homeless assistance 
providers. The suitability criteria in HUD's regulation for 
implementing the Title V homeless assistance program include 
provisions for excluding properties with deficiencies such as 
contamination, structural damage or extensive deterioration that are 
documented, extensive, and considered by HUD as representing a clear 
threat to personal safety. For example, while HUD did not determine 
conditions to rise to the level of a "documented deficiency," our 
analysis of the 630 suitable and available properties reported in the 
HUD's 2013 annual report found properties with conditions described as 
"deteriorated" (35 properties) and in "very poor condition" (18 
properties). 

Moreover, almost 80 percent of the properties published as suitable 
and available in 2013 were for "off-site use only." These properties 
refer to buildings and other removable structures that are located on 
land that is not surplus and, therefore, must be removed and 
relocated. According to officials from the National Law Center, the 
costs of moving the building, preparing the land on which to relocate 
the building, and making improvements needed to convert the building 
to provide services are often beyond the budget of the homeless-
assistance service providers. 

Officials from four of our nine selected landholding agencies told us 
they believe that properties for off-site use only are not practical 
for homeless assistance services. In addition, although an HHS 
official with responsibility for the Title V program told us that four 
of the 122 properties transferred under the Title V homeless 
assistance program were made available for off-site use only, these 
properties were trailers, which are designed to be easily moved, as 
opposed to other types of off-site properties described below, which 
may not be easy to move. For 2013, the most recent year reported, of 
the 630 properties HUD listed as suitable and available in the annual 
report, 78 percent were for "off-site use only" (see table 4). 

Table 4: Number of Properties HUD Reported Suitable and Available for 
"Off-site Use Only": 

Year of reporting: 2013 only; 
Total number of properties reported to HUD: 766; 
Number of properties that were "Suitable/Available": 630; 
Percentage of total that were "Suitable/Available": 82%; 
"Suitable/Available" properties that were for "off-site use only": 489; 
Percentage of "Suitable/Available" properties that were for "off-site 
use only": 78%. 

Year of reporting: 2008 - 2013[A]; 
Total number of properties reported to HUD: 1,677; 
Number of properties that were "Suitable/Available": 1,102; 
Percentage of total that were "Suitable/Available": 66%; 
"Suitable/Available" properties that were for "off-site use only": 859; 
Percentage of "Suitable/Available" properties that were for "off-site 
use only": 78%. 

Source: GAO Analysis of HUD 2008-2013 Annual Reports published in the 
Federal Register. GAO-14-739. 

[A] Our analysis of HUD's annual reports published in the Federal 
Register for calendar years 2008 through 2013 identified 1,677 
properties reported over the six years, of which 982 (59 percent) 
appeared in more than one annual report and 288 (17 percent) appeared 
in each of the six annual reports. 

[End of table] 

Since the majority of properties reported as suitable and available in 
2013 were for off-site use only, as a result, they may be impractical 
for homeless assistance. For example, according to U.S. Army 
officials, since most of the Army's properties reported under Title V 
are located on secured installations and do not involve the transfer 
of land, these properties are often made available to homeless 
assistance providers for "off-site use only." In addition, because 
most buildings in the Army's inventory consist of masonry and steel, 
the removal of these properties is costly. As a result, U.S. Army 
officials said that very few homeless assistance providers have 
expressed interest in Army properties designated for "off-site use" 
since the program's inception.[Footnote 26] Similarly, DOI officials 
told us that because the agency does not relinquish federal park 
lands, the buildings published as suitable and available located 
within federal parks are also designated for "off-site use only." Many 
federal park lands are in remote areas, and moving a building from 
those locations can be costly. 

USICH's 2011 agency annual report stated that, because of the wide 
latitude in the suitability standard, a clear majority of the 
properties HUD finds "suitable" are not actually practical for 
homeless assistance.[Footnote 27] As noted above, HUD considers all 
property suitable for homeless assistance unless a property's 
characteristics meet one or more of six conditions, such as national 
security concerns or location in a floodway. The relatively large 
numbers of properties deemed by HUD to be suitable and that were 
available may give homeless assistance providers, the public, and 
other stakeholders a false impression as to what properties are of 
practical use for homeless assistance because they included a large 
proportion of properties that have substantial deficiencies. In turn, 
this may mislead stakeholders about the extent to which the federal 
government is providing federal real property for homeless assistance. 

An additional concern with HUD's Title V data lies in the limitations 
of its Title V database that HUD uses to store information on 
properties reported by landholding agencies and report them to the 
public. According to HUD officials, the agency has screened at least 
40,000 properties since the early 1990s, of which at least 10,000 (at 
least 24 percent) were determined to be suitable and were available 
for homeless use (see figure 3). These estimates are based on HUD's 
Title V database, which was developed in the early 1990s, and 
maintains data on the properties reported to HUD by landholding 
agencies and HUD's suitability determinations.[Footnote 28] However, 
HUD's database does not have the capability to generate reports on 
properties or data for the purpose of analyzing the properties 
reported for the Title V homeless assistance program. For example, 
when we asked HUD for reports from the database in order to perform 
our own analysis, such as the total number of properties reviewed for 
suitability and the total number published as suitable and available 
since program inception, the agency was unable to provide these data 
to us. The database was designed, and is primarily used, to generate 
listings of properties for publication in the Federal Register. The 
PDF format of the Federal Register reports poses challenges for 
automated analysis, and as a result, we had to manually count numbers 
of properties in specific categories to ensure the validity of our 
analysis, such as those for off-site use only reported in table 4. 
Standards for Internal Control in the Federal Government states that 
managers are responsible for providing reliable, useful, and timely 
information for transparency and accountability of programs and their 
operations.[Footnote 29] Reliability also means that for any computer 
processing of the data elements used, the results are reasonable, 
complete, and accurate. In addition, federal information technology 
guidance for publicly available data states that accessible data 
should be made available in convenient, modifiable formats that can be 
retrieved, downloaded, indexed, and searched.[Footnote 30] As the 
database cannot produce reports on the properties, HUD relies on hard-
copy record keeping, which limits HUD's ability to make information on 
properties readily available, requiring labor intensive use of 
resources to find needed data. This capability is important because 
Title V requires HUD to make available to the public upon request all 
information in its possession about all properties reviewed and not 
identified as suitable for the homeless--about 30,000 properties 
according to HUD's estimate--including the reasons such properties 
were not so identified.[Footnote 31] Moreover, HUD officials told us 
that during the recent litigation, the plaintiffs hired a contractor 
to make copies of the requested data from HUD's hard copy files, and 
it took three individuals several weeks to complete the task. Without 
a comprehensive database that maintains this information, HUD would 
need to respond to such a request on up to 30,000 properties by 
manually looking through files, which would not be an efficient use of 
resources. Because HUD uses the database primarily for generating 
listings, it has not assessed the extent to which the benefits of 
modifying the database to generate electronic reports for the purposes 
of responding to information requests or performing analysis, or if 
developing a new database to do so would outweigh the costs. Modifying 
its database, or developing a new one that is electronically 
searchable, would better position HUD to respond to information 
requests. 

Landholding Agencies Report Many Properties That May Not Be Useful to 
Assist the Homeless, and Do Not Report Some Properties: 

While it is HUD's role to assess the suitability of properties for use 
to assist the homeless, some federal landholding agencies report many 
properties to HUD that may not, in the landholding agencies' 
estimation, be useful to assist the homeless. However, a few 
landholding agencies' officials told us that they do not report such 
properties or other surplus, underutilized, and unutilized properties 
because the reporting requirements are labor intensive or the 
properties may not be useful to the homeless. As noted above, the 
Title V homeless assistance program requires quarterly reporting and 
completion of a checklist for each property. The following examples 
illustrate the variety of Title V reporting practices among the 
agencies we reviewed. 

* U.S. Navy officials told us that they report only excess properties 
to HUD because of the size of their real property portfolio--
approximately 85 installations, and over 65,000 buildings and 
structures. According to these officials, the Navy does not have the 
resources to report on underutilized and unutilized property, which 
they said would require constant monitoring. Furthermore, the Navy 
also does not report some properties within Navy installations that do 
not allow public access within certain areas. 

* US Army officials said that they report eligible Title V property to 
HUD but noted that the Title V process is time-intensive for several 
reasons. They noted that the Army may report up to 500 properties to 
HUD each quarter and that HUD requires submission of each property 
checklist in hard copy. In addition, U.S. Army officials said that the 
Army has to submit a Title V checklist each time it wants to demolish 
an installation building and that the Title V homeless-assistance 
program-reporting requirements could add about 6 months to the 
demolition process. 

* DOE officials said that they report to HUD the property they are 
required to report, but believe that completing the Title V reporting 
requirement was not an efficient use of their resources since much of 
the agency's reported real property has documented deficiencies, 
including environmental contamination requiring remediation, and is 
located within secured boundaries and HUD determines many of these 
unsuitable for homeless assistance. For example, DOE properties 
typically include radiological contaminants commingled with other 
metals and chemicals associated with nuclear research and production. 
In our prior work, DOE also told us that the department understood the 
need to screen excess real property, but that much of its portfolio to 
be disposed had no remaining useful life and was most often located 
within a secure compound.[Footnote 32] 

* DOI officials said that they are required to--and do--report to HUD 
on numerous small, remotely located properties in National Parks that 
they have decided to dispose. For example, many cabins are not 
accessible by road or may be accessible only by water and only during 
certain times of the year. Officials also told us that in 2013, 73 
properties, mainly small houses on National Park lands were determined 
suitable but for off-site use only, yet the majority of these 
properties were in such poor condition that they could not be moved. 
In addition, DOI officials said that they do not report to HUD real 
property that is only used seasonally as unutilized or underutilized 
because the agency will use the properties again in the following 
season. The Title V homeless assistance program checklist, however, 
expressly asks whether an underutilized property is used seasonally 
(see appendix II: HUD Title V Checklist Submitted to Landholding 
Agencies, item 6B). 

* EPA officials noted that although some of its laboratories are only 
partially used, they do not report these as underutilized real 
property for HUD's Title V canvas because they do not believe they are 
required to do so. Rather, EPA's practice has been to report that it 
does not have any underutilized or unutilized properties for each 
quarterly canvass because the space is laboratory space that agency 
officials do not think is practical for homeless assistance programs. 
EPA officials said that they are currently conducting a space 
utilization study for laboratories, and after the study is completed, 
they will determine whether to report underutilized and unutilized 
properties identified through the study. 

* GSA officials told us that as a provider of space to other federal 
agencies, GSA properties are sometimes temporarily or partially vacant 
as the space needs of tenant agencies fluctuate. GSA officials said 
that they do not consider these properties to be underutilized and 
unutilized because the agency plans to use them to house future 
federal tenants. GSA officials said that if they identified 
underutilized and unutilized property in the portfolio that was not to 
be reported as excess, they would report these to HUD's canvass. 
However, GSA could not identify any such properties that it had 
reported to HUD in the 6 years from 2008 through 2013. Nonetheless, 
even if GSA identified a future need for temporarily or partially 
vacant space, it, like other agencies, has two opportunities to inform 
HUD as to why reported properties may not be available: first, the HUD 
Title V checklist asks reporting landholding agencies to provide 
information on any current or anticipated limitations for using the 
property to assist the homeless for a period of one year or more; 
second, landholding agencies are required to provide statements to HUD 
on the availability of properties determined suitable, including 
reasons why the property cannot be declared excess or made available 
for use to assist the homeless. 

HUD officials told us that they review and make a suitability 
determination only for those properties reported to them by 
landholding agencies and that they do not have a way of knowing how 
many properties should be, but are not reported. In 2013, the U.S. 
District Court for the District of Columbia noted that many 
landholding agencies appeared to be "failing to fairly and accurately" 
report Title V homeless assistance program-eligible properties as 
required under both the statute and Order.[Footnote 33] Further, the 
court noted that there was a significant discrepancy between the 
numbers of properties reported to HUD under Title V and the much 
larger number of federal properties listed as "excess" or 
"underutilized" in other government reports and surveys. The District 
Court ordered several steps to ensure the proper reporting of 
properties including that GSA and HUD develop a plan for additional 
improved training programs for landholding agencies. To address the 
court order, GSA and HUD officials told us they conducted a joint 
webinar with HHS in November 2013 for landholding agencies. 

HUD officials told us that they would prefer that agencies not be 
required to report certain types of properties at all because they may 
not be useful to assist the homeless. Requiring agencies to report all 
properties that fall within the four broad categories--excess, 
surplus, underutilized, and unutilized--may not be effective for 
certain types of properties. While there are discretionary elements in 
HUD's suitability criteria that are applied to properties submitted by 
the landholding agencies, HUD does not have the authority to release 
agencies from their statutorily required reporting of certain types of 
properties. Excluding certain types of properties such as "off-site 
use only properties" could enable HUD officials to focus on the 
suitable and available properties that may be more likely to assist 
the homeless and could help address issues of landholding agencies not 
reporting certain properties. In 2013, HUD proposed a revision to the 
law that would limit some of the types of properties agencies report, 
such as those that are located in high security areas and any building 
or structure that is made available for off-site use only. No action 
has been taken on that proposal. 

Homeless Assistance Providers Expanded Services, but Some Reported 
Encountering Challenges in Identifying, Applying for, and Using Real 
Property: 

Of the 11 homeless assistance providers we interviewed, the eight case 
study providers that acquired property cited benefits from the Title V 
program, such as expanding services and obtaining real property at no 
cost. These successes notwithstanding, the providers identified 
challenges such as locating information on available properties, a 
complex application, difficulty altering the approved use of 
transferred properties, and competing stakeholder interests. For 
example, although HUD reports properties in the Federal Register 
multiple times a year, and USICH provides links to them on its 
website, many homeless assistance providers may be unaware of the 
availability of properties. This may be because homeless assistance 
stakeholders have said the Federal Register is not user-friendly. 
Further, HUD's Federal Register reports list many of the same 
properties more than once. This may make listings even less user-
friendly to providers. Homeless assistance providers and advocates we 
interviewed identified a number of actions that could address these 
challenges. 

The Title V Homeless Assistance Program Enabled Selected Providers to 
Expand Services and Obtain Real Property at No Cost: 

Of the 11 homeless assistance providers we interviewed, the eight case 
study providers that acquired property cited a variety of benefits 
resulting from the acquisition of real property under the Title V 
homeless assistance program.[Footnote 34] Representatives of the 
providers responsible for the eight case study properties we reviewed 
either said that the Title V program enabled them to expand their 
program or service capacity (five providers) or acquire real property 
at no cost (four providers). Representatives of two providers cited 
both types of benefits (see appendix V for a description of each of 
the case study properties). 

For example, the following providers spoke of how they were able to 
expand their programs through the Title V homeless assistance program: 

* The acquisition of the former Boyle Heights Social Security 
Administration Building in Los Angeles enabled Volunteers of America 
of Los Angeles (VOALA) to offer services for the homeless, including 
referral services, food and clothing distribution, and job training in 
Los Angeles. VOALA reported serving more than 1,000 persons at this 
facility in 2013. 

* The acquisition of an 84-acre portion of the former Homestead Air 
Force Base in Homestead, Florida, enabled Miami-Dade County to provide 
comprehensive services, including emergency shelter, transitional 
housing, and permanent supportive housing, in addition to job 
training, medical care, and clothing, among other services. In 2013, 
the Miami-Dade County Homeless Trust reported serving 2,143 homeless 
adults and minors at this facility.[Footnote 35] 

Other providers described how the Title V homeless assistance program 
enabled them to acquire property otherwise not affordable: 

* Prior to acquiring four homes located in residential neighborhoods 
on Maryland's Eastern Shore, Crossroads Community, Inc. rented real 
property to provide rehabilitative services to individuals with mental 
illness in residential settings. Through the Title V homeless 
assistance program, the provider was able to replace rental property 
at a relatively low renovation cost with four homes that it acquired 
through the program. In addition, the program property allowed the 
provider to locate clients closer to its other service programs. 
According to Crossroads Community, Inc., the acquisition of the four 
houses currently saves the organization about $62,000 in rent on an 
annual basis. 

* According to a representative of the City of Redmond, Washington, 
the greatest benefit of the Title V homeless assistance program lies 
in providing opportunities for non-profit organizations to acquire 
real property at minimal or no cost. The city acquired at no cost 
about half of a 10.2 acre site under the program that included 16 
housing units formerly used to house U.S. Coast Guard personnel. The 
City of Redmond purchased the remainder of the real property through a 
negotiated sale with GSA. From the outset, the city planned to 
redevelop the Title V homeless assistance program portion of the real 
property into a larger facility to assist the homeless and 1-acre 
park, and develop the non-Title V portion into affordable housing 
units. Leveraging its resources, the city redeveloped the Title V 
homeless assistance program portion of the real property with 59 
housing units that provided emergency, transitional, and permanent 
supportive housing for 319 households in 2013. 

In addition to enabling homeless assistance providers to expand their 
services and obtain property they would likely have to pay for 
otherwise, the National Law Center stated that the Title V homeless 
assistance program also benefits the taxpayers by repurposing and 
reusing real property no longer needed by the federal government, 
helping the government--and by extension, the taxpayers--avoid and 
eliminate the maintenance and operation costs of retaining these 
properties. 

Selected Homeless Assistance Providers Reported a Range of Challenges 
in Identifying, Acquiring, and Using Federal Real Property: 

These successes notwithstanding, homeless assistance providers we 
interviewed identified challenges such as locating information on 
available properties, a complicated application, difficulty altering 
the approved use of transferred properties, and competing stakeholder 
interests. 

Most Selected Homeless Assistance Providers Were Unaware of Federal 
Register Notices: 

Although HUD reports regularly in the Federal Register for the purpose 
of informing homeless assistance providers about properties, among the 
11 homeless assistance providers we interviewed, one said it was 
initially unaware of the program or the availability of real property 
in its area, and eight told us they eventually learned about the 
program through third parties rather than through the Federal 
Register. Title V requires HUD to publish, in the Federal Register, a 
list of real property it has evaluated for suitability. This occurs 
multiple times each year: four quarterly reports and a summary annual 
report. In addition, to comply with the 1988 court order, as modified 
in 1993, HUD publishes a weekly notice in the Federal Register of 
properties that are suitable and available, unavailable, and 
unsuitable (see table 5). 

Table 5: Department of Housing and Urban Development's (HUD) Federal 
Register Reporting Requirements: 

Type of Report: Reporting (general); 
Time frame/publication date: No later than 15 days after receiving 
reports from landholding agencies; 
Purpose: Publish suitability determination of properties submitted to 
HUD by landholding agencies; 
Source Authority: 42 U.S.C §11411 (c)(1)(A)). 

Type of Report: Two Comprehensive Quarterly Report; 
Time frame/publication date: End of 1st quarter - January 1 and; 
End of the 3rd quarter - July 1; 
Purpose: Publish newly reviewed properties as well as previously 
reported properties that may or may not have changes; 
Source Authority: 42 U.S.C. § 11411 (c)(1)(A); National Law Center on 
Homelessness and Poverty v. Veterans Admin., 819 F. Supp. 69 (D.D.C. 
1993). 

Type of Report: Two Supplemental Quarterly Report; 
Time frame/publication date: End of the 2nd quarter and; End of the 
4th quarter - October 1; 
Purpose: Publish only newly reviewed properties from the 
previous quarter; 
Source Authority: 42 U.S.C. § 11411 (c)(1)(A); National Law Center on 
Homelessness and Poverty v. Veterans Admin., 819 F. Supp. 69 (D.D.C. 
1993). 

Type of Report: Annual Report; 
Time frame/publication date: Previous calendar year/around February 15; 
Purpose: Publish all the properties identified as suitable/available 
and suitable/unavailable in the prior calendar year in addition to 
suitable properties from prior years that may still be available or 
for which the availability status has changed; 
Source Authority: 42 U.S.C § 11411 (c)(1)(D), (c)(4)(B). 

Source: GAO Analysis of 42 U.S.C §11411, National Law Center on 
Homelessness and Poverty v. Veterans Admin., 819 F. Supp. 69 (D.D.C. 
1993) and HUD documents. GAO-14-739. 

[End of table] 

HUD shares the Federal Register notices of suitable and available 
properties with the U.S. Interagency Council on Homelessness (USICH) 
multiple times a year, and USICH provides links to the list on its 
agency website. Nonetheless, according to national homeless advocates, 
many providers remain unaware of the availability of properties. For 
example, the National Law Center reported that despite the Title V 
homeless assistance program's having been in existence for 25 years, 
too few local government and homeless providers are aware that they 
are eligible to receive property free.[Footnote 36] Moreover, a 
representative from the National Coalition for the Homeless told us 
that in general, homeless assistance providers do not have the staff 
resources to check the Federal Register consistently. 

In addition, HUD's Federal Register reports list many of the same 
properties more than once, as required, and that may make listings 
more confusing and less useful for providers to use. For example, for 
the period from 2008 through 2013, 59 percent of the properties 
appeared in more than one annual report. Because, under Title V, 
suitable properties must be reported on an ongoing basis until they 
are disposed of--regardless of their availability status--HUD reports 
some properties in the Federal Register multiple times, in some cases 
over several years, even though homeless assistance providers have not 
expressed interest in these properties. Our analysis of HUD's annual 
reports for calendar years 2008 through 2013 found that of the 1,677 
properties reported over the 6 years, 982 (59 percent) appeared in 
more than one annual report and 288 (17 percent) appeared in each of 
the six annual reports. For example, we found one property in 
Baltimore, Maryland, that was listed in three annual reports from 2011 
through 2013. In another case in Macon, Alabama, a property was listed 
in HUD's annual reports each year from 2008 through 2011. In the past, 
some in Congress and the executive branch have expressed concern about 
reporting requirements; the basic concern has been that some 
requirements result in reports that may be unnecessarily burdensome to 
produce or, in some instances, not very useful. Our prior work at 
other federal agencies has reviewed reporting requirements, the 
limited usefulness of some reports, duplicative reporting, and has 
found that less frequent reporting could allow agencies to continue to 
fulfill their responsibilities.[Footnote 37] 

HUD officials told us that, instead of publishing suitable and 
available properties in the Federal Register, they believe it would be 
more efficient and beneficial to homeless providers to publish the 
information on their Community Planning and Development "OneCPD" 
website, which serves as a resource exchange and provides technical 
assistance to stakeholders for a wide variety of programs including 
the Title V homeless assistance program. Further, both the National 
Law Center and the National Coalition for the Homeless suggested that 
available properties should be listed on the Internet in an easily 
accessible format, unlike the Federal Register, which they said is not 
user-friendly. Some stakeholders suggested that the federal government 
could make information more accessible by establishing a single web-
based source of information on the program. However, if HUD were to 
report Title V properties on its OneCPD website, this would add to 
HUD's other reporting requirements if the Title V reporting 
requirements remained unchanged, and HUD officials do not believe they 
have the resources to do both.[Footnote 38] 

Complex Application: 

Five of the homeless assistance providers we interviewed noted 
challenges with the application. Two providers reported that 
completing the application required additional resources and was time 
consuming, particularly in obtaining technical reports such as 
environmental assessments. For example, one organization hired a 
contractor to prepare the application, which was nearly 300 pages long 
and required extensive technical documentation. In another case, the 
representative said that the application process was time consuming 
because of the large volume of supporting documentation required. 
Among the homeless assistance providers we interviewed, one reported 
obtaining the environmental reports from GSA, while others paid a 
consultant to obtain the documentation or used their resources to 
collect it for the purpose of the application. Another provider noted 
that GSA responded slowly to requests for both access to the site and 
for documentation, such as site blueprints. According to this 
representative, GSA took nearly 60 days of the 90-day application 
period to provide access and documentation that had been requested at 
the beginning of the application process.[Footnote 39] Based on our 
work, we believe the large difference, discussed above, between the 
number of notices of interest and the number of applications may be, 
in part, due to the complexity and resources required to complete the 
application within a 90-day period. These case study results are 
consistent with the National Law Center's findings, which state that 
the application is lengthy and cumbersome, making it difficult for a 
homeless assistance provider to complete in the short time frame 
imposed under the law. In addition, the application calls for homeless 
assistance providers to collect information that is already in the 
government's possession, such as a description of the easements on the 
property.[Footnote 40] The HHS Title V official told us that several 
years ago, the Department modified the application packet to address 
some of these stakeholder concerns. Two homeless assistance providers 
we interviewed suggested that HHS consider providing examples of model 
applications on a public website. HHS officials told us that they 
believe posting examples of successful applications on the Internet 
may lead to homeless assistance applicants using examples that may not 
be relevant to their particular circumstances. 

Difficulty Altering Approved Real Property's Use to Meet Changing 
Client Needs: 

HHS, as the agency responsible for ensuring that homeless providers 
use the transferred real properties according to the approved 
application, also approves any changes to the original program of use 
for the properties. Two of the selected case study providers told us 
that they found it difficult to alter the original program of use for 
their properties. According to the two providers, the needs of the 
homeless clientele they serve had changed since their applications 
were approved. For example, one provider told us that the homeless 
population the organization currently serves largely consists of 
persons recently released from incarceration and, unlike the 
population it served when the property was first transferred in 2002, 
is perhaps better educated than the previous population. This provider 
stated that due to the changing population, workforce training has 
become more of a need than it was in the past. The provider noted that 
it took many letters to convince HHS that workforce training was a 
necessary part of the organization's homeless assistance. Another 
provider obtained a property for use as transitional housing for 
mentally ill homeless adults and wanted to alter the program to 
provide permanent housing to this population; a representative for 
that provider told us that the organization has thus far decided not 
to pursue its request to HHS because it understands that it would have 
to restart the application process.[Footnote 41] HHS Title V homeless 
assistance program representatives told us, that while much of the 
information requested for the original application would need to be 
resubmitted, the provider would not need to resubmit a full 
application.[Footnote 42] 

Competing Stakeholder Interests: 

Our literature review and case study interviews found that homeless 
assistance organizations often reported meeting resistance from local 
interests and groups when attempting to acquire federal properties. 
Further, USICH's 2011 annual report noted that, in some cases, local 
opposition to the use of the property by homeless providers has caused 
them to withdraw their applications to the Title V homeless assistance 
program.[Footnote 43] Two of the homeless providers we interviewed for 
our case studies reported meeting strong community opposition, which, 
according to one provider, related to concerns about safety, number of 
homeless assistance facilities within a given area, and the impact on 
real property values, for example: 

* One case study provider, whose real property is located in an 
industrial, non-residential area, told us that the organization 
changed its original plan from providing shelter services to providing 
job training and social services instead of shelter in response to 
local opposition from neighboring businesses. 

* Another case study provider encountered strong local opposition to 
its proposal to use the four residential properties as locations for 
clients undergoing mental health rehabilitation. The provider said its 
organization mitigated the resistance over the course of a year by 
holding multiple informational community meetings and conducting a 
workshop on removing the stigma associated with mental illness and 
homelessness at a local community college. Since the program has been 
in place, the organization has not experienced any further opposition 
to the program. 

* Another case study provider described how the organization 
successfully addressed and minimized the potential for local 
opposition. In this case, the City of Redmond, Washington, worked with 
an inter-local government organization--A Regional Coalition for 
Housing (ARCH)--in acquiring the Title V real property. The City and 
ARCH then worked with a consortium of homeless providers in developing 
a homeless assistance program. Anticipating concerns, particularly 
from nearby residents, ARCH and the city staff reached out to the 
neighborhood to ensure that neighborhood interests were represented 
during the planning phase of the program, including a series of 
meetings. 

Our prior work has found similar competing stakeholder interests. For 
example, state and local governments, business interests in the 
communities where the assets are located, private sector construction 
and leasing firms, various advocacy groups, and the public in general 
have an interest in how the federal government carries out its real 
property management practices.[Footnote 44] We have raised this 
concern as an underlying problem in our biennial high-risk area 
updates on federal real property.[Footnote 45] In addition, we 
recommended to the Office of Management and Budget (OMB) in 2012, the 
development of a cohesive national strategy for managing federal 
excess and underutilized real property that would also address 
competing stakeholder interests. OMB did not directly state whether it 
agreed or disagreed with our recommendation.[Footnote 46] Moreover, 
OMB has not taken action on our recommendation as of the time of this 
report. 

All four federal agencies--GSA, HHS, HUD and USICH--bear some 
responsibility for addressing challenges homeless assistance providers 
face with the Title V homeless assistance program, such as identifying 
and acquiring properties and developing a web-based source of 
information on the program. By collaborating to address these 
concerns, the federal agencies could provide information that would be 
more useful to homeless providers and thereby more effectively manage 
agency resources to contribute to the goal to end homelessness. Our 
prior work has found that many of the meaningful results that the 
federal government seeks to achieve require the coordinated efforts of 
more than one federal agency and often more than one sector and level 
of government.[Footnote 47] We have reported about the importance of 
collaboration among federal agencies for many years. In its 2011 
annual report, USICH noted that the Title V homeless assistance 
program process for identifying properties, determining suitability, 
determining availability by landholding agencies, and leasing or 
deeding surplus properties involves at least three federal agencies 
and can appear quite confusing and cumbersome to homeless 
providers.[Footnote 48] USICH is composed of representatives from 19 
federal agencies--including GSA, HHS, and HUD. While not having the 
authority to ensure compliance, USICH monitors, evaluates, and 
recommends improvements in federal and state homeless assistance 
programs and is required by law to meet at least four times a year. 
USICH is supported by the Council Policy Group, which provides a 
regular forum for coordinating policies and programs, collecting data, 
developing special initiatives, and preparing recommendations for 
consideration by USICH members. Unlike other interagency groups, 
although USICH is a very small agency, it receives an appropriation 
from Congress and employs full-time staff in Washington, D.C., and 
five regional posts.[Footnote 49] As such, resources and a process for 
addressing some of the stakeholder concerns are already in place. 

Conclusion: 

HUD has evaluated at least 40,000 underused, unused, and unneeded 
federal real property assets for the Title V homeless assistance 
program since it began in 1987. However, only a small fraction of the 
properties HUD determined suitable and that were available have been 
transferred to homeless assistance providers since the program's 
inception--likely because the majority of the properties were not 
useful to them. The 81 active properties transferred have provided 
needed services to the homeless population across the nation. While 
HUD lists information on the properties it evaluates in the Federal 
Register multiple times each year, as required by law, many of the 
listings are duplicative, and many service providers are not even 
aware of the Title V homeless assistance program. Given that all 
underutilized, unutilized, excess, and surplus federal real property 
is subject to Title V homeless assistance program reporting 
requirements--including buildings, land, or both, without regard to 
location, size, or practicality--the scope of properties reported 
(with particular attention to the usefulness of the property and the 
frequency of reporting) is crucial to helping HUD make the program 
more useful to homeless assistance providers. In addition, a reliable, 
searchable electronic database of the properties HUD has reviewed 
would improve HUD's ability to provide information to meet required 
reporting needs. While homeless assistance providers benefited from 
obtaining federal real property otherwise not affordable to them and 
expanded their services, addressing the challenges they face in 
identifying properties would improve program effectiveness. Collective 
efforts by all four responsible federal agencies--GSA, HHS, HUD, and 
USICH--could help to address these concerns. Without these changes, 
the Title V homeless assistance program may not be making the best use 
of its resources to make progress toward ending homelessness in the 
nation. 

Matter for Congressional Consideration: 

To ensure that properties determined as suitable and available are 
more likely to be practical for homeless assistance and that Federal 
Register reporting is not redundant, Congress should revisit the scope 
of properties to be reported to HUD with respect to the types of 
properties that may be less likely to be useful to assist the homeless 
and the frequency of Federal Register reporting. 

Recommendations for Executive Action: 

* To improve HUD's database on Title V homeless assistance properties, 
HUD should modify its existing database or create an electronic, 
searchable database to meet reporting needs to the extent that the 
benefits outweigh the costs. 

* HUD, GSA, HHS, and USICH should work together to address the 
challenges that homeless assistance providers face with the Title V 
homeless assistance program by: 

* identifying what kinds of properties are most practical for homeless 
assistance, and: 

* developing a web-based source of information on the program for 
homeless assistance providers. 

Agency Comments and Our Evaluation: 

We provided a draft of this report for review and comment to the four 
agencies with a role in administering the Title V homeless assistance 
program: GSA, HHS, HUD, and USICH. We also provided a draft of this 
report to the landholding agencies we included in our review: the EPA, 
the DOD service branches--the U.S. Air Force, the U.S. Army and the 
U.S. Navy--DOE and DOI. We received written comments from GSA, HHS, 
and USICH, which are summarized below and reprinted in appendixes of 
this report. HUD's agency liaison provided comments via e-mail on 
September 18, 2014, which are summarized below. In addition, GSA, HHS, 
HUD, the U.S. Army and the DOE provided technical comments, which we 
incorporated as appropriate. The EPA, U.S. Air Force, U.S. Navy, and 
DOI did not provide any comments. 

GSA concurred with the findings of the report and the recommendation 
that it work with HHS, HUD, and USICH to address the challenges that 
homeless assistance providers face by identifying what kinds of 
properties are most practical for homeless assistance and developing a 
web-based source of information on the program for providers. GSA 
stated that it will continue to work with both HUD and HHS on this 
effort. GSA noted that it has taken steps to enhance its website with 
additional information and resources about the Title V homeless 
assistance program and provide additional information about how to 
locate available properties. The agency stated that it has also 
provided the opportunity for interested homeless assistance providers 
to subscribe to receive automatic e-mail notifications as properties 
are posted to its website. These are positive steps to provide 
additional information on the homeless assistance program. GSA's 
comments can be found in appendix VI. 

HHS did not concur with our recommendation that it should work 
together with GSA, HUD, and USICH to address the challenges that 
homeless providers face by identifying what kinds of properties are 
most practical for homeless assistance. HHS stated that this was 
outside of the scope of its legal authority and noted that under the 
authorizing statute and the regulation, HUD, is solely authorized to 
identify suitable property and apply the suitability criteria to 
properties reported by landholding agencies pursuant to Title V 
requirements. We recognize that under the statute,[Footnote 50] HUD is 
solely authorized to make determinations regarding whether properties 
are suitable for use to assist the homeless. However, the McKinney-
Vento Homeless Assistance Act, as amended, required GSA, HHS, and HUD 
to promulgate implementing regulations. In response, GSA, HHS, and HUD 
promulgated a joint interim final rule that set out, among other 
things, the criteria to be applied by HUD in making its suitability 
determinations. The interim final rule putting the joint regulation in 
place explained that the suitability criteria have been developed with 
the intent of excluding only those properties that are clearly 
unsuitable for use to assist the homeless. The issuing agencies of the 
joint rule may revisit the scope of such regulatory exclusions of 
clearly unsuitable property to assess if they merit adjustment. Given 
that the rule was a joint issuance by GSA, HHS, and HUD, our 
recommendation that the agencies work together to identify what kinds 
of properties are most practical for homeless assistance is directed 
to the four agencies with responsibility for implementing the program. 
HHS concurred with the second part of the recommendation that it 
should work together with GSA, HUD, and USICH to develop a web-based 
source of information on the program for homeless assistance 
providers, and noted that it is in the process of refurbishing its 
federal real property assistance website and will consult with the 
other three agencies to discuss options relating to web-based sources 
of information on the Title V homeless assistance program. HHS's 
comments can be found in appendix VII. 

HUD also concurred with the report's overall findings, and with the 
recommendation that it modify its database or create a searchable, 
electronic database on the Title V homeless assistance properties to 
meet its reporting needs. HUD officials noted that its proposed 
legislative changes included the development of an improved database 
that would be searchable and would allow HUD stakeholders to view 
profiles of those properties that are suitable and available to be 
used to assist the homeless. HUD also concurred with the 
recommendation that it work together with GSA, HHS and USICH to 
address challenges providers face with identifying the kinds of 
properties that are most practical for homeless assistance, and to 
develop a web-based source of information on the program. HUD noted 
that it had already proposed legislative changes to create a web-based 
source of information on available properties in place of publishing 
properties in the Federal Register. Although we support a legislative 
change to address certain aspects of the law, as stated in our Matter 
for Congressional Consideration, our recommendations to HUD are not 
contingent upon legislative changes. As noted in our report, because 
HUD uses its Title V database primarily for generating listings for 
the Federal Register, it has not assessed the extent to which the 
benefits of modifying it to generate electronic reports, or developing 
a database to do so, would outweigh the costs. In addition, as one of 
the four federal agencies responsible for the program, HUD shares 
responsibility for addressing the challenges that homeless assistance 
providers face, such as identifying and acquiring properties and 
developing a web-based source of information on the program. 

USICH agreed that the scope of properties that agencies are required 
to report under Title V include large numbers of properties that could 
not viably be used for homeless assistance. However, it did not agree 
with our recommendation that it work together with GSA, HHS, and HUD 
to identify the kinds of properties that are most practical for 
homeless assistance. USICH stated that improving the identification of 
properties that are practical for homeless assistance cannot occur 
through collaboration alone and that a legislative fix is an essential 
prerequisite. We continue to believe that, as one of the agencies 
responsible for implementing the Title V homeless assistance program, 
USICH shares responsibility for addressing challenges homeless 
assistance providers face, such as identifying and acquiring 
properties. As noted in our report, by collaborating to address these 
concerns, the federal agencies could provide information that would be 
more useful to homeless providers. USICH concurred with the 
recommendation on developing a web-based source of information on the 
program for homeless assistance providers and stated that it may be 
beneficial for disseminating information on available federal real 
properties to interested stakeholders. USICH's comments can be found 
in appendix VIII. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
Administrators of the Environmental Protection Agency and the General 
Services Administration; the Executive Director of the U.S. 
Interagency Council on Homelessness; and the Secretaries of Defense, 
Energy, Health and Human Services, Housing and Urban Development, and 
the Interior. We are also sending copies of this report to the House 
Committee on Oversight and Government Reform. In addition, this report 
will be available at no charge on GAO's website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-2834 or wised@gao.gov. Contact points for our 
Office of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made key contributions to 
this report are listed in appendix IX. 

Signed by: 

David J. Wise: 
Director: 
Physical Infrastructure Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To determine what is known about the identification and transfer of 
federal real properties for homeless assistance under Title V, we 
reviewed the requirements of Title V of the Act as they apply to the 
General Services Administration (GSA), the Department of Health and 
Human Services (HHS), the Department of Housing and Urban Development 
(HUD), and the United States Interagency Council on Homelessness 
(USICH). We reviewed these agencies' internal policies, procedures and 
other documents on how they implement the requirements of the 
programs. HUD does not maintain electronic records of all the 
properties reported under Title V since the inception of the program. 
Thus, due to the lack of available data in a format that allowed 
analysis, HUD provided us with estimates of the number of 
underutilized, unutilized, excess, and surplus properties reported by 
landholding agencies and the number that HUD determined to be suitable 
and were available for homeless use from the early 1990s through March 
31, 2014. These estimates are based on the number of properties that 
were entered into HUD's Title V database, developed in the early 
1990s, several years after the McKinney-Vento Act was implemented. 
Further, HUD officials are not certain of the extent to which the 
database includes the Title V homeless assistance program properties 
reported prior to its creation. Due to the lack of available data in a 
format conducive to analysis, we could not verify the reliability of 
these estimates. We interviewed officials from HUD about how the 
estimates were derived and could not verify the reliability of these 
estimates. To assess the reliability of these estimates, we 
interviewed officials from HUD about how the estimates were derived 
and determined that the information provided by the agency provides a 
reasonable basis, with caveats, for reporting the number of properties 
that have been screened and published as suitable and available. In 
addition, to determine the number of properties reported in these 
categories and the number and percentage of these that were available 
for "off-site use only," we analyzed HUD annual reports of 
suitable/available and suitable/unavailable properties for years 2008 
through 2013. This time frame was selected to include the 5 years 
prior to the audit, and when HUD's annual report for 2013 became 
available we added it to the analysis to include the most recent 
information. Our analysis of the Federal Register notices relied on 
identifying properties by the unique Property Identification (ID) 
number published with each property listing. We also obtained from HHS 
documents and data on the number of notices of interest and 
applications received for federal real property made available for 
homeless assistance and on the number, location, and use of properties 
transferred from the program's inception in 1987 through March 31, 
2014--the date of the most recently available information. 

To assess the reliability of these data, we interviewed officials from 
HHS about how the data are collected and maintained and the steps 
taken by the agency to ensure the completeness of these data. Based on 
this discussion, we determined that the data were sufficiently 
reliable for the purposes of this report. In order to assess the 
number of properties that received notices of interest and 
applications from interested providers, we also manually reviewed data 
on notices of interest and applications received to identify potential 
duplicate properties by GSA number, property name, location, and 
description. To understand how federal landholding agencies identify 
and report real property to HUD pursuant to the Act's requirements, we 
selected nine landholding agencies to include a range of size among 
real property portfolios of land and buildings. These agencies were 
GSA; HHS; the Departments of Defense's U.S. Army, U.S. Air Force, and 
U.S. Navy; the Departments of Energy; the Interior and Veterans 
Affairs;[Footnote 51] and the Environmental Protection Agency. When 
combined, these nine landholding agencies accounted for almost 90 
percent of the buildings held by the federal government in 2012. 
[Footnote 52] We collected documents from these agencies to understand 
how each agency manages and fulfills its reporting requirements under 
Title V, the extent to which it collaborates with other agencies, and 
to obtain views on how Title V requirements impact the federal real 
property disposal process. We interviewed agency officials from the 
GSA, HHS, and HUD to understand how they process properties reported 
under Title V homeless assistance program requirements, and we 
interviewed officials from USICH to understand its role with Title V. 
We also interviewed agency officials from the nine landholding 
agencies to obtain their views on how they meet the Act's requirements 
and the impact of those requirements on each agencies disposal 
process.[Footnote 53] 

To determine the benefits and challenges selected homeless assistance 
providers and national advocacy organizations reported in identifying, 
acquiring and using federal real property, and the potential actions 
that could help address those challenges, we selected eight homeless 
assistance organizations that acquired federal real property under the 
program. The providers were: the City of Redmond, Washington; 
Crossroads Community, Inc.; Samaritan House; The Miami-Dade County 
Homeless Trust; Third Way Center; Urban Renewal Corporation; Veterans 
Coming Home/New Life Evangelistic Center; and Volunteers of America, 
Los Angeles. We made our selection using criteria such as the size of 
the real property acquired under the program, the services provided, 
geographic distribution, range of experiences with the Title V 
program, and suggestions from agencies and homeless advocacy 
organizations (GSA, HUD, HHS, USICH, the National Law Center on 
Homelessness and Poverty, and the National Coalition for the 
Homeless). In addition, to assist the selection, we also used 
information from news reports and our literature review to identify 
high-profile properties. We interviewed representatives from each of 
the selected organizations, reviewed their annual utilization reports, 
and conducted site visits to two properties transferred under Title V. 
While information from case studies is not generalizable, the 
perspectives of the homeless service providers provided us with 
examples of the benefits and challenges associated with the program. 
Further, to gain additional perspectives on experiences with the 
federal agencies and the application process, and identify potential 
improvements to the process, we convened a virtual discussion panel 
comprised of representatives from homeless assistance organizations 
whose Title V applications were not approved. We selected and 
recruited seven organizations, of which three agreed to participate in 
the panel.[Footnote 54] These organizations were selected from HHS's 
Title V homeless assistance program applicant data from 2006 through 
2013 based on their geographic locations and proposed use of the 
properties. We selected the particular time frame to ensure that the 
information provided was reasonably up to date. Since the virtual 
discussion panel was selected using a non-probability sample of 
homeless assistance applicants whose Title V applications were 
declined by HHS, like the case studies, their experiences cannot be 
generalized to all homeless service providers. In addition, we 
reviewed the reports and interviewed representatives of two national 
advocacy organizations--the National Law Center on Homelessness and 
Poverty and the National Coalition for the Homeless. 

We conducted this performance audit from September 2013 to September 
2014 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Sample Title V Checklist Submitted by Landholding 
Agencies to HUD: 

Title V Property Survey: 
Federal Property Information Checklist: 
(Rev. 11/89): 

Instructions: 
1) Use this form. 

2) Complete all items below or the checklist will be returned for 
completion. 

Date: ______________________
Property ID # [____________________________]; (HUD will assign). 

1. Federal Landholding Agency: Bureau: _______________________________; 

2. Property (name): __________________________________________________; 
(installation name, if applicable): __________________________________; 

3. Address (street and number, or if none, a brief description of how 
to locate property); 

4. GSA Inventory Control No. (if available): 

5. Previously Reported To HUD? 
Yes: 
No: 
Determination by HUD (date: ______________): 
Suitable: 
Unsuitable: 

6. Property Description: 
Building: 
Vacant Land: 
Other (improved land): 

A. Current status: 
Unutilized: 
Underutilized: 
Excess: 
Surplus: 
If excess or surplus, GSA Disposal Control No.: 

B. If underutilized, type of underutilization (describe): 
Portion: 
Seasonal: 
Intermittent: 
Other (describe): 

C. Predominant surrounding land use: 

D. Unusual physical features or impediments: 

E. Legal constraints (right of entry, covenants, permits, 
licenses, etc.): 

F. Other (comments): 

7. Building Description: 
A. Age: 
B. Structure type: 
C. Size (usable square feet per floor): 
D. Number of floors: 
E. Current or most recent use (storage, residential, office, etc.): 
F. If currently occupied or leased, indicate: 
i. Percentage of total space occupied or otherwise in use: ______ 
percent;
ii. Expiration date(s) of any existing lease(s) or renewal period(s): 
F. If currently vacant, indicate number of months vacant: ________. 

8. Building Condition: Meets or has the potential to meet the 
following criteria: 

A. Operating sanitary facilities: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

B. Potable water: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

C. Electric power: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

D. Indicate (if known) distance to nearest utility hook-up(s): 

E. Heating facilities adequate for climate: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

F. Structurally sound: 
i. Foundation: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

ii. Floors: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

iii. Roofs: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

iv. Exterior walls: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

v. Interior walls: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

9. Vacant Land: 

A. Size (acres, square footage): 

B. Description of improvements (i.e. paved, etc.): 

C. Current or most recent use: 

D. If occupied, indicate: : 
i. Percentage of total land area occupied or otherwise in use: percent: 
ii. Expiration date of any existing lease or renewal period: 

10. Vacant Land Condition: Meets or has the potential to meet the 
following criteria: 

A. Operating sanitary facilities: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

B. Potable water: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

C. Electric power: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

D. Indicate (if known) distance to nearest utility hook-up(s): 

11. Access: 

A. Does this property have public access? 
Yes: 
No: 

If yes, how (road, other): 
If no, indicate: 
i. Distance to the nearest road: 
ii. Type of terrain: 
iii. Miles to nearest town/city: : 

Accessible by public transportation? 
Yes: 
No; 

Type of transportation: 

B. Indicate any restrictions on access (hours, etc.): 

12. Environmental Suitability: 

A. Is the property subject to contamination by toxic or hazardous 
materials or waste? 
Yes: 
No: 
Identify the basis for determination (submit documents): 

If yes, also identify: 
i. Nature of contaminants: 
ii. Location of contaminants: 
iii. Extent (percentage of building or number of acres affected) of 
contaminants: 
iv. Any scheduled cleanup plans (include projected date of completion 
and estimate of cost, if known: 

B. Is an industrial/commercial Federal facility handling flammable or 
explosive material (excluding underground storage) located on the 
property or within 2,000 feet of its boundary (exclude underground 
storage, gasoline stations, tank trucks, and any; above-ground 
container(s) with a capacity of 100 gallons or less of such materials)? 
Yes: 
No: 

If yes, indicate: 
i. Number of acres (herein being determined for possible use by the 
homeless); located more than 2,000 feet from such facility: 
ii. Nature of the facility and material: 

C: Is any portion of the property located within an airport runway 
clear zone? 
Yes: 
No: 

If yes, indicate the portion (percentage) of the property which is so 
located: ______ percent. 

D. Is any portion of the property located within a 100 year 
floodplain? (note that the fact that a Federal property is not 
included in an existing floodplain map or study does not, by itself, 
justify a "No" answer); 
Yes: 
No: 

E. Is the property impacted by any other environmental condition which 
might jeopardize the safety of occupants of the property (e.g., friable 
asbestos, PCBs, radon, periodic flooding)? 
Yes: 
No: 

Indicate: 
i. Basis for determination (submit document): 
ii. Nature of condition: 
iii. Extent of condition: 
iv. Location of condition: 

F. Are there any other known environmental conditions which could 
affect or be impacted by the occupancy of the property (e.g., 
endangered species, wild and scenic rivers, wetlands, historic 
properties, storm water runoff; etc.)? 
Yes: 
No: 
Undetermined: 

If yes, for each: 
i. Describe the environmental condition: 
ii. Describe the potential impact: 
iii. Basis for the determination (submit document): 

13. Security: 

A. Is the property located in a secure facility to which the general 
public is denied access? 
Yes: 
No: 

B. If the answer above is yes, can alternative access be provided for 
the general public without compromising security requirements? 
Yes: 
No: 

Indicate method of providing access: : 

14. Limitations On Use: 

A. Are there now, or are there anticipated to be, any other 
limitations not previously described on the use of this property to 
assist the homeless for a period of one year or more? 
Yes: 
No: 

If yes, describe the limitation: 

B. Does the limitation currently exist? 
Yes: 
No: 

If no, when will any limitation take effect? 
date of effect: 

15. Checklist Contact Person: 
name: 
title: 
phone number: 
email: 
date prepared: 

Photos (not required) are attached? 
Yes: 
No: 

Additional amplifying information documents (not required) are 
attached? 
Yes: 
No: 

Additional Remarks (if any): 

F. Other (comments): 

7. Building Description: 
A. Age: 
B. Structure type: 
C. Size (usable square feet per floor): 
D. Number of floors: 
E. Current or most recent use (storage, residential, office, etc.): 
F. If currently occupied or leased, indicate: 
i. Percentage of total space occupied or otherwise in use: 
ii. Expiration date(s) of any existing lease(s) or renewal period(s): 
F. If currently vacant, indicate number of months vacant: 

8. Building Condition: Meets or has the potential to meet the following 
criteria 

A. Operating sanitary facilities: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

B. Potable water: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

C. Electric power: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

D. Indicate (if known) distance to nearest utility hook-up(s): 

E. Heating facilities adequate for climate: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

F. Structurally sound: 
i. Foundation: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 
ii. Floors: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

iii. Roofs: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

iv. Exterior walls: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

v. Interior walls: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

vi. Describe general condition or extent of repairs needed: 

9. Vacant Land: 

A. Size (acres, square footage): 

B. Description of improvements (i.e. paved, etc.): 

C. Current or most recent use: 

D. If occupied, indicate: 
i. Percentage of total land area occupied or otherwise in use: 
ii. Expiration date of any existing lease or renewal period: 

10. Vacant Land Condition: Meets or has the potential to meet the 
following criteria: 

A. Operating sanitary facilities: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

B. Potable water: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

C. Electric power: 
Meets: 
Yes: 
No: 
Potential: 
Yes: 
No: 

D. Indicate (if known) distance to nearest utility hook-up(s): 

11. Access: 

A. Does this property have public access? 
Yes: 
No: 

If yes, how (road, other): 
If no, indicate: 
i. Distance to the nearest road: 
ii. Type of terrain: 
iii. Miles to nearest town/city: 

Accessible by public transportation: 
Yes: 
No: 
Type of transportation: 

B. Indicate any restrictions on access (hours, etc.): 

12. Environmental Suitability: 

A. Is the property subject to contamination by toxic or 
hazardous materials or waste? 
Yes: 
No: 

Identify the basis for determination (submit documents): 

If yes, also identify: 
i. Nature of contaminants: 
ii. Location of contaminants: 
iii. Extent (percentage of building or number of acres affected) of 
contaminants: 
iv. Any scheduled cleanup plans (include projected date of completion 
and estimate of cost, if known: 

B. Is an industrial/commercial Federal facility handling flammable or 
explosive material (excluding underground storage) located on the 
property or within 2,000 feet of its boundary (exclude underground 
storage, gasoline stations, tank trucks, and any above-ground 
container(s) with a capacity of 100 gallons or less of such materials)?
Yes: 
No: 

If yes, indicate: 
i. Number of acres (herein being determined for possible use by the 
homeless) located more than 2,000 feet from such facility: 
ii. Nature of the facility and material: 

C: Is any portion of the property located within an airport runway 
clear zone? 
Yes: 
No: 
If yes, indicate the portion (percentage) of the property which is so 
located: 

D. Is any portion of the property located within a 100 year 
floodplain? (note that the fact that a Federal property is not included 
in an existing floodplain map or study does not, by itself, justify a 
"No" answer.) 
Yes: No: 

E. Is the property impacted by any other environmental condition which 
might jeopardize the safety of occupants of the property (e.g., 
friable asbestos, PCBs, radon, periodic flooding)? 
Yes: 
No: 

Indicate: 
i. Basis for determination (submit document): 
ii. Nature of condition: 
iii. Extent of condition: 
iv. Location of condition: 

F. Are there any other known environmental conditions which could 
affect or be impacted by the occupancy of the property (e.g., 
endangered species, wild and scenic rivers, wetlands, historic 
properties, storm water runoff; etc.)? 
Yes: 
No: 
Undetermined: 

If yes, for each: ; Describe the environmental condition: 

Describe the potential impact: 

Basis for the determination (submit document): 

13. Security: 

A. Is the property located in a secure facility to which the general 
public is denied access? 
Yes: 
No: 

B. If the answer above is yes, can alternative access be provided for 
the general public without compromising security requirements? 
Yes: 
No: 

Indicate method of providing access: 

14. Limitations On Use: 

A. Are there now, or are there anticipated to be, any other 
limitations not previously described on the use of this property to 
assist the homeless for a period of one year or more? 
Yes: 
No: 

If yes, describe the limitation: ; B.Does the limitation currently 
exist? 
Yes: 
No: 
If no, when will any limitation take effect? (date of effect); 

15. Checklist Contact Person: 
name: 
title: 
phone number: 
email: 
date prepared: 

Photos (not required) are attached? 
Yes: 
No: 

Additional amplifying information documents (not required) are 
attached? 
Yes: 
No: 

Additional Remarks (if any): 

[End of section] 

Appendix III: List of Landholding Agencies HUD Canvasses for Title V: 

1. Central Intelligence Agency: 
2. Department of Commerce: 
3. Department of Agriculture: 
4. Department of the Air Force: 
5. Department of the Army: 
6. Department of the Navy: 
7. Department of Education: 
8. Department of Energy: 
9. Department of the Interior: 
10. Department of Justice: 
11. Department of Health and Human Services: 
12. Department of Labor: 
13. Department of State: 
14. Department of Transportation: 
15. Department of the Treasury: 
16. Department of Veterans Affairs: 
17. Environmental Protection Agency: 
18. Federal Communications Commission: 
19. Federal Emergency Management Agency: 
20. General Services Administration: 
21. International Broadcasting Bureau of the Broadcasting Board of 
Governors: 
22. National Aeronautics and Space Administration: 
23. National Science Foundation: 
24. U.S. Army Corps of Engineers: 
25. U.S. Coast Guard: 

[End of section] 

Appendix IV: Services Provided at 81 Active Properties Transferred 
under Title V, by State: 

As of March 2014, 81 Title V properties were currently in use by 
homeless assistance providers across the country to provide a range of 
homeless assistance services. The table below presents the services 
provided at each location by state. 

Table 6: Services Provided at 81 Active Properties Transferred Under 
Title V by State: 

Homeless Provider, Location (by State); Catholic Social Services, 
Inc., Anchorage, AK; 
Services: 
Transitional Housing: 
Permanent Supportive Housing: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Tundra Women's Coalition, 
Bethel, AK; 
Services: 
Transitional Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Tundra Women's Coalition, 
Bethel, AK; 
Services: 
Transitional Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Salvation Army, Benton, AR; 
Services: 
Supportive Services[A]: 
Emergency Shelter: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); The Family Center, Inc., 
Helena, AR.; 
Services: 
Administrative Offices: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Quapaw House, Inc., Hot 
Springs, AR; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Permanent Supportive Housing: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Our House, Inc., Little Rock, 
AR; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Emergency Shelter: 
Daycare/Day Center: 
Total Number of Services: 4. 

Homeless Provider, Location (by State); Esperanza en Escalante, 
Tucson, AZ; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); House of Refuge, Inc., Mesa, 
AZ; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); House of Refuge East, Mesa, AZ; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); The Community Housing 
Partnership, Inc., Mesa, AZ; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Administrative Offices: 
Daycare/Day Center: 
Total Number of Services: 4. 

Homeless Provider, Location (by State); Community Social Model 
Advocates, Inc., Atwater, CA; 
Services: 
Supportive Services[A]: 
Referral Services: 
Administrative Offices: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Community Social Model 
Advocates, Inc., Atwater, CA; 
Services: 
Goods and Clothing Distribution: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Salvation Army, Bell, CA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Emergency Shelter: 
Administrative Offices: 
Mental Health: 
Total Number of Services: 6. 

Homeless Provider, Location (by State); Shelter Partnership, Inc, 
Bell, CA; 
Services: 
Goods and Clothing Distribution: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Salvation Army Southern 
California Division, Los Angeles, CA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Volunteers of America of L.A., 
Los Angeles, CA; 
Services: 
Supportive Services[A]: 
Referral Services: 
Emergency Shelter: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Veterans Transition Center of 
Monterey, Marina, CA; 
Services: 
Transitional Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Housing Authority of the 
County of Monterey, Monterey, CA; 
Services: 
Warehouse and Storage: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Housing Authority of the 
County of Monterey, Monterey, CA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Interim, Inc., Monterey, CA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Shelter Outreach Plus, 
Monterey, CA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Shelter Plus, Monterey, CA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Vietnam Veterans of Monterey 
County, Monterey, CA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); County of Sacramento, Rancho 
Cordova, CA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Vietnam Veterans of 
California, Inc., Redding, CA; 
Services: 
Non-Use (Potential Reversion): 
Total Number of Services: 1. 

Homeless Provider, Location (by State); California Emergency Food 
Link, Sacramento, CA; 
Services: 
Goods and Clothing Distribution: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Grace Apostolic Church, San 
Bernardino, CA; 
Services: 
Goods and Clothing Distribution: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Grace Apostolic Church, San 
Bernardino, CA; 
Services: 
Goods and Clothing Distribution: 
Warehouse and Storage: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Third Way Center, Denver, CO; 
Services: 
Transitional Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Community for Creative 
Nonviolence, Inc., Washington, D.C.; 
Services: 
Education/Job Training: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Metropolitan Dade County 
Government, Homestead, FL; 
Services: 
Transitional Housing: 
Emergency Shelter: 
Permanent Supportive Housing: 
Administrative Offices: 
Daycare/Day Center: 
Total Number of Services: 5. 

Homeless Provider, Location (by State); Mount Olive Community Outreach 
Center, Inc., Albany, GA; 
Services: 
Transitional Housing: 
Emergency Shelter: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Growing Home, Inc., Miller 
Township, IL; 
Services: 
Education/Job Training: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); 5020 State Street, LLC, St. 
Louis, IL; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); North Central-Flint Hill 
Agency on Aging, Manhattan, KS; 
Services: 
Supportive Services[A]: 
Referral Services: 
Case Management: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Aftercare Ministries, Inc., 
Alexandria, LA; 
Services: 
Non-Use (Potential Reversion): 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Monroe Area Guidance Center, 
Monroe, LA; 
Services: 
Transitional Housing: 
Emergency Shelter: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); City of Lynn, Lynn, MA; 
Services: 
Administrative Offices: 
Food Distribution: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Crossroads Community, Inc., 
Chestertown, MA; 
Services: 
Transitional Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Health and Education Services, 
Inc., Topsfield, MA; 
Services: 
Supportive Services[A]: 
Permanent Supportive Housing: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Vietnam Veterans Workshop, 
Inc., Boston, MA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Emergency Shelter: 
Permanent Supportive Housing: 
Total Number of Services: 5. 

Homeless Provider, Location (by State); Advocates for Homeless 
Families, Frederick, MD; 
Services: 
Transitional Housing: 
Education/Job Training: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Catholic Charities of the 
Archdiocese of Washington, Inc., Waldorf, MD; 
Services: 
Supportive Services[A]: 
Referral Services: 
Emergency Shelter: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); City of Bangor, Bangor, ME; 
Services: 
Transitional Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); AMHC Facilities, Inc., 
Caribou, ME; 
Services: 
Supportive Services[A]: 
Referral Services: 
Permanent Supportive Housing: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Homeworkers Organized for More 
Employment, Ellsworth, ME; 
Services: 
Emergency Shelter: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Pontiac Rescue Mission, 
Pontiac, MI; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Emergency Shelter: 
Total Number of Services: 4. 

Homeless Provider, Location (by State); Salvation Army, Warren, MI; 
Services: 
Supportive Services[A]: 
Emergency Shelter: 
Administrative Offices: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Salvation Army, Duluth, MN; 
Services: 
Transitional Housing: 
Referral Services: 
Goods and Clothing Distribution: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Economic Security Corp. of 
Southwest Area, Joplin, MO; 
Services: 
Supportive Services[A]: 
Referral Services: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); New Life Evangelistic Center, 
Inc., Springfield, MO; 
Services: 
Referral Services: 
Education/Job Training: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Human Resource Development 
Council, Inc., Bozeman, MT; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Emergency Shelter: 
Total Number of Services: 4. 

Homeless Provider, Location (by State); Samaritan House, Inc., 
Kalispell, MT; 
Services: 
Supportive Services[A]: 
Emergency Shelter: 
Administrative Offices: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Housing Authority of the 
County of Scottsbluff, NE, Scottsbluff, NE; 
Services: 
Supportive Services[A]: 
Referral Services: 
Emergency Shelter: [Empty]; 
Goods and Clothing Distribution: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Middlesex Interfaith Partners 
with the Homeless, Edison, NJ; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Urban Renewal Corp., Kearny, 
NJ; 
Services: 
Goods and Clothing Distribution: 
Education/Job Training: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); New Day, Inc., Albuquerque, NM; 
Services: 
Supportive Services[A]: 
Referral Services: 
Emergency Shelter: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Overcoming-Love Ministries, 
Brooklyn, NY; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Paterson Coalition for 
Housing, Inc., Clifton, NY; 
Services: 
Transitional Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Rockland Housing Action 
Coalition, Inc., Tappan, NY; 
Services: 
Permanent Supportive Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); Neighbors of Watertown, Inc., 
Watertown, NY; 
Services: 
Supportive Services[A]: 
Referral Services: 
Permanent Supportive Housing: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); United Christian Ministries, 
Lawrenceville, PA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Community Mental Health 
Service Properties, Inc., Phoenixville, PA; 
Services: 
Transitional Housing: 
Food Distribution: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Community Mental Health 
Services. Inc., West Chester, PA; 
Services: 
Referral Services: 
Administrative Offices: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Interfaith Hospitality Network 
of York County, SC, Rockhill, SC; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Wintergarden Women's Shelter, 
Carrizo Springs, TX; 
Services: 
Supportive Services[A]: 
Referral Services: 
Emergency Shelter: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Union Gospel Mission, Dallas, 
TX; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Woman, Inc., Galveston, TX; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); New Haven Home, Mineral Wells, 
TX; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Emergency Shelter: 
Total Number of Services: 4. 

Homeless Provider, Location (by State); Concho Valley Center for Human 
Advancement, San Angelo, TX; 
Services: 
Permanent Supportive Housing: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); City of San Antonio, San 
Antonio, TX; 
Services: 
Supportive Services[A]: 
Referral Services: 
Emergency Shelter: 
Permanent Supportive Housing: 
Total Number of Services: 4. 

Homeless Provider, Location (by State); Central Piedmont Action 
Council, Inc., Farmville, VA; 
Services: 
Referral Services: 
Administrative Offices: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); The Salvation Army, Lynchburg, 
VA; 
Services: 
Daycare/Day Center: 
Total Number of Services: 1. 

Homeless Provider, Location (by State); County of Prince William, 
Woodbridge, VA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); NE Kingdom Community Action, 
Inc., Newport, VT; 
Services: 
Referral Services: 
Administrative Offices: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); King County Housing Authority, 
Kent, WA; 
Services: 
Supportive Services[A]: 
Transitional Housing: 
Referral Services: 
Emergency Shelter: 
Permanent Supportive Housing: 
Total Number of Services: 5. 

Homeless Provider, Location (by State); City of Redmond, Redmond, WA; 
Services: 
Transitional Housing: 
Emergency Shelter: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Integrated Community Services 
of Parkersburg, Parkersburg, WV; 
Services: 
Supportive Services[A]: 
Referral Services: 
Emergency Shelter: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Northwood Health Systems, 
Inc., Wheeling, WV; 
Services: 
Referral Services: 
Emergency Shelter: 
Mental Health: 
Total Number of Services: 3. 

Homeless Provider, Location (by State); Wyoming Coalition for the 
Homeless, Cheyenne, WY; 
Services: 
Education/Job Training: 
Daycare/Day Center: 
Total Number of Services: 2. 

Homeless Provider, Location (by State); Total Number of Services; 
Services: 
Supportive Services[A]: 43; 
Transitional Housing: 42; 
Referral Services: 37; 
Emergency Shelter: 19; 
Permanent Supportive Housing: 12; 
Administrative Offices: 11; 
Goods and Clothing Distribution: 8; 
Education/Job Training: 6; 
Daycare/Day Center: 5; 
Food Distribution: 2; 
Mental Health: 2; 
Warehouse and Storage: 2; 
Non-Use (Potential Reversion): 2; 
Case Management: 1; 
Total Number of Services: 192; 

Source: GAO analysis of HHS information. GAO-14-739. 

[End of table] 

[End of section] 

Appendix V: Eight Homeless Assistance Case-Study Properties: 

California: 

Figure 4: Former Social Security Administration Building: 

Property Name: Boyle Heights Social Security Building: 
Location: Los Angeles, California: 
Property Description: 1 building; .95 acre: 
Notice of interest date: 2/13/2009: 
Application date: 3/31/2009: 
Year transferred: 12/14/2009 (deed conveyance): 
Grantee: Volunteers of America, Los Angeles: 
Homeless Assistance Use: Supportive and referral services: 

[Refer to PDF for image: 2 photographs] 

Source: GAO. GAO-14-739. 

[End of figure] 

Volunteers of America of Los Angeles (VOALA) is a non-profit human 
services organization committed to serving people in need, 
strengthening families, and building communities. The property 
consisted of a single-story masonry building in very good condition. 
VOALA offers several homeless assistance programs at the site including 
Early Head Start, which provides comprehensive services to homeless 
families with children under 4 years of age; Incarcerated Veterans 
Transition Program, which provides employment support for veterans 
about to be released or just released from incarceration; Female & 
Single Head of Household, which provides case management services to 
female and single head-of-household veterans; and Supportive Services 
for Veteran Families, which provides a housing placement program. 
According to VOALA, the four programs served 1,029 individuals in 2013. 

Colorado: 

Figure 5: Former Lowry Air Force Base Building: 

Property Name: Lowry Air Force Base Building: 
Location: Denver, Colorado: 
Property Description: 1 building (6,800 square feet); 1.8 acres: 
Notice of interest date: 10/06/1999: 
Application date: 1/06/2000: 
Year transferred: 6/03/2003 (deed conveyance): 
Grantee: Third Way Center: 
Program Use: Includes shelter, job training and education: 

[Refer to PDF for image: 2 photographs] 

Source: GAO. GAO-14-739. 

[End of figure] 

Third Way Center is a non-profit organization that provides 
transitional housing and round-the-clock psychiatric care for at-risk 
youth in Denver, CO. The property was originally part of the Lowry Air 
Force Base, which closed as a result of the Base Realignment and 
Closure Act (BRAC) in 1991. Since the property became available as a 
result of a pre-Redevelopment Act BRAC action, it was subject to Title 
V Homeless Assistance Program reporting requirements. According to HHS, 
one factor in the long period between the base closure and when the 
property became available was the environmental clean-up that was 
required at the site. When Third Way acquired the property in 2003, the 
property consisted of a one-story building which the provider 
subsequently demolished to construct four residential homes. The 
organization uses this property to provide a number of services to 
homeless adolescents--including shelter, meals, job training, mental 
health treatment and an on-site, state-approved high school. 

Florida: 

Figure 6: Former Homestead Air Force Base: 

Property Name: Homestead Air Force Base: 
Location: Homestead, Florida: 
Property Description: 0 buildings; 84.2 acres: 
Notice of interest date: 12/22/1993: 
Application date: 11/16/1995: 
Year transferred: 6/28/1996 (deed conveyance): 
Grantee: The Miami-Dade County Homeless Trust: 
Program Use: Includes shelter, education and mental health treatment: 

[Refer to PDF for image: 2 photographs] 

Source: GAO. GAO-14-739. 

[End of figure] 

The Miami-Dade County Homeless Trust is an organization within the 
Miami-Dade County government that is responsible for coordinating local 
homeless systems of care. The organization applied for and was conveyed 
84 acres of unimproved land from the former Homestead Air Force Base, 
which was closed as a result of the Base Realignment and Closure Act in 
1993. Since then, Miami-Dade Homeless Trust has developed the property, 
including a 300-bed emergency housing facility, a 192-bed transitional 
housing facility, and a 580-bed facility for families with individuals 
having disabling conditions. Services at these facilities include case 
management, adult and vocational education, job training, and various 
medical services. There is also a working farm and farmer's market on 
the property. According to Miami-Dade Homeless Trust, homeless 
assistance was provided at the property to more than 2,000 individuals 
in 2013. 

Maryland: 

Figure 7: Former U.S. Coast Guard Family Housing Site: 

Property Name: Stillpond Housing Units, U.S. Coast Guard (4 homes): 
Location: Chestertown, MD: 
Property Description: 4 homes (each approx 1,100 square feet); 1.32 
acres: 
Notice of interest date: 1/31/2002: 
Application date: 5/10/2002: 
Year transferred: 8/13/2002 (deed conveyance): 
Grantee: Crossroads Community, Inc., Centreville, MD: 
Homeless Assistance Use: Transitional housing for adults in mental 
health rehabilitation programs. 

[Refer to PDF for image: 2 photographs] 

Source: GAO. GAO-14-739. 

[End of figure] 

Crossroads Community, Inc. is a nonprofit organization that provides a 
full array of psychiatric rehabilitation and case management services 
to adults and children through five counties on Maryland's Eastern 
Shore. The property consists of two raised foyer and two ranch homes 
located in Chestertown, Maryland, but the houses are not contiguous to 
each other. All four houses are being utilized as residences for a 
Residential Rehabilitation Program licensed by the State of Maryland. 
The program provides for licensed, supervised transitional housing for 
homeless adults who have mental illness. The people served are expected 
to transition to a less supervised setting within 24 months. Crossroads 
Community, Inc. initially met strong local opposition to its 
application and program as a result of an unrelated crime that occurred 
several years prior to the property becoming available. The 
organization was able to overcome opposition through a combination of 
informational meetings and a workshop at a local community college. 
Crossroads Community, Inc would like to convert at least two of the 
houses to permanent supportive housing sometime in the future. 

Missouri: 

Figure 8: Former Social Security Administration Building: 

Property Name: Social Security Administration Building: 
Location: Springfield, Missouri: 
Property Description: 1 building (17,346 square feet); 1.08 acres: 
Notice of interest date: 11/1/2007: 
Application date: 12/6/2007: 
Year transferred: 7/18/2008 (deed conveyance): 
Grantee: Veterans Coming Home/New Life Evangelical Center: 
Homeless Assistance Use: Daytime respite center for homeless adults; 
case management: 

[Refer to PDF for image: 2 photographs] 

Source: GAO. GAO-14-739. 

[End of figure] 

Veterans Coming Home Center is a program of New Life Evangelistic 
Center (NLEC), an interdenominational, a non-denominational, faith-
based organization headquartered in St. Louis, MO. Although NLEC 
initially wanted to use this property as emergency shelter for homeless 
veterans, it was unable to win the approval of local authorities for 
this purpose. As an alternative, NLEC developed the property as a 
daytime respite center, providing access to food and hot beverages, 
laundry services, free clothing, and referral services, among other 
services. According to an NLEC representative, Veterans Coming Home 
expanded its outreach to all members of the homeless population in 
2008, its second year of operation at the recommendation of HHS. In 
addition, beginning in 2012, Veterans Coming Home introduced counseling 
and case management services through partnerships with other 
organizations. According to the annual report submitted to HHS, 
Veterans Coming Home provided services to 421 homeless persons in 2013. 

Montana: 

Figure 9: Former Sonstelie Hall Army Reserve Center: 

Property Name: Sonstelie Hall Army Reserve Center: 
Location: Kalispell, Montana: 
Property Description: 2 buildings (13,100 square feet and 750 square 
feet); 2.42 acres: 
Notice of interest date: 11/5/2007: 
Application date: 12/06/2007: 
Year transferred: 7/18/2008 (deed conveyance): 
Grantee: Samaritan House, Inc.
Program Use: Administrative offices, case management, job training. 

[Refer to PDF for image: 2 photographs] 

Source: Samaritan House, Kalispell, MT. GAO-14-739. 

[End of figure] 

Samaritan House, Inc. is a non-profit organization that has provided 
assistance to the homeless population in Kalispell, MT since 1991 
through its several facilities. The organization uses this particular 
property, which consists of a main building and garage, to provide case 
management, job training, tutoring, meetings, and food, clothing and 
furniture distribution. According to Samaritan House, the acquisition 
of this property enabled an increase in capacity at its transitional 
housing facility by moving some of the operations that had been housed 
there to this facility, resulting in the addition of 13 beds. According 
to Samaritan House, the facility was used to provide homeless 
assistance to more than 1,100 individuals in 2013. 

New Jersey: 

Figure 10: Former Naval Reserve Center: 

Property Name: Naval Reserve Center: 
Location: Kearny, New Jersey: 
Property Description: 1 building (about 50,000 square feet); 2.63 acres 
Notice of interest date: 4/26/2001: 
Application date: 6/27/2001: 
Year transferred: 3/27/2002 (deed conveyance): 
Grantee: Urban Renewal Corp.
Program Use: Workforce development, GED training, and warming station 
during winter months: 

[Refer to PDF for image: 2 photographs] 

Source: Urban Renewal Corp, Kearny, NJ. GAO-14-739. 

[End of figure] 

The Urban Renewal Corp. is a community-based, non-profit organization 
providing a variety services to vulnerable populations in New Jersey. 
This property consists of a four-story building that was formerly used 
as a Naval Reserve Center. The building is currently used to provide 
the homeless with job training and education, in addition to a variety 
of social services, such as substance abuse and HIV/AIDS counseling, 
and case management. Initially, the Urban Renewal Corp. had intended to 
use the property as a homeless shelter, but after facing strong local 
opposition, it revised its program of use to include only non-shelter 
services to the homeless. Although it is not formally used as a 
shelter, the provider is authorized to use the facility as a warming 
station during the winter months to house up to 20 homeless people per 
night when outside temperatures fall below a certain point. 

Washington: 

Figure 11: Former U.S. Coast Guard Housing: 

Property Name: U.S. Coast Guard Family Housing Site: 
Location: Redmond, Washington: 
Size: 18 Buildings; 5.1 acres: 
Notice of interest date: 7/5/1996: 
Application date: 11/15/1996: 
Transfer Date: 9/25/1997 (deed conveyance): 
Grantee: City of Redmond, Washington: 
Homeless Assistance Use: Emergency shelter; transitional housing; case 
management: 

[Refer to PDF for image: 2 photographs] 

Source: City of Redmond. GAO-14-739. 

[End of figure] 

When the City of Redmond learned of that federal real property would 
become available for homeless assistance within its boundaries, it 
retained an "inter-local" governmental organization that it is a member 
of, A Regional Coalition for Housing (ARCH), to assist the city in 
preparing an application and developing a program for the property. 
The property consisted of a 5.1 acre parcel including 18 residences 
that had been used to house U.S. Coast Guard staff. The city contracted 
with a consortium of four homeless assistance providers to rehabilitate 
and operate the existing units for transitional housing on 4.1 acres of 
the site, reserving the remaining acre for a recreational area. In 
2003, the consortium demolished the original units and replaced them 
with new buildings that included a total of 59 housing units to provide 
transitional housing for the homeless. According to the City of 
Redmonds's most recent Annual Utilization Report to HHS, the property, 
now called Avondale Park, provided emergency shelter and transitional 
housing in calendar year 2013 to 319 individuals. 

[End of section] 

Appendix VI: Comments from the General Services Administration: 

GSA: 
The Administrator: 
U.S. General Services Administration: 
1800 F Street, NW: 
Washington, DC 20405: 
Telephone: (202) 501-0800: 
Fax: (202) 219-1243: 

September 18, 2014: 

The Honorable Gene L. Dodaro: 
Comptroller General of the United States: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Dodaro: 

The U.S. General Services Administration (GSA) appreciates the 
opportunity to review and comment on the draft report entitled Federal 
Real Property: More Useful Information to Providers Could Improve the 
Homeless Assistance Program (GAO-14-739). 

As the primary disposal agent for surplus Federal real property, GSA 
utilizes authorities enabling various disposition methods in order to 
reposition real property as efficiently as possible, providing 
services to communities and value to the American tax payer. One of 
these disposal methods is Title V of the McKinney-Vento Homeless 
Assistance Act, 42 USC 11411 . After an audit of the program, the 
Government Accountability Office (GAO) recommended that GSA work with 
the Department of Housing and Urban Development (HUD) and Health and 
Human Services (HHS) to identify what kinds of properties are most 
practical for homeless assistance and develop a web-based source of 
information on the program for homeless assistance providers. GSA 
agrees with this recommendation and will continue to work with both 
HUD and HHS on this effort. 

The GSA Office of Real Property Utilization and Disposal has enhanced 
its website with additional information and resources for those 
seeking information regarding the McKinney-Vento Homeless Assistance 
program. The McKinney-Vento module of the website now includes "3 Easy 
Ways" to locate properties available for homeless assistance through 
GSA. The three easy ways include individual screening notices for
each property available through GSA that can be viewed by the user; 
step-by-step instructions on how to search the Federal Register for 
notices of property reviewed by HUD for suitability to assist the 
homeless; and an option for homeless assistance providers to subscribe 
to receive automatic e-mail notifications when GSA posts a new 
property on its website. In addition, GSA has provided links on its 
website to both HUD and HHS, to enable users to more easily locate 
program information and resources. 

During fiscal year 2014, GSA provided increased guidance to other 
landholding agencies with regard to the requirements of the McKinney-
Vento program. In addition to a joint webinar conducted with HUD and 
HHS in November 2013, GSA also provided training to twenty-five 
agencies while conducting the Real Property Utilization and Disposal 
Training classes during May through August of 2014. GSA also conducted
McKinney-Vento program training for the U.S. Department of Agriculture 
in November 2013 and to the National Aeronautics and Space 
Administration in August 2014. 

GSA agrees with GAO's suggestion that revisiting the scope of 
properties reported to HUD may be valuable and could limit current 
confusion, and is prepared to assist Congress with any information 
that may be needed for its consideration of the GAO suggestion. 

If you have any additional questions or concerns, please contact me at 
(202) 501-0800, or Ms. Lisa Austin, Associate Administrator, Office of 
Congressional and Intergovernmental Affairs, at (202) 501-0563. 

Sincerely, 

Signed by: 

Dan Tangerlini: 
Administrator: 

Enclosure: 

cc: David J. Wise, Director, Physical Infrastructures Issues, GAO. 

[End of section] 

Appendix VII: Comments from the Department of Health and Human 
Services: 

Department of Health and Human Services: 
Office of The Secretary: 
Assistant Secretary for Legislation: 
Washington, DC 20201: 

September 16, 2014: 

David J. Wise: 
Director, Physical Infrastructure Team: 
U.S. Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Mr. Wise: 

Attached are comments on the U.S. Government Accountability Office's 
(GAO) report entitled, "Federal Real Property: More Useful Information 
to Providers Could Improve the Homeless Assistance Program" (GAO-14-
739). 

The Department appreciates the opportunity to review this report prior 
to publication. 

Sincerely, 

Signed by: 

Jim R. Esquea: 
Assistant Secretary for Legislation: 

Attachment: 

General Comments Of The Department Of Health And Human Services (BBS) 
On The Government Account Ability Office's Draft Report Entitled: 
Federal Real Property: More Useful Information To Providers Could 
Improve The Homeless Assistance Program (GAO-14-739): 

The Department appreciates the opportunity to review and comment on 
this draft report. 

GAO Recommendation 1: 

HUD, GSA, HHS and USICH should work together to address the challenges 
that homeless assistance providers face with the Title V homeless 
assistance program by identifying what kinds of properties are most 
practical for homeless assistance. 

HHS Response 1: 

HHS non-concurs with GAO's recommendation. Under the current legal 
framework, determinations concerning what kinds of properties are most 
practical for homeless assistance purposes are outside the scope of 
HHS' authority. Pursuant to 42 U.S.C. § 11411, HUD is solely 
authorized to identify suitable property. If a property is found to be 
suitable by HUD after applying the criteria at 45 C.F.R. Part 12a.6, 
the individual landholding agency in control of the property is 
responsible for making a determination of availability. While HHS may 
assist potential applicants that have questions regarding a specific 
property that has been made available, the ultimate decision on the 
practicality of using available property for the potential applicant's 
purpose is solely the potential applicant's determination. 

GAO Recommendation 2: 

HUD, GSA, HHS and USICH should work together to address the challenges 
that homeless assistance providers face with the Title V homeless 
assistance program by developing a web-based source of information on 
the program for homeless assistance providers. 

HHS Response 2: 

HHS concurs with GAO's recommendation. HHS is in the midst of 
revamping its Federal Real Property Assistance website and will 
consult with HUD, GSA and the USICH on recommendations for the site 
and discuss other options relating to web-based sources of information 
on Title V, McKinney-Vento Homeless Assistance Act. 

[End of section] 

Appendix VIII: Comments from the U.S. Interagency Council on 
Homelessness: 

September 19, 2014: 

Mr. David Wise: 
Director: 
U.S. Government Accountability Office: 
441 G Street N.W. 
Washington, D.C. 20548: 

Dear Mr. Wise: 

This letter is in response to GAO's draft report entitled, Federal 
Real Property: More Useful Information to Providers Could Improve the 
Homeless Assistance Program (GAO-14-739). Thank you for the 
opportunity to review and comment on the report. 

USICH agrees that if the intent of Title V were fully realized, it 
could expand the inventory of properties dedicated to meeting the 
needs of people who experience homelessness. Yet, as the report 
indicates, the current legislative requirements related to 
identifying, determining suitability, listing, and categorizing 
properties are complex and cumbersome. Therefore, connections between 
available properties that are most likely to be useful to homelessness 
efforts and interested, qualified parties could be advanced by actions 
that provide clarity and permit agencies to make necessary changes. 

GAO recommended two actions relating to USICH: (1) collaborating with 
HUD, GSA, and HHS to identify the kinds of properties most practical 
for homeless assistance, and (2) developing a web-based source of 
information on the program for homeless assistance providers. 

With regards to the first recommendation, as reflected in GAO's 
recommendation to Congress, the scope of properties that agencies are 
required to report under Title V include large numbers of properties 
that could not viably be used for homelessness assistance. Therefore, 
improving identification of properties that are actually practical for 
homeless assistance cannot occur through collaboration alone, a 
legislative fix is an essential prerequisite. 

USICH concurs with the second recommendation that the development of a 
web-based system may be beneficial for disseminating information on 
available Federal real properties to interested stakeholders, 
including homeless assistance providers. 

If you have any further questions, please contact me at 
Laura.Zeilinger@usich.gov or 202-708-4663. 

Sincerely, 

Signed by: 

Laura Zeilinger: 
Executive Director: 

[End of section] 

Appendix IX: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David J. Wise, (202) 512-2834, or wised@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Amelia Shachoy, Teresa Spisak 
(Assistant Directors), Lindsay Bach, Jennifer Clayborne, Kathleen 
Gilhooly, Geoffrey Hamilton, Delwen Jones, Rosa Leung, John Mingus, 
Josh Ormond, Amy Rosewarne, and Elizabeth Wood made key contributions 
to this report. 

[End of section] 

Footnotes: 

[1] U.S. Department of Housing and Urban Development, The 2013 Annual 
Homeless Assessment Report (AHAR) to Congress, (Washington, D.C.: 
2013). Of the 610,042, 394,698 people were homeless in sheltered 
locations and 215,344 were living in unsheltered locations. 

[2] National Law Center on Homelessness and Poverty. This Land Is Your 
Land: How Surplus Federal Property Can Prevent and End Homelessness 
(Washington, D.C.: October 2013). 

[3] GAO, Federal Real Property: The Government Faces Challenges to 
Disposing of Unneeded Buildings. [hyperlink, 
http://www.gao.gov/products/GAO-11-370T] (Washington, D.C.: Feb. 10, 
2011). 

[4] GAO, High Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-13-283] (Washington, D.C.: February 
2013). 

[5] Pub. L. No. 100-77, 101 Stat. 482 (1987). The Stewart B. McKinney 
Homeless Assistance Act, enacted in 1987, was renamed the McKinney-
Vento Homeless Assistance Act in October 2000 by Pub. L. No. 106-400, 
114 Stat. 1675 (2000). For the purposes of this report, we will refer 
to this program as the Title V homeless assistance program. 

[6] GAO, Federal Real Property: Progress Made Toward Addressing 
Problems, but Underlying Obstacles Continue to Hamper Reform, 
[hyperlink, http://www.gao.gov/products/GAO-07-349] (Washington, D.C.: 
Apr. 13, 2007). 

[7] After preliminary audit work, we did not continue our work at VA 
because we learned that very little of VA's property becomes available 
for Title V purposes. 

[8] Altogether, GSA, HHS, and the other seven landholding agencies we 
reviewed account for almost 90 percent of real property held by the 
federal government in 2012. According to HUD officials, HUD is not a 
landholding agency. 

[9] The national advocacy organizations were the National Coalition 
for the Homeless and the National Law Center on Homelessness and 
Poverty. 

[10] A "landholding agency" is a federal department or agency with the 
statutory authority to control real property. 42 U.S.C. § 11411(i)(3). 

[11] See app. III for a list of the 25 landholding agencies HUD 
currently canvasses. 

[12] 24 C.F.R. § 581.6 (a); 41 C.F.R. § 102-75.1185(a); 45 C.F.R. § 
12a.6(a). 

[13] 42 U.S.C § 11411(b), (c). 

[14] 24 C.F.R. § 581.5(c); 41 C.F.R. § 102-75.1180(c); 45 C.F.R. § 
12a.5(c). 

[15] If the application is for a deed conveyance of the property 
(meaning that the title of the property passes from the government to 
the grantee) as opposed to a lease, the private sector organizations 
must be incorporated under section 501(c)(3) as tax-exempt 
organizations. 

[16] Written notice of intent to apply for a property may also be 
filed after the 60-day holding period. Such applications may be 
approved if the property remains available for homeless assistance use. 

[17] 42 C.F.R. § 581.5(f); 41 C.F.R. § 102-75.1180(f); 45 C.F.R. § 
12a.5(f). 

[18] 45 C.F.R § 12a.9(e)(2). 

[19] According to HHS, reversion for reasons of noncompliance is 
typically a measure of last resort and undertaken only when other 
attempts at bringing the grantee into compliance or a retransfer to 
another provider have failed. 

[20] Pub. L. No. 103-421, 108 Stat. 4346. 

[21] Pub. L. No. 101-510, 104 Stat. 1485,1808. 

[22] Such properties are subject to a process that involves Local 
Redevelopment Authorities' (LRA) consultation with representatives of 
the homeless in the communities in the vicinity of the installation 
concerned to determine the need for homeless assistance and how 
portions of the former military installations might be used to meet 
it. LRA redevelopment plans are reviewed by HUD. Homeless assistance 
providers apply to the LRA for property on such installations that 
might be used to assist the homeless. 

[23] The Federal Real Property Profile, created pursuant to Executive 
Order 13327, is the federal government's inventory system that is to 
contain data on all real property assets within and outside the United 
States, including improvements on federal land. Executive Order No. 
13327, Federal Real Property Asset Management, 69 Fed. Reg. 5897 (Feb. 
6, 2004). 

[24] Federal Property Disposal: Hearing before the House Committee on 
Oversight and Government Reform, 112TH Cong. (2011) (statement of Ms. 
Maria Foscarinis, Executive Director, National Law Center on 
Homelessness & Poverty). 

[25] GAO, Federal Real Property: Most Public Benefit Conveyances Used 
as Intended, but Opportunities Exist to Enhance Federal Oversight. 
[hyperlink, http://www.gao.gov/products/GAO-06-511] (Washington, D.C.: 
June 21, 2006). 

[26] According to our analysis of HHS data, properties made available 
for "off-site use only" received fewer than 30 notices of interest 
from 1988 through March 31, 2014. 

[27] United States Interagency Council on Homelessness. Opening Doors: 
Appendix: Programs for People Experiencing Homelessness 2011 
(Washington, D.C.: 2011). 

[28] HUD officials were uncertain when in the early 1990s the database 
was created and about the number of properties that were added to the 
database screened prior to its creation. 

[29] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington D.C.: November 1999). 

[30] Executive Order No. 13642, Making Open and Machine Readable the 
New Default for Government Information, 78 Fed. Reg. 28111 (May 14, 
2013). 

[31] 42 U.S.C. §11411(c)(1)(C). 

[32] GAO, Federal Real Property: Progress Made Toward Addressing 
Problems, but Underlying Obstacles Continue to Hamper Reform. 
[hyperlink, http://www.gao.gov/products/GAO-07-349] (Washington, D.C: 
Apr. 13, 2007). 

[33] See Court Order accompanying National Law Center on Homelessness 
and Poverty v. Veterans Admin., 931 F. Supp. 2d 167, 174 (D.D.C. 2013). 

[34] Altogether, we interviewed 11 homeless assistance providers, 
including representatives from eight case study properties that were 
acquired under Title V and three providers whose applications for 
property were not approved by HHS. 

[35] The Miami-Dade County Homeless Trust is an organization within 
the Miami-Dade County government that is responsible for coordinating 
local homeless systems of care. 

[36] National Law Center on Homelessness and Poverty. This Land Is 
Your Land: How Surplus Federal Property Can Prevent and End 
Homelessness (Washington, D.C.: October 2013). 

[37] See for example, GAO, Video Marketplace: Competition Is Evolving, 
and Government Reporting Should Be Reevaluated. [hyperlink, 
http://www.gao.gov/products/GAO-13-576] (Washington, D.C.: June 25, 
2013), and GAO, K-12 Education: Selected States and School Districts 
Cited Numerous Federal Requirements As Burdensome, While Recognizing 
Some Benefits. [hyperlink, http://www.gao.gov/products/GAO-12-672] 
(Washington, D.C.: June 27, 2012). 

[38] HUD has taken steps to help homeless assistance providers learn 
about properties such as a listserv and a call-in line that providers 
can use to obtain information about properties. 

[39] According to the implementing regulations, HHS is to assist 
applicants in obtaining any pertinent environmental information in 
GSA, HUD or any other landholding agency's possession. 45 C.F.R. 
§12a.9(b)(8). 

[40] National Law Center on Homelessness and Poverty. This Land Is 
Your Land: How Surplus Federal Property Can Prevent and End 
Homelessness (Washington, D.C.: October 2013). 

[41] HHS concluded in 1992 that long-term housing did not constitute 
an appropriate use of property authorized under Title V and 
subsequently adopted the HUD standard, limiting occupancy to 24 
months. However, HHS revised this policy effective September 1, 2006, 
to include permanent supportive housing, i.e., long-term, affordable 
housing that is linked to appropriate supportive health and social 
services that enable homeless individuals and homeless families with 
disabilities to maintain housing. 71 Fed. Reg.38882. (July 10, 2006). 

[42] HHS officials noted that it requires the grantees wishing to 
change their approved program to address similar questions for the 
change as were required in the initial application. For example, the 
grantee must identify the need for the revised program and the funding 
available to implement the change. This information is used by HHS to 
make a determination on the need for the revised program within the 
community and if it is sustainable for the duration of the deed or 
lease. 

[43] United States Interagency Council on Homelessness. Opening Doors: 
Appendix: Programs for People Experiencing Homelessness 2011 
(Washington, D.C.: 2011). 

[44] [hyperlink, http://www.gao.gov/products/GAO-07-349]. 

[45] [hyperlink, http://www.gao.gov/products/GAO-13-283]. 

[46] [hyperlink, http://www.gao.gov/products/GAO-12-645]. 

[47] GAO, Managing for Results: Key Considerations for Implementing 
Interagency Collaborative Mechanisms, [hyperlink, 
http://www.gao.gov/products/GAO-12-1022] (Washington, D.C.: Sept. 27, 
2012). 

[48] United States Interagency Council on Homelessness. Opening Doors: 
Appendix: Programs for People Experiencing Homelessness 2011 
(Washington, D.C.: 2011). 

[49] GAO, Managing for Results: Implementation Approaches Used to 
Enhance Collaboration in Interagency Groups, [hyperlink, 
http://www.gao.gov/products/GAO-14-220] (Washington, D.C.: Feb. 14, 
2014). 

[50] 42 U.S.C. §11411. 

[51] After preliminary audit work, we did not continue our work at VA 
because we learned that very little of VA's property becomes available 
for Title V purposes. 

[52] According HUD officials, HUD is not a landholding agency. 

[53] We excluded from this report facilities on military bases closed 
after 1994 and subject to the provisions of the Base Closure Community 
Redevelopment and Homeless Assistance Act of 1994 (Redevelopment Act) 
(Pub. L. No.103-421, 108 Stat. 4346) but are reviewing implementation 
of the Act's provisions separately and will report on this in 2015. 

[54] Representative of the other four organizations were unable to 
participate because of unanticipated schedule conflicts. 

[End of section] 

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