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Report to Congressional Requesters:

United States General Accounting Office:

GAO:

September 2003:

Capacity Building:

Section 4 Program Has Expanded and Evolved:

GAO-03-975:

GAO Highlights:

Highlights of GAO-03-975, a report to Chairs, House Subcommittee on 
Oversight and Investigations; House Subcommittee on Housing and 
Community Opportunity, Committee on Financial Services

Why GAO Did This Study:

Congress recognized the importance of building the capacity of 
community development organizations by passing Section 4 of the HUD 
Demonstration Act of 1993. The act authorized the Department of 
Housing and Urban Development (HUD) to partner with several national 
nonprofit organizations that provide funding to these community groups 
for such things as training, staff salaries, office equipment and 
supplies, and management information systems. In 2002, HUD provided 
$31 million for capacity-building activities. To help Congress with 
its oversight of Section 4, we reviewed the evolution and use of 
Section 4 funding, the importance of Section 4 funding to private 
sector involvement, and the management controls and measurements that 
are in place to assess Section 4. 

What GAO Found:

We found that Section 4 has evolved from a narrowly targeted 
initiative that focused on providing funding for capacity building in 
23 urban areas to a broader program that funds groups and activities 
in urban, rural, and tribal areas nationwide. The four organizations 
(grantees) use Section 4 funding to provide a variety of capacity-
building support to their subrecipients. These subrecipients are 
nonprofit organizations that undertake locally targeted initiatives in 
areas such as economic development, low-income housing construction, 
and job training. The Section 4 funds that the grantees receive help 
leverage private sector funding and in-kind contributions such as land 
and equipment, pro bono legal services, office space, and voluntary 
labor. Since the four grantees became eligible for Section 4 funding, 
they have leveraged nearly $800 million in cash and in-kind 
contributions from the private sector. 

HUD is responsible for ensuring that Section 4 funds are used 
according to federal law and regulations and that grantees are 
utilizing funds efficiently and effectively. However, HUD relies on 
grantees to oversee their subrecipients. The grantees had far-reaching 
organizational structures and processes in place to monitor and 
control their subrecipients. But we found that one of the seven 
subrecipients we tested for monitoring and control procedures had 
reimbursed a subrecipient for an item that was prohibited by the 
Office of Management and Budget (OMB). While HUD has the overall 
responsibility to prevent such internal control failures, the cost-
effectiveness of adding additional federal controls must be weighed 
against the amount of the federal dollars involved. We believe that as 
long as HUD and the grantees remain vigilant, additional controls are 
not necessary at this time. HUD is taking steps to develop a framework 
for assessing the effectiveness of its technical assistance programs 
and will take part in an OMB Program Assessment Rating Tool review.

What GAO Recommends:

GAO recommends that HUD take steps to recover the grant funds one 
Section 4 grantee used to cover a bad debt.

www.gao.gov/cgi-bin/getrpt?GAO-03-975.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact Thomas McCool at 
(202) 512-8678 or mccoolt@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Section 4 of the HUD Demonstration Act of 1993 Has Evolved and Expanded 
Over the Years:

Federal Funding Has Encouraged Private Sector Involvement in the 
Section 4 Grantees' Community Development Initiatives:

HUD's Grantee Monitoring and Oversight Is Limited:

Conclusions:

Recommendation for Executive Action:

Agency Comments:

Scope and Methodology:

Appendix I: Contact and Staff Acknowledgments:

GAO Contact:

Acknowledgments:

Tables:

Table 1: NCDI Funding, 1991-2004 (in millions of dollars):

Table 2: Section 4 Funding, 1994-2003 (in millions of dollars):

Table 3: Additional Federal Funding for Capacity-Building and Technical 
Assistance (in millions of dollars):

Table 4: Private Sector Funding (in millions of dollars):

Figures:

Figure 1: The Organizational Structure of Section 4:

Figure 2: Locations of HFHI Affiliates Receiving Section 4 Funds 
between 1997 and 2001:

Figure 3: Cities Where YouthBuild USA Affiliates Received Section 4 
Funds between 1997 and 2001:

Figure 4: Effect of Funding for CHAPA, an Enterprise Subrecipient, for 
Technology Improvements:

Figure 5: Enterprise and LISC Subrecipient Rural County Coverage:

Abbreviations:

CDC: Community Development Corporation:  

CDBG: Community Development Block Grant:  

CHAPA: Citizen's Housing and Planning Association:  

Enterprise: The Enterprise Foundation:  

GED: General Equivalency Diploma:  

HFHI: Habitat for Humanity International:  

HOME: Home Investment Partnerships Program:  

HOPWA: Housing Opportunities for Persons with AIDS:  

HUD: U.S. Department of Housing and Urban Development:  

GIS: Geographical Information Software:  

LISC: Local Initiatives Support Corporation:  

NCDI: National Community Development Initiative:  

OMB: Office of Management and Budget:  

PART: Program Assessment Rating Tool:  

YBUSA: YouthBuild USA:

United States General Accounting Office:

Washington, DC 20548:

September 15, 2003:

The Honorable Sue W. Kelly 
Chairman, 
Subcommittee on Oversight and Investigations 
Committee on Financial Services 
House of Representatives:

The Honorable Bob Ney 
Chairman, 
Subcommittee on Housing and Community Opportunity 
Committee on Financial Services 
House of Representatives:

For fiscal years 1997 through 2002, the Department of Housing and Urban 
Development's (HUD) budget for 20 capacity-building and technical 
assistance programs was over $860 million.[Footnote 1] Of these funds, 
almost $150 million was specifically designated to build the capacity 
of local community development and affordable housing organizations 
through the Section 4 program. Since its inception in 1993, the program 
has provided capacity-building funds and services to over 1,590 local 
organizations in more than 783 cities nationwide, either through direct 
grants or substantial technical assistance activities.

To assist you with your oversight of the Section 4 capacity-building 
program, you asked us to:

* describe how funding under Section 4 of the HUD Demonstration Act of 
1993 has evolved and expanded over the years, how grantees use Section 
4 funding, and what other federal funding is available for capacity 
building;

* determine the importance of Section 4 funding to private sector 
involvement in community development initiatives; and:

* determine how HUD and Section 4 grantees control the management and 
measure the impact of Section 4 programs.

To address these objectives, we reviewed public laws, federal 
regulations, HUD directives, budget documents, and other materials that 
describe the Section 4 program and authorized/appropriated funding 
amounts. We interviewed HUD headquarters officials and grantee and 
subrecipient officials at both the national headquarters and local 
office levels. We visited subrecipients in eight cities, and at several 
we conducted file reviews to evaluate grantee internal controls. 
Finally, we interviewed private funders that provided grants or loans 
to the grantees and subrecipients. We conducted our work in accordance 
with generally accepted government auditing standards in Baltimore, MD; 
Boston, MA; Cleveland, OH; Frederick, MD; Hughesville, MD; Kingston, 
RI; Americus, GA; and Washington, D.C. Our scope and methodology are 
discussed in greater detail at the end of this letter.

Results in Brief:

Section 4 of the HUD Demonstration Act of 1993 has evolved from a 
narrowly targeted initiative that focused on providing funding for 
capacity building in 23 urban areas to a broader program that funds 
groups and activities in urban, rural, and tribal areas nationwide. 
Section 4 authorized HUD to become an equal partner with several 
private foundations and financial institutions in the already existing 
National Community Development Initiative (NCDI). NCDI, currently known 
as Living Cities, began in 1991 as a partnership of public and private, 
for-profit and nonprofit funders committed to revitalizing urban 
communities. NCDI enlisted the assistance of two nationally recognized 
community building organizations, the Local Initiatives Support 
Corporation (LISC) and the Enterprise Foundation (Enterprise) to work 
with local community development corporations (CDC) in 23 
cities.[Footnote 2] In 1997, eligibility for Section 4 funding was 
expanded to include Habitat for Humanity International (HFHI), 
YouthBuild USA (YBUSA) and activities in cities where NCDI was not 
active and in rural and tribal areas (fig. 1). Since then, the four 
designated grantees have delivered Section 4 funds and services as 
operating support to their subrecipients (CDCs and 
affiliates).[Footnote 3] The grantees determine their individual 
approaches and administer their funds in a variety of ways. Grantees 
can also tap into other federal funding sources such as Community 
Development Block Grant (CDBG) funding for capacity-building and 
technical assistance.

Figure 1: The Organizational Structure of Section 4:

[See PDF for image]

[End of figure]

While external factors such as economic trends and private sector 
interests made it difficult to demonstrate empirically that Section 4 
funding directly influenced private sector involvement in community 
development initiatives, all four grantees and most of the private 
foundations and lenders we contacted stressed the importance of federal 
funding in leveraging funds from the private sector. For example, one 
senior executive from a major lending institution indicated that 
federal participation in NCDI provides funders with both a symbolic and 
a financial incentive to join the NCDI consortium. Symbolically, 
federal funding provides a sense of credibility to NCDI, as funders see 
federal participation as a sign of good housekeeping and reduced risk. 
Financially, federal participation adds more money to NCDI capacity-
building initiatives, in turn enabling subrecipients to raise more 
private funding. In addition, Section 4 calls for significant private 
sector participation because every dollar that is provided to grantees 
must be matched with three dollars from private sources. Since federal 
regulations permit contributions in the form of cash or verifiable 
third party in-kind services, private sector involvement comes in the 
form of grants, loans, donated land and equipment, pro bono legal 
services, donated office space, and voluntary labor.[Footnote 4] 
Although all four grantees are able to raise these required matching 
funds, each grantee has its own policies and may raise funds 
nationally, locally, or both. Since the four grantees became eligible 
for Section 4 funding, they have raised nearly $800 million in cash and 
in-kind contributions from private foundations and businesses.

HUD uses desk audits and other document reviews to assess grantees' use 
of funds and relies on grantees to monitor their subrecipients. 
However, HUD does not measure the impact of its grants. HUD is 
responsible for ensuring that Section 4 funds are used according to 
federal law and regulations and that grantees are utilizing funds 
efficiently and effectively. HUD carries out this responsibility 
through limited desk reviews of work plans that outline proposed 
activities and expected outcomes; quarterly and annual progress reports 
that determine whether grantees are achieving their stated goals; and 
payment vouchers and supporting documentation, which help ensure that 
federal funds are used only for eligible activities. HUD receives the 
same reports and follows the same processes for both NCDI and non-NCDI 
activities but reviews NCDI work plans in consort with other NCDI 
funders and non-NCDI activities on its own. HUD depends on grantees to 
provide oversight of their subrecipients. While it appeared that 
grantees maintained far-reaching organizational structures and 
processes to monitor and control their subrecipients, we found that one 
grantee had reimbursed a subrecipient for a bad debt, an activity that 
is prohibited by the Office of Management and Budget (OMB).[Footnote 5] 
HUD does not currently measure the impact of Section 4 funding but 
relies on its grantees to measure the impact of their individual 
programs. However, HUD is taking steps to develop a framework for 
assessing the effectiveness of its technical assistance programs and 
will take part in an OMB Program Assessment Rating Tool review (PART) 
designed to help in making informed budget decisions, supporting 
management, identifying program design problems, and promoting 
performance measurement and accountability.[Footnote 6]

Background:

In 1991, a group of for-profit and nonprofit public and private funders 
started NCDI, currently known as Living Cities, to revitalize urban 
communities.[Footnote 7] NCDI is composed of 17 major corporations, 
foundations, and the federal government--HUD and the Office of 
Community Services of the Department of Health and Human Services. In 
its first decade of operation, NCDI assembled a community development 
system composed of:

* two of the largest national community-building organizations to 
administer the initiative--LISC and Enterprise;

* 300 CDCs in 23 cities; and:

* local operating support collaboratives, which include local 
foundations, banks, corporations, and local governments, that identify 
and draw on local technical expertise and governmental and economic 
resources and use them to sustain and enhance the capacity of CDCs.

As of September 1, 2001, NCDI had provided $234.8 million to its 23 
cities. Of this amount, about three-quarters was for project funding 
and the balance, about $60 million, supported capacity building with 
operating grants and training.

LISC, founded in 1979 and headquartered in New York City, is the 
largest community-building organization. LISC's mission, involving 
hundreds of CDCs, is to rebuild whole communities by supporting these 
groups. LISC operates local programs in 38 urban program areas and 70 
rural communities. According to LISC, it has raised more than $4 
billion from over 2,200 investors, lenders, and donors, which has 
leveraged an additional $6 billion in public and private sector funds. 
In addition, according to LISC, it has helped 2,200 CDCs build or 
rehabilitate more than 110,000 affordable homes, created over 14 
million square feet of commercial and community space, and helped 
generate 40,000 jobs.

Enterprise was founded in 1982 as a vehicle for helping low-income 
people revitalize their communities. Headquartered in Columbia, 
Maryland, Enterprise has offices in 18 communities across the nation. 
Enterprise works with a network of 2,200 nonprofit organizations, 
public housing authorities, and Native American tribes in 800 
locations, including more than 100 CDCs. The Enterprise Foundation 
provides these organizations with technical assistance, training, short 
and long-term loans, equity investments, and grants. According to 
Enterprise, it has raised nearly $430 million to support community-
based development that has helped produce 17,000 affordable homes and 
assisted 20,000 low-income individuals in finding employment.

HFHI, founded in 1976 and headquartered in Americus, Georgia, is a 
nonprofit ecumenical Christian housing ministry (faith-based 
organization) seeking to eliminate substandard housing. HFHI builds and 
rehabilitates houses with the help of homeowner (partner) families, 
volunteer labor, and donations of money and materials. Work is done at 
the local community level by affiliates that coordinate all aspects of 
home building, including fund-raising, building site selection, partner 
family selection and support, construction, and mortgage servicing. 
HFHI provides its affiliates with information, training, and a variety 
of other support services. Affiliates are primarily volunteer driven, 
though some have their own staff. Affiliates are monitored and 
supported by HFHI staff across the country. HFHI currently has over 
1,669 affiliates, and in 27 years has built over 150,000 houses 
worldwide, including more than 40,000 homes in the United States. 
Figure 2 shows the 526 cities where HFHI affiliates have directly 
received Section 4 funds.

Figure 2: Locations of HFHI Affiliates Receiving Section 4 Funds 
between 1997 and 2001:

[See PDF for image]

[End of figure]

YBUSA was founded in 1990 and is headquartered in Somerville, 
Massachusetts. It is a national nonprofit organization that provides 
capacity-building grants on a competitive basis to support the efforts 
of organizations that are planning to or are operating Youthbuild 
programs in their communities, many of which are funded by the HUD 
Youthbuild grant program. [Footnote 8] A Youthbuild program is a 
comprehensive youth and community development program as well as an 
alternative school. Youthbuild programs, which offer job training, 
education, counseling, and leadership development opportunities 
through the construction and rehabilitation of affordable housing, 
serve young adults ages 16 to 24 in their own communities. Participants 
split their time between the construction site and the classroom, where 
they earn GEDs or high school diplomas and prepare for jobs or college. 
The buildings that are constructed or rehabilitated during the program 
are primarily low-income housing. YouthBuild USA serves as the national 
intermediary and support center for over 200 Youthbuild programs. Over 
half of the Youthbuild programs are members of YBUSA's affiliated 
network. As shown in figure 3, YBUSA affiliates located in 106 cities 
have received Section 4 funds from 1997 to 2001.

Figure 3: Cities Where YouthBuild USA Affiliates Received Section 4 
Funds between 1997 and 2001:

[See PDF for image]

[End of figure]

Section 4 of the HUD Demonstration Act of 1993 Has Evolved and Expanded 
Over the Years:

The scope of eligible activities funded by Section 4 of the HUD 
Demonstration Act of 1993 has changed over the years. Originally the 
act focused on providing funding for capacity building in 23 urban 
areas. Currently, it provides funding to groups and activities in 
urban, rural, and tribal areas nationwide. Section 4 authorized HUD to 
join other corporations and foundations as an equal partner in NCDI to 
develop the capacity and ability of CDCs in 23 cities. In 1997, Section 
4 was expanded to include two more grantees, HFHI and YBUSA as well as 
more cities, and rural and tribal areas. The grantees' organizational 
structures and missions vary, as do their strategies for awarding 
Section 4 funds and the types of activities they authorize. Each 
grantee has initiatives in rural and tribal areas.[Footnote 9] 
Additional federal funding, such as Community Development Block Grants, 
is also available to grantees for capacity building and technical 
assistance.

Section 4 Provides Capacity-Building Funding to Four Organizations:

NCDI in 1991 started with seven large national foundations and a major 
insurance company and was administered by LISC and Enterprise. This 
consortium of funders believed CDCs could achieve greater and more 
lasting success if they could count on a significant reliable 
commitment of multiyear operating support, project financing, technical 
assistance, and training. To date, NCDI has had four phases (rounds) of 
funding. In the first phase (1991-93), NCDI funders pledged $62.9 
million (see table 1). With the enactment of Section 4, HUD joined 
phase II of NCDI, which also included 12 private foundations and 
financial institutions, as an equal partner.[Footnote 10] Congress' 
goal in authorizing HUD to participate in NCDI was to develop the 
capacity and ability of CDCs to undertake community development and 
affordable housing projects and programs. HUD's involvement resulted in 
some changes to the way funds were disbursed. While the foundations 
provided funding through Living Cities (NCDI), which in turn 
distributed grant funds to LISC and Enterprise, HUD distributed its 
funding directly to LISC and Enterprise. In addition, unlike other NCDI 
funders, HUD provided funding only after expenses were incurred, 
monitored funding more closely, and restricted uses to capacity-
building activities. In 2001, 17 foundations and corporations committed 
another 10 years to the initiative.

Table 1: NCDI Funding, 1991-2004:

Dollars in millions.

Living Cities Initiative: 

Private funder; Dollars in millions: NCDI I 1991-1993: $62.86; NCDI II 
1994-1997: $67.85; NCDI III 1998-2001: $87; Living Cities (Second 
Decade) 2001-2004: $93.7; Total: $311.41.

HUD; Dollars in millions: NCDI I 1991-1993: 0; NCDI II 1994-1997: 20; 
NCDI III 1998-2001: 16; Living Cities (Second Decade) 2001-2004: 20; 
Total: 56.

Total; Dollars in millions: NCDI I 1991-1993: $62.86; NCDI II 1994-
1997: $87.85; NCDI III 1998-2001: $103; Living Cities (Second Decade) 
2001-2004: $113.7; Total: $367.41.

Source: NCDI.

[End of table]

Congress did not appropriate funds for HFHI and YBUSA until 1997 (see 
table 2).[Footnote 11] At that time, LISC and Enterprise were given the 
option of using Section 4 funding to continue NCDI activities in the 
original 23 cities or to undertake new non-NCDI activities in other 
cities, which expanded the geographical dispersion of Section 4 
funding. In addition, Congress required the grantees to set aside a 
portion of Section 4 funding for rural and tribal areas. Unlike the 
NCDI activities, whose funding objectives were determined by the 
responsible funders, LISC and Enterprise worked directly with HUD in 
creating the objectives for non-NCDI cities.

Table 2: Section 4 Funding, 1994-2003:

Dollars in millions.

1994; Enterprise: NCDI: $10; Enterprise: non-NCDI: $0; LISC: 
NCDI: $10; LISC: non-NCDI: $0; YBUSA: $0; HFHI: $0; Total $ allocated 
for Section 4: $20.

1995; Enterprise: NCDI: 0; Enterprise: non-NCDI: 0; LISC: 
NCDI: 0; LISC: non-NCDI: 0; YBUSA: 0; HFHI: 0; Total $ allocated for 
Section 4: 0.

1996; Enterprise: NCDI: 5; Enterprise: non-NCDI: 0; LISC: 
NCDI: 5; LISC: non-NCDI: 0; YBUSA: 0; HFHI: 0; Total $ allocated for 
Section 4: 10.

1997; Enterprise: NCDI: 3; Enterprise: non-NCDI: 4.6; LISC: 
NCDI: 3; LISC: non-NCDI: 4.6; YBUSA: 7.6; HFHI: 7.6; Total $ allocated 
for Section 4: 30.4.

1998; Enterprise: NCDI: 0; Enterprise: non-NCDI: 7.5; LISC: 
NCDI: 2; LISC: non-NCDI: 5.5; YBUSA: 0; HFHI: 0; Total $ allocated for 
Section 4: 15.

1999; Enterprise: NCDI: 0; Enterprise: non-NCDI: 7.5; LISC: 
NCDI: 2; LISC: non-NCDI: 6; YBUSA: 0; HFHI: 0; Total $ allocated for 
Section 4: 15.

2000; Enterprise: NCDI: 0; Enterprise: non-NCDI: 10; LISC: 
NCDI: 2; LISC: non-NCDI: 8.2; YBUSA: 2.5; HFHI: 3.8; Total $ allocated 
for Section 4: 26.3.

2001; Enterprise: NCDI: 10; Enterprise: non-NCDI: 2.5; LISC: 
NCDI: 10; LISC: non-NCDI: 2.5; YBUSA: 4; HFHI: 3.5; Total $ allocated 
for Section 4: 32.5.

2002; Enterprise: NCDI: 0; Enterprise: non-NCDI: 12.5; LISC: 
NCDI: 1.4; LISC: non-NCDI: 11; YBUSA: 2; HFHI: 4; Total $ allocated for 
Section 4: 30.9.

2003; Enterprise: NCDI: 0; Enterprise: non-NCDI: 14; LISC: 
NCDI: 3; LISC: non-NCDI: 11; YBUSA: 2; HFHI: 4.2; Total $ allocated for 
Section 4: 34.2.

Total; Enterprise: NCDI: $28; Enterprise: non-NCDI: $58.6; 
LISC: NCDI: $37.7; LISC: non-NCDI: $48.8; YBUSA: $18.1; HFHI: $23.1; 
Total $ allocated for Section 4: $214.3.

Source: HUD.

[End of table]

Grantees Use a Variety of Methods to Help Build Capacity:

LISC and Enterprise are national organizations that use local program 
offices to provide financial and technical support to CDCs. The staff 
at the local program offices work with CDCs to achieve community-driven 
goals. For example, through its Boston local office, LISC provided 
several Section 4 grants to the Madison Park Development Corporation. A 
$78,000 grant was used to help the CDC improve the Dudley Square 
Business district in the Roxbury neighborhood of Boston. The Cleveland 
Enterprise office provided Section 4 funds to the Cleveland 
Neighborhood Partnership Program, a local support collaborative that 
provides organizational and real estate development and neighborhood 
planning for Cleveland CDCs.

According to HFHI and YBUSA officials, these organizations provide 
direct grants to affiliates but operate somewhat differently. HFHI has 
provided grants to affiliates on a 3-year diminishing basis to hire new 
staff or establish warehouse facilities, with an expectation of 
increasing house production by at least 15 percent. In addition, HFHI 
has established regional support centers to bring technical assistance 
closer to affiliates. YBUSA uses Section 4 funds to provide a variety 
of grants to its affiliated network, such as operating grants, program 
enhancement grants, special assistance grants, and scholarships to 
staff and students. In addition, YBUSA has used Section 4 funds to 
build its capacity to serve as a national support center and to provide 
technical assistance and training.

LISC and Enterprise consider the subrecipient's stage of development 
when making Section 4 funding decisions. For example, a new 
organization might receive Section 4 funds to pay for a portion of the 
salary of the executive director, whereas more established CDCs might 
receive funding to upgrade their financial management software. All 
grantees stressed that because capacity building takes time, they 
provide multiyear support to subrecipients. However, three of the four 
grantees indicated that they generally fund subrecipients in ways that 
encourage the organizations to become financially independent. 
Officials from LISC and Enterprise explained that although some 
subrecipients receive multiple grants for several years, the grants are 
small enough to keep subrecipients from becoming dependent on Section 4 
funds for daily operations. As noted earlier, HFHI's grants, which are 
provided to hire new staff, diminish over a 3-year period. According to 
HFHI, the affiliates' gradual absorption of staff costs leads to 
independence from--rather than dependence on--federal funding. YBUSA, 
however, has provided Section 4 funding to affiliates to pay for 
general operations during years when they had not received funding 
under HUD's Youthbuild program.

Generally, Section 4 funds are used to pay for staff salaries, 
training, technology, and office supplies and equipment and to fund the 
operating support collaboratives. For example, with its 1997 funds HFHI 
provided direct grants to 60 affiliates to pay for staff salaries 
(usually an executive director). The YouthBuild Boston affiliate used 
Section 4 funds to hire an administrative coordinator and enhance its 
technological capabilities. The Washington, D.C., LISC office provided 
Section 4 funding to a local CDC to pay for some staff training and to 
purchase equipment and other supplies to outfit a homebuyer's training 
center. Enterprise has used Section 4 funds to develop on-line tools, 
such as a best practices database, and to bring current technology to 
CDCs. For example, Enterprise awarded one nonprofit organization, 
Citizen's Housing and Planning Association (CHAPA) in Boston, Section 4 
funds to administer the NET-Works program, a program to enhance the 
technological capacity of CDCs in the New England region. As a result, 
36 CDCs received computer equipment, Internet access, and assistance in 
developing websites. Figure 4 illustrates the broad impact that Section 
4 funding had for this nonprofit organization on other CDCs.

Figure 4: Effect of Funding for CHAPA, an Enterprise Subrecipient, for 
Technology Improvements:

[See PDF for image]

[End of figure]

Rural Areas Now Have Access to Section 4 Funding:

Congress did not require grantees to set aside Section 4 funding for 
rural and tribal areas until 1997.[Footnote 12] All four grantees 
currently have initiatives that focus on these areas. For example, LISC 
has a rural office that supports both a national program and a program 
in the Mississippi River Delta Region of the United States covering 56 
counties and parishes. In fiscal years 1997 through 2002, LISC awarded 
Section 4 grants totaling approximately $9 million to rural CDCs. 
Enterprise has awarded $6.2 million in Section 4 grants to rural CDCs. 
Unlike LISC, Enterprise does not have a rural office. Enterprise 
services its rural and tribal subrecipients through partnerships with 
other state and regional rural agencies and the Housing Assistance 
Council, which administers Enterprise's Rural Capacity Building 
Initiative, and through its regional and local office 
structure.[Footnote 13] Although 218 of the 1,003 LISC and Enterprise 
CDCs provide services to rural and tribal areas, many of them cover 
large geographical areas. For example, 57 of the 72 rural CDCs that are 
funded by LISC, operate in more than one county, and 64 of the 146 
rural CDCs that are funded by Enterprise operate in more than one 
county. Figure 5 shows the cities where LISC and Enterprise 
subrecipients who work in rural areas are located and the multiple 
counties they serve.

Figure 5: Enterprise and LISC Subrecipient City and Rural County 
Coverage:

[See PDF for image]

[End of figure]

HFHI makes an effort to reserve at least one-third of its Section 4 
funding for its rural affiliates. HFHI awarded $4.6 million of its 
fiscal year 1997 Section 4 funds to 60 affiliates of which 33 were 
rural. According to YBUSA officials, meeting the required set-aside has 
been a challenge. YBUSA's outreach efforts have included encouraging 
rural affiliates to apply for planning, operating, and program 
enhancement grants and for specialized technical assistance. According 
to a YBUSA official, over the course of the 1997 grant, about $2.5 
million of YBUSA's $7.6 million allocation was focused on rural and 
tribal and partly rural and tribal programs. Of this amount, about $1.3 
million was for direct grants to sites and about $1.2 million was for 
services to sites. A YBUSA official told us that as of July 2003, 84 of 
the 203 operating Youthbuild programs were rural and partly rural.

Grantees Receive Capacity-Building Funding from Other Federal Programs:

LISC, Enterprise, HFHI, and YBUSA also receive capacity-building and 
technical assistance funds from other HUD programs (table 3). The 
primary difference between Section 4 funding and other federal funding 
is that the other federal funding for capacity-building and technical 
assistance is generally awarded competitively, while Section 4 funding 
is noncompetitive. Several federal programs offer capacity-building 
funds: CDBG, HOME, and Housing Opportunities for Persons with AIDS 
(HOPWA). All grantees' Section 4 capacity-building funds exceed those 
received from other federal programs.

Table 3: Additional Federal Funding for Capacity-Building and Technical 
Assistance:

Dollars in millions.

LISC; Dollars in millions: Total other federal funding: 8.6; 
Federal program: CDBG Technical Assistance; HOME Technical Assistance 
(1994-2002).

Enterprise; Dollars in millions: Total other federal funding: 13.1; 
Federal program: CDBG Technical Assistance; HOME Technical 
Assistance; HUD Technical Assistance /Capacity Building; HOPWA 
Technical Assistance (1995-2002).

YBUSA; Dollars in millions: Total other federal funding: 20.2; 
Federal program: Youthbuild program (1997-2002); Corp. for National and 
Community Service for AmeriCorps (1997-2003); U.S. Dept. of Labor for 
Welfare to Work (1998-2001).

HFHI; Dollars in millions: Total other federal funding: 7.5; 
Federal program: Self-help Homeownership Opportunity Program (1999).

Source: LISC, Enterprise, YBUSA, and HFHI.

[End of table]

Federal Funding Has Encouraged Private Sector Involvement in the 
Section 4 Grantees' Community Development Initiatives:

While it was difficult to demonstrate empirically that Section 4 
directly influenced private sector involvement in community development 
activities, funders and grantees said that federal involvement served 
as a catalyst for private fund-raising and provided credibility to 
subrecipients in terms of their ability to comply with the requirements 
that are associated with federal funding. Some local funders of CDCs 
and affiliates were not aware of the specific Section 4 funding the 
subrecipients received but indicated that both federal funding and 
diverse funding streams are important. Since matching funds can be 
raised either nationally, locally, or a combination of both, each 
grantee employs its own matching policy and raises funds from 
foundations, corporations, banks, individual donors, and 
nongovernmental sources. Since the creation of Section 4, grantees have 
raised nearly $800 million from the private sector, in matching and 
other cash and in-kind contributions.

Grantees and Private Contributors Generally Believe that Federal 
Funding Is Important to Private Sector Participation:

The grantees and nearly all of the private lenders and foundations we 
contacted stressed the importance of federal funding in leveraging 
funds from the private sector. For example, officials from LISC, 
Enterprise, and Living Cities indicated that private funding and 
lending have increased since HUD's involvement. In addition, Enterprise 
officials indicated that the private sector believes that federal 
funding provides an incentive to work in areas and projects that would 
be less likely to receive funding without federal involvement. HFHI 
officials said that federal funding is imperative because it is the 
only way for all-volunteer organizations to transition into staff-
managed, volunteer-based organizations. YBUSA officials said that 
federal funding, especially funding that leverages private funding, has 
enabled YBUSA to be proactive in assisting Native American and rural 
programs.

NCDI lenders and funders indicated that Section 4 funding had both a 
psychological and a real impact on private sector involvement in the 
initiative. For example, one senior executive from a major lending 
institution indicated that federal participation in NCDI provided 
funders with a symbolic and financial incentive to join the NCDI 
consortium. Symbolically, federal funding provides a sense of 
credibility to NCDI, as funders see federal participation as a sign of 
good housekeeping and reduced risk. Financially, federal participation 
adds more money to NCDI capacity-building initiatives, in turn enabling 
subrecipients to raise more private funding. Another lender said that 
HUD's participation in a CDC through Section 4 funding served as an 
indication of good management and internal controls. An insurance 
company also noted that Section 4 funding showed that the federal 
government was strongly committed to a coordinated effort to build CDC 
capacity, and a foundation told us that the federal presence 
legitimized NCDI as the CDC capacity-building vehicle with the greatest 
payoff. Furthermore, nearly all of the YBUSA and HFHI private funders 
that we interviewed said that federal funding was an incentive for 
their participation in the program. For example, one funder said that 
federal support was like a "seal of approval." Another funder said that 
Section 4 funding created a positive incentive because the availability 
of invaluable hard-to-get federal funding increased the viability of 
any project.

Most funders and lenders that provide funding directly to CDCs and 
affiliates stressed that federal funding was beneficial, but some of 
those local funders were not aware that subrecipients received Section 
4 funds. Some LISC and Enterprise subrecipient funders explained that 
federal funding and diverse funding streams were characteristics of a 
viable organization. One funder suggested that public funding was 
critical, since private philanthropy could only do so much. Another 
foundation indicated that it looked to organizations that had a 
diversified funding structure, since it could not provide sole support 
for an organization.

The four funders we spoke with that provided funding directly to the 
YouthBuild Boston affiliate were split on whether federal participation 
was an incentive to their involvement. Two said that federal 
participation was an incentive; while the other two said their decision 
to provide funding was based solely on the affiliate's mission.

Officials from most of the five organizations we spoke with that 
provided funding to an HFHI affiliate in Rhode Island indicated that 
federal participation was not an incentive, but two said that having 
other sources of funding encouraged them to participate. An official 
from one organization indicated that while federal funding indirectly 
provides an incentive for participation, the organization provided 
funding primarily based on the affiliate's reputation and mission.

Cost Sharing Requirements Are Specified in Law and Grantee Policies:

Section 4 funding calls for significant private sector participation in 
community development initiatives because Section 4 requires that 
grantees match each dollar awarded with three dollars in cash or in-
kind contributions from private sources. Matching funds are raised 
nationally and locally and come from nongovernmental sources including 
private foundations, corporations, banks, and individual donors. Each 
grantee has its own matching policy and procedures for complying with 
the matching requirement.

LISC and Enterprise generally meet their matching requirement at the 
national level but encourage CDCs to seek private contributions to aid 
in the match. However, LISC requires subrecipients in rural areas to 
raise at least $1 for each $1 they receive; the remainder of the match 
is raised nationally. Conversely, HFHI and YBUSA require their 
affiliates to raise at least $3 for every dollar of Section 4 funding 
they receive. While both HFHI and YBUSA impose this requirement on all 
of their affiliates, including those in rural and tribal areas, if 
YBUSA rural and tribal affiliates cannot raise the 3 to 1 match, the 
national organization will provide the difference. Officials from the 
four grantees told us that raising the private matching funds had not 
been a problem. For example, for the 1997 grant HFHI and its 60 
affiliates that received Section 4 funding raised almost $155.6 million 
in private contributions. YBUSA and its affiliates raised $26.6 million 
in private contributions to match its $7.6 million grant.

Grantees Have Raised Significant Amounts of Private Sector Funding and 
Other Resources:

Since the four grantees became eligible for Section 4 funding, they 
have raised nearly $800 million from the private sector in matching 
funds and other cash and in-kind contributions. However, we could not 
demonstrate empirically that Section 4 funding influenced the grantees' 
fund-raising owing to external factors such as economic trends and 
private sector interests. Between 1994 and 2001, LISC and Enterprise 
raised $457 million, and from 1997 to 2002, HFHI and YBUSA raised $341 
million (see table 4).

Table 4: Private Sector Funding:

Dollars in millions.

LISC; Dollars in millions: Private sector funding: $319.9[A]; 
Time period: 1994-2001.

Enterprise; Dollars in millions: Private sector funding: 136.7; 
Time period: 1994-2001.

YouthBuild USA; Dollars in millions: Private sector funding: 26.6[B]; 
Time period: 1997-2001.

HFHI; Dollars in millions: Private sector funding: 314.5; Time 
period: 1998-2002.

Total; Dollars in millions: Private sector funding: $797.7; 

Source: LISC, Enterprise, YBUSA, and HFHI.

[A] LISC private sector grants for 1994 and 1995 contain government 
funding due to different accounting practices at that time.

[B] This number only includes YBUSA's matching funds and not all 
private sector funding.

[End of table]

In addition to providing funding, the private sector has contributed 
in-kind services to CDCs, including managerial skills, mentoring, and 
volunteer labor. For example, representatives from the private sector 
serve on LISC's local advisory boards to help local program offices 
make funding decisions and are members of operating support 
collaboratives in several cities. HFHI's local affiliates use 
volunteers for office and construction work and for their boards of 
directors.

HUD's Grantee Monitoring and Oversight Is Limited:

HUD monitoring is limited to desk reviews of the grantees' compliance 
with their grant agreements. In general, the grant agreements require 
several kinds of reporting information including work plans, semiannual 
or quarterly financial status reports, requests for grant payment 
vouchers, and final reports. However, HUD's involvement in reviewing 
grantee work plans differs for NCDI and non-NCDI activities. Since HUD 
does not directly monitor the subrecipients' capacity-building 
activities, it relies on the grantees to monitor and oversee them. The 
grantees have several mechanisms in place to ensure that subrecipients 
are complying with their individual grant agreements. However, in a 
subset of files we reviewed, we found that a grantee had funded an 
ineligible activity for one subrecipient. Also, HUD does not have 
specific impact measures in place for Section 4.

HUD Monitors Grantees but Not Subrecipients:

HUD's efforts to monitor the grantees include desk reviews of work 
plans, annual performance reports, semiannual financial status reports, 
requests for grant payment vouchers, and final performance reports. 
According to HUD, the four grantees sign grant agreements that obligate 
them to comply with HUD and OMB requirements. For example, grantees 
must submit work plans that identify when and how federal funds and 
nonfederal matching resources will be used and present performance 
goals and objectives in enough detail to allow for HUD monitoring. In 
addition, the grant agreements require grantees to submit annual 
reports showing actual progress made in relation to the work plans, 
plus semiannual financial status reports that show private sector 
matches and grant expenditures to a certain date. Grantees are not 
permitted to begin activities or to draw down funds until HUD approves 
the work plans. Furthermore, the grant provisions require that in order 
to receive payment, grantees must submit a payment voucher with 
supporting invoices that provide enough information to allow HUD to 
determine whether the costs are reasonable in relation to the work 
plan's objectives. Finally, the grant agreement stipulates that within 
90 days of completing the grant award, the grantee must submit a final 
report summarizing all the activities conducted under the award 
including any significant program achievements and problems reasons for 
the program's success or failure.

HUD officials told us that staffing constraints caused the agency to 
focus mostly on grantee work plans and payment vouchers. HUD reviews 
how:

the grantees select subrecipients, set benchmarks, and plan to build 
capacity. HUD uses different processes to review NCDI and non-NCDI work 
plans. As an equal player, HUD reviews NCDI's work plans together with 
other funders and meets twice a year to discuss NCDI initiatives and 
goals for each city. However, HUD reviews and approves non-NCDI work 
plans by itself. A HUD official told us that HUD staff focus most of 
their attention on the funding aspects of the work plans. HUD officials 
told us that they check the semiannual financial status reports and 
accompanying narratives to determine whether the expended amounts are 
in line with the amounts stated in the work plans.

Section 4 grant funds are provided to grantees after costs are 
incurred, so grantees must periodically submit vouchers and supporting 
documentation that detail expenditures by city or project in order to 
receive payment. HUD staff review the vouchers and supporting 
documentation to ensure that funds are used for the eligible activities 
stated in the work plans and that expenditures such as travel and 
indirect costs are within HUD guidelines and do not exceed available 
funding. HUD has denied payments for activities not contained in 
approved work plans or not supported by the required documentation. For 
example, in March 2003, HUD withheld over $650,000 in Section 4 funding 
because one grantee did not submit a final report, several financial 
reports, a work plan, and two annual plans. In June 2003, however, the 
grantee provided the necessary documents and HUD released the funds.

In addition, grantees must submit financial status reports that show 
whether the organizations are meeting their matching requirements. 
However, HUD relies on the grantees to ensure that they and their 
subrecipients are matching funds correctly. Both LISC and Enterprise 
have a formal matching policy. LISC's policy explicitly states that 
counting the same funds as matching funds under more than one program 
is prohibited and requires its subrecipients to identify the sources 
and amounts of matching funding they have received twice a year. 
Enterprise's matching requirements are tracked on an ongoing basis and 
are certified by an Enterprise official. YBUSA requires its affiliates 
to submit documentation that supports the sources and amounts of 
matching funds committed before it will release Section 4 funding, and 
HFHI requires affiliates to report matching funds data quarterly.

HUD Relies on Grantees to Monitor Subrecipients:

HUD does not directly monitor subrecipients' and affiliates' capacity-
building activities but instead relies on the grantees for monitoring 
and oversight. Like HUD, grantees initiate grant agreements with their 
subrecipients and affiliates. These grant agreements generally include 
such things as the purpose of the grant, grant amount, time frame, 
disbursement conditions, causes for suspension and termination, 
restrictions on use of grant funds, and reporting and accounting 
requirements that describe how the grantee will monitor the grant. The 
grantees use the grant agreements as the basis for monitoring their 
subrecipients' performance.

The grantees use several mechanisms to ensure that subrecipients are 
complying with their grant agreements. For example, LISC and Enterprise 
officials indicated that throughout the grant period, local offices 
communicate with their subrecipients by telephone or email or in person 
in order to follow their progress. Similarly, YBUSA staff told us that 
they monitor affiliates by telephone as well as through on-site 
technical assistance. LISC, Enterprise, and YBUSA require each 
subrecipient to submit a monthly activity report, semiannual project 
reports and narratives, and final reports. However, the grantees have 
different procedures, forms, and checklists that guide their monitoring 
activities.

Operating support collaboratives aid LISC and Enterprise in their 
oversight through proposal reviews, organizational assessments, work 
plan reviews, on-site reviews, quarterly report reviews, and annual and 
3-year evaluations. The LISC and Enterprise local offices use the 
collaboratives' monitoring information when making their Section 4 
funding decisions.[Footnote 14]

HFHI and its regional office personnel evaluate all affiliates every 3 
years based on a "Standards of Excellence" program. The program has 
three elements: best practices, acceptable practices, and minimum 
standards. According to HFHI officials, continued failure to meet 
minimum standards will lead to probationary status and eventually 
disaffiliation. The program provides clear guidelines for affiliate 
self-assessments and HFHI evaluations as well as a systematic process 
for ensuring that Habitat affiliates are complying with the 
organization's basic principles. If HFHI national or regional staff are 
aware of illegal activities or violations of HFHI's minimum standards, 
immediate action can be taken to correct the problem. The evaluation 
covers internal controls and audits. All affiliates with an annual 
income of $250,000 or more, assets of $500,000 or more, or both are 
required to have an independent annual audit. Affiliates are also 
requested to submit their annual report to HFHI.

Even with Comprehensive Controls, Problems May Still Occur:

While the grantees appear to have comprehensive processes to monitor 
and control their subrecipients, our review of seven subrecipients' 
grant files identified a subrecipient that suffered from organizational 
and financial problems that eventually led to its demise. This 
subrecipient was the grantee's second-largest in terms of Section 4 
funding, receiving 10 grants that totaled almost $1 million over a 7-
year period. One grant for $143,000 paid for several activities, one of 
which was a bad debt--an ineligible expenditure according to OMB 
Circular A-122. Since HUD officials do not receive and review 
subrecipient grant agreements and payment vouchers, HUD was not aware 
of the ineligible cost. The grantee has since taken several steps to 
ensure that similar problems do not occur, including having a staff 
member perform increased subrecipient monitoring to verify that 
sufficient management controls are in place to ensure that grant funds 
are used appropriately and effectively. This monitoring includes a full 
review of the grant request and award documents, followed by a review 
of supporting documentation to verify compliance with allowable 
expenses and consistency with the work plan. In addition, site visits 
are made to subrecipients that have received large amounts of funding 
and a "watch report" is maintained to track all subrecipients that are 
late in responding to requests for information.

HUD Does Not Measure the Impact of Section 4 Funding:

HUD has not measured the impact of Section 4 funding on improving the 
capacity of its grantees and subrecipients. However, HUD requires its 
grantees to submit annual work plans that include specific details of 
how federal and private resources will be used and to identify 
performance goals and objectives that should be attained during the 
grant period. In addition, OMB is currently requiring HUD and the NCDI 
grantees to conduct a PART review. PART assessments are used for making 
budgeting decisions, supporting management, identifying design 
problems, and promoting performance measurement and accountability. The 
assessment includes questions on a program's purpose and design, 
strategic planning, management, and results. Furthermore, in response 
to a GAO report recommendation that HUD require program offices to 
determine the practicability of measuring the impact of technical 
assistance and establishing objective, quantifiable, and measurable 
performance goals, HUD is working with a group of national technical 
assistance providers to develop a framework to assess the effectiveness 
of its technical assistance programs. [Footnote 15]

Living Cities has also contracted with a consultant to develop impact 
measurements for the 23 NCDI cities. Other evaluations[Footnote 16] 
have resulted in measures that gauge the capacity-building system in 
NCDI cities and categorize organizational capabilities into five 
different stages of growth--initiation, demonstration, 
professionalization, instutionalization, and maturation.[Footnote 17]

Conclusions:

While Section 4 funds must be used for capacity-building initiatives, 
grantees are afforded a great deal of discretion as to how they 
administer, use, and oversee these funds. HUD is responsible for 
ensuring that grantees are utilizing Section 4 funds according to 
federal law and regulations and has several controls in place to ensure 
that they do. However, HUD relies primarily on its grantees to make 
certain that this responsibility is carried out at the subrecipient 
level. We found that grantees generally had good management systems and 
controls in place to monitor their subrecipients and to ensure that 
they carried out their work plans, met their objectives, and used 
federal funds legally and responsibly. However, even with good 
controls, problems can still occur, as we found at one CDC. While HUD 
has overarching responsibility for detecting such internal control 
failures, the cost-effectiveness of adding additional federal controls 
at the subrecipient level must be weighed against the size of the 
program and the amount of federal funding involved. Given the relative 
size of the Section 4 program and the fact that similar problems should 
not recur if HUD and the grantees remain vigilant, we do not believe 
that additional controls are necessary at this time.

Recommendation for Executive Action:

We recommend that the Secretary of HUD take steps to recover the grant 
funds that one Section 4 grantee used to cover a bad debt.

Agency Comments:

In an e-mail dated August 7, 2003, HUD provided technical comments, 
which we incorporated into this report as appropriate.

Scope and Methodology:

To accomplish our objectives, we reviewed public laws, federal 
regulations, HUD directives, budget documents and other material that 
described the Section 4 program, grantees' missions and organizational 
structures, and authorized and appropriated funding. To determine how 
Section 4 funding has evolved and expanded over the years and how 
grantees use Section 4 funding, we interviewed HUD, Living Cities, 
LISC, Enterprise, YBUSA, and HFHI officials in national, local, and 
rural offices, and subrecipients in Americus, GA; Baltimore, MD; 
Boston, MA; Cleveland, OH; Frederick, MD; Hughesville, MD; Kingston, 
RI; and Washington, D.C. We collected data from LISC, Enterprise, and 
YouthBuild USA showing the number of multiple grants and amounts 
provided to CDCs or affiliates. We selected five CDCs/affiliates from 
three grantees. For LISC and Enterprise, we chose the CDCs that had 
received the greatest number of grants and analyzed the purpose of each 
grant. For YBUSA, we selected the affiliates that had received the 
highest dollar amounts.[Footnote 18] To create the maps of 
subrecipients and cities that received Section 4 funding, we obtained 
city data from NCDI, LISC, Enterprise, YBUSA, HFHI, and CHAPA and used 
geographical information software (GIS) to create the maps. We used the 
same software to create the rural county maps with data obtained from 
LISC and Enterprise that listed each CDC categorized as rural and the 
counties they served.

To determine the importance of Section 4 funding to private sector 
involvement in community development initiatives, we reviewed public 
laws, federal regulations, HUD directives, budget documents, and other 
materials. We obtained 1994 through 2001 private contribution data from 
LISC and Enterprise and 1997 through 2001 data from YBUSA and HFHI. We 
obtained matching policy information from HUD and the grantees and 
interviewed private funders that had provided either grants or loans to 
each of the grantees and subrecipients we visited in Boston, MA; 
Baltimore, MD; Frederick, MD; and Kingston, RI. We based our selections 
on the subrecipients' proximity to our offices in Washington D.C., and 
Boston, MA, and the amount of Section 4 funding they received.

To determine how HUD and Section 4 grantees controlled the management 
and measured the impact of Section 4 programs, we reviewed and analyzed 
HUD and grantee criteria, processes and procedures for monitoring, 
controlling, and measuring performance and tested grantee monitoring 
and control procedures at seven subrecipients. In addition, we reviewed 
reports prepared by Living Cities and the Urban Institute that 
discussed NCDI's history and accomplishments.

We conducted our work from September 2002 through April 2003 in 
accordance with generally accepted government auditing standards.

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution of this report 
until 30 days from the report date. At that time we will provide copies 
of this report to the Chairman and Ranking Minority Members, Senate 
Committee on Banking, Housing, and Urban Affairs; the Chairman and 
Ranking Minority Member, House Committee on Financial Services; and the 
Ranking Minority Members of its Subcommittees on Oversight and 
Investigations and Housing and Community Opportunity. We will also send 
copies to the Secretary of Housing and Urban Development and the 
Director of the Office of Management and Budget. In addition, the 
report will be available at no charge on GAO's Web site at http//
:www.gao.gov.

Please contact me at (202) 512-8678 if you have any questions about 
this report. Key contacts and contributors are listed in appendix I.

Thomas J. McCool
Managing Director, Financial Markets and Community Investment:

Signed by Thomas J. McCool: 

[End of section]

Appendix I: Contact and Staff Acknowledgments:

GAO Contact:

Andy Finkel (202) 512-6765:

Acknowledgments:

In addition, Emily Chalmers, Nadine Garrick, Diana Gilman, John 
McGrail, John Mingus, Frank J. Minore, and Marc Molino made key 
contributions to this report.

FOOTNOTES

[1] Capacity building can generally be defined as strengthening the 
capabilities of program recipients or providers--typically housing or 
community development organizations--to build institutional knowledge 
within those organizations. Among other things, capacity-building 
assistance can include funding for training, hiring staff, purchasing 
software, obtaining expertise from outside sources, and developing 
accounting systems and strategic plans. Technical assistance can 
generally be defined as training designed to improve performance or 
management. Congress and HUD sometimes use the terms interchangeably. 

[2] Community development corporations are neighborhood-based nonprofit 
organizations that are involved in initiatives that focus on improving 
the economic, social, and physical condition of their communities.

[3] Affiliates are independent, locally run nonprofit organizations 
joined to national organizations by an agreement. HFHI affiliates agree 
to build low-income housing, while YBUSA affiliates agree to provide 
job training, education, counseling, and leadership development 
opportunities through the construction and rehabilitation of affordable 
housing.

[4] Federal regulation 24 CFR 84.23 specifies what constitutes a 
matching contribution and how it is counted and reported. These 
contributions cannot be included to meet the matching requirements of 
any other federally assisted program and cannot be paid by the federal 
government under another award. 

[5] OMB Circular A-122 indicates that, among other things, bad debts 
are ineligible for federal funding.

[6] PART is a series of questions designed to provide a consistent 
approach to rating programs across the federal government.

[7] Prior to becoming Living Cities, NCDI was a virtual organization 
handled by consultants. NCDI did not have staff or occupy office space. 
Living Cities now has staff and oversees NCDI's operations.

[8] Under the Housing and Community Development Act of 1992, "Hope for 
Youth: Youthbuild," HUD awarded Youthbuild programs grants and 
contracts totaling $403 million for fiscal years 1993 to 2002. In 
addition to capacity-building funds, YBUSA has received funds from HUD 
to provide technical assistance to Youthbuild program recipients. 

[9] None of the grantees distinguish between rural and tribal programs.

[10] NCDI's goals coincided with HUD's program goals in the Community 
Development Block Grant Program and the Home Investment Partnerships 
Program (HOME). Both programs emphasize the use of neighborhood-based, 
nonprofit community development organizations to provide affordable 
housing and economic development in low-income neighborhoods. 

[11] Section 4 grants cover a 4-year period. We are only providing 
information on the FY 1997 grant for HFHI and YBUSA because it was the 
only grant that had been completed at the time of our review. 

[12] For its rural and tribal programs, YBUSA generally follows the 
Rural Housing Service's requirement that most households receiving 
assistance be located in rural communities with fewer than 20,000 
residents. HFHI classifies rural counties as those with fewer than 
100,000 residents and rural cities as those with no more than 25,000 
residents. LISC defines rural counties as those having no cities with 
50,000 or more residents. Enterprise considers communities rural if 
they have fewer than 50,000 residents.

[13] The Housing Assistance Council is a national nonprofit corporation 
created to increase the availability of decent and affordable housing 
for rural low-income people.

[14] The operating support collaboratives vary by city. The one in 
Cleveland, for example, distributes money competitively each year, 
while the one in Washington, D.C., has a 3-year funding cycle. They may 
be run by an independent nonprofit organization or as an entity of 
Enterprise or LISC. In some instances, subrecipients that received 
funds from the operating support collaboratives also received Section 4 
grants directly from Enterprise or LISC.

[15] U.S. General Accounting Office, HUD MANAGEMENT: Impact Measurement 
Needed for Technical Assistance, GAO-03-12 (Washington, D.C.: Oct. 25, 
2002).

[16] Christopher Walker and Mark Weinheimer, "Community Development in 
the 1990s" (Washington, D.C.: The Urban Institute, September 1998); and 
Weinheimer and Associates, "HUD Section 4: Building the Capacity of 
CDCs," (Washington, D.C.: Assessment Report, June 2001).

[17] Initiation refers to the first stage of growth, when a civic or 
church group forms to provide a social service or advocate on an issue. 
The group lacks staff or at least lacks staff trained in development. 
Demonstration occurs when an existing group assumes an initial program 
in community development. The new CDC lacks staff and relies on 
volunteers. In the third stage, professionalization, the CDC takes on 
larger projects (20-30 units) or builds several homes and is able to 
secure funds for staff and more projects. When a CDC reaches the fourth 
stage, institutionalization, the staff has developed expertise and taps 
into public and private sources of support that is enabling it to do 
one large project after another. A CDC has reached maturation when it 
can maintain a consistent level of staff expertise, manage multiple 
projects simultaneously, and move into new programs that meet community 
needs.

[18] The criteria differed for YBUSA because of the shorter grant time 
frame. Habitat for Humanity was not included in this analysis because 
it does not allow affiliates to receive multiple grants in any Section 
4 grant cycle. 

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