This week, HUD’s Office of Inspector General (OIG) issued a report critical of HUD’s oversight of the community service and economic self-sufficiency requirement (CSSR). This federal requirement, applicable only to public housing residents, generally requires unemployed, non-elderly, non-disabled residents to perform community service or participate in an economic self-sufficiency program for a minimum of 8 hours monthly. Housing authorities are responsible for annually reviewing and verifying via third party documentation the CSSR compliance of each non-exempt family.
Based on its review of a statistical sample of 80 households nationwide, the OIG report identified certain errors by housing authorities in implementation or reporting into HUD’s systems. The OIG criticized HUD’s oversight of the program, since HUD did not catch the errors. The OIG estimated that, extrapolated nationally, its findings with respect to its 80 household sample would result in 201,000 tenants whose CSSR status was improperly reported and 106,000 units occupied by non-compliant tenants. The OIG then concluded, based on its estimates, that HUD paid more than $37 million in improper operating subsidy payments each month, or more than $448 million annually. This extrapolation tactic by OIG, which significantly inflates the impact of its findings, is common in HUD OIG audits, the accuracy of such sweeping conclusions based on such a small sample size seems quesionable. The OIG’s focus on the CSSR, however, means that housing authorities may need to more closely scrutinize their CSSR enforcement.
The OIG report, perhaps inadvertently, supports critics of the CSSR. Housing authorities already spend significant staff time and other resources to enforce CSSR. If the OIG report is correct, these resources are inadequate, given the errors the OIG found in program reporting and oversight. The significant resources dedicated by housing authorities and HUD to properly ensure that some public housing tenants spend only 8 hours each month engaging in certain activities could certainly be put to better use. Eight hours of monthly activity is likely inadequate to actually promote work or self-sufficiency. With public housing funded so significantly below known need, the money spent to enforce this requirement could be more effectively used to support resident services or to maintain housing for residents.
HUD has proposed to streamline the CSSR by allowing tenants to self-certify their compliance; however, this would not address the OIG’s concerns about oversight. Only Congress can fully eliminate the CSSR and allow housing authorities and HUD to better invest their limited resources in serving their tenants.