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FY 1999 Annual Performance PlanValidation and Verification
HUD needs to achieve better system integration. Too often, the
data used by the Department has been suspect or our systems inadequate
to generate the proper level of reporting and information. In
part, these problems are addressed through the Financial Systems
Integration project. This project is discussed in detail in the
Means and Strategies section. Also, the Department is making
significant progress by strengthening, improving and integrating
many of its program systems.
Following are analyses of the individual program areas. Community Planning and Development
The Integrated Disbursement and Information System (IDIS) consolidates
planning and reporting processes across four CPD formula grant
programs: Community Development Block Grant (CDBG), HOME Investment
Partnerships (HOME), Emergency Shelter Grants (ESG), and Housing
Opportunities for Persons with AIDS (HOPWA). The grantees, State
and local governments, use an integrated system for consolidated
planning, project description, disbursement, and accomplishment
reporting. Reporting occurs as accomplishments are attained,
reducing the burden of end-of-year reports.
When an activity or project is complete, grantees update the
database and report on accomplishments achieved for that activity.
Annually, the grantee will also electronically report on all
accomplishments to date for each activity or project not yet complete.
With a goal of paperless reporting, IDIS permits HUD and the
community to produce reports of on-going projects, activities,
accomplishments, and expenditures tied to those projects - at
any time. These reports constitute a significant part of the
CPD annual performance report requirements on activities, and
will become valuable tools in local decision-making processes.
In conjunction with IDIS, the Grants Management Process (GMP)
System unites CPD's core activities, including grantee consultation,
timely processing of grant awards, oversight of grantee compliance
with regulatory and statutory requirements, performance evaluation,
and technical assistance.
Testing of Baseline Data Sources
A number of reporting sources currently exist in the IDIS and
GMP that will be analyzed to verify and validate grantee performance.
Within IDIS, the following reporting functions document grantee
activity and performance using CDBG, ESG, HOME, and HOPWA funds:
Summary of Activities Report, the Summary of Accomplishments
Report, Summary of Community Development Accomplishments (CDBG
Expenditures by Priority Needs Category), and the Consolidated
Plan Annual Evaluation Report (comparing accomplishments to benchmarks
established in the Consolidated Plan). As part of GMP, grantee
performance is self-evaluated by the Consolidated Annual Performance
and Evaluation Report (CAPER). Field staff assess grantee performance
throughout the program year, documenting strengths and weaknesses
in the GMP system. Such ongoing reviews culminate in the Annual
Community Assessment (ACA) and Program Year Letter, officially
documenting the Department's conclusions regarding a grantee's
performance (in conformance with Title I of the National Affordable
Housing Act and the Housing and Community Development Act of 1974).
Testing these data will include ongoing reviews of IDIS and GMP.
IDIS data will be sampled to determine accuracy, completeness,
and timeliness. Reviews of actual performance data for reporting
periods will include comparing projected targets for the program
year against actual accomplishment data; comparing performance
of other jurisdictions; benchmarking performance against superior
performers; and , ensuring the data agrees with data from other
sources (including evaluation modules within the GMP System).
Analyses of program performance information shall show the extent
to which grantees are meeting statutory and regulatory objectives
of the programs (including costs, services delivered and beneficiaries)
and performance data requirements as specified by IDIS. Public and Indian Housing
As outlined in their FY 1997 Quality Assurance Plan, PIH's monitoring
capabilities are enhanced through the use of the "Performance
Measure Indicators" reports module of the office's Integrated
Business System (IBS). In addition, the Multifamily Tenant Characteristics
System provides valuable information to PIH and other entities
through the extraction of data from the system. Through the use
of both systems, PIH manager's are able to monitor the status
of performance measures.
PIH has not experienced any problems with the current systems;
however, because new performance measure goals have been established,
it will be necessary to modify some of the existing databases.
In addition, PIH is in the process of seeking additional funding
to develop systems to support the new FY99 performance measure
goals established to implement the Native American Housing Assistance
and Self-Determination Act (NAHASDA).
As part of the Quality Assurance Plan to implement the verification/validation
process, PIH has included in its FY 1999 budget submission funding
to utilize the Performance Measure Indefinite Quantity Contracts
procured by the Office of Policy Development and Research.
Public Housing Management Assessment Program (PHMAP)
The Department is developing a revised performance evaluation
system that will expand and improve on the current PHMAP by evaluating
public housing authorities' (PHAs) performance in four areas:
physical conditions, financial stability, management, and customer
service. The new system will answer previous criticisms of PHMAP
by placing greater emphasis on: physical conditions of properties,
objective evidence and third party verification, basic real estate
functions, and input from those served directly by the system
(the "customers"). The result of this effort should
be the increased confidence of everyone concerned -- HUD, PHAs,
residents, Congress, the public -- that it accurately determines
whether PHAs are doing an acceptable or outstanding job and are
providing acceptable basic housing conditions. This is critical
because the consequences of that determination are substantial
-- less scrutiny and additional flexibility for PHAs to be determined
performing well, and intensive technical assistance and short
time deadlines to improve or avoid losing management control for
PHAs to be determined troubled. The new system should better
indicate to everyone the degree of success of the public housing
program under current funding levels.
This revised PHMAP is currently being developed with the benefit
of consultation with public housing authority representatives,
representatives of public housing resident groups and others such
as housing advocacy groups and local government representatives.
The new PHMAP system will be issued as a proposed rule and, like
any other proposed rule, subjected to the public comment process.
While the rulemaking process proceeds, the new aspects of the
system (notably, the independent physical inspection and customer
survey) will be refined and tested. Exact implementation schedules
will depend upon progress on these tasks, and the final proposal
will take into account both that further refinement and testing
and the further public comments and consultations.
Section 8 Management Assessment Program (SEMAP)
The Department is currently developing SEMAP in order to objectively
measure public housing agency (HA) performance in key Section
8 tenantbased assistance program areas. SEMAP will enable
HUD to ensure program integrity and accountability by identifying
HA management capabilities and deficiencies and by improving risk
assessment to effectively target monitoring and program assistance.
HAs could also use SEMAP performance analysis to assess their
own program operations.
The Department is developing a final rule based on comments received
on its proposed rule. This final rule is expected to be issued
during FY 1998. It will commence in FY 1999 and baseline data
for performance measurement will be available in FY 2000.
The use of SEMAP will enable the Department to improve its risk
assessment and to target effectively monitoring and program assistance
to housing agencies (HAs), in key Section 8 tenantbased
assistance program areas, that need the most improvement and that
pose the greatest risk.
It is proposed that SEMAP will have 15 indicators to assess the
HAs performance; the annual HA SEMAP certification and HUD review
process; HUD scoring procedures and procedures for designating
high, standard and troubled performers; and corrective action
plans and strategies for improving performance.
SEMAP will enable HUD to ensure program integrity and accountability
by identifying HA management capabilities and deficiencies and
by improving risk assessment to effectively target monitoring
and program assistance. HAs could use the SEMAP performance analysis
to assess their own program operations. Fair Housing and Equal Opportunity
FHEO utilizes several data sources, including HMDA, GSE, MTCS,
RACS, TEAPOTS, IDIS and others. For those measures listed below
where current data is not available, development of the new system
will be part of their system integration plan. All new systems
will be in line with the required systems development procedures
and in compliance with the Department's system integration plans
and policies. Their FY 1997 Quality Assurance Plan is available
on request. Housing
Housing has analyzed their data sources according to its major
program activities.
Single Family
This system provides support for production, rehabilitation and
financing of low-cost housing to homebuyers through sales of HUD-owned
mortgages.
Production [Source of Data: F17 - CHUMS (In-Place)] In terms of processing, the objective is to have an accurate reflection of HUD's customer service commitment to mortgagees through:
The system, which includes a validation process, is relied upon
for tracking of the process. It automatically tracks and reports
numbers processed and forms the basis for reporting. Field processing
is being consolidated into 4 processing centers in FY98.
For First Time Homebuyers, the system identifies endorsement
of first time homebuyers. System automatically tracks and reports
numbers processed. CHUMS report forms basis for reporting. Validation
process occurs. Field processing is being consolidated into 4
processing centers in FY98.
The CHUMS system also identifies endorsement of 203(k) loans.
Manual adjustment is made for investor loans and the system automatically
tracks and reports numbers processed. Validation process occurs.
Real Estate Owned (REO) - Sales Performance [Source of
Data: A80 - SAMS (In-Place)]
SAMS is updated and generates reports identifying categories
of properties sold for reporting in Commissioner's monthly executive
reports. Current validations by staff is considered adequate.
Executive report cross-checks data reported to accounting against
sales data reported by field.
Local Goals, including 203(k) Production, Energy Efficient
Mortgages (EEMs), REO Inventories, Post Technical Reviews (PTR),
Insurance Production (endorsements), and Appraisal Activity. [Sources
of Data: F17 - CHUMS and A80 - SAMS (In-Place) Lenders/Field Offices enter data into CHUMS, which passes the data to IACS System. Reports are generated weekly, monthly and quarterly and delivered to program offices, operations, and field offices. Reconciliation occurs between the servicing mortgagees and FNMA. Field Office has responsibility of validating data integrity. CHUMS produces reports to the field and headquarters. The data integrity validations are handled by the field. Field office and lender enter data into CHUMS. Weekly, monthly and quarterly reports are generated from CHUMS and distributed to field and headquarters.
Multifamily (MF)
MF Branch maintains PC-based system which is updated daily.
System has edits that kick out any invalid data. No endorsement
processing occurs without the official receipt. Validation process
occurs through interaction among Field, OGC, Accounting Control
Division and headquarters MF program offices. Weekly and Annual
reconciliations occur between FOMNS & F47. 202/811 processing
is handled using the HUD-290 procedures. Initial data entry in
PAS by field. Field offices send in the 290s to MF Headquarters
program office for reporting & validating monthly loan closings.
OFA provides 202 reports to field and 811 reports only upon request.
Action Required: Reconciliation is needed between OFA
reporting and Program office to ensure data integrity.
Asset Management [Source of Data: F49 - MARS (In-Place)]
This system provides support for problems in existing MF portfolio
through sale of mortgage notes.
Resolution of problems in the MF portfolio and expand housing
available to low-income renters. [Existing Source of Data:
Manual System (in place); Planned Source of Data: RAMS (To be
determined during FY98)]
Originally, MF had planned to use the MF Data Warehouse to identify
and track progress of troubled projects. However, there have
been some data problems and the data warehouse cannot be used
at this time. Overall, MF has been enhancing the quality of their
data for quarterly reporting, is looking for ways to better manage
the MF data, and is manually tracking the process and progress
being made on this goal. Field offices report accomplishments
directly to headquarters program office monthly. MF tentatively
plans to use the RAMS system for reporting data and for validation
efforts. See FY98 Quality Assurance Plan.
Property Disposition [Source of Data: F46 - PMS (In-Place)]
The HUD-1 is prepared by closing attorney. MIAS receives HUD-1
confirmation. Field Office enters data into PMS. Closing is not
recognized until MIAS receives the HUD-1. System reports can
be retrieved by headquarters and field. Data integrity is verified
by the PMS contractor and MIAS.
Resolution of data problems in the existing MF portfolio through
validation [Sources of Data: TRACS, FOMNS, PAS (In Place)]
MF pulls extracts from TRACS for each field office. Geo-coding
takes place. Project addresses and identifiers not geo-coded
are returned to the field for verification. This process can occur
as many times as needed to reach 100% accuracy. Validation occurs
directly with the field office and is done on a weekly basis.
Neighborhood Network Centers [Source of Data: PC Based
System Maintained by Aspen Systems (In-Place)] Validation occurs and existing process is adequate for reporting purposes.
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Content Archived: November 29, 2011 | |
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